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| number = ML062280051
| number = ML062280051
| issue date = 08/18/2006
| issue date = 08/18/2006
| title = 2006/08/18-Oyster Creek License Renewal Audit and Review Report for Plant Aging Management Reviews and Programs, Revision 1
| title = License Renewal Audit and Review Report for Plant Aging Management Reviews and Programs, Revision 1
| author name =  
| author name =  
| author affiliation = Brookhaven National Lab (BNL)
| author affiliation = Brookhaven National Lab (BNL)
Line 19: Line 19:


=Text=
=Text=
{{#Wiki_filter:Aud it and Rev iew Report for Plant A ging Ma nageme nt Rev iews and P rogram s Oyster Creek Generating Stati on (OCGS)Docket No.:
{{#Wiki_filter:}}
50-219 Aug ust 18, 2006 Revision 1 Technical S upport Prov ided and Rep ort Compiled by Brookhave n National Lab oratory Upton, New York Contract No. J CN J-3168, T ask Order 4 Report Prepare d for License Rene wal Branch C Division of License Rene wal Office of Nuclear R eactor Regulatio n U.S. Nuclear R egulatory Commission Washington, D.C.
20555-0001 i Table of Conte nts Page #1.Introduction an d General Information
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........1 1.1 Introduction
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..1 1.2 Background
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..1 2.Audit and R eview Scope..........
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........2 3.Aging M anageme nt Rev iew Audi t and R evie w Re sults..........
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.....5 3.0 OCGS's Use o f the Gen eric A ging Les sons-L earned Repor t..........
.....5 3.0.1 Format of the OCGS Li cense Renew al Appli cation..........
......5 3.0.1.1 Overview of OCGS LRA Table 1..........
.........7 3.0.1.2 Overview of OCGS LRA Table 2..........
.........7 3.0.2 Audit and R eview Process..........
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.....9 3.0.2.1 Review of the OCGS AMPs
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...9 3.0.2.2 Revi ew o f the OCGS AMR Resul ts..........
.......9 3.0.2.3 NRC-A pprov ed Pre ceden ts..........
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..10 3.0.2.4 Updated Fin al Safety An alysis Review Supplement
...10 3.0.2.5 Documentation and Documents Review ed..........
10 3.0.2.6 Commitments To Be Inc luded in the Safety Ev aluation Report..........
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........11 3.0.2.7 Exit M eeting..........
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...11 3.0.3 OCGS Agi ng Ma nagemen t Progra ms..........
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.....11 3.0.3.1 OCGS AM Ps That Are C onsis tent w ith th e GALL Repor t..........
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...17 3.0.3.1.1 Thermal Aging and N eutron Irradiati on Embrittlement of Cas t Austenitic Stainless S teel (OCGS AMP B
.1.10)..........
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.17 3.0.3.1.2 Flow-Acce lerated Corrosi on (OCGS AM P B.1.11)..........
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.......19 3.0.3.1.3 Compressed Ai r Monitori ng (OCGS AMP B.1.17)..........
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.......21 ii 3.0.3.1.4 One-Time Inspection (OCGS AMP B.1.24)....24 3.0.3.1.5 Selec tive L each ing o f Mat eria ls (O CGS A MP B.1.25)..........
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..39 3.0.3.1.6 10 CFR Part 50, Appendi x J (OCGS AM P B.1.29)..........
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.......42 3.0.3.1.7 Masonry Wall Program (OCGS AMP B.1
.30)...45 3.0.3.1.8 Protective Coating Mo nitoring and M aintenance Program (OCGS AMP B.1.33)..........
....47 3.0.3.1.9 Elect rical Cabl es and Conne ction s Not S ubject to 10 CFR 50.4 9 Environ mental Qualifica tion Requirements (OCGS A MP B.1.34)..........
57 3.0.3.1.10 Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 5 0.49 Envi ronmental Quali fication Requirements (OCGS A MP B.1.36)..........
60 3.0.3.1.11 Envir onme ntal Qual ific atio n Pro gra m (O CGS A MP B.3.2)..........
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...64 3.0.3.2 OCGS AM Ps That Are C onsis tent w ith th e GALL Repor t with Exce ption s and/or Enh anceme nts..........
...66 3.0.3.2.1 ASME S ection XI Inserv ice Inspecti on, Subsectio ns IW B, IWC, AND IW D (OCGS AMP (B.1.1)....66 3.0.3.2.2 Water Chemistry (OCGS AMP B.1.2)........77 3.0.3.2.3 Reactor Head Closure Stud s (OCGS AMP B.1.3)..........
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.......90 3.0.3.2.4 BW R Vess el ID A tta chme nt W elds (OCG S AMP B.1.4)..........
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...93 3.0.3.2.5 BWR Feedwater Nozz le (OCGS AM P B.1.5)...97 3.0.3.2.6 BW R Control Rod Drive Return Line Nozzle (OCGS AMP B
.1.6)..........
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.103 3.0.3.2.7 BW R Str ess Co rro sion Crac king (OCG S AMP B.1.7)..........
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..109 3.0.3.2.8 BWR Penetrations (OCGS AM P B.1.8)......115 3.0.3.2.9 BWR Vessel Internals (OCGS A MP B.1.9)...119 3.0.3.2.10 Bolting Integrity (OCGS AMP B.1.12).......119 iii 3.0.3.2.11 Open-Cycl e Cool ing W ater Syste m (O CGS A MP B.1.13)..........
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.124 3.0.3.2.12 Close-Cycl e Cool ing W ater Syste m (O CGS A MP B.1.14)..........
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.131 3.0.3.2.13 Bora fle x Rack Manag emen t Pro gra m (O CGS A MP B.1.15)..........
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.135 3.0.3.2.14 Inspection of Ov erhead Heav y Load an d Light Load (Relat ed to R efueli ng) Han dlin g Syst ems (OCGS AMP B
.1.16)..........
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138 3.0.3.2.15 BW R Reac tor W ater Clean up Sys tem (OCG S AMP B.1.18)..........
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.144 3.0.3.2.16 Fire Protecti on (OCGS AM P B.1.19)........149 3.0.3.2.17 Fire Water System (OCGS AM P B.1.20).....158 3.0.3.2.18 Aboveground Outdoor Tanks (OCGS AM P B.1.21)..........
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......165 3.0.3.2.19 Fuel Oil C hemistry (OCGS A MP B.1.22).....169 3.0.3.2.20 Reactor Vessel Surveil lance (OCGS AM P B.1.23)..........
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......192 3.0.3.2.21 Buried Pi ping Inspection (OCGS AMP B.1.26)..........
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......192 3.0.3.2.22 ASME Se ctio n XI , Sub sect ion IW E (OC GS AMP B.1.27)..........
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.199 3.0.3.2.23 ASME Se ctio n XI , Sub sect ion IW F (OC GS AMP B.1.28)..........
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.238 3.0.3.2.24 Structure Mo nitoring Program (OCGS A MP B.1.31)..........
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......244 3.0.3.2.25 RG 1.127, Inspecti on of Water-Control Structures Asso ciat ed with Nucle ar Po wer Pla nts (OCG S AMP B.1.32)..........
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.260 3.0.3.2.26 Elect rical Cabl es and Conne ction s Not S ubject to 10 CFR 50.4 9 Environ mental Qualifica tion Requir ements Used i n Instr ument C ircui ts (OCGS AMP B.1.3 5)..........
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......271 iv 3.0.3.2.27 Meta l Fati gue of Re actor C oolan t Press ure Boundary (OC GS AMP B.3.1)..........
...276 3.0.3.3 OCGS AMPs That Are Not Con sistent wi th the GALL Report or Not Addre ssed i n the GA LL Rep ort.......282 3.0.3.3.1 Periodic Testi ng of Containment Sp ray Noz zles (OCGS AMP B
.2.1)..........
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.282 3.0.3.3.2 Lubr icat ing O il Monit orin g Act ivitie s (OC GS AMP B.2.2)..........
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..282 3.0.3.3.3 Generator Stator Water Chemistry A ctivitie s (OCGS AMP B
.2.3)..........
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.282 3.0.3.3.4 Perio dic In specti on of Ve ntila tion S ystems (OCGS AMP B.2.4)..........
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.......283 3.0.3.3.5 Periodic In spection Program (OCGS AMP B.2.5)..........
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......283 3.0.3.3.6 Wooden Utility Pol e Program (OCGS AM P B.2.6)..........
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......283 3.0.3.3.7 Periodic M onitoring of Combus tion Turbine P ower Plant (OCGS AM P B.2.7)..........
.......283 3.1 OCGS LRA Secti on 3.1 - Agin g Management of Rea ctor Vessel, In ternals, and Reacto r Cool ant Sy stems..........
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.........283 3.1.1 Summary of Technica l Information in the Applic ation..........
...283 3.1.2 Project Team Eval uation..........
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....284 3.1.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..293 3.1.2.1.1 Cracking Due to Thermal and Mec hanical L oading in Class 1 Small Bo re Piping..........
....293 3.1.2.1.2 Cracking Due to S tress Corrosion Cracking and Intergranular Stress Corrosion Cra cking.....294 3.1.2.1.3 Cracking Due to IA SCC of Top Guide
.......296 3.1.2.1.4 Cracking Due to IA SCC of Core Sh roud.....297 3.1.2.1.5 Cracking Due to S CC, IGSCC, AN D IASCC of Core S pray Sparger s..........
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298 3.1.2.1.6 Cracking Due to S CC of CRD Stu b Tubes....299 v 3.1.2.1.7 Cracking Due to IA SCC of In-Core N eutron Mon itor Dry Tubes..........
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........301 3.1.2.1.8 Cracking Due to S CC, IGSCC, and Cyclic Loading of Vessel Drain Nozzle
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.........302 3.1.2.1.9 Cracking Due to S CC, IGSCC, and Cyclic Loading of Valve Bo dies..........
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....302 3.1.2.1.10 Loss of Materi al Due to Ge neral Corrosi on of External S urface or Carbon a nd Low A lloy S teel Compon ents..........
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......303 3.1.2.1.11 Loss of Materi al Due to P itting and Crev ice Corrosion i n Stainles s Steel and Nickel-All oy Reacto r Vess el Int ernal s Comp onents.......304 3.1.2.1.12 Reduction o f Heat Transfer Due to Fo uling...304 3.1.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...305 3.1.2.2.1 Cumu lati ve F atig ue D amage..........
....305 3.1.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevice C orrosion..........
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..306 3.1.2.2.3 Loss of Fracture Toughne ss Due to Ne utron Irradiation E mbrittlement
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.......311 3.1.2.2.4 Cracking Due to S tress Corrosion Cracking and Intergranular Stress Corrosion Cra cking.....312 3.1.2.2.5 Crack Growth Due to Cycli c Loading........315 3.1.2.2.6 Loss of Fracture Toughne ss Due to Ne utron Irradiation E mbrittlement and Void Sw elling...315 3.1.2.2.7 Cracking Due to S tress Corrosion Cracking...315 3.1.2.2.8 Cracking Due to C yclic L oading..........
..316 3.1.2.2.9 Loss of Preload Due to Stress Relaxa tion....316 3.1.2.2.10 Loss of Materi al Due to E rosion..........
..317 3.1.2.2.11 Cracking Due to F low-Induce d Vibration
.....317 3.1.2.2.12 Cracking Due to S tress Corrosion Cracking and Irradiation-Ass isted Stress C orrosion Crackin g (IASCC)..........
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318 vi 3.1.2.2.13 Cracking Due to P rimary Water Stress Corrosion Cracking (PW SCC)..........
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.318 3.1.2.2.14 Wall Thinning Due to Fl ow-Accele rated Corrosion
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......318 3.1.2.2.15 Changes in D imensions D ue to Void Swelli ng..........
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......318 3.1.2.2.16 Cracking Due to S tress Corrosion Cracking and Primary Water Stress Corrosio n Cracking
....318 3.1.2.2.17 Crac king Due to S tres s Co rros ion Cra ckin g, Primary Water Stress Corrosio n Cracking, and Irradiation-Ass isted Stress C orrosion Crackin g..........
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......319 3.1.2.2.18 Quality A ssurance for Aging M anagement of Non-safety-Relat ed Com ponen ts..........
....319 3.1.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......319 3.1.2.3.1 Aging E ffects/mech anisms in Tab le 3.1.1 That Are Not Ap plic able for OCGS..........
.......320 3.1.2.3.2 Reactor Vessel , Internals, and Reactor Cool ant Systems AM R Line Items Tha t Have No Aging Effect (OCG S LR A Tab les 3.1.2.1.1 Thr ough 3.1.2.1.6)
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.........322 3.1.3 Conclusio n..........
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.....323 3.2 OCGS LRA Secti on 3.2 - Agin g Management of Engin eered Safety Fe atures..........
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.........323 3.2.1 Summary of Technica l Information in the Applic ation..........
...323 3.2.2 Project Team Eval uation..........
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....324 3.2.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..332 3.2.2.1.1 Loss of Materi al Due to Ge neral Corrosi on on Internal and E xternal Su rfaces Exposed to Air and Moi sture..........
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333 3.2.2.1.2 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly Influence d Corrosion Steel Containment Iso lation Compo nents Expo sed Internally to Untreated Water
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....335 vii 3.2.2.1.3 General, Pitting, Crevice, and Microbiologically Influenced Corrosi on and Foul ing in Stai nless Steel Containment Iso lation Compo nent Expos ed to Raw or Untreated Water
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.336 3.2.2.1.4 General, Pitting, Crevice, and Microbiologically Influenced Corrosi on and Foul ing in Steel Containment Iso lation Compo nent Expos ed to Raw Water..........
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..336 3.2.2.1.5 Loss of Materi al Due to Ge neral Corrosi on of External S urface of Carbon and Low All oy Steel Compon ents..........
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......337 3.2.2.1.6 Loss of Materi al Due to Ge neral, Pitti ng and Crevice C orrosion..........
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..337 3.2.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...339 3.2.2.2.1 Cumu lati ve F atig ue D amage..........
....339 3.2.2.2.2 Loss of Materi al due to C ladding..........
.339 3.2.2.2.3 Loss of Materi al Due to P itting and Crev ice Corrosion..........
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.........339 3.2.2.2.4 Reduction o f Heat Transfer Due to Fo uling...343 3.2.2.2.5 Hardening and Loss of Strength Due to Elastomer Degradation
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.......345 3.2.2.2.6 Loss of Materi al Due to E rosion..........
..346 3.2.2.2.7 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly Influence d Corrosion, and Fouling..........
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.346 3.2.2.2.8 Loss of Materi al Due to Ge neral, Pitti ng and Crevice C orrosion..........
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..346 3.2.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly Influence d Corrosion
...349 3.2.2.2.10 Quality A ssurance for Aging M anagement of Non-Safety-Rela ted Co mponen ts..........
....350 3.2.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......350 viii 3.2.2.3.1 Aging E ffect/mecha nism i n Tabl e 3.2.1 That Ar e Not Ap plic able for OCGS..........
.......351 3.2.2.3.2 Engineered Sa fety Features AM R Line Items Tha t Have No Aging Effect (OCGS LRA Table s 3.2.2.1.1 Through 3.2.2.1.3
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......355 3.2.3 Conclusio n..........
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.....357 3.3 OCGS LR A Sect ion 3.3 - Agi ng Ma nagemen t of Aux ilia ry Sy stems.......357 3.3.1 Summary of Technica l Information in the Applic ation..........
...358 3.3.2 Project Team Eval uation..........
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....359 3.3.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..375 3.3.2.1.1 Loss of Materi al Due to P itting and Crev ice Corrosion..........
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.........376 3.3.2.1.2 Cracking Initiati on and Grow th Due to Thermal and Mechani cal Loadi ng..........
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.378 3.3.2.1.3 Hardening and Loss of Strength Due to Elastomer Degradation
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.......378 3.3.2.1.4 Cracking Initiati on and Grow th Due to Stres s Corrosion Cra cking..........
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.378 3.3.2.1.5 Components Ex posed to Dry Air wi th No Aging Effect Identified
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....380 3.3.2.1.6 Loss of Materi al Due to Ge neral, Pitti ng, and Crevice C orrosion..........
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..380 3.3.2.1.7 Loss of Preload Due to Stress Relaxa tion....385 3.3.2.1.8 Loss of Materi al Due to P itting, Crevi ce, and Galvanic Corrosion..........
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.385 3.3.2.1.9 Loss of Materi al Due to P itting, Crevi ce, and Microbi ologically Influenced Corro sion, and Fo uling..........
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......386 3.3.2.1.10 Loss of Materi al Due to Ge neral Corrosi on...387 3.3.2.1.11 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly Influence d Corrosion
...390 3.3.2.1.12 Reduction o f Heat Transfer Due to Fo uling...391 ix 3.3.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...392 3.3.2.2.1 Cumu lati ve F atig ue D amage..........
....392 3.3.2.2.2 Reduction o f Heat Transfer Due to Fo uling...393 3.3.2.2.3 Cracking Due to S tress Corrosion Cracking...394 3.3.2.2.4 Cracking Due to S tress Corrosion Cracking and Cyclic Loading..........
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.....396 3.3.2.2.5 Hardening and Loss of Strength Due to Elastomer Degradation
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.......398 3.3.2.2.6 Reduction o f Neutron-Absorbin g Capacity and Loss of Material Due to General Corrosion
.......399 3.3.2.2.7 Loss of Materi al Due to Ge neral, Pitti ng, and Crevice C orrosion..........
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..400 3.3.2.2.8 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Microbiologically- Influenced Corrosion (MIC)
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......403 3.3.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, Microbi ologically Influenced Corro sion and F ouling..........
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......406 3.3.2.2.10 Loss of Materi al Due to P itting and Crev ice Corrosion..........
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.........408 3.3.2.2.11 Loss of Materi al Due to P itting, Crevi ce, and Galva nic C orrosi on for C opper Allo y Ex posed to Treated Water
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.....415 3.3.2.2.12 Loss of Materi al Due to P itting, Crevi ce, and Microbi ologically Influenced Corro sion.......416 3.3.2.2.13 Loss of Materi al Due to Wear
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...418 3.3.2.2.14 Loss of Materi al Due to C ladding Brea ch.....419 3.3.2.2.15 Quality A ssurance for Aging M anagement of Non-Safey-Relat ed Com ponen ts..........
.....419 3.3.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......419 3.3.2.3.1 Aging E ffects/mech anisms in Tab le 3.3.1 That Are Not Ap plic able for OCGS..........
.......420 x 3.3.2.3.2 Auxiliary Systems AMR Line Items That Have No Agin g Effec t (OC GS LR A Tab les 3.3.2.1.1 Thr ough 3.3.2.1.41)
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........422 3.3.3 Conclusio n..........
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.....425 3.4 OCGS LRA Secti on 3.4 - Agin g Management of Stea m and Pow er Conversi on System..........
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....425 3.4.1 Summary of Technica l Information in the Applic ation..........
...426 3.4.2 Project Team Eval uation..........
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....426 3.4.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..434 3.4.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...436 3.4.2.2.1 Cumu lati ve F atig ue D amage..........
....436 3.4.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevice C orrosion..........
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..437 3.4.2.2.3 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly- Influence d Corrosion and Fouling..........
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.439 3.4.2.2.4 Reduction o f Heat Transfer Due to Fo uling...439 3.4.2.2.5 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Mic robiological ly  Influenc ed Corrosion
...440 3.4.2.2.6 Cracking Due to S tress Corrosion Cracking...441 3.4.2.2.7 Loss of Materi al Due to P itting and Crev ice Corrosion..........
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.........441 3.4.2.2.8 Loss of Materi al Due to P itting, Crevi ce, and Microbi ologically Influenced Corro sion.......444 3.4.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, and Galvan ic Corrosio n..........
........444 3.4.2.2.10 Quality A ssurance for Aging M anagement of Non-Safety-Rela ted Co mponen ts..........
....445 3.4.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......446 3.4.2.3.1 Aging E ffect/Me chani sm in Ta ble 3.4.1 Tha t Are Not Ap plic able for OCGS..........
.......446 xi 3.4.2.3.2 Steam and Pow er Conversi on System A MR Lin e Items That Have No Aging Ef fect (OCGS LRA Tables 3.4.2.1.1 Thro ugh 3.4.2.1.7)
.........450 3.4.3 Conclusio n..........
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.....451 3.5 OCGS LR A Sect ion 3.5 - Agi ng Ma nagemen t of Pri mary C ontai nment, Structures, Compone nt Supports, and Piping and Component Insu lation...451 3.5.1 Summary of Technica l Information in the Applic ation..........
...452 3.5.2 Project Team Eval uation..........
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....452 3.5.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..464 3.5.2.1.1 Stress Corrosio n Cracking of High Stre ngth Low Alloy Bolting M aterials (Item 3.5
.1-51).......465 3.5.2.1.2 Degradation of Group 6 Elastomer Se als, Gaskets, and Moi sture Barriers (Ite m 3.5.1-44)
.......465 3.5.2.1.3 Lock-up Due to W ear of Radial Beam Seats in BWR Drywell (Item 3.5
.1-30)..........
....466 3.5.2.1.4 No Aging Effect for Steel (A ll Types) a nd Aluminu m in a ?Concrete" Env ironment..........
....466 3.5.2.1.5 No Aging Effect for Stainl ess and Galv anized S teel and Alumin um in a ?Indoor-Air" or ?Contai nment-Atmosphere" Env ironment..........
......466 3.5.2.1.6 Loss of Preload in Structural Bolting........467 3.5.2.1.7 AMR Re sult for Class MC Pressu re Retainin g Bolting..........
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.467 3.5.2.1.8 Loss of Mecha nical Fun ction for Stainl ess and Galva nize d Stee l and Alumi num AS ME C lass 1 ,2,3 and MC Supports (Item 3.5.1-5 8, Item 3.5.1-59, LRA Table 3.5
.2.1.18)..........
.........467 3.5.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...468 3.5.2.2.1 PWR and BWR Conta inment s..........
...468 3.5.2.2.2 Safety-Related and Other Structure s and Compon ent Su pports..........
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476 3.5.2.2.3 Quality A ssurance for Aging M anagement of Non-Safety-Rela ted Co mponen ts..........
....493 xii 3.5.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......493 3.5.3 Conclu sion..........
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......494 3.6 OCGS LR A Sect ion 3.6 - Agi ng Ma nagemen t of Ele ctrica l Comp onents...494 3.6.1 Summary of Technica l Information in the Applic ation..........
...494 3.6.2 Project Team Eval uation..........
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....495 3.6.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
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..498 3.6.2.2 AMR Resul ts For Which Furth er Ev aluat ion Is Recomme nded B y The GALL R eport..........
...499 3.6.2.2.1 Electrical Equipment Subject to Environ mental Qualification
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.......499 3.6.2.2.2 Degradation of Insul ator Quality Due to Prese nce of Any Salt Deposits and Surface Contamin ation, and Loss of M aterial Due to Mecha nical Wear
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......499 3.6.2.2.3 Loss of Materi al Due to Wind Induced Abrasion and Fa tigue, Loss o f Condu ctor St rength D ue to Corrosion, an Increased Res istance of Conn ection Due to Oxi dation or Lo ss of Pre-load
........500 3.6.2.2.4 Quality A ssurance for Aging M anagement of Non-Safety-Rela ted Co mponen ts..........
....500 3.6.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addres sed In The GAL L Repo rt......500 3.6.3 Conclusio n..........
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.....500 ATTACHMENT 1: LIST OF ABBREVIAT IONS..........
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.....501 ATTACHM ENT 2:  PROJE CT TEAM AND A PPLIC ANT PE RSONN EL; PUBLIC EXIT MEETING ATT ENDEES..........
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.....503 ATTACHMENT 3: AGING MANAGEMENT PROGRAM ELEMENT DESCRIPTIONS
......506 ATT ACHMEN T 4:
 
==SUMMARY==
O F LRA A UDIT OPEN ITE MS..........
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...507 ATTACHMENT 5: LIST OF DOCUMENTS REVIEW ED..........
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........508 ATTAC HM ENT 6: LIS T OF C OMM ITME NTS..........
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......528 ATTA CHM ENT 7  FORKED RIVER COMBUSTION TURBINES, RADIO COMMUNICATION SYST EMS, AND METEOROLOGICAL TO W ER LICENSE RENEWAL AUDIT AND REVIEW
..550 xiii xiv Tables Page #Table 3.0.3-1 OCGS Aging Man agement Programs
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.11 Table 3.1-1 Project Team's Ev aluation for LR A Section 3
.1 - Reactor V essel, Internal s, and Reacto r Cool ant Sy stems C ompone nts in the GA LL Rep ort..........
...285 Table 3.2-1 Staff Evaluation for Engineered Sa fety Features Co mponents in the GALL Report..........
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....325 Table 3.3-1 Staff Ev aluat ion for Auxi liary Syst em Comp onents in th e GALL Repor t.....359 Table 3.4-1 Staff Evaluation for Steam and Pow er Conversi on System C omponents in the GALL R eport..........
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.........427 Table 3.5-1 Staff Evaluation for Containment, S tructures, Componen t Supports, and Piping and Co mponen t Insul ation in th e GALL Repor t..........
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...453 Table 3.6-1 Staff Ev aluat ion for Elec trical Compo nents in the GALL R eport..........
.495
[Thi s Pa ge In tent ion all y Le ft Bl ank]
Au dit and Rev iew Repor t for P lant A ging Ma nageme nt Rev iews and P rogram s For Oyster Creek Generatin g Station 1.Introduction and General Information 1.1 Introduction By letter d ated July 22, 2005 (Agenc ywide Documents Acce ss and M anagement System
[ADAMS] ADAMS Accession Number ML0520800480), AmerGen Energy Company, LLC, (AmerGen , the a ppli cant) s ubmitte d to th e U.S. Nucl ear Re gulato ry Co mmissi on (NR C) its applicatio n for renewal of Facility Operating Licen se No. DPR-1 6 for Oyster Creek Gene rating Statio n (ADA MS A ccessi on Num ber M L0520 80185). The a ppli cant re quested renew al of i ts operat ing li cense for an a dditi onal 20 ye ars be yond the 40-year curren t lic ense t erm.In support of the sta ff's safety review of the licens e renewal applicati on (LRA) for Oyste r Creek Generating Station (OCGS), the Licen se Renew al Branch C (RLRC) led a project team tha t audited and review ed selected aging management revi ews (AM Rs) and assoc iated aging management programs (AM Ps) devel oped by th e applica nt to support the LRA for OCGS. The project team incl uded both NR C staff and contractor pe rsonnel prov ided by Brookhaven National L aboratory (BN L), the RLRC technical c ontractor. Attachmen t 2 lists the project team members, as well as other NRC staff and BNL personnel who supported the project team
's audit and re view.The project team performed i ts work in a ccordance w ith the requiremen ts of Title 10 of the Code of Federal Regulations (CFR), Part 54 (10 CFR Part 54), Requirements for R enewal of Operating License s for Nuclear Po wer Plan ts; the guidance provided in Revi sion 1 of NUREG-1800, S tandard Rev iew Pl an for Revie w of Licens e Renewa l Applic ations for Nucl ear Power Plants (SRP-LR); and the guidance provided in Revision 1 of NUREG-1801, Ge neric Aging L essons Learn ed (GAL L) Rep ort, (GA LL Rep ort).Details of how the project team i mplemented these requirements and guidance are found in "Audit and R eview Plan for Pla nt Aging Mana gement Review s and Programs - Oy ster Creek Generating Station
," Revisi on 1, Docket No.
50-219, (ADAM S Accession Number ML060200084) (OC GS aud it and revi ew p lan).This aud it a nd re vie w re port doc umen ts th e res ults of th e pro ject team's a udi t and rev iew wo rk.The project team performed i ts work at NRC Headquarters, Roc kville, M aryland; a t Brookhaven National Laboratory off ices in Upton, New York; and at the applicant's off ices (OCGS site) in Forked Rive r, New Jerse
: y. The project team conducted o n-site vi sits during the weeks of October 3, 2005, J anuary 23, 2006, February 13, 2006, an d April 19 , 2006. The proje ct team conducted a p ublic ex it meeting at the Lacey Tow nship M unicipal Buildin g in Forked Riv er, New Jersey, on April 20, 2006. Attachment 2 lists the applicant personnel and other individuals contacted by the project team i n support of the w ork documented in this audi t and revi ew repo rt. I t al so l ists thos e att endi ng th e pu bli c ex it me etin g.1.2 Background In 10 CFR 5 4.4, the scope of license rene wal is defined as tho se systems, struc tures, and components (SSC s) (1) that are sa fety-related, (2) w hose failure co uld affect safety-relate d functio ns, or (3) tha t are re lied on to demons trate c ompli ance w ith NR C regul ation s for fire protec tion, envi ronmen tal qua lifica tion, pressu rize d therm al sh ock, ant icip ated tr ansie nts without scram, and station blacko ut. An applicant for a renewed license must review all SSCs 2 within the scope of li cense renew al to iden tify those structu res and compone nts (SCs) subject to an AM R. SCs subje ct to an AM R are those th at perform an intend ed function w ithout movi ng parts or wi thout a change i n configuration or properties, and that are not su bject to replace ment based on qual ified life or sp ecified time pe riod. Pursua nt to 10 CFR 54.21(a)(3), an a pplicant for a renewed license must demonstrate that the effects of aging will be managed in such a w ay that the intend ed function or functi ons of those SCs will be maintain ed for the period of extended o peration.In add ition , 10 CF R 54.2 1(d) re quires that th e appl icant submi t a sup plemen t to the Fina l Safet y Analysi s Report (FSAR) that contains a summary des cription of the programs and activ ities for mana ging the e ffects of agi ng.The SRP-LR pro vides staff guidanc e for review ing applica tions for licen se renewal. The GALL Rep ort is a t ech ni cal ba ses do cum ent. It sum mar iz es s taff-ap pro ve d A MP s fo r th e a gin g of a large number of SCs that are subject to an AMR. It summarizes the aging management evaluati ons, programs, and ac tivities credited for managin g aging for most of the SCs us ed by com mer cia l n ucl ear po we r pl ant s, a nd ser ve s as a r efe ren ce f or b oth the ap pl ica nt a nd sta ff reviewers to quickly identify those AMPs and activities that the staff have determined will provide a dequate aging management d uring the perio d of extended operation. If an applicant commits to imp lement ing the se staff-a pprov ed AM Ps, the time, e ffort, and resour ces us ed to review an appli cant's LRA will be greatly red uced, thereby improving th e efficiency an d effectiveness of the l icense renew al revie w process.
The GALL Report identifies (1)
SSCs, (2)component material s, (3) envi ronments to wh ich the compon ents are exp osed, (4) aging effects/agi ng mecha nisms associ ated w ith th e mater ials and e nvir onments , (5) AM Ps tha t are credited w ith managing the a ging effects, and (6) recommendati ons for further appli cant evaluati ons of aging effects and thei r management for certain c omponent type s.The GALL Report is treated in the sam e manner as an NRC-approved topical report that is generi call y app lica ble. An app lica nt may referen ce the GALL R eport i n its LRA to demons trate that i ts progr ams cor respon d to th ose th at the staff rev iew ed and appro ved i n the GA LL Rep ort. If the material pres ented in the LRA is co nsistent w ith the GALL R eport and is applicabl e to the applicant' s facility, the staff will accept the app licant's re ference to the GALL Report. In making this d etermi natio n, the staff cons iders whe ther th e appl icant has i denti fied sp ecific programs described an d evalua ted in the GAL L Report but d oes not condu ct a revie w of the substa nce of the matters describ ed in the GAL L Report. Rath er, the staff determines tha t the appli cant established that the approv als set forth in the GALL Repo rt apply to its programs.
If an ap plic ant take s credi t for a GA LL Rep ort pro gram, it is in cumben t on th e appl icant to ensure that its plant program add resses all ten program elements of the referenced GALL Report program. These elements are d escribed in the SRP-LR, Appendix A.1, "Aging Management Re view - Generic (Branch Technical P osition RL SB-1)."  In addi tion, the conditions at the plant must be bounded by the co nditions for w hich the GALL Report program was e valu ated. The app lica nt must certify in i ts LRA that i t compl eted th e appr opria te verification s and that thos e verificati ons are documen ted and retain ed by the applicant i n an audit able form.2.Aud it and Rev iew Scope The AM Rs and assoc iated AMP s that the pro ject tea m revi ewed are i denti fied i n the OC GS audit and review plan. The project team examined 49 of the O CGS AMPs, including 11 AMPs for the Forke d River Combustion Turbine (FRCT), and associated AMRs. The FRCT AMPs 1 Table 2 prov ides detailed result s of the AM Rs for those compo nents identified in the LRA Sectio n 2 as being subject to an AMR. 3 and AMR s are addresse d in Attachmen t 7 to this au dit and rev iew repo rt. The project team revi ewed AMP s and AMR s that the ap plic ant cl aimed were consi stent w ith th e GALL Repor t, and AMR s for which further evaluati on is recommend ed by the GALL Report. The project team also revi ewed certai n plant-speci fic AMPs.The applican t noted that some of its AMPs , although descri bed as consi stent with the GALL Report, contain some devi ations from the GALL Report. These de viations are of two ty pes:*exce ption s to th e GALL Repor t - ex cepti ons ar e spec ified to GALL Repor t recomme ndati ons th at the appli cant d oes no t inte nd to i mpleme nt.*enhan cements - enha ncemen ts inc lude those actio ns/acti viti es nec essary to (1) ensure consistency with GALL Report AM P recommendation s, or (2) provi de additio nal features to the program or program a ctivitie s that the appl icant wi ll impleme nt prior to the period of extended op eration. Enh ancements may expand, bu t not reduce, the scope of an AMP.The project team's a udit and rev iew acti vities for the OCGS AMPs , and its con clusions regardi ng these revi ews, are do cumente d in S ectio ns 3.0.3 of thi s audi t and r evie w rep ort.The project team rev iewed a ll OCGS LRA Table 2 1 AMR l ine-items in Chapter 3, ex cept those that were as signed to the Office of Nuc lear Reactor Regulation (N RR), Divi sion of Enginee ring (DE) staff. Those the projec t team review ed were e ither consis tent with the GALL Repo rt, as identified by Notes A throu gh E in OCGS LR A Table 3.X.2-Y (from Co lumn 9 of the Tabl e 2s discussed i n Section 3
.0.1 of this audi t and revi ew report), or review ed and accep ted by the project team on the basis of an N RC-approve d precedent (se e Section 3
.0.2.3 of this audi t and revi ew re port).The project team determi ned that the A MR resul ts, reported by the appli cant to be con sistent with the GALL Report, are consistent w ith the GALL R eport. The project te am also determi ned that the plant-s pecific AM R results repo rted by the applicant a re technical ly accepta ble and applicabl e. For AM R results for w hich the GALL Report recommends further evalua tion, the project team revi ewed the applicant's evaluati on and determi ned that it a dequately ad dresses the issues for w hich the GALL Report recommends further evalua tion.The AMR results that are within the scope of the proje ct team's audit are identified in Appendix D of the OCGS aud it and rev iew pl an. The AM R result li ne-items revi ewed by the project team in C hapter 3 of the OCGS LRA Tables 3.X.2-Y were ei ther consistent with the GALL R eport o r justi fied by the ap plic ant on the ba sis of a n NRC-appro ved p recede nt.In the OCGS LR A, Tabl es 3.X.2-Y, in addi tion t o the n otes, t he app lica nt prov ided a summa ry of AMR resul ts for the appli cable sys tems, which included the SCs, assoc iated material s, environment, any aging effects requiri ng management, and an AMP for each line-item.
The notes descri be how the i nformati on in the ta bles align s wi th the informat ion i n the GA LL Rep ort. Those th at are align ed w ith th e GALL Repor t are a ssigne d lett ers an d are d escrib ed bel ow. Those defined by the applicant are assig ned numbers and are defined in the OCG S LRA.
4 Note A ind icates that the OCGS AMR line-item i s consistent w ith the GALL Report for component, material, env ironment, and a ging effect. In addition , the OCGS AM P is c onsis tent w ith th e AM P ide ntifie d in t he GAL L Repo rt.Note B ind icates that the OCGS AMR line-item i s consistent w ith the GALL Report for component, material, env ironment, and a ging effect. In addition , the OCGS AM P takes some ex cepti ons to the AM P ide ntifie d in t he GAL L Repo rt. The pro ject tea m deter mined that th e ide ntifie d exc eptio ns to t he GAL L Repo rt AMPs are acceptable.
Note C indi cates t hat the compon ent for t he OCGS AMR line-item i s differe nt, but co nsiste nt wi th the GALL R eport fo r materi al, en viro nment, a nd agi ng effect.
This note ind icates that the applican t was unab le to find a l isting of some sy stem components in the GALL Repo rt. Howev er, the appli cant identifie d a different component in the GALL Repo rt that had the s ame material, en vironment, agin g effect, and AMP a s the component that was un der review. The project team determined that the OCGS AM R line-ite m of the different component w as appli cabl e to t he co mpon ent u nder revie w.Note D indi cates t hat the compon ent for t he OCGS AMR line-item i s differe nt, but co nsiste nt wi th the GALL R eport fo r materi al, en viro nment, a nd agi ng effect.
In addition , the OCGS AM P takes some ex ceptions to th e AMP i dentified in the GALL R eport. The pro ject tea m revi ewed these line-items to con firm consi stency wit h the GA LL Rep ort. The projec t team d etermi ned th at the OCGS AMR li ne-item for the different compo nent was a pplicabl e to the compone nt under revi ew. The proje ct team determined that the identi fied excepti ons to the GALL Report AM Ps are accepta ble.Note E ind icates that the OCGS AMR line-item i s consistent w ith the GALL Report for mat erial, environment, and aging ef fect, but a diff erent AMP is cred ited. The proj ect t eam e valua ted t hese line-item s to d eter mine that the AMP credited by the appli cant is appl icable.Note F indi cates that the mate rial is n ot in the GALL Report for the id entified compon ent.Note G indi cates that the e nvironment i s not in the GALL Report for the identified component and material.
Note H indi cates t hat the aging e ffect is n ot in the GAL L Repo rt for co mponen t, material, and environment combination.
Note I indi cates that the a ging effect in the GALL R eport for the iden tified component, material , and envi ronment combinati on is not a pplicabl e.Note J indi cates that nei ther the identi fied component no r the material and envi ronmen t combi natio n is e valu ated i n the GA LL Rep ort.Discrepanci es or issues discovered by the pro ject team during the audit and re view that required a respo nse are documen ted in this audit and re view report. If resolutio n of an issue was not res olved pri or to issuin g this audit a nd review report, a request for ad ditional 5 informat ion (R AI) w as pre pared by th e proje ct team to sol icit the in formatio n need ed to dispo sitio n the i ssue. The RA I wi ll be incl uded a nd di sposi tione d in t he safet y ev aluat ion re port (SER) related to the OCGS LRA. The list of RAIs associated with the audit and review report is provi ded i n Attac hment 4 to thi s audi t and r evie w rep ort.The project team conducted an audit and review of the informat ion provided in the OCGS LRA and progr am ba ses docu ment s, w hic h are ava ila ble at th e ap pli cant's o ffice , and thro ugh interview s with OCGS technical staff. The project team determine d that the appl icable agin g effects were identi fied, the appropri ate combinatio n of materials an d environ ments were l isted, and acceptabl e AMPs were speci fied.The AMR re sults revi ew of OCGS LRA Sections 3.1 through 3.6 rev iewed b y the project team are pro vide d in S ectio ns 3.1 through 3.6 of t his a udit a nd rev iew report.3.Ag ing Man agemen t Rev iew Au dit and Rev iew Result s This se ction of the a udit a nd rev iew report conta ins th e proje ct team's eva luati on of th e OCGS AMPs an d AMRs. In OCGS LRA A ppendix B, the appli cant described the AMP s that it reli es on to manage or monitor the aging of long-liv ed, passiv e components an d structures.
In OCGS LRA Se ction 3, the a pplicant pro vided the results of the A MRs for those structures and components that it iden tifies in OCGS L RA Section 2 as bein g within th e scope of li cense renewal and subject to an AMR.
3.0 OCGS's Use of the Generic A ging Lessons-Learned Rep ort In preparing its OCGS LRA, AmerGen credited the GALL Report. The GALL Report con tains the staff's generic ev aluation o f the existin g plant programs, and it documents the technical basis for dete rmini ng whe re ex istin g programs are ad equate with out mod ificati on, an d wh ere existing pro grams should be augmented for the ex tended period of operation. The evaluati on resul ts docu mented in the GALL R eport i ndica te that many of the e xist ing pro grams are adequate to manage the aging effects for particular s tructures or compone nts for license renewal without ch ange. The GALL Re port also con tains recommendati ons on speci fic areas for which ex isting programs shou ld be augmented for license rene wal. OCGS references the GALL Report i n its LRA to demonstrate that th e programs at its faci lity corre spond to those recomme nded i n the GA LL Rep ort.3.0.1 Format of the OCGS License Rene wal Application The OCGS LRA c losel y foll ows t he sta ndard LRA for mat pre sented in Nu clear Energy Insti tute (NEI) guidance, N EI 95-10, Industry Guideline for Implementing the R equirements of 10 CFR Part 54 - The Lice nse Renew al Rule, R evision 5.The organizati on of Section 3 of the OCGS LRA p arallels Chapter 3 of the S RP-LR. Secti on 3 of the OCGS LRA pro vides the results of the A MRs for SCs that the appli cant identifie d as subject to an A MR. Organiz ation of this se ction is ba sed on Tables 1 through 6 of Vol ume 1 of NURE G-1801, draft da ted Ja nuary 2005, and C hapter 3, "Agi ng Ma nagemen t Rev iew Resul ts,"of NUREG-1800, draf t dated January 2005. The use of the dr aft January 2005 GALL Report is in accordanc e with th e January 13, 2005 meeti ng between th e NRC and NEI on updati ng lice nse re newa l guid ance d ocumen ts, as s ummariz ed and docume nted i n a mee ting su mmary dated Februa ry 17 , 2005 (ADAM S Acce ssion Numbe r ML050490142).
6 In AmerGen letter 2 130-06-20293 d ated March 30, 2006 (M L060950408), th e applica nt summari zed t he res ults o f its rec oncil iatio n of the Oyste r Cree k lice nse re newa l app lica tion w ith the guidance co ntained in the September 2 005 Revi sion 1 NU REG-1800 and NUREG-1801 docume nts. The appl icant prov ided detai ls of th is rec oncil iatio n in i ts reco ncil iatio n docu ment,"Re con cil ia tio n o f Pr ogr am a nd Li ne Ite m Di ffer enc es B etw een Jan uar y 2 005 Dra ft NURE G-1801 and Se ptember 2005 Revi sion 1 NUR EG-180 1," Rev isio n 1, (M L0608 70123). In its rec onc il ia tio n d ocu men t, t he app li can t i den tif ie d a nd rec onc il ed di ffer enc es b etw een the dra ft January 200 5 GALL AM P and AM R line i tems used in th e Oyster Creek LR A, with th ose in the Septem ber 20 05 Rev isio n 1 GAL L Repo rt. Thi s recon cili ation docume nt wa s rev iew ed as part of this audit, a nd was trea ted as an ex tension of the Oy ster Creek lice nse renewa l applic ation for purp oses o f this a udit.OCGS LRA Tables 3.0-1 and 3.0-2 , provide descriptions of the internal and externa l service envi ronmen ts that were used in the aging ma nagemen t revi ews t o dete rmine aging effec ts requir ing man ageme nt. OCG S LRA Table 3.0-3 pr ovides desc ription s of th e passive component material s, and Table 3
.0-4 provid es descripti ons of aging effects. This tabl e also provides the equival ent GALL Repo rt aging effects.
The res ults o f the AM Rs are prese nted i n two table type s. The fi rst tab le ty pe is Table 3.X.1 (Table 1), wh ere the "3" in dicates the ta ble pertain ing to the Cha pter 3 AMR
; the ?X" indicates the table nu mber from Volume 1 of the GALL Report (se e the definiti on table be low), and the 1 indicates th at this is th e first table ty pe (Table 1) i n Section 3.X. For exampl e, in the rea ctor vessel, i nternals, and reactor coolan t systems subse ction, this i s Table 3.1.1, a nd in the engineered safety features subsectio n, this is Tab le 3.2.1.Definition Tab le X Definition 1 Reacto r Vess el, In ternal s, and React or Coo lant S ystems 2 Engineered Sa fety Features 3 Auxi liary Syst ems 4 Steam and Pow er Conversi on System 5 Containment, Stru ctures, Component Supports, and P iping and Component Insul ation 6 Elect rical Compo nents The second table type is Table 3.X.2-Y, (Table 2) where "3" again indicates the OCG S LRA section number; "X" again indic ates the table number from Volume 1 of the GALL Repo rt; the"2" indicates that this is the second ta ble type (Table 2) in S ection 3.X; and "Y" indicate s the system table number. For ex ample, wi thin the  rea ctor vessel , internals, a nd reactor cool ant systems subsection, the AMR results fo r the Isolation Condenser System are pres ented in Table 3.1.2.1.1, and t he results for the Nuclear Boiler Inst rumentation System are in Table 3.1.2.1.2. In the en gineer ed safet y featu res sub sectio n, the contai nment s pray syste m results are presented in Table 3.2.
2.1.1, and the Core Spray System results are in Table 3.2.2.1.2.
7 The applican t compared the OCGS AMR res ults wi th information in the tables o f the GALL Repo rt an d pro vided the r esul ts of its co mpar ison s in two table types that corr espo nd to the t wo table type s described above.3.0.1.1 Overview of OCGS LRA Table 1 OCGS LR A Tabl e 1 pro vide s a sum mary c ompari son of h ow th e OCGS AMR resul ts ali gn wi th the correspondi ng tables of the GAL L Report. OCGS L RA Table 1 c onsists of the foll owing columns:  "Item Nu mber," "Component," "Agi ng Effect/Mechanism," "A MPs," "Furthe r Evaluati on Recommended" and "Discuss ion."  These OCGS LRA tables have the s ame format and are essen tially the same as Tabl es 1 through 6 o f the GALL Report, V olume 1, ex cept that the "ID" and "Type" column s of the GALL R eport t ables were repla ced by an "Ite m Numbe r"column and th e ?Related Generi c Item" and "Uni que Item" columns of the GALL Report tabl es were repl aced by a "Discussio n" column. The "D iscussion" c olumn incl udes further clarifying/ampl ifying information.
The followi ng are exampl es of information that are  containe d within the "Discussi on" column:
(1)information on further e valuatio n required or referenc e to the loca tion of that information (2)the name of a pla nt-specific program bei ng used (3)exceptions to the GALL R eport assumption s (4)a discussi on of how the line-item i s consistent w ith the corresp onding line-item i n the GA LL Rep ort (5)a discussi on of how the line-item d iffers from the corresponding l ine-item in the GALL R eport, when it may appe ar to be consi stent 3.0.1.2 Overview of OCGS LRA Table 2 The OCGS LRA Tabl e 3.X.2-Y (Table 2) provides the detaile d results of the A MRs for those components ide ntified in OCGS LRA Sectio n 2 as bei ng subject to an A MR. There i s a Table 2 for each of the com ponents or systems within a system grouping (e.g., Reactor Vessel, Interna ls, an d Reac tor Coo lant S ystems , Engin eered Safety Featu res, Au xil iary Syst ems, etc.).For ex ample, the En gineer ed Safe ty Fe atures syste m group c ontai ns tab les sp ecific to Containment S pray Sy stem, Core Spray System, and Standby Gas Treatment System. Tabl e 2 consists of the foll owing nin e columns:
(1)Component Type
-  The first colu mn identifies th e component types that are subject to an AMR. The component type s are listed in alphab etical order.
In the structural tables, compon ent types are sub-grouped by mater ial.(2)Intended Functi on -  The second column ide ntifies the li cense renew al in tended functio ns for th e lis ted co mponen t type s. Definitions and abbreviations of intended f unctions are listed in Table 2.1-1 in Section 2 of the OCG S LRA.
8 (3)Material -  The third column lis ts the particul ar materials o f construction for the component type being eva luated.(4)Environment
-  The fourth colu mn lists the e nvironment to which the component ty pes are ex posed. Internal and extern al servi ce envi ronmen ts are indi cated. A des cripti on of th ese en viro nments is provided in Table 3.0-1 and Table 3.0-2, fo r mechanical, struc tural, and elect rical com ponent s, resp ectively.(5)Aging Effect Requiring Management
-  The fifth column l ists the aging effects identified a s requiring management for the material and envi ronment combinati ons of each compon ent type.(6)Aging Mana gement Progra ms -  The six th column li sts the programs used to mana ge the aging effects requiring manageme nt.(7)NUREG-1801 V olume 2 Item
-  The seve nth co lumn d ocumen ts ident ified consi stenci es of fact ors li sted i n Tabl e 2 of th e OCGS LRA w ith th e GALL Repor t by n oting t he app ropria te GALL Repor t AMR line-item. Each combination of the following f actors listed in Table 2 is c ompared to the GAL L Report to i dentify those consistencie s:  component ty pe, material, e nvironment, a ging effect requiring management, and A MP. If there i s no corresponding A MR li ne-item in the GALL Report for a particular comb ina tion of fac tors , Co lumn 7 is left bla nk.(8)Table 1 Item
-  The eighth c olumn is a cross reference of line-items from Tabl e 2 to Table 1. Each combi nation of the following th at has an i dentified GALL Report AM R line-ite m also has a Table 1 line-item re ference number:  compo nent type, material, env ironment, aging effect requirin g management, and AMP. Col umn 8 l ists th e corre spond ing li ne-ite m from Tabl e 1. If there is no c orresponding i tem in the GALL Report Vol ume 1, Col umn 8 is l eft bl ank.(9)Notes -  The ninth colu mn cont ains notes that ar e used to describe the degree of consistenc y with the AMR line-items in the GALL R eport. Notes that u se le tter de signati ons ar e stan dard notes based on the letter fr om A. Nelson, NEI, to P.T. Kuo, NRC,"U.S. Nuclear Industry's Prop osed Standard License Re newal Applicati on Format Package, Re quest NRC Con currence," dated January 24, 2003 (ML030290201).  (N ote that the staff concurred in the format of the stan dardized format for LRAs by l etter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI
[ML030990052].)  Notes that use numer ic designators are specif ic to OCGS. The letter notes are descri bed in deta il in S ection 2 of this a udit a nd rev iew report.
9 3.0.2 Aud it and Rev iew Process The project team performed the audit and r eview in accordance with the criteria defined in Revisio n 1 of NUREG-180 0, "Standard Re view Plan for Rev iew of Lic ense Renew al Applicati ons for Nuclear Power Pl ants (SRP-LR)."
Additiona l details on how the SRP-LR criteria w ere addressed are provid ed in the OC GS audit and review plan. This review process is summarize d in this section.3.0.2.1 Review of the OCGS AMPs For the OCGS AM Ps for which the appli cant claimed consistency with the AMPs i n the GALL Report, the projec t team determined consistency. The project team de termined revi ewed the OCGS AMP d escriptions and compared the ten program elemen ts for those AM Ps to the corresponding pro gram elements for the GALL Report AM Ps (Attachment 3 shows the ten aging managem ent program elemen ts from the SRP-LR). The Division of Engineering (DE) review ed and determi ned the adequac y of the appl icant's 10 CF R Part 50, Ap pendix B Program and the resul ts documented i n Section 3 of the safety ev aluation re port (SER) rel ated to the OCGS LRA.For the OCGS AM Ps that hav e one or more e xceptions and/or enhance ments, the project tea m review ed each ex ception and/o r enhancement to determine w hether the ex ception and/o r enhancement is acceptable, and wheth er the OCGS AM P, as modified by the ex ception and/o r enhan cement, wou ld ad equatel y mana ge the a ging effect s for w hich it is credi ted. In some cases, the project team identified differences that the ap plicant di d not identi fy between the OCGS AMPs credited by the appli cant and the GA LL Report AM Ps. In these c ases, the project team review ed the difference to determine w hether or not i t is acceptab le, and w hether or not the AMP, as modified by the difference, w ould adequatel y manage the a ging effects.
For those OCGS A MPs that a re not inclu ded in the GALL Report, the project team revi ewed the OCGS AMP a gainst the program el ements specified in Appendi x A.1 of the S RP-LR. The project team determin ed whethe r these OCGS AM Ps woul d manage the aging effects for w hich they are cred ited.3.0.2.2 Review of the OCGS A MR Res ults The AMRs i n the GALL Re port fall into two broad categories:
*those the GAL L Repo rt conc ludes are ad equate to mana ge aging of the co mponen ts referenced in the GALL Report, and
*those for whi ch the GALL Re port conclude s that further eval uation is recommended for certain aspects of the aging management pro cess.The project team determi ned that the OCGS AMR res ults, reported b y the appl icant to be consistent w ith the GALL R eport, are consi stent with the GALL Repo rt. The project team al so determined that the plant-specific AMR results reported by the applicant are technically acceptable a nd applic able. For A MR resul ts for which th e GALL Report recommends further evaluation, the project team re viewed the applicant's evaluation to determine whether it adequately a ddresses the i ssues for whi ch the GALL Re port recommended further evaluati on.
10 3.0.2.3 NRC-A pprov ed Pre ceden ts To help facili tate the staff's revi ew of its LR A, an appli cant may reference NRC-approv ed precedents to demonst rate that its non-GALL pro grams corres pond to reviews that the NRC has ap prove d for oth er pla nts du ring i ts rev iew of prev ious appli catio ns for l icens e rene wal. When an applicant ele cted to provi de precedent i nformation, the project team determined whether t he mate rial pres ented in t he prece dent was app licable to the applic ant's f acility, determined w hether the pla nt program was b ounded by the conditi ons for which the precedent was ev aluated and approved, and determined that the pla nt program containe d the program elements of the reference d precedent. In general, if the pro ject team determined that these conditions were satis fied, it used th e information in the precedent to frame and focus its review of the a ppli cant's progra m.It is i mportan t to no te that prece dent i nformati on is not a part of t he LRA; it i s supp lement ary in form ati on vo lu nta ril y p rov id ed by the ap pl ica nt a s a rev ie we r's ai d. The ex ist enc e o f a preced ent, i n and of itsel f, is no t a suffic ient b asis t o acce pt the appli cant's progra m. Rath er, the precedent facilitat es the review of the substance of the ma tters described in the applicant's program. As such, i n the appli cant's documen tation of its programs that are based on preced ents, t he pre ceden t informa tion i s typ ical ly i mplic it in the ev aluat ion ra ther th an ex plic it. If the pr oject te am dete rmined that a prece dent i denti fied by the ap plic ant is not ap plic able to the pa rticul ar pla nt progr am for w hich it is credi ted, i t may h ave r eferred the pro gram to NRR/DE for rev iew in the tradition al manner, i.e
., as described in the SR P-LR, wi thout consideratio n of the precedent information.
AmerGen chose no t to use preced ent information to support its sel ection of OCGS aging management programs.
3.0.2.4 Updated Final Safety Analysis Review Supple ment Consistent w ith the SRP-LR, for the AM R results and associated AMPs that it review ed, the project team also review ed the Update d Final S afety Analy sis Revi ew (UFSA R) supplement that summarizes the applican t's programs and a ctivitie s for managing the effects of aging for the perio d of ex tended opera tion, as requi red by 10 CF R 54.2 1(d).3.0.2.5 Documentation a nd Documents Reviewed In performing its w ork, the project team rel ied heav ily on the OCGS LRA, th e SRP-LR, an d the GALL R eport. The pro ject tea m also revi ewed the ap plic ant's AMP bases docume nts (a catalog of the docu mentation used by the app licant to de velop or justify its AM Ps), and other on-site documen ts, includi ng selected i mplementing documen ts, to determine w hether the applicant' s activiti es and programs w ill adequate ly manage the effects of aging on SCs.
Any disc repancies or issues dis covered duri ng the audit an d review that required a formal response on th e docket are docu mented in thi s audit and review report. If an issu e was no t docketed or wa s not resolv ed prior to i ssuing this au dit and rev iew repo rt, an RAI w as prepared by th e proje ct team descri bing th e issu e and the in formatio n need ed to d ispos ition the i ssue. The RAI, if needed , is inclu ded and di spositioned in the SE R related to the OCGS LRA.
The list of RAIs associate d with th e audit and review is provi ded in Attac hment 4 to this audit and revi ew re port.
11 Attachment 5 chara cterizes the nature and e xtent of the projec t team's revi ews of the applicant's documents, and lists the docum ents reviewed by the project team. During its audit and revie w, the projec t team also con ducted detail ed discussi ons and in terview s with the applicant' s license renewal project personnel and other pe rsonnel w ith technica l experti se relev ant to aging ma nagemen t.3.0.2.6 Commitments To Be Included in the Safety Evalua tion Report During the audi t and revi ew, the proje ct team requested add itional i nformation to resol ve issues related to the content of the LRA. In respondi ng to these requests for ad ditional information, the applica nt, in some cas es, committed to su pplement its LRA to correct entries or imp lement additional activiti es, as needed , to appropriate ly manage agin g of the various SSCs wi thin the scope of license renewal. A list of these commit ments is included in Attachment 6 of this audit and re view report.3.0.2.7 Exit Meeting The project team hel d a publi c exit meeti ng with the applicant o n April 20 , 2006, to di scuss the resul ts of its audi t and r evie w of th e AM Ps and AMR resul ts assi gned to the pr oject te am. These discussions ref lected the project team
's work and its results, as documented in this audit and re view report.3.0.3 OCGS A ging Ma nageme nt Pro grams The project team's a udit and rev iew acti vities for the OCGS AMPs and its con clusions regarding these programs are docum ented below. The audit and review was performed in accordance with the guidance contained in the OCG S audit and review plan, as summarized in Secti on 3.0.2 of thi s audi t and r evie w rep ort.Table 3.0.3-1, OCGS Aging Management Programs, presents the AMPs cred ited by th e applicant a nd described in Append ix B of the LRA. The tabl e also in dicates the S SCs that credit the AM Ps and the GAL L AMP from w hich the app licant cla imed consiste ncy. The secti on of the audit and review report in which the project team's evaluation of the program is documented als o is prov ided.Table 3.0.3-1 OCGS A ging Management Programs (1)OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, and I W D (B.1.1)Co nsis tent w ith excepti on and enhancement XI.M1, ASME Secti on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D Reactor Vessel , I nter nals, and Reactor Coolant Sys.En gine ered Saf ety Features Auxil iar y Sy stems Steam and Power Conversi on Syst em 3.0.3.2.1 OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion 12 W ater Chem istry (B.1.2)Co nsis tent w ith excepti ons XI.M2, Water C he m istr y Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Features Auxil iar y Sy stems 3.0.3.2.2 Reactor Head Closure Studs (B.1.3)Co nsis tent w ith excepti on XI.M3, React or Head Closure Studs Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.3 BW R V ess el ID Att achment W elds (B.1.4)Co nsis tent w ith excepti ons XI.M 4, BW R V ess el ID Att achment W elds Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.4 BW R Feedwater Nozzl e (B.1.5)Co nsis tent w ith excepti on and enhancement XI.M5, BW R Feedwater Noz zl e Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.5 BW R Control Rod Driv e Return L ine Nozzl e (B.1.6)Co nsis tent w ith excepti ons XI.M6, BWR Control Rod Drive Return Li ne N ozz le Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.6 BW R Stress Corrosi on Cracking (B.1.7)Co nsis tent w ith excepti ons (3)and enhancement (2)XI.M7, BWR Stress Corrosi on Cracking Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.7 BW R Penetrat ions (B.1.8)Co nsis tent w ith excepti on XI.M8, BW R Penetrat ions Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.8 BW R Ve ss el In ter na ls (B.1.9)Co nsis tent w ith excepti ons and enh anc em ents XI.M9, BWR Vessel Inte rn als Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.9 Thermal Aging and Neutron I rradi ati on Em bri tt lement of Cast Austeni ti c Stai nless Steel (CASS) (B.
1.10)Consist ent XI.M13, Thermal Aging and Neutron Ir radi ati on Em bri tt lement of Cast Austeni ti c Stai nless Stee l (CASS)Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.1.1 Flow- Accel erat ed Corrosi on (B.1.11)Consist ent XI.M17, Fl ow-Acceler ated Corr osion Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Features Steam and Power Conversi on Syst em 3.0.3.1.2 OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion 13 Bo lting Integ rity (B.1.12)Co nsis tent w ith excepti ons XI.M18, Bolt ing Integ rity Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Feature Syst ems Auxil iar y Sy stems Steam and Power Conversi on Syst em 3.0.3.2.10 Open-Cycl e Cooli ng W ater Syst em (B.1.13)Co nsis tent w ith enh anc em ents X I.M 20 , O pe n-C ycle Cooli ng W ater Syst em Auxil iar y Sy stems 3.0.3.2.11 Closed-Cy cle Cool ing W ater Syst em (B.1.14)Co nsis tent w ith excepti on X I.M 21 , C los ed-C ycle Cooli ng W ater Syst em Auxil iar y Sy stems Steam and Power Conversi on Syst em 3.0.3.2.12 Borafl ex Rack Managem ent Program (B.1.
15)Co nsis tent w ith excepti on XI.M22, Borafl ex Monitor ing Auxil iar y Sy stems 3.0.3.2.13 Inspect ion of Overh ead H eavy Load and Li ght Loa d (R elated to Refueli ng) Handl ing Syst ems (B.1.16)
Co nsis tent w ith excepti ons (3)and enh anc em ents XI.M23, Inspect ion of Overhead Heavy Load and Li ght Loa d (R elated to Refueli ng) Handl ing Syst ems Auxil iar y Sy stems 3.0.3.2.14 C om pr es se d A ir Monitor ing (B.1.17)Consist ent XI.M24, Com pressed Air Monitor ing Auxil iar y Sy stems 3.0.3.1.3 BW R Reactor W ater Cleanup Sy stem (B.1.18)Co nsis tent w ith excepti on XI.M25, BW R Reactor W ater Cleanup Syst em Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.15 Fire Protect ion (B.1.19)Co nsis tent w ith excepti on and enh anc em ents XI.M26, Fire Protect ion Auxil iar y Sy stems 3.0.3.2.16 Fire W ater Syst em (B.1.20)Co nsis tent w ith enh anc em ents XI.M27, Fire W ater Syst em Auxil iar y Sy stems 3.0.3.2.17 Aboveground Outd oor Tanks (B.1.21)Co nsis tent w ith excepti on XI.M29, Aboveground Carb on St eel Tanks Auxil iar y Sy stems 3.0.3.2.18 Fuel Oil Chem istry (B.1.22)Co nsis tent w ith excepti ons (2)and enh anc em ents X I.M 30 , Fu el O il Chem istry Auxil iar y Sy stems 3.0.3.2.19 OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion 14 Reactor Vessel Survei ll ance (B.1.23)Co nsis tent w ith enhancement XI.M31, Reactor Vessel Sur vei ll ance Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.20 One-Time Inspecti on (B.1.24)Co nsis tent w ith excepti ons (2)X I.M 32 , O ne-T im e Inspect ion Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Feature Syst ems Auxil iar y Sy stems Steam and Power Conversi on Syst ems Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.1.4 Select ive Leachi ng of Materi als (B.1.25)Consist ent XI.M33 , Selective Le ac hin g o f M ate ria ls Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Feature Syst ems Auxil iar y Sy stems 3.0.3.1.5 Buri ed Pipi ng Inspect ion (B.1.26)Co nsis tent w ith excepti ons and enh anc em ents XI.M34, Buri ed Pipi ng and Tanks Inspect ion Auxil iar y Sy stems 3.0.3.2.21 AS ME Sec tion X I, Su bse ction IW E (B.1.27)Co nsis tent w ith excepti on XI.S1, ASME Section XI, S ubs ection IW E Reactor Vessel , I nter nals, and Reactor Coolant Sys.En gine ered Saf ety Features Auxil iar y Sy stems Steam and Power Conversi on Syst em 3.0.3.2.22 AS ME Sec tion X I, Su bse ction IW F (B.1.28)Co nsis tent w ith excepti on and enh anc em ents XI.S3, ASME Section XI, Subs ect io n I W F Contai nment Struct ures and Co m pon ent S upp orts 3.0.3.2.23 10 CFR Part 50, Appendix J (B.1.29)Consist ent XI.S4, 10 CFR Part 50, Appendix J Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.1.6 M as on ry W all Program (B.1.
30)Consist ent X I.S 5, M as on ry W all Program Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.1.7 OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion 15 Struct ures Monit ori ng Program (B.1.
31)Co nsis tent w ith excepti ons (2)and enhancement (2)XI.S6, Struct ures Monitor ing Pr ogram Reactor Vessel , I nter nals, and Reactor Coolant Syst ems En gine ered Saf ety Features Auxil iar y Sy stems Steam and Power Conversi on Syst em Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.2.24 RG 1.127, I nspecti on of W ater-Contr ol Struct ures Associ ated W it h Nuclear Power Plant s (B.1.32)Co nsis tent w ith enh anc em ents XI.S7, RG 1.127, Inspect ion of W ater-Contr ol Struct ures Associ ated wit h Nuclear Power Plan ts Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.2.25 Protect ive Coati ng Monitor ing an d Mainten ance Program (B.1.
33)Consist ent XI.S8, Protective Coati ng Monit ori ng and Mainten ance Program Contai nment, Str uctur es and Co m pon ent S upp orts 3.0.3.1.8 Elect ri cal Cabl es and Connecti ons Not Subj ect to 10 CFR 50.49 Env ir onmental Quali fi cati on Re quire m ents (B.1.34)Consist ent XI.E1, Elect ri cal Cables and Connecti ons Not Subj ect to 10 CFR 50.49 Env ir onmental Quali fi cati on Re quire m ents Elec trical C om pon ents and Syst ems 3.0.3.1.9 Elect ri cal Cabl es and Connecti ons Not Subj ect to 10 CFR 50.49 Env ir onmental Quali fi cati on Requirements Used in I nstru mentati on Circui ts (B.1.35)Co nsis tent w ith enh anc em ents XI.E2, Elect ri cal Cables and Connecti ons Not Subj ect to 10 CFR 50.49 Env ir onmental Quali fi cati on R eq uir em en ts U se d in Inst rumentati on Circ uits Elec trical C om pon ents and Syst ems 3.0.3.2.26 Inaccessi ble Medi um Volt age Cables Not Subj ect to 10 CFR 50.49 Env ir onmental Quali fi cati on Re quire m ents (B.1.36)Co nsis tent w ith enhancement (2)X I.E 3, In ac ce ss ible Medium Voltage Ca bles No t Sub ject to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents Elec trical C om pon ents and Syst ems 3.0.3.1.10 OCGS AMP (LRA Sect ion)GAL L R epo rt Compari son GALL Report AMP(s)
OCGS LRA Sys tems or Stru ctu res th at C red it t he A MP Project Te am's Eval uati on Sect ion 16 Peri odic Test ing of Contai nment Spray Nozzl es (B.2.1)N/A Oyster Creek plant-speci fi c program En gine ered Saf ety Features Syst ems 3.0.3.3.1 Lu br ica ting O il Monitor ing Act ivi ti es (B.2.2)N/A Oyster Creek plant-speci fi c program Auxil iar y Sy stems 3.0.3.3.2 Generator Stat or W ater Chem istry Acti vit ies (B.2.3)N/A Oyster Creek plant-speci fi c program Auxil iar y Sy stems 3.0.3.3.3 Peri odic I nspecti on of Venti lat ion Sy stems (B.2.4)N/A Oyster Creek plant-speci fi c program En gine ered Saf ety Features Syst ems Auxil iar y Sy stems 3.0.3.3.4 Peri odic I nspecti on Program (B.2.
5)N/A Oyster Creek plant-speci fi c program Steam and Power Conversi on Syst em 3.0.3.3.5 W ooden Uti li ty Poles Program (B.2.
6)N/A Oyster Creek plant-speci fi c program Elec trical C om pon ents and Syst ems 3.0.3.3.6 Peri odic Moni tori ng of Com busti on Turbin e Power Pla nt (B.2.7)N/A NA None - thi s AMP was dele ted b y the ap plican t.3.0.3.3.7 Metal Fati gue of Reactor Cool ant Pressu re Bound ary (B.3.1)Co nsis tent w ith enh anc em ents X.M1, Metal Fati gue of Reactor Cool ant Pressu re Bound ary Reactor Vessel , I nter nals, and Reactor Coolant Syst ems 3.0.3.2.27 Envir onmental Qua l i fi ca t i on (EQ)Program (B.3.
2)Consist ent X.E1, Envi ronmental Quali fi cati on (EQ) of Elec trical C om pon ents Elec trical C om pon ents and Syst ems 3.0.3.1.11 Notes: (1)Aging management programs for t he Oyster Creek stat ion bl ackout sy stem Forked River combustion t urbi ne power pl ant, radi o comm unicat ions sy stems, and meteorol ogical towe r are add res sed in Attac hm ent 7 to this a udit an d rev iew re port.(2)Excepti on(s) and/or enhancement(s) wer e added based on t he appl icant's r econcil iat ion of t he agi ng managem ent pr ograms in t he draft January 2005 GALL Report wi th t he app rove d Se ptem ber 2 005 GA LL R epo rt.(3)Excepti on(s) and/or enhancement(s) wer e dele ted based on the ap pli cant's reconci li ati on of t he agi ng managem ent pr ograms in t he draft January 2005 GALL Report wi th t he app rove d Se ptem ber 2 005 GA LL R epo rt.
17 3.0.3.1 OCGS AMPs That A re Consistent with the GALL Repo rt 3.0.3.1.1 Thermal Aging and Neut ron Irradiation Embritt lement of Cast Austenitic Stainless S teel (OCGS AM P B.1.10)In the OCGS LRA , Appendix B, Section B.1.10, the appl icant stated th at OCGS AMP B.1.10,"Thermal Aging and N eutron Irradiati on Embrittlement of Cast Austeniti c Stainless Steel (CASS)," is a new pl ant program that w ill be c onsistent w ith GALL AM P XI.M13, "Thermal Aging and Ne utron I rradia tion E mbrittl ement o f Cast A usteni tic St ainl ess St eel (C ASS)." 3.0.3.1.1.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program wi ll provi de for aging management of CASS reactor internal comp onents wi thin the scop e of license renewal. The program wil l be implemented pri or to the peri od of extended operation.
The applican t also stated that the program w ill inc lude a compo nent specific e valuatio n of the loss o f fracture toughne ss. A suppl emental insp ectio n wi ll be performe d for tho se comp onents where loss of fractur e toughness may aff ect the function of the component, using the cr iteria provided in GALL AMP XI.M13. This inspection will ensure the integrity of the CASS components ex posed to the h igh temperature and neutron fluence present in the reactor envi ronmen t.3.0.3.1.1.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B.1.10 is consis tent with GALL AMP XI.M 13.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.10, includin g PBD-AMP-B.1.10, "Thermal Agin g and Neutron Irrad iation Embri ttlement of Cast Austenitic S tainless Ste el," Rev. 0 , which provides an assessment of the AMP el ements'consistency with GALL AMP XI.M 13. Specifica lly, the project team revi ewed the program elements (see S ection 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.10 and associa ted bases doc uments to determine their consi stency w ith GALL AM P XI.M13.The project team rev iewed th ose portions of the applica nt's Thermal Agin g and Neutron Irradiation E mbrittlement of Cast A ustenitic Sta inless Stee l (CASS) for w hich the app licant claims consi stency w ith GALL AM P XI.M13 and found that they are consiste nt with th is GALL Report AM P. The project team found that the app licant's The rmal Aging and N eutron Irradiation E mbrittlement of Cast A ustenitic Sta inless Stee l (CASS) pro gram conforms to the recommended GALL A MP XI.M1 3.3.0.3.1.1.3 Exce ption s to th e GALL Repor t None 3.0.3.1.1.4 Enhan cements None 18 3.0.3.1.1.5 Operating Expe rience The applican t stated, in the OCGS LRA, that the aging management program for Thermal Aging and Neutron Irradiation Embrittlement of Cas t Austenitic Stainless S teel (CASS) is a new program, and therefore, no programmatic operatin g experience exists.In PBD B.1.10 , the appli cant stated that re search data on both labora tory-aged and servi ce-aged materi als h as con firmed th at los s of fractu re tough ness c ould occur i n some reactor vessel CASS internal components.
Oyster Creek internal reactor vessel CASS components are p eriodicall y exami ned, but no d egradation has been identi fied to date. Si nce the thermal aging and neut ron irradiation embrittlem ent of CASS aging manag ement program is a new pro gram, a review of plant operati ng experienc e cannot confirm a t this time that loss of fracture toughn ess of c ast au steni tic sta inle ss stee l is a factor.The Oyster Creek  th ermal aging and n eutron irradia tion embrittle ment of CASS aging manageme nt progr am wi ll i nclud e a co mponen t speci fic ev aluat ion to asses s the s uscept ibil ity for the loss of fracture toughne ss. This ev aluation w ill be p erformed prior to the period of exten ded op eratio n. A s upple mental insp ectio n wi ll be performe d for tho se comp onents whe re loss of fractu re toughness may aff ect function of the component, using the cr iteria provided in NUREG-1801 A ging Management P rogram, XI.M13. This i nspection w ill ensu re the integrity of the CASS co mponents exp osed to the hi gh temperature and n eutron fluence pre sent in the reacto r env ironme nt.The project team als o review ed the operati ng experienc e provide d in the ba sis document, a nd interv iew ed the appl icant's tech nical staff to c onclu de tha t no i ndustr y ope rating expe rienc e wi th thermal aging and embrittlement of CAS S has emerged.
The staff believes that the correctiv e action proc ess wil l capture in ternal and e xternal pl ant operating issue s to ensure tha t aging effects are adequately managed.3.0.3.1.1.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the thermal aging and neutron irradi ation embrittlement of cast austenitic stainless steel (CASS) prog ram in OCGS LRA, Appendix A, Section A.1.1 0, which states that the the rmal aging and ne utron irradiati on embrittlement of cast austeniti c stainless steel (CASS) program is a new program that wi ll provi de for aging management of CASS reactor internal components within the scope of license renewal.
The applican t also stated that the program w ill be i mplemented prio r to the perio d of extended operat ion. The pro gram wi ll i nclud e a co mponen t speci fic ev aluat ion o f the lo ss of frac ture toughness in ac cordance w ith the criteri a specified i n GALL AM P XI.M13. Fo r those compon ents w here l oss of fra cture t oughne ss may affect func tion o f the com ponen t, a supplemental inspection will be performed. T his inspection will ensure the integrity of the CASS components ex posed to the h igh temperature and neutron fluence present in the reactor envi ronmen t.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, an d confirmed that thi s program is ide ntified as a n ew program that w ill be implemented pri or to the peri od of extended operation a s item 10 of the c ommitments.
19 The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.10 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.1.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team determined th at all the pro gram elements are co nsistent w ith the GALL R eport. On the basi s of its revi ew of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.1.2 Flow-Acce lerated Corrosi on (OCGS AM P B.1.11)In OCGS LRA, Ap pendix B , Section B.1
.11, the appli cant stated that OC GS AMP B.1.11,"Flow-Acce lerated Corrosi on," is an ex isting plant program that is cons istent wi th GALL AMP XI.M1 7, "Fl ow-A ccele rated C orrosi on." 3.0.3.1.2.1 Program Descriptio n The applicant stated, in the OCG S LRA, that this program is based on EPRI g uidelines in NSAC-202L-R2, "R ecommen datio ns for an Effectiv e Flo w Ac celer ated C orrosi on Pro gram,"April 1999. The pr ogram predict s, dete cts, an d monito rs wall thinn ing in pipin g, f itting s, valve bodie s, and feedw ater he aters d ue to F low-Accel erated Corro sion (FAC).The applican t also stated that analy tical ev aluations a nd periodi c examinati ons of location s that are most suscepti ble to w all thinn ing due to FA C are used to predict the a mount of wall thinning in pipes, fittings, and feedwa ter heater shel ls. Program activ ities incl ude analy ses to determine critical l ocations, base line ins pections to d etermine the ex tent of thinning at these critical locations, a nd follow-u p inspectio ns to confirm the p redictions.
Inspections are performed using ultrasonic, radiograph ic, visual or other approved testing techniqu es capable of detecting wall thinning. Repairs and replac ement s are per form ed as nece ssary.3.0.3.1.2.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B.1.11 is consis tent with GALL AMP XI.M 17.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.11, includin g program basis docu ment PBD-AM P-B.1.11,"Flow-Accelerated C orrosion," Rev. 0, whi ch pro vide s an a ssessme nt of the AMP eleme nts' co nsiste ncy w ith GA LL AM P XI.M 17. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.11 and a ssoci ated b ases d ocumen ts to determine consi stency w ith GALL AM P XI.M17.Also, the project team r eviewed OCGS document Number ER-AA-430, "Cond uct of FAC Activiti es," Revis ion 1, w hich is a procedure for establ ishing, control ling, updatin g, and documenting FAC programs.
20 The project team rev iewed th ose portions of the applica nt's Flow-Accelerated C orrosion program for which th e applica nt claims con sistency w ith GALL AM P XI.M17 and found that they are consistent with this GALL Report AMP. The project team found that the applicant
's Flow-Acce lerated Corrosi on program conforms to the recommended GALL A MP XI.M1 7.3.0.3.1.2.3 Exce ption s to th e GALL Repor t None 3.0.3.1.2.4 Enhan cements None 3.0.3.1.2.5 Operating Expe rience The applican t stated, in the OCGS LRA, that operating exp erience of Flo w-Accelera ted Corrosion agin g management program activ ities has s hown that the program can dete rmine susceptible locations for flow accele rated corrosion , can predict the component de gradation, and can detec t the wal l thinnin g in pipin g, valves, and other compon ents (such as th e feedwater heater shell s) due to flow-accelerated co rrosion. In ad dition, the program provides for reevaluati on, repair or replacement for lo cations w here calcul ations indi cate an area w ill reach minimum allo wable th ickness before the n ext inspe ction. Peri odic self asse ssments of the program h ave b een pe rformed w hich have iden tified oppor tuniti es for pr ogram im prove ments. In 2000, insp ections of the "C
" feedpump minimum rec irculation line show ed that seve ral 90-degree elbow s experie nced significan t wear. Si milar wea r was found o n several 45-degree elbows. As a result of these inspecti ons, approxi mately 25 feet o f 4" pipe, one 9 0-degree elbow, and three 45-degree elbows were replaced with chrome-moly mater ial.The app lica nt stat ed in the ba sis do cument that du ring Cy cle 1 7, UT In specti ons w ere performed on the high-p ressur e (HP) feedw ater he ater (F WH) shells. These insp ectio ns we re driven by the Point B each FWH shell rupture e vent and o ther industry experien ce as describ ed in SEN 19 9, "Feedwa ter Heater Shel l Rupture," an d NRC Information Notice (IN) 99
-19,"Rupture of the She ll Side of a Feedwate r Heater at the Point Beach Nuclear Pl ant."  Results of the inspections showed wall thinning on all three HP FWH shells. Two areas on the "
A" HP FWH required immedi ate rep air. Ot her id entifi ed degr adati on w as ev aluat ed and determ ine to be acceptabl e through the remai nder of the operati ng cycle at which ti me further inspectio ns and repairs w ere performed. There hav e been a nu mber of steam leaks asso ciated wi th flash tank and drain tank pi ping a nd atta ched p ipin g. How ever, there have been some ca ses w here leaks did occ ur that were not predicted.
As a resul t of these pipe failures, the FA C program was modified to more accuratel y predict that wall thinning w as occurring. The experience at Oyster Creek with the FAC program shows that the FAC program is eff ective in managing FAC in hi gh-ener gy carb on ste el pi ping a nd comp onents. Two defici encie s in t he pro gram we re identified:  1) The System Su sceptibili ty Eval uation did not meet EPRI or procedural recommendations and 2) plant model input to the FAC Program sof tware tool, CHECW ORKS, contai ned a number of error s and omissi ons. Th ese de ficien cies w ere id entifi ed as the pri mary reasons the FAC program has missed identifying component s that developed leaks as a result of Flow Accel erated Corro sion. A FA C progra m impro vemen t proje ct wa s impl emented to correct the defici encies. The p roject was co mpleted durin g August 2003. As a result of the improvement pro ject, the risk of a FAC failure in u nidentified s usceptible lines has been reduced.
21 The project team recogni zed that the corrective action program, w hich captures internal an d external p lant operatin g experience issues, w ill ensu re that operatin g experience is revi ewed and incorpora ted in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.The project team als o review ed the operati ng experienc e provide d in the OCGS LRA, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staf f, the project team determined that th e applicant's Flow-Accel erated Corro sion program w ill adequa tely manage the agi ng effects that ar e identified i n the OCGS LRA for which th is AMP is credited
.3.0.3.1.2.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Flow-Accelerated Corrosion program in OCGS LRA, Appe ndix A, S ection A.1.11, which sta tes that the Fl ow-Accele rated Corrosion program  is an ex isting program based on EPRI gui delines i n NSAC-202L-R2,"Recommendations for an Effective Fl ow Accel erated Corrosio n Program," April 1999. The program predicts, dete cts, and monitors wall thinning in piping, fittings, v alve bod ies, and Feedwater Heaters due to FAC. Anal ytical e valuatio ns and perio dic exami nations of loca tions that are most suscept ible to wall thinning due to FAC are used to predict the amount of wall thinn ing in pipe s, fitti ngs, and Feedw ater He ater sh ells. Progra m activ ities incl ude an alys es to determine criti cal locati ons, baseli ne inspecti ons to determine the extent of thinning at thes e critical l ocations, and follow-up inspections to confirm the pred ictions. R epairs and replace ments are perf ormed as necess ary.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.11 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.2.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team determined th at all the pro gram elements are co nsistent w ith the GALL R eport. On the ba sis of its rev iew of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.1.3 Compressed Ai r Monitori ng (OCGS AMP B.1.17)In OCGS LRA, Ap pendix B , Section B1
.17, the appli cant stated that OC GS AMP B 1.17,"Compressed Ai r Monitori ng," is an ex isting plant program that is cons istent wi th GALL AMP XI.M2 4, "Co mpresse d Air Moni toring." 3.0.3.1.3.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program is w ithin the sp ecified limi ts for the portions of the i nstrument air sy stem withi n the scope o f license renew al. Activ ities consi st of yearly air quality monitoring, pressu re decay tes ting at interv als not ex ceeding five years and 22 visual inspections. The activities are consistent with the Oyster Creek response to NRC Generic Letter (GL) 8 8-14, "Instrument Ai r Supply Problems" and utilize guidance and standards prov ided by INPO SOER 88-01 , EPRI TR-10814 7 and ASM E OMS/ G-1998 , Part 17.
Testing and monitori ng activiti es are imple mented through statio n procedures.
3.0.3.1.3.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B1.17 is consis tent with GALL AMP XI.M 24.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B1.17, includin g program basis docu ment PBD-AM P-B.1.17,"Compresse d Air M onitoring," Rev. 0, whi ch pro vide s an a ssessme nt of the AMP eleme nts' co nsiste ncy w ith GA LL AM P XI.M 24. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B1.17 and a ssoci ated b ases d ocumen ts to determine thei r consistency with GALL AMP XI.M 24.The p roje ct te am al so re vie wed SDB D-0C-852 , Re v. 3. "Pl ant C ompr esse d Ai r Sy stem Des ign Basis Docum ent," a nd the appl icant's res ponse s to GL 88-14 to dete rmine consi stency wit h GALL AMP XI.M24.The project team rev iewed th ose portions of the applica nt's Compressed Air Mo nitoring aging management program for whi ch the appli cant claims c onsistency with GALL AMP XI.M 24 and found that they are consistent with thi s GALL Report A MP. The pro ject team found that the applicant' s Compressed A ir Moni toring aging management pro gram conforms to the recommended GALL A MP XI.M2 4.3.0.3.1.3.3 Exce ption s to th e GALL Repor t None.3.0.3.1.3.4 Enhan cements None.3.0.3.1.3.5 Operating Expe rience In the OCGS LRA, the applicant state d that the reliability of the Oyster Creek instrument air syste m has i mprov ed si nce th e impl ementat ion o f GL 88-1 4 acti viti es and indu stry gu idanc e. The Compressed A ir Moni toring program has imp lemented new industry air quality standard, ISA-S7.0.01-1996, consistent with NUREG-1801 and replacement dryers have increased air quality as indicated b y air qual ity test resu lts and dew point monitori ng In its design basis documen t for the Compressed Air Mon itoring aging management program (PDB-AMP-B.1.17), the applicant stat ed that operating experience, bot h internal and external, is used to enhan ce plant programs, p revent repea t events, and prevent ev ents that hav e occurred at other plants from occurring at Oyste r Creek. The appl icant further stated that its process for managing programs requires th e review of program related op erating experi ence by th e program o wner. Ext ernal opera ting ex perie nce may incl ude su ch thi ngs as I NPO do cuments (e.g., SOERs, SERs, S ENs, etc.), NRC documents (e.g., GLs, LE Rs, INs, etc.), Genera l
23 Electric doc uments (e.g., RCSILs, S ILs, TILs, etc.), and oth er documents (e.g., 10 CFR Part 21 Reports, NERs, etc.). Internal o perating expe rience may include su ch things as ev ent investigations, trending reports, and lessons learned f rom in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction proces s. Issu es and even ts, wh ether e xtern al or plant-speci fic, tha t are p otenti ally signi ficant t o the Compressed Air Monitoring prog ram at OCGS are evaluated. The Com pressed Air Monitori ng program is augmented, a s appropriate, if these eval uations show that program changes are need ed to enhance program effectiveness.
The applicant stated in PDB-AMP-B.1.17 that oper ating experience of GL 88-14 act ivities did not sh ow a ny ad verse trend in pe rformance. In th e OCGS LRA, t he app lica nt stat ed tha t, consistent w ith NUREG 1 801, the Compres sed Air M onitoring program ha s implemented new industry air quality standard, ISAS7.0.
01- 1996, and replacement dryers have increased air qual ity as i ndi cate d by air qual ity test resu lts and dew poi nt mo nito ring.The project team als o review ed the operati ng experienc e provide d in the OCGS LRA, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staf f, the project team determined that th e applicant's Compressed Air Moni toring program w ill adequa tely manage the agi ng effects that ar e ide ntifie d in t he OCGS LRA for whi ch this AM P is credi ted.3.0.3.1.3.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Compressed Air Monitoring progr am in OCGS LRA, Appe ndix A, S ection A.1.17, which sta tes that the Comp ressed Air M onitoring aging management program is an existi ng program that consists of inspection, monitoring, and testing; includ ing (1) pressure d ecay testin g and visua l inspecti ons of system compo nents; and (2) preventi ve monitori ng that checks air qual ity at v arious loca tions in the system to ens ure that dew point, particulates, and suspended hydrocarbons are kept within the specified limits. This program is consis tent with responses to N RC GL 88-14 a nd incorporate s ISA-S7.0.01-19 96,"Quali ty Sta ndard for Instr ument A ir." The project team rev iewed th e UFSAR S upplement OCGS A MP B1.17 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.3.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team that all the program elements are consistent w ith the GALL R eport. . On the b asis of its rev iew of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descrip tion of the program, as required by 1 0 CFR 54.21 (d) 24 3.0.3.1.4 One-Time Inspection (OCGS AMP B.1.24)In OCGS LRA, Ap pendix B , Section B.1
.24, the appli cant stated that OC GS AMP B.1.24,"One-Time Inspection
," is a new plant program that will be consisten t with GALL AMP XI.M 32,"One-Tim e Insp ectio n." 3.0.3.1.4.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program wi ll provi de reasonabl e assurance tha t an aging effect is not o ccurring, or that the aging effect is occurrin g slowly enough to not a ffect the component or structure intende d function duri ng the period o f extended ope ration, and therefore wil l not require a dditional aging management. The pro gram will be credited for ca ses wher e eith er (a) a n agin g effect is not ex pected to occ ur but there i s insu fficient data t o completely rule it ou t, (b) an aging effect is ex pected to progress very sl owly in the speci fied environment, but the local environmen t may be more adverse than that generally expected, o r (c) the characteri stics of the aging effect inc lude a lo ng incubation period. This program wil l be used for th e fol low ing:*To confi rm crack i nitia tion a nd grow th due to stre ss corr osion cracki ng (SCC), intergranular str ess corrosion cracking (IGSCC), or therm al and mechanical loading is not occu rring in Class 1 pipin g less th an or eq ual to f our inche s nomina l pipe size (NPS 4) exp osed t o reac tor coo lant.*To confirm the effectivene ss of the water chemistry program to manage the loss of material and crack initiati on and growth aging effects.
*To confi rm the e ffective ness o f the cl osed c ycle cool ing w ater sy stem pro gram to manage t he lo ss of mat erial aging e ffect.*To confirm the effectiveness of the fuel oil chemistry program and lubricating oil monito ring ac tivi ties p rogram to manage the lo ss of mat erial aging e ffect.*To confirm loss of materia l in stai nless steel piping, pip ing components, an d piping elemen ts is i nsigni ficant i n an i ntermi ttent c onden satio n (int ernal) env ironme nt.*To confirm loss of material in steel piping, piping component s, and piping elements is insi gnifica nt in an in door a ir (in ternal) env ironme nt.*To confirm loss of materia l is ins ignificant for non-safety-related (NSR) piping, pip ing components, and piping eleme nts of vents and drains, floor a nd equipment drai ns, and other systems a nd components th at could con tain a fluid, and are in scope for 10 CFR 54.4(a)(2) for spatial interaction. The scope of the program consists of only those systems not covered by other agin g management activi ties.The applican t also stated that the new program elements i nclude: C Determination of the sample si ze based on an assessme nt of materials of fabrica tion, environment, plausibl e aging effects, and operati ng experienc e.C Identification o f the inspection locations in the sy stem or component b ased on the a ging effect.
25 C Determination of the examinati on technique, i ncluding acce ptance criteri a that wou ld be effective in managi ng the aging effect for which the component i s examined
.C Evaluation of the need for f ollow-up examinations to monitor the progres sion of aging if age related degrada tion is found that could jeo pardize a n intended function before the end of the perio d of extended operation. When evide nce of an aging effect is re vealed by a one-time inspection, the engineering evaluation of the inspection results would identify app ropriate correcti ve action s.The app lica nt furthe r state d that the in specti on samp le in clude s "wo rse cas e" one-time inspection of more susceptibl e materials i n potential ly more aggressiv e environ ments (e.g., low or stagnant flow areas) to manage the effects of aging. Examina tion methods w ill inc lude vi sual examination, VT-1 or VT-3 as appr opriate, or volumetric examinations. Accept ance criteria is based on AS ME Secti on XI, for components requi red to meet ASM E requirements, and on the design code o f record and ind ustry guidel ines for non-ASM E components.
The one-time ins pection aging mana gement program wil l be imple mented prior to the period o f extended o peration.3.0.3.1.4.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.24 is cons istent wi th GALL AMP XI.M 32.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.24, includin g program basis docu ment PBD-AM P-B.1.24, "One-Time Insp ection," Rev ision 0, w hich provi des an asses sment o f the AM P ele ments' c onsis tency wit h GALL AMP XI.M3 2. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.24 and a ssoci ated b ases d ocumen ts to determine thei r consistency with GALL AMP XI.M 32.During the audi t, the project team noted that the a pplicant di d not identi fy any ex ceptions to th e GALL AMP XI.M32 in the LRA as d escribed in program basis do cument PBD-AM P-B.1.24.In addition, the project team also reviewed the OCGS document titled "Inspection Sam ple Basis; Oyster Creek License Renewal Project," dated A ugust 16, 2005.
This document describes the process to be used in de termining the in spection sampl e populati on and loc ation for the OC GS One-Ti me Insp ectio n Progra m.In reviewing this AMP, the project team noted that T able 3.3.1, item 43, in the OCGS LRA stated that the One-Time Inspection Program will be used to verify the e ffectiveness of the Selectiv e Leaching of M aterials Pro gram; however, this intende d use is no t discussed i n the program d escrip tion. The ap plic ant w as aske d to cl arify this i ntende d use of the On e-Time Inspec tion P rogram.The ap pl ica nt s tat ed tha t th e o ne-tim e i nsp ect io n a gin g ma nag eme nt p rog ram do es n ot v eri fy the effect iveness of the selective leaching of mat erials aging managem ent program.
As described in AMP B.1.25, the selective leaching of mater ials aging managem ent program is itself a one-ti me inspection to confirm that lo ss of material du e to the sele ctive le aching aging mech ani sm i s no t occ urri ng.
26 In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to corre ct line i tem 43 in Table 3.3.1 to delete re ference to using the one-time insp ection to v erify the effectiven ess of the Se lecti ve Le achin g of Mat erial s Progra m. This is A udit Commitment 3.0.3.1.4
-1.The project team concurred with the applicant's commitment to revise line item 43 in Table 3.3.1 of the OCGS LRA to delete re ference to using the one-time insp ection to v erify the effectiveness of the S elective Leaching of M aterials Pro gram since this not one of the i ntended uses o f the One-Time In specti on Pro gram.The project team also noted in the OCGS LRA program descr iption for AMP B.1.24 that this program is new and wi ll incl ude program elemen ts to determine th e sample pop ulation si ze and location, as well as inspecti on techniques.
The applican t was asked to provide additional information on the rational to be used i n selecting the populatio n size a nd location , as wel l as the inspecti on techniques.
In its response , the appli cant stated that a n inspectio n sample basi s document has been prepared for one-ti me inspection
: s. This documen t provides information on co mponent population , sample popu lation, and expansi on criteria for the various applicatio ns of the One-Time Inspection Program. Implementati on of the one-time inspections will be through the normal maintena nce planni ng process.
The pro ject tea m revi ewed the i nspect ion s ample basis docume nt, w hich is an OCGS re port titled "Inspec tion Sample Basis, Oyster Creek License Renewal Project," dated A ugust 16, 2005, and no ted that it di d not incl ude a documen t identificati on number or ap proval si gnatures, indicating th at it was not a controll ed document. The applicant w as asked to prov ide the administrative controls that would be used to control this docum ent to ensure that the sample selec tion p rocess remai ns con sisten t wi th the recomme ndati ons i n the GA LL Rep ort.The applican t stated that the inspection sample basis document w ill be c onverted to a contro lled projec t posi tion p aper, w hich wil l be r eference d in t he pro gram bas is do cument, AMP-PBD-B.1.24. The project team determined th at convertin g this document to a position paper would provide the necessary administrative oversight to ensure that the document is properly c ontrolled.
The project team als o noted that the OCGS inspecti on sample ba sis document for A MP B.1.24 stated that the one-tim e inspection sample size for stress corr osion cracking will include only one stainle ss steel pi pe section i n a stagnant or l ow flow area > 140ºF. The applican t was asked to provi de the rationa l and justifica tion for selecti ng the number of sampl es for each aging effect. In particula r, the appli cant was a sked to discuss why on e sample of stai nless steel pipi ng was consi dered to be a n adequate popu lation for detecti ng stress corrosion crac king.The applican t also stated that the selec ted sample for one-time inspecti ons for stress corrosi on cracking wil l be revi sed in the sample basis document for AM P B.1.24 as foll ows and the implementation is being trac ked within the Amergen tracking pro cess, to be compl eted, as necessary, p rior to the pe riod of extend ed operation:
1.Two (2) stainless steel pipe sections in a stagnant or low flow area (>140ºF) in the reactor w ater cleanup system wi ll be in spected. The one-time inspecti on for cracking will be by ultrasonic testing (UT). An example of an acceptable sample 27 location i ncludes the cleanup aux iliary pump discharge l ine betw een V-16-13 a nd the 6" RWCU main process l ine.2.Two (2) stainless steel pipe sections in a stagnant or low flow area (>140ºF) in the isolati on condenser system wi ll be in spected. The one-time inspecti on for cracking wil l be by UT. Example s of acceptable sample locati ons includ e the 12" or 16" non-cla ss 1 isola tion condens er steam inle t piping. Po rtions of the 8" o r 10" condensate return line s up to the no rmally cl osed isola tion condens er condensate return valve s can also be inspected , if they are >1 40ºF.The applican t further stated that the one-time ins pections performed for the non-class 1 portio ns of the isol ation conde nser sy stem to veri fy the effectiv eness of the w ater ch emistry program to man age cracking are different inspections from those inspections perform ed in conjunction w ith ASM E Section XI, w ater chemistry, and the BWR stress corrosion cracking AMPs for RC PB pipin g, piping componen ts, and pipi ng elements. The o ne-time inspe ctions specified for the n on-RCPB porti ons of the reactor w ater cleanup system are i nspections beyo nd tho se requi red by the BWR rea ctor w ater cl eanup syste m aging ma nagemen t progra m.The project team rev iewed th e applica nt's response and determined that the rev ised inspe ction sample popul ation, wh ich wi ll now consist of tw o (2) stainle ss steel pi pe sections in a stagnant or low flow area (>140ºF), w ill prov ide multipl e data poin ts for determining w hether stress corros ion crack ing is occ urring. This will min imize the c hance of obtaining an unrepr esenta tive result for the sy stem being insp ected; therefore, the p roject team found it to be acceptabl e.The project team rev iewed th ose portions of the applica nt's One-Time Inspe ction Program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 32 and found t hat the y are consi stent w ith th e GALL Repor t AMP. The d escrip tion o f OCGS AM P B.1.24 in the OC GS LRA does not state any exceptions to AMP XI.M32 in the GALL Report. However, in their reconc ilia tion d ocumen t, the a ppli cant i denti fied th e foll owi ng exc eptio ns to t he GAL L Repo rt program. The pro ject tea m found t hat the appl icant's One-Time In specti on Pro gram con forms to th e rec omm ende d GAL L AMP XI.M32, with th e exce ptio ns de scri bed be low.3.0.3.1.4.3 Exce ption s to th e GALL Repor t Exception 1 Elements: Program Descriptio n 1. Scope of Program
: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: NUREG-1801 sta tes in XI.M32 that one-time i nspection of Cl ass 1 pipi ng less t han or equal to NP S 4 is addre ssed i n Chap ter XI.M 35. NUREG-1801 a ging management program XI.M35 , will not be used at Oyster Creek. The n ew Oyster Creek One-Time Inspecti on aging management program wi ll incl ude the one-ti me inspection of Class 1 pipi ng less than o r equal to NP S 4. This is a new exception based on the 28 reconc ilia tion o f this agin g manag ement p rogram from the draft J anuary 2005 GALL to th e approved S eptember 2005 GAL L.The GAL L Repo rt ide ntifie s the fol low ing rec ommenda tions for the "program descri ption ," "scope of program," "prev entive ac tions," "parameters monitored or i nspected," "detecti on of aging effec ts," "mon itori ng and trendi ng," and "accep tance criter ia" pr ogram el ements associated w ith the ex ception taken:
Program Descrip tion:  The program incl udes measures to verify the effectiveness of an aging ma nagemen t progra m (AM P) and confirm the i nsigni ficance of an a ging effect
.Situations in which additional confirmation is appropriate include (a) an aging eff ect is not expected to occur but the data is insuf ficient to rule it out with reasonable confidence; (b) an aging effect is expe cted to progress v ery slow ly in th e specified environment, but the local environment may be more adverse than that generally expected; or (c) the characteri stics of the aging effect inc lude a lo ng incubation period.For these case s, there is to be confirmation th at either the a ging effect is indeed not occurring, or the a ging effect is occurring v ery slow ly so as not to affect the compone nt or structure inten ded function du ring the period of extended o peration.A one-time in spection may also be u sed to provi de additio nal assuranc e that aging that has not ye t manifested itsel f is not occurrin g, or that the ev idence of aging sho ws that the aging is so insignificant th at an aging management p rogram is not w arranted. (Class 1 piping l ess than or equal to  NPS 4 is addressed in Chapter XI.M35.1. Scope of Prog ram:  The program includes m easures to verify that unacceptab le degradation is not occurring, the reby val idating the effectiv eness of exi sting AMPs or confirming that there i s no need to manage aging-related d egradation for the pe riod of extended operation. The struct ures and components f or which one-time inspection is speci fied to veri fy the effectiv eness of the A MPs (e.g., w ater ch emistry contro l, etc.)have been identified i n the GALL Re port. Exampl es include the feedwater system compon ents i n boi ling w ater re actors (BWRs) and p ressur ized wate r react ors (PWRs).
: 2. Preventive A ctions:  One-time insp ection is a n inspectio n activi ty indepe ndent of methods to mitigate or prevent d egradation.
: 3. Parameters Moni tored or Inspected
:  The program m onitors parameters directly related to the degradation of a co mponent. Inspecti on is to be performed by qual ified personnel foll owing proce dures consiste nt with th e requirements of the A merican Society o f Mechanica l Engineers (A SME) Cod e and 10 CF R Part 50, Ap pendix B , using a variety of nondestructiv e examinati on (NDE) method s, includi ng visual, volumetric, and surface techni ques.4. Detect ion o f Agin g Effec ts:  The inspecti on includ es a representa tive sampl e of the syste m popul ation , and, wher e prac tical , focuse s on th e boun ding o r lead compon ents most susceptibl e to aging due to time in serv ice, severi ty of operating co nditions, an d lowest de sign margin. The program w ill rely on establi shed NDE te chniques, incl uding visual, ultrasonic, a nd surface techni ques that are performed b y qualified personnel following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B.
The inspection and test techniq ues will have a demonstrated history of eff ectiveness in detecting the agin g effect of concern.
29 5. Monitoring and Trendin g:  The program provi des for increasi ng of the inspecti on sample siz e and loca tions in the event that aging effects are detected.
Determination of the sa mple s ize is ba sed on an as sessme nt of mate rials of fabric ation , env ironme nt, plaus ible aging e ffects, an d oper ating e xperi ence. Unacc eptabl e ins pecti on find ings ar e evaluated in accordan ce with the site correcti ve action process to de termine the nee d for subsequent (incl uding periodi c) inspectio ns and for monitori ng and trending the results.6. Acceptance Criteria
:  Any i ndication o r relevant conditions of degradation detec ted are evalu ated. For ex ample, the ul trasonic thicknes s measurements are to be compared to pr edet ermi ned lim its, suc h as the desi gn mi nimu m wa ll t hic knes s for pip ing.The app lica nt wa s asked to con firm that AMP B.1.24 in th e OCGS LRA w ill be rev ised to include thi s exceptio n.In it s let ter date d Marc h 30, 2006 (ML060950408), the ap plica nt co mmi tte d to r evise AMP B.1.24 in th e OCGS LRA to incl ude th e exc eptio n ide ntifie d in t he rec oncil iatio n docu ment, which states that the new Oyster Creek one-t ime inspection aging manag ement program will inclu de th e one-time inspe ctio n of Class 1 pipin g les s tha n or eq ual to NPS 4, and G ALL AMP XI.M35 wi ll not be used. This i s Aud it Commitment 3.0.3.1.4-2.
In re viewing this excep tion , the proj ect t eam c ompa red t he pr ogr am el emen ts f or OC GS AMP B.1.24 to those for AMP XI.M3 5 in the GALL Report to dete rmine if they were consi stent for the inspe ction of pip ing le ss than 4-inc h NPS. Spec ifical ly, s ince the se lecti on of th e one-time inspection sample popul ation for OCGS AM P B.1.24 is described i n the OCGS ins pection sample basis document, wh ich is an OCGS report title d "Inspection Sample Basi s, Oyster Creek License Renewal Project," date d August 16, 2005, the proj ect team reviewed this document to determi ne how th e small bore piping in spection sampl e populati on wil l be determined. The a ging management program in th e GALL Report, AMP XI.M 35, recommends that, for ASME Code Class 1 small bore piping, a one-time inspection using volumetric examinat ion be perf ormed on select ed weld locat ions to de tect cr acking. The sam ple size should be based on sus ceptibili ty, inspecta bility, dose consid erations, opera ting experie nce, and limiti ng locations of the total popu lation of ASM E Code Cl ass 1 smallb ore piping l ocations.The project team noted that the OCGS inspection sam ple basis document stated that sam ple size for Cla ss 1 pi ping l ess tha n 4 in ch nomi nal p ipe s ize (NPS) wil l inc lude 10% of th e total butt welds, an d inspectio n locations will be based o n physica l accessib ility, e xposure l evels, non-destructiv e examinati on (NDE) techn iques, etc., and w ill be d etermined by the site. The applicant w as asked to cla rify the process for selecting pi pe inspecti on samples to ensure that different piping siz es are incl uded in the sample sel ection for Clas s 1 pipin g less than 4 inches NPS.In its response , the appli cant stated that, b ased on the Oy ster Creek line list for reactor c oolant pressure bound ary systems, fittings less than 2.5 inches a re socket wel d ends. Fi ttings greater than or equal to 2.5 inches are butt wel d ends. The sa mple popula tion for one-time i nspection of Class 1 pi ping less tha n NPS 4 w ill, therefore, co nsist primaril y of samples greate r than or equal 2.5 inc hes and le ss than 4 in ches.The project team reviewed the applicant's response and determined that the inspect ion sample population would be limited to piping greater than 2.5 inches; therefore, it would include only butt weld ed piping. The project team found the applican t's approach for selecting the 30 inspe ction sampl e popu latio n unac ceptab le si nce i t did not ad dress h ow a ging of no n-butt welded piping less than NPS 4 would be managed. The ap plicant w as asked to prov ide additional information on how the sample selection proce ss will ensure that samples of all different pipe sizes less than NPS 4 are inspected. Specifically, the applicant was asked if there are any Class 1 p ipes less than NPS 4 in the scope of this AM P that are not butt weld ed (e.g., socket welde d), and how these non-butt welded pipes w ould be i nspected. The pro ject team also asked th e applica nt to provi de information on Oyster Creek's operating exp erience with Cl ass 1 pipi ng less than N PS 4.In i ts re spon se, t he a ppl ica nt st ated the foll owi ng: a) The o ne-tim e ins pecti on for C lass 1 pipi ng, pip ing com ponen ts, and pipi ng ele ments for cracking initiati on and growth due to thermal and mechani cal loadi ng, stress corros ion crack ing, an d interg ranular stress corros ion crack ing inclu des a repr esenta tive sample of the susc eptible i tems, and, whe re practical, focuses on the bo unding or lea d items most suscepti ble to cracking d ue to time in service, s everity of operating conditions, or lowest design margin. Ap plying AS ME Code Case N-578-1 , "Risk Informed Req uirements for Class 1, 2, or 3 Piping, Method B Section XI, Division 1" is one met hod ot her ap plic ants h ave u sed for d etermi ning sa mple s ize for one-time inspe ction s. With this method , butt w elds are ev aluat ed bas ed on risk an d "bin ned" i nto high, medium, and low ri sk categories. The sel ected sample for o ne-time inspe ction volu metric exami natio n then incl uded 1 0% of the high a nd medi um risk butt w elds. Oyster Creek; however, has not emplo yed risk inform ed ISI an d does not curren tly have a risk based evaluation that categor izes the Class 1 butt welds into risk categories. This evaluati on is ex tensive a nd to perform this e valuatio n at this time is not practi cal, so ASME Code Case N-578-1 will not be utilized. Instead, the one-time inspection sample size w ill inc lude 10% of the total butt w elds in C lass 1 pip ing less than NPS 4. The actual inspection locations will be based on physical accessibility, exposure levels, NDE techniques, etc. a nd wil l be determin ed with site inv olvement. U T techniques consi stent with the ASME C ode and 10 CFR Part 50, Appendix B that permit th e inspectio n of the inside surfaces of the item wi ll be use d for the inspecti on of butt wel ds.The app lica nt furthe r state d that Oyster Creek p ipin g is ba sed up on the ANSI B31.1 (1963) Pow er Piping spe cification. The Class 1 pi ping classifica tion is ba sed upon ASME S ection XI. The Oy ster Creek line specification s, piping and instrument drawings, isometric conf iguration drawings and input fr om the Oyster Creek ISI coordinator w ere used to de termine the lo cation and p opulation of butt welds less than or equal to four i nches. The popu lation in cludes w elds on the reactor recircul ation system, the CR D return lin e, the reactor v essel bottom he ad drain l ine, the reacto r head vent lin e (main steam sy stem), and the reac tor water cl eanup syste
: m. The butt wel ds less than N PS 4 in th ese systems a re two and three inch i n size (th ere is no 2 1/2 inch Class 1 pi ping; nor are the re any butt welds o n the 1 inc h Class 1 piping). The proposed sampl e include s a representati ve sample of welds from these systems and includes b oth two an d three inch NPS pipe.b) The majority o f Class 1 pip ing less than NPS 4 is socket weld ed. The ASM E Section XI Clas s 1 pi ping p rogram re quires surface exami natio n of soc ket we lded conne ction s. The One-Time Inspectio n Program original ly did not include in-situ v olumetric or destructive examinatio n of socket wel ded connecti ons. The One-Time Insp ection Program was to i nclude oppo rtunistic ex aminations o f Class 1 socket w elded conne ction s less than N PS 4. Socket wel d fail ures w ill be ev aluat ed in accord ance w ith 31 the Oyster Cree k 10 CFR Part 5 0, Appendix B correctiv e action program to determine failure mechani sms and correctiv e actions. In addition, the plant modi fication process will require that any class 1 so cket welded connection l ess than NPS 4 that has be en removed duri ng the install ation of a pla nt modification be examine d for cracking and cracking mechanisms.
c) Bas ed on a rev iew of the Oy ster Cr eek CAP Syst em (Cor rectiv e Acti on Pro gram)from 1998 through presen t, cracking due to S CC, IGSCC, or th ermal and mecha nical loading has not been found o n class 1 p iping less than NPS 4.
An eval uation of Oyster Creek OE from 198 5 throu gh 2000 was performed in 20 00 in respo nse to indu stry concer ns rel ated to vib ration relat ed and therma l fatigu e fail ures o f small bore p ipin g. That review identified o ne (1) even t in whi ch a safety-rela ted small bo re socket wel ded connection fail ed. This failure was attrib uted to a defectiv e weld rather than v ibration related or therma l fatigue.
Mechani cal/Vibrati on Fatigue:  V ibration i nduced socket w eld failures is a material degradation is sue that can re sult in crac k initiation and growth.
Small bore pipe and socket welde d vent and drain conne ctions in th e immediate pro ximity of vibration sources tend to be most suscepti ble to high c ycle mecha nical fatigue. V ibration fatigue does not lend itself to periodic in-service examinations as a means of managing this aging mechanism.
Vibration induced fatigue is fast acting and is typically detected early in a compone nt's life. The n ature of this mechan ism is such that, generally , almost the entire fatigue li fe of the component is expended during the in itial pha se of crack initiatio n. Once a crack i nitiates, fail ure quickly foll ows. The pe riod of time betw een crack initiati on, i.e. a crac k size that i s detectable by vol umetric exami nation, and the failure of the press ure boundary is very small and is usuall y measured i n days to months and not ye ars. An ev aluation o f Oyster Creek OE from 1985 through 2000 w as performed in 2000 in response to industry concerns rela ted to vib ration related and thermal fatig ue failures of small bore piping. That review identified one (1) event in which a safety-related small bore s ocket welded connection failed. This fail ure was attributed to a defective w eld rather than vibratio n related or thermal fatigue. Base d upon the Oys ter Creek plant s pecific operati ng experienc e, and rationa le provi ded above, crackin g due to vi bration-induc ed fatigue is not considered a n aging effect for the period of exte nded operatio n.Thermal Fatigue:
A relatively small number of thermal related failure s have occurred in small-bore p ipin g (referen ce:  Pa cific N orthw est Na tiona l Lab oratory report PNNL-13930, "Program Plan for Acqui ring and Ex amining Natural ly Aged M aterials and Components for Nuclear Reactors," dated Decembe r 2001). Fatigue failures in safety-related system s and components have been rare and fat igue in pressure-retaini ng equipment is gene rally de tected as small cracks or leaks, cau ght before reaching a size that could cause a pressure boundary rupture. Thus fatigue is not considere d a safety is sue (reference:  TR-104 534, "EPRI Fa tigue Managemen t Handbook," dated December 1994).
Of those that hav e occurred, the more common source of ther mal fa tigue was either (1) crac king associat ed with the in teract ion of valve leakage and cy clic effects and (2) cyclic tu rbulent penetra tion effects of isolated smal l-bo re pi pin g or d rain lin es. An e val uati on o f Oys ter C reek OE fro m 198 5 thr ough 2000 was performed in 2000 in response to industry concerns rela ted to vib ration related and thermal fatigue failure s of small bore piping. That rev iew id entified one (1
)even t in w hich a safety-relat ed smal l bore socket wel ded co nnecti on fail ed. Thi s failu re was attribu ted to a defectiv e weld rather than v ibration rel ated or thermal fatigue. The 32 issue of thermal fatigue is the sub ject of EPRI Repo rt 1000701, "Interi m Thermal Fatigue Management Guideline (MRP-24)," dated January 2001 which is referenced in GALL program X I.M35, in program Element 1 "Scop e of Program."  As discussed in PBD-B.1.24, EP RI Report 1000 701 recommends sp ecific locati ons for assessment and/or inspec tion whe re cracking and l eakage has been i dentified in nominally stagnant non-iso lab le p ipi ng at tach ed to reac tor c ool ant s yst ems i n do mest ic a nd s imi lar forei gn PWRs. These inspection rec ommendations do not apply to Oyster Cree k which i s a BW R. However, Oyster Creek has evaluated the potential for cracking in nominally stagnant non-isol able pipi ng attached to reac tor coolant sy stems and it w as conclude d that there are no systems w ith unisol able sectio ns that could be subjected to thermal stratification or oscillati ons. This ev aluation i s summarized as follows
:  IN 97-46 discusses a situation tha t occurred at Ocon ee Unit 2 w here cracks dev eloped in an uniso labl e secti on of a combin ed makeu p (MU) and h igh-pre ssure i njecti on (HP I) lin e. The IN goes on to reference NRC Bu lletin 88-08 and its s upplements. B ulletin 8 8-08 describes the circumstances tha t occurred at Fa rley 2 w here a crack dev eloped in an unisolabl e section of EC CS pipin g. The crack resulted from high cycle thermal fatigue caused by relativel y cold w ater leaking through a closed glob e valv e. Oyster Cree k performed a rev iew of sys tems co nnecte d to th e Reac tor Coo lant S ystem in res ponse to NRC Bull etin 88-08 a nd its Supp lements to determi ne whethe r unisolabl e sections o f piping conne cted to the Re actor Coolan t System coul d be subjected to stresses from temperature stratificati on or temperature oscillati ons. It was concluded that there are no systems wi th unisolab le sections which could be su bjected to thermal stratification o r oscillati ons. The pipi ng system eva luations en compassed both the weld ments (as required by Bulletin 88-08) and the base metal (as req uired by Supplement 1 to Bulletin 88-08).Stress Corrosion Crack ing:  Three simultaneous con ditions must be present f or IGSCC to occur:  susce ptible materi al, envi ronment, and tensi le stress. Tensi le stress at the weld roo t, which i s exposed to impurities in the reacto r coolant that can accelera te the initiatio n and propagati on of IGSCC, is ty pically produced duri ng butt weld ing of piping components and is less of a concern wi th socket wel ded connecti ons. The Oyster Creek One-T ime Inspection Program for class 1 piping less than NPS 4 will focus on full penetration bu tt welds w hich are more susceptible (bounding) than socket weld ed conne ction s to th e stres s corro sion crackin g aging me chani sm.In review ing the appli cant's respons e, the project team recognized th at failures in socket welded piping less than NPS 4 have bee n prevale nt in the i ndustry, and have recei ved increasing atten tion by th e staff. As noted in the appli cant's respons e, socket wel ded pipin g accounts for the majori ty of piping l ess than NPS 4; therefore, an acc eptable method of ensuring that agin g of these weld s will be managed for the p eriod of exten ded operation must be demonstrated.
While the applicant' s program wil l inspect b utt welde d piping l ess than NPS 4, there is no ev idence to de monstrate that this inspection sample popu lation can be cons ide red a lea din g ind ica tor o r a l imi ting loc atio n for fail ures in s ocke t we lde d pi pin g.In its response , the appli cant stated that th e OCGS One-Time Inspe ction Program w ill inc lude opportunistic examinati ons of Class 1 socket weld ed connectio ns less than NPS 4. S ocket weld fail ures wil l be eva luated in accordance w ith the Oyste r Creek 10 CFR Part 50, Appen dix B corre ctiv e acti on pro gram to d etermi ne fail ure mec hanis ms and correc tive actio ns. The project team recogni zed that op portunistic i nspection of soc ket weld fail ures wil l provid e insights into the cause of the fai lures; how ever, as note d in NRC Branch Technica l Positio n RLSB-1 (SRP-LR, Appendi x A), in order for an aging managemen t program to be consi dered 33 effect ive, detection of aging ef fects must occ ur before there is a loss of the component's intended functio
: n. Further, a pro gram based solel y on detec ting component fail ure should n ot be considered an effec tive aging manageme nt program f or license renewal.
In its response , the appli cant further stated that the plant modi fication process will require that any class 1 socket wel ded connecti on less than NPS 4 that has been remov ed during the installati on of a plant mod ification be examined for cra cking and cracking mecha nisms. The project team recogniz ed that this w ould prov ide reasonab le assurance that cracking of socket welded small bore p iping is no t occurring. How ever, the pro ject team did no t feel that there w as certainty tha t a socket wel d would be examin ed prior to e ntering the peri od of extended operation.
In response to the project team's questions on thi s issue, the applicant c ommitted to the following:  "The O ne-Tim e Inspec tion Pro gram will also include destru ctive or no n-dest ructive exami natio n of one socket wel ded co nnecti on usi ng techn iques p roven by p ast in dustry experience to be effect ive for the identification of cracking in small bore sock et welds. This examination will be an examination of opportunity (e.g., sock et weld failure or socket weld replacement). S hould an i nspection of opp ortunity no t occur prior to entering the pe riod of extended operation, a susceptible small bore sock et weld will be ex amined either destructively or non-destru ctiv ely prior to ente ring th e peri od of ex tended opera tion. The cur rent pl an is to exami ne a s uscept ible small bore C lass 1 elbo w off of a n iso latio n cond enser syste m drai n lin e. Results of the i nspection w ill be e valuated in accordanc e with th e Oyster Creek 10 CFR Part 50 , Appe ndix B Cor rectiv e Acti on pro cess."In its letter d ated May 1, 2006, (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to the follow ing:  The One-Time Inspe ction Program w ill als o include destructive or non-destructiv e examinati on of one socket w elded conne ction using tec hniques prov en by pas t indus try ex perie nce to be effect ive for the i denti ficatio n of crac king in small bore s ocket w elds. Should an inspection opportunity not occur (e.g
., socket weld failure or sock et weld replacement), a s usceptible small-bore soc ket weld w ill be e xamined ei ther destructiv ely or non-de structi vely prior to ent ering t he per iod o f exten ded op eratio n. This is A udit Commitme nt 3.0.3.1.4-3. This s pecifi c commi tment w ill be add ed to t he LRA Appen dix A.5 Commitm ent Li st, as p art of Co mmitment 24 as socia ted w ith One-Time In specti on Pro gram.The project team determi ned that the ap plicant has now committe d to volu metrically or destructivel y exami ne at least o ne socket wel d prior to the period of ex tended operati on, and perform examinati on of 10% of the butt w elded small bore pipi ng, in response to the project team's concern in this area. As this i s a samplin g process, the projec t team determined that one socket weld will represent the population for Class 1 piping less than 4-inch NPS.
Exception 2 Elements: Program Descriptio n 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: NUREG-180 1 ref eren ces, in XI.M32 a nd XI.M35, the 20 01 ASME Section XI B&P V Code, in cluding the 2 002 and 200 3 Addenda for 34 Subsections IW B, IW C, and IW D. The current Oyster Creek ISI Progr am Plan f or the f ourth t en-year inspect ion inter val eff ective from October 15, 2002 th rough October 14, 20 12, approve d per 10CFR50.55a, is based on the 1995 ASME Section XI B&PV Code, incl uding 1996 ad denda. The nex t 120-month insp ection interv al for Oy ster Cr eek wi ll i ncorpo rate th e requi rements specified in the versi on of the ASM E Code in corporated into 10 CFR 50.55a twelve months before the sta rt of the inspecti on interv al. This is a new exception based on the reconcilia tion of this aging management program fro m the draft January 2005 GALL to the app roved September 2005 GALL.
The GAL L Repo rt ide ntifie s the fol low ing rec ommenda tions for the "program descri ption ," "scope of progra m," "par ameters monito red or inspe cted," "detec tion o f aging effec ts,""monitoring and tre nding," and "acce ptance criteri a" program elements a ssociated w ith the exception taken: Program Descrip tion:  The program incl udes measures to verify the effectiveness of an AMP and confirm the insi gnificance of an agin g effect. Situations in which additional confirmation is appropriate i nclude (a) an aging effect is not ex pected to occur but the data is insufficient to ru le it out with reasonable confidence; (b) an aging effect is expected to progress very slowl y in the specified env ironment, but the local env ironment may be more a dverse than that generally expected; o r (c) the characteri stics of the aging effect include a long incuba tion period. For these cas es, there is to be confirmation that either the aging eff ect is indeed not occurring, or the aging eff ect is occurring very slowl y so as n ot to affect the component or structure inten ded function during the peri od of extended operation.
A one-time in spection may also be u sed to provi de additio nal assuranc e that aging that has not ye t manifested itsel f is not occurrin g, or that the ev idence of aging sho ws that the aging is so insignificant th at an aging management p rogram is not w arranted. (Class 1 pip ing le ss than or equa l to  N PS 4 i s addr essed in Ch apter XI.M35.)1. Scope of Prog ram:  The program includes m easures to verify that unacceptab le degradation is not occurring, the reby val idating the effectiv eness of exi sting AMPs or confirming that there i s no need to manage aging-related d egradation for the pe riod of extended operation. The struct ures and components f or which one-time inspection is speci fied to veri fy the effectiv eness of the A MPs (e.g., w ater ch emistry contro l, etc.)have been ident ified in the GALL R eport.3. Parameters Moni tored or Inspected
:  The program m onitors parameters directly related to the degradation of a co mponent. Inspecti on is to be performed by qual ified personnel foll owing proce dures consiste nt with th e requirements of the A SME Cod e and 10 CFR Part 50, Appendix B, using a variety of NDE methods, including visual, volumetric, and surface techni ques.4. Detect ion o f Agin g Effec ts:  The inspecti on includ es a representa tive sampl e of the syste m popul ation , and, wher e prac tical , focuse s on th e boun ding o r lead compon ents most susceptibl e to aging due to time in serv ice, severi ty of operating co nditions, an d lowest de sign margin. The program w ill rely on establi shed NDE te chniques, incl uding visual, ultrasonic, a nd surface techni ques that are performed b y qualified personnel 35 following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B.
The inspection and test techniq ues will have a demonstrated history of eff ectiveness in detecting the agin g effect of concern.
: 5. Monito ring and Trendin g:  The program provid es for increasin g of the inspectio n sample siz e and loca tions in the event that aging effects are detected.
Determination of the sa mple s ize is ba sed on an as sessme nt of mate rials of fabric ation , env ironme nt, plaus ible aging e ffects, an d oper ating e xperi ence. Unacc eptabl e ins pecti on find ings ar e evaluated in accordan ce with the site correcti ve action process to de termine the nee d for subsequent (incl uding periodi c) inspectio ns and for monitori ng and trending the results.6. Acceptance Criteria
:  Any i ndication o r relevant conditions of degradation detec ted are evalu ated. For ex ample, the ul trasonic thicknes s measurements are to be compared to prede termined limi ts, such as the design minimum w all thickness for pip ing.The app lica nt wa s asked to con firm that AMP B.1.24 in th e OCGS LRA w ill be rev ised to include thi s exceptio n.In it s let ter date d Marc h 30, 2006 (ML060950408), the ap plica nt co mmi tte d to r evise AMP B.1.24 in th e OCGS LRA to incl ude th e exc eptio n ide ntifie d in t he rec oncil iatio n docu ment, which states that the 1995 ASME Section XI B&PV Code, including 1996 addenda, is current ly used a t Oyste r Cree k. This is A udit Commitment 3.0.3.1.4
-4.The project team evaluated this exception as part of its review of OCGS AMP B.1.1 and found it acceptable.
The project teams's evaluati on is disc ussed in S ection 3.0.3.2.1
.3 of this audi t and revi ew re port.Exception 3 Elements: Program Descriptio n 1. Scope of Program
: 5. Monito ring and Trendin g Exception: NURE G-1801 states in XI.M 35 tha t the gu idel ines of EPRI Repor t 1000701, "Interi m Thermal Fatigue M anagement Guideli ne (MRP-24)," Ja nuary 2001 should be used for identi fying piping suscep tible to pot entia l effects of therma l fatigu e. EP RI Rep ort 1000701 recommen ds specific l ocations for asses sment and/or inspection where cracking and leaka ge has been identified in nominally stagnant non-iso lable pi ping attached to reactor coolan t systems in d omestic and si milar foreign PWRs. As Oyster C reek is a B WR, these in specti on gui deli nes ar e not a ppli cable. This is a new exceptio n based on the reconcil iation of th is aging management program fro m the draft January 2005 GALL to the approved Sep tember 2005 GALL
.The GAL L Repo rt ide ntifie s the fol low ing rec ommenda tions for the "program descri ption ,""scope of program," and "mon itoring and tren ding" program elements associated w ith the exception taken:
36 Program Descrip tion:  The program incl udes measures to verify the effectiveness of an AMP and confirm the insi gnificance of an agin g effect. Situations in which additional confirmation is appropriate i nclude (a) an aging effect is not ex pected to occur but the data is insufficient to ru le it out with reasonable confidence; (b) an aging effect is expected to progress very slowl y in the specified env ironment, but the local env ironment may be more a dverse than that generally expected; o r (c) the characteri stics of the aging effect include a long incuba tion period. For these cas es, there is to be confirmation that either the aging eff ect is indeed not occurring, or the aging eff ect is occurring very slowl y so as n ot to affect the component or structure inten ded function during the peri od of extended operation.
A one-time in spection may also be u sed to provi de additio nal assuranc e that aging that has not ye t manifested itsel f is not occurrin g, or that the ev idence of aging sho ws that the aging is so insignificant th at an aging management p rogram is not w arranted. (Class 1 pip ing le ss than or equa l to N PS 4 i s addr essed in Ch apter XI.M35.)1. Scope of Prog ram:  The program includes m easures to verify that unacceptab le degradation is not occurring, the reby val idating the effectiv eness of exi sting AMPs or confirming that there i s no need to manage aging-related d egradation for the pe riod of extended operation. The struct ures and components f or which one-time inspection is speci fied to veri fy the effectiv eness of the A MPs (e.g., w ater ch emistry contro l, etc.)have been ident ified in the GALL R eport.5. Monitoring and Trendin g:  The program provi des for increasi ng of the inspecti on sample siz e and loca tions in the event that aging effects are detected.
Determination of the sa mple s ize is ba sed on an as sessme nt of mate rials of fabric ation , env ironme nt, plaus ible aging e ffects, an d oper ating e xperi ence. Unacc eptabl e ins pecti on find ings ar e evaluated in accordan ce with the site correcti ve action process to de termine the nee d for subsequent (incl uding periodi c) inspectio ns and for monitori ng and trending the results.The app lica nt wa s asked to con firm that AMP B.1.24 in th e OCGS LRA w ill be rev ised to include thi s exceptio n.In it s let ter date d Marc h 30, 2006 (ML060950408), the ap plica nt co mmi tte d to r evise AMP B.1.24 in th e OCGS LRA to incl ude th e exc eptio n ide ntifie d in t he rec oncil iatio n docu ment, whi ch stat es tha t EPRI Repor t 1000 701 i s not a ppli cable at Oys ter Cre ek. This is A udit Commitment 3.0.3.1.4-5.
In review ing this ex ception, the p roject team noted th at, whil e EPRI Repo rt 1000701 focuses on locations susceptible to thermal f atigue that are specif ic to PW R plants, it also includes generic guidance that may be useful for BWR plants. The a pplicant w as asked to cla rify whethe r the gen eric guid ance in EPRI Repor t 100 0701 was con side red in the de velop ment of O CGS A MP B.1.24.In its response , the appli cant stated that th e Oyster Creek ev aluation to identify pi ping potentiall y suscepti ble to the e ffects of thermal fatigue is prov ided in p rogram basis docume nt PBD-AMP-B.1.24, Section 3.1. This evaluation addresses the generic guidance of the EPRI document for identi fication of locati ons. No lo cations w ere identified as requiring i nspection.
The project team rev iewed S ection 3.1 of the program basis docu ment for OCGS AMP B.1.24 and confirmed that the evalu ation used th e generic guidan ce in the E PRI report. The 37 eval uatio n ide ntifie d no l ocati ons at Oyste r Cree k that w ould be sub ject to thermal fatigue. On this basis, the project team de termined that thi s exceptio n is accepta ble.3.0.3.1.4.4 Enhan cements None 3.0.3.1.4.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th is program appli es to potentia l aging effects for which the re are currently no operatin g experience indicati ng the need for an a ging management program. Neverthe less, the el ements that compris e these insp ections (e.g., the sc ope of the inspections and inspe ction techni ques) are consis tent with industry pra ctice.Since this is a new program, there wa s no plant-sp ecific operatin g experience for the project team to review. However, the project team expects that O CGS AMP B.1.24 will adequately manage the aging effects for whi ch it is cre dited on the basis that i t is consis tent with GALL AMP XI.M 32, with exceptions
.The project team recogni zed that the corrective action program, w hich captures internal an d external p lant operatin g experience issues, w ill ensu re that operatin g experience is revi ewed and incorpora ted in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.3.0.3.1.4.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he One-Time Ins pecti on Pro gram in OCGS LRA, Append ix A, Se ction A.1.24, w hich states tha t the Oyster Cre ek one-time insp ection aging management program is a new program that will address potenti ally l ong incubatio n periods for certain aging effects and will provide a means of confirming that an aging effect is eith er not occ urr in g or is pro gre ssi ng s o sl ow ly as to n ot h av e a n e ffec t on the in ten ded fun cti on of a structure or compone nt withi n the exten ded period of operation. The On e-Time Inspection Program will provide measures to ve rify that an agi ng management program is no t needed, confirms the effectivene ss of existin g activitie s, or determines that degradation is occurring whi ch wi ll re quire e valu ation and c orrecti ve ac tion. The in specti ons w ill be imp lement ed pri or to the period of extended operation to m anage the eff ects of aging for selected component s within the scope of license renewal.
Inspection metho ds wil l includ e visual examinati on or vol umetric exami nations. Acc eptance criter ia are in ac cordan ce wi th ind ustry guide line s, code s, and stand ards. The One-Time Inspec tion P rogram pr ovid es for th e eva luati on of th e need for foll ow-u p exa minati ons to monitor the progressi on of aging if age-related degradation i s found that coul d jeopardiz e an intended functio n before the end of the period of ex tended operati on. Should aging effects be detected, the pro gram triggers actions to c haracterize the nature and extent of the agin g effect and de termin es wh at sub sequent monito ring i s need ed to e nsure inten ded fun ction s are maintained d uring the perio d of extended operation.
The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, an d confirmed that thi s program is ide ntified as a n ew program that w ill be implemented pri or to the peri od of extended operation a s item 24 of the c ommitments. The 38 speci fic commi tments i denti fied i n this report secti on w ill be add ed to t he LRA Appen dix A.5 Commitm ent Li st, as p art of Co mmitment 24 as socia ted w ith th e One-Ti me Insp ectio n Progra m.In its letter d ated March 30, 2006 (M L060950408), th e applica nt committed to make the following revisions to the OCGS LRA:
*AMP B.1.2 4 in the OCGS LRA wi ll be rev ised to in clude the ex ception ide ntified in the reconcilia tion document, w hich states tha t the new Oyster Creek one-ti me inspection aging management program w ill inc lude the on e-time inspecti on of Class 1 piping less than or equal to NPS 4.  (C ommitment 3.0.3.1.4-2)
*AMP B.1.2 4 in the OCGS LRA wi ll be rev ised to in clude the ex ception ide ntified in the reconcilia tion document, w hich states tha t the 1995 AS ME Secti on XI B&PV C ode, includin g 1996 addenda , is currently used at Oys ter Creek.  (Commitment 3
.0.3.1.4-4)
*AMP B.1.2 4 in the OCGS LRA wi ll be rev ised to in clude the ex ception ide ntified in the reconcilia tion document, w hich states tha t EPRI Report 1000701 is not applica ble at Oyster Creek.  (Commi tment 3.0.3.1.4-5)
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to make the followin g revision to the OCGS LRA:
*AMR line item 4 3 in Ta ble 3.3.1 w ill be rev ised to del ete refe rence to usi ng the o ne-tim e inspection to verify the effectiveness of the Selectiv e Leaching of M aterials Pro gram since this is not one of the intended uses of the one-ti me inspection. (Commitment 3.0.3.1.4-1)
In its letter d ated May 1, 2006 (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to make the following revision to the OCG S LRA:*AMP B.1.2 4 in the OCGS LRA wi ll be rev ised to in clude destructi ve or non-destructive examination of one soc ket welded connection.  (Audit Commitment 3.0.3.1.4-3)
The applican t's licens e renewal commitment list and UFSAR update are to b e revised to reflect these new commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.24. Contingent up on the inclusi on of commitments 3.0.3.1.4
-1 thru 5, the pro ject team found that i t was cons istent with the GALL Report, and determined tha t it provi ded an adequate summary descri ption of the program, as identi fied in the S RP-LR FSAR Supplement ta ble and as required by 10 CFR 54.21 (d).3.0.3.1.4.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith ex cepti ons, i s adequ ate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Suppl ement for this AMP and, c ontin gent up on the incl usion of Audi t Commi tments 3.0.3.1.4-1 39 thru 5, found that i t provides an adequate summary description of the program, as required by 10 CFR 54.21 (d).3.0.3.1.5 Selectiv e Leaching of M aterials (OCGS AMP B.1.2 5)In OCGS LRA, Ap pendix B , Section B.1
.25, the appli cant stated that OC GS AMP B.1.25,"Sel ecti ve Lea chin g of Mater ials," is a n ew plan t pro gra m tha t is co nsis tent with G ALL AMP XI.M33 , "Sel ectiv e Leac hing o f Mate rials." 3.0.3.1.5.1 Program Descriptio n The app lica nt stat ed, in the OC GS LRA , that t his p rogram w ill consi st of one-time i nspect ions to determine if los s of material due to selectiv e leachin g is occurring. The scope of the program includes s usceptible components such as piping, pu mps and val ves wi thin the scop e of license renew al tha t are e xpos ed to r aw w ater, c losed cool ing w ater, tr eated wate r, aux ilia ry ste am, condens ation or soil. Susce ptible co mponen t mate rials are gray cas t iron, b rass and bronze with greater than 1 5% zi nc, an d alu minum b ronze wit h greate r than 8% alu minum.The applican t also stated that the One-Time Insp ection Program in cludes vi sual inspe ctions consi stent w ith AS ME S ectio n XI VT-1 requir ements, hardn ess tes ts and other approp riate exami natio n metho ds as m ay be requir ed to c onfirm o r rule out se lecti ve l eachi ng, and to evaluate the remaining component wall thickness. Components of the susc eptible materials are selected from the different potential ly aggressiv e environ ments. The purpose of the progr am is to de termi ne if los s of ma terial du e to selec tive leachi ng is occ urring. If se lective leach ing is found, the pro gram  pro vide s for ev aluat ion a s to th e effect i t wi ll ha ve on the ab ilit y of the affected components to perform their intend ed function for the p eriod of exten ded operation, and the need to expand the sample of compone nts to be tested
.The applican t further stated that the program wil l be imple mented prior to the period o f extended o peration.3.0.3.1.5 2 Consi stency wit h the GA LL Rep ort In OC GS LR A, th e appl ican t sta ted t hat O CGS A MP B.1.25 is c onsi sten t with GALL AMP XI.M33.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.25, incl uding program b asis d ocumen t PBD-AMP B.1.25 , "Sel ectiv e Leac hing o f Mate rials ,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M33. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this a udit a nd rev iew report) conta ined in OCGS AMP B.1.25 and a ssoci ated b ases d ocumen ts to determine con sistency w ith GALL AM P XI.M33.The project team reviewed those portions of the applicant's Selective Leaching of Materials Program for which the applica nt claims con sistency w ith GALL AM P XI.M33 and found that they are consistent with this GALL Report AMP. The project team found that the applicant
's Selectiv e Leaching of M aterials Pro gram conforms to the recommende d GALL AM P XI.M33.
40 3.0.3.1.5 3 Exce ption s to th e GALL Repor t None 3.0.3.1.5 4 Enhan cements None 3.0.3.1.5.5 Operating Expe rience The app licant st ated, in the OCG S LRA and th e progr am basis documen t, that the Select ive Leaching of Materials aging m anagement prog ram is new. Therefore, no programmat ic operating exp erience is availab le.The app licant st ated th at opera ting expe rience, both inte rnal and ext ernal, is used in two ways at Oyster Creek to enhance pla nt programs, preven t repeat eve nts, and prev ent events th at have occurre d at other pl ants from occurring at Oy ster Creek. The first w ay in w hich operati ng experience is used i s through the Oys ter Creek operatin g experience process. The op erating experience process screen s, evalua tes, and acts on operating ex perience doc uments and information to prevent or mitigate the consequ ences of similar events. The second way is through the process for managing programs. This p rocess requires the review of program relate d oper ating e xperi ence b y the program owne r.Demonstration th at the Oyster C reek Selectiv e Leaching of M aterials agin g management program to effectively manage loss of materi al in compo nents suscepti ble to sel ective l eaching will be achiev ed through objecti ve evi dence. The follo wing indu stry operatin g experience and site-s pecif ic findi ngs at Oyster Cr eek have been utilize d in creat ing the Oyster Cr eek Sele ctive Leach ing of M ateria ls agi ng manage ment pr ogram: Indust ry op eratin g expe rienc e has ident ified graphi tiza tion o f submerge d pump components from long-term i mmersion in sa ltwater env ironments and dezinci fication of copper allo y components.
Graphitiza tion has occ urred in the Oyster Creek serv ice water sys tem and the ci rculating w ater system at th e intake structure.
In the case o f the non-nuclear s ervice w ater pumps, the pu mp suction bow ls were at one time al l made of cast i ron. S ubmergen ce in the i ntake ba y for y ears a t a time cause d sev ere graphitization of these bowls. This diagno sis was made at the time by a materials engineer on the staff of the pump company and was confirmed based on visua l observ ation by th e mater ials engin eer of th e prev ious plant own er.At this time, c ast iron is no longer used or specified for use in the su bmerged portions o f the service water pumps. Replacemen t parts are constru cted from corrosion re sistant materials. Ad ditionall y, the Emergency service w ater pumps do n ot contain ca st iron parts.In the case of the circulating w ater pumps, the su ction column sections (4) for ea ch of the four pumps w ere all ori ginally purchased w ith cast iron parts. Again, e vidence of graphitic corrosi on was found occurring early in their l ife. Steps w ere taken to repl ace the sections with new sections fabric ated of stainle ss steel or ca rbon steel as deemed necessary.
In addition , to prevent galvanic c orrosion, ins ulation kits were insta lled between flan ges where di ssimilar metal s met. At the pre sent time, there re main a few sections stil l made of the ori ginal cast i ron, but these a re heavil y coated.
These 41 sectio ns are vis uall y in specte d by the rep air faci lity durin g over hauls in w hich the pu mp is removed from service and shipped to them. The circul ating water p umps are not within the scope of License Renewal.
As such, sampl e inspectio ns at Oyster C reek will include remaining cast i ron compon ents su bjected to a s altw ater en viro nment.Once implemented the Oyster Cre ek Selectiv e Leaching of M aterials agin g management program will manage loss of m aterial such that intended func tion(s) of compone nts susceptible to selectiv e leachin g will be maintaine d consistent with the CLB for the peri od of extended operation.
The staff believes that the correctiv e action proc ess wil l capture in ternal and e xternal pl ant operating issue s to ensure tha t aging effects are adequately managed.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applic ant's t echnica l staf f, th e proje ct team determ ined that the applic ant's  sele ctive leaching program will adequately manag e the aging eff ects that are identified in the OCG S LRA for which thi s AMP i s credited.
3.0.3.1.5.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Selectiv e Leaching of M aterials Pro gram in OCGS LRA, Appendix A, Section A.1.25, whi ch stated that the Selectiv e Leaching of Ma ter ia ls agi ng m ana geme nt p rog ram is a n ew pro gra m th at w il l c ons ist of i nsp ect io ns o f a representative selection of com ponents of the diff erent susceptible materials to det ermine if loss of material due to sel ective l eaching is o ccurring. One-time i nspections w ill be c onsistent with AS ME Secti on XI VT-1 visu al inspecti on requirements an d supplemented by hardne ss tests and other examinatio ns of the selecte d set of components.
If selective leaching i s found, the conditio n will be eval uated to determi ne the need to expand inspections. This new inspection program will be implemen ted prior to the period of ex tended operati on.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, an d confirmed that thi s program is ide ntified as a n ew program that w ill be implemented pri or to the peri od of extended operation a s item 25 of the c ommitments.
The project team rev iewed th e UFSAR S upplement OCGS A MP B.1.25 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.5.7 Conclusio n On the basis of its audit and review of the applicant's prog ram, the project team found that all the program elements are consistent with the GALL Report. On th e basis of its review of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).
42 3.0.3.1.6 10 CFR Part 50, Appendi x J (OCGS AM P B.1.29)In OCGS LRA, Ap pendix B , Section B.1
.29, the appli cant stated that OC GS AMP B.1.29,?10 CFR Part 50, Appendi x J," is a n existi ng plant program that i s consistent w ith GALL AMP XI.S4, " 10 CFR Part 5 0, App endix J." 3.0.3.1.6.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for detectio n of age-related pressure bound ary degradatio n and loss of leak tightness due to aging effects such as loss of materi al, cr acking, or los s of prel oad i n the p rimary conta inment and v ariou s sys tems penetrating primary containment. The program also dete cts age related d egradation in material proper ties o f gaskets, o-rings, and p acking ma terial s for the prima ry co ntain ment pr essure boundary a ccess points.
The applican t also stated that the program consi sts of tests performed in accordance w ith the regula tions and gu idanc e prov ided in 10 CFR P art 50 Appen dix J, ?Primary Rea ctor Containment Le akage Testing for Water-Cooled Power R eactors," Option B , Regulatory Guide 1.163, ?Performa nce-Ba sed Co ntain ment Le ak-Testi ng Progra m," NEI 94-01, ?Indust ry Guidel ine for Implem entin g Performa nce-Ba sed Opt ions of 10 CF R Part 50, Ap pendi x J,"ANSI/A NS 56.8, ?Containment S ystem Leakage Testing R equirements," and sta tion procedures. Co ntainment lea k rate tests are performed to assure that l eakage through the primary conta inment and sy stems and compone nts penetrating pri mary contain ment does not exceed al lowabl e leakage limi ts specified i n the Technical Specificatio ns. An inte grated leak rate test (ILRT) is performed during a period of reactor shutdown at the f requency specified in 10 CFR Part 50, Appendi x J, Option B. Local l eak rate tests (LLRT) a re performed on iso lation valv es and conta inment acces s pene tratio ns at fre quenci es tha t compl y w ith th e requi rements of 10 CFR Part 50 Appendix J, Option B.
3.0.3.1.6.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B.1.29 is consis tent with GALL AMP XI.S4.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.29, incl uding program b asis d ocumen t, PBD-AMP-B.1.29 , ?10 CFR Part 50, Appendi x J," Rev. 0, 12/0 1/20 05, wh ich pr ovide s an as sess ment of t he AMP e leme nts' cons iste ncy wit h GAL L AMP XI.S4. Specifical ly, the pro ject team revie wed the p rogram elements (see Section 3.0.2.1 of this a udit a nd rev iew report) conta ined in OCGS AMP B.1.29 and a ssoci ated b ases d ocumen ts to determine con sistency w ith GALL AM P XI.S4.The pro ject t eam revie wed those po rtions of the a pplicant's 10 CFR Par t 50, App endix J program for which th e applica nt claims con sistency w ith GALL AM P XI.S4 and found th at they are consistent with thi s GALL Report A MP. The pro ject team found that the applican t's 10 CFR Part 50, Appen dix J pro gram conforms to the recommende d GALL AM P XI.S4.3.0.3.1.6.3 Exce ption s to th e GALL Repor t None 43 3.0.3.1.6.4 Enhan cements None 3.0.3.1.6.5 Operating Expe rience The app lica nt stat ed, in the OC GS LRA and th e progra m basi s docu ment, th at the primar y contai nment l eakage te sting p rogram ac tivi ties h ave b een effec tive in mai ntain ing the pressu re integrity of the c ontainment bou ndaries, inc luding iden tification of lea kage within th e various systems pressure boundaries.
The Oyster Cree k facility demon strates a good ope rating experience in maintai ning the integrity of the containmen t boundaries as evide nced by th e selection o f Option B of 10 CF R Part 50 Ap pendix J leakage testing requi rements. Oyster Creek h as ex perie nced 'as found' LLR T resul ts that were in ex cess o f the ad minis trativ e limi ts for the indiv idual con tainment penetrati on. Eval uations w ere performed and co rrective acti ons were taken to restore the ind ividual containment pe netration lea kage rates to wi thin the established administrati ve leakage l imits. The ex perience at Oy ster Creek wi th the 10 CFR Part 50 Appendix J aging managem ent program shows that th e program is eff ective in managing loss of materi al, loss of prel oad, loss of sea ling, loss o f leak tightness, and cracking in the contai nment, associated welds, penetrations, a nd other access openings.
The applican t's operating e xperience review process incl udes both ex ternal and i nternal source s. Ex ternal opera ting ex perie nce may incl ude su ch thi ngs as I NPO do cuments (e.g., SOERs, SERs, SENs, etc.), NRC docum ents (e.g., G Ls, LERs, INs, etc.), General Electric documents (e.g., RCSIL s, SILs, TILs, etc.), and other documents (e.g., 10CFR Part 2 1 Reports, NERs, etc.). Inte rnal operati ng experienc e may incl ude such thi ngs as event investigati ons, trending reports, an d lessons l earned from in-hous e events a s captured in program notebooks, self-assessments, and in the 10 CFR Part 50, Appendix B correctiv e action proc ess.The app licant ide ntifie d the fo llowing exam ples of operati ng exper ience to p rovide obj ective evidence that the Appendix J LRT program is ef fective in assuring that intended function(s) will be maintaine d consistent with the CLB for the peri od of extended operation:
The LLRT of V-26-8 de termined that the leakage rate wa s above th e alert li mit for that valve. The rate was evaluated to be acceptable as-found. The valve was subsequently rebuilt and retested satisfactori ly the ne xt refueling ou tage. This examp le provi des objective e vidence that leak rates ab ove admini strative li mits are iden tified for engineering ev aluation, a nd that correcti ve action s are taken prior to component lo ss of intended functio
: n. This issue was id entified in th e applica nt's CAP 0 2000-1355.
The LLRT of V-19-20 d etermined that the leakage rate ex ceeded the ac tion limit.
The valve was repaired and the post-maintenance test LLRT was acceptable.
This example provides objective evidence that components deter mined to exceed the allowable leakrates are ente red into the corrective a ctions process , identified for rep air, and subsequently retested in ac cordance w ith the program. Thi s issue w as identified in the applicant' s CAP 0200 2-1564.The LLRT of MSIV NS04A dete rmined that the leakage rate failed to meet acceptance criter ia. Th e main seati ng surfac e wa s lap ped an d a su ccessfu l LLR T was performed. As a result of this occurrence, the MSIV overhaul procedure w as revised to includ e a documented management review prior to el iminating seat lapping after popp et replacement ev en if a success ful blue chec k has been obtai ned. This ex ample provi des 44 objecti ve ev idenc e that a compo nent e xcee ding th e all owab le le ak rate w as ent ered i nto the co rrecti ve ac tions proce ss, rep aired , and s ubseque ntly retest ed per the pr ogram. This issue w as identified in the app licant's C AP 02004-344 2.Oyster Creek CAP O2005-1350 de scribes tw o issues regardi ng 10 CFR Pa rt 50 Appe ndix J t esti ng of comp onen ts:  1.) Fe ed wat er pip ing e xpans ion be llows (consi dered to be u ntesta ble) a re not local leak ra ted tes ted. Th e bel low s are pressurized during Integrated Le akage Rate Testing. Tw o main steam be llows and these two fee d wa ter bel low s wer e the s ubject of a rel ief reque st from l ocal leak ra te testing due to the ir design. The main steam bel lows w ere specifical ly iden tified in the exem ptio n; th e fe ed wat er be llows we re no t. Cla rif icat ion of the f eed wat er be llows exemption s tatus is currentl y in proc ess. 2.) Shutdo wn Cool ing isolati on valv es are not leak ra te test ed due to a s ystem configur ation that l acks in board test bo undary val ves. Although a prev ious NRC conclusion determined tha t these val ves did not require an exemption, a n error exi sted in the o riginal ex emption submitta
: l. Documentati on is not available to indicate these valves have ever been leak rate tested. Clarification of this issue status i s in process.
These exampl es provid e objective evidenc e that deficien cies in the Appe ndix J p rogram are entered i nto the correcti ve action process.The applican t concluded that the operati ng experienc e of the Appendi x J LRT program di d not show any adverse tren ds in performance.
Problems ide ntified wou ld not cause significant impact to the sa fe operation of the p lant, and ad equate correctiv e actions w ere taken to prev ent recurrence. Ther e is sufficient conf idence that the implementation of the LRT program will effectiv ely mainta in the integr ity o f contai nment, p enetra tions , and o ther ac cess o penin gs. Periodic s elf-assessments of the L RT program are performed to i dentify the are as that need improv ement to mainta in the quali ty pe rformance of the p rogram.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d program basis document, and interviewed the applicant's technical staf f to confirm that the plant-specific operating exp erience did not reveal any degradati on not bound ed by in dustry ex perience.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's 10 CFR Pa rt 50, Appen dix J progra m wil l ade quatel y mana ge the a ging effect s that are id entifi ed in the OC GS LRA for whi ch this AM P is credi ted.3.0.3.1.6.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e 10 CFR Part 50, Appendix J program in OCGS LRA, Appe ndix A, S ection A.1.29, whi ch states that the 10 CFR Part 50, Appen dix J program detects degradati on of the contai nment structure and components that comprise the contai nment p ressur e boun dary, incl uding seals and ga skets. C ontai nment l eak rate tests a re performed to assure tha t leakage through the p rimary contai nment and sy stems and compon ents p enetra ting pr imary conta inment does not ex ceed a llow able leakage limi ts specified in the technica l specificati ons. This program co mplies w ith Option B requirements of 10 CFR Part 50 Appendi x J wi th plant-speci fic exceptio ns approved by the N RC as part of license amen dments, and impl ements the guidel ines prov ided in R G 1.163 and NE I 94-01.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.29 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry 45 description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.6.7 Conclusio n On the basis of its audit and review of the applicant's prog ram, the project team found that all the program elements are consistent with the GALL Report. On the basis of i ts review of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.1.7 Masonry Wall Program (OCGS AMP B.1
.30)In OCGS LRA, Ap pendix B , Section B.1
.30, the appli cant stated that OC GS AMP B.1.30,"Masonry Wall Program," is an exi sting plant pro gram that is consi stent with GALL AMP XI.S5,"Masonry Wall Program."  The applican t stated that the Masonry Wall Program is implemented through its st ructure s moni toring program (OCGS AM P B.1.31).Because the a pplicant i mplements its M asonry Wall Program through its structures monitori ng program, the pro ject tea m also confirm ed tha t the s cope o f the stru ctures monito ring pr ogram, which i s evalua ted in Secti on 3.0.4.2.24 of thi s audit and review report, inclu des the eleme nts of the M asonry Wall Progra m.3.0.3.1.7.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program is p art of its Structures Monitori ng Program (OCG S AMP B.1.31). The program is based on the g uidance provided in Bull etin 8 0-11, ?Maso nry Wall D esign," and IN 87-67 , ?Lessons Learne d from Regional Insp ecti ons of Li cens ee A ctio ns i n Re spon se to Bul leti n 80-11," an d is imp leme nted thro ugh station proced ures. The scope of program includes all masonry walls that perform an inte nded function in accordance with 10 CFR 54.4. The prog ram requires inspect ion of masonry walls for cracking on a frequency of 4 years, so that the establ ished ev aluation b asis for each masonry w all remains valid during the peri od of extended operation.
3.0.3.1.7.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B.1.30 is consis tent with GALL AMP XI.S5.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.30, includin g PBD-AMP-B.1.30, "Mas onry Wall Program," Revi sion 0,12/18/0 5, which provides an assessment of the AM P elements' co nsistency with GALL AMP XI.S5.
For additio nal information, see S ection 3.0.3.2.2 4.2 of this audi t and revi ew report.
The project team found that the appli cant's Ma sonry Wall Program conforms to the recommended GALL A MP XI.S5.3.0.3.1.7.3 Exce ption s to th e GALL Repor t None 46 3.0.3.1.7.4 Enhan cements None 3.0.3.1.7.5 Operating Expe rience The app lica nt stat ed, in the OC GS LRA and th e progra m basi s docu ment, th at the Maso nry Wall Program has pr ovid ed for d etecti on of cra cks, and other minor aging effec ts in masonry walls. Maintena nce history revealed minor degradatio n of masonry bl ock walls; but none that could impact their intende d function. Oys ter Creek masonry walls that perform an inten ded function under 10 CFR 54.4 h ave been systematical ly iden tified in acc ordance wi th the scopin g and screening methodolog y described in the LRA. The walls include walls identified in response to NR C Bulleti n 80-11, USI A
-46, and those that perform 10 CFR 54.48 intende d function. Review of industry operating experience has conf irmed that cracking of masonry walls has occurred in the past (NRC Bulletin No. 80-11; NRC IN 87-67. In res ponse to NRC Bulletin 80-11, ?Maso nry Wall D esign," and IN 87-67 , ?Lessons Learne d from Regional Ins pections of Licensee Ac tions in R esponse to Bu lletin 80-11," variou s actions w ere taken. Actio ns include d modifications o f some walls and removal of others, program enhan cements, follow-up inspections to substantia te masonry w alls anal yses and c lassification s, and the dev elopment of procedures for t racking and record ing changes to the walls
. These actions addressed all concerns raise d by Bul letin 80-11 and IN 87-67 , namely un analyz ed conditio ns, improper assumptions, i mproper classi fication, and l ack of procedural co ntrols.The applican t's operating e xperience review process incl udes both ex ternal and i nternal source s. Ex ternal opera ting ex perie nce may incl ude su ch thi ngs as I NPO do cuments (e.g., SOERs, SERs, SENs, etc.), NRC docum ents (e.g., G Ls, LERs, INs, etc.), General Electric documents (e.g., RCSIL s, SILs, TILs, etc.), and other documents (e.g., 10CFR Part 2 1 Reports, NERs, etc.). Inte rnal operati ng experienc e may incl ude such thi ngs as event investigati ons, trending reports, an d lessons l earned from in-hous e events a s captured in program notebooks, self-assessments, and in the 10 CFR Part 50, Appendix B correctiv e action proc ess.The app licant pr ovided the following examples o f oper ating e xperienc e to provid e object ive evidence that the M asonry Wall Program is effectiv e in assuri ng that intended function(s) wi ll be maintained c onsistent w ith the CLB for the period of ex tended operati on: CAP No. 020 03-0038 w as issued to document and evaluate degraded and mis sing mortar between masonry blocks on a fire barrier masonry wall in the lower cable spreading room. The degraded and mis sing mortar was evaluate d by the qual ified structural engine er and the fire p rotection engine er. The structural engineer concl uded that the degraded and miss ing mortar does not adversely impact the masonry wall structural inte grity. The fire prote ction enginee r concluded that the observ ed conditio n of the fire barrier maso nry wal l does not render the barri er inoperabl
: e. Action R equest#A2 0523 36 w as ge nera ted t o rep air the m ason ry w all and rest ore i t to i ts de sign condition.
CAP No. 020 02-0065 w as issued to document and evaluate small cracks in a fire barrier masonry w all in th e turbine bu ilding. The c racks were ev aluated by the qualified structural engine er and the fire p rotection engine er. The structural engineer concl uded that the small cracks have no impact on the structural in tegrity of the masonry wall. The fire protection en gineer determined that the cracks do not impact the fire barrier intended function of the masonry wall.
47 The applican t concluded that the operati ng experienc e of the Maso nry Wall Program did not show any adverse tren d in performance.
Problems ide ntified wou ld not cause significant impa ct to the safe operati on of the plant, and adequate co rrective acti ons were ta ken to prevent recurrence. Ther e is sufficient conf idence that the implementation of the Masonry Wall Program will effectively determine cracking.
Appropriate gui dance for reeva luation, repa ir or repla cement is pro vide d for lo catio ns wh ere cra cking ha s occu rred. P eriod ic sel f-assess ments of the M asonry Wall Progra m are p erformed to ide ntify the are as tha t need impro vemen t to mainta in the quali ty pe rformance of the p rogram.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d the program basis docu ment, and interv iewed th e applica nt's technical staff to confirm that the plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Masonry Wall Program will adequately manage the aging effects that are identified i n the OCGS LRA for which thi s AMP i s credited.
3.0.3.1.7.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Masonry Wall Progr am in OCGS LRA, Appendix A, Section A.1.30, whi ch states that the Masonry Wall Program manages aging effect s so that the evaluation basis established for each ma sonry wall WSLR remains valid through the perio d of extended operation. The applicant' s Masonry Wall Program is based on the structures mon itoring requirem ents of 10 CFR 50.65. The applicant's Masonry W all Program is imple mented by i ts structures monito ring program for managing speci fic aging effects.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.30 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.7.7 Conclusio n On the basis of its audit and review of the applicant's prog ram, the project team found that all the program elements are consistent with the GALL Report. On th e basis of its review of the UFSAR Suppl ement for this program, the pro ject tea m found t hat it prov ided an ade quate summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.1.8 Protective Coating Mo nitoring and M aintenance P rogram (OCGS AMP B.1.33)In OCGS LRA, Ap pendix B , Section B.1
.33, the appli cant stated that OC GS AMP B.1.33,"Protective Coating Monitoring and Maintenance Prog ram," is an existing plant progr am that is consi stent w ith GA LL AM P XI.S8 , "Prot ectiv e Coat ing M onito ring an d Ma inten ance P rogram." 3.0.3.1.8.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for aging management o f Service L evel I co atings insid e the primary containment an d Service Level II coatings for the 48 external drywell shell in the area of the sand bed region. Service Level I coatings are used in areas where the coating failure could adversely aff ect the operation of post-accident fluid syste ms and thereb y imp air sa fe shutd own. Oyste r Cree k was not ori ginal ly c ommitte d to Regulatory Gui de 1.54 for Serv ice Leve l I coatings b ecause the pl ant was l icensed pri or to the issuance of thi s Regulatory Guide in 19
: 74. Currently , Oyster Creek is committed to a mod ified version of this Regulatory Guide, as descr ibed in the response to GL 98-04, and, as detailed in the E xel on Qu ali ty A ssur ance Topi cal Rep ort (QATR) NO-AA-1 0. S erv ice Lev el I I coa ting s provi de cor rosio n prote ction and d econta minabi lity in th ose ar eas ou tside of the p rimary containment that are subject to rad iation ex posure and rad ionuclid e contaminatio
: n. The Protective Coating Mo nitoring and M aintenance P rogram provides for visual i nspections, assessment, and repairs for any condition that adversely affec ts the ability of Service Level I coatings, or sand bed region S ervice Le vel II coa tings, to function as intended.
3.0.3.1.8.2 Consi stency wit h the GA LL Rep ort In OCGS LRA, the applican t stated that OCGS A MP B.1.33 is consis tent with GALL AMP XI.S8.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.33, incl uding PBD-A MP-B.1.33, ?OCGS Program Basis Document:  Protec tive Coati ng Monitori ng and Mai ntenance Program," Re
: v. 0, wh ich provi des an assess ment of the AMP elements' consistency with GALL AMP XI.S8.
Specificall y, the project team review ed the program elements (see S ection 3.0.2.1 of this audit a nd review report) contain ed OCGS AM P B.1.33 and associated b ases documents to determine thei r consistency with GALL AMP XI.S8.
The project team als o review ed SP-1302-52
-120, "Specificati on for Inspection and Locali zed Repair of the Torus and Vent Sy stem Coating", Rev. 2, July 2003, and Ca lculation C-1302-187-E 310-03 8, ?Oyster Creek Torus C orrosion Al lowabl e Pit Depth", Rev. 0, Octobe r 2002.The project team noted that the descri ption of AM P B.1.33 in the LRA is not completely clear about whi ch coatings are credited for corrosi on protection of metal surfaces. In res ponse to a question, the app licant cla rified that Serv ice Leve l 2 coatin gs are used onl y for corrosion protection in the external drywell shell sand bed region. Similarly, while some service Level 1 coatings are use d to provi de corrosion protection, Oys ter Creek does no t credit them for corrosion prote ction for the dry well s hell abov e the sand be d region for lice nse renewa l purposes. An analysi s has been p erformed which demonstrates that the upper portio n of the drywel l vessel will meet ASME code requirements for the remaining l ife of the plant ba sed on corrosion rates.
The corrosion of the drywe ll shell above the sand bed regi on is consi dered a TLAA an d is fur ther de scribe d in L RA Se ction 4.7.2. How ever, Serv ice L evel 1 coa tings a re credited for corrosi on protection for the vent hea der and torus.
The applican t further stated in re sponse to an audit question that for LOCA debri s generation and transport, the drywel l coating is qualified for a LOC A environ ment. The mass of coati ng released following a LOCA jet impingem ent was conservatively estimated at 47 lbs. No additional coating flaking was assumed due to the harsh environment since the coating is quali fied. C oatin g with in the vent syste m and to rus is expe cted to contri bute 0 lbs o f debri s to the suction strainer load following a LOCA. However, the applicant conser vatively assumed in the a nal ysi s tha t 10 lbs of de bris is a ttri bute d to the v ent s yst em an d tor us c oati ng.
49 The pro ject tea m also asked t he app lica nt to c larify whe ther an y Ser vice Leve l III c oatin gs are credited for corrosi on protection for license rene wal. In response, the a pplicant sta ted that Exel on Cor porate Proce dure E R-AA-3 30-008 in pa ragraph 2.7.3 define s Serv ice L evel III coatings as coa tings used on any exp osed surface area located outsi de containment whose failur e coul d adv ersel y affect normal plan t opera tion, or orde rly a nd safe plant shutd own. Servi ce Lev el III coati ngs are also used i n area s outsi de the reacto r conta inment whe re fail ure could adve rsely affect the safety functio n of a sa fety-re lated structu re, sy stem, or compon ent. Oyster Creek Spec ification SP
-9000-06-004, i n paragraph 3.2.1.c, specifies the u se of Service Level III coatings on structu res/components subj ected to a corrosive environment (e.g
., liquid immersion, saltwater contact , underground burial, outd oor exposure, etc.). For license renewal, Service L evel III coa tings are only credited for corros ion protectio n for the externa l surfaces of piping and fitti ngs exposed to a soil (external) e nvironment i n the emergency service w ater sys tem, serv ice wa ter s yst em, a nd ro of dra in a nd o ver boar d di scha rge s yst em. T hese coa ting s are managed under the Buried P iping Inspecti on  aging management p rogram, B.1.26. Other than th e Serv ice L evel I and II coat ings di scusse d in P BD-AM P-B.1.33, an d the S ervi ce Lev el III coatings descri bed in respo nse to this ques tion, no other protective c oatings are credi ted for corrosion protection f or license renewal.
The project team als o noted that the discussio n in LRA Table 3.5.1, Item Nu mber 3.5.1-15, appears to id entify a larger scope than the scope iden tified in the AMP des cription. The project team asked the appl icant to cla rify this. In response, the a pplicant sta ted that the structu res and/or components and envi ronments "rolled-up" into LRA Table 3.5.1 Item N umber 3.5.1-15 (refe renc e LR A Tab le 3.5.2.1.1 for p rima ry c onta inme nt) i ncl ude the fo llo wi ng:*Access hatch covers - containment atm osphere (internal)
*Down comers - cont ainmen t atmosp here*Drywell penetration sleeves - containment atmosphere (inte rnal)*Drywell shell - containment atmosphere (internal) and indoor air (exter nal)*Personnel airlock/equ ipment hatch - containment at mosphere (internal)
*Suppression chamber penetr ations - containment atmosp here (internal)
*Suppression chamber ring g irders - containment atmo sphere (external)
*Suppression chamber shell - containment atmosphere (internal)
*Vent line, and vent header - containment atmosp here (internal) and indoor air (external)
*Downcomers
- immersed
*Suppression chamber ring girders
- immersed
*Suppression chamber penetrati ons - immersed
*Suppression chamber shell
- immersed The applican t stated that for Serv ice Leve l I coatings, the Protective Coating M onitoring and Maintenance Program is not used to manag e loss of material for access hatch covers, drywell penetration sl eeves, and personnel ai rlock/equipment hatch exposed to a containment atmosph ere (i nterna l) env ironme nt. Ac cordi ngly, LRA Ta ble 3.5.2.1.1 for the prima ry containment w ill be re vised to delete the P rotective C oating Moni toring and M aintenance Program (B.1.33) from the se comp onent types expo sed to a con tainme nt atmos phere environment.
For Servi ce Level II coatings, the P rotective C oating Moni toring and M aintenance Program is not use d to manage corrosi on for the vent line, and vent heade r exposed to an indoor air (external) e nvironment.
Accordingly , LRA Table 3
.5.2.1.1 and Tabl e 3.5.1, item 3.5.1-15, wi ll be rev ised to del ete the Protecti ve Coatin g Monitori ng and Mai ntenance Program (B.1.33) from thi s compo nent ty pe ex posed to an indoo r air e nvir onment.
50 In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise LRA Tabl es 3.5.2.1.1 and 3.5
.1 to delete the Protectiv e Coating M onitoring and Maintena nce Program (B.1.33) from line i tems to manage loss of material for acces s hatch cov ers, drywe ll penetrati on sleev es, an d pers onnel airl ock/equi pment h atch e xpos ed to a conta inment atmosp here (internal) env ironment, and l ine items to manage corrosion for the vent li ne, and ve nt header exposed to an indoor a ir (external) environmen
: t. This is i dentified as Aud it Commitment 3.0.3.1.8-1.
The project team found the applican t's clarificati ons acceptabl e, because the y defined the scope of coati ngs cred ited fo r corro sion protec tion, and al so defi ned th e coat ings th at are specifically monitored and maintained by AMP B.1.33 for license renewal.
During its rev iew of pla nt-specific opera ting experie nce related to containment de gradation, the project team asked a number of questions a bout the impl ementation of AM P B.1.33 for the exterior surface of the sand bed region and for the s ubmersed interi or surface of the torus.
The project team's i nquiries and assessments of the ap plicant's responses are documented in the evaluati on of the appli cant's ASM E Section XI, S ubsection IWE program (B.1.27), in Section 3.0.3.2.22 of th is au dit an d rev iew report.The project team rev iewed th ose portions of the applica nt's Protectiv e Coating M onitoring and Maintena nce Program for whi ch the appli cant claims c onsistency with GALL AMP XI.S8.
3.0.3.1.8.3 Exce ption s to th e GALL Repor t None 3.0.3.1.8.4 Enhan cements Although the LR A did not i dentify any enhancements for A MP B.1.33 , PBD-AM P-B.1.33,?OCGS Pr ogram Ba sis D ocumen t:  Prot ectiv e Coat ing M onito ring an d Ma inten ance P rogram,"Rev. 0, id entified the foll owing enha ncement in ord er to meet the GALL program elements:
Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 6. Acceptance Criteria Enhan cement:?The insp ection of Service Leve l I and Servic e Level II pr otecti ve coatings that are credited for mitigati ng corrosion on interior surfaces of the Torus shel l and ve nt system, and, on exterio r surfaces of the Dryw ell shel l in the a rea of the sand b ed region, w i l l b e c o n s i s t e n t w i t h A S M E S e c t i o n X I , S u b s e c t i o n I WE require ments."The GALL Report i ncludes the following re commendations for the
?parameters monitored or inspe cted," ?detection of aging effects," and
?accept ance c riteri a" progr am ele ments re lated to the enhancement stated: 3. Parameters Moni tored or Inspected
:  Regulatory Position C4 in RG 1.5 4, Rev. 1, sta tes tha t "A STM D 5 163-96 pro vi des gui del in es t hat are acc ept abl e to the NR C s taff for establishin g an in-servi ce coatings moni toring program for Servi ce Level I coating systems in o perating nucle ar power p lants..." ASTM D 5163-96 ha s been supers eded by 51 ASTM D 516 3-05. A STM D 5163-05, su bparagr aph 10.2, id entifi es the parame ters moni tore d or ins pect ed to be " any vi sib le d efect s, su ch a s bl iste ring , cra ckin g, fla king, peeli ng, rusti ng, and phys ical damage." 4. Detect ion o f Agin g Effec ts:  ASTM D 5163-05, paragraph 6, defines the i nspection frequency to be ea ch refueling outage o r during other major maintenance ou tages as needed. ASTM D 5163-05, p aragraph 9, discu sses the quali fications for inspe ction pers onne l, th e insp ecti on co ordi nato r and the in spec tion resu lts e valua tor. AST M D 5163-05, subpa ragraph 10.1, disc usses deve lopment of the in spection pl an and the inspection methods to be us ed. It states, "A general vis ual inspe ction shall be condu cted o n all readi ly a ccessi ble c oated surfaces durin g a wa lk-thro ugh. Afte r a walkthrough, or d uring the general visual inspection, thorough visu al inspecti ons shall be carried out on previous ly desi gnated areas and on areas noted as deficient during the walk-through. A thorough visu al inspecti on shall also be carri ed out on al l coatings ne ar sumps or screens associated with the Emer gency Core Cooling System (ECCS)."  This subp arag raph also a ddre sses fiel d doc umen tat ion of inspe ctio n res ults. AST M D 5163-05, subpa ragraph 10.5, ide ntifies instruments and equipment n eeded for inspection.
: 6. Acceptance Criteria
:  ASTM D 516 3-05, s ubpara graphs 1 0.2.1 t hrough 10.2.6 , 10.3 and 10.4, conta in one acce ptable method for characterizati on, documentatio n, and testing of defective or deficient coa ting surfaces. Addi tional AS TM and othe r recognized test methods are a vailabl e for use in ch aracterizin g the severity of observed d efects and deficiencies.
The evalu ation cov ers blisteri ng, cracking, flaking, peeli ng, delaminatio n, and rusting. AS TM D 5163-0 5, paragraph 12, a ddresses ev aluation.
It specifies that the inspecti on report is to be eval uated by th e responsibl e evalua tion personne l, who prepar e a su mmary o f findin gs and r ecommen datio ns for futu re surv eill ance o r repai r, including an analysis of reasons or suspected rea sons for failure.
Repair work is prioritized as major or minor def ective areas. A recommended corr ective action plan is require d for majo r defecti ve ar eas, so that th ese ar eas ca n be re paire d duri ng the s ame outage, if appropria te.The inclusi on of this enha ncement in B.1
.33 resulted from di scussions be tween the project team and the ap plicant duri ng the October 3-7, 2 005 on-site a udit. At that time, the appl icant indicated i ts intention to use the Pro tective Co ating Moni toring and M aintenance P rogram in lieu of the requirements of ASM E Section XI, S ubsection IWE, for inspection of coatings. The project team noted that a Protectiv e Coating M onitoring and Maintena nce Program can be credi ted for c orrosi on miti gation , but i s not a substi tute for IWE inspecti on requ iremen ts. On this basis, the applica nt committed to i mplement the app licable IW E requirements for contai nment c oatin gs insp ectio n in i ts Prot ectiv e Coat ing M onito ring an d Ma inten ance P rogram.The project team asked th e applica nt to clarify what changes are necessary to make the Protec tive Coati ng Mo nitori ng and Mai ntenan ce Pro gram con sisten t wi th ASM E Sect ion XI, Subsection IWE requirements. In its response, th e applica nt stated that the requirements for coating inspec tions are in cluded in Oyster Creek spe cifications:  S P-1302-52-120,"Specification for Inspection an d Localiz ed Repair o f the Torus and Vent System Coati ng" and IS-328227-004, "F unctional R equirements for Dryw ell Contai nment Vessel Thickness Exami nati on."  Thes e spe cif icat ions do not curr entl y invok e all of the r equ irem ents of AS ME Section XI, Sub section IWE. The followi ng requirements wi ll be in cluded in these inspe ction specifications
:
52 1. Torus and v ent sy stem in ternal coati ng insp ectio ns wi ll be per Ex aminat ion C ategory E-A and w ill require VT-3 visual examinati ons per IWE-3510.2. The inspe cted area shal l be exa mine d (as a mi nimu m) for evi denc e of fl akin g, bl iste ring , pee lin g, discolorati on, and other s igns of distress. A reas that are su spect shall be disposi tioned by en gineer ing ev aluat ion o r corre cted b y rep air or repla cement in ac cordan ce wi th IW E-3122. Supp lemental ex aminations i n accordance with IWE-3200 shall be performed when s pecified as a result of enginee ring evalua tion.2. San d bed Region exte rnal c oatin g inspe ction s wi ll be per Ex aminat ion C ategory E-C (augment ed ex aminat ion) a nd w ill require VT-1 v isual exami natio ns per IWE-3412.1.
The i nspe cted area sha ll b e ex amin ed (a s a m ini mum) for ev ide nce of fla king, bli ster ing, peeling, dis coloration, a nd other signs o f distress. Areas that are suspect shall be dispositioned by engineering evaluation or correcte d by repair or replacement in accordance w ith IWE-3122. Supplemental examinati ons in acco rdance wi th IWE-3200 shall be performed when s pecified as a result of enginee ring evalua tion.In its letter d ated April 4, 2006 (M L060970288), th e applica nt committed to the following:
The coati ng insi de the torus wil l be v isual ly i nspect ed in accord ance w ith AS ME S ectio n XI, Subsection IWE, per the protec tive coati ngs program. This commitment will be performed every other refueling outag e prior to and during the period of extended operation. This is A udit Commitment 3.0.3.1.8-2.
The project team finds th is enhancemen t to the Protecti ve Coatin g Monitori ng and Mai ntenance Prog ram t o be acc epta ble , bec ause it e nsur es th at th e req uire ment s of I WE rela ted t o co atin gs inspection will be implemented during the ex tended period of operation.
3.0.3.1.8.5 Operating Expe rience The applican t stated, in the OCGS LRA and the program basis document, that Oy ster Creek has succ essfu lly ide ntifi ed i ndi cati ons of age-rel ated degr adat ion in S erv ice Lev el I coa ting s prio r to t he l oss of in tend ed fu ncti ons and has taken app ropr iate corr ecti ve a ctio ns th rough evaluati on or repair in accordanc e with th e Service Level I coatings procedu res and specifications. The applicant further stat ed that the Service Level II coating eff ort completed in 14R has bee n effective in mi tigating corrosion in the san d bed area.
The applican t stated that Oys ter Creek was not originall y committed to Regulatory Gui de 1.54 becau se the plan t was lice nsed p rior to the i ssuanc e of thi s Regul atory Guide in 19 74. Currently, Oy ster Creek is commi tted to a modified version of this Regulatory Guide, as descri bed i n the Oy ster Cr eek resp onse t o GL 98-04, an d, as d etail ed in the Ex elon Quali ty Assurance Topic al Report (QATR)
NO-AA-10. Oyste r Creek's response to GL 98-04 sati sfies the recommendation s for an acceptabl e coatings main tenance aging managemen t program (AMP) for li cense renew al as ide ntified in the "Program Descripti on" paragraph of NUR EG-1801 Chapter XI program XI.S8. The Oyster Creek program for moni toring and mainta ining Serv ice Leve l I co atings insi de con tainme nt is imple mented through speci ficatio n of app ropria te technical a nd quality recommendations o f RG 1.54, Rev. 0 , and American National Standards Institute (ANSI)
N101.2, "Protecti ve Coatin gs (Paints) for Light Water Nuclear R eactor Contai nment F acil ities ," and N101.4 , "Qual ity A ssuran ce for P rotecti ve Co atings Appli ed to Nucle ar Fac ilit ies."  The gui dance prov ided in El ectric Pow er Res earch Instit ute (EP RI)Technical Re port TR-109937, "Gui delines o n Nuclear S afety-Related C oating" has bee n evaluated and improv ements have been implemen ted to the program as appropriate.
The experience at Oyster Cree k with the P rotective C oating Moni toring and M aintenance P rogram 53 aging managem ent program shows that th e program is eff ective in managing Service Level I protective c oatings insi de the contai nment, and, in managing Servic e Level II coatings on the external d rywell shell i n the area of the sand bed regio n.The app lica nt stat ed tha t opera ting ex perie nce from both e xtern al an d inte rnal (also referred to as in-house) sources is rev iewed. External o perating expe rience may include su ch things as INPO documents (e.g., SOE Rs, SERs, SE Ns, etc.), NRC d ocuments (e.g., GLs, LER s, INs, etc.), Ge neral Elec tric d ocumen ts (e.g., RCSIL s, SILs , TILs, e tc.), an d othe r docu ments (e.g., 10CFR Part 2 1 Reports, NER s, etc.). Internal operating exp erience may include such things as event investigations, trending re ports, and lessons learned fr om in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction process.The applican t described th e followi ng examples o f operating experi ence as objecti ve evi dence that the Protecti ve Coatin g Monitori ng and Mai ntenance Program agi ng management program is effective in assuring that i ntended function(s) will be maintain ed consisten t with the CLB for the period o f extended ope ration: (1) Drywell:  The Oy ster Cr eek dry wel l int erior surfaces abov e the c oncret e floor , incl uding jet defl ectors, and th e ext erior of the d ryw ell a bove the w ater se al su pport bracket were ori ginally coated wi th one coat of Ca rboline Ca rbo-Zinc 11 p aint. The interior surface of the drywell below el. 12'-3" and the exterior surface of the drywell in direct contact w ith final sup port concrete w as not painte
: d. The potentia l for corrosion o f the dryw ell ves sel was first recognized when w ater was no ticed coming from the s and bed drai ns i n 19 80. Corr osi on w as l ater con firme d by ult raso nic thi ckne ss (U T)measurements taken in 1986 durin g the 11R refueli ng outage. During the 12R refuelin g outage in 1988 , the first extens ive correcti ve action , installati on of a cathodi c protection system, was taken. This prov ed to be in effective. The sys tem was remov ed during the 14R refueling ou tage in 1992.
The upper regions of the vessel , above the sand bed, were hand led separatel y from the sand b ed region beca use of the significa nt difference in corrosion rate and phy sical difference i n design. Corre ctive acti on for the upper vessel i nvolve d providi ng a corrosion allowa nce by de monstrating, through ana lysis, tha t the original drywel l design pres sure was c onservativ
: e. Amendment 165 to the Oyster Creek Technical Specification reduced the d rywell design pressure from 62 psig to 44 psig. Th e new desi gn press ure co upled wit h measu res to preve nt wa ter in trusio n into the gap betw een th e ves sel a nd the concre te wi ll al low the up per po rtion of the v essel to meet AS ME c ode for the rem ainde r life of the p lant.In the sand be d region, labo ratory testing d etermined the co rrosion mechani sm to be gal va ni c. T he hi gh r ate of c orr osi on in thi s re gio n re qui red pro mpt cor rec tiv e a cti on of a physical nature. Correcti ve action was define d as; (1) remov al of sand to b reak up the galvanic c ell, (2) remov al of the corrosi on product from the v essel and (3) applicati on of a protective coating. Keep ing the vess el dry w as also id entified as a requirement even though it wo uld be le ss of a concern i n this region once the coati ng was appl ied. The work was initiated during the 12R refueling outage in 1988 by removing sheet metal from arou nd the vent heade rs to p rovi de acc ess to the sa nd bed from the Torus ro om. During operatin g cycle 13 some sand w as removed a nd access hol es were cu t into the sand bed regio n through the shi eld wal l. The work w as finished d uring the 14R refueling outage in 1992
.
54 After sand removal , the concrete floo r was found to be unfinishe d with i mproper provisio ns for water drai nage. Correctiv e actions taken in this regio n during the 14 R refueling outag e in 1992 included; (1) cleaning of loose rust f rom the drywell shell, followed b y appli cation of epox y coating an d (2) removin g the loose de bris from the concrete floor foll owed by rebuildi ng and reshapi ng the floor wi th epoxy to allow drainage of any water that ma y leak into the region.
During 14R, UT measurem ents were taken from the outside surface of the drywell vessel i n the sand be d region. M easurements w ere taken in ea ch of the ten sand bed bays. The res ults of this i nspection an d the structural evaluati on of the "as found" conditio n of the vessel are c ontaine d in TDR No.
1108, "S ummar y Report of Correct ive Action Taken fr om Operating Cycle 12 Throug h 14R", Revision 0. As documented in TDR No. 1108, th e vessel was ev aluated to co nform to ASME code requirements gi ven the deteriorated thickness condi tion. In general these measurements verified project ions that ha d been made b ased o n measu rements taken fro m insi de the dryw ell. Several a reas were th inner than p rojected. In al l cases, the applicant foun d these areas met ASME code requirements a fter structural anal ysis.The coated surfaces o f the former sand bed regi on have b een subsequentl y inspecte d during refueling outages in 1994, 1996, 2000, and 2004 as docum ented in DCR 05-00023-00 A ttachment 1, Page 12 , paragraph 7.8.1.3.1.
The inspecti ons showe d no coating failure o r signs of deteriora tion. The appl icant therefore con cluded that th e cleaning, floor ref urbishing and coating ef fort completed in 14R has been effective in mitigating corrosio n in the sa nd bed area.
Since thi s was acc omplished w hile the v essel thickness wa s sufficient to sati sfy ASME code requirements, the applica nt has concluded th at drywe ll vess el corrosion in the san d bed region i s no longer a limiting factor in plant operation; how ever, inspe ctions are co nducted to ens ure that the coa ting remain s effecti ve. I n addi tion, UT measu rements are al so taken from ins ide th e dry wel l. The freque ncy a nd ex tent of t he coa ting i nspect ions and UT thickne ss meas uremen ts are as follow s: C For the upper elevatio ns, UT measurements a re taken every second refueli ng outage. After each i nspection, a determination will be made if addi tional inspection is to be pe rformed. Although protec tive coati ng is not credi ted for corros ion mi tigati on in these areas , the c oatin g is in specte d to en sure i ts int egrity for the purpose of main taining ECCS suction strai ner debris l oading assumptions.
C For the sand bed re gion, v isual insp ectio n of the coati ng is p erformed every second refueling outa ge. After each inspect ion, a determination will be made if additional inspection is to be p erformed.C For water l eakage not associa ted with refueling activ ities, an i nvestigation will be made as to the source of the lea kage. Oyster Creek w ill take corre ctive acti ons, evaluate the impact of the l eakage and, if necessa ry, perform an addi tional drywel l inspecti on about three months after the disc overy of the water lea kage.Calculati on Number C-13 02-187-E310-03 7, "Statistical Analysi s of Drywel l Vessel Thickness Data," Re vision 2, provide s the eval uation of the l atest dryw ell UT ins pections performed by IS-328 227-004 (through N ovember 2004
). Oyster Creek ha s committed 55 to notify the N RC prior to implementing an y changes to the dryw ell thickness measure ment in specti on pro gram.The drywel l coating hi story and op erating experi ence provi des objectiv e eviden ce that previous corrective a ctions hav e been effective in mitigating co rrosion in the sand bed region and that the Protectiv e Coating M onitoring and Maintena nce Program aging management program is effectiv ely impl emented to ensure that the inten ded function of systems, structures, and components within the scope of li cense renew al wil l be maintained d uring the exte nded period of operation.
(2) Torus a nd Ven t Sys tems:  The Oyster Creek tor us and vent system were originally coated wi th one coat of Ca rboline Ca rbo-Zinc 11 p aint. In 198 3, the Torus inte rior surfaces, the interi or of the Vent Sy stem up to the dry well a nd all ex ternal surfaces of the Vent Sy stem were grit b lasted to SS PC-10 or SSP C-5 at 1 1/2 - 3 mils profile.
Pitted surfaces of i mmersed Torus shell were repa ired by w elding. Rou gh areas of Torus sh ell w ere bl ended by gri nding. Mob il 46-X-16 E poxy Fill er wa s appl ied to selected pitted areas of th e Torus immersed shell portion pr ior to coating. Surfac es in the V ent S yst em th inn ed b y co rros ion we re re pai red b y w eld ing.The immersed bottom ha lf of the torus shel l, the interi or of the down comer and the entire interior surfa ces of the Vent System were given 3 coats of Mobil 78 Hi-Build Epoxy (DFT-16 mils). The vapor phase upper half of the to rus shell, e xterior of the V ent Header and vent lines portions inside the torus were given two coats of Mobil 78-Hi Build epox y (DF T-10 mil s).Follow ing coating appl ication, the entire torus i nterior wa s heat cured a t 108/F for 48 hours. Demine ralized water w as put back in the torus. Subs equent to this co ating appli catio n, mino r coati ng repa irs ha ve be en per formed us ing BR UTEM-15 (U T-15).De-sludging, in spection, and repair of the i nterior coatin g of the torus shell and vent system located above and below the water line is performed during ref ueling outages in accordance w ith Specifica tion SP-1302 120. Torus an d vent hea der vapor s pace Service L evel I co ating inspecti ons performed in 2 002 found the co ating in these areas to be in good condition.
Inspection of the immersed coating i n the torus id entified blistering. The blistering occ urred primaril y in the shell in vert but w as also note d on the upper shell near the w ater line.
The majority of the b listers remain ed intact and continued to protect the base metal. How ever, sev eral blis tered areas in cluded pi tting damage where th e blisters w ere fractured. A qual itative a ssessment of the id entified pits was performed and concl uded that the me asured pit de pths were s ignificantly less than th e esta blis hed ac ceptan ce cri teria. The frac tured b liste rs we re repa ired t o reesta blis h the p rotecti ve co ating b arrier.The tor us and vent system co ating h istory an d operat ing exper ience pro vides obje ctive evidence that previous corrective actions have been eff ective in mitigating corrosion in the torus and v ent system and that the Protecti ve Coatin g Monitori ng and Mai ntenance Program aging management program i s effectively implemented to ensure that the intended functio n of systems, structure s, and componen ts within the scope of l icense renewal will be maintaine d during the ex tended period of operation.
56 (3) Mis cell aneou s OE:  CAP No.
O2000-1429 id entified that a modification w as to add approx imatel y 28 square fe et of ho t dipp ed gal vani zed u nistru t steel to the dryw ell. Specification SP-1302-06-00 9, "Specificati on for Applica tion and Re pair of Servi ce Level I Coati ngs on F errous Meta l Surfa ces Oy ster Cr eek Nuc lear Ge nerati ng Stati on," Appendix A, for approved coatings insi de the primary containment, do es not incl ude galvaniz ed coating as an approve d coating. An evaluati on performed by th e engineering group c oncluded tha t a) DBA con ditions w ill not a dversely affect galvaniz ed surfaces or the functio ning of safety sy stems, b) hot dip ped galvani zed surfaces are not required to be D BA tested by any code , standard, or regul ation, and c) the additio n of this galvan ized uni strut steel to the drywel l was a cceptable. Thi s example provides objective e vidence that the additi on of unqualified coatings to the p rimary contai nment are evalu ated for impact on safety-related sy stems and structures
.CAP No. O200 3-2454 iden tified that the re placement motor for the "A" recircul ation motor was top coated wi th a non-DBA qualified coati ng on the motor hou sing, end bel ls, and stator. Engineering analysis concluded that the unqualified coating would minimally impact the strai ner debris l oading follow ing a postula ted LOCA and that any ad ditional head loss created by the additional unqualified coating was negligible. This example provi des ob jectiv e evi dence that th e addi tion o f unqual ified coati ngs to th e prim ary containment is evaluate d for impact on sa fety-related sy stems and structures
.In summary, the o perating expe rience of the Pro tective Co ating Moni toring and Maintenance Program aging management prog ram did not show any adverse trend in per form anc e. Pro bl ems id ent ifi ed wo ul d n ot c aus e si gni fic ant imp act to the saf e operation of the plant, and a dequate correctiv e actions w ere taken to prev ent recurrence. The ap plicant has sufficient confidence that the impl ementation of the Protective Coating Mo nitoring and M aintenance P rogram aging management program will effectively man age Service Level I c oatings insi de the primary containment an d Service L evel II co atings for the exte rnal dryw ell shel l in the a rea of the sand b ed region.
The project team rev iewed th e above o perating expe rience prov ided in th e LRA and the B.1.33 program basis docu ment, and also interview ed the appl icant's techni cal staff. The project team determined that the OCG S plant-specific operating experience with containment degradation is unique , and i s not b ounde d by indus try ex perie nce. A s disc ussed abov e, in Secti on 3.0.3.1.8.2 of this audit a nd review report, the project team's revi ew of operati ng experienc e led to a number of questions a bout the impl ementation of AM P B.1.33. As a result of these inquiries, the pro ject tea m iden tified an au dit op en ite m.3.0.3.1.8.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Protective Coating M onitoring and Maintena nce Program in OCGS LRA, Appen dix A, S ection A.1.33, which sta tes that the Protective Coating Mo nitoring and M aintenance P rogram is an ex isting program that pro vides for aging management of Servi ce Level I coatings in side the pri mary contain ment and Serv ice Level II c oatings for the ex ternal dryw ell shel l in the a rea of the sand b ed region. Se rvice Lev el I coatings are us ed in areas where the coating failure c ould adv ersely affect the o peration of post accident fluid systems and ther eby impair safe shutdown. Oyster Creek was not originally committed to Regul atory Guide 1.54 for Servic e Level I coatings becau se the plant was licensed prior to the issuance of this Reg ulatory Guide in 1974. Currently, Oyster Creek is committ ed to a modifi ed ve rsion of this Regul atory Guide , as de scribe d in t he res ponse to GL 98-04, and, as detailed i n the Exel on Quality Assurance Topi cal Report (QATR)
NO-AA-10.
57 Service L evel II co atings provi de corrosion protection and decontaminabi lity in those areas outside of the p rimary contai nment that are sub ject to radiati on exposu re and radio nuclide contamination.
The Protectiv e Coating M onitoring and Maintena nce Program provi des for inspections , assessment, and repairs for any condition that adversel y affects the abil ity of Service L evel I co atings, or sand b ed region Serv ice Leve l II coatings, to function as inte nded.In i ts l ette r dat ed A pril 4, 2 006, the appl ica nt co mmit ted t o the foll owi ng:*Implement the app licable ASME S ection XI, Subse ction IWE requirements for containment coa tings inspecti on in its Protective Coating Mo nitoring and M aintenance Program. (Audit Commi tment 3.0.3.1.8-2)
In i ts l ette r dat ed A pril 17, 2006 , the app lic ant c ommi tted to th e fol low ing:*Revise L RA Tables 3.5
.2.1.1 and 3.5.1 to delete the Protective Coating Mo nitoring and Maintena nce Program (B.1.33) from l ine items to manage loss of materia l for access hatch covers , drywel l penetration sleeves, and personnel airlock/equipment hatch exp osed to a con tain ment atmo sphe re (i nter nal) env iron ment , and lin e it ems t o man age corrosion for the vent line, and vent header exposed to an indoor air (exter nal)environment.  (Audit Commitmen t 3.0.3.1.8-1)
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.33. Contingent up on the inclusi on of audit commitmen ts 3.0.3.1.8-1, 3.0.3.1
.8-2 and resol utions to ope n item 3.0.3.2.22-3, the p roject team found that i t was cons istent wi th the GALL Re port, and determined that it provided an adequat e summary description of th e program, as identif ied in the SR P-LR F SAR S upple ment tab le an d as re quired by 1 0 CFR 54.21 (d).3.0.3.1.8.7 Conclusio n On the basis o f its audit and review of the applic ant's program and the plant-speci fic operating experience and discus sions wi th the appli cant's technica l staff, the project team i nitiated op en item 3.0.3.2.22-3 for primary containment (drywell) for further evaluation of the applicant's Protec tive Coati ng Mo nitori ng and Mai ntenan ce Pro gram.On the basis o f its review of the UFSAR Supplement for thi s program, the project te am found that, c ontin gent up on the incl usion of commi tments 3.0.3.1.8-1, 3.0.3.1.8-2, and resol ution s to open item 3.0.3
.2.22-3, it prov ided an ad equate summary des cription of the program, as require d by 10 CFR 54.21 (d).3.0.3.1.9 Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Qualification Requirements (OCGS A MP B.1.34)In OCGS LRA, Ap pendix B , Section B.1
.34, the appli cant stated that OC GS AMP B.1.34,?Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements," is a new plan t progra m that w ill be con sisten t wi th GALL AMP XI.E1, ?Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements."
58 3.0.3.1.9.1 Program Descriptio n In the OCGS LRA, the applicant state d that this program will be used to manage non-EQ cables and connections within the scope of li cense renew al that are su bject to adve rse locali zed environments. The applic ant stated that a n adverse localiz ed enviro nment is a con dition in a limit ed pl ant are a that is si gnifica ntly more se vere than th e spec ified servi ce env ironme nt for a subject cable or connection. An adverse variation in the environment is signif icant if it could appreciably increase the rate of aging of a compone nt or have an immediate a dverse effect on operabi lity.The app lica nt als o state d that cable s and conne ction s subje ct to a n adv erse e nvir onment are managed by i nspection of thes e components. A sample of access ible ele ctrical cabl es and connections installed in advers e locali zed env ironments w ill be v isually inspected for si gns of accelerated a ge-related degradati on such as e mbrittlement, disc oloration, cra cking, or surface contamination.
Additiona l inspecti ons, repairs, o r replacements a re initiate d as appropri ate.The applican t further stated that acc essible ca bles and co nnections l ocated in ad verse loca lized areas wil l be insp ected before the pe riod of extend ed operation, with an inspection frequency of at least once every 1 0 years. The scope of this pro gram includes i nspections o f power, control and instrumentati on cables, a nd connectio ns located i n adverse localiz ed areas.3.0.3.1.9.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.34 is cons istent wi th GALL AMP XI.E1.
The pro ject tea m inter view ed the appl icant's tec hnica l staff an d rev iew ed, in who le or in pa rt, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.34, incl uding program b asis d ocumen t (PBD) PBD-AMP-B.1.34 , ?Electrical Cables and Conne ction s Not S ubject to 10 C FR 50.49 Env ironme ntal Qu alifi catio n Requi rements ,"Revi sion 0, wh ich a ssesse s the A MP e lement s' con sisten cy w ith GA LL AM P XI.E1. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.34 and a ssoci ated b ases d ocumen ts to determine thei r consistency with GALL AMP XI.E1.
The project team rev iewed th ose portions of the applica nt's Electri cal Cable s and Conne ctions Not Subject to 1 0 CFR 50.49 Environme ntal Qualifica tion Requiremen ts Program, for which the applicant claims consistency with GALL AMP XI.E1, and found that they are consistent with this GALL Report AM P. The project team found that the app licant's E lectrical C ables and Connections Not Subject to 1 0 CFR 50.49 Environme ntal Qualifica tion Requiremen ts Program conforms to the recommende d GALL AM P XI.E1.3.0.3.1.9.3 Exce ption s to th e GALL Repor t None 3.0.3.1.9.4 Enhan cements None 59 3.0.3.1.9.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e Electrical Cables an d Connectio ns Not Subject to 10 C FR 50.49 Env ironme ntal Qu alifi catio n Requi rements Program is a new program. A review of plant-specific operating exp erience rev ealed ins tances of potentia l age-related degradation of cabl es identified during routine maintenance activiti es. These w ere remedied using the correcti ve action program. In each c ase, engineeri ng evaluati ons determined the cause of the appar ent deg radatio n, the ef fect on operab ility, and t he appro priate c orrect ive action.The project team als o review ed the operati ng experienc e provide d in the OCGS LRA and interview ed the appl icant's tech nical staff to confirm tha t the plant-spe cific operating e xperience did not rev eal any degradation not bounded by industry experience
.The staff believes that the correctiv e action proc ess wil l capture in ternal and e xternal pl ant operating issue s to ensure tha t aging effects are adequately managed.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technic al staff, the project team d etermined that the applican t's Electric al Cables and Co nnecti ons No t Subje ct to 1 0 CFR 50.49 Envi ronmen tal Qua lifica tion R equire ments Program will adequately manage the aging effects that are identified i n the OCGS LRA for which thi s AMP i s credited.
3.0.3.1.9.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Electrical Cables an d Connectio ns Not Subject to 10 C FR 50.49 En vironmental Qualification Requirements Pro gram in Section A.1.34 of Appendix A to the OCGS LRA, whi ch states that the Electrical Cables an d Connectio ns Not Subjec t to 10 CFR 5 0.49 E nvir onmenta l Qual ificati on Requ iremen ts Program is a new program that wil l be used to manage the aging of non-EQ cables an d connection s during the pe riod of extended operation. A representative sample of accessible cables and connections located in adverse l ocalize d environ ments wil l be vi sually inspected at least once e very 10 years for indication s of accelerated insulation aging such as e mbrittlement, disc oloration, cra cking, or surface contaminati on. An adv erse locali zed env ironment is a condition in a limi ted plant area that is signi ficantly more s evere than the specified s ervice en vironment for a s ubject electric al cable or con nection.The project team als o review ed the lic ense renew al commitment li st in Sectio n A.5 of the OCGS LRA to co nfirm that this program w ill be i mplemented before the period of ex tended operation and noted that i t is Item 34 on the list o f commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.34 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.9.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those portio ns of the program for whi ch the appl icant clai ms cons isten cy w ith th e GALL Repor t are consistent with the GALL Report. On the basis of i ts review of the UFSAR Supplement for 60 this program, the pro ject team found that i t provided an adequate su mmary descripti on of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.1.10 Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Environmenta l Qualificati on Requirements (OC GS AMP B.1.36)In OCGS LRA, Ap pendix B , Section B.1
.36, the appli cant stated that OC GS AMP B.1.36,?Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements," is a new plan t progra m that i s cons isten t wi th GALL AMP XI.E3, ?Inaccessible Medium-Vo ltage Cables Not Subject to 1 0 CFR 50.49 Environme ntal Qualifica tion Requir ements."3.0.3.1.10.1 Program Descriptio n In the OCGS LRA, the applicant state d that this new program will manage inaccessible medium-voltage cables that a re exposed to significant moi sture simultane ously w ith significant voltage.The applican t stated that si gnificant moisture i s defined as p eriodic ex posures to mois ture that lasts more th an a few days (e.g., a cabl e in s tandi ng wat er). Pe riodi c exp osures to moi sture that lasts le ss than a few days (e.g., normal rain and d rain) are not significant. Si gnificant voltage ex posure is de fined as bein g subjected to sy stem voltage for more than 25 percen t of the time.The app lica nt furthe r state d that OCGS ha s a tot al of 4 7 medi um-vo ltage c able insta llati ons. Becau se of the histo ry of me dium-v oltage cabl e fail ures a t OCGS, all 4 7 cabl e circ uits a re conser vati vely assume d to ha ve th e pote ntial to be expo sed to signi ficant m oistu re con ditio ns. Furthe rmore, a ll ar e cons ervat ivel y ass umed to be en ergiz ed more than 2 5 perc ent of th e time. Consequently , all 47 med ium-voltage ca ble circui ts are inclu ded in the scope of the Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements Program.The applican t stated that thi s program wil l also i nspect manhole s, conduits, an d sumps associated w ith the 47 ca ble circui ts (2.4 kV and 4.1 6 kV) for water col lection so that draining o r other correctiv e actions ca n be taken. Inspe ctions for wate r collectio n will be performed at le ast once e very 2 ye ars, an d the fre quency of testi ng wi ll be adjust ed bas ed on the res ults o btain ed. The first inspectio ns wil l be comple ted before the peri od of extended operation.
In addition , these medium-v oltage cable circuits w ill be e xamined us ing a proven test for detect ing de terior ation of the i nsula tion s ystem resul ting from wetti ng, such as po wer fac tor, partial di scharge, or polari zation i ndex, as d escribed in EPRI TR-10383 4- P1-2, or othe r testing that is state-of-the-art a t the time the te st is performed. Ca ble testing w ill be p erformed at least once e very 10 y ears, a nd the frequenc y of te sting w ill be adj usted depen ding o n the r esult s obtained. The first tests wil l be comple ted before the peri od of the exten ded operation. The applicant s tated that current methodologies a t OCGS implement a polariz ation inde x test as part of step voltage and me gger testing , and the applicant does not currently use, nor does it plan to use in th e future , pola riza tion i ndex testi ng as th e lon e cond ition monito ring te st in its AMP B.1.3 6.In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise AMP B.1.36 in the OCGS LR A to clarify that the appli cant does not use polariz ation inde x testing as the lone 61 condi tion mo nitori ng test fo r medi um-vo ltage c able circui ts. This is A udit C ommitmen t 3.0.3.1.10-1.In NRC Reques t for Additional Information (RAI) 2.5.1
.19-1, dated Se ptember 28, 2005 , the staf f expre ssed the need fo r additio nal info rmati on to cont inue its r eview of long-lived pass ive components of the Fo rked River co mbustion turbin es (FRCTs). By letters dated October 12, 2005, and No vember 11, 20 05, the appl icant provi ded its respo nses. The AM P B.1.36 program scope has be en rev ised to inc lude 13.8 kV inac cessi ble me dium-v oltage cabl es ass ociat ed w ith the FRCTs. In a ddition, as a result of the a pplicant's reconcili ation of the Sep tember 2005 revision of NUREG-1801 to the January 2005 draft revi sion, 34.5 kV sy stem cables w ill be added to thi s progra m.In it s let ter date d Marc h 30, 2006 (ML060950408), the ap plica nt co mmi tte d to r evise AMP B.1.36 in the OCGS LRA to i nclude 34.5 kV system cabl es in the p rogram. This commitment wil l be a dded t o the Ta ble A.5 Lic ense R enew al Co mmitment List Item No. 36. This is A udit Commitme nt 3.0.3.1.10-2.3.0.3.1.10.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.36 is cons istent wi th GALL AMP XI.E3.
The pro ject tea m inter view ed the appl icant's tec hnica l staff an d rev iew ed, in who le or in pa rt, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.36, incl uding PBD-A MP-B.1.36, ?Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Environmenta l Qualificati on Requirements," w hich assesse s the AMP elements' co nsistency with GALL AMP XI.E3.
Specificall y, the project team review ed the program ele ments (see Section 3.0.2.1 of this audit and revie w report) con tained in OCGS AMP B
.1.36 and asso ciated bases documents to determine the ir consisten cy wi th GALL AM P XI.E3.The p roje ct te am re vie wed thos e po rtio ns o f the appl ica nt's Inac cess ibl e M edi um-V olta ge Cables Not Subject to 10 C FR 50.49 En vironmental Qualification Requirements Pro gram for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.E3 and fou nd tha t they are consistent with this GALL Report AMP. The project te am found that the applicant
's Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requirements Program co nforms to the recommended GALL AMP XI.E3.3.0.3.1.10.3 Exce ption s to th e GALL Repor t None 3.0.3.1.10.4 Enhan cements None 3.0.3.1.10.5 Operating Expe rience In th e OCG S LR A, th e ap pli cant stat ed th at i t has exp erie nced 11 i nser vic e med ium-vol tage circuit failure s to date. Fi ve resulted from water intrus ion, four from manufacturing defects, a nd two from a singl e lightning stri ke. The majority of thos e failures occu rred in EPR-insulated
?UniShiel d" cables manu factured by Ana conda before 1985. In 1991, the applicant 62 impl emen ted a medi um-v olta ge ca ble test ing p rogra m cov erin g its 2.3 kV an d 4.1 kV medium-vol tage ci rcuits in an attempt to id entify cabl e degra datio n so th at app ropria te corrective a ction could be taken before failu re. That inspecti on program successfull y identi fied degrada tion i n XLPE-insu lated cabl es befor e fail ure. H owev er, the insp ectio n progra m faile d to identify degrada tion in the EPR-insul ated cables prior to failure. Testing performed unde r the current cable testing program successful ly iden tified degradation in XLPE-in sulated cabl es (e.g., GE Vulkene) such that replacemen ts could be made before inserv ice failures.
Eleven XLPE-insulate d cable ci rcuit replace ments have b een made base d on test resul ts since the testin g prog ram was im plement ed in 1991.
No inservice failur es of X LPE-insu lated cab le have occurred since the testing program w as implemented in 1991.Testing performed under the current cable testing program has n ot successfully identified degradation in EPR-insul ated UniShi eld type cables (e.g., Anac onda UniS hield), such that replacements could be made bef ore inservice failures. Five inservice failures of UniShield cable circuits exposed to moisture have occurred since the t esting program was implemented in 1991. Four o f the five failed cables w ere manufactured before U niShield manufacturing process improv ements were implemented i n mid-1984 to address manufacturin g defects.
Following t he most recent inservice c able fa ilure in 200 3, the ap plicant c omplet ed corr ective actions to (1) test failed cabl es to confirm the fail ure mechanisms, (2) confirm the accurac y of configuration informatio n for 4160V circ uits, (3) eva luate all remaining Uni Shield ca bles and repla ce or s chedu le for r eplac ement th ose man ufacture d before 1985 that mi ght be e xpos ed to significant moistu re, and (4) el iminate the future use of UniShi eld cable s at OCGS. The appli cant test ed 18 o f it s med ium-volta ge ca ble ci rcui ts in 2004 i n a tr ial us e of a new, state-of-the-art testing method based on parti al discharge.
As a result, o ne XLPE-insul ated cabl e w as re pla ced. The typ e of c abl e cu rren tly bei ng us ed fo r in acce ssi ble medi um-v olta ge cable repla cements is Okon ite Okogu ard, w hich is de signed to w ater-re sistan t crite ria. Additional medium-vol tage cables are scheduled for tes ting. The appli cant stated that th e current inspection prog ram will remain in effect until it is replaced by the Inaccessible Medium-Vo ltage Cables Not Subject to 1 0 CFR 50.49 Environme ntal Qualifica tion Requirements Program pri or to entering the period of ex tended operati on.The applican t stated that 31 cables are c urrently l ocated underground. Two unit substation (1A2 and 1B2) cables w ere rerouted and are at the top of the sand bed in the turbi ne buildi ng baseme nt. Tw o cabl es, on e for un it sub statio n 1B1 and on e for the B con densa te pump , wer e reroute d abov e groun d. Fut ure rer outes of two other c ables to abo vegrou nd lo catio ns are planned for refueli ng outage 1R21 i n 2006. These two cable s are for the 2C feedw ater and C condensate pu mp motors.
Currently, OC GS implements a medium-vol tage cable testi ng program for its 5 kV cabl es. The intent of the program i s to identify the potential for cable failure and impleme nt a replaceme nt before failure. Testin g has been compl eted for all 47 OCGS 2.3 kV and 4.1 kV cables.
Of the 42 4.1 kV cabl es, 38 hav e been tested using a new test methodology by DTE that performs an onli ne det ectio n of par tial disch arge meth odolo gy. Ei ghteen were tested in 20 04 and twen ty were tested in 2005 us ing the DTE method ology. The remai ning 2.3 kV and 4.1 kV cables have had th eir i nsula tion i ntegrit y che cked by step (from 1 kV t o 10 kV) vol tage tes ting. Addit ional ly, t he app lica nt has repla ced ap proxi mately 75 pe rcent o f its ori ginal 5 kV ca bles. The project team noted that the existing cable testing program and extensive cable replacements demonst rate the applicant's heightened att ention to medium-voltage cable issues.
63 The project team als o review ed the operati ng experienc e provide d in the OCGS LRA and interview ed the appl icant's tech nical staff to confirm tha t the plant-spe cific operating e xperience did not rev eal any degradation not bounded by industry experience
.The project team noted that OCGS AM P B.1.36 is a new pro gram that include s the underground circuits in the 2.4 kV, 4.16 kV, 13.8 k V, and 34.5 kV systems at OCG S. This program will test in-scope medium-voltage cables at OCGS to provide an indic ation of the condition o f the conductor in sulation. The specific typ e of test performed wi ll be an industry-end orsed, proven test for detecting dete rioration of the insulation system resul ting from wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-1038 34-P1-2, or o ther te sting th at is state-o f-the-art at the time th e test is pe rformed. Additional ly, insp ections for wa ter collecti on in the man holes, condu its, and sumps containing medium-voltag e cables with in the sco pe of th is prog ram will be per form ed as a pre ventive measure. The appl icant stated th at underground ci rcuits associ ated with the 13.8 kV ci rcuits at the FR CT pow er pla nt, as wel l as 3 4.5 kV c ircui ts that prov ide o ffsite feed s to OC GS, are included in the appl icant's XI.E3 p rogram. These circui ts date back to the installa tion of alternate ac c apabiliti es for station bl ackout (SBO) at OCGS i n 1989. There h ave been no failures reported on these cabl es.The pro ject tea m asked the ap plic ant w hether it ha s any plan s to tre nd the cabl e test data during the ex tended period of operation. The applicant s tated that ongoin g test results from the current OCGS mediu m-voltage cabl e testing program are b eing trended. Trend ing of test results wi ll contin ue through the pe riod of extend ed operation.
In its letter d ated April 17, 2006 (M L061150320) a nd in its response to au dit questions (ML060600122), the appl icant committed to revise A ppendix A Table A.05 commitment #36, and OCGS LRA Appendices A.1.36 and B.1
.36, to state that cable test/moni toring frequency will be at least o nce every 10 years, that it wi ll be adju sted based on test/monitoring resu lts, and that th e test resul ts wi ll be trende d. This is A udit C ommitmen t  3.0.3.1.10-3.The project team als o noted that the recent indus try concern w ith dc high-po tential testi ng and its impact on the life of cable s is not a c oncern at OCGS b ecause the majori ty of the medium-voltage cables at OCGS are tested usi ng partial di scharge and/or pow er factor testing methodologies.
The applican t stated that it is not currentl y implemen ting the hi-pot testing at OCGS as part of its medium-voltage cable testin g program except for five circuits feedi ng the 2.4 kV recircula tion pump motors.
These cables are dc step-v oltage tested to o nly a max imum of 4 kV. The industry concern regards h i-pot testing at v ery high dc voltages.The staff believes that the correctiv e action proc ess wil l capture in ternal and e xternal pl ant operating issue s to ensure tha t aging effects are adequately managed.On the basis o f its review of the above plant-specific operating exp erience, as w ell as discussions with the applicant's technical staff , the project team det ermined that the applicant's Inaccessible Medium-V oltage Cable s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requirements Program w ill adequate ly manage the aging effects that are ide ntified in the OCGS LRA for wh ich this A MP is credited.3.0.3.1.10.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Inaccessibl e Mediu m-Voltage Cable s Not Subject to 10 C FR 50.49 En vironmental Qualification Requirements Pro gram in Section A.1.36 64 of Appendix A to the OCGS LRA, whi ch states that the Inaccessibl e Mediu m-Voltage Cable s Not Subject to 1 0 CFR 50.49 Environme ntal Qualifica tion Requiremen ts Program is a ne w program that will be used to manage the aging of medium-voltage (2.3 kV, 4.1 k V, and 13.8 kV) cable circu its at OCGS. These cables may at times be e xposed to moisture and may be subjected to sy stem voltage for more than 25 percen t of the time. M anholes, con duits, and sumps associate d with th ese cable c ircuits w ill be i nspected for wa ter collecti on at least o nce every 2 years and drained as re quired. The first in spections w ill be c ompleted before the period of extended op eration. In ad dition, the cable circu its wil l be eva luated usin g a proven tes t for detect ing de terior ation of the i nsula tion s ystem resul ting from wetti ng, such as po wer fac tor, partial di scharge, or polari zation i ndex, as d escribed in EPRI TR-10383 4-P1-2, or other testing that is state-of-the-art a t the time the te st is performed. The c able circui ts will be tested at l east once every 10 years.
This new program will be implemen ted before the peri od of extended operation.
The applican t stated that the inclusion of the 13.8 kV sy stem circuits i n this program reflects the scope expa nsion of the SB O system electri cal commoditi es and the 34
.5 kV system cab les as a result of its reco nciliati on of the September 2005 revi sion of NURE G-1801 to the Jan uary 2005 draft revision
.The project team als o review ed the lic ense renew al commitment li st in Sectio n A.5 of the OCGS LRA to co nfirm that this program w ill be i mplemented before the period of ex tended operation, and noted that i t is Item 36 on the list o f commitments. In addi tion, the appl icant stated that it w ill rev ise Commitment 3 6 to address n ew audi t commitments 3.0.3.1.10
-1, -2, and -3.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.36. Contingent up on the inclusi on of commitments 3.0.3.1.1 0-1, 2, and 3, th e project team found th at it was consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.10.7 Conclusio n On the basis of its audit and review of the applicant's prog ram, the project team found that all the program elements are consistent with the GALL Report. On the basis of i ts review of the UFSAR Suppl ement for this program, conti ngent u pon th e inc lusi on of co mmitment s 3.0.3.1.10-1, 2, an d 3, the project team found that it p rovides a n adequate summary description of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.1.11 Environmenta l Qualificati on Program (OCGS AM P B.3.2)In OCGS LRA, Ap pendix B , Section B.3
.2, the appli cant stated that OC GS AMP B.3.2,?Envi ronmen tal Qua lifica tion (EQ) Pro gram," is an ex istin g plan t progra m that i s cons isten t wi th GALL A MP X.E 1, ?Envi ronmen tal Qua lifica tion (EQ) of El ectric al Co mponen ts."3.0.3.1.11.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program is i mplemented through s tation proced ures a nd pre venti ve mai ntenan ce tasks. The OC GS EQ p rogram co mplie s wi th 10 CFR 50.49 , ?Environmenta l Qualificati on of Electrica l Equipment Importa nt to Safety for Nuclear Pow er Plants."  A ll EQ equipmen t is inclu ded with in the scope of license re newal. The 65 program p rovi des for m ainte nance durin g the qua lifie d life of ele ctrica l equi pment i mportan t to safety with in the scope of 10 CFR 50.4
: 9. Program activ ities establ ish, demonstrate, and document the le vel of quali fication, qualified configuration, main tenance, surv eillance , and replacement requi rements necessary to meet 10 CF R 50.49. Re analysi s addresses attri butes of analytica l methods, data collection and reductio n methods, underl ying assumpti ons, accept ance c riteri a, corr ectiv e acti ons i f accept ance c riteri a are n ot met, a nd the perio d of time before the end of qualified life when the reanalysis will be completed. Qualified life is determined for equipme nt withi n the scope o f the EQ program, and app ropriate actio ns such as replacement or re furbishment are taken b efore or at the end of the qualified l ife of the equipment so that the aging limit is not ex ceeded.The applican t also stated that the EQ program ad dresses the l ow-vol tage I&C cable issues, consistent w ith those des cribed in the closure o f Generic Safety Issu e (GSI) 168,?Envi ronmen tal Qua lifica tion o f Elect rical Equip ment."3.0.3.1.11.2 Consi stency wit h the GA LL Rep ort In th e OCG S LRA, the ap plica nt st ated that OCGS AMP B.3.2 is cons iste nt wit h GAL L AMP X.E1.The pro ject tea m inter view ed the appl icant's tec hnica l staff an d rev iew ed, in who le or in pa rt, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.3.2, incl uding PBD-A MP-B.3.02, ?Environmenta l Qualificati on (EQ) Program," Rev ision 0, w hich assesses the A MP ele ments' consis tency w ith GALL AM P X.E1. Speci fically, the project team review ed the program ele ments (see Secti on 3.0.2.1 of this audit and re view report) containe d in OCGS AMP B.3.2 and as socia ted ba ses do cuments to det ermine their consi stency wit h GALL AMP X.E1.The project team rev iewed th ose portions of the applica nt's EQ program for w hich the app licant claims consi stency w ith GALL AM P X.E1 and found that they are consistent w ith this GALL AMP. On th e basis of its review , the project team d etermined that the applican t's EQ program provided reasonable a ssurance that el ectrical compo nents important to safety in ha rsh environments will be adequately managed. The proj ect team found that the applicant's EQ program conforms to the recommen ded GALL AM P X.E1.3.0.3.1.11.3 Exce ption s to th e GALL Repor t None 3.0.3.1.11.4 Enhan cements None 3.0.3.1.11.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e EQ program provi des for considera tion of operating exp erience to rec oncile qual ification base s and concl usions, inc luding the equi pment qualified li fe. Operating expe rience and s ystem, equipment, o r component-relate d information, as reported throu gh NRC bull etins, notice s, circulars, gen eric letters, a nd 10 CFR Part 21 notif ications , are evalu ated f or applic ability. T he evaluat ions are d ocumen ted and co rrect ive actions are identified. Opera ting experience is reviewed to determine if it is applicable to EQ 66 equipment. W hen the applicant has identified problems thr ough industry or plant-specif ic experience , it has taken co rrective acti ons to preve nt recurrence.
The project team
's review of the applicable correction action program database and sample EQ binders did not reveal any occurre nce where the qualified l ife of a component ha s been exce eded. This r evie w di d not i ndica te any adve rse tre nd in the EQ program.The project team als o review ed the operati ng experienc e provide d in the OCGS LRA and interview ed the appl icant's tech nical staff to confirm tha t the plant-spe cific operating e xperience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technic al staff, the project team d etermined that the applican t's  EQ program will adequately manage the ag ing effect s that are identified in the OCGS LRA f or which this AMP is credited.3.0.3.1.11.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the EQ program in Se ction A.3.2 of Appendix A to the OCGS LRA, whi ch states that the EQ program is an existing pro gram that manages the aging of ele ctrical equipme nt withi n the scope o f 10 CFR 50.49.
The program establishes , demonstrates, and documents the l evel of quali fication, qualified configurations, mai nte nan ce, sur ve il la nce , an d re pl ace men ts n ece ssa ry to mee t 10 CF R 5 0.4 9. A qu al ifi ed li fe is determined for equipment wi thin the scop e of the program, and ap propriate acti ons such as replacement or re furbishment are taken b efore or at the end of the qualified l ife of the equipment so that the aging limit is not ex ceeded. The effects of aging on the intende d functions wi ll be ade quately managed in accordanc e with th e requirements of 10 CFR 54.21(c)(1)(iii). In Appendix A to the OCGS LRA, th e applicant states that EQ components that cannot be qualified for 60 years will be replaced before the end of their quali fied l ife (Co mmitment 45).The project team rev iewed th e UFSAR S upplement for OCGS A MP B.3.2, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.1.11.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those portio ns of the program for whi ch the appl icant clai ms cons isten cy w ith th e GALL Repor t are consistent with the GALL Report. On the basis of i ts review of the UFSAR Supplement for this program, the pro ject team found that i t provided an adequate su mmary descripti on of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2 OCGS A MPs That A re Consistent with the GA LL Report with Exceptio ns and/or Enhan cement s 3.0.3.2.1 A S M E S e c t i o n X I I n s e r v i c e I n s p e c t i o n , S u b s e c t i o n s I WB , I WC , A N D I WD (OCGS AMP (B
.1.1) 67 In the OCGS LRA , Appendix B, Section B.1.1, the appl icant stated th at OCGS AMP B.1.1,"ASME S ection XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD," is an exi sting plant program t hat is consi stent w ith GA LL AM P XI.M 1, wi th ex cepti ons an d an e nhanc ement.3.0.3.2.1.1 Program Descriptio n In the OCGS LR A, the appli cant st ated th at thi s progra m is pa rt of its Inserv ice In specti on (ISI)program, and that it provides for condition mon itoring of reactor coo lant pressure retaining piping and c omponents wi thin the scop e of license renewal. It also prov ides for conditi on monitoring of reactor i nternal compone nts withi n the scope o f license renew al, and the isolation condenser. The p rogram is implemen ted through procedu res that require ex aminations consi stent w ith AS ME S ectio n XI, an d throu gh spec ific ta sks that requir e the A SME Secti on XI augmentation acti vities i dentified in NUREG-1801.
The program includ es:*Cracking monitoring for su sceptible i nservice i nspection co mponents subject to a steam or treated w ater enviro nment, through vol umetric exami nations of pressure retain ing welds and their h eat affected zones in pipin g components.
*Cracking monitoring o f the reactor vess el flange leak de tection lin e.*Cracking monitor ing of the isolation condensers t hrough surf ace and volumetric examinatio ns of pressure retai ning nozz le wel ds and their heat affected zones that ar e subje ct to a steam o r react or wa ter env ironme nt.*Loss of material monitoring of portion s of the isola tion condens ers subject to a steam or reactor w ater enviro nment, through syste m pressure tests.
*Cracki ng dete ction of the i solat ion c onden ser tub e sid e compo nents due to stress corrosion cracking and in tergranular stress co rrosion cracking, or loss of mate rial dete ctio n du e to gene ral, pit ting and crev ice corr osi on th rough temperature and rad ioactivi ty monitorin g of the shell-si de (cooling) w ater, eddy current inspecti ons of the tubes, a nd inspecti ons (VT or UT) of the ch annel head and tube shee ts.3.0.3.2.1.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.1 is consi stent with GALL AMP XI.M1 , wi th ex cepti ons an d an e nhanc ement.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.1, incl uding basis docume nt PBD-AMP-B.1.01 , ?ASME S ection XI Inserv ice Inspecti on, Subs ecti ons I W B, IW C, an d IW D," R evisio n 0, whi ch pr ovide s an as sess ment of t he AMP elements' consi stency w ith GALL AM P XI.M1. Sp ecifically , the project team re viewe d the prog ram elem ents (see Sect ion 3.0.2.1 of this audit and re view re port) con tain ed in O CGS A MP B.1.1 and asso ciated bases documents to de termine their co nsistency with GALL AMP XI.M 1.In reviewing this AMP, the project team noted that th e program descript ion in the OCGS LRA for AM P B.1.1 lis ts five aging e ffects for w hich this A MP w ill be cre dited to mana ge aging. Howeve r, in additi on to the five aging effects listed, the OCGS LRA cred its AMP B.1.1 for managing aging of CASS components subjec t to loss of fracture tou ghness due to the rmal 68 agi ng e mbr itt le men t (s ee Tab le 3.1.1, it em 4 7). The pro jec t te am a ske d th e a ppl ica nt t o cl ari fy why this aging effec t is n ot inc luded in th e AM P lis ting, a nd to i denti fy any other aging effec ts for w hic h thi s AM P is cred ited in t he L RA t hat a re no t in clu ded in t he A MP lis ting.In its response , the appli cant stated that th e list in cluded in the OCGS LRA program description for AMP B.1.1 provides examples o f the methods by which the ASME Section XI Inserv ice Inspection, Su bsections IWB, IWC, and IW D program addresses loss of material and cracking initiatio n and growth for which the program is credi ted to manage aging. N o example was provided for loss of fracture toughness; howeve r, it is al so an aging effect for whi ch the program i s credi ted. C rack in itiat ion a nd grow th, lo ss of mat erial , and l oss of fra cture toughness are the only agin g effects for which this AMP i s credited. The project team found the applicant' s response acc eptable sin ce it clari fies that loss o f fracture toughness is an aging effect for which this AMP is credited, which is consistent with the aging management reviews in the OCGS LRA.
The program description in the OCGS LRA for AMP B.1.1 also states that the program is imple mented through proce dures that re quire e xamin ation s cons isten t wi th ASM E Sect ion XI. The pro ject tea m asked the ap plic ant to descri be the quali ficatio ns and train ing requ iremen ts for pers onnel that p erform in specti ons an d exa minati ons un der the ASM E ISI p rogram.In its respo nse, th e appl icant prov ided OCGS pr ocedu re TQ-AA-122, ?Qualification and Certification o f Nondestructiv e Examina tion (NDE) P ersonnel," Re
: v. 1, wh ich provi des the OCGS qualification and traini ng requirements for personn el performing inspe ctions and exami natio ns und er the ASM E ISI p rogram. Th is pro cedure appl ies to all person nel c ertifie d to perform NDE inspe ctions. The proje ct team revie wed this procedure and determined that personnel ce rtified in ND E are qualified in accordan ce with ASNT SNT-TC-1A, throu gh 1984 Edition; AN SI/ASNT CP-189, 1991 editi on; and ASM E Section XI, 1 986 through 1998 Edition, as applicable. Four levels of qualification are identif ied, including NDE Level I to III and NDE instructor. Edu cation, traini ng, and experi ence requirements a re addressed for ea ch level. The project team re view ed the se trai ning re quireme nts an d dete rmined that th ey ar e acce ptabl e to ensure that quali fied personnel are used to p erform the ASME inspection
: s. In additi on, the appli cant p rovi ded a copy of OCGS p rocedu re ER-AA-32 5-025, ?Oversight of Vendor NDE Activities," Rev. 1, which details the requirements f or vendors. The project team reviewed this docume nt and confirm ed tha t appro priate quali ficatio n and traini ng requi rements are i m p l e m e n t e d fo r v e n d o r s t h a t p e r fo r m A S M E S e c t i o n X I , S u b s e c t i o n I WB , I WC , a n d I WD inspections
.The pro ject tea m further noted that th e progra m basi s docu ment for A MP B.1.1 (PBD-AMP-B.1.01) stated tha t repairs and replacements are performed in acco rdance wi th the 1995 A SME Secti on XI Co de, 19 96 add enda, whi ch spe cifies the re quireme nts in IWA-4000.
The GALL Report re fers to sections IWB-4000, IWC-4000, and IWD-4000 for repairs, and sect ions IW B-70 00, I W C-70 00, a nd IW D-70 00 f or re plac emen ts. In rev iewing the AS ME Section XI Cod e, the project team determined that Sections IWB-4000, IWC-4000, and IWD-4000 for re pairs , and s ectio ns IWB-7000, IWC-7000, an d IWD-7000 for repla cements have been deleted i n later ve rsions of the AS ME Secti on XI Code, in cluding the 1 995 versi on, and the requiremen ts have be en incorporate d into Secti on IWA-4000. Therefore, the appli cant has appropria tely referenced section IWA-4000 for repairs an d replacement in the program basis docume nt for th is pro gram.The project team rev iewed th ose portions of the OCGS ASM E Section XI In service Ins pection, Subse ction s IWB, IWC, and IWD program fo r whi ch the appl icant clai med con sisten cy w ith 69 GALL AMP AMP XI.M 1 and found that they are con sistent wi th the GALL Re port AMP.
The project team found that the applica nt's ASM E Section XI In service Ins pection, Subs ections IW B, IWC, and IW D program conforms to the re commended GALL A MP XI.M1 , with the excep tion s and enhan ceme nt de scri bed be low.3.0.3.2.1.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements: Exception 1 Elements: 1. Scope of Program
: 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria
: 7. Correctiv e Actions Exception: NUREG-1801 i ndicates that the aging of the iso lation cond enser is to be mana ged by ASM E Sect ion XI Inserv ice In specti on (ISI)Subsection IWB (for Class 1 c omponents). How ever, the Oy ster Creek isolati on condensers are ISI Class 2 on the tub e side and ISI Class 3 on the shell side. Therefore, Su bsections IWC and IW D are used , as Class 1 requir ement s do not ap ply.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?detect ion o f aging effec ts," ?monito ring an d trend ing," ?acceptance cri teria," and
?correc tive actions" program el ements associate d with th e excepti on taken: 1. Scope of Prog ram:  The A SME Secti on XI pr ogram pro vide s the r equire ments for ISI, repair, and rep lacement. The co mponents wi thin the scop e of the program are spe cified in Subsecti ons IWB-1100, IW C-1100, and IWD-1100 for Class 1, 2, and 3 components, respectivel y, and in clude all pressure-retain ing components a nd their in tegral attachments in light-water cooled power plants. The components descr ibed in Subsections IW B-1220, IWC-1220, and IWD-1220 are exempt from the examinatio n requirements of Subsec tions IWB-2500, IWC-2500, and IWD-2500.
: 4. Detect ion o f Agin g Effec ts:  The extent a nd schedule of the inspecti on and test techniques prescri bed by the program are designed to maintain structural inte grity and ensure that aging e ffects will be discovere d and repai red before the lo ss of intended functio n of the compon ent. In specti on can reve al cra cking, l oss of ma terial due to corrosion, le akage of coolant and indication s of degradation du e to wear or stress relaxatio n, such as v erification of cl earances, settin gs, physical displacemen ts, loose or missing parts, deb ris, wear, e rosion, or lo ss of integrity a t bolted or w elded conne ctions.Components are examined a nd tested as s pecified in Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1, respectivel y, for Class 1 , 2, and 3 comp onents. The tabl es specify the extent and schedule of the inspection and examin ation methods for th e components of the pressure-retai ning boundari es. Alternati ve approv ed methods that me et the requirements of IWA-2240 are also sp ecified in th ese tables.
70 5. Monitoring and Trendin g:  For Class 1, 2, or 3 components, the inspect ion schedule of IW B-2400, IWC-2400, or IWD-2400, respectivel y, and the extent and frequency of IW B- 2500-1, IWC-2500-1, or IWD-2500-1, respectiv ely, prov ides for timely detection of degradation. The s equence of component examinatio ns establis hed during the first inspection interval is repeated d uring each succ essive i nspection i nterval, to the extent practical. If f law conditions or relevant conditions of degradation are evaluated in accordance w ith IWB-3100, IW C-3100, or IWD-3100, and the c omponent is qual ified as acceptable for co ntinued serv ice, the areas containing s uch flaw i ndications and relev ant conditions are reexamin ed during the n ext three i nspection pe riods of IWB-2110 for Class 1 comp onents, IWC-2410 for Class 2 co mponents, and IWD-2410 for Class 3 components. Ex aminations tha t reveal i ndications that exceed the acceptance standards described below are extended to include additional examinations in accord ance w ith IWB- 243 0, IWC-2430, or IWD-2430 (1995 e ditio n) for Cl ass 1, 2, or, 3 compon ents, r espect ively.6. Acceptance Criteria
:  Any i ndication o r relevant conditions of degradation detec ted are evalu ated in acco rdance wi th IWB-3000, IW C-3000, or IWD-3000, for Class 1 , 2, or 3 components, respect ively. Examination results are evaluated in accordance with IWB-3100, IWC-3100, or IWD-3100 by comparing the results wi th the acceptan ce standards of IW B-3400 and IWB3500, or IWC-3400 and IWC-3500, or IWD3400 and IWD3500, respectivel y for Class 1 or Class 2 and 3 compon ents. Flaw s that excee d the siz e of allowa ble flaws, as defined in IWB-3500, IW C-3500, or IWD3500, are ev aluated by using the anal ytical p rocedures of IWB-3600, IWC-3600, or IW D-3600, respecti vely, for Class 1 or Class 2, an d 3 components.
Flaws that exceed the size of allowab le flaws, as defined in IWB-3500 or IW C-3500, are ev aluated by using the ana lytical procedures of IW B-3600 or IWC-3600, respectiv ely, for Cla ss 1 or Cla ss 2 and 3 c omponents.
Approved B WRVIP- 14, BW RVIP-59, and BWRVIP-60 documents provi de guidelin es for evaluati on of crack growth i n stainless steels, nic kel alloy s, and low-alloy s teels, respec tively.7. Corrective Acti ons:  For Class 1, 2, and 3, respectively, repair is perform ed in conforma nce w ith IWB-4000 , IWC-4000, a nd IWD-4000, and re place ment ac cordi ng to IW B-7000, IWC-7000, and IWD-7000. Approved BWRVIP-44 and BWRVIP-45 documents, respecti vely, p rovide guid elines for w eld repair of nickel allo ys and for weldability of irradiated structural component
: s. As discussed in the appendix to this report, the st aff finds t he requ iremen ts of 10 CFR P art 50, Appen dix B, acc eptabl e to address the corre ctive acti ons.In reviewing this exception, the project team not ed that Table 3.2-1 in the OCGS UFSAR identifies the isolatio n condenser s ystem as bei ng Class 1. The project team asked th e applicant to clarify and provide the technical basis for the current isolation condenser ISI classificatio n.In its respo nse, th e appl icant stated that th e iso latio n cond ensers are he at ex changer s comprised of ISI Cl ass 2 tube bu ndle assembl ies inserted into ISI Cl ass 3 shell assemblies.
The condenser heat exchanger units do not con tain any Class 1 components. OCGS UFSAR Table 3.2-1, whic h lists Cl ass 1 syste ms, includes the isolati on condenser system since the system contains ISI C lass 1 pip ing and compone nts from the attachment po ints on the re actor vessel to, and incl uding, the contai nment isolati on valv es on both the steam supply side and the condensate return side. The pi ping changes to IS I Class 2 a t the isolati on valv es and conti nues to the heat ex changer tube bund les as ISI C lass 2. The Oy ster Creek Inservi ce Inspection 71 Program Plan (OC-1) describing the ISI classificati ons of piping an d components, i ncluding those of the isolation condenser system , is current licensing basis inform ation. The ISI classificatio n for the isola tion condens ers has not ch anged since o riginally determined, an d was included in the submi ttal for each of the 1 0-year inte rval ins pection programs to the NRC for review and eval uation.To confirm the appli cant's respons e, the project team review ed the OCGS in service i nspection program plan (OC-1) ti tled ?OCGS IS I Progra m Plan Fourth Ten-Ye ar Insp ectio n Inter val,"Rev. 1, d ated 09/3 0/04. Ap pend ix B of t hat d ocum ent, "Cl ass 1 Sy stem s Su mmary ," pa ge 2-53, c onfirms that th e iso latio n cond enser syste m has C lass 1 , 2 and 3 comp onents. A transition from Cl ass 1 to Cl ass 2 occurs a t isolation valve s V-14-31, V-14
-32, V-14-34, an d V-14-35. Base d upon the i nformation in thi s document, the p roject team was able to v erify that the isolati on condenser tubes are Cl ass 2 and the shell i s Class 3, w hile pip ing connected directly to the reactor v essel is C lass 1. This is part of the curre nt licensi ng basis.Since the i solation co ndenser tubes are Class 2 , and the shel l is Cla ss 3 in the current licen sing basis, the pro ject team determined that the ASM E Section XI IS I requirements for Cla ss 1 components are n ot applicab le to the i solation co ndenser. On thi s basis, the project team found this ex ception acce ptable.Exception 2 Elements: Program Descriptio n 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria
: 7. Correctiv e Actions Exception: NUREG-1801 sp ecifies the 200 1 ASME Section XI B&P V Code, 2002 a nd 200 3 Adde nda for Subse ction s IWB, IWC, and IWD.
The current Oyster Creek ISI Program Pla n for the fourth ten-ye ar ins pect ion int erv al e ffecti ve fr om Oc tobe r 15, 200 2 thr ough October 14, 2012, approved p er 10CFR50.55 a, is based on the 1995 ASME Sect ion XI B&P V Code, 19 96 addend a. The ne xt 120-month inspe ction interv al for Oyster Cree k will i ncorporate the requirements speci fied in the v ersion of the AS ME Code incorporated i nto 10 CFR 50.55a 12 month s before the start of the inspection interval.
The GALL Report i dentifies the foll owing recommend ations for the
?program d escrip tion," ?detect ion o f aging effec ts," ?monito ring an d trend ing," ?acceptance cri teria," and
?correc tive actions" program el ements associate d with th e excepti on taken: Program Descrip tion:  Title 10 of the Code of Federa l Regulatio ns, 10 CFR 5 0.55a, imposes the i nservice i nspection (ISI) requirements of the AS ME Code , Section XI, for Class 1, 2, and 3 pressure-retaining components and their integr al attachments in light-water c ooled pow er plants. Ins pection, repai r, and replace ment of these components are c overed in Subsections IWB, IW C, and IWD, respectively , in the 200 1 edition 1 including the 2002 and 2003 Addenda. The progr am generally includes periodic visual, surface, and/or vo lumetric ex amination an d leakage test of all Class 1, 2 , and 3 pressu re-reta inin g compon ents a nd the ir in tegral attach ments. The ASM E Sect ion XI 72 Inservice In spection program i n accordance with Sub sections IWB, IW C, or IWD has been s hown to be general ly e ffective in man aging agi ng effects in Cl ass 1, 2, or 3 compon ents a nd the ir in tegral attach ments i n ligh t-wat er coo led p ower plan ts. Ho wev er, in c erta in c ases , the ASM E in serv ice ins pect ion prog ram i s to be a ugmen ted t o man age effects of a ging for l icens e rene wal and i s so i denti fied i n the GA LL Rep ort.[Footnote 1:  An applicant may rely on a different version of the ASME Code, but should justify such use. An applicant may wish to refer t o the SOC for an update of 10 CFR §50.55a to just ify us e of a mo re rece nt edi tion o f the Co de.]4. Detect ion o f Agin g Effec ts:  The extent a nd schedule of the inspecti on and test techniques prescri bed by the program are designed to maintain structural inte grity and ensure that aging e ffects will be discovere d and repai red before the lo ss of intended functio n of the compon ent. In specti on can reve al cra cking, l oss of ma terial due to corrosion, le akage of coolant and indication s of degradation du e to wear or stress relaxatio n, such as v erification of cl earances, settin gs, physical displacemen ts, loose or missing parts, deb ris, wear, e rosion, or lo ss of integrity a t bolted or w elded conne ctions.Components are examined a nd tested as s pecified in Tables IWB-2500-1, IWC-2500-1, and IWD-2 500-1, res pec tiv el y, for Cl ass 1, 2, a nd 3 co mpo nen ts. The tab le s sp eci fy theex tent an d sche dule of the i nspect ion a nd ex aminat ion me thods for the c ompone nts of the pressure-retai ning boundari es. Alternati ve approv ed methods that me et the requirements of IWA-2240 are also sp ecified in th ese tables.
: 5. Monitoring and Trendin g:  For Class 1, 2, or 3 components, the inspect ion schedule of IW B-2400, IWC-2400, or IWD-2400, respectivel y, and the extent and frequency of IW B- 2500-1, IWC-2500-1, or IWD-2500-1, respectiv ely, prov ides for timely detection of degradation. The s equence of component examinatio ns establis hed during the first inspection interval is repeated d uring each succ essive i nspection i nterval, to the extent practical. If f law conditions or relevant conditions of degradation are evaluated in accordance w ith IWB-3100, IW C-3100, or IWD-3100, and the c omponent is qual ified as acceptable for co ntinued serv ice, the areas containing s uch flaw i ndications and relev ant conditions are reexamin ed during the n ext three i nspection pe riods of IWB-2110 for Class 1 comp onents, IWC-2410 for Class 2 co mponents, and IWD-2410 for Class 3 components. Ex aminations tha t reveal i ndications that exceed the acceptance standards described below are extended to include additional examinations in accord ance w ith IWB- 243 0, IWC-2430, or IWD-2430 (1995 e ditio n) for Cl ass 1, 2, or, 3 compon ents, r espect ively.6. Acceptance Criteria
:  Any i ndication o r relevant conditions of degradation detec ted are evalu ated in acco rdance wi th IWB-3000, IW C-3000, or IWD-3000, for Class 1 , 2, or 3 components, respect ively. Examination results are evaluated in accordance with IWB-3100, IWC-3100, or IWD-3100 by comparing the results wi th the acceptan ce standards of IW B-3400 and IWB3500, or IWC-3400 and IWC-3500, or IWD3400 and IWD3500, respectivel y for Class 1 or Class 2 and 3 compon ents. Flaw s that excee d the siz e of allowa ble flaws, as defined in IWB-3500, IW C-3500, or IWD3500, are ev aluated by using the anal ytical p rocedures of IWB-3600, IWC-3600, or IW D-3600, respecti vely, for Class 1 or Class 2, an d 3 components.
Flaws that exceed the size of allowab le flaws, as defined in IWB-3500 or IW C-3500, are ev aluated by using the ana lytical procedures of IW B-3600 or IWC-3600, respectiv ely, for Cla ss 1 or Cla ss 2 and 3 c omponents.
Approved B WRVIP- 14, BW RVIP-59, and BWRVIP-60 documents provi de guidelin es for 73 evaluati on of crack growth i n stainless steels, nic kel alloy s, and low-alloy s teels, respec tively.7. Corrective Acti ons:  For Class 1, 2, and 3, respectively, repair is perform ed in conforma nce w ith IWB-4000 , IWC-4000, a nd IWD-4000, and re place ment ac cordi ng to IW B-7000, IWC-7000, and IWD-7000. Approved BWRVIP-44 and BWRVIP-45 documents, respecti vely, p rovide guid elines for w eld repair of nickel allo ys and for weldability of irradiated structural component
: s. As discussed in the appendix to this report, the st aff finds t he requ iremen ts of 10 CFR P art 50, Appen dix B, acc eptabl e to address the corre ctive acti ons.In review ing this ex ception, the p roject team noted th at, in accorda nce with Title 10 of the C ode of Federal Regul ations, Part 50 , Section 55 a (10 CFR 5 0.55a), the ASM E code edi tion to be used for ISI insp ections is the latest edi tion avai lable 12 months prior to th e start of the ten-y ear inspe ction inter val. In the OCGS L RA, th e appl icant stated that Oy ster Cr eek is curren tly i n its fourth ten-year i nspection i nterval, w hich is effectiv e from October 15, 2002 through October 14, 2012. Fo r this interv al, the 1995 ASME Section XI Cod e, with 1 996 addenda is the appropriate edition to be used; theref ore, the project team determined that this exception is justified. On this basis, the p roject team found this exceptio n acceptable
.3.0.3.2.1.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancement in order to mee t the GALL Report program e lements: Eleme nt(s): 1. Scope of Program
: 3. Parameters M onitored or Ins pected 5. Monito ring and Trendin g Enhan cement: Enhan cement activ ities , whi ch are in ad ditio n to th e requi rements of ASME Se ction XI, Subsec tions IWB, IW C, and IWD, consist of temperature and rad ioactivi ty monitorin g of the isolatio n condenser shel l-side (cool ing) water, ed dy current tes ting of the tubes, and in spections (VT or UT) of the channel head and tu be sheets, wi th verificati on of the effectivenes s of the program through monitoring an d trending of resul ts.Since the Oy ster Cr eek iso latio n cond enser tube b undle s wer e replaced in the ?A" isolati on condenser in 2000 an d in the ?B"isol ation conde nser i n 1998 , util izi ng upgrad ed mate rials that a re more resistant to intergranular stres s corrosion cra cking, these inspections will be performed durin g the first ten yea rs of the extended p eriod of operati on.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parameters monitored or inspected
," and ?monito ring an d trend ing" pr ogram el ements associ ated w ith th e state d enha ncemen t: 1. Scope of Prog ram:  The A SME Secti on XI pr ogram pro vide s the r equire ments for ISI, repair, and rep lacement. The co mponents wi thin the scop e of the program are spe cified in Subsecti ons IWB-1100, IW C-1100, and IWD-1100 for Class 1, 2, and 3 components, 74 respectivel y, and in clude all pressure-retain ing components a nd their in tegral attachments in light-water cooled power plants. The components descr ibed in Subsections IW B-1220, IWC-1220, and IWD-1220 are exempt from the examinatio n requirements of Subsec tions IWB-2500, IWC-2500, and IWD-2500.
: 3. Parameters Moni tored or Inspected
:  The A SME Secti on XI IS I progra m detec ts degrada tion o f compon ents b y usi ng the e xamin ation and i nspect ion re quireme nts specified in ASME Section XI Table s IWB-2500-1, IW C-2500-1, or IWD-2500-1, respectivel y, for Class 1 , 2, or 3 compon ents.5.Monitoring and Trendin g:  For Class 1, 2, or 3 comp onents, the in spection sche dule of IW B-2400, IW C-2400, or IW D-2400, respectively, and the extent and freq uency of IW B-2500-1, IWC-2500-1, or IWD-2500-1, respectivel y, provi des for timely detection of degradation. The s equence of component examinatio ns establis hed during the first inspection interval is repeated d uring each succ essive i nspection i nterval, to the extent practical. If f law conditions or relevant conditions of degradation are evaluated in accordance w ith IWB-3100, IW C-3100, or IWD-3100, and the c omponent is qual ified as acceptable for co ntinued serv ice, the areas containing s uch flaw i ndications and relev ant conditions are reexamin ed during the n ext three i nspection pe riods of IWB-2110 for Class 1 comp onents, IWC-2410 for Class 2 co mponents, and IWD-2410 for Class 3 components. Ex aminations tha t reveal i ndications that exceed the acceptance standards described below are extended to include additional examinations in accord ance w ith IWB- 243 0, IWC-2430, or IWD-2430 (1995 e ditio n) for Cl ass 1, 2, or, 3 compon ents, r espect ively.In review ing this enha ncement, the project team noted that the OCGS program basis document for this AMP (PBD-AM P-B.1.01) incl udes the abov e enhancement i n Section 2
.4 ?Summary of Enhancements to NUREG-1801," ho wever, th e enhancement i s not addressed in any of the 10 program elements ev aluated in Section 3
?Evaluati on and Techni cal Basis."
The applica nt was asked to identi fy the specific program elements to w hich this e nhancement appl ies.The applican t stated that the program basis docu ment, PBD-AM P-B.1.01, for the AS ME Secti on XI Inser vice Inspe ction s, Sub sectio ns IWB, IWC, IWD will be rev ised to li st the enhan cement to add temp erat ure a nd ra dio acti vit y mo nito ring of th e is ola tion con dens er sh ell-sid e (co oli ng)water, and e ddy current te sting of the tubes, an d inspectio ns (VT or UT) of the cha nnel head and tube shee ts, in program ele ments 1. scope o f program, 3. parameters monito red or ins pect ed, a nd 5. mon itor ing a nd tr endi ng.The project team conc urred with the program elemen ts identified by the app licant as b eing impact ed by this enhan cement.The project team als o noted that Tabl e IV.C1 in the GALL Repo rt, item IV.C1-4 for i solation condenser compo nents stated that GALL AMP XI.M1 is to be augmented to d etect cracking due to stress co rrosion cracking. In addition, the GALL Repo rt stated that v erification of the progr am's effec tiv enes s is nec essa ry t o en sure that sign ific ant d egrad atio n is not occu rrin g, and the compone nt's intende d function w ill be mai ntained duri ng the extende d period of operat ion. An acc eptabl e ver ificati on pro gram is to inc lude tempera ture an d radi oacti vity monitoring of the she ll side water, and e ddy current te sting of the tubes.
Therefore, the applicant' s enhancement to add temperature and radioacti vity moni toring of the isol ation condenser shel l-side (cool ing) water, ed dy current tes ting of the tubes, an d inspectio ns (VT or UT) of the channel head and tu be sheets, w ith verifica tion of the effectiven ess of the program 75 through monitoring an d trending of resul ts, will make the appli cant's AM P consistent with the recommendations in the GALL Report AMP. On this basis, the project team f ound this enhancement acc eptable.The app lica nt wa s asked to cl arify if the a bove enhan cement activ ities wil l be i nclud ed as part of OCGS A MP B.1.1, o r if the y w ill be in clude d in a separ ate agi ng manage ment pr ogram. In its response, the applicant state d that the enhancements f or isolation condenser inspection will be in clude d as p art of th e ASM E Sect ion XI ISI, Su bsecti ons IWB, IWC and IWD progra
: m. Inspections of the tube sheet an d channel head wi ll be performed a s part of the mainte nance activiti es required for performance of the eddy cu rrent examina tions of the iso lation cond enser tubes, whi ch is incl uded a s part of the B.1.1 pr ogram. Th e proje ct team found th is ap proach to be acc eptabl e sin ce the activ ities wil l be i nclud ed in an ex istin g aging ma nagemen t progra m.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhancement is implemented, OC GS AMP B.1.1, "ASME Section XI Inse rvice Inspe ction, Subsections IW B, IWC, and IW D," will be consiste nt with GAL L AMP XI.M 1 and wi ll provi de additional assurance that the effects of aging wil l be adequatel y managed.
Considerin g the relativ ely short time period re maining before OCGS e nters the lic ense renew al period, the pro ject team inquired about the status of implementing proc edures required for new AMPs, and for significant enha ncements to ex isting AM Ps. The appli cant was a sked to provi de (a) the s tat us of the im plem enti ng pr oced ures for each enhan ceme nt to the ex isti ng AS ME Section XI ISI, S ubsection IWB, IWC, and IW D program, (b) the sch edule for ini tiating each o f t h e e n h a n c e m e n t s t o t h e e x i s t i n g A S M E S e c t i o n X I I S I , S u b s e c t i o n I WB , I WC , a n d I WD program, (c) a sample of an implementi ng procedure for one enhancement to th e existi ng ASME S ection XI ISI, Sub section IWB, IW C, and IWD program, and (d) the resu lts of any enhanced in spections that have alre ady been completed.
In its respo nse, th e appl icant stated that i mpleme nting p rocedu res for e nhanc ements to OCGS AMP B.1.1 have been ident ified, and s evera l are under deve lopmen t and i n draft for m;howeve r, none we re complete at the time of this a udit. In add ition, the a pplicant sta ted that the enhancement of edd y current testi ng of the isolati on condenser tubes, with examinati on (VT or UT) of the tubesheet a nd shell head is to be performed during the first ten years of the period of extended o peration. Sh ell wa ter is currentl y periodi cally mon itored for temperature and radioactivity, and procedure commitm ents addressing these enhanc ement activities will be in place prior to the period of extended op eration. No enhanced in spections ha ve been p erformed as of the time of this audit; conse quently, no i nspection resu lts were a vailabl e for review by the project team.The project team rev iewed th e applica nt's response and determined that it is acceptable s ince all activ ities w ill be c ompleted prio r to entering the period of exte nded operatio n.3.0.3.2.1.5 Operating Expe rience In the OCGS LRA , the appli cant stated that Oy ster Creek has suc cessfully i dentified ind ications of age-related degradati on prior to th e loss of the i ntended functions of the components, a nd has taken appropri ate correctiv e actions thro ugh evaluati on, repair or replacement of the compon ents i n acco rdance wit h ASM E Sect ion XI and st ation imple mentin g proced ures. Some site-specific examples were provided. In addition, the applicant st ated that periodic self assessments of the IS I programs have b een performed to id entify the area s that need impr ovement to maint ain prog ram qu ality.
76 In addition to review ing the operati ng experienc e described in the OCGS LR A and program basis documen ts, the project team re viewe d a self-assessmen t report titled
?Foc use d A rea Se lf-Assessment (FAS A) Report Oyste r Creek ISI Program," w hich wa s performed April 26-29, 2004. The report confirms that self asse ssments have been performed to i dentify program strengths and w eaknesses, as w ell as corre ctive acti ons needed.
The report addresse s the follow ing are as:  a) the re pair a nd rep laceme nt progr am, b) t he ISI, incl uding IGSCC, program, c) the pressu re test program, d) the snubb er progr am, and e) the conta inment program (CISI).The report results related to the OCGS ISI program incl uded the id entification o f 3 deficiencies and 12 re comme ndat ion s for impr ove ment. The defi cie nci es i dent ifie d are the foll owi ng:*The use of ASM E Code case s N-416-2,N-513
-1, and -546 were appro ved by NRC, but were not i ncluded i n the program documen t (OC-1)*Augmented inspec tion requirements were not a ddressed in detail for NUR EG-0619 BWR feedwater nozzl e and CRD return line nozzle cracking; Branch Tech nical posi tion MEB 3-1, "High Energy Fluid Systems, Protection Aga inst Postulated Piping Failures in Fluid Sy stems Outside Con tainment;" a di scussion of the Class 2 Thin Wall piping augmented inspections; and snubber visual inspection and testing perfo rmed in accord ance w ith OC GS Techn ical Speci ficatio ns Sec tions 3.5.A.8 and 4.5.M*Relief Request OC 02 for the reactor pressure vessel support skirt k nuckle weld received provisio nal approv al from the NRC howeve r, the provi sion to augment th e ASME C ode required su rface examinati on with a volumetri c (UT) examina tion of the restricted area is not addres sed A corrective action pl an was i ssued to addre ss all defici encies ide ntified in thi s report. The project team revi ewed the deficiencies associated w ith the ISI pro gram and determined that they did not adversel y impact the conclusio n that the OCGS A MP w ill effectivel y manage aging degradation.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d in the AMP bas is document, i nterview ed the appl icant's techni cal staff, and confirmed th at the plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions with t he app lican t's tech nica l sta ff , the proj ect t eam d eter mine d tha t the appli cant's ASME Section XI Inservice Inspection, Subsection IW B, IW C and IW D Program will adequately manage the aging effects f or which this AMP is credited in the OCGS LRA.
3.0.3.2.1.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th is AMP in the OCGS LRA, Appendix A, Section A.1.1, which states that the ASME Section XI Inser vice Inspection, Subsections IW B, IW C, and IWD aging management program is an existin g plant program that co nsists of periodic v olumetric and visual examinati ons of components for as sessment, identi fication of signs of degradation, and establi shment of correctiv e actions. The inspections will be imple mented in ac cordan ce wi th 10 C FR 50.55(a).For the isolation condensers this prog ram also includes enhancement activities identif ied in NUREG-1801, l ines IV.C1-5 and IV.C1-6. The se are new activiti es in addi tion to those required 77 by ASM E Section XI, S ubsections IWB, IWC, and IW D. The isol ation conden ser test and inspection enhancement acti vities d etect cracking due to stress corrosio n cracking or intergranular stres s corrosion cra cking, and detect l oss of material d ue to general, p itting and crevice co rrosion. These e nhancement acti vities v erify that signi ficant degradation is not occurring, and the refore that the inten ded function of the isolation condenser is maintained durin g the pe riod o f exten ded op eratio n. Thes e enha ncemen t acti viti es con sist o f tempera ture and radioacti vity moni toring of the shell side w ater, which will be implemen ted prior to the period of extended op eration, and e ddy current te sting of the tubes, w ith inspecti on (VT or UT) of the tubesheet and channel hea d, which will be performed during the first ten years of the period of extended o peration.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 1 o f the commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.1, and found that i t was consi stent w ith th e GALL Repor t. The p roject t eam det ermine d that it pro vide s an a dequate summary descrip tion of the program, as identified i n the SRP-LR UFSAR Su pplement tabl e and as requi red by 10 CF R 54.2 1(d).3.0.3.2.1.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eptions and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects for whi ch it is cre dited. Als o, the project team review ed the enhancement and determined tha t implementatio n of the enhance ment prior to the period of exten ded op eratio n wo uld re sult i n the e xist ing AM P bei ng cons isten t wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and found that i t provides an adequate summary description of the program, as require d by 10 CFR 54.21 (d).3.0.3.2.2 Water Chemistry (OCGS AMP B.1.2)In the OCGS LRA , Appendix B, Section B.1.2, the appl icant stated th at OCGS AMP B.1.2,?Water Chemistry," is an ex isting plant program that is cons istent wi th GALL AM P XI.M2,?Water Chemistry," with ex ceptions.3.0.3.2.2.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program's acti vities co nsist of measures th at are us ed to ma nage agi ng of pip ing, pi ping co mponen ts, pi ping e lement s and heat e xcha ngers exposed to reactor water, condensate an d feedwater, con trol rod driv e water, demi neralize d water storage tan k water (DWST), condensate storage tan k water (CST), torus water, and spent fuel pool water. Re actor water, c ondensate, con trol rod driv e, feedwater, demi neralize d water storage tan k, condensate tank, torus and spent fuel pool w ater are class ified as treated water for aging managemen
: t. The program activ ities prov ide for monitorin g and controll ing of wate r chemi stry u sing st ation proce dures and pr ocesse s base d on B WRVIP-130: 
?B WR Vessel and Internals Project BWR W ater Chemistry Guideline s," 2004 Rev ision for the prevention or mitigation of loss of material, reduction of heat transfer and cracking agin g
78 effects. The Water Chemistry Program is al so credited for mi tigating loss of materi al and cracking for components ex posed to sodi um pentaborate a nd boiler treated water environments. The standby liquid con trol system co ntains a treate d water an d sodium pentaborate sol ution and i s controlled in accordan ce with plant procedu res and Techni cal Specifications. The heating and process steam system contains boiler treated water that is controlled i n accordance with pl ant procedures.
In accordance w ith NUREG-18 01, the appl icant also stated that the Water Chemistry Program may not be e ffective in low flow or stagnan t flow areas.
The one-time i nspection (B.1
.24) aging management program incl udes provi sions speci fied by NUR EG-1801 for veri fication of chemistry con trol and confirmati on of the absence of loss of material and cracking in stagnant flow areas i n piping sy stems and compone nts.3.0.3.2.2.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.2 is consi stent with GALL AMP XI.M 2, with e xceptions.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.2, incl uding the OCGS Program basi s docu ment, P BD-AM P-B.1.02, ?Water Chemistry," Rev. 0, dated 11-22-200 5, which provides an assessment of the AMP el ements' consisten cy wi th GALL AMP XI.M2. Spec ifical ly, t he pro ject tea m revi ewed the pr ogram el ements (see S ectio n 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.2 and associa ted bases documents to dete rmine their co nsistency with GALL AMP XI.M 2.Also, the pro ject team revie wed sev eral OCGS impl ementing procedure s, includi ng CY-AB-120-1 100, ?Reacto r Water Hydr ogen Water Ch emistry , Nobl e Chem and Z inc In jectio n,"Rev. 2 and CY-AB-120-1 00, ?Reactor Water Chemistry," Rev. 7.The applican t stated that OCGS s tarted hydrogen water chemi stry (HWC) in 1990, zi nc injection i n 2000 and noble metal chemical app lication (NMCA) i n 2002. To imp lement these changes, the appl icant has be en followi ng the most current up date of the EPRI guidelines, which is currently BWRVIP-130, as applicable to the plant-specific needs t o mitigate IGSCC in compon ents e xpos ed to r eactor or trea ted w ater.For HWC pla nts suc h as OC GS, BWRVIP-6 2, ?Te c h n i c a l B a s i s fo r I n s p e c t i o n R e l i e f f o r B WR Interna l Comp onents wit h Hyd rogen In jectio n," and BWRVIP-75, ?Technical Ba sis for Revi sions to GL 88-01 Ins pecti on Sch edule s," id entify circu mstance s and condi tions for wh ich re lief (t o perform alternate in service i nspection ac tivities in lieu of the current ISI co mmitments) may be granted by the staff. The applicant w as asked if a request for relief has been submitted and approved b ecause of the HWC status. In resp onse, the appl icant stated th at OCGS has not yet submitted any relief requests to the staff based on i ts HWC status. The project team determined that the applica nt's response was accep table since a relief request i s not being relied upon to perform alter nate inservice inspection activities in lieu of the current ISI commitments for the ex tended period of operation.
The project team recogni zed that flow accelerated corrosion (FAC) in carbon and low alloy steel components is affected by the al loy compos ition, the p H at operatin g conditions, d issolved oxygen concentration, fluid bulk velocity, component geometry and upstr eam influences, f luid tempera ture an d stea m quali ty. Th e oxy gen affects the form and so lubi lity of the o xide lay er, 79 the dissolu tion of whi ch is inhe rent in FAC. Section 3
.4 of BWRVIP-79 states that the rate of FAC increas es dramaticall y if oxy gen concentration is less th an about 25 ppb in the feedwater and condensate system, there fore, oxygen is sometimes injected to achieve this oxygen level.
The applican t was asked to describe the OCGS procedures to maintain a ppropriate ox ygen leve ls in reacto r wat er in vari ous pl ant pri mary a nd sec ondary syste ms, inc ludi ng main steam, feedwater and condensate, to mitigate loss o f material due to FAC (i.e., eros ion/corrosion
, steam cutting, etc.). In response, the a pplicant pro vided a copy of OCGS imp lementing proced ure CY-AB-12 0-110, ?Condensate a nd Feedw ater Chemistry
," Rev. 7. The project team review ed this proce dure and v erified that the oxygen l evels for the condensate an d feedwater systems are moni tored continuo usly to mai ntain them at a goal of 30-80 pp
: b. The oxy gen levels for the main steam sy stem are not spec ifically monitored. Typi cal reactor w ater oxygen levels with lo w HWC/NMCA pla nts (includi ng OCGS) have o ften been in the region of 30 to 8 0 ppb. Since steam is generate d from reactor wate r, for which o xygen le vel is monitored and controlled i n accordance with impl ementing procedure CY-AB-120-10 0, Rev. 2, th e oxygen level in the steam is maintained above 25 ppb. The project team f ound the applicant's procedures for control ling oxy gen level s acceptable since they are consiste nt with th e recommendations i n BWRVIP-79.
The project team noted that Section 4 of BWRVIP-79 recommends that the re actor water i ron level b e monitored as a new d iagnostic parame ter, and the feedw ater copper le vel be monito red as one o f the con trol p aramete rs. The projec t team a sked the appl icant to con firm that the OCGS W ater Chemistry Program includes monitoring of thes e parameters, as stat ed in the BWRVIP-79 guidelines. In response, the applica nt provide d copies of OCGS implementing procedures CY-AB-120-100 (R ev. 2) and CY-AB-120-11 0 (Rev. 7).
The project team review ed these proce dures, and v erified that these parameters are ap propriately monitored, as recommended in BWRVIP-130. Therefore, the project team found this accepta ble.The project team rev iewed th ose portions of the Water Chemistry Program for whi ch the applicant c laims consi stency w ith GALL AM P XI.M2 and found that they are consistent with the GALL Report AM P. The project team found that the app licant's Water Chemistry Program conf orm s to t he re comm ende d GAL L AMP XI.M2, wi th th e exce ptio ns de scri bed be low.3.0.3.2.2.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements: Exception 1 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected Exception: NUREG-1801 indicates that water chemist ry control is in accordance w ith BWRVIP-29 for water chemi stry in BWRs.
BWRVIP-29 references the 1996 re vision of EPRI TR-103515,"BWR W ater Chemistry Guideline s."  The Oyster Cre ek Water Chemistry P rogram is based o n BWRVIP-130, which i s the 2004 Revision of "BW R Wa ter Chemistry Guidelines." EPRI periodically updates the w ater chemistry guidelines, as new i nformation becomes avai lable.
80 The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?parameters monitored or inspected
" program elements as sociated w ith the ex ception taken:
: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control is in acco rdance wi th industry guidelines such as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.3. Para meters M onito red or Inspec ted:  The concentration of corrosive impurities l isted in the EPRI guidel ines discu ssed a bove , whi ch in clude chlo rides , fluori des (P WRs only), sulfate s, dis solv ed ox ygen, and hy drogen perox ide, a re moni tored t o miti gate degradation of structura l materials.
Water quality (pH and con ductivity) is also mainta ined in ac cordan ce wi th the guidan ce. Ch emical speci es and wate r quali ty are monitored by in process methods or through sa mpling. The chemi cal integrity of the samp les is m ain tain ed a nd v erifi ed to ens ure t hat t he me thod of sa mpli ng an d sto rage will not cause a c hange in the c oncentration o f the chemical sp ecies in th e samples.
BWR Water Chemi stry:  Th e g u i d e l i n e s i n B WR V I P-2 9 (E P R I T R-1 0 3 5 1 5) fo r B WR reactor water recommend that the c oncentration o f chlorides, sul fates, and dissol ved oxygen are monitored and kept below the recommended l evels to mitigate corrosion
.The two impu rities,chlori des and sul fates, determine the c oolant condu ctivity; dissolv ed oxy gen, hy drogen perox ide, a nd hy drogen determi ne el ectroch emical poten tial (ECP).The EPRI guidel ines recommend that the coola nt conductiv ity and E CP are also monitored and kept below the recomm ended levels to mitigate SCC and corrosion in BWR plants.
The EP RI guid elin es in BWRVIP-29 (TR-1035 15) for B WR feedwate r, condensate, an d control rod drive w ater recommend that c onductivi ty, dissol ved oxy gen level, a nd concentrati ons of iron and copper (feedw ater only) are monitored a nd kept below th e recommended l evels to mitigate SCC.
The EPRI guidel ines in B WRVIP-29 (TR-103 515) a lso i nclud e reco mmendat ions for contr olli ng wat er che mistry in au xil iary systems:  torus/pre ssure suppressi on chamber, cond ensate storage tank, an d spent fuel pool.
In the OCGS LRA , the appli cant stated that th e OCGS water chemistry AM P is based on BWRVIP-130 (EPRI-TR-1008 192):  ?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Guidelines
- 2004 Rev ision," w hich is the latest revi sion of the EP RI water ch emistry guidel ines for BW R plants. The GALL Report recom mends BW RVIP-29 (which is Revision 1 of the EPRI document EPRI-TR-10 3515, publi shed in 19 96), or later rev isions.The project team recogni zed that the staff's SER for the pea ch Bottom and D resden/Quad Cities LRA (NUREGs-1769 and 1796) ha s accepted BWRVIP-79, wh ich is Re vision 2 of the EPRI document EPRI-TR-103515, p ublished in 2000. There fore, the project team rev iewed th e applicant' s assessment of the d ifferences between the 2000 rev ision (BWRVIP-79) and 20 04 revi sion (BWRVIP-130
), wh ich a re prov ided in the appl icant's res ponse to an audit questi on. The comparison d emonstrated that the use of the 2004 revisio n of the EPRI B WR water chemistry guidelines provides an acceptable method of controlling water chemistr y that is consistent with the GALL recomme ndations. On this basis, the projec t team found this exception acceptable.
81 Exception 2 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected Exception: In transitioni ng from TR-103515-R2 to B WRVIP-130, Oyster Creek has revi ewed BWRVIP-130 and has determined that the most significant di fference from Revision 2 is that a recent poli cy of the U.S. nuc lear i ndustr y comm its ea ch nuc lear u tili ty to adopting the resp onsibili ties and proc esses on the management of materials aging i ssues describ ed in ?NEI 03-08:  Gui deline for t h e M a n a ge m e n t o f M a t e r i a l s I s s u e s."  S e c t i o n 1 o f t h e B WR Water Chemistry Guidelin es specifies w hich portion s of the document are
?Mand atory ," ?Neede d," or ?Good Practices,"
using the classifica tion describ ed in NEI 03-08. A new section (secti on 7) has been a dded and con tains recommended goals for water chemistry opti mization.
These are
?good practice" recommendations for targets that plants may use in op timizing water chemi stry that bal ances the con flicting requirements o f materials, fuel a nd radiatio n control. S ignificant time an d expense may be req uired to meet th ese tar gets; thus ef fort s to achie ve these goals should be considered in the context of the overall strategic plan for the plant. Therefore, Oy ster Creek is no t committing to obtai ning these targets. A ll other cha nges do not change the origin al intent o f revision 2 implementatio n.The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?parameters monitored or inspected
" program elements as sociated w ith the ex ception taken:
: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control is in acco rdance wi th industry guidelines such as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.3. Para meters M onito red or Inspec ted:  The concentration of corrosive impurities l isted in the EPRI guidel ines discu ssed a bove , whi ch in clude chlo rides , fluori des (P WRs only), sulfate s, dis solv ed ox ygen, and hy drogen perox ide, a re moni tored t o miti gate degradation of structura l materials.
Water quality (pH and co nductivi ty) is al so mainta ined in ac cordan ce wi th the guidan ce. Ch emical speci es and wate r quali ty are monitored by in process methods or through sa mpling. The chemi cal integrity of the samp les is m ain tain ed a nd v erifi ed to ens ure t hat t he me thod of sa mpli ng an d sto rage will not cause a c hange in the c oncentration o f the chemical sp ecies in th e samples.
BWR Water Chemi stry:  Th e g u i d e l i n e s i n B WR V I P-2 9 (E P R I T R-1 0 3 5 1 5) fo r B WR reactor water recommend that the c oncentration o f chlorides, sul fates, and dissol ved oxygen are monitored and kept below the recommended l evels to mitigate corrosion
.The two impu rities, chlo rides and su lfates, determine the coolant con ductivity; dissolv ed oxy gen, hy drogen perox ide, a nd hy drogen determi ne el ectroch emical poten tial (ECP).
82 The EPRI guidel ines recommend that the coola nt conductiv ity and E CP are also monitored and kept below the recomm ended levels to mitigate SCC and corrosion in BWR plants.
The EP RI guid elin es in BWRVIP-29 (TR-1035 15) for B WR feedwate r, condensate, an d control rod drive w ater recommend that c onductivi ty, dissol ved oxy gen level, a nd concentrati ons of iron and copper (feedw ater only) are monitored a nd kept below th e recommended l evels to mitigate SCC.
The EPRI guidel ines in B WRVIP-29 (TR-103 515) a lso i nclud e reco mmendat ions for contr olli ng wat er che mistry in au xil iary systems:  torus/pre ssure suppressi on chamber, cond ensate storage tank, an d spent fuel pool.
Durin g the au dit, th e proje ct team revi ewed the w ater ch emistry guide line s give n in b oth BWRVIP-79 (EPRI TR-103515-R2) and BWRVIP-130 (EPRI TR-100 8192) and no ted that the new sectio n 7 in BWRVIP-130 conta ins goa ls for w ater ch emistry optimi zati on. The se are?good practice" recom mended targets that plants may use in optimizing water chemistry in order to bala nce the conflic ting requirements of materi als, fuel and radiation co ntrol. The project team also noted that al l other changes between B WRVIP-79 and BWRVIP-130 do not change the origin al intent o f the Revisi on 2 guideli nes in BWRVIP-79. The app licant w as asked to cla rify th e deta ils o f this e xcep tion s ince it w as not clea r why this exce ption was neede d. Based on the applican t's response, th e project team dete rmined that not all of the good practi ces rec ommende d in B WRVIP-130 a re app lica ble to , or ac hiev able by OC GS. Ho wev er, the ap plic ant ha s impl emented those practi ces tha t are a ppli cable to the plan t and a re beneficial to the total w ater chemistry optimizati on program. For ex ample, an ex cess of feedwater zinc can be harmful to reac tor fuel, but benef icial for radiation field control. At OCGS, the appli cant establi shes an opti mum zinc program to protect the fuel, a s well as manage radiation contr ol.The project team determi ned that the ap plicant has implemented th ose good practic e recommendations th at are appli cable to the conditions of the OCGS reactor w ater, and beneficial to the total w ater chemistry optimizati on program. On this basis, the pro ject team found this ex ception acce ptable.Exception 3 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected Exception: NURE G-1801 indi cates t hat hy drogen perox ide i s moni tored t o mitigate degradation of structural materia ls. The Oyster Creek program does not moni tor for hydrogen pero xide bec ause the rapid decomp ositi on of hy drogen perox ide ma kes rel iabl e data exceptiona lly di fficult to obtain a nd BWRVIP-130 Section 6.3
.3,"Water Chemistry Guidelin es for Power Ope ration," does n ot addres s moni toring for hyd rogen p eroxi de. Hy drogen addit ion to feedwater has b een appli ed in order to mitigate occurren ce of IGSCC of structural ma terials by suppressing the formation of hydrogen perox ide. The hy drogen additio n has accompl ished an Electrochemica l Corrosion Potential (ECP) val ue less than
-230 mV, S HE (Stan dard Hy droge n El ectr ode). By mai ntai nin g a low ECP l ess tha n -230 mV, SH E, the reacto r wat er che mistry minimizes the effect s from hydrogen per oxide below the threshold that prompted the i ssue raised in NUREG 1 801. Oyster C reek 83 uses the ISI pro gram to investi gate whether stru ctural degradatio n in potentially affected locations is ong oing. Oyster Creek' s ISI program provides f or condition monitoring of the reactor vessel, reactor internal components and ASME Class 1 pre ssure retaini ng components in accordance w ith ASM E Section XI, S ubsection IW B. Indication s and relev ant conditio ns detected du ring exami natio ns are eval uated in ac cordan ce wi th ASM E Sect ion XI Articles IWB-3000, for Class 1
.The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?parameters monitored or inspected
" program element ass ociated w ith the ex ception taken:
: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control i s in accorda nce with industry gui delines su ch as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.3. Para meters M onito red or Inspec ted:  The concentration of corrosive impurities l isted in the EPRI guidel ines discu ssed a bove , whi ch in clude chlo rides , fluori des (P WRs only), sulfate s, dis solv ed ox ygen, and hy drogen perox ide, a re moni tored t o miti gate degradation of structura l materials.
Water quality (pH and co nductivi ty) is al so mainta ined in ac cordan ce wi th the guidan ce. Ch emical speci es and wate r quali ty are monitored by in process methods or through sa mpling. The chemi cal integrity of the samp les is m ain tain ed a nd v erifi ed to ens ure t hat t he me thod of sa mpli ng an d sto rage will not cause a c hange in the c oncentration o f the chemical sp ecies in th e samples.
BWR Water Chemi stry:  Th e g u i d e l i n e s i n B WR V I P-2 9 (E P R I T R-1 0 3 5 1 5) fo r B WR reactor water recommend that the c oncentration o f chlorides, sul fates, and dissol ved oxygen are monitored and kept below the recommended l evels to mitigate corrosion
.The two impu rities, chlo rides and su lfates, determine the coolant con ductivity; dissolv ed oxy gen, hy drogen perox ide, a nd hy drogen determi ne el ectroch emical poten tial (ECP).The EPRI guidel ines recommend that the coola nt conductiv ity and E CP are also monitored and kept below the recomm ended levels to mitigate SCC and corrosion in BWR plants.
The EP RI guid elin es in BWRVIP-29 (TR-1035 15) for B WR feedwate r, condensate, an d control rod drive w ater recommend that c onductivi ty, dissol ved oxy gen level, a nd concentrati ons of iron and copper (feedw ater only) are monitored a nd kept below th e recommended l evels to mitigate SCC.
The EPRI guidel ines in B WRVIP-29 (TR-103 515) a lso i nclud e reco mmendat ions for contr olli ng wat er che mistry in au xil iary systems:  torus/pre ssure suppressi on chamber, cond ensate storage tank, an d spent fuel pool.
As part of the aud it, the project tea m interview ed the appl icant's tech nical staff to disc uss technical i ssues related to this ex ception. Du ring the interv iew, the applicant s tated that hydrogen addi tion to feedw ater has been applied to mitigate occurrenc e of IGSCC in stru ctural materials by suppressing the formation of hydrogen peroxide.
The hydrogen a ddition ha s accomplished an Electrochemical Corros ion Potential (ECP) value less than -230mV, SHE (Standard Hy drogen Electrode
). By main taining a lo w ECP l ess than -230mV, SHE, the reacto r water chemi stry minimiz es the effects from hydrogen p eroxide.
84 The project team recogni zed that the ECP quantifies the oxidi zing pow er of a solutio n in contact with a specific metal surface.
The ECP of differ ent reactor internals comp onent materials is very sen sitive to the concentrati on of oxygen, hydrogen, and hydrogen perox ide (whi ch determine the E CP), and therefore i s different at different loca tions wi thin the BWR reactor system. Secti on 5.3 of BWRVIP-79 discusses the potential locations suitable for meas uring the ECP (Fig. 5.5) a nd Section 5.4 provid es alternate E CP estimation techniques. There fore, the applicant w as asked to cla rify how th e threshold E CP leve l is mainta ined wi thin the reacto r system without monitoring the hydrog en peroxide level.
In its response, the applicant stat ed that at OCGS the ECP is directly monitored with ECP probes in the B recirculation loop via the reactor water cleanup (RW CU) system (location E in Fig. 5.5 of BWRVIP-79). In additi on, the disso lved ox ygen is moni tored in the reactor water as a se cond ary para mete r to e nsur e tha t mit igat ion is m ain tain ed i n the reci rcul atio n lo ops. To assure that an adequate excess of hydrogen relative to oxygen is present to reduce the ECP below -2 30 mV (SHE) a t target locations during pow er operation, th e measured reacto r water hydrogen-to-oxygen molar r atio (an alternate to ECP per Appendix E of BW RVIP-130) is main tain ed a t grea ter t han 3 du ring hyd rogen inj ecti on. Thus , OCG S ha s ch osen a st rate gy that uses ECP or the measured molar ratio of hy drogen-to-oxygen as the primary indicator o f IGSCC mitigation with pro of of sufficient catalys t loading. A ccording to OCGS i mplementing procedure CY-A B-120-1000 (Re
: v. 2), Secti on 4.6B, ve rification of mitigati on can also be based on rad ioly sis mo deli ng usin g an EP RI mode l as a n alte rnate t o ECP measur ement.The project team determi ned that the OCGS Water Chemistry Program inclu des activi ties that are adequate to e nsure that the re actor water c ontains an a dequate excess of hydrogen relative to oxygen to reduce the E CP below -230 mv (SH E) at target locati ons. On this b asis, the project team found this excep tion acceptab le.Exception 4 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected Exception: NUREG-1801 i ndicates that dissolve d oxygen is monitored.
Consistent w ith the guidan ce provid ed in BWRVIP-130, conde nsate storage tank, de minera liz ed w ater st orage ta nk wat er, spent fuel pool water and torus water are not sample d for dissolve d oxygen.
The Oyster Cree k chemistry proce dures require monitorin g of conductivi ty, chlorid es, sulfates and total organic carbon (TOC) i n accordance with li mits set by BWRVIP-130 as an alternate method for ensurin g component integr ity.The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?parameters Mo nitored or Insp ected" program elemen ts associated with the exception taken: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control is in acco rdance wi th industry guidelines such as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for 85 primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.3. Para meters M onito red or Inspec ted:  The concentration of corrosive impurities l isted in the EPRI guidel ines discu ssed a bove , whi ch in clude chlo rides , fluori des (P WRs only), sulfate s, dis solv ed ox ygen, and hy drogen perox ide, a re moni tored t o miti gate degradation of structura l materials.
Water quality (pH and co nductivi ty) is al so mainta ined in ac cordan ce wi th the guidan ce. Ch emical speci es and wate r quali ty are monitored by in process methods or through sa mpling. The chemi cal integrity of the samp les is m ain tain ed a nd v erifi ed to ens ure t hat t he me thod of sa mpli ng an d sto rage will not cause a c hange in the c oncentration o f the chemical sp ecies in th e samples.
BWR Water Chemi stry:  Th e g u i d e l i n e s i n B WR V I P-2 9 (E P R I T R-1 0 3 5 1 5) fo r B WR reactor water recommend that the c oncentration o f chlorides, sul fates, and dissol ved oxygen are monitored and kept below the recommended l evels to mitigate corrosion
.The two impu rities, chlo rides and su lfates, determine the coolant con ductivity; dissolv ed oxy gen, hy drogen perox ide, a nd hy drogen determi ne el ectroch emical poten tial (ECP).The EPRI guidel ines recommend that the coola nt conductiv ity and E CP are also monitored and kept below the recomm ended levels to mitigate SCC and corrosion in BWR plants.
The EP RI guid elin es in BWRVIP-29 (TR-1035 15) for B WR feedwate r, condensate, an d control rod drive w ater recommend that c onductivi ty, dissol ved oxy gen level, a nd concentrati ons of iron and copper (feedw ater only) are monitored a nd kept below th e recommended l evels to mitigate SCC.
The EPRI guidel ines in B WRVIP-29 (TR-103 515) a lso i nclud e reco mmendat ions for contr olli ng wat er che mistry in au xil iary systems:  torus/pre ssure suppressi on chamber, cond ensate storage tank, an d spent fuel pool.
As part of the aud it, the appl icant's tech nical staff were intervie wed to di scuss technic al issues related to thi s exceptio
: n. During the interview , the appli cant stated that th e water i n the conde nsate storage tank, de minera liz ed w ater st orage ta nk, spen t fuel p ool, a nd toru s are exposed to atmospheric con ditions (i.e
., air-saturated) a nd hence, measu ring dissolv ed oxygen in the w ater for these loca tions wou ld not prov ide the actua l oxygen content nor he lp determine the qua lity of the w ater. Th e appl icant was asked to expl ain w hat al ternate parame ters ar e monito red for t he w ater i n thes e tanks, whi ch are expo sed to the at mosphe re and therefo re contain w ater saturated w ith oxy gen. In its respo nse, the appl icant stated th at dissolv ed oxygen is monitored routinely for the feedwater, c ondensate and CRD wa ter systems, as recommended in BWRVIP-1 30, an d thus , is co nsiste nt wi th GALL. How ever, the ab ove t anks or reserv oirs associated w ith these sy stems are monitored for conductivi ty, chlorid es, sulfates and total organic carbon (TOC) i n accordance with li mits set by BWRVIP-130, Appendix B, as an alterna te met hod for ensuring compone nt integ rity.The pro ject tea m deter mined that th e OCGS Water Chemis try Pr ogram mon itors the w ater bo th within the subject systems, and within their associated tank s or reservoirs, as recomme nded in BWRVIP-130. On this basis , the project team found this exce ption accepta ble.Exception 5 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 86 Exception: NUREG-1801 indicates that water quality (pH and conduct ivity) is mainta ined in ac cordan ce wi th esta blis hed gui dance. How ever, per BWRVIP-130, "BWR W ater Chemistry Guideline s," Section 8.2.1.11, pH measurem ent accuracy in most BW R streams is generally s uspect because of the dependen ce of the instrument reading on io nic strength of the sa mple soluti on. In addi tion, the monitoring of pH i s not discuss ed in BWRVIP-130, Appen dix B for condensate stora ge tank, deminerali zed wa ter storage tank, or torus water. pH is not monitored f or torus water, however pH is monito red in the CS T & DWST. Alt ernate method s are a ppli ed to monitor the w ater chemistry of the torus in l ieu of direct p H measure ments. The Oys ter Cre ek chemi stry p rocedu res requ ire monitoring of conduc tivity, chlorides a nd sulfates in accordance with li mits set by BWRVIP-130.
The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?parameters Mo nitored or Insp ected" program elemen t associated with the exception taken: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control is in acco rdance wi th industry guidelines such as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.3. Para meters M onito red or Inspec ted:  The concentration of corrosive impurities l isted in the EPRI guidel ines discu ssed a bove , whi ch in clude chlo rides , fluori des (P WRs only), sulfate s, dis solv ed ox ygen, and hy drogen perox ide, a re moni tored t o miti gate degradation of structura l materials.
Water quality (pH and co nductivi ty) is al so mainta ined in ac cordan ce wi th the guidan ce. Ch emical speci es and wate r quali ty are monitored by in process methods or through sa mpling. The chemi cal integrity of the samp les is m ain tain ed a nd v erifi ed to ens ure t hat t he me thod of sa mpli ng an d sto rage will not cause a c hange in the c oncentration o f the chemical sp ecies in th e samples.
BWR Water Chemi stry:  Th e g u i d e l i n e s i n B WR V I P-2 9 (E P R I T R-1 0 3 5 1 5) fo r B WR reactor water recommend that the c oncentration o f chlorides, sul fates, and dissol ved oxygen are monitored and kept below the recommended l evels to mitigate corrosion
.The two impu rities, chlo rides and su lfates, determine the coolant con ductivity; dissolv ed oxy gen, hy drogen perox ide, a nd hy drogen determi ne el ectroch emical poten tial (ECP).The EPRI guidel ines recommend that the coola nt conductiv ity and E CP are also monitored and kept below the recomm ended levels to mitigate SCC and corrosion in BWR plants.
The EP RI guid elin es in BWRVIP-29 (TR-1035 15) for B WR feedwate r, condensate, an d control rod drive w ater recommend that c onductivi ty, dissol ved oxy gen level, a nd concentrati ons of iron and copper (feedw ater only) are monitored a nd kept below th e recommended l evels to mitigate SCC.
The EPRI guidel ines in B WRVIP-29 (TR-103 515) a lso i nclud e reco mmendat ions for contr olli ng wat er che mistry in au xil iary systems:  torus/pre ssure suppressi on chamber, cond ensate storage tank, an d spent fuel pool.
87 In review ing this ex ception, the p roject team noted th at OCGS monitors co nductivi ty, chlorid es, sulfates and total organic carbons (TOC) in the torus, per BWRVIP-130, Table B-3, w hich does not in clude pH as one o f the pa rameter s. The a ppli cant w as aske d  to e xpla in the alter nate method that i s used to moni tor pH in the torus wate r. In re sponse , the a ppli cant st ated th at a pH analy sis of the torus w ater has been performed periodic ally an d the torus w ater pH has been found to be near neutral (i.e., 6.6 - 7.4
). This is ba sed on measuremen ts during the l ast five years (July 200 1 - 6.7; M arch 2002 - 7
.0; July 2 003 - 6.9; Ap ril 2005 -
7.4; and June 2005- 6.6). The appl icant also stated that this pH analy sis wil l continue during the peri od of extended o peration.The pro ject tea m deter mined that th e appl icant has b een ro utine ly mo nitori ng para meters suggested in the B WRVIP-130, and, in additi on, the appl icant is pe rforming pH analy sis of the torus water periodically to ensure its quality. On this basis, the proj ect team found this exception acceptable.
Exception 6 Elements: 1. Scope of Program
: 4. Dete ction of Agin g Effects Exception: Aging of Standby Liquid Control (SBLC) sy stem components no t in the reactor coolant pressu re boundary section of SBL C system relies on monitoring and c ontrol of SBLC makeup water chem istr y. T he ma keup wa ter i s mon itor ed i n li eu o f the stor age tank, because the sodium pentabo rate that is mai ntained in the storage tank w ould mask most of the c hemist ry pa rameter s monitored. The effectiv eness of the Water Chemistry Pro gram will be verified by a one-ti me inspection of the SBLC sy stem as discussed i n the One-Time Inspe ction (B.1.24) a ging manageme nt progr am.The GALL Report i dentified the foll owing recommend ations for the
?scope of program" and
?detection of aging effects" program e lements associ ated with the excep tion taken:
: 1. Sco pe of P rogram:  The prog ram inclu des p erio dic m onit orin g and cont rol of known detrimental con taminants such as chloride s, fluorides (PWRs only), d issolved oxygen, and sulfate conc entrations bel ow the l evels know n to result i n loss of materia l or cracking. Water chemistry control is in acco rdance wi th industry guidelines such as BWRVIP-29 (EPRI TR-103515) for w ater chemistry in BWRs, EPRI TR-105714 for primar y w ater ch emistry in PWRs, an d EPR I TR-102 134 for second ary w ater ch emistry in PWRs.4. Dete ction of Agi ng Effe cts:  This is a miti gation program and d oes not prov ide for detection of any aging effects.
In cert ain c ases a s ide ntifie d in t he GAL L Repo rt, ins pecti on of se lect c ompone nts is to be und ertaken to ve rify th e effecti vene ss of the chemi stry c ontrol program and to ensur e that significant d egradation is not occurring and the component i ntended function will be maintained d uring the exte nded period of operation.
88 As part of the aud it, the project tea m interview ed the appl icant's tech nical staff to disc uss technical i ssues related to this ex ception. Du ring the interv iew, the applicant s tated that aging of Standby Li quid Control (SBLC) syste m components reli es on monitori ng and control of SBLC makeup water ch emistry. The makeup water is monitored in lieu of the sto rage tank, because the sodium pe ntaborate that i s maintained in the storage tank would mask most of the chemistry para meters monitored.
The applican t claims that th e effectiveness of the Water Chemistry P rogram will be verified by a one-time inspecti on of the SBLC system, as di scussed in the one-ti me inspection aging management program (AM P B.1.24). The a pplicant w as asked to confirm that the one-time ins pection w ould consi der the SBLC pump casing, an d the associated tan k discharge pipi ng and val ve bodie s in addi tion to the tan
: k. In its respons e, the applicant s tated that one s tainless ste el sample o f the entire sy stem (includi ng the piping a nd fittings , tanks, thermow ells , and v alve bodi es) w ould be sel ected for thic kness me asureme nts and crack detectio n using a v olumetric ex amination su ch as UT. Si nce the SBLC is a standb y syste m, any secti on of pi pe (w ith th e smal lest t hickne ss wh en comp ared to val ve an d pump bodies or oth er pipe fittings) c ontaining sod ium pentaborate represents a
?worst-case" l ocation.The project team determi ned that the ap plicant w ould sele ct a ?worst-case" sa mple from the SBLC sys tem in the One-Time Inspection Pro gram, which w ill prov ide assuranc e the aging effect s for this system will be adequately managed. On t his basis, the project team f ound this exception acceptable.
3.0.3.2.2.4 Enhan cements None 3.0.3.2.2.5 Operating Expe rience In the OCGS LR A, the appli cant st ated th at peri odic self-as sessme nts of th e wa ter che mistry activ ities have been, and c ontin ue to b e perfor med to i denti fy area s that need i mprov ement to mainta in the qu ality perf orman ce of t he activit y.The Water Chemistry Program has i dentified ins tances whe re parameters w ere outside th e establ ished speci ficatio ns. In crease d sampl ing an d acti ons to bring the pa rameter s back i nto speci ficatio n we re ini tiated. The ch emistry excu rsion is th en doc umented in a condi tion r eport in accordanc e with p lant admini strative proc edures. The correc tive acti ons program ensures that the condi tions adv erse to quality are promptly corrected. If the de ficiency i s assessed to be significantly adverse to quality, the cause of the cond ition is determined and a correctiv e action plan is d eveloped to preclude repetition. S ome example s are as follo ws:*The deminerali zed wa ter system w as contaminated due to a cros s-connection w ith the fuel po ol. Th e sys tem wa s flush ed and use o f demine raliz ed w ater re quired chemi stry sampling to ens ure that the w ater was '
clean'. A plan w as devel oped to sampl e the demineraliz ed water sy stem from many locati ons. The comple tion of this pl an enabled the demineral ized w ater system to b e declared '
clean' agai n.*There hav e be en s ome i nsta nces of re acto r wa ter s ulfa te l eve ls e xce edi ng ?Action Lev el 1" limits of 5 p pb. When this occurred, in creased sampli ng was performed an d corrective a ctions (such a s placing 2 RWCU pump inservice) w ere implemented
.*A resin in gress caused by failure of the und erdrain sy stem occurred in one of the condensate de mineraliz ers. This ev ent was en tered into the corrective a ction process 89 and the apparent cause was determined to be due to incomp lete work in the underdrain insta llati on four years prior.In its PBDs the applica nt stated that a review of industry o perating expe rience has c onfirmed that IGSCC has occurred in s mall and l arge diameter BWR piping made o f austenitic stai nless steels a nd nicke l-based alloys. Sig nifica nt crac king has occur red in rec irculat ion, cor e spray, residual he at removal, a nd RWCU systems pipin g welds. IGSC C has also occurred in a number of vess el in ternal compon ents, i nclud ing cor e shro ud, ac cess h ole c over, top gui de, an d core spray sparger s as re ferenced in NR C Bul letin 80-13 , IN 95-17, GL 94-03, and N UREG-1 544. No occ urrenc e of SCC in pi ping a nd oth er comp onents in st andby liqui d cont rol sy stems exposed to sodium pentaborate solution has ever been repor ted as referenced in NUREG/CR-6001
.The project team rev iewed a n OCGS self-assessmen t report titled
?Focus Area Self-Assessment Re port, 4/13 - 4/16 , 2004," whi ch was pe rformed during April 2004, and verified that it identified areas of improvements to maintain the perf ormance quality of this AMP.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the ap plic ant's t echni cal st aff, the pr oject te am dete rmined that th e appl icant's Water Che mistry Program will adequately manage the aging effects that are identified i n the OCGS LRA for which thi s AMP i s credited.
3.0.3.2.2.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he Water Che mistry Program in OC GS LRA, Append ix A, Se ction A.1.2, w hich states tha t the water c hemistry aging man agement program is an ex isting program wh ose activi ties consist of monitoring and co ntrol of water chemistry to ma nage the aging of pipi ng, piping compone nts, piping el ements and heat exch angers t hat are expo sed to treate d wa ter to ke ep pea k leve ls of v ariou s conta minant s below syste m-speci fic li mits ba sed on indu stry-r ecogni zed gu idel ines of BWRVIP-130
:  ?B WR Vessel and Internals Project BWR W ater Chemistry Guideline s" for the preven tion or mitigati on of loss of material, reduction of heat transfer and cracking agin g effects. In addition, the Water Chemi stry P rogram i s also credi ted for mi tigati ng loss of materi al an d cracki ng for com ponen ts exposed to sodium pentabo rate and boi ler treated w ater enviro nments. To mitigate a ging effects on component surfaces, the chemistry program is used to control w ater chemistry for impurities th at accelerate corrosion.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.2, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR UFS AR Supple ment table and as require d by 10 CFR 54.21 (d).3.0.3.2.2.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and 90 their associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.3 Reactor Head Closure Stud s (OCGS AMP B.1.3)In OCGS LRA, Ap pendix B , Section B.1
.3, the appli cant stated that OC GS AMP B.1.3, "Reactor Head Closu re Studs," is a n existi ng plant program that i s consistent w ith GALL AM P XI.M3,"Reactor Head Closure Stud s," with an exceptio n.3.0.3.2.3.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for conditi on monitoring an d preventiv e activi ties to manage stud cracking. The program is implemented thro ugh station procedures base d on the ex amination an d inspectio n requirements spec ified in AS ME Secti on XI, Tabl e IWB-2500-1 and p reven tive measur es des cribe d in R egulat ory Gu ide 1.65, ?Materials and In specti on for R eactor Vesse l Clo sure S tuds."3.0.3.2.3.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.3 is consi stent with GALL AMP XI.M 3, with a n excepti on.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.3, includin g PBD-AMP-B.1.03, "Reactor H ead Closure Studs," Rev. 0, which provides an assessment of the AM P elements' co nsistency with GALL AMP XI.M 3. Specifical ly, the pro ject team re view ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report)contained i n OCGS AMP B.1.3 and as sociated bas es documents to determine thei r consistency with GALL AMP XI.M 3.Also, the pr oject te am rev iew ed OCGS stud d rawi ng CE 2 32-573 , ?Stud, N ut, Washer, &
Bushing Detail, Re
: v. 10 and its certif ied mate rial test report (CMTR), Crucible Steel Com pany,?Piece Numbe r 573-01, Code Number G-385," date d 8/7/65, to con firm that the closure studs are constructed o f ASME SA-193 GR. AISI 43 40 material, w hich has a tensile stren gth of less than 170 ksi a nd complies with Regul atory Guide 1.65.The project team rev iewed th ose portions of the Reactor Hea d Closure S tuds Program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 3 and found th at they are consistent w ith the GALL R eport AMP. The project team found that the appl icant's Re actor Head Closu re Studs Program con forms to the recommendati ons in GALL AMP XI.M 3, with th e excep tion desc ribe d belo w.3.0.3.2.3.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Elements: 3:  Parameters M onitored/ Inspe cted 4:  Det ectio n of Agi ng Effects 91 5:  Moni toring and Trendin g 6:  Acceptance Criteria Exception: The current ASM E code of record for ISI at Oyster Cree k is the 1995 Editi on through the 19 96 Addenda.
The GALL Report i dentifies the foll owing recommend ation for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and acce ptance criteri a"program elements asso ciated wi th the excep tion taken:
: 3. Parameters Moni tored or Inspected
:  The ASM E Section XI IS I program detects and sizes crac ks, detects loss o f material, and de tects coolant l eakage by follow ing the examinatio n and insp ection requiremen ts specified i n Table IWB-2500-1.
: 4. Detect ion o f Agin g Effec ts:  The extent a nd schedule of the inspecti on and test techniques prescri bed by the program are designed to maintain structural inte grity and ensure that aging e ffects will be discovere d and repai red before the lo ss of intended functio n of the compon ent. In specti on can reve al cra cking, l oss of ma terial due to corrosion or w ear, and lea kage of coolant. The pro gram uses visu al, surface, and volumetric examinatio ns in accord ance wi th the general re quirements of Subsecti on IW A-2000. Surface e xamination uses magnetic pa rticle, liqui d penetration, or eddy current exami nations to i ndicate the p resence of surface di scontinuiti es and flaw s.Volumetric ex amination us es radiographi c or ultrasoni c examinati ons to indi cate the presen ce of di sconti nuiti es or fl aws t hrougho ut the volu me of mate rial. Visu al VT-2 examinatio n detects ev idence of lea kage from pressure-retainin g components, as require d duri ng the s ystem pressu re test.Components are examined a nd tested as s pecified in Table IWB-2500-1. Examina tion category B-G-1 for press ure-retaining bo lting greater than 2 in. diameter in reactor vessels s pecifies vo lumetric ex amination of stud s in place , from the top of the nut to the bottom of the flange hol e, and surface and volumetric examinati on of studs wh en remov ed. Al so spe cified are v olumet ric ex aminat ion o f flange th reads and v isual VT-1 examinatio n of surfaces of nuts, w ashers, and bu shings. Exa mination category B-P for all pressure retaining component s specifies visual VT-2 examination of all pressure-retaini ng boundary c omponents durin g the system le akage test and the syste m hydr ostati c test.5. Monitoring and Trendin g:  The Inspection schedule o f IW B-2400, and th e extent an d frequency of IWB-2500-1 provide ti mely detecti on of cracks, loss of materi al, and leakage.6. Acceptance Criteria
:  Any indi catio n or re leva nt con ditio n of degra datio n in c losur e stud bolting i s evalua ted in accord ance wi th IWB-3100 by comparing ISI re sults wi th the acceptance stan dards of IWB-3400 and IWB-3500.
The applican t stated, in the OCGS LRA, that for justification of ex ceptions to th e ISI program see the ASM E Section XI In service Ins pection, Subs ections IWB, IW C, and IWD aging management program, AM P B1.1. The pro ject team revie wed OCGS A MP B.1.1 and documented its acceptabili ty in Sec tion 3.0.3.2.1 o f this report. On thi s basis, the project team found this ex ception acce ptable.
92 3.0.3.2.3.4 Enhan cements None.3.0.3.2.3.5 Operating Expe rience The applicant stated, in the OCG S LRA, that Oyster Creek is curr ently in its fourth ISI inspection interval.
In the history of the Oyster Cree k ISI program no evi dence of head stu d crack ing has b een fou nd. The reacto r head clo sure st uds, nut s, washer s, and bus hings ha ve been coated w ith a manganese phosphate surface treatment. The operati ng experienc e for these components indicates th at nicks, scratches, gouges, and thread d amage have occ urred due to mainten ance activ ities durin g refueling outages. This normal we ar type of damage w as determined to b e acceptable for continued se rvice. There have been no deficienc ies attributed to distortion/p lastic deformation from stress relaxa tion or loss of material due to mechanical wear. This provides evidence that the aging mana gement program is effective.
In its PBDs the applica nt stated that a review of industry o perating expe rience has c onfirmed that cracking due to SCC has occ urred in reacto r head studs. A review of plant operati ng experience at OCGS show s that cracking of the he ad studs from SCC, IGSCC, and lo ss of material due to wear ha s not occurred.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Reactor Head Closure Stud s Program wil l adequately manage the aging effects that a re identified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.3.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Reactor Head Closure Studs Program in OCGS LRA, Appe ndix A, S ection A.1.3, w hich states tha t the Reactor H ead Closure Studs Program is an ex isting program that pro vides for con dition moni toring and prev entive ac tivities to manage stud crackin
: g. The program is impl emented through stati on procedures based on the ex aminat ion a nd in specti on requ iremen ts spec ified in AS ME S ectio n XI, Tab le IWB-2500
-1 and pr even tive measur es des cribe d in R egulat ory Gu ide 1.65, ?Material s and Inspecti on for Reacto r Vess el Cl osure Studs."The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.3, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.3.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to 93 manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.4 BWR Vessel ID Attachment Welds (OCGS AM P B.1.4)I n O C G S L R A , A p p e n d i x B , S e c t i o n B.1.4 , t h e a p p l i c a n t s t a t e d t h a t O C G S A M P B.1.4 , " B WR Vessel ID A ttachment Welds," is an exi sting plant pro gram that is consi stent with GALL AMP XI.M 4, "BWR Vessel ID Attachment Welds," with excepti ons.3.0.3.2.4.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program's acti vities i ncorporate the i nspection and ev aluat ion re commend ation s of BWRVIP-4 8, as w ell a s the w ater ch emistry recommendations o f BW RVIP-130. The p rogram is implemen ted through station procedures that provid e for mitigation of crackin g through water ch emistry and monitoring for cracking through in-ves sel exami nations. Re actor vessel attachment we ld inspecti ons are impl emented through station pro cedures that are part of in-serv ice inspec tion and i ncorporate the req uire ment s of ASME, S ecti on XI. Ins pect ions are pe rfo rme d in ac cord ance with AS ME requirements consi stent with BWRVIP-48.
3.0.3.2.4.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.4 is consi stent with GALL AMP XI.M 4, with e xceptions.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.4, includin g PBD-AMP-B.1.04, "BWR Vessel ID Attac hment Welds," Rev. 0, wh ich provi des an assessment of the AM P elements' co nsistency with GALL AMP XI.M 4. Specifical ly, the pro ject team re view ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report)contained i n OCGS AMP B.1.4 and as sociated bas es documents to determine thei r consistency with GALL AMP XI.M 4.Also, the pr oject te am rev iew ed OCGS Program Plan OC-5, ?Reacto r Intern als P rogram,"Revisio n 0, 9/30/2005, which l isted the lo ng-term inspection schedule, requi rements and inspe ction type for each indi vidu al co mponen t.The inspection guidelines of BWRVIP-48 recommend enhanced visual VT-1 (EVT-1) exami natio n of al l safety-relat ed atta chments and th ose no n-safety-relat ed atta chments identified as being suscepti ble to IGSCC.
The applica nt's exami nation pla n applies EVT-1 for all of the ID attachment wel ds, regardless i f the welds are known to be susceptib le to IGSCC o r not. Th e proje ct team found t his accep table sin ce the app licant's plan is mor e conser vative than the GALL R eport recommendatio n.The project team rev iewed th ose portions of the BWR Vessel ID Attachment Welds Program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 4 and found th at they are c o n s i s t e n t w i t h t h e G A L L R e p o r t A M P. T h e p r o j e c t t e a m fo u n d t h a t t h e a p p l i c a n t's B WR Vesse l ID A ttachme nt Welds Pro gram con forms to t he rec ommende d GALL AMP XI.M4 , wi th the e xcept ions desc ribe d belo w.
94 3.0.3.2.4.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements: Exception 1 Eleme nt: 2:  Preventi ve Action s Exception: NUREG-1801 indicates that water chemist ry control is in accordance w ith BWRVIP-29 for water chemi stry in BWRs.
BWRVIP-29 references the 1993 re vision of EPRI TR-103515,"BWR W ater Chemistry Guideline s."  The Oyster Cre ek Water Chemi stry P rograms a re bas ed on BWRVIP-130:
  ?BWR Vessel and Internals Project BW R Wa ter Chemistry Guidelines", which is the 20 04 rev isi on of ?BWR W ater Chemistry Guideline s". For justification of ex ceptions to th e Water Chemistry Program see the Water Chemistry aging management p rogram, B.1.2.
The GALL Report i dentified the foll owing recommend ation for the
?preventiv e actions" pro gram element associ ated with the excep tion taken:
: 2. Preventive A ctions:  The BWRVIP-48 provides guidance on detection, but does not provi de gui dance on meth ods to mitiga te crac king. M ainta inin g high w ater pu rity reduces suscep tibility to SCC or IGS CC. Reactor coolant w ater chemistry is monitored and mai ntain ed in accord ance w ith th e guid elin es in BWRVIP-29 (EPRI TR-10351 5).The program descripti on and ev aluation a nd technical basis of monito ring and maintaining rea ctor water ch emistry are p resented in S ection XI.M2.
The app lica nt stat ed, in the OC GS LRA , that t he Oys ter Cre ek Water Chemi stry P rograms a re based on BWRVIP-1 30:  ?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Gui del in es", w hi ch i s th e 2 004 rev isi on of ?BWR W ater Chemistry Guideline s."  For justificati on of exceptions to the Water Chemistry Program, see the water chemistry agin g management program, AMP B.1.2. The pr oject te am rev iew ed AM P B.1.2 and docume nted i ts acce ptabi lity in Section 3.0.3.2.2 of this re port. On this ba sis, the project team found this ex ception acceptable.
Exception 2 Elements: 3:  Parameters M onitored/ Inspe cted 4:  Det ectio n of Agi ng Effects 5:  Moni toring and Trendin g 6:  Acceptance Criteria Exception: NUREG-1801 program XI.M9 references ASME Section XI, Table IW B 2500-1 (200 1 edition, includin g the 2002 and 2003 Addenda). Oy ster Creek ISI program i s based on th e 1995 (including 1 996 Addenda) version of ASME Se ction XI. For just ific atio n of excep tion s to t he IS I pro gra m see the AS ME S e c t i o n X I I n s e r v i c e I n s p e c t i o n , S u b s e c t i o n s I WB , I WC , a n d I WD aging management program, B1.1.
95 The GAL L Repo rt ide ntifie s the fol low ing rec ommenda tion fo r the a bove program elemen ts associated w ith the ex ception taken:
: 3. Parameters Moni tored or Inspected
:  The program monitors the effects of SCC and IGSCC on the i ntended function of vessel attac hment weld s by detecti on and siz ing of cracks by ISI i n accordance with the guidelines of approved B WRVIP-48 and the requirements of the AS ME Code , Section XI, Tabl e IWB 2500-1 (2001 editio n3 includ ing the 2002 and 2003 Adden da). An appl icant may u se the guidel ines of BWRVIP-62 for inspection relief for vessel internal co mponents wi th hydrogen w ater chemistry provided that such reli ef is submitted u nder the prov isions of 10 CFR 50.55a and approv ed by the sta ff.4. Detect ion o f Agin g Effec ts:  The extent and schedule o f the inspection and test techniques prescri bed by BWRVIP-48 guidel ines are des igned to maintai n structural integrity and ensure that agi ng effects will b e discove red and repai red before the lo ss of inten ded fun ction. Inspe ction can re veal cracki ng. Ves sel ID attach ment w elds are inspected in accordance with the requirem ents of ASME Section XI, Subsection IW B, examinatio n category B-2.
The Section XI i nspection sp ecifies vi sual VT-1 ex amination to detect disco ntinuities and imperfections on the surfaces of compo nents and v isual VT-3 examinati on to determine the general mech anical an d structural con dition of the component suppo rts. The inspecti on and ev aluation gui delines o f BW RVIP-48 recommend more strin gent inspection s for certain attach ments. The guidel ines recommend enhance d visual VT-1 examina tion of all s afety-related attac hments and those non-safety-re lated attachments identified a s being suscep tible to IGSC C. Visual VT-1 ex aminat ion i s capa ble o f achie ving 1/32 i n. reso lutio n; the enhan ced v isual VT-1 examination method is capable of achieving a 1-mil wire resolution. The NDE techniques appro priate for inspe ction of BWR vessel in ternals incl uding the uncert ainti es in herent in de liv ering a nd ex ecuti ng NDE techn iques i n a BWR, are included in BWRVIP-03.
: 5. Moni toring and T rendi ng:  Inspections sc heduled i n accordance with IWB-2400 and approv ed BWRVIP-4 8 guid elin es pro vide timel y det ectio n of crac ks. If flaw s are detected, the sco pe of examina tion is ex panded.6. Acceptance Crit eria:  Any in dica tion dete cted is eval uate d in ac cord ance with AS ME Section XI or the staff-approved BWRVIP-48 guideli nes. Appli cable and approved BWRVIP-14, BW RVIP-59, and BWRVIP-60 documents provi de guidelin es for evalua tion of cra ck gr owth in stai nless st eels (SSs), nick el alloys, an d low-alloy st eels, re spective ly.The pro ject tea m revi ewed this exce ption as pa rt of its revi ew o f OCGS AM P-B.1.1, ?ASME Section XI Inservice Inspection, Subsection IW B, IW C, and IW D" program and f ound it acceptable.
The project team's e valuatio n is documente d in Secti on 3.0.3.2.1 of this audit and revi ew re port.3.0.3.2.4.4 Enhan cements None.
96 3.0.3.2.4.5 Operating Expe rience The applican t stated, in the OCGS LRA, that the Oyster Cree k inspection a nd testing methodologies h ave not de tected cracking in the attachment w elds in th e history of the Oyster Creek plant. This provides evidence that the W ater Chemistry Program has been effective in minimi zing the effect s of stre ss corr osion cracki ng in t he atta chment wel ds. The same inspection and testing method ologies are u sed for the attachment welds a s are used for othe r reactor internal
: s. These processe s have de tected cracking in other vessel internal components.
The project team rev iewed th e summary of correcti ve action programs (CAP) prov ided in th e program basis docu ment. Those CAPs indicated that other aging managemen t activiti es similar to th ose for the reactor v essel ID attac hment weld s have de tected aging degradati on with app ropriate correcti ve action s implemented to maintain s ystem and comp onent intende d functions, incl uding prompt repai r of degraded componen ts prior to fail ure. The project tea m found that the app licant's a ging management activ ities approp riately a ddressed the a ging effect s for cracking due to IGSCC.
The project team als o review ed the operati ng experienc e provide d in the OCGS LRA, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions w i t h t h e a p p l i c a n t's t e c h n i c a l s t a ff , t h e p r o j e c t t e a m d e t e r m i n e d t h a t t h e a p p l i c a n t's B WR Vesse l ID A ttachme nt Welds Pro gram wi ll ad equatel y mana ge the a ging effect s that are identified i n the OCGS LRA for which th is AMP is credited
.3.0.3.2.4.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the BWR Vessel ID Attachment Welds Program in OCGS LRA, Appen dix A, Sec tion A.1.4, w hich states that th e BWR Vesse l ID Attachment Welds Program is an e xisting program tha t includes (a) inspectio n and flaw evaluati on in conformance with the guidelines of staff-approved boil ing water rea ctor vessel and intern als p roject B WRVIP-48 an d (b) mo nitori ng and contro l of rea ctor co olant wate r chemi stry in accordanc e with th e guideline s of BWRVIP-130.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.4, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.4.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).
97 3.0.3.2.5 BWR Feedwater Nozz le (OCGS AM P B.1.5)In the OCGS LRA , Appendix B, Section B.1.5, the appl icant stated th at OCGS AMP B.1.5,?BWR Feedwater Nozz le," is an existing pl ant program that is consistent w ith GALL AM P XI.M5,?BWR Feedwater Nozz le," with exceptio ns and enhan cements.3.0.3.2.5.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program provi des for monitoring of feedw ater nozzle s for cracking through statio n procedures b ased on the 1 995 Editio n through 1996 Addendum of ASM E Section XI, S ubsection IWB, Table IWB 2500-1. The program speci fies periodic ul trasonic (UT) in spections of cri tical regions of the feedwater no zzle. The inspection s are performed at inte rvals not exceedin g ten years.
3.0.3.2.5.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.5 is consi stent with GALL AMP XI.M5 , wi th an e xcep tion a nd an enhan cement.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.5, incl uding the OCGS program basis docume nt (PB D), PB D-AM P-B.1.05, ?BWR Feedwater Nozzl e," Rev. 0, 1 2/09/2005, w hich prov ides an ass essment of the AM P elements' co nsistency with GALL AMP XI.M 5. Specifical ly, the pro ject team revie wed the p rogram elements (see Section 3.0.2.1 of this audit and revie w report) con tained in OCGS AMP B
.1.5 and associ ated bases documents to determine the ir consisten cy wi th GALL AM P XI.M5.Also, the pr oject te am rev iew ed GE N E-523-A71-05 94-A, ?Alternate BW R Feedwater Nozzle Inspection Re quirement,"  Rev ision 1, A ugust 1999 and Letter P. F. M cKee (NRC) to J. J.Barton (GPU), ?Evaluati on of the Request for Re lief From NURE G-0619 for Oyster Cree k Nuclear Genera ting Station (TAC No. M85 751)" dated Octobe r 4, 1994.
In the PBD, t he app lica nt stat ed tha t OCGS r eplac ed the origi nal fee dwat er spa rgers i n 1977 to address indu stry-wide feedwater noz zle cracking i ssues in resp onse to NUR EG-0619. Each OCGS replacement f eedwater sparger incorpora ted a piston ring seal at the single nozzle thermal sleev e to safe end con nection, and included a flow baffle to b etter protect the l ow all oy steel noz zles. Al so, OCGS removed stainless steel cladd ing at the feedw ater nozz le areas and repai red al l crac ks found there. OCGS a lso ch anged t he feed wate r flow contro l sy stem to improve sy stem performance and red uce temperature fluctu ations at the nozzle bend areas durin g low pow er ope ration. OCGS did n ot rero ute the reacto r wat er cle anup s ystem. In accordance w ith NUREG-06 19, OCGS performed li quid penetrant e xamination (PT) of the originally cladded su rfaces to ensure tha t there were no cracks remaini ng in the noz zle area.The app lica nt wa s asked to di scuss the res ults o f the PT e xamin ation s perfor med in 1977. In its response, th e applica nt stated that the PT examinati on of the nozz le area duri ng the 1977 inspections detected 54 u nacceptable flaws distri buted among all four nozzl es. Follo wing clad removal of the nozzle inside su rface, the inspecti ons were re peated and rev ealed 12 s maller indication s in three of the nozzl es, as follow s:  45-degree noz zle - 5 indication s (0.5-1.5 inch es long), 135-degree no zzle - no indic ations, 225-de gree nozzl e - 4 indi cations (0.3 to 3 inches long) a nd 315-degree nozz le - 3 indi catio ns (0.2 5 to 1 inch long). These i ndica tions were 98 grounded out w ith pencil grinders and s urface polished. Subsequent ex aminations h ave not identified an y new indication s.The applican t also stated in its respo nse that OCGS con tinued to pe rform visual i nspections o f the feedwater sp arger during eve ry subsequent re fueling outage and found no sign of any degradation. During th e 1988-89 refueling outag e (12R), the applicant perf ormed ultrasonic examinations (UT) fr om outside of all nozzle safe ends, bores, and inside blend radii in accordance w ith NUREG-06 19, Section 4.3.2.3 (i.e., UT i nspection an d subsequent PT of recordable i ndications) and detected n o reportable indication s.After submitting the ab ove resul ts to the staff in 1992 (Appendix VIII UT qualificati on), the applicant s ubmitted a rel ief request to eli minate routine PT examinati on of the feedwate r and CRD return l ine nozz les, as committed to earlier in response to NUREG-0619, and utili ze the phased-array UT technique (most ad vanced metho d of UT at the time) a s the primary method to d ete ct, cha rac ter iz e, a nd mon ito r fl aw s i n th ese no zz le s. O n Oc tob er 4 , 19 94, the sta ff approved the applicant's request f or relief and since then the applicant has been perf orming UT examinatio n of these noz zles in lieu of the P T examinatio n recommended i n NUREG-0619
.The project team recogni zed that rel ief requests typi cally a pply onl y to the cu rrent inspecti on interval; therefore, they are not applica ble to the p eriod of exten ded operation and cannot b e credited for that pe riod. The appl icant was asked to confirm that the relief appro ved in 1 994 has no time l imit. In its respo nse, th e appl icant stated that th is pa rticul ar rel ief is from a commitme nt made to meet the re commend ation s of NUR EG-061 9 at th e time, and h as no time limit. M oreover, the applicant i s still co mmitted to perform PT ex amination, sho uld any indication s of cracking be found ba sed on the U T examinatio n, as required i n NUREG-0619
.Subse quent to the afo rementi oned r elie f request, the BWR Ow ner's Group (BWROG)submitted GE topi cal report GE-NE
-523-A71-0594 to the staff. This report sp ecifies a new advanced UT technique, and examinatio n of specific region s of the nozz le blend radius and bore. On June 1998, the staff approv ed this BWR feedwater noz zle ins pection report as an alternate to the recomm endations set forth in NUREG-0619, subject to the conditions listed in the SE R. On A ugust 19 99, the BWROG issue d Rev isio n 1 of GE topic al rep ort (GE-NE-523-A 71-059 4-A) afte r inco rporati ng all recomme ndati ons l isted in th e SER. Chap ter 4 of the GE report spec ifies ultrasoni c testing (UT) requiremen ts as the primary means of inspection.
OCGS has committed to implementi ng the UT methodolo gy recommended i n the GE report to ins pect the noz zle in future. This wi ll incl ude the standa rd performance demonstration i nitiativ e (PDI) UT methodol ogy that meets the requirements of Appe ndix VIII o f ASM E Sect ion XI. OCGS i s pla nning to enh ance i ts curr ent au gmented inspe ction program to meet this UT method ology and other conditi ons set forth by the staff SER prior to the period of extended o peration.The project team rev iewed th ose portions of the BWR Vessel ID Attachment Welds Program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 5 and found th at they are c o n s i s t e n t w i t h t h e G A L L R e p o r t A M P. T h e p r o j e c t t e a m fo u n d t h a t t h e a p p l i c a n t's B WR Vessel ID A ttachment Welds Program conforms to the recommen ded GALL AM P XI.M, wi th the excep tion and en hanc emen t des crib ed bel ow.
99 3.0.3.2.5.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria
: 7. Correctiv e Actions Exception: NUREG-1801 program XI.M5 references ASME Section XI, Table IW B 2500-1 (200 1 edition, includin g the 2002 and 2003 Addenda). Oy ster Creek ISI program i s based the 1 995 (includ ing 1996 Addend a) version of ASME S ection. For ju stification of exceptions to the ISI program se e the ASM E Section XI In service Inspection, Su bsections IWB, IWC, and IW D aging management program, B1.1.
The GALL Report i dentified the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"?acceptance cri teria," and
?corrective a ctions" program el ements associate d with th e excepti on taken: 1. Sco pe of P rogram:  The program includ es enhanced ISI to monitor the effects of crackin g on the inten ded fun ction of the c ompone nt, and syste ms modi ficatio ns to miti gate crac king.3. Para meters M onito red or Inspec ted:  The aging manag ement program (AMP)monitors the effects of cracking on the intende d function of the co mponent by d etection and sizi ng of cracks by ISI i n accordance with AS ME Secti on XI, Subsectio n IWB and the recommendation of GE NE-523-A71
-0594.4. Dete ction of Agi ng Effe cts:  The extent and schedule o f the inspection prescribed b y the program are desi gned to ensure tha t aging effects will be discov ered and repa ired befor e the los s of i nten ded funct ion of th e co mpon ent. Ins pect ion can rev eal crac king.GE NE-523-A71-0 594 specifies ultrasonic te sting (UT) of specific regi ons of the blen d radius and bore. The UT examination techniq ues and personnel qualifications are in accordance w ith the guidel ines of GE NE-52 3-A71-0594. B ased on the i nspection method and techn iques and pl ant-specific fracture mech anics assess ments, the ins pect ion sch edul e is in a ccor danc e w ith Tabl e 6-1 of GE NE-523-A71-059 4. L eaka ge monitoring may be used to modif y the inspection interval.
: 5. Mon itori ng and Trend ing:  Inspec tions sched uled in ac cordan ce wi th GE NE-523-A71-059 4 provide timely de tection of cracks.
: 6. Accep tance Criter ia:  Any cracking i s evalua ted in accord ance wi th IWB-3100 by comparing inspe ction results with the acceptance stan dards of IWB-3400 and IW B-3500.
100 7. Corr ective Actio ns:  Repair is performed in conformance with IWB-4000 and repla cement in ac cordan ce wi th IWB-7000.
As di scusse d in t he app endix to thi s repo rt, the staff finds the requirements of 10 CFR Pa rt 50, Appendi x B, accep table to add ress the correctiv e actions.
In re viewing this excep tion , the proj ect t eam r ecog nized that , in ac cord ance with no te 4 t o AMP XI.M5 in the GALL R eport, ?An applic ant may rely on a different v ersion of the AS ME Code , but should justi fy such use. A n applica nt may wi sh to refer to the S OC (statements of consideratio n) for an update o f 10 CFR § 50.5 5a to justify us e of a more recent e dition of the Code."The project team als o recognized that 10 CFR 50.55a is revised p eriodicall y to adopt, by reference, new e ditions and addenda of the ASME C ode. For each successiv e 120-month (10 year) insp ectio n inte rval , appl icant s are r equire d to re vise the nu clear plan t's IS I progra m to incorporate the requirements speci fied in the v ersion of the AS ME Code referenced in 1 0 CFR 50.55.a 12 months prior to th e start of the inspection inter val.In the OCGS LRA , the appli cant stated that a t present, the Oy ster Creek is commi tted to the 1995 versi on (includi ng 1996 addend a) of the ASM E Section XI C ode during its fourth ten-year inspection interval, which i s effective from October 15, 2002 through October 14, 2012, approved p er 10 CFR 5 0.55a. The nex t 120-month insp ection interv al wil l incorporate the requirements speci fied in the v ersion of the AS ME Code referenced in 1 0 CFR 50.55 a 12 months prior to the star t of the inspection interval.
Also, the pro ject team noted tha t the 1995 or later versi on of the ASM E Section XI C ode does not contain s ections IWB-4000 for repair and IWB-7000 for replacement, as stated in the GALL Report. Instead, repair and re placement are performed in conformance with IWA-4000, as discussed i n the OCGS basi s document. This is consisten t with the ASME Section XI Cod e used by OCGS at this time.
The current OCGS ISI p rogram is based o n the 1995 v ersion (incl uding 1996 ad denda) of the ASME S ection XI and th e program wil l be update d in accorda nce with 10 CFR 50.5 5a after each 10 y ear interva l to meet the GA LL-recommended Co de (2001 edi tion, inclu ding the 2002 and 2003 Addenda). On this basis, the proje ct team determined tha t this exception is acceptable.
3.0.3.2.5.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancement in order to mee t the GALL Report program e lements: Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g Enhan cement: The Oyster Creek Fe edwater No zzle a ging management program w i l l b e e n h a n c e d t o i m p l e m e n t t h e r e c o m m e n d a t i o n s o f t h e B WR Owners Group Licensing Topical Repor t General Electric (GE)
NE-523-A71-059
: 4. These enhan cements wil l be imple mented prior to enteri ng the period o f extended ope ration.
101 The GALL Report i dentified the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detection of aging effects," and
?monitoring and trending" program eleme nts associated with the enhancement taken:
: 1. Sco pe of P rogram:  The program includ es enhanced ISI to monitor the effects of crackin g on the inten ded fun ction of the c ompone nt, and syste ms modi ficatio ns to miti gate crac king.3. Para meters M onito red or Inspec ted:  The aging manag ement program (AMP)monitors the effects of cracking on the intende d function of the co mponent by d etection and sizi ng of cracks by ISI i n accordance with AS ME Secti on XI, Subsectio n IWB and the recommendation of GE NE-523-A71
-0594.4. Dete ction of Agi ng Effe cts:  The extent and schedule o f the inspection prescribed b y the program are desi gned to ensure tha t aging effects will be discov ered and repa ired befor e the los s of i nten ded funct ion of th e co mpon ent. Ins pect ion can rev eal crac king.GE NE-523-A71-0 594 specifies ultrasonic te sting (UT) of specific regi ons of the blen d radius and bore. The UT examination techniq ues and personnel qualifications are in accordance w ith the guidel ines of GE NE-52 3-A71-0594. B ased on the i nspection method and techn iques and pl ant-specific fracture mech anics assess ments, the ins pect ion sch edul e is in a ccor danc e w ith Tabl e 6-1 of GE NE-523-A71-059 4. L eaka ge monitoring may be used to modif y the inspection interval.
: 5. Mon itori ng and Trend ing:  Inspec tions sched uled in ac cordan ce wi th GE NE-523-A71-059 4 provide timely de tection of cracks.
In the OCGS LRA , the appli cant stated that OC GS is committed to implementing th e recommendations i n NE-523-A71
-0594, Revi sion 1, prio r to entering the period of exte nded operation. The applicant' s BWR Vessel ID Attachment Welds Program AMP wi ll be enh anced to include the recommendation s of the BWR owners group li censing topica l report General Electric (GE) N E-523-A71-0594 , Revisi on 1, whi ch include s UT examina tion of specific regions of the nozzl e blend rad ius and bo re region, UT methodo logy and p ersonnel qual ifications, and frac ture m echanic s metho dology.The project team rev iewed th e OCGS ISI Program Pl an, OC-1 and found that it has no t been updated in the section for the feedwater noz zle ins pections si nce the commitments were made in response to NUREG-0619. There fore, the applicant was asked to confirm that the UT exami natio n spec ified in the GE top ical report wil l be i nclud ed in this ISI pro gram pla n. In i ts response, the a pplicant sta ted that the OCGS ISI Program Plan, OC
-1, will be revis ed at the time this AM P is enhan ced, whic h will be prior to starting the ex tended period of operation.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed OCGS AMP B.1.5, ?BWR Feedwater Nozz le," wil l be consi stent with GALL AMP XI.M 5.3.0.3.2.5.5 Operating Expe rience In the OCGS LRA, the applicant state d that Oyster Creek inspect ed the feedwater nozzles in 1977 in resp onse to indu stry expe rience at that time. Cracks w ere found in the nozzl es and repaired. To mi nimize the rmal cycli ng and fatigue indu ced cracking the the rmal sleev e was modif ied with a pist on type des ign. Sub seque nt inspec tions, the most recent in 2000, ha ve 102 found no indi cation of cracking i n the feedwate r nozzl e. This prov ides evi dence that the thermal sleeve mod ification has been effective i n mitigating the e ffects of thermal fatigue on the feedwater noz zles.The pro ject tea m revi ewed past i nspect ion re sults of the fee dwat er noz zles since OCGS implemented NUREG-0619 recom mendations and found that the UT examination of the nozzle area reveal ed no new indicati ons. Also, th e applica nt has been ro utinely performing inspectio ns of the feedwater sp argers and no suc h degradation o f the replacement sp argers was note d.Although the ap plicant cl aims that the V T-3 visual inspection of the sparger flow h oles and welds i n the sparger tees and sparger arm are being performed at a frequency of at least once every fourth re fueling outage, as requi red in NUR EG-0619, the projec t team did not find any evidence of this finding. However, the applicant will enhance the BW R Vessel Internals Program (B.1.9) to in clude and document the con ditions of the feedwater noz zle, as w ell as the CRD return l ine nozz le thermal sl eeves.The project team rev iewed th e operating ex perience prov ided durin g the audit, and intervie wed the ap plic ant's t echni cal st aff to con firm that since the re commend ation s of NUR EG-061 9 we re implemented, i ncluding the installati on of replacement feedwater spargers, th is program has no t detected any cracks in the f eedwater nozzle regions at OCGS.
On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the ap plic ant's t echni cal st aff, the pr oject te am dete rmined that th e appl icant's  BWR Ves sel ID Attachment Welds Program  wil l adequately manage the aging effects that a re identified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.5.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the BWR Vessel ID Attachment Welds Program in OCGS LRA, Appen dix A, Sec tion A.1.5, w hich states that th e BWR Vesse l ID Attachment Welds Program aging management program i s an exi sting program that prov ides for monitoring of feedwate r nozzl es for cracking through stati on procedures based on the 1995 Edition thro ugh 1996 Adden dum of ASME Section XI, Sub section IWB, Table IWB 2500-1. The program specifies pe riodic ul trasonic (UT) in spections of cri tical regions of the feedwater nozzle. The inspecti ons are performed at intervals not exceedi ng ten years.
The Oyster Creek Ve ssel ID Attach ment Welds Program aging management program wi ll be enhanced to i mplement the reco mmendations of the B WR Owners Group Licensin g Topical Report General Electric (GE) N E-523-A71-0594. These enhance ments wil l be imple mented prior to enteri ng the period o f extended ope ration.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 5 o f the commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.5, and found that i t was consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.5.7 Conclusio n 103 On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects for whi ch it is cre dited. Als o, the project team has revie wed the enhancement and determined tha t the implementa tion of the enha ncement prior to the period o f exten ded op eratio n wo uld re sult i n the e xist ing AM P bei ng cons isten t wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and found that i t provides an adequate summary description of the program, as require d by 10 CFR 54.21 (d).3.0.3.2.6 BWR Control Rod Driv e Return Lin e Nozz le (OCGS AM P B.1.6)In the OCGS LRA , Appendix B, Section B.1.6, the appl icant stated th at OCGS AMP B.1.6,"BWR Control Rod Driv e Return Lin e Nozz le," is an existing pl ant program that is consistent with GALL AMP XI.M 6, "BWR Control Rod Driv e Return Lin e Nozz le," with exceptio ns.3.0.3.2.6.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program provi des for monitoring of the Control Rod Dr ive Ret urn L ine No zzle f or cr ack ing t hrou gh st atio n ISI proc edur es ba sed o n ASME Section XI, augmented by insp ections performed i n accordance with the inspection recomme ndati ons of N UREG-0 619, "B WR Feedwa ter Noz zle and Co ntrol Rod D rive Return Line Noz zle Crackin g."  Oyster Creek requested and receiv ed relief from the NR C for the recommendation of NUREG-0619 to perform ultrasonic examination testing in lieu of periodic dye penetra nt testing. The in spections w ill be p erformed at interva ls not ex ceeding ten y ears.3.0.3.2.6.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.6 is consi stent with GALL AMP XI.M 6, with e xceptions.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.6, incl uding the OCGS program basis docume nt, PB D-AM P-B.1.06, ?BWR CRD Return Line Nozzl e," Rev. 0, 1 2/08/2005, w hich prov ides an ass essment of the AM P elements' co nsistency with GALL AMP XI.M 6. Specifical ly, the pro ject team revie wed the p rogram elements (see Section 3.0.2.1 of this audit and revie w report) con tained in OCGS AMP B
.1.6 and associ ated bases documents to determine the ir consisten cy wi th GALL AM P XI.M6.The app lica nt wa s asked to di scuss the ac tivi ties p erformed at the curren t time i n resp onse t o NUREG-0619.
In its response , the appli cant stated that OC GS removed the original co ntrol rod drive return line (CR DRL) nozz le thermal sl eeve and performed a dye p enetrant exami nation (PT) on the inside diameter of the nozzle in 1977 (7R outage) to address industry-wide CRDRL nozzle cracking issues in response to NUREG-0619.
No indi cation of cracking w as observed at the time. The app licant al so stated that a fter finding no indi cations, the C RDRL noz zle thermal sleeve w as replaced with a n ewly designed thermal sleeve that directed th e flow farther in to the downcomer regi on and aw ay from the noz zle area.
The new the rmal sleev e is a one inch schedule 40 pipe that i s attached to th e remaining po rtion of the remov ed thermal sl eeve by an interfe rence fit. The one i nch pi pe in crease s fluid vel ocity to min imiz e the p ossib ilit y of re entry 104 of hot reactor recirc ulation flow back into the thermal sleev e, which carries cold CRD wa ter at 100/F The project team noted that the applicant continued to perf orm visual inspections of the CRDRL nozzle during every subsequent refueli ng outage and found n o sign of degradation. During the 1991 refueling ou tage (13R), the app licant performed u ltrasonic ex aminations (U T) from outside of the nozzl e in accorda nce with NUREG-0619, S ection 4.3.2.3 (i.e., UT inspec tion and subsequent PT of recorda ble indi cations) and detected no rep ortable ind ications.The project team reviewed those portions of the BW R Control Rod Drive Return Line Nozzle Program for which the applica nt claims con sistency w ith GALL AM P XI.M6 and found that they a r e c o n s i s t e n t w i t h t h e G A L L R e p o r t A M P. T h e p r o j e c t t e a m fo u n d t h a t t h e a p p l i c a n t's B WR Control Rod Drive Re turn Line No zzle P rogram conforms to the recommend ations in GALL AMP XI.M6, wi th th e exce ptio ns de scri bed be low.3.0.3.2.6.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements: Exception 1 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria
: 7. Correctiv e Actions Exception: NUREG-1801 program XI.M6 references ASME Section XI, Table IW B 2500-1 (200 1 edition, includin g the 2002 and 2003 Addenda). Oys ter Creek ISI program is based the 19 95 (includi ng 1996 Addend a) version of ASME S ection XI. For ju stification of exceptions to the ISI program se e the ASM E Section XI In service Inspection, Su bsections IWB, IWC, and IW D aging management program, B1.1.
The GALL Report i dentified the foll owing recommend ations for the
?parameters Mo nitored or Inspec ted," ?detect ion o f aging effec ts," ?monito ring an d trend ing," ?acceptance cri teria," and
?corrective a ctions" program el ements associate d with th e excepti on taken: 3. Para meters M onito red/ In specte d:  The agin g manageme nt progr am (AM P) moni tors the effects of cracking on the i ntended function of the CRDRL n ozzles by detecti ng and sizing cracks b y ISI in a ccordance w ith Table IWB 2500-1 and N UREG-0619.
: 4. Dete ction of Agi ng Effe cts:  The extent and schedule of inspection, as delineated in NUREG-0619, as sures detection of cracks before the los s of intended functi on of the CRDRL noz zles. Inspe ction recommendati ons includ e liquid p enetrant testing (PT) o f CRDR L noz zle blend radiu s and bore re gions a nd the reacto r ves sel w all a rea be neath the nozz le, return-flow-capacity d emonstration, CR D-system-performance tes ting, and ultras onic inspe ction of wel ded co nnecti ons i n the r eroute d lin e. The inspe ction is to 105 include base metal to a distance of one-pipe-wall thickness or 0.5 in., whichever is greater, on both si des of the we ld.5. Mon itori ng and Trend ing:  The inspection schedule of NUREG-0619 provides timely detection of cracks.
: 6. Accep tance Criter ia:  Any cracking i s evalua ted in accord ance wi th IWB-3100 by comparing inspe ction results with the acceptance stan dards of IWB-3400 and IWB-350 0. A ll c racks foun d in the CRD RL n ozz les are to be remo ved by grin din g.7. Corr ective Actio ns:  Repair is performed in conformance with IWB-4000 and repla cement in ac cordan ce wi th IWB-7000.
As di scusse d in t he app endix to thi s repo rt, the staff finds the requirements of 10 CFR Pa rt 50, Appendi x B, accep table to add ress the correctiv e actions.
In acco rdance wit h GALL note 5 to thi s AM P, ?An applic ant may rely on a different v ersion of the AS ME C ode, b ut sho uld ju stify s uch us e. An appli cant ma y w ish to refer to the SO C (statements of conside ration) for an upd ate of 10 CFR § 50.55a to justi fy use of a more rece nt editi on of th e Code."The project team noted that 10 CFR 50.55a is revised p eriodicall y to adopt, by reference, ne w editions an d addenda o f the ASME Code. For ea ch successiv e 120-month (10 year) insp ection interval, applicants are required to re vise the nuclear pla nt's ISI program to i ncorporate the requirements speci fied in the v ersion of the AS ME Code incorporated into 10 CFR 50.55a 12 months before t he start of the inspect ion interval.
At present, the a pplicant i s committed to the 1995 versi on (includi ng 1996 addend a) of the ASME S ection XI Code during its fourth ten-year insp ection interv al effective from October 1 5, 2002 through October 14, 2012, appro ved per 10 CFR50.55a. The next 120-mon th inspectio n interval will incorporate the requirements speci fied in the v ersion of the AS ME Code incorporated into 10 CFR 50.55a 12 months bef ore the start of th e inspection interval.
Also, the pro ject team noted tha t the 1995 or later versi on of the ASM E Section XI d oes not contain secti ons IWB-4000 for repair and IWB-7000 for replacemen t, as stated in the GALL.
Instead, repair and replacem ent are perform ed in conformance with IW A-4000, as discussed in the OCGS basi s docu ment. Th is is consi stent w ith th e ASM E Sect ion XI Code u sed by OCGS at this time.
The current OCGS ISI p rogram is based o n the 1995 v ersion (incl uding 1996 ad denda) of ASME S ection XI and th e program wil l be update d in accorda nce with 10 CFR 50.5 5a after each 10 y ear interva l to meet the GA LL-recommended Co de (2001 edi tion, inclu ding the 2002 and 2003 Addenda). On this basis, the proje ct team determined tha t this exception is acceptable.
Exception 2 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g
106 Exception: The Oyster Creek au gmented ISI program for the CR D return lin e nozzle perf orms ult rasonic examinat ion (UT) testing in lieu of dye penetrant testin g (PT). Oyster Creek requeste d and receiv ed relief from the NRC to perform ultrasoni c examinati on (UT) testing in lieu of the periodic PT testing [re commendations] specif ied in NUREG 0619.
The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detection of aging effects," and
?monito ring an d trend ing" pr ogram el ements associated w ith the ex ception taken:
: 3. Para meters M onito red or Inspec ted:  The aging manag ement program (AMP)monitors the effects of cracking on the intende d function of the CR DRL nozz les by detecting and si zing cracks by ISI in accord ance wi th Table IWB 2500-1 and NUREG-0619.
: 4. Dete ction of Agi ng Effe cts:  The extent and schedule of inspection, as delineated in NUREG-0619, as sures detection of cracks before the los s of intended functi on of the CRDRL noz zles. Insp ection recommenda tions incl ude liquid penetrant testin g (PT) of CRDR L noz zle blend radiu s and bore re gions a nd the reacto r ves sel w all a rea be neath the nozz le, return-flow-capacity d emonstration, CR D-system-performance tes ting, and ultras onic inspe ction of wel ded co nnecti ons i n the r eroute d lin e. The inspe ction is to include base metal to a distance of one-pipe-wall thickness or 0.5 in., whichever is greater, on both si des of the we ld.5. Mon itori ng and Trend ing:  The inspection schedule of NUREG-0619 provides timely detection of cracks.
As discussed in Sectio n 3.0.3.2.5.2 of this audit and review report, in 19 92 the appl icant submit ted a r elie f request to eli minate routi ne PT e xamin ation of the fee dwat er and CRD r eturn line noz zles, as c ommitted to earli er in respons e to NUREG-06 19, and util ize the p hased-array UT tech nique (most ad vanc ed meth od of UT at the time) a s the p rimary method to det ect, characterize and monitor flaw s in these n ozzles. On October 4, 19 94, the staff approve d the applicant' s request for relief and since then the applica nt has been p erforming UT examinati on of these nozz les in l ieu of the PT ex amination rec ommended in N UREG-0619.
The project team recogni zed that rel ief requests typi cally a pply onl y to the cu rrent inspecti on interval; therefore, they are not applica ble to the p eriod of exten ded operation and cannot b e credited for that pe riod. The appl icant was asked to confirm that the relief appro ved in 1 994 has no time l imit. In its respo nse, th e appl icant stated that th is pa rticul ar rel ief is from a commitme nt made to meet the NU REG-06 19 at t he time and h as no time l imit. More over, periodic C RDRL noz zle ins pections are performed using quali fied UT techniques at least once every 10-y ear pe riod (120 mon ths). Th e ins pecti on in terva l is based on fati gue crac k growth analy ses pe rformed i n acco rdance wit h the me thodol ogy i n Sect ion XI of the A SME Code. Should UT ex amination res ults indi cate the presen ce of a flaw ex ceeding the AS ME Code allowa ble crack siz e, OCGS is committe d to perform a PT ins pection in the vici nity of the indication to verify the results. Qua lification te sting by the inspection vendor has demonstrated that th e UT tec hnique can re liab ly d etect a nd si ze fla ws i n the a reas o f intere st. M odific ation to the CRDRL nozzle thermal sleeve has played a major role in the prevention of CRDRL nozzle cracks.
107 The project team noted that the CRD RL nozz le is in cluded in the Oyster Cre ek ISI program plan under Categor y B-D , ?Full Pene tration Welds of Nozzl es in Vesse ls," consisten t with the require ments o f Table I WB 2500-1. A ugmented insp ectio ns are performe d in a ccorda nce w ith NURE G-0619, ?BWR Feedwater Nozz le and Con trol Rod Dri ve Return L ine Noz zle"recommendations.
The project team rev iewed th e OCGS ISI Program Pl an, OC-1, and found that it has no t been updated in the section for the CRDRL nozzle inspections since the comm itments were made in response to NU REG-0619. The ap plicant w as asked to confirm tha t the UT exami nation technique included in the relief req uest, or the most advanced techniq ue (Appendix VIII UT qualification), w ill be i ncluded i n the OCGS ISI pro gram plan. In i ts response, the applicant stated that the OCG S ISI Program Plan, OC-1, will be revised to reflect the CRDRL nozzle inspections prior to ente ring the exten ded period of operation.
The project team determi ned that the cu rrent OCGS ISI program i ncludes the recommendations gi ven in N UREG-0619, and is consis tent with the GALL-recommended guidelines.
On this basi s, the project team d etermined that thi s exceptio n is accepta ble.Exception 3 Elements: 6. Acceptance Criteria
: 7. Correctiv e Actions Exception: NURE G-1801, XI.M6 , speci fies an y det ected crack be ground out. Oyster Creek procedur es allow a crack that is found unacceptable under IWB-3400 and IWB-3500 to be ev aluat ed und er ASM E XI, IW B-3600 or repa ired by a n NRC appro ved procedu re.The GALL Report i dentified the foll owing recommend ations for the
?acceptance cri teria" and
?corrective a ctions" program el ements associate d with th e excepti on taken: 6. Acc eptanc e Crit eria:  Any cracking i s evalua ted in accord ance wi th IWB-3100 by comparing inspe ction results with the acceptance stan dards of IWB-3400 and IWB-350 0. A ll c racks foun d in the CRD RL n ozz les are to be remo ved by grin din g.7. Corr ective Actio ns:  Repair is performed in conformance with IWB-4000 and repla cement in ac cordan ce wi th IWB-7000.
As di scusse d in t he app endix to thi s repo rt, the staff finds the requirements of 10 CFR Pa rt 50, Appendi x B, accep table to add ress the correctiv e actions.
The applican t was asked to clarify the OCGS position stated in thi s exceptio
: n. The appli cant responded that all indi cations and relevant co nditions de tected during pas t examinati ons at OCGS were ev aluated in accordance w ith ASM E Section XI S ubsection IWB-3100, for Class 1 components, usi ng the criteria of IW B-3512. When a flaw ex ceeded the ap plicable acceptance standa rds of IWB-340 0 or IWB-3500 ,a pla nt con ditio n repo rt wa s ini tiated in ac cordan ce wi th applicabl e procedures.
An analy tical ev aluation w as performed in ac cordance w ith IWB-3600 or an a pprov ed rep air w as per formed i n acco rdance wit h pla nt proc edure ER-AA-330-0 02. In either case, N RC's approv al was required prior to resumption of ope ration.The applican t also stated that NUREG-0619 recommends any cracks found during the initial NUREG-0619 i nspection be grounded out, un less clad removal is performed. How ever, the 108 NURE G does not pro vide guida nce i f flaws are fou nd in the su bsequen t insp ectio ns. OC GS inspections during 1977 a nd subsequent i nspections h ave not found any flaw indication s in the CRDRL nozzle. The applicant has been following the OCGS ISI guidelines fo r this nozzle inspection as stated abov
: e. According to these guidel ines, repairs are performed if the flaw does not meet the requirements of IWB-3600, in wh ich case crac k repairs may u se the grind out option.
The project team noted that the 1995 or later version of the ASME Section XI does not contain sections IWB-4000 for repair and IWB-7000 for replacement as stated in the GALL.
Instead, repair and re placement are performed in accorda nce with IW A-4000, as di scussed in the OCGS program basis document for this AMP.
On this basis , the project team d etermined that thi s exceptio n is accepta ble.3.0.3.2.6.4 Enhan cements None.3.0.3.2.6.5 Operating Expe rience In the OCGS LRA, the applicant state d that Oyster Creek inspect ed the CRD nozzle in 1977 in respon se to indu stry exper ience at t hat tim e. No crac ks were f ound in the nozzle. To m inimize thermal cycl ing and fatigue in duced cracking, the thermal sleev e was modi fied to dive rt the relatively cold CRD flow away from the nozzle. The most rec ent inspection of the nozzle in 2002 confirms the lack of cracking in the nozzl e area. This p rovides good evidenc e that the thermal sleev e modification has been effectiv e in mitigati ng the effects of thermal fatigue on the CRD nozz le.The pro ject tea m revi ewed past i nspect ion re sults of the C RD ret urn li ne noz zle since OCGS implemented NUREG-0619 recom mendations and found that the UT examination of the nozzle area reveal ed no new indicati ons. Also, th e applica nt has been ro utinely performing visual inspections of the nozz le thermal sl eeve area and no such degradation of the re placement thermal sleev e was no ted.The project team rev iewed th e operating ex perience prov ided durin g the audit, and intervie wed the ap plic ant's t echni cal st aff to con firm that since the re commend ation s of NUR EG-061 9 we re implemented, i ncluding the installati on of replacement nozzle thermal slee ve, this p rogram has not detected any cracks in the CRDRL nozzle regions at OCGS.
On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's BWR Control Rod D rive Return Line Nozz le Pro gram wi ll ad equatel y mana ge the a ging effect s that are identified i n the OCGS LRA for which th is AMP is credited
.3.0.3.2.6.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the BWR Control Rod Driv e Return Lin e Nozzl e Program in OCGS L RA, Appendi x A, Secti on A.1.6 w hich states tha t the BWR control rod drive return line nozzle aging management program is an exis ting program that prov ides for monitoring of the con trol rod driv e return lin e nozzl e for cracking through statio n procedures based on AS ME Secti on XI, Subsectio n IWB, Table IW B 2500-1, augmented by insp ections 109 p e r fo r m e d i n a c c o r d a n c e w i t h t h e i n s p e c t i o n r e c o m m e n d a t i o n s o f N U R E G-0 6 1 9 , " B WR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking."  Based on an NRC approved re lief request, the pe riodic dy e penetrant tests required by N UREG-0619 hav e been replaced by ultrasonic measurements. The i nspections w ill be p erformed at interva ls not exceeding ten years. Modifications were made to the control rod drive retur n line nozzle ther mal sle eve to mi tiga te or prev ent t herm all y i nduc ed fa tigu e cra ckin g.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.6, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.6.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and their associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.7 BWR Stress Corrosion Crackin g (OCGS AMP B
.1.7)In the OCGS LRA , Appendix B, Section B.1.7, the appl icant stated th at OCGS AMP B.1.7,"BWR Stress Corrosion Crackin g," is an exi sting plant pro gram that is consi stent with GALL AMP XI.M 7, "BWR Stress Corrosion Cra cking," with on e excepti on.3.0.3.2.7.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program mitigates IGS CC in stai nless steel reactor coolan t pressure boun dary pipi ng components and piping four inch es and greater nominal pi pe size exposed to reactor coolan t above 20 0°F. Preve ntive measu res include monitoring and c ontrolling of w ater impuritie s by w ater chemistry activiti es and prov iding replacement stai nless steel components in the solutio n annealed condition with a max imum carbon content of 0.035 wt. % an d a minimum ferrite level o f 7.5 wt. %. Inspe ction and flaw evaluati on are conduc ted in accord ance wi th the inserv ice inspec tion program plan for the station.The applican t also stated that the program is implemented thro ugh station proce dures based o n N U R E G- 0 3 1 3 , " Te c h n i c a l R e p o r t o n M a t e r i a l S e l e c t i o n a n d P r o c e s s i n g G u i d e l i n e s fo r B WR Coolant Pres sure Boundary Piping Rev. 2," GL 88-01, "NR C Position on Intergranular Stress Corrosion Cra cking (IGSCC) in B WR Austenitic Stainle ss Steel Pi ping," and its Supplement 1, BWRVIP-75, "Technical Basi s for Revisi ons to GL 88-01 Inspection Sc hedules," BWRVIP-130,?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Gu idel ines," and A SME Secti on XI.3.0.3.2.7.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.7 is consi stent with GALL AMP XI.M 7, with o ne excepti on.
110 The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.7, incl uding the OCGS program basis docume nt, PB D-AM P-B.1.07, ?BWR Stress Corrosion Cracking," Rev. 0 , 12/19/2005, w hich prov ides an ass essment of the AM P elements' consistency with GALL AMP XI.M 7. Specifical ly, the pro ject team revie wed the p rogram elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report) conta ined in OCGS AMP B.1.7 and associa ted bases doc uments to determine their consi stency w ith GALL AM P XI.M7.The applican t was asked to provide details of al l weld repairs and material repl acement of components that o ccurred in ord er to implement the NUREG-0313 and GL 88-01 recommendations.
The applicant responded that the f ollowing piping was replaced with IGSCC resistant materia l (low carbon stainl ess steel):  a) all iso lation cond enser large bore piping outside the d rywell (from the drywe ll penetrati ons to the is olation con densers), incl uding new stress-improved welds; b) all pi ping withi n the four isol ation conden ser dryw ell penetra tions and the two RWCU system dry well p enetrations, w hich contai n welds that are not i nspectable; c) the isolati on condenser piping at the isolation condensers on 95 feet eleva tion; d) the he ad cooli ng spray nozz le as sembly; and e) the 4 inch tee an d flange of the r eactor vent line. Addit ional ly, a ll ac cessi ble/ i nspect able wel ds in side the dry wel l (ex cept R WCU system) were stress improve d.The applicant also stated that, of the 380 welds in the scope of GL 88-01, which includes 85 in the RWCU system outside the second co ntainment isol ation val ves, 40 w elds we re identified with IGSCC indications. Following numerous piping replacements , 11 welds remained in service with indications of IGSCC. Nine welds were repaired with full structural overlays (4 in core spray, 4 in recircul ation and 1 in shutdow n cooling sy stems). The remaini ng two we lds were in service w ithout repair in the recirc ulation sy stem, howev er, they w ere both stress improved be fore inspections found IGSCC. After the implementatio n of the NRC-app roved Performance Demonstration Initiative (PDI) inspect ions in 2002 and 2004 using the new UT technique, it w as determined that there we re no indi cations of IGSCC in either o f the recirculatio n system w elds.The project team rev iewed th e OCGS program plan (OC-2:  Program Pla n - IGSCC Insp ection Program, Rev. 0, 0 7/31/2003) for impl ementing the GL 88-0 1 and BWRVIP-75 recommendations.
The program plan di d not reference BWRVIP-14, 59, or 60 for guidance on the evalu ation of crack growth in stainl ess steel, ni ckel alloy s, and low alloy steel componen ts, respectivel
: y. In respon se to a prev ious audi t question, the ap plicant con firmed that these documents are i n use at the OC GS IGSCC program. Thus, th e applica nt has fully implemented the NR C progra ms and has be en in specti ng the r elev ant pi ping i n acco rdance wit h NRC-approv ed BWRVIP-75 since the B WR SCC program was first impl emented.With regards t o the p rogram el ement for ?corrective a ctions," the GALL Report stated th at the guidan ce for w eld o verl ay re pair a nd stre ss imp rovem ent or repla cement is pro vide d in N RC GL 88-01; ASM E Section XI, S ubsections IWB-4000 and IWB-7000, IWC-4000 and IWC-7000, or IW D-4000 and IWD-7000, respecti vely, for C lass 1, 2, or 3 components; an d ASME Code Case N-504-1. These A SME Sec tion XI subsecti ons in earl ier editio ns (1986 edi tion) have been replaced by subsections IW A-4000 in the later editions of the ASME Code. The OCGS ISI program currently performs its correctiv e action requi rements in acco rdance wi th IWA-4000 of the 19 95 edi tion o f the Co de. The projec t team fou nd thi s acce ptabl e sin ce it is con sisten t wi th the v ersi on o f the ASM E Se ctio n XI C ode curr entl y ap pli cabl e to Oys ter C reek.
111 The project team rev iewed th ose portions of the BWR stress corrosion crackin g program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 7 and found th at they are consistent w ith the GALL R eport AMP. The project team found that the appl icant's BWR stress corrosion crackin g program conforms to the recommend ed GALL AM P XI.M7, w ith the excep tion and th e enha ncem ent d escr ibed b elow.3.0.3.2.7.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elemen t: Eleme nt: 2. Preventi ve Action s Exception: NUREG-1801 indicates that water chemist ry control is in accordance w ith BWRVIP-29 for water chemi stry in BWRs.
BWRVIP-29 references the 1996 re vision of EPRI TR- 103515
,"BWR W ater Chemistry Guideline s."  The Oyster Cre ek Water Chemi stry P rogram i s base d on B WRVIP-130, ?BWR Vessel and Internals Project BWR W ater Chemistry Guideline s - 2004 Revi sion."  For j ustific ation of exc eptio ns, see Water Chemi stry Program, B.1.2.
The GALL Report i dentifies the foll owing recommend ations for the
?preventiv e actions" pro gram element associ ated with the excep tion taken:
: 2. Preventive Action:  The comprehensive progr am outlined in NUREG-0313 and NRC GL 88-01 address es improvemen ts in all three elements that, in combin ation, cause IGSCC. These ele ments consist of a susceptible (sensitiz ed) material, a significant tensile stress, and an agg ressive environment. Sensitization of nonstabilized austenitic SSs contain ing greater than 0.03 wt.% carbon involv es precipita tion of chromium carbides at th e grain bounda ries during ce rtain fabrication or weld ing processes.
The formation of carbides creates an envelope of chromium depleted region that, in certain environments , is suscepti ble to SCC. Residual tensile stre sses are intro duced from fabrication proce sses, such as weldin g, surface grinding, or forming. H igh level s of disso lved oxy gen or a ggressiv e cont aminan ts, suc h as su lfates o r chlo rides , accel erate the SCC proc esses.The program deline ated in NU REG-0313, NRC GL 88-01, and in the staff-approve d BWRVIP-75 re port i nclud es reco mmendat ions regardi ng sele ction of materi als th at are resistant to sen sitizati on, use of speci al processes that reduce resi dual tensil e stresses, and monitorin g and maintenanc e of coolant che mistry. The resi stant materials are used for new and replacement compone nts and include low-carbon grades of aust enitic SS and w eld me tal, w ith a maxim um carb on con tent of 0.035 w t.% and a mini mum ferri te content of 7.5% in weld metal and cast auste nitic stainless steel (CASS). Inconel 82 is the only commonly used nickel-base weld metal considered to be resistant to SCC;other nickel-al loys, such as Alloy 600 are ev aluated on an indiv idual bas is. Speci al processes are u sed for existi ng, indivi dual basi s. Special processes are u sed for existing, ne w, and rep lacement compone nts. These proces ses includ e solution heat treatme nt, hea t sink w eldi ng, ind uctio n heat ing, an d mecha nical stress impro vemen t.
112 The program delineated in NUREG-0313 and NRC GL 88-01 does not provide specific guid eli nes for co ntro lli ng re acto r wa ter c hemi stry to mi tiga te IG SCC. M ain tain ing h igh water puri ty reduces s usceptibil ity to SC C or IGSCC. The program description , and eval uatio n and techni cal b asis o f monito ring an d main taini ng react or wa ter che mistry are addressed throu gh implementatio n of Section XI.M 2.In Atta chment 1, Item B.1.7 of its recon ciliation documen t, the a pplicant stated that th e above exception for OCGS AMP B
.1.7 is no l onger required and will be withd rawn. The ap plicant w as asked to clarify the reason for w ithdrawi ng this exce ption. In i ts response, the applicant s tated that AMP XI.M7 in the September 2005 GALL Report, to which OCGS AMP B.1.7 was compared, no l onger makes reference to BWRVIP-29; therefore, thi s exceptio n no longer applies to OCGS AMP B
.1.7.The project team v erified that the reactor coolan t water chemi stry at OCGS i s monitored an d mainta ined in ac cordan ce wi th the guidel ines in BWRVIP-1 30, ?BW R Vessel and Internals Projec t BWR Water Chemis try Gui deli nes" to mainta in hi gh wat er puri ty to reduce susce ptibi lity to SCC or IG SCC. The pr ojec t tea m rev iewed t he OC GS W ater Chem istr y Prog ram (AMP B.1.2) and conc luded that the use of BWRVIP-130 is accep table. The proje ct team's eva luation of OCGS AMP B.1.2 is discussed in Section 3.0.3.2.
2 of this audit and review report. On this basis , the p roject t eam det ermine d that the ab ove e xcep tion i s not r equire d, and concu rred w ith the applica nts decisio n to with draw the e xception.3.0.3.2.7.4 Enhan cements In the OCGS LR A, the appli cant st ated th at ther e are n o enha ncemen ts for thi s AM P. Howeve r, in the program ba sis document, P BD-AMP B.1.07, the appl icant identi fied the following e nhancement in order to meet the GALL Report program e lements, whi ch is not included in the OCGS LRA:
Eleme nt: 2. Preventi ve Action s Enhan cement: The program wil l be enhan ced to require th at, for those components w ithin the sc ope of the BWR Stress Corrosio n Cracking aging management pro gram, all new and replace ment SS materials be low-ca rbon grades of SS w ith carbon co ntent limited to 0
.035 wt. % max imum and ferrite con tent limited to 7.5%minimu m.The GALL Report i dentifies the foll owing recommend ations for the
?preventiv e actions" pro gram element associ ated with the enhancemen t taken: 2. Preventive Action:  The comprehensive progr am outlined in NUREG-0313 and NRC GL 88-01 address es improvemen ts in all three elements that, in combin ation, cause IGSCC. These ele ments consist of a susceptible (sensitiz ed) material, a significant tensile stress, and an agg ressive environment. Sensitization of nonstabilized austenitic SSs contain ing greater than 0.03 wt.% carbon involv es precipita tion of chromium carbides at th e grain bounda ries during ce rtain fabrication or weld ing processes.
The formation of carbides creates an envelope of chromium depleted region that, in certain environments , is suscepti ble to SCC. Residual tensile stre sses are intro duced from fabrication proce sses, such as weldin g, surface grinding, or forming. H igh level s of 113 disso lved oxy gen or a ggressiv e cont aminan ts, suc h as su lfates o r chlo rides , accel erate the SCC proc esses.The program deline ated in NU REG-0313, NRC GL 88-01, and in the staff-approve d BWRVIP-75 re port i nclud es reco mmendat ions regardi ng sele ction of materi als th at are resistant to sen sitizati on, use of speci al processes that reduce resi dual tensil e stresses, and monitorin g and maintenanc e of coolant che mistry. The resi stant materials are used for new and replacement compone nts and include low-carbon grades of aust enitic SS and weld metal, with a maximum carbon of 0.035 wt.% and a minimum f errite of 7.5% in weld metal and cast austenitic stainless steel (CASS). Inconel 82 is the only commonly used nickel-ba se weld metal consid ered to be resi stant to SCC; o ther nickel-all oys, such as Alloy 600 are ev aluated on an indiv idual bas is. Speci al processes are used for existing, i ndividu al basis.
Special p rocesses are us ed for existi ng, new, and replacement compo nents. These proc esses incl ude solutio n heat treatment, he at sink wel ding, i nducti on hea ting, a nd mech anica l stre ss imp rovem ent.The program delineated in NUREG-0313 and NRC GL 88-01 does not provide specific guid eli nes for co ntro lli ng re acto r wa ter c hemi stry to mi tiga te IG SCC. M ain tain ing h igh water puri ty reduces s usceptibil ity to SC C or IGSCC. The program description , and eval uatio n and techni cal b asis o f monito ring an d main taini ng react or wa ter che mistry are addressed throu gh implementatio n of Section XI.M 2.The applican t was asked to confirm that AM P B.1.7 in the OCGS LRA w ill be re vised to include this e nhanc ement.In its lette r dated April 17, 20 06 (M L0611 50320), the a ppli cant co mmitted to rev ise A MP B.1.7 in the OCGS L RA to incl ude th e enha ncemen t iden tified in th e progra m basi s docu ment, PBD-AMP-B.1.07, whi ch states that for thos e components w ithin the sc ope of the BWR stress corrosion crackin g aging management program, all new and replacement S S materials w ill be low-carbo n grade s of SS with carbo n cont ent li mited t o 0.03 5 wt. % maxi mum and ferrite conten t limi ted to 7.5% mi nimum. This is A udit Commitment 3.0.3.2.7
-1.In rev iew ing thi s enha ncemen t, the p roject t eam not ed tha t the c arbon conten t and fe rrite content screeni ng criteria, as s tated in GL 88
-01, are appl icable to both new and replaceme nt components w hile procuri ng and instal ling them duri ng the life of a pl ant. Therefore, these criter ia sh ould alrea dy ha ve be en imp lement ed at Oy ster Cr eek. The appl icant was asked to explain the reasons for thi s enhancement to an exis ting program, whi ch should h ave incl uded this screeni ng criteria as part of the current l icensing basi
: s. In its resp onse, the appl icant stated that all rep lacements of pip ing components v ulnerable to IGSCC durin g refueling outage 13R were performed i n accordance with GL 88
-01. Howe ver, the curren t documentation does not incl ude th e GL 88-01 co mmitment s in t he OCGS BWR stress c orrosi on cra cking pr ogram;therefore, this enha ncement to the pro gram is necessary to update the plant documenta tion so that i t wi ll mee t the re commend ation s in t he Sep tember 2005 GA LL Rep ort.On this basis , the project team found the enhancemen t to be accepta ble since when the enhan cement is imp lement ed, OCGS AMP B.1.7, ?BWR Stress Corrosion Crackin g," will b e consistent w ith GALL AM P XI.M7.
114 3.0.3.2.7.5 Operating Expe rience In the OCGS LRA , the appli cant stated that, o f the welds included in the scope of GL 88-01, Oyster Creek had 11 welds in service with indications of IGSCC. Nine were repaired with full str uctu ral ov erla ys (f our in core spra y, fo ur in r ecir cula tion and on e in sh utdo wn cool ing). Two were in service w ithout repair in the recirc ulation sy stem since they were both stress improv ed befor e the insp ections found I GSCC. Bot h of the se welds in th e recirc ulation s ystem ha ve recently be en re-examin ed using the U T method and no IGSCC was identified. N o new indication s of IGSCC have been detected by insp ection durin g the last six (6) outages.
The applicant also stated that Oyst er Creek replaced the f ollowing piping material with IGSCC resistant materia l:  1) all isolatio n condenser l arge bore pipi ng outside the drywel l (from the drywell penetrations to the isolation condensers),including all new stress-improved welds; 2) all piping within the four (4) isolation condenser drywell penetrations and the t wo (2) RWCU system dryw ell penetra tions, whi ch contain w elds that are not inspectab le; and 3) th e head cooling spray nozzle assembly 4 inch tee and flange of the reacto r vent line. Additionally, all accessible/i nspectable w elds insi de the dryw ell (exc ept RWCU system) were s tress improved
.Furthermore, as a re sult of the improv ed quality of water chemis try due to th e implementati on of HWC and NW CA, reduction s in inspe ction frequency, w hich are permi ssible per BWRVIP-75, wer e im ple ment ed a t Oy ster Cre ek.The applican t further stated that BWR stress corrosi on cracking aging management program activiti es have d etected flaw indication s in reactor c oolant pressu re boundary piping prio r to loss of intended functio ns of the components. These indi cations w ere evalu ated and w ere repaired, as necessary , in accordan ce with ASME S ection XI. As a result, Oyster Creek has no indication s of IGSCC at this time.The project team rev iewed th e operating ex perience in formation given i n the PBD a nd found that, since GL 8 8-01 was i ssued, Oyster C reek has been pe rforming ISI examinati ons on pip ing subject to the gene ric letter reco mmendations. Du ring this peri od, Oyster Cree k has implemented hydrogen water chemist ry (HW C) and performed st ress improvements as IGSCC mitigators. In add ition, ex amination pro cedures hav e been improv ed and ex amination personnel ha ve receiv ed training on the latest tec hniques for IGSCC d etection. Oy ster Creek personnel ha ve gained years of exp erience in the detection and sizi ng of IGSCC. No new indication s of IGSCC have been detected by insp ection durin g the last six (6) outages.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions with the applicant's technical s taff, the project team determine d that the appl icant's BWR stress corrosion crackin g program will adequately manage the aging effects that are identified i n the OCGS LRA for wh ich this A MP is credited.3.0.3.2.7.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the BWR stress corrosion cracking pro gram in OCGS LRA, Appendix A, Section A.1.7 whi ch states that the BWR stress corrosion cracking aging management program is an existi ng program based on N UREG-0313, and Nuclear 115 Regulatory C ommission GL 88
-01and its S upplement 1; N UREG-0313, "Techni cal Report o n Mate rial Selec tion a nd Pro cessi ng Guid elin es for B WR Coolant Press ure Bo undary Pipi ng;" GL 88-01, "NRC Position on Intergr anular Stress Corrosion Crack ing (IGSCC) in BW R Austenitic Stain less S teel P ipin g," and its Su ppleme nt 1; B WRVIP-75, "Te chnic al Ba sis for Revi sions to GL 88-01 Inspecti on Schedul es;" and ASM E Section XI.
The scope of the BWR stress corros ion c racking aging ma nagemen t progra m incl udes r eactor cool ant pre ssure b ounda ry components and piping four inch es and larger n ominal pip e size mad e of stainless steel and exposed to reactor coolan t above 20 0ºF. The program incl udes (a) repla cements and preve ntiv e measu res to mitigat e IGSCC , and (b) ins pecti ons to monito r IGSCC and i ts effects. Water chemistry is controll ed through imple mentation of the rec ommendations of BWRVIP-130,?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Gu idel ines."The applican t committed to rev ise AMP B.1.7 (see Se ction 3.03.2.7.4 , commitment 3.0.3.2.7-1) in the OCGS LR A to inclu de the enhan cement identifie d in the reco nciliati on document, w hich states that for those c omponents wi thin the scop e of the BWR stress corrosion cra cking aging management pr ogram, all new and replacement SS mater ials will be low-carbon grades of SS with carbo n content li mited to 0.035 wt. % maxi mum and ferrite conten t limited to 7.5%minimum. The appl icant's li cense renew al commitment li st and UFSA R update are to be revi sed to reflect this new commitme nt.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.7.
Contingent upo n the inclusion of commitment  3.0.3.2.7-1 , the project team found that it w as consistent with the GALL Report, and determined tha t it provi ded an adequate summary descri ption of the program, as identi fied in the S RP-LR UFSA R Supplemen t table and as required by 10 CFR 54.21(d).3.0.3.2.7.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team determined th at those portio ns of the program for whi ch the appl icant clai ms cons isten cy w ith th e GALL Repor t are consistent with the GALL Report. In addition, the project team rev iewed th e one exc eption stated in the OCGS LRA for this AMP, and concurred w ith the appl icants deci sion to w ithdraw this excep tion based o n reconcili ation of the AM Ps in the d raft January 200 5 version of the GALL Report w ith the approv ed September 20 05 versio n of the GALL Rep ort. The project team also rev iewed th e enhancement a nd its associ ated justificatio ns, and determin ed that the AMP, w ith the enha ncement, is ade quate to manage the agi ng effects for which it is credited.
The project team als o review ed the UFSA R Supplemen t for this AMP and, contingen t upon the incl usion of Audi t Commi tment 3.0.3.2.7-1, the projec t team fou nd tha t it pr ovid es an adequa te summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).3.0.3.2.8 BWR Penetrations (OCGS AM P B.1.8)In the OCGS LRA , Appendix B, Section B.1.8, the appl icant stated th at OCGS AMP B.1.8,"BWR Penetrations," is an e xisting pl ant program that is consistent w ith GALL AM P XI.M8,"BWR Penetrations," with exceptions
.3.0.3.2.8.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program's acti vities i ncorporate the i nspection and ev aluat ion re commend ation s of BWRVIP-2 7-A, ?BWR Standby Liqui d Cont rol Sy stem/Co re Plate Delta-P Insp ectio n and Flaw Eval uatio n Guid elin es," an d BWRVIP-49-A, ?Instrument 116 Penetration In spection and Flaw E valuatio n Guidelin es,? as w ell a s the w ater ch emistry recomme ndati ons of B WRVIP-130, ?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Guidelines
," for the standby liquid contro l nozz le and in strument penetratio ns.The applican t also stated that the program is implemented thro ugh station proce dures that prov ide for mi tiga tion of cr acki ng th rough wa ter c hemi stry , and moni tori ng for crac king thro ugh inservice inspection examinati ons. Penetrati on inspecti ons are impl emented through stati on procedures that are part of reactor i nternals ins pection and incorporate the requirements of ASM E Sect ion XI.3.0.3.2.8.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.8 is consi stent with GALL AMP XI.M 8, with e xceptions.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.8, incl uding the OCGS program basis docume nt, PB D-AM P-B.1.08, ?BWR Penetrations," Rev. 0
, 11/2 2/20 05, wh ich pr ovide s an as sess ment of t he AMP e leme nts' cons iste ncy wit h GAL L AMP XI.M8. Specifically, the project team reviewed the program elements (see Section 3.0.2.1 of th is audit and re view report) conta ined in OCGS AMP B.1.8 and as socia ted ba ses do cuments to determine thei r consistency with GALL AMP XI.M 8.The pro ject tea m noted that OC GS has imple mented the rec ommenda tions of BWRVIP-27-A and BWRVIP-49-A through the foll owing ins pection proce dures:  Exe lon impleme ntation proced ures E R-AB-3 31, ?BWR RX Internals Management Program Activi ties," Rev.
3, and ER-AB-331-1 001, ?BWR Internals," Rev. 0. Thes e procedures a re based on th e ?ISI Program Plan" (OC-1, Re
: v. 1, 9/1/2004) and the
?Reactor Internal s Program Plan" (OC-5 , Rev. 0, 9/30/2 005). Repai rs and repla cements are gov erned by pr ocedu re ER-AA-33 0-009, ?ASME Section XI Rep air/Replace ment Program," Rev. 3
.The project team v erified that the OCGS reactor intern als program plan , OC-5, includ es the instrument penetra tions and the standby l iquid control nozzl e, and imple ments the recommendations of BWRVI P-27-A and BW RVIP-49-A. Inspections are per formed in accord ance w ith th e stati on ISI program (OC-1).The project team also noted that repair and replacement act ivities, if needed, are perfor med in accordance w ith the recommend ations of the ap propriate BWRVIP repair/repl acement guidel ines. These are sp ecifie d in i mpleme ntatio n proc edure ER-AB-331-1 001 (R ev. 0).The project team rev iewed th ose portions of the BWR Penetrations program for w hich the applicant c laims consi stency w ith GALL AM P XI.M8 and found that they are consistent with the GALL Report AM P. The project team found that the app licant's B WR penetrations program conf orm s to t he re comm ende d GAL L AMP XI.M8, wi th th e exce ptio ns de scri bed be low.3.0.3.2.8.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements:
117 Exception 1 Eleme nt: 2. Preventi ve Action s Exception: NUREG-1801 indicates that water chemist ry control is in accordance w ith BWRVIP-29 for water chemi stry in BWRs.
BWRVIP-29 references the 1996 re vision of EPRI TR-103515,"BWR W ater Chemistry Guideline s."  The Oyster Cre ek water chemistry programs are based on BWRVIP-130, which is the 2004 revi sion of "BWR W ater Chemistry Guideline
: s. For justification of ex ceptions to th e water che mistry program see the Water Chemistry aging management program, B.1
.2.The GALL Report i dentified the foll owing recommend ations for the
?preventiv e actions" pro gram element associ ated with the excep tion taken:
: 2. Prev entiv e Acti ons:  Maintai ning high w ater purity reduces suscep tibility to SCC or IGSCC. Reactor c oolant w ater chemistry is monitored and maintain ed in accord ance with the guidelines in BWRVIP-29 (EPRI TR-10351 5). The program descri ption and th e eval uatio n and techni cal b asis o f monito ring an d main taini ng react or wa ter che mistry are presented in Chapter XI.M2.
The project team rev iewed th e OCGS Water Chemistry Program (AM P B.1.2) and c oncluded that th e use of BWRVIP-130 is ac ceptab le. Th e proje ct team's eva luati on of OC GS AM P B.1.2 is discusse d in Secti on 3.0.3.2.2 of this audit and review report. On this basis, the pro ject team determined that the above exception is acceptabl e.Exception 2 Eleme nt: 3. Parameters M onitored or Ins pected Exception: NUREG-1801 program XI.M9 references ASME Section XI, Table IW B 2500-1 (200 1 edition, includin g the 2002 and 2003 Addenda). Oys ter Creek ISI program is based on the 1995 (including 1 996 Addenda) version of ASME Se ction XI. For just ific atio n of excep tion s to t he IS I pro gra m see the AS ME S e c t i o n X I I n s e r v i c e I n s p e c t i o n , S u b s e c t i o n s I WB , I WC , a n d I WD aging management program, B1.1.
The GALL Report i dentified the foll owing recommend ations for the
?Parameters Mo nitored or Inspected" program el ement associate d with th e excepti on taken: 3. Para meters M onito red or Inspec ted:  The program monitors the effects of SCC/IGSCC on the intended function of the compon ent by dete ction and si zing of cracks by ISI i n accordance with the guidelines of approved B WRVIP-49 or BW RVIP-27 and the recommend ations of the AS ME Code , Section XI, Tabl e IWB 2500-1 (2001 Edition 6 includin g the 2002 and 2003 Addend a). An appl icant may u se the guidel ines of BWRVIP-62 for inspection reli ef for vessel in ternal componen ts with hy drogen water chemistry, prov ided that suc h relief is s ubmitted under the provisi ons of 10 CFR 50.55a and ap pro ve d b y t he sta ff.
118 In re viewing this excep tion , the proj ect t eam r ecog nized that , in ac cord ance with no te 5 t o AMP XI.M9 in the GALL R eport, ?An applic ant may rely on a different v ersion of the AS ME Code , but should justify such use. An applicant may wish to refer to the SOC for an update of 10 CFR § 50.55a to just ify us e of a mo re rece nt edi tion o f the Co de."The project team als o recognized that 10 CFR 50.55a is revised p eriodicall y to adopt, by reference, new e ditions and addenda of the ASME C ode. For each successiv e 120-month (10 year) insp ectio n inte rval , appl icant s are r equire d to re vise the nu clear plan t's IS I progra m to incorporate the requirements speci fied in the v ersion of the AS ME Code referenced in 1 0 CFR 50.55a 12 months prior to the sta rt of the inspection interval.
At present, the a pplicant i s committed to the 1995 versi on (includi ng 1996 addend a) of the ASME S ection XI Code during its fourth ten-year insp ection interv al, whi ch is effective from October 15, 20 02 thro ugh Octo ber 14 , 2012 , appro ved p er 10C FR50.5 5a. The next 120-mo nth inspection interval will incorporate the requirements speci fied in the v ersion of the AS ME Code referenced in 10 CFR 50.55a 12 month s prior to the start of the inspection interval.
The current OCGS ISI p rogram is based o n the 1995 v ersion (incl uding 1996 ad denda) of ASME S ection XI, and th e program wil l be update d in accorda nce with 10 CFR 50.5 5a after each 10 y ear interva l to meet the GA LL-recommended guid elines. On this basis, the project team determined th at this ex ception is acceptable.
3.0.3.2.8.4 Enhan cements None.3.0.3.2.8.5 Operating Expe rience In the OCGS LR A, the appli cant st ated th at OC i s curre ntly in i ts fourth ISI in specti on in terva l. In the history of the Oyster Cree k ISI program no evi dence of instrument penetration or standby liqui d cont rol no zzl e cracki ng has b een fou nd. Thi s prov ides evid ence t hat the wate r chemi stry program has been e ffective in mini mizing the e ffects of stress corrosion crac king in the instrument and s tandby li quid control p enetrations.
The applican t also stated in the OCGS LR A that the same inspection and testing method ologies are used for the B WR penetrations as are used for other reactor in ternals. These p rocesses have detecte d cracking in oth er vessel internals co mponents, as des cribed in the operating experience of the BWR vessel intern als program, OCGS AM P B.1.9.A review of Oyster Creek ope rating experi ence show s that cracking in these penetrati ons has not occurred. It is, therefore, evi dent that the B WR penetration program, in conjun ction wi th the Water Chemistry Program, is effectivel y managing crackin g in the ve ssel SBLC and instrument penetrations.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions w i t h t h e a p p l i c a n t's t e c h n i c a l s t a ff , t h e p r o j e c t t e a m d e t e r m i n e d t h a t t h e a p p l i c a n t's B WR 119 penetr ation s progra m wil l ade quatel y mana ge the a ging effect s that are id entifi ed in the OC GS LRA for whi ch this AM P is credi ted.3.0.3.2.8.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he BWR pene tratio ns pro gram in OCGS LRA, Append ix A, Se ction A.1.8, w hich states tha t the BWR penetrations aging mana gement program is an ex isting program that i ncludes (a) i nspection an d flaw ev aluation i n conformance with the guidelines of staff-approved boil ing water rea ctor vessel and interna ls project (BWRVIP) A, ?Instrument Penetrati on Inspection and Flaw Evaluati on Guideli nes," and BWRVIP-27-A , ?BWR Standby Liquid C ontrol Sys tem/Core Plate D elta-P Inspecti on and Fla w Evaluati on Guideli nes," documents, an d (b) monitorin g and control o f reactor coolant w ater chemis try i n acco rdance wit h ind ustry-recogn ized guide line s of BWRVIP-1 30: ?BWR Vessel and Internals Project BWR W ater Chemistry Guideline s," to ensure the long-term integrity and saf e oper atio n of boilin g wat er re acto r vess el int erna l com pone nts. The r equ irem ents of AS ME Secti on XI w ill be imp lement ed in accord ance w ith 10 CFR 5 0.55(a).The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.8, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.8.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and their associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.9 BWR Vessel Internals (OCGS A MP B.1.9)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.2.10 Bolting Integrity (OCGS AMP B.1.12)In OCGS LRA, Ap pendix B , Section B.1
.12, the appli cant stated that OC GS AMP B.1.12,"Bolting Integrity
," is an ex isting plant program that is cons istent wi th GALL AM P XI.M18,"Bolting Integrity
," with ex ceptions.3.0.3.2.10.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for conditi on monitoring of pressu re reta inin g bolte d join ts wi thin t he sco pe of l icens e rene wal. The B oltin g Integri ty Program incorporates NRC and i ndustry recommend ations deli neated in N UREG-1339,?Resolution of Generic Safety Issue 29: Bol ting Degradation or Failure in Nuclea r Power Plant s", EPR I TR-104 213, ?Bolted Joint Maintenance & Applications Guide," and EPRI NP-57 69, ?Degradation and Failure o f Bolting in N uclear Pow er Plants," as part of the 120 comprehensiv e corporate compo nent pressure re taining bolti ng program. The program manages the loss of bolting function, i ncluding lo ss of material, crac king, and loss o f preload aging effec ts, by performi ng vi sual inspe ction s for pre ssure r etain ing bo lted j oint l eakage. Insp ecti on of ASME Cla ss 1, 2 and 3 comp onen ts is cond ucte d in ac cord ance with AS ME Sect ion XI. N on-C las s 1, 2 an d 3 c ompo nent ins pect ion s rel y on dete ctio n of v isi ble lea kage during routine observation s and equipment maintenance ac tivities. Procurement con trols and installati on practices, d efined in pl ant procedures, ensure that onl y approv ed lubrican ts and torque are appli ed. The activ ities are i mplemented through s tation procedu res.The applican t also stated that the A193 Gr. B7 bolting i s commonly u sed in ASM E XI, Class 1, 2, & 3 pipi ng systems and components. A19 3 Gr. B7 is a chromium-molybd enum material th at is gene rally not su scepti ble to stress corros ion c racking. The bo lting is con sider ed lo w stre ngth bolti ng at Oy ster Cr eek, and is us ed in appl icati ons th at do n ot requi re high strength bolti ng. This is docume nted in NR C Safety Ev aluation for ISI relief request R-15, which a ddresses leakin g of bolt ed flan ges date d Octob er 3, 1 996, s tated t hat Oy ster Cr eek has no hi gh stren gth bolti ng, ex cept for CRD S ystem.3.0.3.2.10.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.12 is cons istent wi th GALL AMP XI.M 18, with exceptions
.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.12, incl uding program b asis d ocumen t PBD-AMP B.1.12 , ?Bolting Integrity
," Revisi on 0, whi ch provi des an asses sment o f the AM P ele ments' c onsis tency wit h GALL AMP XI.M1 8. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.12 and a ssoci ated b ases d ocumen ts  to determine consi stency w ith GALL AM P XI.M18.The project team rev iewed th ose portions of the Bolting Integri ty Program for whi ch the appli cant cl aims c onsis tency wit h GALL AMP XI.M1 8 and found th at they are co nsiste nt wi th the GAL L Repo rt AM P. The project team fou nd tha t the a ppli cant's Bol ting In tegrity Program conf orm s to t he re comm ende d GAL L AMP XI.M18, with th e exce ptio ns de scri bed be low.3.0.3.2.10.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Elements: 1. Scope of Program
: 7. Correctiv e Actions Exception: NUREG-1801 indicates that the prog ram covers all bolting within the scope of li cense renew al inclu ding component s upport and structural bol ting. The Oyster C reek Bolting Integrity Program does not addr ess stru ctur al o r com pone nt su ppor t bol ting.The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
121 1. Scope of Prog ram: This program covers bolting within the scope of license renewal, including: 1) safety-r elated bolting, 2) bolting f or nuclear steam supply system (NSSS) component suppo rts, 3) bolting for oth er pressure retai ning components, i ncluding non-safety-related bolting, and
: 4) structural bo lting (actual measured yi eld strength ³ 15 0 ksi). The aging management o f reactor head clo sure studs is addressed by XI.M3, and is not incl uded in thi s program. The staff's recommendati ons and guide lines for compreh ensiv e bol ting i ntegrit y pro grams tha t enco mpass a ll sa fety-re lated bolti ng are delineated in NURE G-1339, whi ch include the criteria established in the 199 5 edition through the 1996 addenda of ASM E Code Sec tion XI. The ind ustry's tech nical basi s for the p rogra m for s afety-rel ated bol ting and guid eli nes for ma teri al s ele ctio n an d tes ting , bolting prelo ad control, ISI, plant operati on, and mainte nance, and ev aluation o f the structural inte grity of bolted joints, are outl ined in E PRI NP-5769, with the exceptions noted in NUREG-1339. For other bolting, this information is set f orth in EPRI TR-104213.
: 7. Corrective Acti ons: Replacement of ASME pressure retaining bolting is performed in accordance w ith appropri ate requirements of Sec tion XI of the ASM E Code, as s ubject to the additi onal guidel ines and rec ommendations of EP RI NP-5769.
Replacement o f other pressure re taining bolti ng (i.e., non-Cla ss 1 boltin g) and disposi tion of degraded structural bol ting is performed in accordance w ith the guidel ines and rec ommendations of EPRI TR-104213. Replacem ent of NSSS component suppor t bolting is perform ed in acc ord anc e w ith EP RI N P-5 769. A s di scu sse d i n th e a ppe ndi x t o th is rep ort , th e st aff finds the requirements of 10 CFR Pa rt 50, Appendi x B, accep table to add ress the corrective a ctions.The applican t stated in the OCGS LRA, that the Oyster Cree k Bolting Integrity Program does not address struc tural or compone nt support bol ting. The aging management o f structural bolti ng is a ddress ed by the St ructure s Mo nitori ng Progra m, B.1.3 1 and ASM E Sect ion XI, Subsection IWE, B.1.27, addre sses Primary Containment p ressure bolti ng. Aging management of ASME Se ction XI Class 1, 2, and 3 and Class MC suppo rt members is add ressed by th e ASME S ection XI, Subse ction IWF aging management program, B.1.28.
The pro ject tea m revi ewed this exce ption and fou nd tha t struct ural o r compo nent s upport bolting aging effects w ill be a dequately mana ged by the stru ctures monitorin g program, B1.31 and AS ME S ectio n XI, Su bsecti on IWE, B.1.2
: 7. The project team's revi ew o f these A MPs are discussed i n Sections 3
.0.3.2.24, 3.0.3.2.22 and 3.0.3.2.26, re spectivel y. On this basis, the project team found thi s exceptio n acceptable
.3.0.3.2.10.4 Enhan cements In the program b asis d ocumen t, the a ppli cant i denti fied th e foll owi ng enha ncemen t in o rder to meet the GALL Re port program elements:
Elements: 1. Scope of the P rogram 2. Preventi ve Action s 7. Correctiv e Actions Enhan cement: Enhance site procedure to i nclude reference to EPRI TR-1042 13,?Bolted Joi nt Mainte nance & App lication Guide," December 1995.
122 The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associ ated w ith th e enha ncemen t: 1. Scope of Prog ram: This program covers bolting within the scope of license renewal, including: 1) safety-r elated bolting, 2) bolting f or nuclear steam supply system (NSSS) component suppo rts, 3) bolting for oth er pressure retai ning components, i ncluding non-safety-related bolting, and
: 4) structural bo lting (actual measured yi eld strength ³ 15 0 ksi). The aging management o f Reactor Head C losure Studs is addressed by XI.M3, and is not included in this program.
The staff's recommendations and guideli nes for compreh ensiv e bol ting i ntegrit y pro grams tha t enco mpass a ll sa fety-re lated bolti ng are delineated in NURE G-1339, whi ch include the criteria established in the 199 5 edition through the 1996 addenda of ASM E Code Sec tion XI. The ind ustry's tech nical basi s for the p rogra m for s afety-rel ated bol ting and guid eli nes for ma teri al s ele ctio n an d tes ting , bolting prelo ad control, ISI, plant operati on, and mainte nance, and ev aluation o f the structural inte grity of bolted joints, are outl ined in E PRI NP-5769, with the exceptions noted in NUREG-1339. For other bolting, this information is set f orth in EPRI TR-104213.
: 2. Preventive A ctions: Selection of bolting materia l and the u se of lubricants and sealants is in accordan ce with the guidelin es of EPRI NP-5 769, and the additional recommendations o f NUREG-1339, to p revent or miti gate degradation an d failure of safety-related bo lting. NURE G-1339 takes exce ption to certai n items in E PRI NP-5769, and recommends ad ditional measures wi th regard to them. Bo lting replace ment activiti es include proper torquing of the bolts and ch ecking for uniformity of the gasket compression after as sembly. M aintenance p ractices require the applica tion of an appropriate pre load, based on EPRI doc uments.7. Corrective Acti ons: Replacement of ASME pressure retaining bolting is performed in accordance w ith appropri ate requirements of Sec tion XI of the ASM E Code, as s ubject to the additi onal guidel ines and rec ommendations of EP RI NP-5769.
Replacement o f other pressure re taining bolti ng (i.e., non-Cla ss 1 boltin g) and disposi tion of degraded structural bol ting is performed in accordance w ith the guidel ines and rec ommendations of EPRI TR-104213. Replacem ent of NSSS component suppor t bolting is perform ed in acc ord anc e w ith EP RI N P-5 769. A s di scu sse d i n th e a ppe ndi x t o th is rep ort , th e st aff finds the requirements of 10 CFR Pa rt 50, Appendi x B, accep table to add ress the corrective a ctions.The applican t stated, in the program basis do cument, that the Oy ster Creek program addres ses the gui dance conta ined in EP RI TR-1 04213 , ?Bolte d Joi nt Ma inten ance & Appl icati ons Gui de,"howeve r the report is not specifical ly cited as a reference i n the Exel on corporate or stations'specific bolte d joint insp ection/repair procedures. En hance site p rocedure to in clude reference to EPRI TR-1042 13, Bolted J oint Mai ntenance & A pplication Guide, Decembe r 1995. The project team noted that this enha ncement is not identified i n OCGS LRA B1
.12. The appli cant was asked to clarif y this discr epancy.In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the Bol ting Integrity Program (B.1.1
: 2) in the OCGS LRA to incl ude the enha ncement identi fied in the program basis docu ment, which states that the si te procedure w ill be e nhanced to i nclude referenc e to EP RI TR-1 04213 , ?Bolted Joi nt Mainte nance & App lication Guide," December 1995. This is A udit Commitment 3.0.3.2.1 0-1.
123 The project team reviewed the EPRI TR-104213, 1995 edition and found it to be an acceptable revision of the original EPRI TR-10421
: 3. On this ba sis, the project team found this enhancement acc eptable sin ce when enhancement is implemented, OC GS AMP B.1.12,"Bolting Integrity
," will be consiste nt with GAL L AMP XI.M 18 and w ill prov ide additi onal assurance that th e effects of aging will be adequately managed.3.0.3.2.10.5 Operating Expe rience The applican t stated, in the OCGS program basis document, that a review of plant operati ng experience at Oyster Cree k shows that l oss of bolting functi on has occurre d in a few isolated cases how ever in a ll cases th e existi ng bolting inte grity aging management p rogram existing inspections and testing metho dology hav e discove red that deficien cy and corre ctive acti ons were taken pri or to loss of sy stem or component i ntended function.
Operati ng exp erien ce, bo th int ernal and e xtern al, i s used in tw o wa ys at Oyste r Cree k to enhance pla nt programs, preven t repeat eve nts, and prev ent events th at have oc curred at other plants from occur ring at Oyster Creek. The first way in which operating experience is used is through the Oyster Creek operating ex perience proc ess. The operati ng experienc e process screens, eva luates, and a cts on operati ng experienc e documents and information to pre vent or mitigate the conse quences of simila r events. The second wa y is throu gh the process for managing programs. This pro cess requires the review of program related op erating experi ence by th e progra m own er.The effective use of the corrective a ction program has identified torqui ng issues w ith plant equipment and i dentified improv ement was n eeded. A C AP 02004-234 0 requested a rev iew of the existi ng Exelon Procedures and EPRI guidel ines to in corporate best p ractices from recogni zed e xpert s. Cor rectiv e acti ons i nclud ed pro cedure change s and traini ng to as sure proper torquing requirements are included in mainte nance work packages.
This example provides objective e vidence that industry experien ce is consi dered and pro vided i mprovement to the Bolti ng Integri ty agi ng manage ment pr ogram.Oyster Creek has experience d isolated cases of loss o f bolting function attri buted to loss of materi al. R evie w of op eratin g histo ry ha s not i denti fied an y cra cking of s tainl ess ste el bo lting. Reactor coola nt pressure bou ndary lea kage due to boric acid indu ced degradation is not applicabl e since the station is a BWR. In all cases, the existing i nspection an d testing methodologies h ave disco vered the d eficiencies a nd correctiv e actions w ere implemented prior to loss of sys tem or component i ntended functions. This provi des objectiv e eviden ce that loss of bolt ing fu nction will be detect ed prior to loss of intended funct ion and ade quate correc tive action is ta ken to resolv e issues.A review of Corrective Action Program (CA P) documents for Oys ter Creek boltin g indicates tha t they have been effectiv e in i denti fying d egradat ions and ta king cor rectiv e acti on as necess ary. Exa mple s of d isc repa nci es i ncl uded CAP 020 01-0 960, wh ere fl ange bol ts on a bl ind flan ge were found to lack full nut en gagement by approx imately tw o threads. The co ndition w as corrected. This p rovides o bjective ev idence that d eficiencies a re identified within the Bolting Integrity AM P and are en tered into the 10 CFR Part 50, Appendi x B, correcti ve action process and actions are taken to resol ve issues.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.
124 On the basis o f its review of the above plant-speci fic operating ex perience and discussio ns with the applicant's technical s taff, the project team determine d that the appl icant's  B olting Integrity Progr am will adequately manage the aging ef fects that are ident ified in the OCGS LRA for which thi s AMP i s credited.
3.0.3.2.10.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Bolting Integrity Prog ram in OCGS LRA, Appendix A, Section A.1.12, whi ch states that the Bolting Integrity Program is an e xisting program t hat in corpor ates i ndustr y rec ommenda tions of EPR I NP-5 769, ?Degradation and Fail ure of B oltin g in Nu clear Pow er Pla nts," a nd in clude s peri odic visu al in specti ons of c losur e bolting for loss of bolting function. Inspec tion of Class 1, 2, and 3 components is conduct ed in accordance w ith ASM E Section XI.
The requirements of ASM E Section XI w ill be i mplemented in accordance with 10 CFR 50.55(a). Program activities address the guidance contained in EPRI TR-10421 3, ?Bolte d Joi nt Ma inten ance a nd App lica tions Guide". Non-ASM E Cla ss 1, 2 and 3 bolte d joint insp ections rely on detection of visibl e leakage during mai ntenance or rou tine observ ation. The B oltin g Integri ty Pro gram doe s not a ddress prima ry co ntain ment pr essure retaining, structura l and compon ent support bol ting. Primary containment pres sure retainin g bolting are ad dressed by ASME S ection XI, Subse ction IWE, A.1.27. The structures mon itoring program, B.1.31 addre sses th e agin g manageme nt of stru ctural bolti ng. The A SME Secti on XI, Subsection IWF program, B.1.28, add resses aging management o f ASME Sec tion XI Class 1, 2, and 3 and Class M C support members.
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the Bol ting Integrity Program (B.1.1
: 2) in the OCGS LRA to incl ude the enha ncement identi fied in the program basis docu ment, which states that the si te procedure w ill be e nhanced to i nclude referenc e to EP RI TR-1 04213 , ?Bolted Joi nt Mainte nance & App lication Guide," December 1995. This i s Audit Commi tment 3.0.3.2.10-1. The applicant' s license renewal commitment list and UF SAR s upple ment ar e to be revi sed to reflect this new commitme nt.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.12. Contingent up on the inclusi on of Audit Co mmitment 3.0.3.2.10-1, the project team found tha t it was consistent with the GALL Report, and determined tha t it provi des an adequate summary descri ption of the program, as identi fied in the S RP-LR FSAR Supplement ta ble and as required by 10 CFR 54.21(d).3.0.3.2.10.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to manage the aging effects for whi ch it is cre dited. Als o, the project team has revie wed the enhancements an d determined th at the implemen tation of the enh ancements prior to the period of exte nded o perati on w ould resul t in th e exi sting A MP b eing co nsiste nt wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and, contingent upon the inclusion of Audit Comm itment 3.0.3.2.1 0-1, found that it provi des an adequa te summa ry de script ion o f the pro gram, as require d by 10 CFR 54.21 (d).3.0.3.2.11 Open-Cycle Cooling Water System (OCGS AM P B.1.13) 125 In OCGS LRA, Ap pendix B , Section B.1
.13, the appli cant stated that OC GS AMP B.1.13,"Open-Cycle Cooling Water System," is a n existi ng plant program that i s consistent w ith GALL AMP XI.M 20, "Open-Cycl e Cooling Water System," w ith enhancemen ts.3.0.3.2.11.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program is an existin g program that manages aging of piping, piping components, piping element s and heat exchangers that are included in the sco pe of l icens e rene wal for los s of mate rial and re ducti on of he at tran sfer, and are exposed to raw wa ter - salt w ater at Oyster C reek. Program activi ties inclu de (a) survei llance and control o f biofouling (incl uding bioci de injection
), (b) verificati on of heat transfer capa bilities for components cool ed by the service w ater and emergency service w ater systems, (c) inspection and maintenan ce activi ties, (d) wa lkdown in spections, and (e) review of maintenance, operating and training practices and procedur es. Inspections may include visual, ultrasonic, a nd eddy c urrent testing (ECT) meth ods. The OCCWS program is based on the recommendations o f NRC GL 89-13.
Th e a p p l i c a n t a l s o s t a t e d t h a t i t s s e r v i c e w a t e r (S W) a n d e m e r ge n c y s e r v i c e w a t e r (E S W)systems are pe rformance tested for acceptab le flow rate s, operating temperatu res and operating pressure
: s. Volumetric (UT) inspectio ns are performed at v arious abov eground loc atio ns o f the SW and E SW pipi ng, i ncl udi ng in spec tion s pe rforme d ou tsid e at the i ntake structure. Resul ts of the inspecti ons are documen ted and conti nually analyz ed to determine maximum exp ected corrosion rates and sus ceptible l ocations for future in spections. The aboveground i nspection l ocations are representativ e of the same inte rnal coatings, environments and aging effects present in the buri ed sections of the ESW and SW system piping. Therefore the inspection program adequately monitors the co nditions of the ESW and SW syst em i nter nal pip ing, inc lud ing t he b urie d pi pin g.The applican t further stated that v olumetric in spections of abo veground ESW and SW piping that is origin al to the pl ant design are performed at a mini mum of 10 location s every 2 years, based on the maximum antici pated corrosio n rates determine d from past inspecti ons and analyses. The results of the volumetr ic inspections are trended and pipe replacement is scheduled prior to predicted fa ilure. Predicting the failure based on cor rosion rates, current wall thickness, env ironment, and sc heduling repl acement of the pip e is a miti gative actio n to preven t leaks. For pi ping th at has been repla ced, v olumet ric i nspect ions wil l be p erformed at a minimum of 4 abov eground locati ons every 4 years, b ased on the o bserved and anticipated performance of the new pipe. The sc ope of these in spections w ill be e valuated to include addit ional insp ectio n loc ation s as ne w pi ping i s repl aced i n the p lant.3.0.3.2.11.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.13 is cons istent wi th GALL AMP XI.M 20, with enhancements.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.13, incl uding program b asis d ocumen t PBD-AMP-B.1.13 , ?Open C ycle Cool ing Water Sy stem," Rev. 0 , which provi des a n ass essm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M20. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this a udit a nd rev iew report) conta ined in OCGS AMP B.1.13 and a ssoci ated b ases d ocumen ts to determine the ir consisten cy wi th GALL AM P XI.M20.
126 The pro ject tea m revi ewed OCGS p rocedu re EE-AA-34 0, Rev. 2, ?GL 89-13 Program Implementing Proced ure," since the aging management program rel ies on impl ementation of the recommendation s of the Nuclea r Regulatory Commission GL 89-13 to assure that the effects of aging on the open-cy cle cooli ng water (OCCW) (or service water) sys tem will be managed for the exten ded pe riod o f operat ion. The pro ject tea m also revi ewed topic al rep ort TR 140, Rev. 2, ?Emergen cy Se rvic e Water and S ervi ce Water Sy stem Pi ping P lan,"speci ficatio n SP 1 302-12-261, R evs. 7 and 8a, ?Safety-relat ed Spe cifica tion fo r Pipe Integri ty Inspec tion P rogram," a nd TDR-829, R ev. 4 , ?Inspec tion H istory of the OC NGS Pi pe Inte grity Prog ram (Pipe Inte gri ty Ins pect ion Pr ogr am)," t o det erm ine co nsis tenc y with t he GA LL AMP XI.M20.The project team rev iewed th ose portions of the open-cycl e cooling w ater system program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 20 and found t hat the y are consistent with the GALL Report AMP. The project team found that the applicant
's open-cycle cooling w ater system program co nforms to the recommended GALL AMP XI.M20, w ith the enha ncem ents desc ribe d belo w.3.0.3.2.11.3 Exce ption s to th e GALL Repor t None.3.0.3.2.11.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancements in order to mee t the GALL Report program e lements: Enhan cement 1 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g Enhan cement: The open-cycl e cooling w ater aging management program w ill be enhanced to i nclude v olumetric in spections, for pi ping that has been rep laced, at a minimum of 4 above groun d locatio ns every 4 years based on the observ ed and anti cipated performance of the new pip e.The GALL Report i dentified the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detection of aging effects," and
?monitoring and trendi ng" progr am ele ments a ssoci ated w ith th e enha ncemen t: 1. Scope of Prog ram: The program addresses the aging effects of material l oss and fouling due to mi cro- or macro-organisms and vario us corrosion mechanisms. ... The guidelines of NRC GL 89-13 include ... (c) routine in spection and a maintenanc e program to ensure tha t corrosion, ero sion, protecti ve coatin g failure, silti ng, and biofouling cann ot degrade the pe rformance of safety-related systems serv iced by OCCW; ...
127 3. Parameters Moni tored or Inspected
: Cl eanl ine ss a nd ma teri al i ntegr ity of pi pin g, components, heat exchangers, el astomers and thei r internal l inings or coa tings (when applicabl e) that are part o f the OCCW system or that are cool ed by the OCCW system are periodi cally i nspected, monito red, or tested to ensure heat tran sfer capabiliti es. The program ensures (a) remo val of accumul ations of biofoul ing agents, corrosio n products, and silt, an d (b) detection of defective prote ctive coati ngs and corroded OCCW system pipi ng and compon ents th at cou ld ad verse ly a ffect perfor mance o f their inten ded sa fety functions 4. Detect ion o f Agin g Effec ts: Visu al in specti ons ar e typ ical ly p erformed; how ever, nondestructiv e testing, such a s ultrasonic testing, eddy current testing, an d heat transfer capabili ty testing are effective methods to measure surface cond ition and the extent o f wall th inning associ ated with the servi ce water sy stem piping and components, w hen determ ined nece ssary.5. Monitoring and Trendin g: Inspection sc ope, method (e.g., v isual or N DE), and testi ng frequenci es are in ac cordan ce wi th the utili ty co mmitment s unde r NRC GL 89-1 3. ...Inspections or nondestructiv e testing wi ll determine the extent of biofouling, the condition o f the surface coating, the magnitude of local ized pi tting, and the amou nt of MIC, if appl icable.In review ing this enha ncement, the project team noted that v olumetric in spections of abov eground ESW and SW pipi ng that is ori ginal to the plan t desi gn are p erformed at a minimum of 10 loc ations ev ery 2 ye ars based on the maximum an ticipated co rrosion rates determined from past i nspections a nd analy ses. The stated e nhancement w ill add a minimum of 4 UT i nspect ions every 4 ye ars on abov eground pipi ng that has be en rep laced wit h the s ame coatings and materi als as new buried ES W and SW piping. Si nce above ground and buri ed piping are subject to the sam e internal environments and failure mech anisms, the volumetric inspections of aboveground piping bound the buried portions of pip ing. During the audit, the applicant c onfirmed that the i nspection l ocations for new piping are i n addition to the minimum of 10 location s for the original aboveground ESW and SW piping. The a pplicant al so stated that the period icity of the testing and in spections are based on prev ious findings a nd, if testing and inspecti ons need to b e more frequent, or the sc ope needs to be increased , then the program a llow s for thi s adjus tment.The project team determi ned that the ab ove enhan cement wil l provid e an adequate meth od of inspecting pi ping that has b een replaced , and is con sistent wi th the recommendati ons in the GALL Report. The inspection sample popul ation and frequency are adequate si nce, based on previous findings, the appl icant's program a llows for adjustment of the popul ation and frequency, as need ed.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhancement is implemented, OC GS AMP B.1.13, "Open-Cyc le Cooli ng Water System," will b e consistent w ith GALL AM P XI.M20, and will provide additional assurance that the effects of aging will be adequately managed.Enhan cement 2 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 128 5. Monito ring and Trendin g Enhan cement: The open-cycl e cooling w ater aging management program w ill be enhan ced to incl ude sp ecific ity o n ins pecti on of he at ex changer s for loss of material due to general, pitting, crevi ce, galvani c and MIC in the RBCCW, TBCCW and Containment Spray preventativ e maintenance tasks.The GALL Report i dentified the foll owing recommend ation for the
?scope of progra m",?parame ters mon itored or in specte d," ?detection of aging effects," and
?monitoring and trendi ng" progr am ele ments a ssoci ated w ith th e enha ncemen t: 1. Scope of Prog ram: The program addresses the aging effects of material l oss and fouling due to mi cro- or macro-organisms and vario us corrosion mechanisms. Be cause the characteristi cs of the servi ce water sy stem may be sp ecific to each facility, the OCCW system is defined as a system or sy stems that transfer heat from sa fety-related systems, structures, and components (SSC) to the u ltimate heat si nk (UHS). ... The guidelines of NRC GL 89-13 include (a) surveill ance and con trol of biofoulin g; (b) a test program to verify heat transfer capabi lities; (c) ro utine inspe ction and a maintenance program to ensure tha t corrosion, ero sion, protecti ve coatin g failure, silti ng, and biofouling cann ot degrade the pe rformance of safety-related systems serv iced by OCCW; (d) a system walk dow n inspectio n to ensure co mpliance w ith the li censing basis, and (e) a review of maintenance, o perating, and trai ning practices and procedures.
: 3. Parameters Moni tored or Inspected
: Cl eanl ine ss a nd ma teri al i ntegr ity of pi pin g, components, heat exchangers, el astomers and thei r internal l inings or coa tings (when applicabl e) that are part o f the OCCW system or that are cool ed by the OCCW system are periodi cally i nspected, monito red, or tested to ensure heat tran sfer capabiliti es. The program ensures (a) remo val of accumul ations of biofoul ing agents, corrosio n products, and silt, an d (b) detection of defective prote ctive coati ngs and corroded OCCW system pipi ng and compon ents th at cou ld ad verse ly a ffect perfor mance o f their inten ded sa fety functions 4. Detect ion o f Agin g Effec ts: Inspections for b iofouling, damaged c oatings, and degraded material condition are conducted.
Visual i nspections a re typical ly performed; howeve r, nondestructiv e testing, such a s ultrasonic testing, eddy current testing, an d heat transfer capabi lity testi ng are effective method s to measure surface condition a nd the extent o f wall thi nning associa ted with the service water sy stem piping and compon ents, whe n determ ined nece ssary.5. Monitoring and Trendin g: Inspection sc ope, method (e.g., v isual or N DE), and testi ng frequenci es are in ac cordan ce wi th the utili ty co mmitment s unde r NRC GL 89-1 3. Testing and insp ections are d one annual ly and d uring refueling outa ges. Inspections or nondestructiv e testing wi ll determine the extent of biofouling, the co ndition of the surface coating, the magnitud e of localiz ed pitting, and the amount of M IC, if applica ble. Heat transfer testing results are documented i n plant test p rocedures and are trended and review ed by the appropriate group
.In review ing this enha ncement, the project team noted that the RBCCW and containment sp ray heat exchan gers are inclu ded in the scope of licen se renewal for the intended function of 129 pres sure bou ndar y an d he at tr ansfe r. Th e TBC CW heat exc hang ers a re i ncl uded for a lea kage boundary function only. The current GL 89-13 program at Oyster Creek only includes the ESW system and containment spray heat exchang ers. This commitm ent will not change as a result of this enhancemen t, howev er, attributes of the GL 89-13 guidanc e will be implemen ted for the SW system, RBCCW system, and TBCCW system heat exc hangers as part of the OCGS open cycle cooling water aging managem ent program (AMP B.1.13).
Upon implementation of this enha ncem ent, the O CGS A MP B.1.13 will b e con sist ent wit h the reco mme ndat ions in AMP XI.M20 in th e GALL Repor t.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhancement is implemented, OC GS AMP B.1.13, "Open-Cyc le Cooli ng Water System," will b e consistent w ith GALL AM P XI.M20, and will provide additional assurance that the effects of aging will be adequately managed.3.0.3.2.11.5 Operating Expe rience In the OCGS LRA, the applicant state d that Oyster Creek has reviewed both  plant-specif ic operating exp erience rela ting to the OCCWS aging management program. Insp ections implementing the guidance of GL 89
-13 have i dentified deteri oration, degradati on and los s of material from insi de the pipe
.Oyster Creek has performed evalua tions to ide ntify the buri ed piping w ith high risk of deve lopi ng lea ks and h igh con sequenc es, sho uld l eaks oc cur. P ipin g repla cements are scheduled b ased on the ri sk priority, a nd the monitori ng and inspec tion program assures that the pi ping ma intai ns ade quate w all t hickne ss wi th margi n prio r to rep laceme nt.The methodology for determining corrosi on rates and p rojected servi ce life wa s revised in 2002 based on a nalysis of station operati ng exper ience and previous ins pection results. Additio nally, in 2004 fifty p ercent of the burie d ESW and ten percent of the b uried SW piping was replaced with new pipe and a n impr oved coati ng sys tem. A plan is in plac e to re place the ot her fifty percent of the buri ed ESW piping prior to 2 007.After identifyin g and review ing several ESW pipe leaks and w all thinn ing events, a common failur e mecha nism (l ocal wal l thi nning due to salt-wate r corro sion) was ident ified. The re sults were entered into the corrective action process, and an operability evaluation was performed in 2003. The op erabi lity eval uatio n als o inc luded an ev aluat ion o f the effect of the fai lure mechanism on th e SSC safety functions incl uding functional thresholds a nd methods for detection of le aks for each of the safety functions. Addi tionally , the correctiv e action proc ess probl em reso lutio n resp onse i nclud ed the deve lopmen t of an i nspect ion p lan, ?Topica l Rep ort 140 - ESW and Service W ater Syst em Plan."  Some of the plan's goals ar e to prior itize modifications a nd inspecti ons based on risk and conse quence of a leak, modi fy piping seg men ts t hat po se a hi gh r isk an d co nse que nce an d ca nno t be rea son abl y i nsp ect ed, mod ify piping to allow system flexibility for future repairs and inspect piping to ensure disposition/repair prior to failure. The plan ca ptures exis ting analys is, past acti on and future acti on for ESW and SW pipe.The OCCWS aging management program is conti nually adjusted to acco unt for station experience and research. As additional operating experience is obtained, lessons learned will be used to ad just this program as needed. The pro ject team revie wed topi cal report TR 14 0, Rev. 2, ?Emergency Service W ater and Service W ater System Piping Plan," specif ication SP 1302-1 2-261, Revs. 7 and 8a, ?Safety-related S pecification for P ipe Integrity Inspection 130 Program," and TD R-829, Rev. 4, ?Inspection Hi story of the OCNGS Pipe Integrity Program (Pipe Integrity Inspection P rogram)," and conclud ed that it v erifies the effective ness of the applicant' s aging management program i n its use of  sta tion operatin g experience to assess program performance, impleme nt program adjustments, an d to plan future actions.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions with the applicant's technical staff , the project team det ermined that the applicant's  open-cycle cooling water system program will adequately manage the aging eff ects that are identified in the OCGS LRA for w hich this A MP is credited.3.0.3.2.11.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the open-cycl e cooling w ater system program in OCGS LRA , Appendix A, Section A.1.13, whi ch states that the open-cycl e cooling wat er sy stem agin g man ageme nt pr ogram is a n ex isti ng pr ogram that mana ges a ging of pi pin g, piping compone nts, piping el ements and heat exchangers that are include d in the sco pe of license ren ewal for lo ss of material an d reduction o f heat transfer and are exposed to raw wa ter- salt w ater at Oyster C reek. Program activi ties inclu de (a) survei llance an d control of biofouling (in cluding bio cide injecti on), (b) veri fication of heat tran sfer capabiliti es for components cool ed by the Service Water and Emergency Service Water systems, (c) inspection and maintenan ce activi ties, (d) wa lkdown in spections, and (e) review of maintenance, operating , and training practices and proce dures. Inspections may include visual, UT, and eddy current testing (EC T) methods. The program w ill be e nhanced to i nclude specificity on inspecti on of heat exc hangers for loss of materi al due to gene ral, pitting, crev ice, galvanic a nd MIC i n the RBCCW, TBCCW and containment spray preventati ve maintena nce tasks. Addition ally, the program wil l be enhan ced to incl ude volu metric inspecti ons, for piping that has been replaced, at a minimum of 4 abov eground locati ons every 4 years, b ased on the observed an d anticipate d performance of the new pipe. Enh ancements to the program will be implemented pri or to entering the period of ex tended operati on. The OCCWS aging management program is ba sed on the rec ommendations of NR C GL 89-13.
The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 13 of the commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.13 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.11.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. Also, the project team ha s review ed the enhan cements and determined that the implementati on of the enhanc ements prior to th e period of ex tended operation w ould result in the ex isting AM P being consi stent with the GALL Repo rt AMP to which 131 it was co mpared. The project te am also rev iewed th e UFSAR S upplement for this AMP an d found that it prov ides an ad equate summary des cription of the program, as required by 10 CFR 54.21 (d).3.0.3.2.12 Close-Cyc le Cooli ng Water System (OCGS AMP B
.1.14)In the OCGS LRA , Appendix B, Section B.1.14, the appl icant stated th at OCGS AMP B.1.14,"Closed-Cy cle Cooli ng Water System," is an exi sting plant pro gram that is consi stent with GALL AMP XI.M 21, "Closed-C ycle Coo ling Water System," with an excepti on.3.0.3.2.12.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program manages agin g of piping, pipi ng components, pip ing elements an d heat exc hangers that are i ncluded i n the scope o f license renewal for loss of material and reduction of heat transfer and a re exposed to a closed cooling water env ironment at Oys ter Creek. The program prov ides for preve ntive, performance monito ring an d cond ition monito ring ac tivi ties t hat are imple mented through stati on pro cedure s. Preventiv e activi ties inclu de measures to mai ntain wa ter purity a nd the addi tion of corrosion inhi bitors to min imiz e corro sion based on EP RI TR-1 00782 0, "Cl osed C ooli ng Water Chemi stry Guidel ines." The applicant also stated that perf ormance monitoring provides indications of degradation in closed-cycl e cooling w ater systems, w ith plant o perating condi tions provi ding indica tions of degradation in normally operating syste ms. In additi on, station mai ntenance ins pections and NDE provi de conditio n monitoring of hea t exchangers ex posed to clo sed-cycle cooling w ater environments
.3.0.3.2.12.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.14 is cons istent wi th GALL AMP XI.M 21, with an excepti on.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.14, incl uding program b asis d ocumen t PBD-AMP-B.1.14 , ?Close d Cyc le Co olin g Water Syste ms," Rev. 0 , which provi des a n ass essm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M21. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.14 and associ ated bases do cuments to determine the ir consisten cy wi th GALL AM P XI.M21.The project team als o review ed, in part, se veral of the c orporate and sta tion procedure s used for chemi stry c ontrol activ ities and s urvei llan ce test ing, i nclud ing CY-AA-12 0-400, ?Closed Cooli ng Water Chemi stry S trategi c Pla n," Rev. 8; CY-AA-12 0-110, ?Chemistry Li mits and Frequen cies," Rev. 0; and 309.1.1, ?Turbine Buil ding Closed Cooling Water Routine Evolutio ns," Rev. 1, to assure that a ging effects attributable to closed-cy cle cooli ng water systems wi ll be ade quately managed during the peri od of extended operation, an d to determine consistency with GALL AMP XI.M 21.The project team rev iewed th ose portions of the Closed-Cy cle Cooli ng Water System program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 21 and found t hat the y are 132 consistent w ith the GALL R eport AMP. The project team found that the appl icant's program conf orm s to t he re comm ende d GAL L AMP XI.M21, with th e exce ptio n des crib ed bel ow.3.0.3.2.12.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Elements: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: NUREG 1801 refers to EPRI TR-1073 96 Closed Cooling Water Chemi stry Gu idel ines 1997 R evis ion. Oy ster Cr eek imp lement s the guidance p rovided i n EPRI 1007 820 "Closed Cooling Water Chemi stry Gu idel ine, R evis ion 1" whi ch is the 20 04 Rev isio n to TR-1073 96. EP RI peri odica lly updat es in dustry wate r chemi stry guidelines, as new i nformation becomes a vailabl e. Oyster Cree k has revie wed EPR I 1007820 an d has determin ed that the most signifi cant d ifference is th at the new revi sion provi des mor e prescriptiv e guidance an d has a more c onservativ e monitoring approach. EP RI 1007820 mee ts the same [recommend ations] of EPRI TR-107396 for maintaining c onditions to minimize corrosion and microbio logical grow th in close d cooling w ater systems for effectively mi tigating many agin g effects.
The GALL Report i dentified the foll owing recommend ations for the
?preve ntiv e acti ons,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"and ?acceptance cri teria" program elemen ts associated with the exception taken: 2. Preventive A ctions: The program relies on the use of appropriate materi als, lini ng, or coating to protect the underly ing metal surfaces a nd maintain system corrosi on inhibi tor concentrations within the specified l imits of EPRI TR-10 7396 to mini mize corrosi on and SCC.3. Parameters Moni tored or Inspected
: The aging management program mon itors the effect s of corrosion and SCC by testing and inspection in accordan ce with guidance in EPRI TR-107396 to evalu ate system and component cond ition.4. Detection of Aging Effects:
Control of w ater chemistry does not precl ude corrosion or SCC at loc ations of stagnant flow conditions or crevice
: s. Degradation of a component due to corrosi on or SCC w ould result in degradation of system or compo nent performan ce. The exte nt and sched ule o f inspe ction s and testin g shoul d assu re detect ion o f corrosi on or S CC be fore the loss of the i ntende d functi on of th e compo nent. (NURE G 1801 refers to EPRI TR-1007 820 for contro l of w ater ch emistry).5. Monitoring and Trendin g: In accordance with EP RI TR-107396, i nternal vi sual inspe ction s and performan ce/funct ional tests a re to b e perfor med per iodi call y to demons trate s ystem operab ilit y and confirm the effec tive ness o f the pro gram.
133 6. Acceptance Criteria
: Corrosion i nhibitor con centrations are maintained within the limit s spec ified in the EPRI wate r chemi stry gu idel ines for CCC W.  (NUREG 18 01 refer s to EPR I TR-100 7820 fo r contr ol of w ater ch emistry).As part of the aud it, the project tea m interview ed the appl icant's tech nical staff to disc uss techni cal i ssues relate d to th is ex cepti on. Du ring th e inte rvie w, th e appl icant descri bed i ts revi ew a nd ev aluat ion o f the di fferences betw een EP RI TR-1 07396 , ?Closed Coo ling Water Chemistry Gui delines," the 1997 revi sion of the guide lines referred to in NUREG-18 01, and EPRI TR-10078 20, ?Closed Coo ling Water Chemistry Guidel ine, Revi sion 1," w hich is the 2004 revision implemented b y Oyster Cre ek. In additio n, in its res ponse to an a udit question, the appli cant st ated th at the most si gnifica nt differe nce i s that EPRI TR-10078 20 pro vide s more prescriptiv e guidance an d has a more c onservativ e monitoring app roach. The appl icant further stated that EPR I TR-1007820 meets the same recommenda tions of EPRI TR-1 07396 for maintaining co nditions to minimize corrosion and microbiolo gical growth i n closed co oling wate r systems for ef fectively mitigating many ag ing effect
: s. In addition, the applicant stated that it had co ntacte d the a uthor o f EPRI TR-10739 6 and EPRI TR-10078 20, An thony Selb y, to confirm that the new guidance that was prov ided in TR-1 007820 w as not contrary to the guidance in TR-107396.
The pro ject tea m revi ewed EPRI TR-1007 820, ?Closed Coo ling Water Chemistry Guidel ine, Revisio n 1," and EPR I TR-107396 (Rev ision 0) a nd confirmed the a pplicant's assessment that the new re vision provides more prescriptiv e guidance, ha s a more conserv ative moni toring approach, and meets the same requi rements for maintaini ng conditions to minimiz e corrosion and microbio logical grow th in close d cooling w ater systems for effective ly mitigati ng many aging effects. On this basis , the project team found this exce ption accepta ble.3.0.3.2.12.4 Enhan cements None.3.0.3.2.12.5 Operating Expe rience In the OCGS LRA , the appli cant stated that i t has not ex perienced a loss of intende d function failure of components due to corrosi on product bui ldup or throu gh-wall l oss of material for components w ithin the sc ope of licens e renewal that are subject to closed-cy cle cooli ng water system activ ities. Add itionall y, industry experien ce demonstrates tha t the use of corrosi on inhibitor s in closed-cycle coo ling water systems that are monitor ed and mai ntained is eff ective in mitigating l oss of material a nd buildu p of deposits. E vents hav e occurred w here build up of deposits resul ted in degraded heat transfer in heat exchan gers; howev er, this has o ccurred on the tube side of the heat ex changers. The tube side of the hea t exchangers are exposed to raw wate r - sal t wat er and are ma naged b y the open cycl e cool ing w ater pr ogram.In the OCGS LR A, the appli cant st ated th at in 2002 t hey i ncreas ed the ir des ired m olyb date range in all of the closed-cycle cooling water systems f rom 50-125 ppm to 200-1000 ppm. This enabled the applicant to align with industry best practices. In 2004, th e pH in the TBCCW system decreas ed outside th e Action Le vel 1 ran ge for pH. A causti c was add ed that returned pH back to specifications  within the acceptable tim e period for correcting an Action Level 1 CCW limit.
In addit ion to mit igatin g loss of mater ial and build up of de posits b y maintain ing water chemist ry, the applica nt monitors the R BCCW, TBCCW and EDGCW for microbiological growth (total 134 bacter ia co loni es) in accord ance w ith EP RI TR-1 00782 0, "Cl osed C ooli ng Water Chemi stry Guidelines
."  To date, there h ave been no adverse trends associa ted with microbiologic al growth in cl osed-cycle cooling w ater systems.
In its design basis documen t for the CCCW system (PDB B.1
.14), the appli cant stated that operating exp erience, both internal an d external , is used to enhance pla nt programs, preven t repeat even ts, and preve nt events tha t have occu rred at other pl ants from occurring at Oy ster Creek. Through its op erating experi ence revi ew process the appli cant screens, ev aluates, and acts on operati ng experienc e documents and information to pre vent or miti gate the consequences of si milar even ts. In additi on, the appl icant stated th at its process for managing programs requir es the revi ew o f program r elate d oper ating e xperi ence b y the program owne r.Both of these proce sses revie w operati ng experienc e from both externa l and inte rnal (also referred to as in-ho use) sources. E xternal op erating experi ence may i nclude such things as INPO documents (e.g., SOE Rs, SERs, SE Ns, etc.), NRC d ocuments (e.g., GLs, LER s, INs, etc.), Ge neral Elec tric d ocumen ts (e.g., RCSIL s, SILs , TILs, e tc.), an d othe r docu ments (e.g., 10CFR Part 2 1 Reports, NER s, etc.). Internal operating exp erience may include such things as event investigations, trending re ports, and lessons learned fr om in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction proces s. Issu es and even ts, wh ether e xtern al or plant-speci fic, tha t are p otenti ally signi ficant t o the closed c ycle cool ing water pro gram at OCGS are ev aluated. The c losed-cycl e cooling water program is augmented, as app ropriate, if these evaluati ons show that program changes are needed to enhance program effectiv eness.The corrective actions prog ram ensures that the condit ions adverse to quality are promptly corrected. If the defici ency is assessed to be significantly adverse to quality, the cause of the condition i s determined a nd a correctiv e action pl an is dev eloped to p reclude repeti tion. The applicant s tated, in the OC GS LRA, that OCGS has not ex perienced a loss of intende d function failure of components due to corrosi on product bui ldup or throu gh-wall l oss of material for components w ithin the sc ope of licens e renewal that are subject to closed-cy cle cooli ng water system activ ities. The ap plicant further sta ted that proble ms that have been identi fied would not have a si gnificant impact on the safe operatio n of the plant a nd, to date, there have bee n no adve rse tre nds as socia ted w ith mi crobi ologi cal gro wth i n clo sed cy cle co olin g wate r syst ems In the OCGS LRA and the program ba sis document, th e applica nt stated that by improving th e close d-cyc le co olin g wate r chemi stry mo nitori ng para meters, returni ng out o f range pa rameter s within acceptable l imits in a timely mann er and monitori ng for microbiologic al growth, the applicant h as been effective in managing compo nents for loss of materi al and redu ction of heat transfer tha t are exposed to a closed cooling water environment. Additionally, the Closed-Cycle Cooli ng Water Sys tem agin g manageme nt progr am is c ontin uall y adj usted to acco unt for station exp erience and research. As a dditional operating ex perience is obtained, l essons learned are used to adjust th is program as nee ded.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions with the applicant's technical s taff, the project team determine d that the appl icant's Close d-Cyc le Co olin g Water Syste m program wil l ade quatel y mana ge the a ging effect s that are identified i n the OCGS LRA for which th is AMP is credited
.
135 3.0.3.2.12.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Closed-Cy cle Cooli ng Water System program in OCGS LRA, Appendix A, Section A.1.
14, which states that the Closed-Cycle Cooling Water System program is an exis ting program that manages a ging of piping, pip ing components, pip ing elements an d heat exc hangers that are i ncluded i n the scope o f license renewal for loss of material and reduction of heat transfer and a re exposed to a closed cooling water env ironment at Oys ter Creek. The program prov ides for preve ntive, performance monito ring an d cond ition monito ring ac tivi ties t hat are imple mented through stati on pro cedure s. Preventiv e activi ties inclu de measures to mai ntain wa ter purity a nd the addi tion of corrosion inhi bitors to min imiz e corro sion based on EP RI TR-1 00782 0, "Cl osed C ooli ng Water Chemi stry Guidelines."  Perform ance monitoring provides indications of degradation in closed-cycle cooling water systems, with plant operating condit ions providing indications of degradat ion in normally o perating systems.
In additio n, station main tenance insp ections and NDE provi de condition mo nitoring of heat ex changers expos ed to closed-cycle coo ling water environments
.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.14 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.12.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.13 Boraflex Rac k Management Program (OCGS AMP B.1.15)In OCGS LRA, Ap pendix B , Section B.1
.15, the appli cant stated that OC GS AMP B.1.15,"Borafl ex Ra ck Man agement Program," is a n exi sting p lant p rogram th at is consi stent w ith GALL AMP XI.M22, "Boraflex Monitori ng," with an exception.
3.0.3.2.13.1 Program Descriptio n The applicant stated, in the OCG S LRA, that this program is based on ma nufacturer's recommendations, i ndustry guide lines dev eloped in response to N RC GL 96-04, a nd plant specific operati ng experienc
: e. The program employ s a defense in depth strategy to detect and take appropriate act ions for degraded Bora flex to ensure the 5% subcriticality marg in is maintained. The progr am consists of condition mon itoring activities that include periodic inspection of sample Boraf lex coupons, in-situ testing of bor on areal density using BADGER device, mon itoring dissol ved sil ica in the spent fuel storage pool and tre nding the resul ts using EPRI RACK LIFE predicti ve code.
The RACKLIFE predictive model is u pdated period ically and validate d through the BA DGER boron are al density tests. The BAD GER test is co nducted every 3 years.3.0.3.2.13.2 Consi stency wit h the GA LL Rep ort 136 In the OCGS LRA , the appli cant stated that OC GS AMP B.1.15 is cons istent wi th GALL AMP XI.M 22, with an excepti on.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.15, incl uding program b asis d ocumen t PBD-AMP B.1.15 , ?Borafle x  Ra ck Man agement Program,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M22. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.15 and associ ated bases do cuments to determine con sistency w ith GALL AM P XI.M22.The project team rev iewed th ose portions of the boraflex rac k management program for whi ch the applica nt claims con sistency w ith GALL AM P XI.M22 and found that they are consiste nt with the GALL Report AM P. The project team found that the app licant's b oraflex rack management program conforms to the recommended GALL A MP XI.M2 2, with th e excepti ons note d belo w.3.0.3.2.13.3 Exce ption s to th e GALL Repor t The applican t stated, in the OCGS LRA, that the excepti on to the GALL Report program elements is a s follows:
Eleme nt: 2. Preventi ve Action s Exception: Blackness test i s not performed. The tes t is replace d with b oron areal densi ty measurements u sing the BADGE R device , which gives a bett er ind icati on of Bo raflex effectiv eness to perfo rm its intended functio n.The GALL Report i dentifies the foll owing recommend ation for the
?preventiv e actions" pro gram element associ ated with the excep tion taken:
: 2. Preventive A ctions: For Boraflex panels, moni toring silic a level s in the stora ge pool water, measuri ng gap formation by b lackness testing, p eriodicall y measuring bo ron areal den sity.The applicant stated, in the OCG S LRA, that blackness test is not perf ormed. The test is replaced w ith boron are al density measurements usi ng the BADGER d evice, w hich gives a better indica tion of Boraflex effectiveness to p erform its intended function. The project team questioned w hy area de nsity measure ment is equal to or better than b lackness tests. The OCGS replied that blackness tes ting only provides information regarding th e presence of neutron absorbe r material. Bl ackness testing w ill prov ide information regarding gaps or missi ng sections in the Boraflex panel. Ho wever, a real density testing using BA DGER provi des a direct measurement of in-rack pe rformance of Boraflex pa nels. The area l density test measures gaps, erosion and gener al thinning of the scanned Boraf lex panel. Blackness testing gives only an indication whether neutron absorber is present or not in a boraflex panel whereas BADGER test provide s a quantitativ e measurement of Boron
-10 areal de nsity of neutro n absorber in the rack.The project team rev iewed th is excepti on and determi ned that, becau se the Areal Density test is more quantitati ve than the blackness test, th is excepti on was a cceptable.
137 3.0.3.2.13.4 Enhan cements None.3.0.3.2.13.5 Operating Expe rience The applican t stated, in the OCGS LRA, that the Oyster Cree k boraflex rack management program has been i n effect since 1986 when the new high d ensity po ison racks w ere install ed in the spent fuel storage pool.
The program initi ally co nsisted of testin g of sample coupons maintained i n the spent fuel pool and upgraded later to include in-situ testi ng of boron areal density u sing the BADGE R device. To date two BADGER tests were condu cted, one in 1997, and the secon d in 2001.
Both tests id entified the pre sence of degradation s similar to those experience d in the i ndustry, inc luding some are as of local d issolution of boron carbid e, and formatio n of shri nkage in duced gaps. H owev er, bot h tests show that th e ave rage are al de nsity of Boraflex is well i n excess o f the minimum certified areal densi ty by the manufacturer. The in-situ areal density test using the B ADGER dev ice has prov ed effective in identifying unacce ptabl e degra datio n prio r to a l oss of a n inte nded fu nctio n. Cor rectiv e acti ons ar e initiated if the test results find that the 5%
subcritical ity margin can not be maintai ned because of current or projected future Boraflex d egradation.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-speci fic operating ex perience and discussio ns with the applicant's technical s taff, the project team determine d that the appl icant's  bo raflex rack management program wi ll adequatel y manage the a ging effects that are identi fied in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.13.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e boraflex rack manag ement program in OCGS LRA, Appe ndix A, S ection A.1.15, which sta tes that the Bora flex Rack M anagement Program  is an e xisting program tha t provides for aging management of the Boraflex neutron poison material. The progr am consists of monito ring the condition of Boraf lex by routinely sampling fuel pool silica levels, periodically trending the condition of Bor aflex using RACKLIFE, and periodically performing in-situ m easurement of bor on-10 areal density using the BADGER device. The BADGER de vice test i s conducted e very 3 y ears.The project team also reviewed the License Renewal Commitment List to confirm that this program will be implemen ted prior to the period of ex tended operati on as item 15 of the commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.15 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.13.7 Conclusio n 138 On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.14 Insp ecti on o f Ove rhea d He avy Loa d an d Li ght L oad (Rel ated to R efuel ing)Handling Sy stems (OCGS AMP B.1.16)In the OCGS LRA , Appendix B, Section B.1.16, the appl icant stated th at OCGS AMP B.1.16,"Inspection of Ove rhead Heav y Load an d Light Load (R elated To Refuel ing) Handli ng Systems," is an existi ng plant program that i s consistent w ith GALL AM P XI.M23, "Inspe ction of Overhead Hea vy Load and Light Loa d (Related To Refueling) Handl ing Systems," w ith an exception and enhancemen ts.3.0.3.2.14.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program provi des for periodi c visual inspection s of overhead heavy load and light load (related to refueling) handling systems. The prog ram is implemented thro ugh station proce dures and is relied up on to manage los s of material of crane and hoist stru ctural componen ts, includi ng the bridge, the tro lley, bo lting, lifting dev ices, and the rail syste m within the scope of 10 C FR 54.4. Bo lting is moni tored for loss of materi al, and lo ss of preload by inspecting for mis sing, detached o r loosened b olts. The program rel ies on procurement contr ols and installation practices, defined in plant proced ures, to ensure that only approved l ubricants and proper torque are applied c onsistent w ith the NUR EG-1801 Bolti ng Integrity Progr am. Inspection fr equency is annual for cranes and hoists that are accessible during plant o peration, and every 2 years for cranes and hoists th at are only accessibl e during refueling outages.
3.0.3.2.14.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.16 is cons istent wi th GALL AMP XI.M 23, with an excepti on and enha ncements.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.16, incl uding basis docume nt, PB D-AM P-B.1.16, ?Inspection of Ov erhead Heav y Load an d Light Load (Relate d to Refuelin g) Handling Sy stems," Revisi on 0, whi ch provid es an assessmen t of the AMP elements' consi stency w ith GALL AM P XI.M23. S pecifically , the project team review ed the program ele ments (see Secti on 3.0.2.1 of this audit and re view report) containe d in OCGS AMP B.1.16 and a ssoci ated b ases d ocumen ts to d etermi ne the ir con sisten cy w ith GALL AMP XI.M23.The project team rev iewed th ose portions of the Inspection of Overhead Hea vy Load and Light Load (Relat ed to R efueli ng) Han dlin g Syst ems Pro gram for w hich the ap plic ant cl aims consi stency wit h GALL AMP XI.M2 3 and found th at they are co nsiste nt wi th the GALL R eport AMP. The project team found that the applica nt's Inspectio n of Overhead H eavy Lo ad and Light Load (Rel ated to Refueli ng) Handling S ystems Program conforms to the recommended 139 GALL A MP XI.M23, ?Insp ecti on o f Ove rhea d He avy Loa d an d Li ght L oad (Rel ated To Ref uelin g) Ha ndlin g Syst ems," with the ex cept ion an d enha ncem ents desc ribe d belo w.3.0.3.2.14.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Eleme nt: 5. Monito ring and Trendin g Exception: NURE G-1801 indi cates t hat the number and ma gnitud e of li fts made by the crane are rev iewed. The Oyster Creek pro gram does n ot requi re trac king of th e numbe r and m agnitu de of l ifts. Administrative controls are implement ed to ensure that only allowa ble loads are handle
: d. As discu ssed in the Crane Load Cycle Li mit time-limite d aging analy sis (TLAA), the p rojected number of load cycles for 60 years f or the reactor building crane is 2800 cycl es. The projected number of load cy cles for 60 y ears for the turbine bu ilding and heater bay cranes are 200 0 and 600 cycles res pectivel y. The reactor building cra ne, the turbine buil ding a nd the heate r bay crane s wer e desi gned for 2 0,000 to 100,000 loa d cycles.
Thus tracking the numbe r of lifts, or load cycles, i s not required b ecause the pro jected number of crane loa d cy cle s for 60 y ears is s igni fica ntly low er th an th e de sign value.The GALL Report i dentifies the foll owing recommend ations for the
?moni tori ng an d tre ndi ng'program element asso ciated wi th the excep tion taken:
: 5. Monitoring and Trendin g: Monitori ng and trending are not required as part of the crane inspe ction program.In rev iew ing thi s exc eptio n, the project team no ted tha t, wh ile e arly vers ions of the GA LL Rep ort included a recommendation to monitor the number and magnitud e of lifts made by the cranes, the approved September 2005 Revision 1 version of the GALL Report no longer includes this recommendation.
Therefore, the appli cant's program el ement is consi stent with the GALL Report wit h resp ect to monito ring th e numbe r of li fts, and no ex cepti on is requir ed. In Attachment 1, item B.1.16 of its recon ciliatio n document, the a pplicant sta ted that this e xception was del eted.On the basis th at the approv ed September 20 05, Revis ion 1, ve rsion of GALL doe s not recommend monitori ng the number of li fts made by each crane, the proje ct team determined that the applicant's progra m element is consistent with the GALL Report and this exception is not required.
3.0.3.2.14.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancements in order to mee t the GALL Report program e lements:
140 Enhan cement 1 Eleme nt: 1. Scope of Program Enhan cement: Increa se the scope of the p rogram to incl ude ad ditio nal h oists ident ified as pot entia l Sei smic II/I conc ern, i n acco rdance wit h 10 CFR 54.4(a)(2).The GALL Report i dentifies the foll owing recommend ations for the
?scope of program" program elemen t assoc iated wit h the s tated e nhanc ement: 1. Scope of Prog ram: The program manages the e ffects of general corrosion o n the crane and trol ley structura l components for tho se cranes that a re withi n the scope o f 10 CFR 5 4.4, an d the e ffects of w ear on the ra ils i n the r ail s ystem.The project team noted that Section 2.3.3.11 of the OCGS L RA stated that other cranes an d hoists that are not in scop e of NUREG-0612 but travel in the vi cinity o f safety-related sy stems, structures, and co mponents (SSCs) are also i n scope of li cense renew al; if it is determined that their failure w ill impac t a safety-related function. As a result, the rea ctor buildi ng (RB) crane, the turbine building crane, turbine building heater bay crane, recirculation pumps m onorail, spent fuel pool jib cranes, co ntainment va cuum breakers jib c ranes/hoists, equi pment handli ng monorail (RB El. 95'), and the torus bay monorail are in the scope of license renewal. This enhan cement makes th e AM P cons isten t wi th the recomme ndati ons of th e GALL Repor t.On this basis , the project team found the enhancemen t acceptable since wh en the enhancement is implemented, OC GS AMP B.1.16, "Inspection of Overhead He avy Loa d and Light Load Ha ndling Sy stems," will be consiste nt with GAL L AMP XI.M 23 and w ill prov ide additional assurance that the effects of aging wil l be adequatel y managed.
Enhan cement 2 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects Enhan cement: The pro gram wi ll pr ovid e for spe cific i nspect ions for rail wea r.The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored or inspected" an d ?detection of aging effects" program e lements associ ated with the stated enhan cement: 3. Parameters Moni tored or Inspected
: The program eval uates the effectiven ess of the maintenance mon itoring program and the effects of past and future us age on the structural reli ability of cranes.
: 4. Detect ion o f Agin g Effec t: Crane rails and structural component s are visually inspected on a routine b asis for degradatio n.The project team rev iewed th e GALL Report recommendations for the se program elements and dete rmin ed th at th e addi tion of sp ecif ic ins pect ions for rail we ar will mak e the appli cant's AMP consistent with the recommendat ions in the GALL Report; theref ore, this enhancement is acceptable.
141 On this basis , the project team found the enhancemen t acceptable since wh en the enhancement is implemented, OC GS AMP B.1.16, "Inspection of Overhead He avy Loa d and Light Load Ha ndling Sy stems," will be consiste nt with GAL L AMP XI.M 23 and w ill prov ide additional assurance that the effects of aging wil l be adequatel y managed.
Enhan cement 3 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 6. Acceptance Criteria Enhan cement: The program wil l provid e for specific in spections for corros ion of crane and hoi st structural compo nents, inclu ding the bridge, th e troll ey, b oltin g, lifti ng dev ices, and th e rail syste m.The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detection of aging effects," and
?acceptance cri teria" program elemen ts associated with the st ated e nhanc ement: 3. Parameters Moni tored or Inspected
: The program eval uates the effectiven ess of the maintenance mon itoring program and the effects of past and future us age on the structural reli ability of cranes.
: 4. Detect ion o f Agin g Effec t: Crane rails and structural component s are visually inspected on a routine b asis for degradatio n.6. Acceptance Cri teria: Any signifi cant v isual indi catio n of lo ss of mat erial due to corrosion or w ear is ev aluated acco rding to appli cable ind ustry standard s and good industry pra ctice. The crane may also h ave been designed to a specific Serv ice Class as defined in the Crane Manufacturer s Association of America, Inc. (CMAA)Specification
#70 (or late r revisio ns), or CMA A Specificati on #74 (or l ater revisi ons). The specification that was ap plicable at the time the crane was manufactured is u sed.The project team rev iewed th e GALL Report recommendations for the se program elements and determined that the additio n of specific in spections for corros ion of crane an d hoist structura l components, including the br idge, the trolley, bolting, lif ting devices, and the rail system will make the applicant's AMP consistent with the recomm endations in the GALL Report. On this basis, the pro ject team determined that this enh ancement is ac ceptable.On this basis , the project team found the enhancemen t acceptable since wh en the enhancement is implemented, OC GS AMP B.1.16, "Inspection of Overhead He avy Loa d and Light Load Ha ndling Sy stems," will be consiste nt with GAL L AMP XI.M 23 and w ill prov ide additional assurance that the effects of aging wil l be adequatel y managed.
Considerin g the relativ ely short time period re maining before OCGS e nters the lic ense renew al period, the pro ject team inquired about the status of implementing proc edures required for new AMPs, and for significant enha ncements to ex isting AM Ps. The appli cant was a sked to provi de (a) the status of the i mpleme nting p rocedu res for e ach en hance ment to the ex istin g program;(b) the schedul e for initiati ng each of the enha ncements to the e xisting program; (c) a sample of an implementi ng procedure for one enhancement to th e existi ng program; and (d) the re sults of any enhan ced inspecti ons completed.
142 In its response , the appli cant stated that a ll program enhan cements wil l be comple ted and issue d for imp lement ation by D ecembe r 1, 20 06. En hance ments to the pr ogram tha t are related to cran es and hoi sts that are acce ssible onl y during a refueling outage w ill be e xpedited and issued by April 2006. Implemen tation of the enh ancements wi ll be compl eted by December 31, 20
: 07. The enhanc ements wil l be ini tiated follow ing completion of enhanced procedures. Therefore, n o enhanced i nspection resu lts were a vailabl e for review by the pro ject team.The project team rev iewed th e applica nt's response and determined that it is acceptable s ince all activ ities w ill be c ompleted prio r to entering the period of exte nded operatio n.3.0.3.2.14.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e plant ope rating and mainte nance exp erience review identified n o inciden ts of failure of passi ve cranes a nd hoists struc tural components due to age related d egradation. M inor non-age rel ated degradation has been i dentified in non-load bearing components dur ing the inspections. The deg radation was repaired and documented in accordance w ith the correcti ve activ e process.
The applican t was asked to provide documentation to support the cl aim that no i ncidents of failure of passiv e crane and h oist structural components hav e occurred. In response, the applicant s tated that the C orrective A ction Program (CAP) at Oyster Cree k requires documentation of con ditions adverse to quality. For AMP B.1.16, a search of the CAP databa se wa s perfor med to i denti fy if lo ss of mat erial in pa ssiv e compo nents of crane s or ho ists resulted in dropping a load or impacting saf ety-related structur es, systems, or component
: s. No such cases w ere identified. Based upo n this findin g, it was co ncluded that there were no failures of passive component s on cranes or hoists due to age-relat ed degradation. As examples o f the types of inc idents found i n the database , CAPs O2000-1 446, O2004-601, a nd O2004-2877 w ere provid ed for review. The project team rev iewed th ese documents, w hich included the followi ng incidents:
*The reactor buil ding crane main hoist failed to move due to the airbra ke limit sw itch being out of adjustmen t*The lower l imit swi tch for the main an d auxil iary hoi sts were found not to be function al durin g an in specti on and a wa rning l ight di d not i llumi nate*The heater bay crane failed due to a shorte d drive moto r The project team determi ned that none of the inciden ts were due to age-related d egradation of passive l ong-lived c omponents, such as structural membe rs or rails.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's inspection of overhead heavy load and light load (related to refueling) handling systems program will adequately manage the ag ing effect s that are identified in the OCGS LRA f or which this AMP is credited.
143 3.0.3.2.14.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th is AMP in OCGS LRA, Appendix A, Section A.1.1 6, which stated that the i nspection of ov erhead heav y load a nd light loa d (related to refue ling) handl ing sy stems a ging man agement program i s an e xist ing pro gram that confirm s the effect iven ess of th e main tenanc e moni toring program a nd the effects o f past an d future usage on the structur al reliability of cranes and hoists. Administrative controls ensur e that only allowa ble loads are handle
: d. As discu ssed in the crane load c ycle li mit time-limite d aging analysi s (TLAA), the projecte d number of load cycles for 60 years is s ignificantly lower tha n the design val ue and thus fati gue is not a c oncern for cranes d uring the perio d of extended oper atio n. C rane and hoi st st ruct ural comp onen ts, i ncl udi ng th e bri dge, the t roll ey, bol ting , liftin g devi ces, an d the r ail s ystem are v isual ly i nspect ed per iodi call y for l oss of ma terial. Bolting is a lso monitored for loss of preloa d by ins pecting for missing, de tached, or loo sened bolts. The program rel ies on procu rement controls a nd install ation practic es, defined in plant proc edur es, t o en sure that onl y ap prov ed l ubri cant s an d pro per t orque are appl ied to b olti ng.Prior to the p eriod of exten ded operation , the scope of the program will be enhanced to includ e additional hoists that h ave been identified as being in sc ope for license renewal per 10 CFR 54.4 (a)(2). The program w ill als o be enhance d to inclu de inspecti ons for rail w ear, and loss of material due to corrosi on of crane and hoist structural components.
The pro ject tea m noted that th e state ments re gardin g visu al in specti ons for l oss of ma terial are unclear sin ce it is sta ted that crane a nd hoist structu ral components, includin g the bridge, the trolley, b olting, lifting de vices, and the rail s ystem are v isually inspected p eriodicall y for loss of material; how ever, the pro gram will be enhanced to include inspections for rail we ar and loss of materi al du e to co rrosio n of cran e and hoist structu ral co mponen ts. The appli cant w as aske d to clarify speci fically w hat aging management acti vities a re included in the ex isting program, and what the en hance ment w ill add to the ex istin g program.
In its response , the appli cant stated that th e existi ng program has been e ffective in managin g general corros ion o f structu ral co mponen ts, and wea r on th e rail s for cra nes an d trol leys. Howeve r, the implementi ng procedures do not expli citly i dentify steps to inspect for these aging mechanisms. Therefore, a s stated in th e OCGS LRA, Ap pendix B.1.16, the program w ill be enhanced to p rovide for spe cific inspecti ons for rail w ear, and for corrosi on of crane and hoist structural compone nts. The project tea m determined that inspections for general corrosi on and rail wear are currently being perform ed as good practices; however, they are not explicitly included in the OCGS i mplementing proced ures. This enh ancement wi ll provi de a means of formally incorporating these inspections into the OCGS implemen ting procedures. On th is basis, the pro ject team determined that the statements in the appl icant's UF SAR suppl ement are acceptabl e.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 16 of the commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.16 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table, and as require d by 10 CFR 54.21 (d).3.0.3.2.14.7 Conclusio n 144 On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consi stent w ith th e GALL Repor t. In a dditi on, the projec t team r evie wed the ex cepti on and its associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption , is a dequate to manage the aging effects for whi ch it is cre dited. Als o, the project team review ed the enhancements an d determined th at the implemen tation of the enh ancements prior to the period of exte nded o perati on w ould resul t in th e exi sting A MP b eing co nsiste nt wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and found that i t provides an adequate summary description of the program, as require d by 10 CFR 54.21 (d).3.0.3.2.15 BWR Reactor W ater Cleanup System (OCGS A MP B.1.18)In the OCGS LRA , Appendix B, Section B.1.18, the appl icant stated th at OCGS AMP B.1.18,"BWR Reacto r Water Clea nup Sy stem," i s an e xist ing pl ant pro gram that is co nsiste nt wi th GALL AMP XI.M25, "BWR Reactor Water Cleanup Sy stem," with an exceptio n.3.0.3.2.15.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program describ es the requirements for augmented inserv ice inspec tion (ISI) for SCC or IGSCC on sta inless stee l reactor w ater cleanup sy stem piping w elds outboard of the second co ntainment isol ation val ves. The program i nclud es in specti on gui deli nes de line ated i n NUR EG-031 3, Rev. 2, an d NRC GL 88-01. The pr ogram al so pro vide s for w ater ch emistry contro l in accord ance w ith BWRVIP-130:
?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Gu idel ines" to minimize the potential of crack initiation and growth due to SCC or IGSCC.
The applican t also stated in the OCGS LR A that, in ac cordance w ith GL 88-01, S upplement 1, upgrades and enhancement s have been implemented to the RW CU isolation valves in accord ance w ith GL 89-10 to ens ure tha t the v alve s wi ll pr oduce suffici ent thr ust to perform their design b asis function, w hich is the isolatio n of containment i n the even t of a pipe brea k downstream of the valve s. Based on these upgrades/ en hancements, an e ffective hydrogen water chemistry program , and the complete lack of cracking fou nd during any of the RW CU piping we ld inspecti ons under GL 8 8-01, all i nspection requi rements for the portion of the RWCU system outboard of the se cond contain ment isolati on valv es have b een elimin ated.The app lica nt furthe r state d in t he OCGS LRA t hat the reacto r cool ant sy stem (R CS) ch emistry activiti es that support the aging management program for the RWCU system consist of preve ntiv e measu res tha t are u sed to manage crackin g in l icens e rene wal compon ents exposed to reactor water and steam. RCS chemistry a ctivitie s provide for monitoring and controlling R CS water chemistry usi ng Oyster Creek proce dures and proc esses based o n the 2004 r evis ion to EPRI TR-1035 15, w hich is BWRVIP-1 30, ?BWR Vessel and Internals Project BWR W ater Chemistry Guideline s."  The BWR water chemistry guidelines include information to develop proactive plant-specific water chemistr y programs to minimize IGSCC.
3.0.3.2.15.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.18 is cons istent wi th GALL AMP XI.M 25, with an excepti on.
145 The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.18, incl uding basis docume nt, PB D-AM P-B.1.18, ?BWR Reactor Water Clean up Sy stem,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M25. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.18 and associ ated bases do cuments to determine the ir consisten cy wi th GALL AM P XI.M25.In reviewing this program, the pro ject team noted that Section 2.3.3.32 of the O CGS LRA identifies the entire RWCU as being i n the scope o f license renew al; howe ver, the app licant limited the scope of this pro gram to include only that portion of the RWCU system ou tboard of the second co ntainment isol ation val ve. The projec t team asked the app licant 1) co nfirmation that the scope of this AMP included only no n-safety-related p iping outboard of the second cont ain ment iso lati on v alv es, a nd 2) cl arifi cati on a s to wha t pro gram w oul d be use d to mana ge aging for the safety-rela ted portion of the RWCU system inboard of the second conta inment isolation valves.In its response , the appli cant stated that th e OCGS BWR reactor water cl eanup syste m aging management pr ogram addresses SCC and IG SCC in 4-inch or larger austenitic stainless steel, non-safety-related , non-RCPB (re actor coolant pressure bound ary) reactor w ater cleanup system pipi ng outboard of the se cond primary containment i solation v alves, ab ove 200ºF.
For austenitic s tainless ste el non-safety-rel ated, non-RCP B reactor w ater cleanup system pipi ng less than 4-i nch, the Water Chemistry Program (A MP B.1.2) and the One-Time Ins pection Progr am (AMP B.1
.24) app ly.The applicant furth er stated that SCC and IGSCC in 4-inch or large r austenitic stainless steel, safety-related, R CPB portion s of the reactor w ater cleanup system inboa rd of the second primary conta inment isol ation val ves, abov e 200ºF, are ad dressed by the OCGS BWR stress corrosion crackin g program (AMP B.1
.7), the ASM E Section XI In service Ins pection, Subsections IW B, IWC, and IW D program (AMP B.1.1), and the Water Chemistry Program (AMP B.1.2
). For austeni tic stainle ss steel safety-related, RCP B reactor w ater cleanup system piping less than 4 inches, the ASME Section XI Inservice Inspection, subsections IW B, IW C, and IWD program (AMP B.1.1), the One-Time Inspectio n Program (AMP B.1.24), and th e W ater Che mistr y Progra m (AMP B.1.
: 2) apply.The project team reviewed the applicant's response and determined that it is acceptable since it appropriately limits the scope of this AM P to non-safety-re lated pipi ng outboard of the se cond containment is olation v alves, i n accordance with the guidance prov ided in N RC GLs 88-01 and 89-10. Pipi ng inb oard o f the sec ond co ntain ment is olati on va lves wil l rema in su bject to i n s p e c t i o n u n d e r t h e A S M E S e c t i o n X I I n s e r v i c e I n s p e c t i o n , s u b s e c t i o n s I WB , I WC , a n d I WD program (AMP B.1.1), or the One-Tim e Insp ectio n Progra m (B.1.2 4).The project team als o noted that the description of AMP B.1
.18 in the OCGS LRA stated th at 1)GL 88-01, Supplement 1, upg rades and enhancements have been implement ed to the RW CU isolation valves in accordan ce with GL 89-10, 2) an effective hydrogen water chemi stry program is being impl emented, and 3) a complete l ack of cracking was found during the RWCU piping weld i nspections u nder GL 88-01.
Therefore, all ins pection require ments for the portion of the RWCU system outboard of the se cond contain ment isolati on valv es have b een elimin ated. The project team asked the applicant to provide documentation to support the el imination o f inspection requirements for the porti on of the RWCU system outboard of the second containment is olation v alves.
146 In its response , the appli cant stated the GPU letter to N RC 1940-00-20 096, dated Ap ril 13, 2000, ?Oyster Creek R equest t o Eli minate Inspe ction s," and OCGS d ocumen t OC-2, ?IGSCC Inspection Program (GL 88-01 and BW RVIP-75)," document the basis for this finding. No formal response was received fr om the NRC for letter 1940-00-20096; however, since all required action s identified in previ ous corresponde nce with the NRC that would a llow for the elimi natio n of the RWCU augment ed in specti ons w ere co mplete d, no r espon se wa s exp ected. Therefore, Oyster Creek con sidered this request approv ed.The pro ject tea m revi ewed GPU l etter to NRC 1 940-00-20096 , dated April 13, 20 00, ?Oyster Creek R equest t o Eli minate Inspe ction s," and OCGS d ocumen t OC-2, ?IGSCC Inspectio n Program (GL 88-01 and BWRVIP-75)."  OCGS document OC-2 i ncludes a l ist of RWCU system welds a nd summarizes the results o f the IGSCC inspe ctions condu cted to date. The project team's revi ew of the resu lts reported i n this documen t confirm that the RWCU system w elds have been inspected and no indications of IGSCC were found, which supports the applicant's claim. As noted in the GALL Report for AMP XI.M25, the elimination of RW CU weld inspections outboard of th e second containment isolation valves is acceptable if the guidance in GL 89-10 is co mpleted to v erify the iso lation functio n of these val ves, and n o indicati ons of IGSCC have been found in previous inspections. Since the applicant has successf ully completed al l required acti ons, the insp ections w ere appropriate ly eli minated. On thi s basis, the project team de termined that the applicant' s response w as acceptabl e.The project team rev iewed th ose portions of the BWR Reactor Water Cleanup System pro gram for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 25 and found t hat the y are c o n s i s t e n t w i t h t h e G A L L R e p o r t A M P. T h e p r o j e c t t e a m fo u n d t h a t t h e a p p l i c a n t's B WR reactor water cleanup sy stem program  conforms wi th the recommended GALL AMP XI.M25,"BW R Reac tor W ater Clean up Sys tem ," wit h the excep tion desc ribe d belo w.3.0.3.2.15.3 Exce ption s to th e GALL Repor t In th e OCG S LRA, the ap plica nt st ated the f ollowi ng ex cept ion to the G ALL Re port AMP elements: Elements: Program Descriptio n 2. Preventi ve Action s Exception: NUREG-1801 indicates that water chemist ry control is in accord ance w ith BWRVIP-29, ?E P R I R e p o r t T R-1 0 3 5 1 5-R 1 , B WR Water Chemistry Guidelin es" dated 1996. The Oyster Creek Water Chemis try Pr ogram is based on BWRVIP-1 30, ?B WR Vessel and Internals Project BWR W ater Chemistry Guideline s"dated 2004.
The GALL Report i dentifies the foll owing recommend ations for the
?program description
" and?preventiv e actions" pro gram elements associ ated with the excep tion taken:
Program Descrip tion: The program inclu des inserv ice inspec tion (ISI) and monitoring and control of reactor coolant water chemistry to manage the ef fects of SCC or IG SCC on the inten ded function of aus tenitic stai nless steel (SS) pipi ng in the reacto r water cleanup (RW CU) system. Based on the Nuclear Regulator y Commission (NRC) criteria related to i nspection guid elines for RWCU piping w elds outboard of the second i solation valve, the program includes the measure s delineated in NUREG-0313, Rev. 2, and NRC 147 GL 88-01. Cool ant water ch emistry is monitored and maintained i n accordance with the Electric Po wer Resea rch Institute (EP RI) guidelin es in boi ling water reactor vesse l and intern als p roject (BWRVIP) -29 (TR-103 515) to minim ize the po tentia l of cra cking du e to SCC or IGSCC.
: 2. Preventive A ctions: The comprehensive progra m outlined in NUREG-0313 and NRC GL 88-01 address es improvemen ts in all three elements that, in combin ation, cause SCC or IGSCC.
These elements are a suscepti ble (sensiti zed) material , a significant tensile stress, and an agg ressive environment. The progr am delineated in NUREG-0313 a nd NRC GL 8 8-01 includ es recommendation s regarding selec tion of materials that a re resistant to sensitiza tion, use of spec ial process es that reduce residual ten sile stresses , and monitori ng and maintenan ce of coolant ch emistry. The resistant materia ls are used for new and re placement compon ents and inc lude low-carbon grades of austeniti c SS and w eld metal, w ith a maxi mum carbon of 0.035 wt.% and a mi nimum ferrite of 7.5% in weld metal and cast aus tenitic stai nless steel (CASS). Inconel 82 is the only commonl y used ni ckel-base we ld metal con sidered resistant to SC C; other nickel-alloys, such as All oy600, are evaluated on an ind ividual basis. Speci al processes are used for ex isting as w ell as ne w and rep lacement comp onen ts. Th ese proc esse s in clu de s olu tion hea t tre atme nt, h eat s ink w eld ing, induction heating, and mechanical str ess improvement. The prog ram delineated in NUREG-0313 a nd NRC GL 8 8-01 varie s depending o n the plant-sp ecific reactor w ater chemistry to mitigate SCC or IG SCC.The pro ject tea m revi ewed the ap plic ant's exce ption as pa rt of the OCGS Water Ch emistry Program (AMP B.1.2) and deter mined that it is acceptable. The evaluation of th is exception is discu ssed i n Sect ion 3.0.3.2.2 of thi s audi t repor t.3.0.3.2.15.4 Enhan cements None.3.0.3.2.15.5 Operating Expe rience In the OCGS LRA , the appli cant stated that n o indicati ons of IGSCC hav e been found i n the RWCU system, which i s not stress imp roved. The foll owing miti gative actio ns have a lso been implemented to reduce the susc eptibility of the RW CU System to IGSCC:
C Improved w ater chemistry guidelines (BWR W ater Chemistry Guideline s 2004 Revi sion (BWRVIP-130
))C Hydrogen W ater Chemistry (HW C)C Noble Metals Chemical Addition (NMCA)
The project team asked clarification on when the hydrogen water chem istry and noble metals chemical add ition mitigati ve action s were i nitiated at Oyster Creek. In i ts response, the applicant s tated the hy drogen water c hemistry w as implemented during cycl e 12 (1990), a nd noble metals chemi cal a dditi on w as imp lement ed in outage 1R19 (2002).The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d program basis documen ts, intervie wed the a pplicant's te chnical sta ff, and confirmed that the 148 plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions w i t h t h e a p p l i c a n t's t e c h n i c a l s t a ff , t h e p r o j e c t t e a m d e t e r m i n e d t h a t t h e a p p l i c a n t's  B WR reacto r wat er cle anup s ystem program w ill adequa tely manage the agi ng effects that ar e identified i n the OCGS LRA for which th is AMP is credited
.3.0.3.2.15.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th is AMP in the OCGS LRA, Appendix A, Section A.1.1 8, which stated that the B WR reactor water cleanup system aging management program is an ex isting program that de scribes the re quirements for augmented i nservice inspection (ISI) for SCC or IGSCC on stainl ess steel rea ctor water cl eanup syste m piping w elds outboard of the sec ond containmen t isolation valve s. The program incl udes inspec tion guidelines delineated in NURE G-0313, Rev. 2 and NRC GL 88-01. The program a lso provi des for wat er che mistry contro l in accord ance w ith BWRVIP-130: ?BW R Vessel and Internals Project BWR W ater Chemistry Guideline s" to minimiz e the potentia l of crack initi ation and growth due to SCC or IGSCC.
In accordance w ith GL 88-01, S upplement 1, u pgrades and enh ancements hav e been implemented to the RWCU isolation v alves i n accordance with GL 89
-10 to ensure th at the valves will produce sufficient thrust to perform their d esign basis functi on, which is the iso lation of containment in the event of a pipe break do wnstream of the v alves. B ased on these upgrade s/enha ncemen ts, an effectiv e hyd rogen w ater ch emistry program, and th e compl ete lack of crack ing found during any of the RW CU piping weld inspections under GL 88-01, all inspection requirements for the porti on of the RWCU system outboard of the second containment is olation v alves ha ve been e liminated.
Reactor coola nt system (RCS) chemistry ac tivities that support the aging management program for the RW CU system consist of preventive measures t hat are used to manage crac king in license ren ewal co mponents exp osed to reactor water and steam. RCS ch emistry activ ities provide for moni toring and control ling RCS w ater chemistry using Oyster Cre ek procedures and proces ses ba sed on BWRVIP-130
: ?BWR Vessel and In ternal s Proje ct BWR Water Chemi stry Guidelin es."  T he BW R water che mistr y guideline s include in form ation to develop pro active plant-specific water chemist ry programs to minimize IGSCC.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.18 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.15.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eption and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption , is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).
149 3.0.3.2.16 Fire Protecti on (OCGS AM P B.1.19)In OCGS LRA, Appen dix B, Sec tion B.1.19, the ap plic ant sta ted tha t OCGS A MP B.1.19, "Fire Protec tion," is an exi sting p lant p rogram th at is consi stent w ith GA LL AM P XI.M 26, "Fi re Protection," w ith an ex ception and enhancements.
3.0.3.2.16.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program provi des for aging management of various fire protection-rela ted components w ithin the sc ope of licens e renewal. The program provides for visual i nspections o f fire barrier penetrati on seals for si gns of degradation, such as change in materi al propertie s, cracking, and lo ss of material, throu gh periodic i nspection, surveill ance, and mai ntenance acti vities. The inspection s are implemen ted through recurrin g task work orders an d station proc edures.The applican t also stated that the program prov ides for vis ual inspe ction of fire barrie r walls , ceilings, an d floors in struc tures withi n the scope o f license renew al for the aging effects of crackin g and l oss of ma terial. The i nspect ions are im plemen ted thr ough re currin g task w ork orders and stati on procedures.
The program also prov ides for period ic visu al inspecti ons of fire doors for hol es in skin, w ear, or missi ng parts. Fire door c leara nces a re che cked du ring pe riodi c insp ectio ns and whe n fire doors and co mponen ts are repai red or repla ced. A dditi onall y, pe riodi c functi onal tests o f fire doors are impl emented through recurri ng task work orders an d station proc edures.The applican t further stated that the program wil l provid e for managing loss o f material aging effects for the fuel oil sy stems for the Oyster C reek diesel-dri ven fire pumps by the performance of peri odic fuel oi l sy stem su rvei llan ce test s that are im plemen ted thr ough re currin g task w ork orders and stati on procedures.
The program wil l provid e for aging management of exte rnal surfaces of the Oy ster Creek carbon diox ide and Ha lon fire suppre ssion sys tem components for corros ion and mech anical damage t hrough perio dic o perabi lity tests b ased o n NFP A code s and visu al in specti ons. Testing and insp ections are i mplemented through re curring task work orde rs and station procedures.
3.0.3.2.16.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.19 is cons istent wi th GALL AMP XI.M 26, with an excepti on and enha ncements.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.19, incl uding the pro gram bas is do cument, PBD-A MP-B.1.19, ?Fire Protecti on," Rev. 0, which provides an assess ment of the AMP eleme nts' co nsisten cy with GALL AMP X I.26. Specific ally, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this aud it and rev iew report) contained in OCGS AMP B.1.19 and associated bases documents to determ ine their consistency with GALL AMP XI.M 26.The project team rev iewed th ose portions of the fire protection program for which the applica nt claims consi stency w ith GALL AM P XI.M26 and found that they are consiste nt with th e GALL 150 Report AMP. The p roject t eam foun d that the ap plic ant's fire pr otecti on pro gram  con forms to the rec ommende d GALL AMP XI.M2 6, "Fi re Prot ectio n," w ith th e exc eptio n and enhan cements desc ribe d belo w.3.0.3.2.16.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects Exception: NUREG-1801 rec ommends visu al inspecti on and function al testing of the halon and CO 2 fire suppressio n systems at l east once e very six months. The Oy ster Cr eek hal on and low-press ure carbon diox ide fire suppre ssion sys tems undergo operati onal testing and in spections ev ery 18 months. Addition ally, the halon fire suppression system undergoe s an inspec tion of the sy stem charge (storage tank we ight/level and pressure) e very 6 mo nths, and the low-pressure carbon dioxide fire suppressio n system undergoes a w eekly tank check a nd monthly valve position alignment ve rification. These test frequencies are considered sufficient to ensure system ava ilabili ty and ope rability based on the sta tion's opera ting hi story that s hows no agi ng rela ted ev ents that have a dversely affected the systems' o peration. The te st procedures w ill be e nhanced to i nclude v isual in spections of the component ex ternal surfaces. Test and inspecti on frequency adequacy w ill be e valuated as part of the correc tive acti on process based on actual tes t and inspec tion results.
The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspected" an d ?detection of aging effects" program e lements associ ated with the excep tion taken: 3. Parameters Moni tored or Inspected
: The periodic visual inspection and functional test of the halon an d CO2 systems is performed at le ast once ev ery six months to ex amine the signs of degradati on.4. Detect ion o f Agin g Effec ts: Visual inspection of the alon/CO 2 fire suppressio n system detects any sign of added degrada tion, such as corrosion, mech anical da mage, or damage to dampers. The periodic function test and inspection performed at least o nce every six months detects degradation of the halon/CO 2 fire su ppress ion s ystem before the loss of the c omponent inten ded function.
In review ing this ex ception, the p roject team noted th at the Oyster C reek fire protection a ging management program directs halon fire sup pression sy stem surveil lance that v erifies halon storage tank wei ght, level, a nd pressure on ce every six months. Actuation of the system (automatic and ma nual, incl uding dampers) an d flow is verified ev ery 18 months. The program also directs performance of functional operabili ty testing and flow ve rification, in cluding operation of asso ciated ve ntilation dampers, and manu al and auto matic actuation. The low-pressu re carbon dio xide fire su ppression sy stem undergoes a w eekly tank check a nd 151 monthl y va lve posit ion a lignme nt ve rificat ion. V isual aging d egradat ion i nspect ions are performed durin g the op erabi lity tests. Exi sting o perabi lity testi ng requi rements are implemented thro ugh station proce dures. The project team noted that the current lice nsing basis for peri odic visu al in specti on and functio nal te st frequen cy of th e hal on and CO2 sy stems is every 18 months.
As described in Sectio n 3.0.3.2.16.4 be low, OCGS te st procedures w ill be e nhanced to i nclude visual inspections of the component e xternal surfaces for signs of corrosion and mechanica l damage. In LRA S ection B.1.19 and in respo nse to an aud it question, the applicant s tated that plant-specific operating exp erience has shown no loss of material on the ex ternal surfaces of components in the halon a nd carbon di oxide sy stems that have adversel y affected system operation. The applicant' s review of station operati ng experienc e did not i dentify any occurrence of aging rel ated degradation which adversely affected the operation of the halon o r CO 2 systems.While the frequency of functional testing exceed s the frequency reco mmended in NUREG-1801, A MP XI.M2 6, the project team determined that it is sufficient to ensure sy stem availab ility a nd operabil ity based on the enha ncement to incl ude visu al inspecti ons of the component ex ternal surfaces for si gns of corrosion and mechanical damage. In additi on, the station operating histor y, indicates no occurrence of ag ing-related events having adversely affect ed system operation. Based on its review of the applicant's progr am and plant-specific operating exp erience, the p roject team concurred that the 18-month frequency is ade quate for aging management consi derations. On th is basis, th e project team found th is excepti on acceptable.
3.0.3.2.16.4 Enhan cements In the OCGS LRA , the appli cant identifie d  the follow ing enhancements in order to mee ting the GALL Report program e lements: Enhan cement 1 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The fire protection aging management program w ill be e nhanced to include inspection for corrosion and mechanical d amage on external su rfaces of piping and components for the Oy ster Creek halon and carbon diox ide fire suppre ssion sys tems.The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and
?accept ance c riteri a" program e lement s asso ciate d wi th the enhan cement: 3. Parameters Moni tored or Inspected
: The periodic visual inspection and function test is performed at least o nce every six months to examine the signs of degradati on of the halon/CO2 fire su ppression sy stem. Materi al conditi ons that may affect the performan ce of the syste m, such as cor rosio n, mech anica l dama ge, or d amage to dampers, are obse rved durin g these tests.
152 4. Detect ion o f Agin g Effec ts: Visual i nspection of the halon/CO2 fire su ppression system detects a ny sign of add ed degradation, such as corrosi on, mechanical damage, or damage to dampers.
The periodic function test and inspection performed at least once every six months detects degradati on of the halon
/CO2 fire suppressi on system before the loss o f the component in tended function.
: 5. Monitoring and Trendin g: The performance of the hal on/CO2 fire suppres sion syste m is monitored during the peri odic test to d etect any de gradation in th e system. These peri odi c tes ts pr ovi de d ata n eces sary for tr endi ng.6. Acceptance Criteria
:  ...any signs of corrosion and mechanical d amage of the halon/CO2 fire su ppression sy stem are not acce ptable.In review ing this enha ncement, the project team noted that the applican t's fire protectio n aging manageme nt progr am curre ntly incl udes p eriod ic ha lon a nd lo w-pre ssure c arbon diox ide fi re suppression system inspections, including inspections for operation of the dampers. This enhancement w ill add visual inspections of the piping a nd components for ex ternal surface corrosion degrada tion and mech anical da mage, as recommended i n the GALL Re port. The addition o f these visua l inspecti ons wil l provid e addition al assurance that aging degradati on of the fire protection system piping and components will be adequately managed; ther efore this enhancement is acceptable.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.19 , "Fire Protec tion," wil l be c onsis tent w ith GALL AMP XI.M26 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 2 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The fire protection aging management program w ill be e nhanced to provide specific guida nce for examini ng the fire pump di esel fuel supply systems for corrosi on during pump tests.The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and
?accept ance c riteri a" program e lement s asso ciate d wi th the enhan cement: 3. Parameters Moni tored or Inspected
: The diesel-d riven fire pu mp is under o bservation durin g performa nce te sts suc h as flo w an d dis charge t ests, s equenti al sta rting ca pabil ity tests, and controller f unction tests for det ection of any degradation of the fuel supply line.4. Detect ion o f Agin g Effec ts: Periodic tests performed at lea st once eve ry refueling outage, such as flow and discha rge tests, sequential starting capabi lity tests, and controller functi on tests performed on diesel-driv en fire pump ensu re fuel supply line 153 performan ce. The performan ce test s dete ct degra datio n of the fuel su pply line s before the loss of the c omponent inten ded function.
: 5. Monitoring and Trendin g: The performance of the fire p ump is monitore d during the periodic tes t to detect any degradation i n the fuel supp ly lin es. Periodi c testing provi des data (e.g., pr essure) for trendin g neces sary.6. Acceptance Criteria
: No corrosion is acceptab le in the fuel supply line for the diesel-driv en fire pump.
In review ing this enha ncement, the project team noted that the applican t's fire protectio n aging manageme nt progr am curre ntly incl udes o perati onal tests o f the di esel-driv en fire pumps to record flow a nd discharge, sta rting capabil ity, and c ontroller functio n, to be performed ev ery 18 months. These performance tests detect degradati on of the fuel supp ly lin es before the lo ss of the component i ntended function.
This enhance ment will add a vi sual inspe ction for detectin g any degradati on of external surfaces of the fuel sup ply li ne during engin e operation, a s recommended in the GALL Repo rt. Since the inclusio n of visual inspection s will provide additional assurance that aging degradation of the f uel supply lines is adequately managed, this enhancement is acceptable.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.19 , "Fire Protec tion," wil l be c onsis tent w ith GALL AMP XI.M26 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 3 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The fire protection aging management program w ill be e nhanced to prov ide a dditi onal inspe ction guida nce for d egradat ion o f fire barrier wa lls, ceil ings, and floors su ch as spall ing and loss of material cause d by freeze-th aw, chemica l attack, and reac tion with aggregates. En hancements w ill be i mplemented prio r to the period of exte nded operatio n.The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and
?accept ance c riteri a" program e lement s asso ciate d wi th the enhan cement: 3. Parameters Moni tored or Inspected
: Visual i nspection of the fire barrier w alls, ceilings, an d floors exami nes any si gn of degradation such as cracking, spal ling, and loss of material caused by freeze-thaw, chemical attac k, and reaction w ith aggregates.
: 4. Detect ion o f Agin g Effec ts: Visual i nspection by fire protection qualified insp ectors of the fire barri er wa lls, ceil ings, a nd floo rs, per formed i n wa lkdow ns at l east o nce ev ery refueling outage ensu res timely detection of conc rete cracking, spall ing, and loss of material.
154 5. Monitoring and Trendin g: Conc rete cr acking, spall ing, an d los s of mate rial are detectable by visual inspection and based on operating ex perience, v isual in spection performed at least o nce every refueling outage de tects any si gn of degradation of the fire barrier w alls, ceil ings, and floors b efore there is a loss of the in tended function.
: 6. Acceptance Criteria
: Inspection re sults are acce ptable if there are...no visu al indication s of concrete cracking, sp alling and loss of material of fire barrier w alls, ceilings, an d floors;In rev iew ing thi s enha ncemen t, the p roject t eam not ed tha t, as p art of th e appl icant's fire protection aging man agement program, the aging effects on th e intended function of fire barrier walls, ceilings, and floors that perf orm a fire barrier f unction are managed using specific inspe ction parame ters i n acco rdance wit h ind ustry codes , stand ards, a nd gui deli nes th at ens ure aging degradat ion is detected and corrected prior to loss of intended functions. This enhancement w ill add enhanced in spections of fire ba rrier wal ls, ceili ngs, and floors lo ok for signs of degradation includin g but not limi ted to cracking, spal ling, and lo ss of material cau sed by freeze-thaw , aggressive che mical attack, reacti on with aggregates, and corrosion of embedded steel, as recomm ended in the GALL Report. Since these enhanced inspections will provide additional assurance that aging deg radation of fire bar rier walls, ceilings, and floors will be adequately managed, this en hancement is a cceptable.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.19 , "Fire Protec tion," wil l be c onsis tent w ith GALL AMP XI.M26 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.In reviewing the program basis docume nt, PBD-AMP-B.1.19, the audit team noted that there is a dis crepan cy be twee n OCGS LRA, S ectio n B.1.1 9, ?Fire Protection," and the prog ram basis document PBD-A MP-B.1.19, R ev. 0. The pro gram basis documen t stated an enh ancement related to peri odic vi sual inspe ctions of fire door surface integrity and clearanc e checks;howe ver, t his e nhanc ement i s not i nclud ed in the OC GS LRA , nor i s it a ddress ed in the OC GS reconcilia tion document.
The project team dis cussed this d iscrepancy with the applican t, and the applicant committed to add th is enhancement to the OCGS LRA.
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise AMP B.1.19 in the OCGS L RA to add th e foll owi ng enha ncemen t to the OCGS fir e prote ction program, related to peri odic vi sual inspe ctions of fire door surface integrity and clearanc e checks, as descri bed i n the p rogram ba sis do cument, PBD-A MP-B.1.19, to the OCGS LR A. This is A udit Commitment 3.0.3.2.16-1.
Enhan cement 4 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The fire protection aging management program w ill be e nhanced to require that surface integrity and clearances of fire doors in the scope of lice nse re newa l be r outin ely inspe cted e very two years. The program currently requires these d oors be intac t and veri fied 155 functional, w ith fire doors i dentified as se condary con tainment receivin g routine clea rance checks. Other fire doors in the scope of licen se renewal c urrent ly receive cle arance checks if they ha ve been damaged or u ndergone maintena nce such that the clearances may have bee n physica lly al tered. The enhan cement of requiring routine surface integ rity and clearance checks for all fire doors in th e scope of li cense renew al wil l provid e assurance that degradation of fire doors prior to loss of inte nded function will be detected.
The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and
?accept ance c riteri a" program e lement s asso ciate d wi th the enhan cement: 3. Parameters Moni tored or Inspected
: Fire-rated doo rs are visu ally i nspected on a plant specific interv al to veri fy the integrity of door surfaces and for clearances. The plant specific insp ection interv als are to be determined by engineering ev aluation to detect degradation of the fire doors prior to the loss of in tended function.
: 4. Detect ion o f Agin g Effec ts: Visu al in specti on by fire pr otecti on qual ified inspe ctors detect s any sign o f degrada tion o f the fire door s uch as wea r and m issin g parts. Perio dic v isual insp ectio n and functio n tests detec t degrad ation of the fi re doo rs befor e there is a l oss of intended function.5. Monitoring and Trendin g: Based on o perating expe rience, degraded integrity or clearances i n the fire door a re detectable by vis ual inspe ction performed on a plant-speci fic freque ncy. The v isual insp ectio ns det ect de gradati on of th e fire d oors prior to loss of the intended function.
: 6. Acceptance Criteria
: Inspection re sults are acce ptable if there are...no visu al indi catio ns of mi ssing p arts, h oles, and w ear an d no d eficie ncies in th e functi onal tests of fire doors.
In review ing this enha ncement, the project team noted that the applican t's fire protectio n aging management pr ogram will direct that fire doors in the scope of license renewal are to be visually inspected by designated qual ified personne l for signs of degradati on such as w ear, missing parts, holes, a nd clearance
: s. Functiona l/operational condition tests of fire doors are also conducted. In the progr am basis document, PBD-AMP-B.1.19 and in its respon se to an audit question, the app licant further state d that enhance ments to the program w ill dire ct visual inspe ction of fire d oors for integr ity o f door su rfaces a nd cl earanc e chec ks eve ry tw o yea rs. This inspecti on frequency ensu res the timely identificati on and correcti on of degraded door conditions prior to a l oss of intended function. The project team determined th at visual inspection of fire doors for signs of degrada tion such as wear, missi ng parts, holes, a nd clearances w ill prov ide additi onal assuran ce that the effects of aging are adequately man aged, as recommended i n the GALL Re port; therefore, this e nhancement is acceptable.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.19 , "Fire Protec tion," wil l be c onsis tent w ith GALL AMP XI.M26 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.
156 3.0.3.2.16.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e fire protection aging management program has been effective i n identifyi ng aging effects and taking approp riate correctiv e action. M inor degradation such as minor cracks h ave been detected in c oncrete componen ts in structures within the scope of li cense renew al. The observ ed degradation was ev aluated and disposit ioned bas ed on prog ram acc eptanc e criter ia and in acc ordanc e with the co rrect ive actio n proc ess. Th e appl icant's ex perie nce w ith fir e barri er pen etrati on sea ls is consi stent w ith the in dustry expe rienc e; sil icone foam fire barri er pen etrati on sea ls are used at Oys ter Cre ek. The applican t stated that it has experi enced fire door component degradati on due to w ear, loss of material due to corrosion, an d physica l damage and mi tigating actions have been taken as appropriate.
In the OCGS LRA , the appli cant stated that o perating expe rience has s hown no loss of material on the exte rnal sur faces of com ponent s in the halo n and carb on dioxide sys tems t hat have adversely affected system operati on.In the OCGS LR A, the appli cant a lso st ated th at the diese l-dri ven fi re pump fuel o il sy stems have experienced minor system events that have been detected and corre cted in a timely manner. These even ts we re ide ntifie d and correc ted pri or to l oss of i ntende d functi on of th e fire pumps. There have been no reports of loss of material or flow blockag e of the fuel oil subsystems.
In its program basi s document for the fire protection aging man agement program (PDB-AMP-B.1.19), the applicant stat ed that operating experience, bot h internal and external, is used to enhan ce plant programs, p revent repea t events, and prevent ev ents that hav e occurred at other plants from occurring at Oyste r Creek. Through its o perating expe rience rev iew process the app licant scree ns, evalu ates, and acts o n operating ex perience doc uments and information to prev ent or mitigate the consequences o f similar ev ents. In addi tion, the appl icant stated that its process for managing programs re quires the rev iew of program-rel ated operating experience by the pro gram owner. Bo th of these processe s review operating ex perience from both external and interna l (also referred to as in-hous e) sources. Ex ternal operati ng experienc e may include items such as INPO documents (e.g., SOERs, SERs, SENs, etc.), NRC documents (e.g., GLs, LER s, INs, etc.), General Electric d ocuments (e.g., RCSILs , SILs, TILs, etc.), and other d ocuments (e.g., 10CFR Part 21 Rep orts, NERs, etc.).
Internal operati ng experience may incl ude documents s uch as eve nt investi gations, trending re ports, and les sons learned from in-ho use events as captured i n program notebooks, sel f-assessments, and in the 10 CFR Part 50, Appendi x B correcti ve action process. Issue s and eve nts, whether external o r plant-speci fic, tha t are p otenti ally signi ficant t o the fi re prot ectio n progra m at OCGS are evaluated. The fire protectio n program is augmented , as appropria te, if these ev aluations s how that program changes are needed to e nhance program effective ness. The correcti ve action s program ensures that th e condition s adverse to quality a re promptly c orrected. If the defici ency is assessed to be significan tly adv erse to quality , the cause of the condition i s determined a nd a corrective a ction plan is devel oped to precl ude repetitio n.In the OCGS LRA, the applicant state d that the fire protec tion program has been ef fective in identifying aging ef fects and tak ing appropriate correct ive action. In its program basis docume nt (PD B-AM P-B.1.19) the appl icant further stated that th e oper ating e xperi ence o f fire protection program d id not show any adv erse trends in performance, those pro blems identi fied would not ca use sign ifican t impact to the saf e operat ion of t he plant, and adeq uate cor rective actions w ere taken to prev ent recurrence.
157 The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d the program b asis d ocumen t (PDB-AMP-B.1.19), and interv iew ed the appl icant's tech nical staff to confirm that the pl ant-specific ope rating experi ence did n ot reveal any degradati on not bound ed by i ndustr y ex perie nce. The fire pr otecti on agi ng manage ment pr ogram ac tivi ties w ith enhancements de scribed abov e will be effective in managing aging degradati on for the period of extended op eration by providi ng timely de tection of aging effects and i mplementing appropriate co rrective acti ons prior to l oss of system or c omponent inten ded functions.
On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's fire protection program will adequately manage the aging effects that are identified i n the OCGS LRA for which thi s AMP i s credited.
3.0.3.2.16.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e fire protection prog ram in OCGS LRA, Appendix A, Section A.1.19, which stated that the fir e protection aging man agement prog ram is an ex istin g program that i nclud es a fir e barri er ins pecti on pro gram and a die sel-d rive n fire p ump inspection program. The fire barrier i nspection pro gram requires periodi c visual inspection of fire barrier penetr ation seals, fire wraps, fire barrier walls, ceilings, and floors, and periodic visual inspection and functional tests of fire rated doors to ensur e that their operability is mainta ined. The pro gram inc ludes surv eill ance t ests of fu el oi l sy stems for the di esel-driv en fire pumps to ensure that the fuel supp ly lin es can perform inten ded functions. The program also incl udes v isual insp ectio ns and perio dic o perabi lity tests o f halon and c arbon diox ide fi re suppression systems based on NFPA c odes.In the UFSAR Supplement for the fire protection program in OCGS LRA , Appendix A, Section A.1.19, the appl icant stated th at prior to the period of exte nded operatio n the fire protecti on aging management program w ill be e nhanced to i nclude: 1.Speci fic fuel suppl y in specti on cri teria for fire p umps du ring te sts 2.Inspection of ex ternal surfaces of the halon and carbon diox ide fire suppre ssion syste ms 3.Additional inspection criteria for degrada tion of fire barrier walls, ceilings, an d floors The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 19 of the commitments.
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise AMP B.1.19 in the OCGS L RA to add th e enha ncemen t disc ussed in the program basis docume nt, PBD-AMP-B.1.19, to require periodic v isual in spections of fire do or surface integrity and clearance ch ecks. This is Au dit Co mmitment 3.0.3.2.16-1. The applica nt's licen se renewal commitme nt li st and UFSA R supp lement are to be rev ised to refle ct thi s new commit ment.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.19. Contingent up on the inclusi on of commitment 3.0.3.2.1 6-1, the project tea m found that it w as consistent with the GALL Report, and determined tha t it provi des an adequate summary descri ption of the 158 program, as identi fied in the S RP-LR FSAR Supplement ta ble and as required by 10 CFR 54.21(d).3.0.3.2.16.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects for whi ch it is cre dited. Als o, the project team has revie wed the enhancements an d determined th at the implemen tation of the enh ancements prior to the period of exte nded o perati on w ould resul t in th e exi sting A MP b eing co nsiste nt wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and, contingen t upon the i nclusion o f commitment 3.0.3.2.16-1, found that it prov ides an ade quate su mmary d escrip tion o f the pro gram, as require d by 10 CFR 54.21 (d).3.0.3.2.17 Fire Water System (OCGS AM P B.1.20)In OCGS LRA, Appen dix B, Sec tion B.1.120 , the a ppli cant st ated th at OCGS AMP B.1.20 , "Fire Water Syste m," is a n exi sting p lant p rogram th at is consi stent w ith GA LL AM P XI.M 27, "Fi re Water System," with enhan cements.3.0.3.2.17.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program wi ll manage id entified aging effects for the water-based fire prot ection system and associated component s, through the use of periodic inspections , monitoring, and performance testing. The p rogram includes preventiv e measures and inspecti on activi ties to detect aging effects prior to los s of intended functi ons. System functional tests, flow tests, flushe s and inspe ctions are pe rformed in accordanc e with gui dance from NFP A stan dards. Fire syste m main heade r flow tests a re con ducted at le ast on ce ev ery three yea rs. Hydra nt flus hing and inspect ions are c onduct ed at leas t once ever y twelve months. The condi tion of the fire pump s is confirmed o nce every 18 months by performance of a pump functio nal te st. The redund ant w ater st orage ta nk is i nspect ed onc e eve ry 5 y ears. Sprinkler sy stem inspectio ns are performed at l east once ev ery refueling o utage. The fire wa ter system is mai ntained at the required normal operating pressure and monitored such that a l oss of system pressure is immediatel y detected a nd correctiv e actions i nitiated. P eriodic w ater samples wi ll be tested to detect the p resence of MIC. The program wi ll be enh anced to inc lude volumetric inspections using appropriat e techniques on system piping to monit or pipe wall thickness and e valuate i nternal pip e condition
: s. The system flow testing, vis ual inspe ctions and volumetric inspections assure that the aging effects of reduction of he at transfer and los s of material due to corrosion, M IC, or biofouli ng are managed such that the syste m intended functions are mai ntained.3.0.3.2.17.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.20 is cons istent wi th GALL AMP XI.M 27, with enhancements.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.20, incl uding program b asis d ocumen t, PBD-AMP-B.1.20 , ?Fire Water System," Rev. 0 , which 159 provi des an asses sment o f the AM P ele ments' c onsis tency wit h GALL AMP XI.M2 7. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.20 and a ssoci ated b ases d ocumen ts to determine consi stency w ith GALL AM P XI.M27.The pro ject tea m also revi ewed the ap plic ant's proce dure 1 01.2, R ev. 5 4, ?Oyster Creek S ite Fire P rotecti on Pro gram," an d proc edure CC-AA-211, R ev. 1 , ?Fire P rotecti on Pro gram," to determine consi stency w ith GALL AM P XI.M24.The project team rev iewed th ose portions of the fire water s ystem program for wh ich the appli cant cl aims c onsis tency wit h GALL AMP XI.M2 7 and found th at they are co nsiste nt wi th the GAL L Repo rt AM P. The project team fou nd tha t the a ppli cant's fire w ater sy stem pro gram conforms to the recommende d GALL AM P XI.M27, "Fi re Water System,"with the enha ncem ents desc ribe d belo w.3.0.3.2.17.3 Exce ption s to th e GALL Repor t None.3.0.3.2.17.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancements in order to mee t the GALL Report program e lements: Enhan cement 1 Elements: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The fire water sy stem aging management program w ill be enhanced to i nclude peri odic non-in trusive w all thickness measurements of selec ted portions o f the fire water sy stem at intervals that do not ex ceed every 10 years.
The GALL Report i dentified the foll owing recommend ations for the
?preve ntiv e acti ons,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"and ?accept ance c riteri a" progr am ele ments a ssoci ated w ith th e enha ncemen t: 2. Preventive A ctions: To ensure no s ignificant corrosi on, MIC, or biofouling has occurred in w ater-based fire prote ction syste ms, periodic flu shing, system pe rformance testing, and in spections may be conducted
.3. Parameters Moni tored or Inspected
:  Loss of material due to corrosi on and bio fouling could reduce wall thickness of the fire pro tection pipi ng system and re sult in sy stem failure. Theref ore, the parameter s monitored are the system's ability to maintain pressure and i nternal sys tem corrosion co nditions. P eriodic flow testing of the fire w ater system is pe rformed using the guide lines of NFP A 25, or w all thickness evaluati ons may be performed to ensu re that the sy stem maintains its intended function.
160 4. Detect ion o f Agin g Effec ts:  Wall thi ckness eval uatio ns of fire protec tion p ipin g are performed on system components using non-intr usive techniques (e.g., volumetric testing) to identi fy eviden ce of loss of materia l due to co rrosion.5. Monitoring and Trendin g:  Degradation i dentified by non-intrusiv e or internal inspection is eval uated.6. Acceptance Criteria
:  No unacce ptable signs of degradation obse rved durin g non-intrusiv e or visu al assessment of internal sy stem condition s.In review ing this enha ncement, the project team noted that the applican t's fire wate r system aging ma nagemen t progra m wil l mana ge ide ntifie d agin g effects for the w ater-ba sed fire protection sy stem and associ ated components, through the use of pe riodic in spections, monitoring, and p erformance testing. The pro gram includes p reventiv e measures and inspection activiti es to detect agin g effects prior to loss o f intended function
: s. System functional tests, flow tests, flushe s and inspe ctions are pe rformed in accordanc e with gui dance from NFP A stan dards. This e nhanc ement w ill add v olumet ric i nspect ions using a ppropr iate techniques on s ystem pipi ng to monitor pip e wall thickness and evaluate internal pi pe conditions, as recommende d in the GALL Report. Since the addition of non-intr usive wall thickness measuremen ts of selected po rtions of the fire w ater system w ill prov ide additi onal assurance that th e effects of aging will be adequately managed, the project team determined that this enha ncement is acc eptable.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.20 , "Fire Water Syste m," wi ll be consi stent w ith GALL AMP XI.M27 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 2 Eleme nt: 2. Preventi ve Action s Enhan cement: The fire water sy stem aging management program w ill be enhanced to i nclude peri odic wa ter sampling of the fire water system for th e presen ce of MIC, at inter vals not to exceed every 5 years The GALL Report i dentified the foll owing recommend ation for the
?Preventiv e Actions" pro gram elemen t assoc iated wit h the e nhanc ement: 2. Preventive A ctions:  To ensure no significant corrosi on, MIC, or biofouling has occurred in w ater-based fire prote ction syste ms, periodic flu shing, system pe rformance testing, and in spections may be conducted
.In review ing this enha ncement, the project team noted that the applica nt's fire wa ter system aging management program inc ludes prev entive ac tions to precl ude build up of significant corrosion, M IC or biofouli ng by prov iding for period ic flushing, sy stem performance testing, an d inspections to identify these degr aded conditions prior to loss of system intend ed function. This enhancement w ill add water sampl ing for the presence of MIC ev ery 5 ye ars, as recommended in the GALL R eport. Since the additi on of water sa mpling for the presen ce of MIC w ill prov ide 161 additional assurance that the effects of aging wil l be adequatel y managed, the p roject team determined that this enhance ment is accepta ble.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.20 , "Fire Water Syste m," wi ll be consi stent w ith GALL AMP XI.M27 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 3 Eleme nt: 4. Dete ction of Agin g Effects Enhan cement: The fire water sy stem aging management program w ill be enhanced to i nclude in spection of spri nkler heads before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the e xtended pe riod of operatio n to ensure tha t signs of degra dation, such as corrosion, are det ected in a timely manner.The GALL Report i dentified the foll owing recommend ation for the
?Detection of Agin g Effects" program e lement assoc iated wit h the e nhanc ement: 4. Detect ion o f Agin g Effec ts:  Sprinkler he ads are insp ected before the en d of the 50-year spri nkler head serv ice life and at 10-year intervals thereafter during the exten ded pe riod o f operat ion to ensur e that signs o f degrada tion, such a s corro sion, are detected in a timely man ner.In review ing this enha ncement, the project team noted that the applican t's fire wate r system aging ma nagemen t progra m wil l mana ge ide ntifie d agin g effects for the w ater-ba sed fire protection sy stem and associ ated components, through the use of pe riodic in spections, monitoring, and p erformance testing. The pro gram includes p reventiv e measures and inspection activiti es to detect agin g effects prior to loss o f intended function
: s. System functional tests, flow tests, flushe s and inspe ctions are pe rformed in accordanc e with gui dance from NFP A stan dards. Spri nkler s ystem inspe ction s are p erformed at lea st once ever y refueling outage. This enhancement w ill inc lude 50-y ear sprinkler he ad inspecti ons using the guidance of NFPA 25 ?Standard for the Insp ection, Testing an d Mainte nance of Water-Based Fire Protecti on Systems" (1 998 Editio n), Section 2
-3.1.1. Represen tative sampl es wil l be submitted to a testing laboratory prior to being in service 50 years. Thereaf ter, this testing will be rep eated on a fre quency of once ever y 10 years durin g the ex tended perio d of ope ration to ensure that si gns of degradation, such as corrosion , are detected i n a timely manner. Initi al inspections will be performed prior to the sprinkler heads being i n service for 50 years. S ince the additio n of 50-year sp rinkler head i nspections w ill prov ide additi onal assuran ce that the effect s of aging are adeq uately managed, the projec t team determined that this enhancement is acceptable.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.20 , "Fire Water Syste m," wi ll be consi stent w ith GALL AMP XI.M27 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.
162 Enhan cement 4 Eleme nt: 1. Program Scope Enhan cement: The fire water sy stem aging management program w ill be enhanced to i nclude v isual in spection of the re dundant fire w ater storage tank heater duri ng tank internal i nspections.
The GALL Report i dentified the foll owing recommend ation for the
?program scope" program elemen t assoc iated wit h the e nhanc ement: 1. Program Scope
:  The AMP focuses on managin g loss of material due to corrosi on, MIC, or bio foulin g of carbo n stee l and cast i ron co mponen ts in fire pro tectio n sys tems expo sed to wate r.In review ing this enha ncement, the project team noted that the applican t's fire wate r system aging ma nagemen t progra m wil l mana ge ide ntifie d agin g effects for the w ater-ba sed fire protection sy stem and associ ated components, through the use of pe riodic in spections, monitoring, and p erformance testing. The pro gram includes p reventiv e measures and inspection activiti es to detect agin g effects prior to loss o f intended function
: s. System functional tests, flow tests, flushe s and inspe ctions are pe rformed in accordanc e with gui dance from NFP A stan dards. The re dunda nt wa ter sto rage tan k is in specte d once ever y fiv e yea rs. This enhancemen t will include visual inspection of the redundant fire water storage tan k heater during tank interna l inspecti ons, as recommende d in the GALL Report. Si nce visua l inspecti on of the re dunda nt fire wate r stora ge tank h eater w ill provi de add ition al as suranc e that the effect s of aging are adeq uately managed, the projec t team determined that this enhancement is acceptable.
In review ing the program basi s document, PBD-AMP-B.1.20 , the audit tea m noted that Sec tion 2.4, ?Summary of Enhanc ements to NURE G-1801," states that th e Oyster Creek fire water system aging management program will be enhanced to includ e visual inspection of the water storage tank heater pres sure boundary components duri ng the periodi c tank internal inspe ction s. How ever, this enhan cement was n ot ide ntifie d or di scusse d in t he Sec tion 3.0 evaluati on of the indi vidual GALL aging management pro gram elements. Duri ng the audit, the applicant s tated that PBD-A MP-B.1.20 will be revise d to inclu de this enha ncement in the program b asis d ocumen t Secti on 3.1 , ?scope of progra m".The applicant stated that th e program basis documen t for AMP B.1.20, fire water system , will be revise d to add the enhancement for v isual in spection of the w ater storage tank heater pressure bound ary componen ts during the pe riodic tank i nternal insp ections to the
?scope of program" elemen t of the program.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.20 , "Fire Water Syste m," wi ll be consi stent w ith GALL AMP XI.M27 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.3.0.3.2.17.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e fire water s ystem aging management p rogram has been effectiv e in iden tifying aging effects and takin g appropriate co rrective acti on. In 2002, 163 a hydrant w as identified with si gnificant leakage bel ow ground w hen operated. The problem was disc overed duri ng the hydrant flush survei llance acti vity. The hydrant w as declared inoperable , but did no t affect the rest of the sys tem and was also consi dered avai lable for use in an emergency. The hydrant was repla ced with a new hy drant. In 2003, a leak was disco vered in a small diame ter coo ling w ater l ine a ssoci ated w ith th e #2 d iesel-driv en fire pump. A failure ana lysis p erformed on a sample of the failed pi ping determined that turbulent flow downstream of a 90/ elbow tended to remov e corrosion p roduct build up, and that co nstant remov al of co rrosio n prod uct bu ildu p wo uld e xpos e fresh m etal l eadin g to acc elera ted att ack. The preferential atta ck identified on the bottom of the pi pe suggests the attack might h ave been influenced by incomplete drainage follow ing pump operati on. The resulti ng stagnant lay-u p of fresh wa ter p rov ide s a fa vor abl e co ndi tion for M IC a ttac k. The con diti on c reat ed p in-h ole lea ks which h ave been repaired. As a result of thi s failure, NDE inspection s were performed at piping locations s ubject to simil ar condition
: s. Some addi tional smal l bore w all thinn ing has been identified, an d is bein g tracked for repair and replacement. The applicant s tated in the LRA that pump performance testin g, hydrant ins pection acti vities, a nd the correcti ve action process identified an d corrected these degraded condi tions prior to a loss of fire pro tection sys tem intended functio ns.In its program basi s document (PDB-AMP-B.1.20) the appli cant stated that th e fire water system is designed, inspected, t ested and maintained in accordance with the applicable NFPA minimum standards. The applic ant further stated that operating exp erience, both internal an d external, i s used to enh ance plant p rograms, prevent rep eat events, a nd prevent events that have occurre d at other pl ants from occurring at Oy ster Creek. Through its operating experience review process the a pplicant sta ted that it scre ens, eval uates, and acts on operating experience documents and information to prev ent or mitigate the consequences o f similar events. In a ddition, the applicant s tated that its p rocess for managing programs requi res the review of program related op erating experi ence by th e program owner.
Both of these processes rev iew ope rating experi ence from both ex ternal and i nternal (also referred to as in-ho use) so urces. Exte rnal o perati ng exp erien ce may incl ude su ch thi ngs as I NPO do cuments (e.g., SOERs, SERs, S ENs, etc.), NRC documents (e.g., GLs, LE Rs, INs, etc.), Genera l Electric doc uments (e.g., RCSILs, S ILs, TILs, etc.), and oth er documents (e.g., 10C FR Part 21 Reports, NERs, etc.). Internal o perating expe rience may include su ch things as ev ent investigations, trending reports, and lessons learned f rom in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction proces s. Issu es and even ts, wh ether e xtern al or plant-speci fic, tha t are p otenti ally signi ficant t o the fire water system aging management program at OCGS are ev aluated. The fire water system aging management program is augmented, as appropriate, i f these evalu ations show that program changes are needed to e nhance program effective ness. The correcti ve action s program ensures that th e condition s adverse to quality a re promptly c orrected. If the defici ency is assessed to be significan tly adv erse to quality , the cause of the condition i s determined a nd a corrective a ction plan is devel oped to precl ude repetitio n.In its program basi s document (PBD-AMP- B.1.2
: 0) the appli cant further stated that its revie w of operating exp erience of the fire water sys tem aging management program di d not show any adverse trend in fire wa ter system performance.
Problems id entified did not cause a l oss of the system intend ed function, and adequate correctiv e actions w ere taken to prev ent recurrence.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience. The fire wate r system aging managem ent program act ivities, with enhancements described above, will be effective in 164 managing aging degradatio n for the period of extended op eration by providi ng timely de tection of aging effects and implementi ng appropriate c orrective ac tions prior to loss of syste m or component inten ded functions.
On the basis o f its review of the above industry an d plant-speci fic operating ex perience and discussions with the applican t's technical staff, the project team determin ed that the app licant's fire water sy stem program wil l adequately manage the aging effects that a re identified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.17.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he fire wate r syst em progra m in OC GS LRA, Append ix A, Se ction A.1.20, w hich states tha t the fire wate r system program is an exis ting program t hat pro vide s for sy stem pre ssure m onito ring, fir e sys tem hea der flo w tes ting, p ump performance testing, hy drant flushing, w ater sampling an d visual inspection s activiti es. System flow tests measu re hydraul ic resistance and compare re sults wi th previou s testing, as a mea ns of evaluatin g the internal piping condi tions. M onitoring sy stem piping flow characteristic s ensures that si gns of internal pi ping degradation from significant corrosi on or fouling w ould be detected in a timely man ner. Pump performance tests, hydrant flushing and sy stem inspectio ns are performe d in accordance with applicable NFPA standards. A motor driven pump normally maintains fire water system press ure. Significant leaka ge (exceeding the capacity of this pump) w ould be id entifi ed by automa tic sta rt of the dies el dri ven fi re pump s, wh ich w ould initi ate immediate inv estigation and corrective action.The applican t further stated in th e LRA that the fire water sy stem aging management program wil l be e nhanc ed to i nclud e spri nkler h ead te sting i n acco rdance wit h NFP A 25, ?Inspection, Testing and M aintenance o f W ater-Based Fi re Protection S ystems."  Sampl es wil l be submitte d to a testing la boratory pri or to being in service 5 0 years. Thi s testing wi ll be repe ated at intervals not exceedi ng 10 years.
Prior to the p eriod of exten ded operation , the program wi ll be enhanced to i nclude w ater sampling for the presence of M IC at an inte rval not to exceed 5 years, perio dic non-intru sive w all thickness measurements of sele cted portions of the fire water syste m at an interv al no t to ex ceed e very 10 y ears, a nd vi sual inspe ction of the r edund ant fire water storage tan k heater during tank i nternal insp ections.The project team reviewed the UFSAR Supplement for OCGS AMP B.1.20, and found th at it was consi stent with the GALL Repo rt. The project team de termined that i t provides an adequate summary d escription o f the program, as identi fied in the S RP-LR FSAR Supplement table and a s requi red by 10 CF R 54.2 1(d).3.0.3.2.17.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. Also, the project team ha s review ed the enhan cements and determined that the implementati on of the enhanc ements prior to th e period of ex tended operation w ould result in the ex isting AM P being consi stent with the GALL Repo rt AMP to which it was co mpared. The project tea m also revi ewed the UFSAR Sup plement for this A MP and found that it prov ides an ad equate summary des cription of the program, as required by 10 CFR 54.21 (d).
165 3.0.3.2.18 Aboveground Outdoor Tanks (OCGS AM P B.1.21)In OCGS LRA, Ap pendix B , Section B.1
.21, the appli cant stated that OC GS AMP B.1.21,"Aboveground Ou tdoor Tanks," is a ne w plant program that is cons istent wi th GALL AMP XI.M 29, "Abovegroun d Carbon Stee l Tanks," with an excepti on.3.0.3.2.18.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program wi ll provi de for management of loss of material aging effects for outdoo r carbon steel and alumin um storage tanks. The program credits the ap plication of paint as a c orrosion prev entive meas ure and performs peri odic vi sual inspections to monitor degrada tion of the pai nt and any resulting metal degradation for the carbon steel tanks. The program wi ll incl ude periodi c visual inspection s of the above ground aluminum tank. P eriodic i nternal UT in spections w ill be p erformed on the bottom o f outdoor carbon steel tanks a nd the outdo or alu minum s torage t ank sup ported by e arthen/concre te foundations. The c arbon steel ta nks not directly supported by earthen or con crete foundations undergo externa l visua l inspecti ons witho ut the necessi ty of bottom surface UT i nspections.
The applican t also stated that the tanks supp orted by ea rthen/concrete foundati ons havi ng sealants/coati ngs at the tank-foundation interfaces wi ll be peri odically inspected for degradation. Fo r raised tanks no t directly supported by earthen or con crete foundations, inspect ion of t he sealan t or caulk ing at t he tank-fou ndation interf ace does not apply.
The program wil l require remov al of insula tion to permit visual inspection of insulated ta nk surfaces. Remova l of insulati on wil l be on a sampling basi s.The applican t further stated that the program wil l be imple mented prior to the period o f extended o peration. Tanks w ill be i nspected at an initial frequency of every five yea rs.3.0.3.2.18.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.21 is cons istent wi th GALL AMP XI.M 29, with an excepti on.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.21, incl uding program b asis d ocumen t OCGS P BD-AM P B.1.21, "Ab ovegro und Out door Ta nks,"Revisio n 1, whi ch provid es an assessmen t of the AMP elements' consi stency w ith GALL AMP XI.M 29. Specifica lly, the project team revi ewed the program elements (see Section 3.0.2.1 of this aud it and rev iew repo rt) contained i n OCGS AMP B.1.21 and a ssociated ba ses documents to dete rmine consiste ncy wi th GALL AM P XI.M29.The pro ject tea m also revi ewed OCGS d ocumen ts SP-1 302-52-108, ?Inspec tion o f Tanks,"Revi sion 3, and MA-A A-716-210, ?Performance Centered Maintena nce Process," R evision 2, that provid ed guidance re garding the abov eground tanks program and the tanks ranking and schedule for in spection.The project team rev iewed th ose portions of the aboveground outdoor tanks program for w hich the applica nt claims con sistency w ith GALL AM P XI.M29 and found that they are consiste nt with the GALL Report AM P. The project team found that the app licant's a boveground ou tdoor 166 tanks program conforms to the rec ommended GALL AM P XI.M29, w ith the ex ceptions desc ribe d belo w.3.0.3.2.18.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Exception 1 Elements: 1. Scope of Program
: 2. Preventi ve Action s Exception : The Oyster Creek pro gram includes i nspection of the outdoor aluminum storage ta nks. Due to corros ion resistan ce properties of aluminum, these tanks are not pai nted.The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
: 1. Scope of Prog ram: The pr ogram co nsists of (a) p reven tive measur es to mi tigate corrosion by protecting the ex ternal surfaces of carb on steel tanks p rotected wi th paint or coatings and (b) periodic system wal kdowns to mana ge the effects of corrosion on the intended function of these tanks.
Plant wa lkdowns cov er the entire outer surface of the tank up to i ts surface in con tact with s oil or con crete.2. Preventive A ctions: In ac cordan ce wi th ind ustry practi ce, tan ks are c oated with protective p aint or coati ng to mitigate corrosi on by prote cting the exte rnal surface of the tank from environmental exposure.
The applican t stated, in the OCGS LRA, that the Oyster Cree k program includes the outdoor aluminum storage ta nks in additi on to the carbo n steel tanks. D ue to corrosio n resistance properties of al uminum, the tanks are not painted. For alumin um tanks, the aging management program includes visual inspection s, sealants/coa ting examina tion at the tan k foundation interfaces, and pe riodic UT i nspections o n the tank bottom. On the basis of i ts review of operating exp erience for the a boveground ou tdoor tanks program (see S ection 3.0.3.2.1 8.5, below), the project team f ound this exception to be acceptable since the exception appropriately adds a lumin um tanks to the scope of the a ging man agement program.The project team rev iewed th is excepti on and concl uded that it is acceptabl e to inclu de aluminum tanks in this prog ram because it adds aluminum tank within the scope of the AMP.
The staff finds that it is also accepta ble to not p aint alumin um tanks because e xperience has shown that aluminum does not rust wh en expose d to atmospheric conditions
.In the program b asis d ocumen t, the a ppli cant st ated th e foll owi ng exc eptio n to th e GALL Repor t program elements:
Exception 2 Eleme nt: 5. Monito ring and Trendin g
167 Exception: The spe cified freq uency by the Oyster Cr eek pr ogram is every 5 years in place of syste m walkdow ns each outage.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
: 5. Monitoring and Trendin g: The effects of corrosion of the aboveground e xternal surface are detectabl e by vi sual techni ques. Based on operating ex perience, pl ant system wal kdowns durin g each outage prov ide for timely detection of agin g effects.
The applican t stated, in the program basis do cument, the frequency of 5 years spe cified for monitoring of exte rior surfaces of tanks is consistent w ith the frequency specified for ex terior surfaces of supporting struc tures. The 5 y ear frequency is consistent w ith industry guidelines and has prov en effective in detecting loss of material due to corrosion, an d change in mate rial properties of str uctural elastomers on exterior sur faces of str uctures. Consequent ly this frequency wil l also be effective for detectin g loss of material and change in material prop erties on exterio r surfaces of tank before an i ntended function is impacted.
The project team questio ned the sched ule for conducti ng the walkdow ns and asked i f the schedule i s consistent w ith the GALL re commendation. The applicant s tated that they use structured inspe ctions eve ry five y ears rather than system wal kdowns ev ery outage and that this is an exception to the GALL reco mmendation. The a pplicant sta ted that the in spection frequency is con sistent wi th the practica l life of the coa tings and the i ndustry appl ication of the structures monitori ng programs in respon se to the M aintenance R ule. The project team found this excep tion to GALL to be acceptabl e, because i t meets the requiremen ts of the Mai ntenance Rule. How ever, the pro ject team noted tha t the appli cant has not i dentified this exceptio n in the OCGS LRA.In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the aboveground o utdoor tanks program (B.1.2
: 1) in the OCGS LRA to incl ude the ex ception identified i n the program basi s document, w hich states tha t the specified frequency by the Oyster Creek p rogram i s eve ry 5 y ears i n pla ce of sy stem w alkdow ns eac h outa ge. This is Aud it Commitment 3.0.3.2.18-1
.On the basis o f its review of operating ex perience for the Aboveground Outdoor Tanks program (see Section 3.0.3.2.18.5, bel ow), the proje ct team found this e xception to be acceptab le based on industry experien ce and operati ng experienc e.3.0.3.2.18.4 Enhan cements None.3.0.3.2.18.5 Operating Expe rience The applican t stated, in the OCGS LRA and the program basis document, that the aboveground o utdoor tank inspe ction program is a new pro gram being implemen ted at Oyster Creek, and therefore, no program experi ence exi sts. It wil l replace selective inspection s and will complement those activiti es in pla ce for tank management of petrol eum and other hazardous a boveground an d buried tan ks. The program is base d on indus try guidance and the GALL program for above ground carbon stee l tanks. How ever, speci fic plant ex perience doe s exist. Co rrosion of the con densate storage tan k was prev iously detected.
168 On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's aboveground outdoo r tanks p rogram w ill adequa tely manage the agi ng effects that ar e ide ntifie d in OC GS LRA for whi ch this AM P is credi ted during the p eriod of exten ded operation
.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.The staff believes that the correctiv e action proc ess wil l capture in ternal and e xternal pl ant operating issue s to ensure tha t aging effects are adequately managed.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's aboveground outdoor tanks program w ill adequate ly manage the aging effects that are ide ntified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.18.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e  Aboveground Outdoor Tank s program in OCGS LRA , Ap pend ix A, S ecti on A.1.2 1, w hic h sta ted t hat t he A bov egrou nd Ou tdoo r Tan ks program is a new program that wi ll manage corros ion of outdoor c arbon steel a nd aluminum tanks. Paint i s a corrosion preventiv e measure, and periodic v isual in spections of the exterior surface will monitor degradati on of the paint and any re sulting metal d egradation of carbon steel tanks or the unpainted aluminum tank. In scope carbon steel tanks are b oth supported b y structural steel and by e arthen or concre te foundations. The aluminum tank i s supported by an earthen foundation. Therefore, inspecti on of the seala nt or caulking at the tank-foundation interfa ce, an d UT in specti on of i nacces sibl e tank l ocati ons su ch as o n-grade tank bo ttoms apply on ly to thos e tanks on earthen and concrete pads. UT insp ections w ill als o be performed on the tank-f oundation where caulking or sealants are used.
Removal of insulation will permit visual inspection of insulated ta nk surfaces and caul king. This new inspection program wil l be implemented pri or to the peri od of extended operation.
The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, an d confirmed that thi s program is ide ntified as a n ew program that w ill be implemented pri or to the peri od of extended operation a s item 21 of the c ommitments.
As stated in Audit Commitment 3.0.3.2.18-1, the a pplicant co mmitted to revi se the aboveground o utdoor tanks program (B.1.2
: 1) in the OCGS LRA to incl ude the ex ception identified i n the program basi s document, w hich states tha t the specified frequency by the Oyster Creek program i s every 5 years i n place of sy stem walkdow ns each outage.
The applicant' s license renewal commitment list a nd UFSAR supplement are to be revi sed to reflect this n ew co mmitment.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.21. Contingent up on the inclusi on of Audit Co mmitment 3.0.3.2.18.1, the project team found tha t it was consistent with the GA LL Rep ort. The projec t team d etermi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).
169 3.0.3.2.18.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd, contingent up on the incl usion of Audi t Commitment 3.0.3.2.18
.1, found that it prov ides an ad equate summary des cription of the program, as required by 10 CFR 54.21 (d).3.0.3.2.19 Fuel Oil C hemistry (OCGS A MP B.1.22)In the OCGS LRA , Appendix B, Section B.1.22, the appl icant stated th at OCGS AMP B.1.22,"Fuel Oil C hemistry," is an existi ng plant program that i s consistent w ith GALL AM P XI.M30,"Fuel Oil C hemistry," w ith excep tions and en hancements.
3.0.3.2.19.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program's acti vities a re preventi ve activ ities that provid e assurance tha t contaminants a re maintained at acceptabl e level s in fuel oi l for systems and c omponents wi thin the scop e of license renewal. The fuel oil tanks within the scope of license renewal are maintained by monitoring and cont rolling fuel oil contaminants in accordance w ith the guidel ines of the Ameri can Society for Testing and M aterials (AS TM). Fuel oil sampling activities meet the intent of ASTM D 4057-95 (2000). Fuel oil will be routinely sampled and analyz ed for particula tes in accord ance wi th modified ASTM Standard D 2276-00 Met hod A, a nd fo r the pres ence of w ater and sed imen t in acc orda nce wi th A STM Standa rd D 27 09-96. Fuel oil sampli ng and analy sis ar e perfor med in accord ance w ith approved p rocedures for new fuel and stored fuel. Fuel o il tanks are p eriodicall y drained of accumulated water and sediment, and will be periodically drained, cleaned, and internally inspected. These activities eff ectively manage the effe cts of aging by providing reason able assurance that p otentially harmful contaminan ts are maintai ned at low concentration s.3.0.3.2.19.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.22 is cons istent wi th GALL AMP XI.M 30, with exceptions and enhance ments.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.22, incl uding basis docume nt PBD-AMP-B.1.22 , ?Fuel Oil C hemistry," Rev ision 0, w hich prov ides an assessment of the AMP el ements' consisten cy wi th GALL AM P XI.M30. S pecifically , the project team revi ewed the program elements (see Section 3.0
.2.1 of this audi t and revi ew report) contained in OCGS AMP B.1.22 and associated bases documents to determ ine their consistency with GALL AMP XI.M 30.In reviewing this AMP, the project team noted that th e program descript ion in the OCGS LRA for AMP B.1.22 stated that fuel o il wi ll be routi nely sampl ed and anal yzed for parti culates and for the presence of w ater and sedi ment; howev er, the frequency of thes e activi ties was not discussed. The applican t was asked to provide the frequency of these activiti es.
170 In its response , the appli cant stated that th e sample frequencie s, sample loc ations, and accept ance c riteri a are i nclud ed in OCGS p rocedu re 828.7, ?Secondary Systems Anal ysis: Plant Oil."  All analy sis frequ encie s are qu arterl y or m ore frequ ent, i n acco rdance wit h NURE G-1801, AMP XI.M3 0, wh ich st ates i n progra m eleme nt 5 th at bas ed on indus try operating exp erience, quarterly sampling and analysi s of fuel oil p rovide for timel y detection of conditions conducive to corrosion. The proj ect team reviewed OCGS procedure 828.7, as well as GALL AM P XI.M30, w hich confirmed th at the appli cant's sampli ng frequency is con sistent the recommendation s in the GALL Report. On thi s basis, the project team determin ed that the applicant' s sampling frequency was acce ptable.The project team further note d that the program de scription i n the OCGS LRA for AMP B.1
.22 states that fue l oil tanks are periodically drained of accumulated water and sediment , and will be periodi cally d rained, clea ned, and in ternally inspected. H owever, the tanks on w hich these activiti es woul d be performed w ere not iden tified. The appl icant was asked to prov ide additi onal information on the tanks include d in the sco pe of these activ ities.In its response , the appli cant stated that th e followi ng implementing ac tivities address the perio dic d raini ng of acc umulat ed w ater an d sedi ment:*Rec urri ng ta sk w ork o rder R08 0158 4 (T-9-103 , fire pon d di esel fuel oil stor age t ank ?A")is perf ormed quart erly.*Rec urri ng ta sk w ork o rder R08 0158 6 (T-9-104 , fire pon d di esel fuel oil stor age t ank ?B")is perf ormed quart erly.*Recurring task w ork order R204544 9 (T-36-1, fuel oil storage tank) is performed quart erly.*Recurring task work order R2044252 (T 2, diesel generator f uel oil storage tank) is perf ormed quart erly.The applicant furth er stated that the f ollowing implementing activities address the periodic draining, cle aning, and in ternal inspe ction:*Rec urri ng ta sk w ork o rder R20 6056 9 (T-9-103 , fire pon d di esel fuel oil stor age t ank ?A")will be performed every 5 years b ased on the
?Tanks" mai ntenan ce temp late, criti cali ty determination, duty cycl e, and servi ce conditio n.*Rec urri ng ta sk w ork o rder R20 6057 0 (T-9-104 , fire pon d di esel fuel oil stor age t ank ?B")will be performed every 5 years b ased on the
?Tanks" mai ntenan ce temp late, criti cali ty determination, duty cycl e, and servi ce conditio n.*Recurring task w ork order Rxx xxx(ne w) (T-36-1, main fuel oil stora ge tank) will be performed every 10 years b ased on the
?Tanks" mai ntenan ce temp late, criti cali ty determination, duty cycl e, and servi ce conditio n*Recurring task work order R2042556 (T 2, diesel generator f uel oil storage tank) is currently pe rformed every 1 0 years ba sed on the
?Electro-Mo tive Di vision Diesel Generator" maintena nce template, cri ticality determination , duty cy cle, and serv ice condition.
171 The applican t further stated that the EDG fuel oil storage tank (T-39-2) w as last open ed, cleaned, and inspected i n October/Nove mber 2004.
The applicant was asked when the draining, cleaning, and inspection of the main fuel oil storage tank and the fire pond dies el fuel oil tanks woul d be initi ated. In its re sponse, the applicant stated that the task s for draining, cleaning , and internally inspecting these tanks will be performed prior to the period of extended op eration.Based on the applican t's responses, the project determi ned that all of the major fuel oil tanks at OCGS w ill be dra ined of wate r and s edimen t on a quarterl y bas is, w hich is rea sonab le to mini miz e co ntac t tim e w ith the t ank b otto m. Fu rthe r, th e fir e po nd d ies el fu el o il s tora ge ta nks wi ll b e dra ine d, cl eane d, an d in tern all y i nspe cted eve ry 5 yea rs, a nd th e mai n fue l oi l st orage tank and the EDG fuel oil stora ge tank will be drained , cleaned, an d inspected every 10 years, which i s reasonable to ensure that aging degradation i s adequately managed. The performanc e of these activities on a periodic basis is consistent with the recomme ndations in the GAL L Repo rt. Thes e acti viti es wi ll be performe d prio r to the perio d of ex tended opera tion. The only fuel oil tanks no t included in these acti vities a re the diesel generator day tanks, and they are ad dressed in a program excepti on, which is discus sed below. On this basi s, the project team de termin ed tha t the a ppli cant's progra m activ ities for drai ning w ater an d sedi ment, as well as for drainin g, cleaning, and inspecting the fuel oil stora ge tanks are acceptab le.The project team rev iewed th ose portions of the fuel oil chemistry program for w hich the appli cant cl aimed consi stency wit h GALL AMP XI.M3 0 and found th at they are co nsiste nt wi th the GALL Repo rt AMP. The project team found that the applica nt's fuel oil chemistry p rogram conforms to the recommende d GALL AM P XI.M30, "Fue l Oil Che mistry," wi th the excep tions and en hanc emen ts de scri bed be low.3.0.3.2.19.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xceptions to the GALL Re port program elements: Exception 1: Elements: 1. Scope of Program
: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: NUREG-1801 i ndicates that fuel oil tanks s hould be s ampled for water and sediment, biol ogical activ ity, and p articulate on a periodic ba sis, and that multileve l sampling of tan ks should be performed. Mul tilevel sampling and tank bottom samplin g of the Emergency Diesel Generator (EDG) Day Tanks are not rout inely performed at Oyster Cre ek. The EDG Day Tanks do not hav e the capabili ty of being sampl ed, howev er, these tanks are supplied directly from the EDG Fuel Storag e Tank, which is routinely sampled and analyzed.
The EDG Da y Tanks are smal l in size and experi ence a high tu rnover rate o f the fuel stored w ithin as a 172 result of routine engine operati ons. Stratificati on of fuel is not likely to occur in the EDG Day Tanks d ue to the hi gh turnover rate. Ad diti onal ly, the Emer genc y D ies el G ener ator Day Tanks are skid mounted on the Emergency Diesel Gen erator skid and are en close d wi thin t he di esel enclo sure, w hich is mai ntain ed at a constant temperature during cold p eriods through o peration of the Emer genc y D ies el G ener ator keep war m sy stem. M ain tain ing a constant temperature during cold p eriods mini mizes Emergency Diesel Gene rator Day Tank the rmal cycli ng and reduces th e potential for con densation formatio n withi n the Day Tanks. The routine drai ning of water an d sediment from the b ottom of the Day Tank s is there fore not neces sary.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?preve ntiv e acti ons," ?parame ters mon itored or in specte d," ?detect ion o f aging effec ts,"?monitoring and tre nding," and
?acceptance cri teria" program elemen ts associated with the exception taken: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 2. Preventive A ctions: The qual ity o f fuel oi l is mainta ined by ad ditio ns of bi ocide s to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibito rs to mitigate corros ion. Perio dic cleani ng of a tank allow s removal of sediments, and p eriodic drai ning of water co llected at th e bottom of a tank mini mizes the amo unt of w ater an d the l ength o f contac t time. Accor dingl y, the se meas ures a re effective in miti gating corrosion i nside die sel fuel oil tanks. Coatings, i f used, prevent or mitigate corrosion by protecti ng the internal surfaces of the tank from contact with w ater and microbio logical organi sms.3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic 173 thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.5. Monitoring and Trendin g: Water and biological ac tivity or particulate contamination concentrations are monitored a nd trended i n accordance with the plant's tech nical specifications or at least q uarterly. Based on industry operating experience, q uarterly sampli ng and analy sis of fu el oi l prov ides for timel y det ectio n of con ditio ns con duciv e to corros ion o f the in ternal surface of the d iesel fuel o il ta nk before the po tentia l los s of its intended functio n.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 62 17 and Modified D 2276, M ethod A are u sed for guidance for de termination of parti culates. The modification to D 2276 cons ists of using a fil ter with a pore siz e of 3.0 mm, instead of 0.8 mm.The project team noted that, as part of the justification for thi s exceptio n, the OCGS LRA stated that the EDG day tanks experi ence a high tu rnover rate o f fuel, and that stratifica tion of the fuel is not li kely to occur due to this h igh turnover ra te. The appli cant was a sked to provi de additional information as to what the day tank fuel turn over rate i s and the bas is for concludi ng that st ratific ation wou ld no t occur.In its response , the appli cant stated that th e EDG day tanks are small in size (130 gallons) and expe rienc e a hi gh turno ver ra te of the fuel st ored w ithin as a r esult of routi ne engi ne ope ration s. During diesel generator load testing, approxi mately 200 gallons of fuel oi l wil l be consumed (approximatel y 1 hour o f operation at 20 0 gallons pe r hour). Depen ding on the da y tank lev el (normal lev el is abo ve 1/4 full), the day tan k contents may turn over multip le times duri ng load testing, which is perform ed every 14 days. Stratification of fuel is not likely to occur in the EDG day tanks due to this hi gh turnover rate.
Additiona lly, the EDG day tan ks are skid mounted on the EDG skid an d are enclos ed withi n the diesel enclosure, w hich is mai ntained at a constant temperature during c old period s through operatio n of the EDG keepw arm system. M aintainin g a constant tempera ture during col d periods mi nimizes E DG day tank the rmal cycli ng and reduces the po tential for conde nsation formation within the day tan ks.The project team rev iewed th e applica nt's response and determined that the turnov er rate for the da y tan ks is re asona ble, a nd w ill preve nt stra tificat ion o f the fuel stored in th e day tanks. Furthe r, the e nclos ed lo catio n of the day tanks to gether w ith th e use of the E DG keepw arm system to mini mize thermal cycling of the tanks will reduce the po tential for conde nsation forming inside the tan ks. On this basis, the proj ect team determined th at the applicant's conclusion regarding day tank turnover rate is acceptabl e.Upon further revi ew of this e xception, th e project team note d that part of the jus tification is that the EDG day tanks are suppl ied by th e EDG fuel storage ta nks, which a re routinely sampled and analy zed. The app licant w as asked to prov ide additi onal information on the frequency of these activ ities.In its response , the appli cant stated that th e followi ng analyses are performed for the ED G fuel stor age t ank:
174*Weekly - partial on-site lab fuel oi l analy sis, (API gravi ty, water and sediment, a nd kinem atic visco sity)*W eekly - complete off-site lab fuel oil analysis (particulate contamination, bacteria, API gravi ty, w ater an d sedi ment, ki nemati c vi scosi ty, su lfur con tent, fl ash po int, c loud point , ash, distil lation tempera ture, cetane in dex, carbon residue, and copper strip c orrosion)*After transf er from the main f uel oil tank - partial on-site lab fuel oil analysis, (API gravit y, water and sedimen t, and k inemat ic viscosit y)*Mont hly - oxi datio n stab ilit y*Monthly - water a nd sediment (b ottom sample)
The applicant furth er stated that fue l deliveries to the main fuel oil tank or directly to the EDG fuel storage tank are sa mpled as follo ws:*On-site water and sediment and API gravi ty analy sis before the tan ker unloads
*Complet e off-site lab fuel oil an alysis (par ticulat e contam ination, bacter ia, API g ravity, water and sediment, kinemati c viscosi ty, sulfur conten t, flash point, cl oud point, a sh, distilla tion temperature, c etane index , carbon resid ue, and coppe r strip corrosi on)The applican t further stated that al l frequencies are less than tha t specified i n NUREG-1801
, AMP XI.M 30, which stated in pro gram element 5 that b ased on in dustry operati ng experienc e, quart erly samp ling and a nalysis of fuel oil pr ovides f or time ly detect ion of co nditions conducive to corrosion.
The project team rev iewed th e applica nt's response and determined that the sampli ng activiti es performed for the EDG fuel o il storage tank are in accordan ce with standard indu stry practice s, and provide adequate monitoring of the EDG fuel oil to detect the pr esence of oil contamination.
On this basi s, the project team d etermined that the applican t's activi ties for sampling the E DG fuel oil s torage tank are accepta ble.As part of the review for this exception, the pro ject team reviewed the operating experience in the OCGS program basi s document for AM P-B.1.22 (PBD-A MP-B.1.22) a nd noted that Oy ster Creek experie nced a probl em with i ncreasing lev els of water and sediment in the bottom samples and the all-level samples from the EDG fuel oil storage tank in 2003.
Based on this operating exp erience, the p roject team recogniz ed that, since the EDG day tanks are filled by transferr ing oil from the EDG f uel oil storage tank, and the day tank s are not periodically sampled or i nspected, w ater and sedi ment could ha ve been i nadvertently introduced i nto the day t anks du ring th e trans fer of oil from the EDG fuel oil storage tank w ithou t bein g detect ed. This leads to the possibi lity that undetected corros ion could be present i n the day tanks. The applicant w as asked to prov ide additi onal information on why the day ta nks cannot be sa mpled, cleaned, or i nspected, and what ev idence ex ists to demonstra te that the aforementi oned operating exp erience has not caused un detected corrosi on in the d ay tanks.In its response , the appli cant stated that th e day tanks a re not equipped with sa mpling capability and periodic sampling will not be done for the day tanks; however, the OCGS f uel oil chemistry program , AMP B.1.22, will be revised to include a one-time inspection of the EDG day tanks.
175 In it s let ter date d Apr il 17, 2006 (ML061150320), the ap plica nt co mmi tte d to r evise OCGS AMP B.1.22, fuel oil chemistry, i n the OCGS LRA to includ e a one-time i nternal insp ection of the EDG day tan ks to confirm the absen ce of aging effects. Visual inspection will be performed and further inspec tions wi ll be performed to quantify the de gradation, shoul d there be an y evid ence o f corrosi on or p ittin g observ ed dur ing the vis ual i nspect ion. This is A udit Commitment 3.0.3.2.19-1.
The applicant furth er stated that the increasing trend in water and sediment in the EDG fuel oil storage tank was a ttributed to lo ng-term accumulation. Prior to thi s 2003 ev ent, Oyster Cree k did not hav e in plac e recurring tasks to p eriodicall y drain a ccumulated w ater and sedi ment from the bottom of f uel oil storage tanks. Curre nt Oyster Creek pract ice includes a quarterly recurring task to drain accumulated water and sediment f rom the bottom of the EDG fuel oil storage tank. The EDG fuel oil storage tan k is also periodically drained, cleaned, and internally inspected ev ery 10 y ears, and is periodical ly tested for water and s ediment (bottom samp les tested monthly; multilevel samples tested weekly and fo llowing transfer fr om the main fuel oil storag e tank). Based on these c urrent practic es, which in p art were d eveloped as correc tive actions to the 2003 eve nt discussed above, and the fact that all sample resul ts from that event were w ithin speci fication, wh ich is l ess than or equal to 0.05% wa ter and sedime nt, current or impending probl ems in the ED G day tanks are not expected
.The project team rev iewed th e applica nt's response and determined that the new commitment to perfo rm a on e-time insp ectio n of the EDG da y tan ks wi ll pr ovid e obje ctiv e evi dence to determi ne if u ndetec ted agi ng degrad ation is pr esent. If ind icati ons of d egradat ion a re detect ed, furth er acti ons w ill be taken to quan tify a nd, if n ecessa ry, co rrect th e degra datio n. On this basis, the project team de termined that the applicant' s response i s acceptable
.On the basis o f its review of this exce ption, the app licant's re sponses to the audit question s, and the appl icant's commitmen t to perform a one-time inspection of the EDG day tanks, the project team determin ed that this e xception is acceptabl e, because a one-time insp ection of the EDG day tan ks will identify agin g effects. If aging effects are detected, the a pplicant ha s committed to take app ropriate actio ns.Exception 2 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 6. Acceptance Criteria Exception: Oyster Creek has not committed to A STM D 405 7-95 (2000) for manual sampli ng standards:
Samp lin g of th e Eme rgenc y D ies el G ener ator Fue l St orage Tank, although not di rectly compara ble to any of the tank samplin g methods descri bed i n ASTM D 405 7-95 (2 000), e nsures that a multilevel sample and a bottom sample are obtained. T he EDG Fuel Storage Tank i s equipped w ith a sample station that i ncludes a sample reci rculation pu mp and sample collection points lo cated internal to the tank at seve ral tank elev ations, thus makin g the Emergency Die sel Generator Fu el Storage Tank sampl e station effective for obtaini ng multilev el samples.
Tank bottom samples 176 are obtained through a sample line loc ated 1/2" off of the bottom of the tank sump.
The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detection of aging effects," and
?acceptance cri teria"program elements asso ciated wi th the excep tion taken:
: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 6 217 and Modified D 2276, M ethod A are u sed for guidance for de termination of parti culates. The modification to D 2276 cons ists of using a fil ter with a pore siz e of 3.0 mm, instead of 0.8 mm.In review ing this ex ception, the p roject team noted th at neither the OCGS LRA nor th e program basis document for th is AMP discussed the specific sampling process used f or the EDG fuel oil storage tank, or the di fferences compar ed to A STM 4 057-95. The a ppli cant w as aske d to prov ide add iti onal info rmati on o n the samp lin g pro cess use d for the E DG fue l oi l st orage tank.In its response , the appli cant stated that s ampling of the ED G fuel oil stora ge tank, although not direc tly c ompara ble to any of the ta nk sampl ing meth ods de scribe d in A STM D 4057-95 (20 00), ensures that an
?all-levels" sample and a bottom sample are obtained. T he EDG fuel oil storage tank is equip ped with a sample stati on that incl udes a sample recirculati on pump and sample coll ection poin ts located i nternal to the tank at several tank elevati ons, thus making the 177 EDG fuel oil stor age t ank s ampl e sta tion effec tiv e for obta ini ng ?all-lev el" samples.
Tank bottom s amples are ob taine d throu gh a sam ple l ine l ocated off of the b ottom of t he tan k sump which i s specificall y designed to collect th e condensati on/moisture and sediment from wi thin the tank.The applican t further stated that, from draw ings CHO 082-1 and CHO 082-2 , there are four 3/8" tubes that are u sed for sampling the tank. The bottom sampl e is taken from a tube that ends 1/2" from the bot tom of the sump (ab out 51/4" below the tank bottom). The bottom sample is pulled by a pump that rec irculates the oil back i nto the tank, disc harging about 30" from the bottom of the tank. The tank sa mple is taken from a tube the ends 1/2" from the bottom of the tank. This sample is pulle d by a pu mp and recircul ated back into th e tank, discharging a bout 30" from t he tan k bottom.The project team rev iewed th e applica nt's response and determined that additi onal information was neede d to fully understand the EDG fuel oil storage tank samplin g process, and ho w the sample station on the tank prov ided ?all-lev el" samples from the tank. The appli cant was a sked for additional information on th e EDG fuel oil storage tank sampli ng process. In ad dition, information wa s requested on the main fuel oi l storage tank sampl ing process, si nce it w as not mentioned in the excep tion.In its respo nse, th e appl icant stated that th e EDG fu el sto rage tan k capac ity i s 1500 gallo ns. The recommendations in ASTM D 4057-95 (2 000) for tap sampli ng are most analo gous to the sampling techni ques employed for the EDG fuel stora ge tank. The follow ing compares the ASTM requiremen ts for a 1500 gall on tank with the Oyster Cre ek sampling proced ure:*Taps should be a minimu m of 1/2" i n diameter
:  The Oy ster Cr eek EDG sampl e tube s are 3/8", which is acceptab le since th e ASTM taps are gravity fed while Oyster Creek use s sample pumps to obtain sampl es.*Sample taps a nd piping should be flushed unti l they have been completel y purged:  The Oyster Creek EDG s ample pump i s run for at least one minute to flush the sample lines and esta bli sh re circ ula tion and mix ing w ithi n the tank.*Sample tap sp ecification s should meet the recommendation s of ASTM D 4057-95 (2000) Table s 6 and 7: The Oyster Creek sa mple taps do not meet the recommendations f or number of taps and vertical location of the taps, as specified in ASTM D 40 57-95 (2000). H owever, the sample pu mp provides for recirculatio n and mixing betw een elev ation 1/2" and 3 0" withi n the EDG fuel s torage tank. Although the tank samp le i nle t is loc ated in t he l owe r thi rd of the t ank, wi th re circ ula tion and mix ing, the sa mple i s more r eprese ntativ e of the tank co ntents than a bottom or low er thi rd sample.With regard to the sampling proces s for the main fuel oil storage tan k, the applican t stated that the m ultil evel sa mpli ng of the m ain f uel oi l tank meet s the reco mme ndat ions of t he AST M D 4057-95 (2000) guidance and, therefore, was not identif ied as an exception. The main fuel oil storage tank is 75,00 0 gallons an d the ?runni ng" or ?all-l evels" sam ple m etho d of ASTM D 4057-9 5 (200 0) is used. Oyste r Cree k sampl ing pro cedure 828.7 , ?Secon dary Syste ms Analysi s: Plant Oil
" allow s for the use of eith er a metal sampl ing cage or a w eighted sampli ng bottle, as des cribed in ASTM D 40 57-95 (2000). A clean, drie d, and corked sampl er is low ered from the t op of th e tank th rough a manhol e to ap proxi mately one foo t abov e the t ank bott om. The cork is remove d and the samp ler is rai sed at a uni form rate. If the sample v olume is no t
178 between 50% and 85%, it is discarded and another sample is obtained.
Once an acceptable sample is o btained, it is emptied i nto a sample bottle, if required, and capped.
The project team rev iewed th e applica nt's response, as well as ASTM D 4057-95 (200
: 0) and the applica nts oil sampl ing procedure 8 28.7. The Oyster Creek technical staff were also interviewed to discuss the sample station operation. The project team determ ined that, while there a re four s ample tubes in the EDG fue l oil storage tank sa mple s tation , two are us ed to supply su ction to the re circulation pumps, and tw o are used as return line s from the recirculation pumps back t o the tank. Theref ore, there are eff ectively only two locations wi thin the tank from which oil sampl es are taken; one is from the tank sump an d one is 1/2" from the tank bottom. True
?multileve l" sampling i s not obtaine d for the EDG fuel o il storage tank. The sample station used by Oyster Creek prov ides for a simul ated multile vel sampl e through the use of recircula tion and mix ing of the oil.
For the tank sampl e, oil is pumped from the tube located 1/2" from the tan k bottom and recircu lated back to the tank through the tube discharging 30" from the tank bottom. This recirculation cont inues for at least one minute bef ore a sample is taken, whi ch allow s mixing to occur betwe en the 1/2" and 3 0" elevati ons. Since the tank sample is obtained from the lower third of the tank, and the use of recirculation pumps will provide s ome degree of mixi ng with fuel oil from the midd le leve l of the tank, the Oy ster Creek sampling proced ure wil l provid e a conserv ative esti mate of contaminants in the fuel oi l, whic h tend to settle to the low er level s of the tank. On this basis, the p roject team determine d that this excep tion is acc eptable.Exception 3 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 6. Acceptance Criteria Exception: Oyster Creek has not committed to A STM D 405 7-95 (2000) for manual sampli ng standards:
Fire Pond D iesel Fue l Tank samples are obtained from the tank fuel oil outl et line l ocated 4" off of the bottom of the tanks. The Fire Pond D iesel Fue l Tanks are each 2.1 cu meter (550 gallons)capacity.
Spot samplin g recommendations i n ASTM D 4057-95 (2000) for tanks less than or equal to 159 cu meter i nclude a single sampl e from the middl e (a di stance of one-half of th e dept h of liquid below the liquid's surface). Although the actual sample location i s lower in the tank than prescribed b y the ASTM , the lower el evation i s more likely to contain c ontaminants and water and sediment which ten d to settle i n the tank, thus making th is an effectiv e spot sampl ing lo catio n. Bot tom samp les from the Fi re Pond Diese l Fuel Tanks are taken off of the tank drain l ocated on the b otto m of th e tan k.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detection of aging effects," and
?acceptance cri teria"program elements asso ciated wi th the excep tion taken:
179 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 6 217 and Modi fied D 2276, Meth od A, a re use d for gui dance for dete rminat ion o f partic ulate s. The modification to D 2276 co nsists of using a filter with a pore siz e of 3.0 mm, instead of 0.8 mm.
In reviewing this exception, the project team re viewed ASTM D 4057-95 (2000). For fuel oil storage tanks less tha n 159 cubi c meters, spot sampl ing recommendation s in ASTM D 4057-95 (2000) include a single sample from the middle (a distance of one-half of the depth of liquid below the liquid's surface). Since the OCG S fire pond diesel fuel oil storage tank s are 2.1 cubic meters, the spot samp ling requirements i n ASTM D 4057 are app licable. The project team reco gniz ed th at th e ac tual samp le l ocat ion for th e OCG S fir e po nd d ies el fu el o il s tora ge ta nks is low er in the tan ks than prescribe d by the A STM D 405 7 standard, w hich wi ll result in the samples bein g more likely to capture contami nants, water and sediment.
Therefore, the samples are ex pected to be c onservativ ely repres entative o f the fuel in the tank. On this basi s, the project team de termined that thi s exceptio n is accepta ble.Exception 4 Elements: 1. Scope of Program
: 2. Preventi ve Action s 180 Exception: Oyster Creek does not add corros ion inhi bitors to fuel o il. The analy sis f or pa rtic ulat e con tam inant s usin g mo dif ied AS TM D 2276-00 M ethod A is sufficient for the detecti on of corrosion products at an early stage.
Fuel contami nants and degrada tion products will normally settle to the tank bottom where they would be detected by routine ana lysis o r by perio dic draini ng of water and sediment from the storage tank bottoms.
The GALL Report i dentifies the foll owing recommend ations for the
?scope of program" and
?preventiv e actions" pro gram elements associ ated with the excep tion taken:
: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 2. Preventive A ctions: The qual ity o f fuel oi l is mainta ined by ad ditio ns of bi ocide s to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibito rs to mitigate corros ion. Perio dic cleani ng of a tank allow s removal of sediments, and p eriodic drai ning of water co llected at th e bottom of a tank mini mizes the amo unt of w ater an d the l ength o f contac t time. Accor dingl y, the se meas ures a re effective in miti gating corrosion i nside die sel fuel oil tanks. Coatings, i f used, prevent or mitigate corrosion by protecti ng the internal surfaces of the tank from contact with w ater and microbio logical organi sms.In evalua ting this ex ception, the p roject team revi ewed the applicant' s fuel oil s ampling activ ities to determine if they are adeq uate to provide timely detection of corros ion. From the applicant's response to an audit questio n, the project team determined that fuel oil ana lyses for particulates, as well as water a nd sediment, are performed quarterly or more frequently for the Oyster Creek fuel o il storage tanks. In particular, i n its respons e to an audi t question, the appli cant st ated th at comp lete o ff-site l ab fuel oil analy ses are performe d for pa rticul ate contami natio n, bac teria, API gra vity , wat er and sedi ment, ki nemati c vi scosi ty, su lfur con tent, flash point, cl oud point, a sh, distill ation temperature, cetane index , carbon resid ue, and coppe r strip corrosion. This is pe rformed weekly for the EDG fuel oi l storage tank, and quarterly for the main fuel oil stor age t ank. In a ddi tion , the mai n fue l oi l st orage tank , the EDG fuel oil stor age tank, an d the fi re pon d die sel fue l tanks wil l be p eriod ical ly d raine d, cle aned a nd in specte d. A one-time insp ection wi ll be performed for th e EDG day tanks. The project team d etermined that the applica nt's fuel oil sampling acti vities, togeth er with th e inspectio n activi ties wi ll provi de assurance that, if corrosion were occurring in the fuel oil tank s, it would be detected in a timely manner. If ev idenc e of corr osion is de tected , corre ctiv e acti ons w ill be taken to miti gate it. On this basis, the project team de termined that thi s exceptio n is accepta ble.In Attachment 1, Item B
.1.22 of its reconc iliation document, the ap plicant i dentified the foll owing additional exception to the GALL Report progr am, which is not included in the OCGS LRA:
Exception 5 Eleme nt: 1. Scope of Program 181 Exception: NUREG-1801 sta tes in XI.M30 that the fuel oi l aging management program is in pa rt based on the fuel oil p urity and testing require ments o f the pl ant's Te chnic al Sp ecific ation s that are based on the Standard Techni cal Speci fications of NURE G-1430 through NUREG-143
: 3. Oyster Cree k has not adopted the Standard Techni cal Speci fications as de scribed in these NUREGs, how ever, the Oy ster Creek fuel oil specification s and procedures in voke simila r requirements for fuel oi l purity and fuel oil t estin g, as de scribe d by the Sta ndard Techni cal S pecifi catio ns. These include te sting requir ement s for n ew fuel oil (API gr avity, kinematic vi scosity, w ater and sedi ment) prior to ad ding the new fuel to the storage ta nk to ensure that th e oil has not been contami nated with substa nces th at wo uld h ave a n immed iate detrimental i mpact on diese l engine combu stion, and tes ting of new fuel after ad ding it to the storage tank to confirm that th e remain ing fuel oil proper ties a re wi thin s pecifi catio n requi rements. Oyster Creek fuel o il activ ities also provide for the trending of particulate c ontamination in new and stored fuel oil. Water and Sediment are d rained peri odically (quarterly) from the E mergency Diesel Gene rator Fuel Sto rage Tank. This period icity ex ceeds the Standa rd Tech nical Speci ficatio ns requi rements of "once ever y[31] days", ho wever, i t is aligned with the requirements of Regulatory Guide 1.137, which states that a quarterly basis is sufficient unless accumulated co ndensation i s suspected (i n which case a monthl y bas is is appro priate). This is a new exception based on the reconcilia tion of this aging manage ment program from the draft Janua ry 2005 GALL to the approved September 2005 GALL.
The GALL Report i dentifies the foll owing recommend ations for the
?scope of program" program element associ ated with the excep tion taken:
: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
The app lica nt wa s asked to con firm that AMP B.1.22 in th e OCGS LRA w ill be rev ised to include thi s exceptio n.In it s let ter date d Marc h 30, 2006 (ML060950408), the ap plica nt co mmi tte d to r evise AMP B.1.22 in th e OCGS LRA to incl ude th e exc eptio n ide ntifie d in t he rec oncil iatio n docu ment, which sta ted that Oyster C reek has not adop ted the Standa rd Technical Specification s, howe ver, t he Oys ter Cre ek fuel o il sp ecific ation s and proced ures i nvoke simil ar requi rements for fuel o il pu rity and fue l oil testi ng. This is A udit Commitment 3.0.3.2.1 9-2.The applican t was asked to provide additional information on th e specific fuel oil speci fications used at Oyster Creek, and how they differ from the require ments in the sta ndard technic al 182 specifications. The applic ant was al so asked to justify the frequency for drai ning water a nd sedi ment from t he E DG fue l st orage tank in l ight of pa st op erat ing e xpe rien ce a t Oy ster Cre ek, in which increasing water and sediment concentrations were observed in the store d fuel oil.
In its response , the appli cant stated that w ater and sedi ment are draine d from the EDG fuel storage tank on a quarterl y basis.
This exceed s the standard technical s pecifications requirements of 31 day s; howev er, it is al igned with Regulatory Guide 1.137.
Regulatory Gui de 1.137 states that a quarterly ba sis is sufficien t unless accu mulated conden sation is s uspected, in whi ch case a month ly basi s is appropri ate. With regard to the frequency for drai ning water and sediment from the EDG fuel oil storage tank, the appl icant stated th at the increas ing trend in water and sediment was attribu ted to long-term accu mulation. Pri or to this ev ent, Oyster Creek did not h ave in p lace recurrin g tasks to periodic ally dra in water and sediment from the bottom of fuel oil storage tanks. Current Oy ster Creek practice s include quarterly recurri ng tasks to d rain acc umul ated wa ter a nd s edi ment from t he b otto m of th e ED G fuel oil stor age tank. This practice has been e ffective in prev enting recurrence of high level s of water and sedi ment in t he E DG fue l oi l st orage tank.The applican t further stated in i ts response that the standard tech nical spec ifications reference Regula tory Gu ide 1.137 for recomme nded fu el oi l prac tices, as sup plemen ted by ANSI N195. The fuel oil p roperties gove rned by the se requirements are the water an d sediment con tent, the kinematic vi scosity, spe cific or API grav ity, and i mpurity lev el. These fuel o il properti es are governed by the Oyster Cre ek fuel oil che mistry program, w hich is i mplemented by procur ement s pecifi catio n SP-1 302-38-010 a nd samp ling a nd ana lysi s proce dure CY-OC-120-1107. Thes e procedures are based on Regulator y Guide 1.137, Revision 1, ANSI N195-1 976 an d ASTM D975-81. The se imp lement ing do cuments incl ude fue l oil requir ements for wat er and sedi ment co ntent, the kin ematic vis cosity , speci fic or A PI grav ity, and i mpurit y level for ne w and store d fuel consiste nt with th e requirements id entified in th e referenced standard techni cal specifica tions.The project team rev iewed th e applica nt's response, as well as OCGS procureme nt speci ficatio n SP-1 302-38-010, ?Oyster Creek Ge nerati ng Stati on Di esel Fuel Oil N o. 2,"Revisio n 8, June 23, 2004; Oyster C reek sampling and analysi s procedure CY-OC-120-1107,?Fuel Oil S ample and A nalysis Schedule," R evision 0; and the sta ndard technic al specificati ons for Gener al El ectric plan ts, NU REG-14 33, ?Standard Technical Specificat ions General Electric Plants, BWR/4," Volume 1, R evision 3, June 2004. The project team co nfirmed that the implementing do cuments inclu ded fuel oil requirements for wa ter and sedime nt content, the kinematic vi scosity, spe cific or API grav ity, and i mpurity lev el for new a nd stored fuel co nsistent with the requirements iden tified in the referenced standard technical s pecifications; therefore, the ap plic ant's fuel o il sp ecific ation s are c onsis tent w ith th e requi rements in th e stan dard technical specifications. On th is basis, the project team det ermined that this exception is acceptable.
3.0.3.2.19.4 Enhan cements In the OCGS LRA , the appli cant identifie d  the follow ing enhancements in order to mee t the GALL Report program e lements: Enhan cement 1 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 183 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The Oys ter Cre ek Fuel Oil C hemist ry pro gram wi ll be enhan ced to include rou tine analy sis for particul ate contaminati on using modified ASTM D 2276-00 M ethod A on fuel oil sampl es from the Emergency Die sel Generator Fu el Storage Tank, the F ire Pond Die sel Fue l Tan ks, a nd th e M ain Fue l Oi l Tan k.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"and ?accept ance c riteri a" progr am ele ments a ssoci ated w ith th e state d enha ncemen t: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.5. Monitoring and Trendin g: Water and biological ac tivity or particulate contamination concentrations are monitored a nd trended i n accordance with the plant's tech nical specifications or at least q uarterly. Based on industry operating experience, q uarterly sampli ng and analy sis of fu el oi l prov ides for timel y det ectio n of con ditio ns con duciv e to corros ion o f the in ternal surface of the d iesel fuel o il ta nk before the po tentia l los s of its intended functio n.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 6 217 and 184 Modified D 2276, M ethod A are u sed for guidance for de termination of parti culates. The modification to D 2276 cons ists of using a fil ter with a pore siz e of 3.0 mm, instead of 0.8 mm.The applican t's enhancemen t will add routine analysi s for particulate contamination using modified ASTM D 2276-00 M ethod A on fuel oil sampl es from the EDG fuel sto rage tank, the fire pond dies el fuel tanks, and the main fuel oil tank, w hich is co nsistent w ith the recommendations in the GALL Report. Routine analysis for particulate cont amination will provide results that can be used to ensure that con tamination is maintained at acceptable levels.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.22 , ?Fuel Oil C hemist ry," w ill be con sisten t wi th GALL AMP XI.M30 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 2 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The Oys ter Cre ek Fuel Oil C hemist ry pro gram wi ll be enhan ced to include a nalysis for particulate co ntamination u sing modified ASTM D 2276-00 Method A on new fuel oil.
The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"and ?accept ance c riteri a" progr am ele ments a ssoci ated w ith th e state d enha ncemen t: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d
185 microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.5. Monitoring and Trendin g: Water and biological ac tivity or particulate contamination concentrations are monitored a nd trended i n accordance with the plant's tech nical specifications or at least q uarterly. Based on industry operating experience, q uarterly sampli ng and analy sis of fu el oi l prov ides for timel y det ectio n of con ditio ns con duciv e to corros ion o f the in ternal surface of the d iesel fuel o il ta nk before the po tentia l los s of its intended functio n.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 6 217 and Modified D 2276, M ethod A are u sed for guidance for de termination of parti culates. The modification to D 2276 cons ists of using a fil ter with a pore siz e of 3.0 mm, instead of 0.8 mm.The applican t's enhancemen t will add routine analysi s for particulate contamination using modified ASTM D 2276-00 M ethod A on n ew fuel oi l, whic h is consi stent with the recommendations in the GALL Report. Routine analysis for particulate cont amination will provide re sults that can be used to en sure that contami nation from new fuel oil i s not introduc ed into t he OCGS fuel o il sy stem.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.22 , ?Fuel Oil C hemist ry," w ill be con sisten t wi th GALL AMP XI.M30 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 3 Elements: 1. Scope of Program
: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Enhan cement: The Oys ter Cre ek Fuel Oil C hemist ry pro gram wi ll be enhan ced to include a nalysis for water and s ediment usin g ASTM D 27 09-96 for Fire Pond D iesel Fue l Tank bottom samples
.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?parame ters mon itored or in specte d," ?detect ion o f aging effec ts," ?monito ring an d trend ing,"and ?accept ance c riteri a" progr am ele ments a ssoci ated w ith th e state d enha ncemen t: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the 186 plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.5. Monitoring and Trendin g: Water and biological ac tivity or particulate contamination concentrations are monitored a nd trended i n accordance with the plant's tech nical specifications or at least q uarterly. Based on industry operating experience, q uarterly sampli ng and analy sis of fu el oi l prov ides for timel y det ectio n of con ditio ns con duciv e to corros ion o f the in ternal surface of the d iesel fuel o il ta nk before the po tentia l los s of its intended functio n.6. Acceptance Cri teria: The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for guidance on th e determination of water and s ediment contami nation in diesel fuel.
ASTM D 62 17 and Modified D 2276, M ethod A are u sed for guidance for de termination of parti culates. The modification to D 2276 cons ists of using a fil ter with a pore siz e of 3.0 mm, instead of 0.8 mm.The appli cant's enh ance ment will add rout ine an alysis for water and se dime nt us ing A STM D 2709-96 for fire pond diesel fuel tank bottom samples, which i s consistent w ith the recommendations i n the GALL Re port. Routine analysi s for water and sediment in the fire pond diese l fuel tank w ill provi de res ults t hat ca n be u sed to ensur e that these contami nants are maintained a t acceptable levels, and that the frequency for draining w ater and sedi ment from the tanks is ade quate.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.22 , ?Fuel Oil C hemist ry," w ill be con sisten t wi th GALL AMP XI.M30 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.
187 Enhan cement 4 Elements: 1. Scope of Program
: 2. Preventi ve Action s 4. Dete ction of Agin g Effects Enhan cement: The Oys ter Cre ek Fuel Oil C hemist ry pro gram wi ll be enhan ced to include a nalysis for bacteria to v erify the effectiven ess of biocide addi tion in t he E merge ncy Die sel Gene rato r Fu el S tora ge Tan k, the F ire Pon d Di esel Fue l Tan ks, a nd th e M ain Fue l Oi l Tan k.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?preventiv e actions," an d ?detection of aging effects" program e lements associ ated with the stated enhan cement: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC (M IC) of the diesel fuel tank internal surfaces in acco rdance with the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, NUREG-1432, N UREG-1433) on fuel oil puri ty and the guidelines of ASTM Standa rds D1796, D2276 , D2709, D621 7, and D4057. The program serve s to reduce the potential of exposure of the tank internal su rface to fuel oil contaminated w ith water and microbiologic al organisms.
: 2. Preventive A ctions: The qual ity o f fuel oi l is mainta ined by ad ditio ns of bi ocide s to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibito rs to mitigate corros ion. Perio dic cleani ng of a tank allow s removal of sediments, and p eriodic drai ning of water co llected at th e bottom of a tank mini mizes the amo unt of w ater an d the l ength o f contac t time. Accor dingl y, the se meas ures a re effective in miti gating corrosion i nside die sel fuel oil tanks. Coatings, i f used, prevent or mitigate corrosion by protecti ng the internal surfaces of the tank from contact with w ater and microbio logical organi sms.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.The applican t's enhancemen t will add routine analysi s for bacteria to v erify the effectiven ess of biocide a ddition i n the EDG fuel s torage tank, the fire pond diesel fuel tanks, and the mai n fuel oil tank, which is consistent with the recommendations in the GALL Report. Routine analysis for bacte ria w ill provi de res ults t hat ca n be u sed to ensur e that the bi ocide addi tion a ctiv ities are effectiv e in p reven ting th e grow th of ba cteria in th e fuel oil s ystem.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.22 , :Fuel Oil C hemist ry," w ill be con sisten t wi th 188 GALL AMP XI.M30 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.Enhan cement 5 Elements: 1. Scope of Program
: 2. Preventi ve Action s 4. Dete ction of Agin g Effects Enhan cement: The Oys ter Cre ek Fuel Oil C hemist ry pro gram wi ll be enhan ced to incl ude pe riodi c drai ning, c leani ng, and insp ectio n of the Fire Pond Diese l Fuel Tanks an d the Mai n Fuel Oil Tank (already perfo rmed for th e Eme rgenc y D ies el G ener ator Fue l St orage Tank). Inspec tion activities will include the use of ultrasonic techni ques for d etermi ning ta nk botto m thickn esses shoul d there be a ny e vid ence of co rros ion or p itti ng.The GALL Report i dentifies the foll owing recommend ations for the
?scope of progra m,"?preventiv e actions," an d ?detection of aging effects" program e lements associ ated with the stated enhan cement: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and MIC o f the diesel fuel tank internal surfaces in accord ance wi th the plant's tech nical spec ifications ( i.e., NUREG- 1430 , NUREG-1431, N UREG-1432, NUREG-1433) on fuel oil p urity and the guidelin es of ASTM Sta ndards D1796 , D2276, D2709, D6217 , and D4057.
The program serves to reduce the p otential of ex posure of the tank internal surface to fuel oi l contaminated with w ater and microbi ological organisms.
: 2. Preventive A ctions: The qual ity o f fuel oi l is mainta ined by ad ditio ns of bi ocide s to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibito rs to mitigate corros ion. Perio dic cleani ng of a tank allow s removal of sediments, and p eriodic drai ning of water co llected at th e bottom of a tank mini mizes the amo unt of w ater an d the l ength o f contac t time. Accor dingl y, the se meas ures a re effective in miti gating corrosion i nside die sel fuel oil tanks. Coatings, i f used, prevent or mitigate corrosion by protecti ng the internal surfaces of the tank from contact with w ater and microbio logical organi sms.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measuremen t of the tank bottom surface en sures that signi ficant degradation is n ot oc curr ing.The app lica nt's e nhanc ement w ill add pe riodi c drai ning, c leani ng, and insp ectio n of the fire pond diesel fuel tanks and the main fuel oi l tank. This acti vity i s already performed for the emergency dies el generator fuel s torage tank. Inspectio n activi ties wi ll incl ude the use o f
189 ultrasonic te chniques for determin ing tank bottom thickness es, should th ere be any evidenc e of corros ion o r pitti ng. This activ ity i s cons isten t wi th the recomme ndati ons i n the GA LL Rep ort, and will ensure that aging of the f ire pond diesel fuel tanks and the main f uel oil tank is properly managed.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.1.22 , ?Fuel Oil C hemist ry," w ill be con sisten t wi th GALL AMP XI.M30 and will provide a dditional assurance that the effects of aging wil l be adequately man aged.3.0.3.2.19.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e fuel oil chemistry agin g management program has pr oven to be effectiv e in i denti fying a nd cor rectin g abnor mal co nditi ons i n a ti mely manner.In 2003, Oyster Creek experienced hig h concentrations of water and sedim ent in main fuel oil tank samples. On p revious o ccasions, hi gh concentrations of water and sediment had also been detected in the EDG fuel storage tank and fire p ond diesel fuel tanks. There w ere no fuel oil sys tem failures attrib uted to a lo ss of material con dition or b iofouling as a result of these findings. Althou gh fuel oil ch emistry activ ities detecte d the high le vels of conta minants in th e fuel in a time ly manner, a nd correctiv e actions w ere initia ted before blockage of fuel oil sys tem suppl y li nes or corros ion o f fuel oi l tanks and fue l sup ply line s occu rred, fue l oil chemi stry activ ities were enhan ced to incl ude th e addi tion o f bioci des an d stab iliz ers to fuel oi l, and to incor porate impro ved t est meth ods for t he ear ly d etecti on of w ater an d sedi ment.In review ing the appli cant's operati ng experienc e, the project team noted that the d iscussion of operating exp erience in the program basis document for AM P B.1.22, PBD-AMP-B.1.22 , stated that Oyster Cree k experience d an increas ing trend in th e concentratio n of water and sediment in E DG fue l oi l st orage tank bott om an d mul til eve l sa mple s. C orre ctiv e ac tion s in vol ved usi ng a feed and bleed process to rep lace the oi l in the E DG fuel oil s torage tank. The project tea m asked the applicant to provide additional inform ation on the root cause and severity of this problem, alon g with how the problem w as corrected.
In its response , the appli cant stated that th e events i nvolvi ng increasing tren ds in w ater and sedime nt in the ED G fuel s torage t ank bott om and multil evel sampl es we re attri buted to lon g-ter m acc umul atio n. P rior to th is e ven t, Oy ster Cre ek di d no t hav e in pla ce re curr ing t asks to periodica lly drai n water an d sediment from the b ottom of fuel oil sto rage tanks. Current Oyster Creek practi ces includ e quarterly pe riodic recurri ng tasks to drain ac cumulated w ater and sediment from the bottoms of the EDG fuel storage tank, fire pond diesel fuel tanks, and the m ain fuel oil tank.The applicant furth er stated in its response that an increase was noted in the monthly EDG storage tank bot toms sa mple fro m 10/08/03 as wate r and s edimen t incr eased from < 0.0 5% to 0.05%. A w eekly EDG sto rage tank sample from 10/05/0 3 also in dicated an i ncrease from
< 0.05% to 0.05%.
All sample results from the ED G storage tank and bottoms were w ithin the specification, which i s less than or equal to 0.05
% water and sediment. On 10
/09/03, the pla nt obtained the use of a vacuum truck and a tanker truck. The vacuum truck pulled aproximately 400 gallons of EDG fuel oil off the tank's sump. The tanker tru ck then made up to the tank by adding 400 gal lons of clean fuel oil.
This process w as repeated an additiona l four times so th at approximatel y 1870 gal lons of oil was ble d from the tank and 187 0 gallons of fresh oi l was added to the tank. A subsequent bulk sample w as taken on 10/10
/03 and w as < 0.05% w ater and se diment. The i ncreas ed tren d in w ater an d sedi ment w as attr ibute d to l ong-term 190 accumulation.
The use of the feed a nd bleed p rocess to repl ace the fuel oi l in the E DG fuel storage tank w as not inten ded to addre ss the root ca use of th is in creasi ng trend. Acti ons to prevent recurre nce includ ed the creatio n of quarterly recu rring tasks to drain accumulated w ater and sediment from the bottoms of the EDG fuel storage tank, the fire po nd diesel fuel tanks, and the m ain fuel oil tank.The project team reviewed the applicants response and determined that the increa sing trend in water and sediment in the fuel oil storage tanks was a result of lon g-term accumulation since Oyster Creek d id no t peri odica lly drain wate r and s edimen t from the tanks. Water tends to accumu late i n fuel oil t anks du e to co ndens ation insi de the tanks i f they are su bjected to thermal cycl ing, which is typi cal of outdoor tan ks. Subsequent to thi s event, Oy ster Creek implemented rec urring tasks to perio dically drain w ater and sedi ment from the tanks, whi ch eliminated the problem. On this basis, the project team determ ined that the applicant's corrective a ctions to add ress the incre asing water content of the fuel o il were acceptable, and perio dic mo nitori ng of the fuel oi l tanks wil l dete ct any recurr ence o f this p roble m.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the basis o f its review of the above plant-specific operating exp erience, and discussions with the applicant's technical staff , the project team det ermined that the applicant's f uel oil chemis try pr ogram w ill adequa tely manage the agi ng effects that ar e ide ntifie d in t he OCGS LRA for whi ch this AM P is credi ted.3.0.3.2.19.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e fuel oil chemistry program in OCGS LRA, Appendix A, Section A.1.22, whi ch stated that the fuel oil ch emistry aging mana gement program is an ex isting program that i ncludes prev entive ac tivities to provid e assurance tha t contaminants are maintained at acceptable levels in fuel oil for systems and component s within the sco pe of l icens e rene wal. The fue l oil tanks w ithin the sc ope of l icens e rene wal are maintained b y monitorin g and controll ing fuel oil contaminants i n accordance with the guidelines of the American Society for Testing and Materials (ASTM). Fuel oil sampling and analysis is perfo rmed in a ccor danc e w ith appr ove d pro cedu res fo r new fuel and stor ed fu el. Fuel oil tank s are periodically drained of accumulated water and sediment. These activities effec tively manage the effects of aging by providin g reasonable a ssurance that po tentially harmful contaminants are maintained at low c oncentrations.
The fuel oil c hemistry aging man agement program will be enhanced to includ e:*Routine ana lysis for pa rticulate con tamination usi ng modified ASTM D 2276-00 M ethod A on fue l oil sampl es from th e emerge ncy d iesel genera tor fuel storage tank, th e fire pond die sel fuel tank s, an d the mai n fue l oi l ta nk.*Analysi s for particulate contamination using modified A STM D 227 6-00 Metho d A on new fuel oil.
*Analysi s for water and sediment usi ng ASTM D 2 709-96 for fire pond diesel fuel tank bottom samples 191*Analysi s for bacteria to v erify the effectiven ess of biocide addition in the emergency diesel generator fu el storage tank, the fire pond diesel fuel tank s, and the main fuel oil tank.*Periodic d raining, clea ning, and ins pection of the fire pond diesel fuel tanks and the main fuel oil tank. Inspection activiti es wil l includ e the use of ul trasonic techni ques for determining tank botto m thicknesses shou ld there be any evi dence of corrosio n or pitt ing.These enhancemen ts will be implemen ted prior to the period of ex tended operati on.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 22 of the commitments.
In i ts l ette r dat ed A pril 17, 2006 (ML061150320), t he a ppl ica nt co mmit ted t o the foll owi ng:*AMP B.1.22 , fuel o il ch emistry , in th e OCGS LRA w ill be rev ised to inc lude a one-time internal i nspection of the EDG day tan ks to confirm the absen ce of aging effects. Visual inspection will be performed and further i nspections w ill be p erformed to quantify the degradation, shou ld there be any evi dence of corrosio n or pitting ob served duri ng the visu al in specti on.  (c ommitmen t 3.0.3.2.19-1).In i ts l ette r dat ed M arch 30, 2006 (ML060950408), t he a ppl ica nt co mmit ted t o the foll owi ng:*AMP B.1.2 2, fuel oil c hemistry, in the OCGS LRA will be revise d to inclu de the exc eption identified i n Attachment 1, i tem B.1.22 of the reco nciliati on document, w hich stated th at Oyster Creek has not adopted the Standard Techni cal Speci fications, how ever, the Oyster Creek fuel o il specifica tions and pro cedures inv oke similar requi rements for fuel oil p urity and fue l oil testi ng. (commi tment 3.0.3.2.1 9-2).The applican t's licens e renewal commitment list and UFSAR update are to b e revised to reflect these Audit Commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.22. Contingent up on the addition of audit commitm ents 3.0.3.2.19-1 and 3.0.3.2.19-2, the pr oject team fou nd that it was c onsis tent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.19.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eptions and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects for whi ch it is cre dited. Als o, the project team review ed the enhancements an d determined th at implementati on of the enhanc ements prior to th e period of exten ded op eratio n wo uld re sult i n the e xist ing AM P bei ng cons isten t wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and, contingen t upon the i nclusion o f audit commitment 3.0.3
.2.19-1 and 3.0.3
.2.19-2, 192 found that it prov ides an ad equate summary des cription of the program, as required by 10 CFR 54.21 (d).3.0.3.2.20 Reactor Vessel Surveil lance (OCGS AM P B.1.23)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.2.21 Buried Pi ping Inspection (OCGS AMP B.1.26)In OCGS LRA, Ap pendix B , Section B.1
.26, the appli cant stated that OC GS AMP B.1.26,"Buried Pi ping Inspection
," is an ex isting plant program that is cons istent wi th GALL AMP XI.M 34, "Buried P iping and Tanks Ins pection," w ith excep tions and en hancements.
3.0.3.2.21.1 Program Descriptio n The app lica nt stat ed, in the OC GS LRA , that t his p rogram i nclud es pre venti ve mea sures t o miti gate corr osi on a nd p erio dic ins pect ion of ex tern al s urfac es fo r lo ss o f mate rial to ma nage the effect s of corrosion on the pressur e-retaining capacity of piping and components in a soil (exte rnal) envi ronmen t. Prev entiv e measu res are in ac cordan ce wi th stan dard i ndustr y practices for mainta ining extern al coatings a nd wrappi ngs. External inspection s of buried components w ill occur opportunistic ally w hen they a re excav ated during main tenance. Upon entering the period of extended operation, inspection of buried piping will be performed within ten years, un less an opp ortunistic i nspection oc curs withi n this ten-y ear period.
The program will be enhanced as described below to provide assurance that buried pip ing and pipi ng components w ill perform thei r intended functi on during the e xtended pe riod of operatio n.3.0.3.2.21.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.26 is cons istent wi th GALL AMP XI.M 34, with exceptions and enhance ments.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.26, incl uding OCGS pr ogram ba sis do cument PBD A MP B.1.26, ?Buried Pi ping Inspection
," Rev. 0, whi ch pro vide s an a ssessme nt of the AMP eleme nts' co nsiste ncy w ith GA LL AM P XI.M 34. Specifically, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and re view report) conta ined in OCGS AMP B.1.26 and a ssoci ated b ases d ocumen ts  to determine consi stency w ith GALL AM P XI.M34.The project team rev iewed th ose portions of the Buried P iping Inspecti on Program for whi ch the appli cant cl aims c onsis tency wit h GALL AMP XI.M3 4 and found th at they are co nsiste nt wi th the GALL Repo rt AMP. The project team found that the applica nt's Buried Piping Inspe ction Program conforms to the reco mmended GALL AM P XI.M34, w ith the ex ceptions and enha ncem ents desc ribe d belo w.3.0.3.2.21.3 Exce ption s to th e GALL Repor t The applican t stated, in the OCGS LRA, the following e xception to the GALL Re port program elements:
193 Exception Elements: 1. Scope of the P rogram 2. Preventi ve Action s 6. Acceptance Criteria Exception: Secti on X1.M.34, ?Buried Piping and Tanks Inspec tion," AMP only includes b uried carbon steel pipi ng; howeve r, Oyster Creek has other material, such as stain less steel, aluminum, bronz e and cast iron, in the ir buried p iping program that w ill be man aged as part of this A MP. The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
: 1. Scope of the Program:  The GA LL Report states that th e progr am relies on prevent ive measures such a s coating, wra pping and peri odic inspe ction for loss o f material caused by corrosio n of the externa l surface of buried steel pip ing and tanks.
: 2. Preventive A ctions: The GALL Report states that in accordance w ith industry practice, underground pip ing and tanks are coated during i nstallation with a protective c oating syste m, such as coa l tar e namel with a fibe rglass wrap and a kraft pap er oute r wra p, a polyoli fin tape coatin g, or a fusion bond ed epoxy coating to protec t the pipin g from contac ting th e aggress ive soil envi ronmen t.6. Acceptance Criteria
:  The GALL Repo rt states that any coating and w rapping degradations are reported and ev aluated acco rding to site co rrective acti ons procedures.
The project team asked th e applica nt if the buried pipe w ill be i nspected w ithin 10 y ears of the end of the current p eriod of operati on and duri ng the first 10 ye ars of the period of extended operation. The applicant re plied that there wil l not be a focused inspecti on withi n 10 years of entering the peri od of extended operation b ecause opportu nistic ins pections hav e occurred within this 10 y ear period.
Also, a focused inspection will occur during the first 10 years of entering the peri od of extended operation u nless an op portunistic i nspection oc curs during that time.The project team als o asked the appl icant if each different kind of buried material w ill be inspe cted. The app lica nt stat ed tha t all of the d ifferent t ypes of materi als w ill not be exami ned. Rather , the i nspect ions wil l be p erformed on a s ystem with high l ikeli hood o f corrosi on pro blems or systems that have a hi story of corrosio
: n. The OCGS buri ed pipe agin g management program contains al uminum, cast iron , stainless steel, and bro nze in a ddition to the carbon steel. All but 25 feet to the al uminum pipe has b een re locat ed to a n abov e groun d loc ation. The remaining buri ed aluminum pipe is p art of the condensa te transfer system. The cast iron pipe is p art of the fire protectio n system. The h eating & proces s steam and roof drai n &overb oard d ischa rge sys tems may conta in sta inle ss stee l and bronz e fitti ngs that are co ated. OCGS has nev er experie nced any failures of these mate rials. To be conservativ e, OCGS has incl uded t hese ma terial s in t he sco pe of th e buri ed pi pe agi ng manage ment pr ogram.The project team found the applican t's excepti on to the GALL Report to be a cceptable after discu ssion s wi th the appli cant. In part icul ar, the appl icant expl ained that th e bron ze fit tings a re 194 coated and tha t, with the exception of the aluminum p ipe, none o f the other material s has experienced any problems. Only a small portion of the aluminum pipe rem ains buried. On this basis, the pro ject team found this exception acceptable.
3.0.3.2.21.4 Enhan cements The applican t stated, in the OCGS LRA, the following e nhancement in order to meet the GALL Report program ele ments: Elements: 1. Scope of the P rogram 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 6. Acceptance Criteria Enhan cement: The Buried Pi ping Inspection aging management program w ill be enhanced to i nclude Fi re Protection c omponents in the scope of the program. Inspecti on of buried pi ping withi n ten years of entering the peri od of extended operation w ill be c onducted, unless an o pportunistic inspection occurs wi thin this ten-year period. Pi ping located inside the vault are in the scope of the program The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
: 1. Scope of the Program:  The GALL Repo rt stated that the program relies on preventiv e measures such as coating, w rapping and pe riodic in spection for los s of material cause d by corrosi on of the extern al surface of burie d steel pi ping and tanks.
: 3. Preventive A ctions: The GA LL Rep ort sta ted tha t in a ccorda nce w ith i ndustr y practi ce, unde rgro und piping and tank s are coat ed during installat ion with a pro tective coating system, s uch as coal tar enamel w ith a fiberglass wrap and a kraft paper outer wrap, a po lyolifin tape coating, o r a fusion bond ed epoxy coating to protec t the pipin g from cont actin g the aggre ssiv e soi l env ironme nt.4. Detect ion o f Agin g Effec ts:  Inspections performed to confirm that co ating and wrapping are intact are an effective method to ensure that corros ion of externa l surfaces has not occurred and the in tended function i s maintained
.Buried pip ing and tanks are opportunistic ally i nspected w henever the y are ex cavated durin g mainte nance. When oppo rtunis tic, th e ins pecti ons ar e perfor med in areas wit h the highest li kelihood of corrosi on problems, a nd in areas with a h istory of corrosi on problem s, within th e areas m ade acce ssible to support the maint enance ac tivity.The applicant's program is to be evaluated for the extended period of operat ion. It is anticipated that one or more opportunistic inspection s may occur w ithin a ten-year period. Prio r to entering the period of exte nded operatio n, the appli cant is to v erify that there is at l east one oppo rtunistic or focuse d inspectio n is performed w ithin the p ast ten years.
195 Upon enterin g the period of ex tended operati on, the appl icant is to perform a focused inspection within ten years, unless an opportunistic inspection occurr ed within this ten-year peri od.Any credi ted inspecti on should be performed in are as with the highest li kelihood of corrosion prob lems, and in areas wi th a history of corrosion prob lems.6. Acceptance Criteria
:  The GALL Repo rt states for Element 6 that any coating and wrapping de gradations are rep orted and ev aluated acco rding to site co rrective acti ons procedures.
The applican t stated, in the OCGS LRA, that inspections will be performed to con firm that coating and w rapping are in tact. These insp ections are a n effective method to ensure that corros ion o f exter nal s urfaces has no t occur red an d the i ntende d functi on is mainta ined. Inspections are performed to confirm that c oating and w rapping are in tact. External inspection s of buried compone nts wil l occur oppo rtunisticall y when they are e xcavated during maintena nce.Buried pip ing wil l be opportu nisticall y inspecte d whenev er excav ated for maintenanc
: e. The inspections will be performed on al l of the areas mad e accessibl e to support the maintenance activity. Areas w ith the highes t likelihoo d of corrosion pro blems, and are as with a history of corros ion p roble ms hav e been iden tified in Top ical Repor t ?Oyster Creek Und erground Pipin g Program Descri ption and S tatus".There have be en several yard ex cavation activiti es to date that have unco vered buri ed piping and inspections of the buried piping.
Oyster Creek has perfo rmed focused inspect ion on their underground pip ing withi n the past ten years.Sev eral ins pect ion s ha ve b een perfo rmed on t he E SW and S W syste ms, w hic h ha ve a high likelihood of corrosion prob lems and hav e a history of corrosion rel ated problems. In addition other inspecti ons and testi ng have been performed per the Techn ical Data Report TDR-829,?Pipe Integri ty Ins pecti on Pro gram," an d Topi cal R eport TR-116, ?Oyster Creek Und erground Pipi ng Progra m Descr iptio n and Status."Upon enterin g the period of ex tended operati on inspecti on of buried pi ping wil l be performed within ten years, un less an opp ortunistic i nspection oc curs withi n this ten-y ear period.
Areas wi th the highest l ikelihood o f corrosion probl ems, and areas w ith a history of corrosion problems have been identified in the above Topical Report. Thes e are primarily in the ESW and SW systems. Inspection s in these a reas have been performed w ithin the p ast ten years
.Addit ional ly, I nserv ice S ervi ce Testi ng and monito ring for the ES W, SW , RBCC W, Fire Protection and Condensate Transfer systems are pe rformed. Monitori ng and trending from the performance of these tests can aid i n the detectio n of system pip e leaks. Peri odic leak testi ng and co mponen t insp ectio ns are bein g credi ted as wel l. Se ction XI Pres sure Te sting d irects testing of buried cooling water piping for the detection of leaks. This pressure test ing is performed via pu mp surveil lances.This enhancemen t adds additi onal compone nts into the B uried Pipi ng Inspection P rogram which is conservative. On this basis, the project team f ound this enhancement acceptable since whe n the e nhanc ement i s impl emented , OCGS A MP B.1.26, "Buri ed Pi ping In specti on,"
196 wil l be c onsis tent w ith GA LL AM P XI.M 34 and wil l prov ide a dditi onal assura nce th at the effects of aging will be adequately managed.3.0.3.2.21.5 Operating Expe rience The applican t stated, in the OCGS LRA and program basis do cument, that a rev iew of pla nt operating exp erience at Oy ster Creek show s that there has been only one underground leak that devel oped as a res ult of failure of the external p ortion of buried pipe. In 1 992 the Serv ice Water system developed a leak that resul ted from failure of the ex ternal coatin
: g. The root cause eval uatio n dete rmined that fai lure w as due to imp roper o rigina l coa ting ap plic ation. Subse quentl y, Oy ster Cr eek ini tiated the Oy ster Cr eek Und ergroun d Pip ing Pro gram.Additional ly, in 1 980, 1992 &
1996 leaks de veloped in buried aluminum Con densate Transfer pipe. As a resul t 90% o f the AL pipi ng was repla ced an d relo cated abov eground. Subsequently , Oyster Creek in itiated the Oyster Creek Und erground Pipin g Program in whi ch the inspecti on and modifica tions of the remai ning 25 feet of burie d AL Conde nsate Transfer system pipe are tracked. The pri mary contribu tor of the buried aluminum pi pe at Oyster C reek high corrosion rate is galv anic corrosi on. The galva nic mechanis m is primaril y due to th e interaction b etween the aluminum pi pe wall and the la rge copper groundin g grind located o n the west side of the plant. The grounding grid protects the main trans formers and other el ectrical equipment and l ies in the same footprint as the majority o f the direct buri ed aluminum pipe;before it was replaced by above ground pipe. The dissimilar metals and m oisture in the soil resul t in a high e lectri cal/ch emical poten tial that dr ive the gal vani c corro sion. Corro sion occurs in local areas whe re the coating w as not properl y appli ed or has broken down. By moving the AL pi pe to a bove ground the agi ng mecha nism o f galva nic co rrosio n conc ern is elimi nated. Additional ly, the Oy ster Creek Underground Piping Program tra cks the inspecti on and modifications o f the remaining 25 feet of buried AL C ondensate Transfer sy stem pipe. To da te, there have been no othe r buried pi pe leaks due to external degradation.
Although failure of buried pip ing has occurred , it has been determined tha t the integrity of the buried piping leaks were caused by degradation of the inside of the buried piping which is evaluated with the Open Cycl e Closed C ooling Water aging management program. The existing Bu ried Pipi ng Inspection agi ng management program has i dentified the l oss of material due to general corrosion, pitt ing, crevice corrosion and MIC of fer rous materials and change in material prope rties on the e xternal surfaces of buried pip
: e. The experi ence at Oyster Creek with the Buried Piping Inspection Program shows that the Buried Piping Inspection Progr am is effective in managi ng loss of material due to general corrosion, pi tting, crevice corrosion and MIC of ferrous materi als and cha nge in material properties on the externa l surfaces of buried pipe.Operati ng exp erien ce, bo th int ernal and e xtern al, i s used in tw o wa ys at Oyste r Cree k to enhance pla nt programs, preven t repeat eve nts, and prev ent events th at have oc curred at other plants from occur ring at Oyster Creek. The first way in which operating experience is used is through the Oyster Creek Operating Ex perience proc ess. The Operatin g Experience process screens, eva luates, and a cts on operati ng experienc e documents and information to pre vent or mitigate the conse quences of simila r events. The second wa y is throu gh the process for managing programs. This pro cess requires the review of program related op erating experi ence by th e progra m own er.Demons tratio n that t he eff ects of aging are eff ectively ma naged is achieved th rough object ive evidence that shows that loss of materi al is bei ng adequately managed in the B uried Pipi ng 197 Inspec tion Pro gram. The f ollowing exam ples of operati ng exper ience pro vide objec tive evidence that the Buri ed Piping In spection Program i s effective in a ssuring that inte nded function(s) wi ll be main tained consi stent with the CLB for the p eriod of exten ded operation
: The applican t has no ex ceptions to N UREG-1801. El ement 3 and ha s added enha ncements by includin g fire protection co mponents to the s cope of the program. In addition, the applican t has condu cted n umerou s insp ectio ns and has i denti fied key loca tions to in spect o n a regu lar ba sis. When coating degradation or damage to pipe is discovere d, corrective action is taken. About half of the ESW piping has bee n replaced a nd the remaind er will be replaced before the perio d of extended op eration.Oyster Creek h as per formed nu merous exter nal i nspect ions of thei r buri ed comp onents between 1 991 and prese nt day. The res ults of these in spections ha ve show n no significan t external co ating failures. Co atings have been repaire d during these inspections in accordan ce with corpo rate procedures.
In 20 04, 5 0% of the b urie d ES W and 10% of S W pipin g we re re pla ced wi th ne w, c oate d pi pin g.The project team asked th e applica nt when th e remaining pi pe wil l be repla ced. In its l etter dated May 1, 2006 (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to replac e the previo usly un-re placed buri ed safety-related ESW piping prior to the period of exte nded operat ion. This is a A udit Commitment 3.0.3.2.2 1-1.In 1993 an i nspection of 20 feet of RBCCW was performed and the results show ed that the exter nal c oatin g was in goo d cond ition..In 199 2 the F ire Pr otecti on sy stem un dergrou nd pi ping w as in specte d vi a exc avati on and some internal i nspection. The E xternal coa ting was i n good conditi on as we ll as the internal carb on steel.In 19 80 th e un coat ed a lumi num u nder groun d pi pin g in the v ici nity of th e co nden sate stor age tank was repl aced. In 1991 and 1994 b uried pipi ng adjacent to the condensate trans fer shack was determi ned to hav e severe co rrosion durin g an inspecti on. As a res ult, a significa nt modific ation was performed whi ch rel ocated alumi num pi ping a bove ground, in tu nnels or va ults. Currently 9 0% of all AL piping is l ocated abov eground. The remain ing buried A L pipe w as inspected i n 1993 and has an ex pected servi ce life of 15-20 y ears. Action Request A211612 6 has been sub mitted to perform and i nspection of the remaining burie d, uncoated AL pipe prio r to December 200
: 8. The remaini ng buried AL piping does have cathod ic protection
.The oper atin g exp erie nce o f th e Oyst er Cr eek Burie d Pipin g In spec tion Prog ram has sh own objective e vidence that the program has identified su sceptible b uried pipe locations and has created an moni toring program that has been effective i n preventi ng failures prior to the loss o f system intend ed function.
The operating ex perience of the Buried Pi ping Inspection Program did not show any adverse tre nd in pe rfor man ce. Pr obl ems id ent ifi ed wo ul d n ot c aus e si gni fic ant imp act to the saf e operat ion o f the pl ant, an d adequ ate co rrecti ve ac tions were taken to prev ent rec urrenc e. There is sufficient c onfidence that the implementatio n of the Buried Piping Inspec tion Program will effectively de termine loss o f material due to the manage the effects of corrosi on on the pressure-retaini ng capacity of buried pipi ng. Appropriate guidance for reev aluation, rep air or replacement is provided for locations where loss of material was identified. Periodic 198 self-assessments of the B uried Pipi ng Inspection P rogram are performed to id entify the area s that ne ed imp rovem ent to mainta in the quali ty pe rformance of the p rogram.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Buried Pi ping Inspec tion P rogram w ill adequa tely manage the agi ng effects that ar e ide ntifie d in t he OCGS LRA for whi ch this AM P is credi ted.3.0.3.2.21.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for Bur ied Piping Inspection Program in OCGS LRA, Appe ndix A, S ection A.1.26, which sta ted that the Bu ried Pipi ng Inspection Program in OCGS LR A, Appendix A, Section A.2.2, whi ch stated that the buried pi pe inspecti on aging management program is an existi ng program that manages the external su rface aging effect s of loss of mater ial for piping and piping system componen ts in a soil (external) environment.
The Oyster Cree k buried pipi ng activiti es consist of pre ventive and condition-moni toring measures to ma nage the loss of material due to external corrosion for piping, piping system component s in the scope of license renewal that are in a soil (external)env ironment. The program w ill be e nhanced to i nclude in spection of buri ed piping within ten years of en tering the perio d of extended operation, unl ess an opportu nistic ins pection occurs wi thin this ten-year perio
: d. The program wi ll also be enhanced to include the buried portions of the fire protection sy stem and the pi ping located inside the vault in the scope of the program. Exte rnal i nspect ions of buri ed comp onents wil l occu r oppo rtunis tical ly w hen th ey ar e excavate d during mainten ance. Upon entering the peri od of extended operation, i nspection of burie d pip ing w ill be per formed w ithin ten y ears, u nless an op portun istic insp ectio n occu rs within this ten-yea r period. Pro gram enhancements w ill be i mplemented prio r to entering the period of exte nded operatio n.The pro ject t eam also reviewed the applicant
's license renewal com mitme nt list in Ap pendix A of the OCGS LRA, and conf irmed that the enhancemen ts to this program ar e identified and will be implemented prior to the period of exte nded operatio n as item 26 of the commitments. The project team also review ed the appl icant's Aud it Commitment (3.0.3.2
.21-1) to replac e the remaining ESW piping prior to the period of extended op eration and this wi ll also be implemented pri or to the peri od of extended operation.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.26. Contingent up on the inclusi on of audit commitmen t 3.0.3.2.21-1, the project team found that it was co nsistent with the GALL Report, and determined tha t it provi des an adequate summary descri ption of the program, as identi fied in the S RP-LR FSAR Supplement ta ble and as required by 10 CFR 54.21(d).3.0.3.2.21.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to 199 manage the aging effects for whi ch it is cre dited. Als o, the project team has revie wed the enhancements an d commitment 3.0.3.2.21
-1 and determin ed that the i mplementation o f the enhancements pri or to the peri od of extended operation w ould result in the ex isting AM P being consistent w ith the GALL R eport AMP to whic h it was compared. The pro ject team also reviewed the UFSAR Supplement for this AMP and, contingent upon the inclusion of audit commitment 3.0.3.2.21-2, found that it prov ides an ad equate summary des cription of the program, as requi red by 10 CF R 54.2 1(d).3.0.3.2.22 ASME S ection XI, Subse ction IWE (OCGS AMP B.1.2 7)In OCGS LRA, Ap pendix B , Section B.1
.27, the appli cant stated that OC GS AMP B.1.27,?ASME S ection XI, Subse ction IWE," is an exis ting plant program tha t is consis tent with GALL AMP XI.S1, "A SME Sec tion XI, Subsecti on IWE," with an exce ption.3.0.3.2.22.1 Program Descriptio n The app lica nt stat ed, in the OC GS LRA , that t his p rogram pr ovid es for i nspect ion o f primary containment compo nents and the containment v acuum breakers sy stem piping and components. It i s implemented through station pl ans and proce dures and cov ers steel containment she lls and th eir integral a ttachments; contain ment hatches and airlocks, seal s and gaskets, containment v acuum breakers sy stem piping and components, and pressure retai ning bolting. The progr am includes visual examination and limited surface or volumetric examinatio n, when a ugmented examin ation is requi red, to detect l oss of material.
The program also prov ides for managing lo ss of sealing for sea ls and gaskets, and loss of prelo ad for pressure retain ing bolting. P rocurement control s and instal lation practi ces, defined in plant procedures, ensu re that only approved lubricants a nd tension o r torque are appl ied. The Oyster Creek program comp lies w ith Subsecti on IWE for steel containments (Cl ass MC) o f ASME S ection XI, 1992 Edition i ncluding 199 2 Addenda i n accordance with the provisio ns of 10 CFR 50.55a.
3.0.3.2.22.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.27 is cons istent wi th GALL AMP XI.S1, w ith an ex ception.The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.27, incl uding PBD-A MP-B.1.27, ?ASME S ection XI, Subse ction IWE," Revision 0 , which provides an assessment of the AM P elements' co nsistency with GALL AMP XI.S1.
Specificall y, the project team re view ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report)contained i n OCGS AMP B.1.27 and a ssociated ba ses documents to determine consi stency with GALL AMP XI.S1.
During the on-si te audits on October 3-7, 2005, January 23-2 7, 2006, Februa ry 13-17, 20 06, and Ap ril 1 9-20, 2 006, th e proje ct team condu cted a n in-d epth re view of (1) th e OCGS histo ry of containment degrada tion due to corrosion; (2) th e corrective actions taken a t the time; (3) the curren t IWE augmented insp ectio ns, an d othe r progra ms and activ ities to moni tor/mit igate additional corrosion; an d (4) the appl icant's li cense renew al commitments to manage aging of the degraded conta inment during the extended period of operati on.
200 The project team had numerous discu ssions w ith the appl icant's staff and su bmitted numerous questions to the applicant c oncerning contai nment degradation.
The project team al so review ed a number of i nspection rep orts, analys is reports, and official correspon dence betw een the staff and the appl icant, related to the contai nment degradation.
Through the au dit pr ocess, the ap plic ant mad e a nu mber of s ignific ant ne w com mitment s to manage aging of the dry well s hell. How ever, three i ssues remain u nresolved.
The project team's revi ew of the app licant's i nitial l icense renew al commitments, the developmen t of the applicant's new commitments, and the re maining unresolved issues are chronicled below, via the project team's questions and th e applica nt's responses
.The project team focused on the follow ing four specific are as related to the containment degradation:
: 1) Water leakage from the refueling cavi ty into the annulus b etween the drywel l and the shield wall;
: 2) Corrosion of the upper dry well re gion above the former sand bed region;3) Corrosion of the former sand bed re gion of the dryw ell; and 4) Pit ting Co rrosio n of the suppr essio n chamb er (toru s).The operating ex perience and proposed agin g management activi ties for each of these areas were rev iewed i n detail, a nd additio nal information was obtai ned, as neces sary, to facili tate a thorou gh eva luati on of th e appl icant's agi ng manage ment pl ans for t he li cence renew al pe riod. The results of this detailed a udit are docu mented in the following p aragraphs. The dis cussion first documents the p roject team's aud it questions, an d the appli cant's respons es, in each of these four areas. A pplicabl e question numbe rs from the audit questi on and answ er database are also prov ided as a reference in the following se ctions. The proje ct team's eva luation of the applicant' s commitments for each o f these four areas is provided at the end of thi s section.
Water Le akage from  th e Refu elin g Cavi ty During the projec t team's discu ssions w ith the appl icant's staff on October 4 , 2005, concern ing the OCGS ASM E Section XI, S ubsection IWE aging management program (AM P B.1.27), the appli cant st ated th at a sp ecial coati ng is a ppli ed, pri or to fl oodin g the re actor for refuel ing, to prevent leakage into the annular space between the drywell shell and the concrete shield wall (refuel ing cav ity). As a resul t, the a ppli cant b elie ves t hat w ater i ntrusi on in to the refueli ng cav ity has been eliminated as a source for f urther degradat ion on the exterior surface of the drywell shell.Since the a pplicant us ed this spec ial coati ng to minimiz e water i ntrusion into the annulu s between the drywel l and the c oncrete shiel d wall , in audit question AM P-118, the projec t team asked the applicant to specif ically identify whether it is committed to continue the use of th is speci al co ating a s part of its re fuelin g proced ure thr ough th e ext ended perio d of ope ration. If not, the appli cant was a sked to identify what enh anced inspe ctions wi ll be con ducted during the extended p eriod of operati on in order to monitor poten tial corrosi on on the dry well e xterior surface from the upper flange re gion to the san d bed region.
201 In its respo nse, th e appl icant stated that th e coat ing ap plie d to th e reac tor cav ity l iner p rior to refueli ng was not cr edite d in t he li cense renew al ap plic ation as an aging ma nagemen t acti vity for managing loss of materia l due to co rrosion on the exterior s urfaces of the dryw ell. The coati ng was consi dered one of t he many good p ractic es imp lement ed dur ing the curren t term to minimize water intrusion in the annular space between the drywell shell and the drywell shield wall. The coating also facilitates de contamination of the reactor cav ity post refuel ing. The applicant c onsidered the credited AS ME Secti on XI, Subsectio n IWE program (B.1.27), 10 CFR 50, Appendi x J program (B.1.29
), and the Prote ctive Coa ting Moni toring and M aintenance Program (B.1.33), wh ich is cred ited for monitorin g protective co atings on the e xterior surfaces of the drywell shell in the sand bed region, adequate to manag e corrosion of the drywell shell.
During discus sions wi th the appli cant's techni cal staff on January 26, 2006, the applicant w as asked to provi de the techni cal basis for not crediting the use of the speci al coating as part of the Oyster Cree k refueling procedure to mitigate wa ter leakage into th e annulus during the period of exte nded operatio
: n. In response , the appli cant stated that th e strippable coating has been e ffective in mi tigati ng wat er int rusio n into the an nular space. The a ppli cant co mmitted to applyin g the strippabl e coating to the reactor cavi ty liner prior to floodi ng for refueling during the period of extended operation. This cons titutes a new commitment not pr eviously identified in the LR A, and was docume nted a s a sup plemen tal re sponse to aud it ques tion A MP-1 18. In its letter dated A pril 4, 200 6 (ML060970288), the app licant committed to the follow ing: Consisten t with curren t practice, a stri ppable coati ng will be appli ed to the reacto r cavity liner to p revent water intrus ion into th e gap betwee n the dryw ell shie ld wal l and the d rywell shell du ring periods when the refueling cavi ty is floode
: d. This commitment a pplies to refueling outages pri or to and during the peri od of extended operation.
This is Aud it Commitment 3.0.3.2.22-1
.In rev iew ing pro gram bas is do cument PBD-A MP-B.1.27 fo r the a ppli cant's ASM E Sect ion XI, Subsection IWE aging management program (B.1
.27), the project tea m noted that, on page 7 of this docume nt, the appl icant stated that ?Under the curren t term, Oyster Creek i s committed to the NRC to monitor the for mer sand bed region drains f or water leakage. The com mitment is to i nve stig ate t he s ourc e of l eaka ge, ta ke co rrec tiv e ac tion s, ev alu ate t he i mpac t of th e le akage and, if necessary , perform additiona l dryw ell insp ections. This commitment wil l be imple mented during the period of extended oper ation. This is a new commitment not previously identified in the LRA." In i ts letter dated April 4, 20 06 (ML060970288), the ap plicant commi tted to the following: The reactor cavi ty seal l eakage trough drains a nd the dryw ell sand bed region drai ns will be monitored for w ater leakage perio dically. This is Aud it Commitment 3.0.3.2.22-2
.The project team asked th e applica nt to describe this commitment i n more detail , includi ng the following i nformation in aud it question AM P-205:*Is th is c onti nuou s mon itor ing o r out age m oni tori ng?*What have b een th e resu lts of th e curre nt wa ter le akage mon itori ng acti viti es, w ith respect to inv estigating the sou rce of leakage, taking correcti ve action s, evalua ting the impact of the lea kage and, if necessary performing additio nal dryw ell insp ections?*If no water le akage has been de tected under the previous commitment, describ e any preve ntiv e acti ons ta ken to a llev iate t he pre viou s wat er lea kage prob lem.In its response, the applicant stat ed that the commitme nt for monitoring the sand bed drains is contained i n an NRC S afety Eval uation Repo rt (SER) transmitted in a lette r dated Nov ember 1, 1995. This SE R requested a co mmitment be made to perform inspections
?3 months after the 202 discovery of any w ater leakage". Subs equent corresponde nce from GPUN clari fied the commitment af ter discussions with the NRC. The commitme nt made and accepted by the NRC in a letter dated February 15, 1996, was to perfor m additional inspections of the drywell 3 months after discovery of any water leakage during power operation between scheduled drywell inspections. The requirement w as not meant to a pply to mi nor leakage associ ated with normal refueling activ ities. This in part is believe d to be the p resent commitment and the commitment contained i n the appli cant's program basi s document, PBD-AMP-B.1.27
.The applican t further stated in i ts response that there are no cu rrent formal leakage moni toring activiti es in pla ce. Although th e monitoring has not been formali zed, the ap plicant state d that there has been no reported e vidence of leakage from the former sand bed drains. The applicant a lso stated tha t Issue Report #
348545 w as submitted i nto the correcti ve action program when thi s was di scovered. C orrective ac tions hav e been ini tiated to create recurring activ ities contro lled wit h the w ork mana gement p rocess and p rocedu res, to perform a ll futu re required inspe ctions to meet th e present day commitment. The app licant has stated that sin ce there has been no reported l eakage, there has bee n no need to investi gate the source of leakage , take co rrecti ve ac tions , eva luate the i mpact o f the le akage an d, if ne cessar y performing additiona l dryw ell insp ections.The applican t further stated that acti ons taken to all eviate the previous water le akage problem have been numerous, since the discovery of the leakag e, and consequential drywell shell corrosion. Some of the sig nificant actions consisted of inspections of the reactor cavity wall, remote visua l inspecti on of the trough area below th e reactor cav ity bell ows seal area, and subsequent repai r of the trough area an d clearing of the drain from the trough are
: a. Clearin g of the trough drain and repair of the trough assure rout ing of any leakage away from th e drywell shell. In addition, a strippable coating is ap plied to th e reactor cav ity wa lls prior to filling the reactor cavi ty with water to mi nimize the likelihoo d of leakage into th e trough area. These preventiv e actions ha ve resulted in the la ck of evidence of leakage over the years at the former sand bed drai ns.Corrosion of the Upper Drywel l above the Former Sand Be d Region In review ing the lice nse renewa l information for the upper region of the drywel l shell, the project team noted that the applicant ref erred to the LRA Section 4.7.2 Drywell Corrosion TLAA evaluati on for further discussi on. In LRA Section 4.7.2, the applica nt stated that the dispositi on of this TLAA is in accordanc e with 1 0 CFR 54.21 (c)(1)(iii), and the Oyster Cre ek ASME S ection XI, Subsection IWE aging management program i s credited to address the dry well c orrosion TLA A. In LRA Se ctio n 4.7.2, under Analys is, t he app lican t sta ted t hat t he Oys ter Cree k ASME Section XI, Subsection IW E aging managem ent program (B.
1.27) ensures that the red uction in vesse l thi ckness wil l not adve rsely affect the abil ity o f the dry wel l to p erform it s safety functio n. The ASME Section XI, Sub section IWE aging management program ensures that the appl icant performs periodic UT inspection s at critical locations; performs calculati ons to track corrosi on rates; projects v essel thickness based on co nservativ es corrosion rates; and demons trates that the minimum require d vessel thickness is mai ntained.The app lica nt furthe r state d in t he LRA that i nspect ions condu cted si nce 19 92 demo nstrate that, as a result of cor rective a ctions, the corr osion rat es are ver y low or, in som e cases, have been a rrested. The d ryw ell s urfaces that w ere co ated d o not s how signs o f deteri oratio n. Drywel l vessel wall thickness measuremen ts indicate there is subs tantial margin to the minimum wal l thickness, ev en when projected to the y ear 2029 usi ng conservativ e estimates of the corrosion rates. Th e applicant stated that continued assess ment of the observed drywell 203 vessel thi ckness ensures tha t timely ac tion can be taken to correct degrada tion that coul d lead to loss of the i ntended function.
The project team rev iewed th e applica nt's discuss ion of aging management a ctivitie s for the upper region of the drywel l shell and determined that additi onal information was nee ded pertaining to th e augmented scope of IW E, as describ ed above.
The project team asked the applicant to provide the followi ng information in audit question AMP-70: (a) Confirm that the s tated activi ties are curren tly inco rporated into, a nd implemented as part of t he ex istin g IWE program, (b) Provide the IWE implementing procedure s for these activ ities, (c) Clarify the scope of thes e activities with regard to whether the sand bed region, in addition to the upper regio n of the dryw ell shel l, is also included in the augmented scope; and whether other locations are reg ularly or randomly checked, to ensure that all degraded areas a re known and monitored, (d) Provide the measured w all thickness history, the corrosion rate trending resul ts, the projected remaini ng wall thickness at the end of the exte nded period of operation, an d the CLB mini mum required wa ll thickness for each locatio n that is moni tored, (e) Ide ntify the cu rrent fre quency of augmen ted UT i nspect ions, corros ion ra te calculatio ns, and end-of-opera ting life thickness calculati ons, and (f) Ident ify th e pla nned fre quency of augmen ted UT i nspect ions, corros ion ra te calculatio ns, and end-of-opera ting life thickness calculati ons for the exte nded period of operation.
In response, the applicant s tated that Oyster Creek was co mmitted to the dry well c orrosion program in 1986 b efore implementatio n of IWE in September 9, 2001.
The program elements, includin g periodic UT i nspections a t critical l ocations, performing ca lculations to track corrosion rates, projecting v essel thickness based on co nservativ e corrosion ra tes, and demonstra ting that the minimum re quired vesse l thickness i s maintained are now incorporated i nto IWE as an augmented inspecti on. The appli cant provid ed procedures ER-AA-330, ER-AA-330-007, OC-6
, and 24 00-G MM-390 0.52 for revie w.The applicant furth er stated in its response that examination of the drywell interior surfaces in the former sand bed region is in cluded as p art of the ASM E Section XI IWE inspectio ns. The inspection of the exterior surfaces of the dryw ell in th e sand bed region is in cluded in the protec tive coati ngs and monito ring pr ogram (B.1.33).The applican t also prov ided a tabu lation of measure d thicknesses for the monitored ele vation of the upper region of the dryw ell shel l, along w ith calcul ation 1302-18 7-E310-0037, w hich summarizes tren ding results, pro jected remainin g wall thi ckness at the end of the extende d period of operati on, and the C LB minimum requi red thickness.
The applican t further stated that UT i nspections a re performed every other refueling ou tage, and that calc ulation 13 02-187-E310-00 37 provid es the corrosi on calcula tion, and end-of-operating li fe thickness calcul ation.
204 In its letter dated April 4, 2006 (ML060970288), the applicant committed to conduct UT thic knes s mea sure ment s in the uppe r regi ons of the dry wel l sh ell eve ry o ther refue lin g out age at the same lo cations as a re currently measured. This w ill be p erformed every other refueling outage prior to a nd during the p eriod of exten ded operation. This is Aud it Commitment 3.0.3.2.22-3.
In rev iew ing pro gram bas is do cument PBD-A MP-B.1.27 fo r the a ppli cant's ASM E Sect ion XI, Subsection IWE aging management program, the project team noted that, in the discussion on pages 25 through 31 related to d rywell corrosion ab ove the sa nd bed region, the applica nt stated that "Correc tive acti on for these regions involv ed provid ing a corrosio n allow ance by demons tratin g, throu gh anal ysis , that t he ori ginal dryw ell d esign p ressur e wa s cons ervat ive. Amen dmen t 165 to th e Oy ster Cre ek Tec hni cal Spe cifi cati ons redu ced the d ryw ell des ign pressure from 62 psi g to 44 psig. The n ew desi gn pressure coupl ed with measures to prev ent water intrus ion into th e gap betwee n the dryw ell shel l and the c oncrete wi ll allo w the upp er portio n of the dryw ell t o meet A SME code require ments." The pro ject tea m asked the ap plic ant to descri be the measur es to p reven t wat er int rusio n into the gap betwe en the dryw ell shel l and the c oncrete that w ill all ow the up per portion o f the drywel l to meet ASM E code requiremen ts in audi t question AM P-210. In add ition, the a pplicant was further asked to clarify w hether these meas ures to preve nt water i ntrusion w ere credited for license ren ewal, an d, if not, to cla rify how A SME cod e requirements w ill be met during the extended p eriod of operati on.In its response , the appli cant stated that th e measures taken to prevent w ater intrusion into the gap bet ween the dr ywe ll sh ell a nd the concre te that wil l all ow th e uppe r porti on of th e dry wel l to main tain the ASM E co de re quir emen ts ar e the foll owi ng: 1. Cleared th e former sand bed re gion drains to improve the drainage path.
: 2. R epl aced reac tor c avi ty s teel trou gh dr ain gaske t, w hic h w as fo und to be lea king.3. Applied stainless steel type tape and strip pable coati ng to the reactor ca vity du ring refueli ng outa ges to s eal i denti fied cra cks in the sta inle ss stee l li ner.4. Confirmed that the reactor cavi ty concrete tro ugh drains are not clogged
: 5. Monito red former sand bed region drains and reactor cav ity concrete trough drains for leakage during refueli ng outages and pl ant operation.
The applican t further stated that Oy ster Creek is commi tted to implemen t these measures during the peri od of extended operation.
Corrosion of the Former Sand Bed Region of the Dryw ell In review ing information for the sand bed regio n at the bottom o f the drywel l, the project tea m noted that, in the AMP B.1.27 discus sion of operati ng experienc e, the appli cant stated that s and was r emove d and a prote ctiv e coat ing w as app lied to the shel l to mi tigate further c orrosi on. The coating is mon itored perio dically under LRA AMP B.1.3 3, Protectiv e Coating M onitoring and Mai ntenance Program, w hich is di scussed in Section 3.0.3.1
.8 of this audi t and revi ew report. The project te am review ed LRA AM P B.1.33, and determined that the aforementioned coating is i ncluded w ithin its scope. The projec t team noted that th e discussi on of operating 205 exper ienc e in LRA AMP B.1.33 is simil ar to the di scus sion of op erat ing e xperi ence in LRA A MP B.1.27.The project team rev iewed th e applica nt's aging management a ctivitie s for the former sand bed region of the d ryw ell s hell and d etermi ned th at add ition al in formatio n wa s need ed per taini ng to aging ma nagemen t of thi s regio n. In a udit qu estio n AM P-071, the ap plic ant w as aske d to provide th e followi ng information: (a) At the presen t time, is moni toring and mainte nance of the coati ng in the sand bed region inclu ded in the scope of the curren t Protective Coating M onitoring and M a i n t e n a n c e P r o gr a m o r i s i t p e r fo r m e d a s p a r t o f t h e c u r r e n t A S M E S e c t i o n X I I WE program?(b) Provide the implementi ng procedure for this activity , and (c) Does li cense renew al aging management o f the containment sh ell in th e sand bed region inclu de both the a ugmented IWE activities and the coating moni toring and maintenance ac tivities under B.1.33?
If only B.1
.33 is credi ted, provid e the technic al basis f or conclu ding th at the au gment ed IW E activitie s are not necessa ry.In response, the applicant s tated that monitori ng and maintenan ce of the coating i n the former sand bed regio n is incl uded in the scope of the Pro tective Co ating Moni toring and M aintenance Program (AMP B
.1.33). These acti vities a re in accorda nce with specifications SP-1302-32-03 5 and SP-9000-0 6-003, whi ch are incl uded wi th program B.1.33.
The applicant furth er stated in its response that ag ing management of the sand bed region is not in clud ed in t he aug ment ed ins pect ion re quir ed by AS ME Sect ion X I, Su bsec tion IW E (AMP B.1.27). As state d in AM P B.1.27 opera ting experie nce, correctiv e actions tha t include cleaning and coating of the sand bed regio n implemented in 1992 ha ve arrested c orrosion. The co ated surfaces were i nspected in 1994, 1996, 20 00, and 2004 , and the in spection sho wed no c oating failure or signs of degradation. Thus, the region is not subject to aug mented inspection in accordance w ith IWE-1240. The coating w ill be i nspected ev ery other refuel ing outage during the pe riod o f exten ded op eratio n cons isten t wi th NRC commit ments for the cu rrent te rm.As a result of discussions between the project team and the applica nt on January 26, 2006 an d April 20, 20 06, the appl icant suppl emented its i nitia l resp onse t o audi t questi on AM P-071, to inc lud e the foll owi ng:*Oyster Creek will also perform periodic UT inspections of the drywell shell thickness in the sand bed region. Detail s are provi ded in respo nse to audit questions AM P-141 and AMP-209.*Oyster Creek w ill als o enhance the Protective Coating M onitoring and Maintena nce Program (B.1.33) to requi re inspectio n of the coating cre dited for corrosio n (torus inte rnal , vent syste m int erna l, sa nd bed reg ion ext erna l) in a ccor danc e with A SME Section XI, Sub section IWE. Details are provided in the di scussion of aud it question AMP-188 later in thi s section.
*On Ap ril 20, 2006 , Oy ster Cre ek pr ovi ded supp leme ntal info rmati on o n tor us c oati ng.Refer to AMP
-072 response later in thi s section for thi s information.
206 Details of the enhancement to th e Protectiv e Coating M onitoring and Maintena nce Program (B.1.33) and the projec t team's evaluation of this AMP are discussed in Section 3.0.3.1.8 of this audit and re view report.Based on the applican t's initi al response to audit questi on AMP-0 71, the project tea m asked the appli cant to pr ovide its t echn ical b asis for not al so cr edit ing i ts AS ME IW E pro gra m (AMP B.1.27) for managing los s of material due to corrosion in the former sand bed region of the dryw ell, in au dit que stion AMP-141(a).The a ppl ica nt st ated , in its resp onse to a udi t que stio n AM P-14 1(a) the foll owi ng: That v isual insp ectio n of the conta inment dryw ell s hell , cond ucted in ac cordan ce wi th ASME Section XI, Subsection IW E, is credited for aging management of accessible areas of the contai nment dryw ell shel l. Typical ly this inspection is for internal surfaces of the d ryw ell. The ex terior surface s of the dryw ell s hell in th e sand bed re gion for Mark I containment i s considered inaccessi ble by A SME Sec tion XI, Subsecti on IWE, thus, visual inspection is not possi ble for a typi cal Mark I c ontainment, in cluding Oyste r Creek before the sand w as removed from the sand bed regio n in 1992.
After removal o f the sand, an epox y coating w as applie d to the ex terior surfaces of the d rywell shell i n the sand bed region. The reg ion was made accessible during refueling out ages for periodic inspection of the coating. Sub sequently, Oy ster Creek performed peri odic vi sual inspection of the coating in accordance with an NRC current licensing basis comm itme nt. This comm itme nt was imple ment ed pr ior t o imp leme ntat ion of ASME Section XI, Subsection IW E. As a result, inspection of the coating was conducted in accordance w ith the Protecti ve Coatin g Monitori ng and Mai ntenance Program. Oy ster Creek's evaluation of this aging management prog ram concluded the progr am is adequate to manage agi ng of the dryw ell shel l in the s and bed region during the peri od of extended op eration consi stent with the current li censing basis commitment, and tha t incl usion of the c oatin g inspe ction under the AS ME IWE ins pecti on is not re quired. Howeve r, Oyster Creek is amending this position an d will commit to monitor the protective coating on the exterior surf aces of the drywell in the sand bed region in accordance w ith the requiremen ts of ASME S ection XI, Subse ction IWE during the period of exte nded operatio n.In its letter d ated April 4, 2006 (M L060970288), th e applica nt committed to the following: P rior to the period of extended op eration, AmerGen w ill perform addi tional v isual in spections of the epoxy c oating that w as applie d to the ex terior surface of the dry well s hell in the sand bed region, such that the coated surfaces in all 1 0 drywe ll bays will have bee n inspected at least once. In addi tion, the in service i nspection (ISI) program will be enhanced to require ins pection of 100% of the epox y coating ev ery 10 y ears during the period of exte nded operatio
: n. These inspe ction s wi ll be performe d in a ccorda nce w ith AS ME S ectio n XI, Su bsecti on IWE. Performance of the insp ections w ill be s taggered such that at l east three bay s will be examin ed every oth er refueling outage.
This commitment appl ies prior to the period o f extended operation, and every te n years du ring the period of extended o peration. This is Au dit Commitment 3.0.3.2.22-4.
During discus sions wi th the appli cant's staff on October 4, 2 005, regarding the a ugmented inspe ction condu cted u nder A SME IWE, the app lica nt pres ented tabul ated i nspect ion re sults obtained from the m id-1980s to the present, to m onitor the remaining drywell wall thickness in the cyli ndrical and spherical regions whe re significant corro sion of the outsi de surface was previ ously detec ted. Th e proje ct team asked th e appl icant , in a udit qu estio n AM P-141(b), to prov ide (1) a co py o f thes e tab ula ted i nspe ctio n res ults , (2) a li st of the n omin al d esi gn 207 thicknesses in each region of the drywel l, (3) a li st of the minimum requi red thicknesses i n each region of the dry well, a nd (4) a li st of the projected rema ining wal l thicknesses in each regio n of the dryw ell in th e year 202 9.The applican t stated, in i ts response to a udit question AMP-141(b), that a tabula tion of ultrasonic testing (UT) thickness measur ement results in monitored are as of the drywell sphe rica l reg ion ab ove th e san d bed r egio n and i n the cylind rica l reg ion is inclu ded in the AS ME Section XI, Sub section IWE program basis documen t (PBD-AM P-B.1.27). The tabu lation contai ns in formatio n reque sted b y the staff and is av aila ble for revi ew d uring t he AM P audi t. The nominal d esign thicknesses of each region of the d rywell are:*Embedded shel l below the sand bed region:  0.676 inches*Sand bed regi on shell:
1.154 inches
*Spherical region at Ele vation 23 feet to 51 feet: 0.770 inches*Spherical region at Ele vation 51 feet to 65 feet: 0.722 inches*Transition from spheri cal to cyl indrical region: 2.625 i nches*Cylind rical region:
0.640 inches During the projec t team's discu ssions w ith the appl icant's staff on October 5 , 2005, the applicant d escribed the history and resolution of corrosion in the sand bed region. The applicant stated that, af ter discovery of corrosion in the sand bed reg ion of the drywell, thickness measure ments were taken fr om 1986 through 1992 to mon itor the progression of wall loss. Remedial actions were completed in early 1993. At that time, the rem aining wall thickness exc eeded the min imum required thi ckness. The appli cant conclud ed that it ha d comple tely correc ted the condi tions whi ch le d to th e corro sion, and te rminat ed its program to monitor the remai ning wall thickness. At th at time, the remai ning plant op erating life w as expe cted to be no more th an 16 years (end o f the cur rent l icens e term).As stated in the OCGS LRA, th e applica nt's aging management commitmen t for license renewal is limited to periodi c inspectio n of the coating tha t was appl ied to the e xterior surface o f the dryw ell as pa rt of the remedial actions. The ap plicant di d not make a li cense renew al commitment in the LRA to measure wall th ickness in the sand bed regi on in order to confirm the effectiveness of the reme dial acti ons taken. To facili tate evalu ation of the app licant's pos ition, in audit ques tion AM P-141(c), the proje ct team asked the ap plicant to p rovide the followin g information:
*Tabulated ins pection resul ts obtained b etween 19 86 and 1992 for the sand bed region.*The nominal d esign thickness i n the sand be d region.*The minimum required thickness in the sand bed region.*The minimum measured wall thickness in 1 992.*The minimum remain ing corrosion allowa nce in 199 2.*A de tail ed te chni cal bas is fo r con clu din g tha t the re i s no nee d to confi rm (th rough thickness measuremen ts) that corrosion has been a rrested in the sand bed regio n.The applican t stated, in i ts response to a udit question AMP-141(c), the followi ng: In December 1992, wi th approval from the NRC a p rotective ep oxy coa ting was ap plied to th e outside su rface 208 of the drywell shell in the sand bed region to prevent additional corrosion in that area. UT thickness measuremen ts taken in 1992 , and in 19 94, in the sa nd bed region from inside the drywell confirmed that the corrosion in the sand bed reg ion has been arrested. Periodic inspe ction of the c oatin g indi cates t hat the coati ng in t hat regi on is performi ng sati sfactori ly w ith no signs of deteriorat ion such as blisters, flakes, or discoloration, etc. Additional UT measurements, taken in 1996 from insid e the dryw ell in th e sand bed region show ed no ongoing corrosion and provi ded objectiv e eviden ce that corrosio n has been arrested.The applican t further stated that as a result of these UT measurements and the observed condition o f the coating, the ap plicant con cluded that c orrosion has been arrested a nd monitoring of t he protective coating alone, without additional UT measu rements, will adequately manage loss of materia l in the d rywell shell i n the sand be d region. How ever to prov ide addit ional assura nce th at the protec tive coati ng is p rovi ding a dequate protec tion t o ensu re drywell integrity, Oyster Creek will perform periodic conf irmatory UT inspections of the drywell shell in the sand bed region. The in itial UT meas urements wi ll be taken p rior to enterin g the period of extended operation and then every 10 years thereaf ter. The UT measur ements will be taken from inside the dryw ell at the same location s where the UT measurements w ere taken in 1996. This revises th e license renewal commitment communicate d to the NRC in a lette r from C. N. Swens on Site Vi ce President, Oyster Creek Generati ng Station to U. S. Nuclear Regulatory C ommission, "Add itional C ommitments Associa ted with Applicati on for renewed Operating License
- Oyster Cree k Generating Station", dated December 9, 2005. This letter commits to one-time inspection to be conduc ted prior to e ntering the peri od of extended operation.
As a result of discussions between the project team and the applica nt's staff on April 20, 2006, the applica nt supplemented its response to audit questi on AMP-1 41(c). The appl icant stated that Oy ster Cr eek is committ ed to t he foll owi ng: ?During the in itial UT i nspections o f the sand bed region from insi de the dryw ell, conduc ted prior to e ntering the peri od of extended operation, an attempt will be made to locate and evaluate some of the locally thinned areas identif ied in the 1992 inspection from t he exterior of the drywell. This will be performed using the latest UT methodology w ith exis ting shell p aint in pl ace. The UT thickness measurements for these locally thinned are as may be ta ken from either insi de the dryw ell or outsi de the dryw ell (sand bed re gion) t o limi t radi ation dose to as l ow a s reaso nably achi evab le (AL ARA)." In i ts l ette r dat ed A pril 4, 2 006, the appl ica nt co mmit ted t o the foll owi ng: Ultrasonic Tes ting (UT) thickness meas urements of the dry well s hell in the sand bed region will be performed on a freq uency of every 10 years. The initial inspection will occur prior to the period o f extended ope ration. The UT meas urements wi ll be taken from the i nside of the d ryw ell a t the s ame lo catio ns wh ere UT m easure ments w ere performed in 19 96. The insp ectio n resu lts w ill be comp ared to prev ious resul ts. Statistically significant deviations fr om the 1992, 1994, and 1996 UT results will result in correc tive actio ns tha t incl ude th e foll owi ng: a) p erform ad ditio nal U T measur ements to confirm the readin gs; b) notify NRC within 48 hours of confirmati on of the identi fied condition; c) conduct visual inspection of the externa l surface in the sand bed region in areas where any unex pected corrosio n may be de tected; d) perform engine ering evaluati on to assess th e extent of con dition and to determine i f additional inspections are required to a ssure dryw ell integrity
; and e) perform opera bility determination and justifi catio n for op eratio n unti l nex t insp ectio n. Thes e acti ons w ill be comp leted prior to restart from the associ ated o utage.
209 This is Au dit Co mmitment 3.0.3.2.22-5. Also, in i ts letter dated May 1, 2006 (AmerGen Lette r No. 2130-06-2 0328), the appl icant committed to the foll owing: Duri ng the next U T inspections to be performed on th e drywe ll sand bed region (reference AmerGen 4/4/06 l etter to NRC), a n attempt wi ll be made to locate and evaluate some of the local ly thinn ed areas ide ntified in the 1992 insp ection from the ex terior of the drywell. This testing will be performed using the latest UT methodology with existing shell paint in p lace. The UT thi ckness measurements for thes e locall y thinned areas may b e taken from eith er ins ide th e dry wel l or o utsid e the d ryw ell (sand b ed regi on) to limit radia tion d ose to as low as reasonabl y achiev able (ALAR A). This is Au dit Co mmitment 3.0.3.2.22-6.In rev iew ing pro gram bas is do cument PBD-A MP-B.1.27 fo r the a ppli cant's ASM E Sect ion XI, Subsection IWE aging management program (B.1
.27), the project tea m noted that, on page 17 of this docume nt, the appl icant stated that, ?As di scusse d wi th NRC staff duri ng the A MP a udit, Oyster Creek w ill perform one-ti me UT thickness measu rements of the dryw ell shel l, in the s and bed region, to c onfirm that the protecti ve coatin g is effective. The U T measurements wi ll be taken from inside the drywell at the same or approximate locations measured in 1996. This constitutes a n ew commitment th at will be implemen ted prior to e ntering the peri od of extended operat ion."The project team asked th e applica nt to provi de additio nal information related to thi s new commi tmen t, in aud it qu esti on A MP-209 , in clu din g the foll owi ng:*Has th is be en add ed to t he sco pe of th e one time i nspect ion p rogram (A MP B.1.24)?*How w ill this commitment be tracked and implemente d?*Are the loca tions selec ted for one-time in spection those that had the minimum remaining thicknes s based on p rior UT results, and if not, ex plain the technical b asis for why the selected l ocations are adequate?*W hat steps will be taken if the current conclus ion, that corrosion has been arrest ed, is not confirmed by the one-time i nspection?
In its response , the appli cant stated that th e one-time in spection commitmen t has not been added to One-Time Inspection Pro gram (AMP B.1.2 4). As discu ssed with NRC staff on January 26, 2006, Oyster C reek will perform periodic UT inspection s during the pe riod of extended o peration in stead of a one-time inspection. The initia l UT inspecti ons wil l occur prio r to entering the p eriod of exten ded operation and every 10 years thereafter. The project tea m noted that this is Audit Commitment 3.0.3.2.22-5 , which was disc ussed previ ously i n this secti on of the a udit a nd rev iew report.The applican t further stated in i ts response that this commitment w ill be tra cked in accorda nce with Oys ter Creek commitment trackin g process. Addi tionally , the commitment w ill be i ncluded in a revision to the Appendix A.5 commitment list, item #27, which will be submitted to the NRC and inc orpo rate d in the UFS AR s uppl emen t. Im ple ment atio n of t he c ommi tmen t wi ll b e thr ough the Oy ster Cr eek ASM E Sect ion XI, Subse ction IWE program.
The applican t stated the lo cations sel ected for UT measurements are the same as those inspected us ing UT measurements i n 1996 and include the thinnest measu red area. If the curren t concl usion that c orrosi on has been arreste d is n ot con firmed b y UT me asureme nts 210 taken pri or to ente ring the peri od o f ext ende d op erat ion , Oy ster Cre ek is comm itte d to take corrective a ctions defined in Audit C ommitment 3.0.3.2.22-5.
The project team asked th e applica nt to provi de a discus sion of the scop e of the current coa ting inspection program and the li cense renew al commitment, in the second p art of audit questio n AMP-209, includin g the followi ng information:
*What percent of the total circumference is inspecte d during each inspection?
*How many years and how many inspection s does it take to complete a 3 60 degree inspection of the sand bed region?*Whether a complete 360 degree i nspection be en completed yet, and*How many complete 360 degree inspecti ons wil l be comple ted during the l icense renewal period?In its response to the second part of audit questi on AMP-2 09, the appl icant stated th at protec tive coati ngs on t he ex terior surface s of the dryw ell s hell in th e sand bed re gion a re monitored in accordance w ith the Protecti ve Coatin g Monitori ng and Mai ntenance Program (B.1.33). The c urrent program r equire s vi sual inspe ction of the c oatin g in ac cordan ce wi th engineering spec ification IS-32 8227-004. Insp ection criteri a are not spec ifically provided by the specification.
Howev er, inspectio ns are performed by indivi duals quali fied to perform coating inspections. Acceptance criteria prov ided in th e specificatio n are that any identified c oating defects shall b e submitted for engin eering eval uation. The i nspection frequency is every other refueling outage.
The applican t further stated in i ts response that, as discussed with NR C Staff, the existi ng protective c oating monitorin g and maintenanc e aging management program (AM P B.1.33) does not currently invoke al l of the requirements of ASME Se ction XI, Subsec tion IWE. The appli cant a lso st ated th at Oys ter Cre ek is c ommitte d to en hanci ng the p rogram to inco rporate coated surface s insp ectio n requi rements speci fied i n ASM E Sect ion XI, Subse ction IWE. In response to NR C Question AM P-188, Oyster C reek provided specific enha ncements that w ill be made to the program as follows: Sand b ed Regi on ex ternal coati ng insp ectio ns wi ll be per Ex aminat ion C ategory E-C (augmented exami nation) and will require VT-1 vi sual exa minations pe r IWE-3412.1.
a.The i nspe cted area sha ll b e ex amin ed (a s a m ini mum) for ev ide nce of fla king, blistering, pe eling, disco loration, and other signs of di stress.b.Areas that are s uspect shall be disposi tioned by engineering ev aluation o r corrected by repair or repl acement in acc ordance wi th IWE-3122.
c.Supplemental examinati ons in acco rdance wi th IWE-3200 shall be performed when speci fied as a resu lt of en gineer ing ev aluat ion."The applican t further stated in i ts response that the coated surface of the drywe ll in the sand bed region is divide d into 10 b ays that con stitute 360 de grees. The current program re quires inspe ction of coati ngs in at lea st 2 ba ys ev ery o ther re fuelin g outage. Certa in ba ys w ere conside red crit ical and have been inspe cted mo re than o nce. Ins pection of 5 out of 10 bays (50%) has been completed to da te.
211 The applican t further stated that for li cense renew al, Oyster Cre ek is committed to inspect the remaining 5 ba ys prior to entering the pe riod of extend ed operation.
This wil l result i n a complete (100%) c oating inspecti on of all the 10 bays (3 60 degree) prior to entering the p eriod of extended op eration.The applican t also stated that Oyster Cree k is committed to i nspect the coati ng in accordanc e with AS ME Secti on XI, Subsectio n IWE. Thus, inspection of 100%
of the coating w ill be comple ted du ring ea ch Con tainme nt ISI 1 0-Year Interv al. In specti ons w ill be con ducted ever y other refueling outa ge during whi ch at least 3 bays (30% o f the coating minimu m) will be examined.
The applican t therefore expects to inspect 1 00% of the coating tw ice during the period of exte nded operatio
: n. The inspec tions wi ll be con ducted in ac cordance w ith the enhanced Pro tective Co ating Moni toring and M aintenance P rogram (B.1.33), incl uding enhancements di scussed in NRC Audi t Question AM P-188.The project team noted that the abov e commitments are i ncluded as part of Audit Co mmitment 3.0.3.2.22-4, whi ch wa s disc ussed previ ously in th is sec tion o f the au dit an d rev iew report.The project team als o noted that pa ges 25 through 31of the program basis docu ment (PBD-AMP-B.1.27) for the appl icant's AS ME Secti on XI, Subsectio n IWE aging management program, presented a discussion of the OCGS operatin g experience. This document stated that "As a resul t of the presence o f water in the sand bed regi on, extensi ve UT thickness measurements (about 1000) of the dry well s hell w ere taken to determi ne if degradation was occurring. These m easurements corre sponded to known water leaks and indicated that wall thinn ing ha d occu rred i n this region." The pro ject tea m asked the ap plic ant [au dit que stion AMP-210] t o exp lain the ab ove s tatemen t, and clarify whether the water lea ks referred to were limited to o nly a po rtion of the circumference, and w hether wal l thinnin g was found onl y in thes e areas.In its response , the appli cant stated that th is statement w as not meant to i ndicate that w ater leaks were limited to o nly a po rtion of the circu mference. The statement w as meant to reflect the fact that wate r leakage was observed co ming out of certain s and bed region drains and those locat ions were suspe ct of w all t hinni ng. Wall thi nning was n ot li mited t o the a reas w here water lea kage from the drains w as observed. Wall thinning occurred in all a reas of the sand bed region bas ed on UT measure ments and vi sual inspe ction of the area conducted after the sand was removed in 1992. How ever, the de gree of wall thinning va ried from location-to-lo cation. For example , 60% of the meas ured loca tions in t he sand be d regio n (bays 1, 3, 5, 7, 9, an d 15) indi cate that the av erage measured dry well s hell thic kness is nearl y the same as the design nominal thick ness, and that these locations experienced neg ligible wall thinning; w hereas bay 19A experi enced approx imately 30
% reduction i n wall thickness.
The project team also noted the following statement in PBD-AMP-B.1.27; "After sand rem oval, the concrete surface below th e sand w as found to be u nfinished w ith improper p rovision s for water drai nage. Correctiv e actions taken in this regio n during 1992 included; (1) cleaning of loose rust from the d rywell shell, foll owed by applicati on of epoxy coating and (2) removing the loose debri s from the concre te floo r follo wed by re buil ding a nd res hapin g the flo or wi th epo xy t o allow drainage of any water that ma y leak into the region. UT meas urements taken from the outside after cle aning verifie d loss of materia l projections that had been made based on measurements taken from the i nside of the dry well. There were, ho wever, so me areas thinn er than projected; bu t in all cases engineeri ng analysi s determined tha t the dryw ell shel l thickness satisfied ASM E code requiremen ts."  The project team a sked the appli cant to describ e the 212"concrete surface bel ow the san d" that is di scussed in this statement i n audit questi on AMP-210.In its respo nse, th e appl icant stated that th e conc rete su rface be low the sa nd w as in tended to be shaped to promote flow tow ard each of the fiv e sand bed drains. How ever once the sand was remov ed the appl icant disco vered that the floor was n ot properly finished and shaped as required to permit proper drainage.
There were l ow poin ts, craters, and rou gh surfaces that could allo w moi sture t o pool inste ad of flo win g smooth ly to ward the dr ains. These concre te surfaces were re furbished to fill low are as, smooth rough surfaces, and coat these surfaces with epox y coa ting to promot e impr oved drain age. The dryw ell s hell at jun cture o f the con crete floor was sealed with an elastomer to prevent water intrusion into the embedd ed drywell shell.
The project team asked th e applica nt to provi de the follow ing information rel ated to inspe ctions of the drywe ll sand b ed region in audit question AMP-210: (1) Identify the minimum recorded thickness in th e sand bed region from the outsid e inspection, and the mini mum recorded thicknes s in the san d bed region from the inside inspections. Is this con sistent wi th previou s information prov ided verb ally? (.8 06" minimu m)(2) What was the projected thi ckness based on measurements taken from the i nside?(3) Describe th e engineering a nalysis that determined satisfaction of ASM E code require ments a nd id entify the mi nimum r equire d thic kness v alue. Is thi s cons isten t wi th previ ous i nformati on pro vide d ver ball y? (.7 33" mi nimum)(4) Is the mini mum required thickness based on stre ss or buckling cri teria?(5) Reco ncile and co mpare the thick ness me asurem ents pr ovided in (1) and (3) ab ove with the 0.736" minimum corroded thick ness that was used in the NUREG-1540 analysis of the degraded Oyste r Creek sand bed region.In its response , the appli cant stated that th e minimum recorde d thickness in the sand bed region from outside i nspection i s 0.618 inch es. The minimum re corded thickness in the sand bed region from insi de inspecti ons is 0.603. These minimum re corded thicknesse s are isola ted local measur ement a nd rep resent a sin gle po int UT measure ment.On April 19 , 2006, the app licant supp lemented its response to au dit question A MP-210, sta ting that th e low est rec orded readi ng was 0.603 in De cember 1992. The ap plic ant sta ted tha t a rev iew of th e pre vio us re adi ngs fo r the peri od 1 990 thru 199 2, an d tw o su bseq uent read ings taken in Septembe r 1994 and 1 996, show this point s hould not b e considered valid. The average readi ng for this point ta ken in 1994 a nd 1996 w as 0.888 inc hes. Point 14 in loc ation 17D was the next l owest v alue of 0.646 i nches, recorded during the 1994 outage. A rev iew of readings at thi s same point, ta ken during the peri od from 1990 through 19 92, and subse quent readings taken in 1996 are consist ent with this value. Thus, the minimum recorded th ickness in the sand bed region from inside inspections is 0.646 i nches, instead of 0.603 inche s.The ap pl ica nt f urt her sta ted in it s re spo nse tha t th e 0.80 6 i nch es t hi ckn ess pro vi ded to the sta ff verba lly is an aver age min imum gen eral t hickne ss cal culat ed bas ed on 49 UT me asureme nts taken in an are a that is app roximately 6"x 6". Thus, the two l ocal isol ated minimum reco rded thicknesses cann ot be compared directly to the general th ickness of 0.806". The 0.806" 213 minimum avera ge thickness verb ally di scussed wi th the staff during the AM P audit w as recorded in l ocation 19A in 1994. L ower mini mum average thicknes s values were recorde d at the same locati on in 1991 (0.803") and i n September 199 2 (0.800"). How ever, the three values are wi thi n th e to le ran ce o f +/- 0.0 10" di scu sse d w ith the sta ff.The applican t further stated in i ts response that the minimum projec ted thickness de pends on whether the trended data i s before or after 1992, as demonstrated b y corrosion trends provi ded in response to audit questi on AMP-3 56. For li cense renew al, using corros ion rate trends after 1992 is ap propriate beca use of corrosion mitigating measures, s uch as remov al of the sand and coating of the shell. Then , using corrosion rate tr ends based on 1992, 1994, and 1996 UT data; and the mi nimum average th ickness measured in 1992 (0.8 00"), the minimum p rojected average thickness through 2009 an d beyond remains approx imately 0.8 00 inches.
The projected minimum thickness durin g and through the pe riod of extend ed operation will be reevaluate d after UT inspecti ons that wi ll be con ducted prior to entering the pe riod of extend ed operat ion, a nd after the pe riodi c UT in specti on ev ery 1 0 yea rs ther eafter.The applican t also stated in its respo nse that the en gineering anal ysis that d emonstrated compli ance t o ASM E code requir ements was p erformed in tw o parts , stress and s tabil ity analy sis w ith sa nd, an d stres s and stabi lity anal yses with out sa nd. The anal yses are documented in GE Reports Index No. 9-1, 9-2, 9-3, and 9-4, which were transmitted to the NRC in De cember 1990 a nd in 1991, respe ctiv ely. Index No. 9-3 and 9-4 w ere rev ised later to correc t errors iden tified durin g an in ternal audi t, and were resub mitted to the staff in J anuary 1992. The analys es ar e brie fly d escr ibed b elow.Summary of Anal yses: The drywel l shell thickness in th e sand bed region is bas ed on stabil ity anal ysis w ithout sand. As des cribed in detail in attachment 1 &
2, the analy sis is bas ed on a 36-d egree section model that takes adva ntage of symmetry of the drywel l with 10 vents.
The model incl udes the dry well s hell from the bas e of the sand be d region to the top of elliptic al head an d the vent and vent h eader. The torus is not incl uded in thi s model because the b ellows provide a very fle xible c onnection, w hich does n ot allow significant structural interact ion between the drywell and the torus. The analysis conservatively assumed that the shell thi ckness in the e ntire sand be d region has b een reduced uniformly to a thickness of 0.736 inches.The app lica nt's r espon se furthe r state d the fo llow ing: The basic approach used in the buckling evaluation follows the methodology outlined in ASME C ode Case N-2 84, Revis ion 0, w hich wa s reconcile d later w ith Revi sion 1 of the Code Case. Following the proc edure of this Code Ca se, the allowable com pressive stress is evaluated in three steps. In the f irst step, a theoretical buck ling stress is determined, and secondly modified usin g appropriate ca pacity an d plastici ty reduction factors. In the final step, the all owable compressive stress is obtai ned by di viding the buckling stress cal culated in the second step by a safety factor of 2.0 for Design an d Level A & B servi ce conditio ns, and 1.67 for Le vel C se rvice cond itions.Using the ap proach descri bed ab ove, the an alys is sho ws th at for th e most s evere design basis load combin ations, the l imits of ASM E Section III, Subsection N E 3213.10 are fu lly met. As d escr ibe d ab ove , the buc klin g ana lys is w as p erfor med a ssum ing a uniform gener al thickness of the sand bed reg ion of 0.736 inches. However the UT 214 measurements identif ied isolated, localized areas where the drywell shell thickness is less than 0.7 36 inches.
Acceptance for thes e areas wa s based on e ngineering calculatio n C-1302-187-5 320-024.The calculati on uses a
?Local Wall Acceptance Criterion". Thi s criterion c an be appl ied to small area s (less than 12" by 12"), which a re less than 0.736" thick as l ong as the small 12" by 12" area is at least 0.53 6" thick. How ever, the cal culation do es not provi de additional criteria as to the acceptab le distance between multiple smal l areas. Fo r example, the minimum required linear di stances betw een a 12" by 12" area thi nner than 0.736" but thic ker than 0.536", and another 12" b y 12" area thinner than 0
.736" but thicker than 0.536" were not provided.The actual data for two bay s (13 and 1) show that th ere are more than one 12" by 12" areas t hinner t han 0.73 6" but th icker than 0.5 36". Also , the act ual data f or two bays shows that there are more tha n one 2 1/2'" diameter areas th inner than 0
.736" but thicker than 0.490". Acc eptance is b ased on the fol lowing ev aluation.The effect of these very local w all thickness areas on the buckling of the shel l requires some discussi on of the bucklin g mechanism in a shell of rev olution un der an appl ied axial a nd lateral pressure load. To begin the d iscussion, w e will describe the buckling of a simply supported cy lindrical shell un der the influen ce of lateral p ressure and ax ial load. As d escribed in chapter 11 of the Theory of Elasti c Stabili ty, Second Edition, by Timoshenko and Gere, th in cyli ndrical she lls buckle in lobes in both the axial a nd circumferential di rections. These lobes are de fined as half w ave lengths of sinusoidal functions. The function s are governed by the rad ius, thickness a nd length of the cylinde r. If we look at a specific thi n-walle d cylin drical shel l both the l ength and radiu s wou ld b e es sent ial ly cons tant s an d if t he th ickn ess was cha nged loc all y th e ch ange would h ave to be significant and continuous o ver a majority of the lobe so that the compressive stress in the lobe wo uld exce ed the critic al buckling stre ss under the applied loads, thereby causing the shell to buckle locally. This approach can be easily extrapolated to any sh ell of revol ution that w ould exp erience both an axial load and lateral press ure as in the case of the dry well. This local lobe buckli ng is demonstrated in a GE Letter Repor t ?Sandbed Loc al Thinning a nd Raisin g the Fixi ty Height An alysis"where a 1 2 x 12 square inch secti on of the dryw ell sand bed region is reduced by 200 mils and a local buckle occurred in the finite ele ment eigenval ue extractio n analys is of the dryw ell. Therefore, to i nfluence the bu ckling of a shell the very local are as of reduced thickness would have to be contiguous and of the same thickness. This is al so cons iste nt w ith Cod e Ca se N-284 in S ecti on -1 700 whi ch i ndi cate s tha t the ave rage stress valu es in the sh ell shoul d be used for cal culating the b uckling stress. Therefore, an acceptabl e distance b etween area s of reduced thic kness is not requi red for an acce ptab le b uckl ing a nal ysi s ex cept that the area of re duce d thi ckne ss i s sma ll e noug h not to influe nce a buckli ng lob e of the shel l. The very loca l area s of thi ckness are dispersed over a wide area with varying thickness and as such will have a negligible effect on the buckling res ponse of the dry well. In addition , these very local w all areas are centered ab out the ven ts, which significantly stiffen the shell. This stiffening effect limits the sh ell buckli ng to a point i n the shell sand bed regi on whic h is locate d at the midpoint betw een two v ents.The acceptance c riteria for the thi ckness of 0.49 inch es confined to a n area less than 21/2 inches i n diameter ex periencing pri mary membrane + b ending stresses is based on ASME C ode, Section III, Subsection NE, Class M C Components, P aragraphs 215 NE-3213.2 Gross Structural Di scontinuity , NE-3213.10 L ocal Primary Membrane S tress, NE-3332.1 Openi ngs not Requirin g Reinforcement, NE-33 32.2 Required A rea of Reinforcement and NE-3335.1 Re inforcement of Mul tiple Openi ngs. The use of Paragraph NE-333 2.1 is li mited by the requirements of Paragraph s NE- 3213.2 and NE-3 213.10. I n pa rtic ula r NE-321 3.10 lim its the m erid ion al d ista nce betw een open ings without reinforcement to 2.5 x (square root of Rt). Also Paragraph NE-3335.1 only appli es to o penin gs in s hell s that are cl oser th an tw o times their aver age di ameter.The implicati ons of these paragraph s are that shel l failures at these locati ons from primar y stress es produ ced by pres sure can not occu r, provid ed opening s in shells ha ve sufficient reinforcement. The current design p ressure of 44 psi g for drywell requires a thickness of 0.4 79 inches in the sand bed region of the drywell. A review of all the UT data presented in Appendi x D of the ca lculation indicates th at all thi cknesses in the dryw ell s and be d regio n exc eed th e requi red pre ssure t hickne ss by a sub stanti al mar gin. Therefore, the requirements for pre ssure reinforcement s pecified in the previo us paragraph are not req uired for the very local wall thickness evaluation presented in Revisio n 0 of Calcul ation C-1302
-187-5320-024.
Review ing the stabil ity anal yses prov ided in b oth the GE Rep ort 9-4 and the GE Letter Report ?Sand bed Lo cal Thinnin g and Raisi ng the Fixi ty Height An alysis," a nd recognizing that the plate elemen ts in the sand bed region of the mod el are 3" x 3", it is clear that the circumferential bu ckling lobes for the drywel l are substan tially larger than the 2 1/2 inch diameter very local w all areas.
This, combined with the local rei nforcement surrounding these local are as, indicate s that these are as wil l have n o impact on th e buckli ng margin s in t he she ll. I t is a lso cl ear from t he GE L etter R eport t hat a u niform reduction in thickness of 27% to 0.536" over a one square foot are a would only cre ate a 9.5% reduction in the load facto r and theoretical buckling st ress for the whole drywell, resulting in the largest reducti on possibl
: e. In additi on to the reporte d result for the 2 7%reduction in wall thickness, a second buckling analysis was perfor med for a wall thickness reducti on of 13.5% ove r a one square foot a rea, which only red uced the loa d factor and theoretic al buckling stre ss by 3.5% for the whole drywel l, resulting i n the largest reduction possible. T o bring these results into perspec tive, a review of the NDE report s indicat e there a re 20 UT m easure d areas in the whole san d bed reg ion that have thickne sses l ess tha n the 0.736 i nch th icknes s used in GE Repor t 9-4, w hich cove r a cons erv ativ e tot al a rea o f 0.68 squa re fee t of th e dry wel l su rface wi th an ave rage thickness of 0.7 03" or a 4.5% reduction in wall thickness. There fore, to ef fectively change the buckli ng margins on the d rywell shell i n the sand be d region, a redu ced thickness wo uld have to cover a pproximatel y one square foot of shell area at a locatio n in the shel l that is most susceptible to buckling w ith a reducti on in thic kness greater than 25%. This lea ds to the conc lusion that the buckling of the s hell is unaffected by the distance betw een the ve ry local wall thicknesses; in fact these local areas could be cont iguo us p rov ide d the ir to tal area did not exc eed one squa re foo t and thei r av erage thickness wa s greater than the th ickness analy zed in th e GE Letter Rep ort, and provided the methodology of Code Case N-284 was employed to determine the allowa ble bucklin g load for the dry well. Furthermore, all of these very local w all areas are centered ab out the ven ts, which significantly stiffen the shell. This stiffening effect limits the sh ell buckli ng to a point i n the shell sand bed regi on, which is located at the midpoint betw een two v ents.
216 As part of its resp onse, the appl icant also stated that the mi nimum thickness of 0.7 33" is not correct. The correct mi nimum thickness i s 0.736". The min imum required thi ckness for the sand bed regi on i s co ntro lle d by buc klin g.The applican t also stated in its respo nse that it ca nnot reconcil e the difference betw een the current (low est measured) of 0.736" in NURE G-1540 and the minimum measured thickness of 0.806 inches discussed with the staff. Perhaps the v alue in N UREG-1540 sho uld be la beled min imu m re qui red by the Co de, as doc ume nte d i n se ve ral cor res pon den ces wi th t he sta ff, in ste ad of l ow est mea sur ed. In a l ett er d ate d S ept emb er 1 5, 1 995 , GP U p rov id ed the sta ff a table that lists sand bed region thick nesses. The table indicates that nom inal thickness is 1.154". The mini mum measured thickness in 1994 i s 0.806", and th e minimum thicknes s required by C ode is 0.736
". These thicknesse s are consiste nt with th ose discusse d with th e staff duri ng the A MP/A MR a udit.The project team also noted the following statement in PBD-AMP-B.1.27; "Evaluation of UT measurements taken from insi de the dryw ell, in th e former sand bed re gion, in 1992 , 1994, and 1996 confirmed tha t corrosion i s mitigated. It i s therefore conclu ded that corrosi on in the s and bed region has been arrested and no further lo ss of material i s expected.
Monitori ng of the coating in accordance with the Protective Coating Monitoring and Maintenance Program, will continue to e nsure that the c ontainment dry well s hell mainta ins its in tended function d uring the perio d of ex tended opera tion." The project team compare d the statement ab ove from PBD-AM-B.1.27 wi th a discussi on from NURE G-1540, publ ished in Ap ril 1 996, w hich incl udes t he foll owi ng state ments re lated to corrosion of the Oy ster Creek sand be d region: (page v ii) "How ever, to assu re that these measures are effective , the licens ee is required to perform periodi c UT measurements." an d (page 2) "As assura nce that the co rrosion rate i s slower than the rate ob tained from previ ous measurements, GPU i s committed to make UT mea surements period ically."  In audit ques tion AMP-210, t he app lica nt wa s asked to rec oncil e the a ging man agement commitme nt (one-time UT inspection and monitori ng of the conditio n of the coating) w ith the appa rent recommendation/ co mmitment documented i n NUREG-1540
.In its response , the appli cant stated that i ts review of NUREG-1540, p age 2, indica tes that the statements appear to be based on a 1991 or 1993 GPU commitment to per form periodic UT measurements. In fact, UT th ickness measurements were taken i n the sand be d region from inside the drywel l in 1992 and 1994.
The trend of the UT measu rements indica tes that corrosion has been arrested.
GPU informed NRC in a letter dated Septembe r 15, 1995 that UT measurements will be taken one more t ime, in 1996, and the epoxy coating will be inspected in 1996 and, as a minimum, again in 2000. The UT measurements w ere taken in 19 96, per the commitment, and confirmed the corrosion rate trend of 1992 and 1994.
The results of the 1992 , 199 4, an d 1996 UT me asur emen ts wer e pro vided to th e sta ff durin g th e AMP/A MR audits.The ap pl ica nt a lso sta ted tha t i n re spo nse to a GP U S ept emb er 1 5, 1 995 le tte r, N RC sta ff found the proposed chang es to the sand bed region commit ments (i.e. no additional UT measurements after 1996) reasonable a nd acceptabl
: e. This respon se is documen ted in a November 1, 1995, Safety Evaluation for the Drywell Monitoring Program. For license renewal, Oyster Creek had not committed to p erform UT inspection of the drywe ll shell in the san d bed region. How ever, in re sponse to an NRC audit question, Oyster C reek revised the commitment to perform UT inspecti ons periodi cally. The initial inspection will be conducted prior to ente ring the pe riod o f exten ded op eratio n and addit ional insp ectio ns wi ll be condu cted e very 10 y ears 217 thereafter. The UT measuremen ts will be taken from insid e the dryw ell at same locations a s 1996 UT campaign. This is Audit Comm itment 3.0.3.2.2 2-5, which was discussed previously in this section
.To assist the project team in its detailed assessment of the condition of the sand bed region, in audit question AMP-356 , the project team a sked the appli cant to provi de the follow ing addition al information:
(1) Identify the specific loca tions around the circumference i n the former sand be d region where UT thickness read ings have b een and w ill be ta ken from inside contai nment. C onfirm th at all poin ts prev iousl y rec orded wil l be i nclud ed in future inspections
.(2) Describe th e grid pattern at each locati on (meridiona l length, circu mferential length, grid point spacing, tot al number of point readings
), and graphically locate each grid pattern with in the former sand bed region.
(3) For each grid location, subm it a graph of remaining thickness versus time, using all inspection results obtai ned since th e initiati on of the program (both p rior to and foll owing remov al of th e sand and a ppli catio n of the exte rnal c oatin g).(4) Clearly describe the acceptance cri teria appli ed to each arra y of point thi ckness readings, incl uding both glob al (entire a rray) and l ocal (subregion of array) accepta nce criteria.In its response , the appli cant stated that th e circumference of the d rywell is div ided into 10 bays, desi gnated as bay s 1, 3, 5, 7, 9, 11,13, 15, 17, a nd 19. UT thi ckness readings ha ve been taken in each bay at one or more locations. The spec ific locations around the circumf erence in the former sand bed region where UT thickness read ing have b een taken from insid e containment are bay 1D, 3D, 5D, 7D, 9A, 9D, 11A, 11C, 13A, 13C, 13D, 15A, 15D, 17A, 17D, 17/19 Frame, 19A , 19B, and 19 C. For each location, U T measurements we re taken centered at elevation 11'-3". These represent the locations where UT measurements were taken in 1992, 1994, an d 1996. In a ddition, UT mea surements were taken one time i nside 2 trenc hes excavate d in dryw ell floor con crete. The purpose of these UT measuremen ts is to determi ne the extent o f corrosion in the lowe r portions of the sand bed regio n prior to remov ing the sand and making accessi ble for visu al inspecti on. Future UT thi ckness measurements w ill be ta ken at the same lo cations as th ose inspecte d in 1996, in accordanc e with th e Oyster Creek commitment documented in response to audit questi on AMP-1 41. This is Audit Commitment 3.0.3.2.22-5, w hich wa s discussed previousl y in thi s section.
The applican t further stated in i ts response that, for locations w here the ini tial inv estigations found significan t wall thinning (9D, 11A, 11C, 13A, 13D, 15D, 17A, 17D, 17/19 Fram e, 19A, 19B, and 19C) the grid pattern consists of a 7 x 7 grid cen tered at elev ation 11'-3 (meridian) and centered a t the centerli ne of the tested l ocation w ithin each bay, wh ich consis ts of a 6"x 6" square template. The grid spacing is 1" on center.
There are 49 poi nt readings. Fo r locations where the initial investigati ons found no si gnificant wal l thinnin g (1D, 3D, 5D, 7D , 9A, 13C, and 15A) the grid pa ttern consists o f 1 x 7 grid ce ntered at elev ation 11'-3" (meridian) on 1" centers.
The app lica nt furthe r state d that a graph repres entin g the re maini ng thic kness v ersus t ime using UT readin gs since the i nitiation of the program (both prio r to and follow ing removal of the sand and application of the external coating) for locations 9D, 11A, 11C, 13A, 13D, 15D, 17A, 218 17D, 17/19, 19 A, 19B, and 1 9C is inc luded in a graph provi ded to the proje ct team. Other locations (i.e. 1D, 3D, 5D , 7D, 9A, 13C , and 15A) are not inclu ded because wall th inning is n ot significant and the trend li ne wil l be essenti ally a straight line.
The applican t stated that the methodology an d acceptance criteria that w ere applie d to each grid of point thic kness readings, in cluding both global (entire array) ev aluation a nd local (subregion of array) are describe d in enginee ring specificatio n IS-328227-00 4 and in c alculation No. C-1302-1 87-530 0-011. The ap plic ant al so stat ed tha t these docume nts w ere su bmitted to the N RC in a l ett er da ted N ovem ber 2 6, 19 90 and provi ded t o the staf f du ring the AMP/AMR audit. A bri ef s umm ary of the m etho dolog y and ac cept ance crit eria is des crib ed bel ow.Summary of Me thodology an d Acceptance Criteria: The in itial loca tions whe re corr osion loss was m ost sev ere in 1986 and 19 87 w ere selec ted for r epeat inspe ction over time to measur e corro sion rate. F or loc ation s whe re the initia l inves tigations found si gnificant wal l thinnin g, UT inspection consisted of 49 indivi dual UT data points equall y spaced o ver a 6"x 6" area. Eac h new se t of 49 value s was then te sted for normal di stribution. The mean valu es of each grid w ere then compared to the re quired minimum un iform thickness criteri a of 0.736. In ad dition, each indivi dual readi ng was compare d to the loca l minimum require d criteria of 0.4 9". The basis for the requi red minimum uni form thickness criteria and the lo cal minimum required criteri a is prov ided in re sponse to a p revious N RC audit ques tion.A decrease i n the mean v alue ove r time is repre sentative o f corrosion. If corrosi on does not exist, the mean value will not vary wi th time except for random variations in the UT measure ments. If corros ion i s conti nuing, the mea n thic kness w ill decrea se li nearl y w ith time. Theref ore, the curve fit of the data is tested to determine if linear regression is appropriate, i n which case the corro sion rate is equal to the s lope of the li ne. If a slope exists, then upper and l ower 95% co nfidence interv als of the curv e fit are calcul ated.The lower 9 5% confidence i nterval i s then projected into the future an d compared to the required minimum u niform thickness crite ria of 0.736.
A similar process is applied to the thinnest individual reading in each grid. The curve f it of the data is te sted to determine if linear regress ion is ap propriate. If a sl ope exis ts, then th e low er 95% confide nce i nterv al is then p rojecte d into the futu re and compar ed to the requ ired m inimu m loca l thi ckness criter ia of 0.49".The project team asked th e applica nt to provi de the follow ing information rel ated to the evaluation of the results obtained in the next UT inspection of the sand bed region in audit question AM P-357: (1) When a new set of poin t thickness readi ngs is taken is the former sand bed region, prior to enteri ng the LR peri od, what w ill be th e quantitativ e acceptance criteria for concluding tha t corrosion ha s or has not o ccurred since the last ins pection in 1996.(2) If additional corrosion i s detected in the upcoming i nspection, de scribe in d etail the augmented inspecti ons and other steps that w ill be ta ken to evalu ate the exte nt of the corrosion, and describe the approach to e nsuring the conti nued structural adequacy of the co ntain ment.
219 In its response , the appli cant stated that th e new se t of UT measurements for the former sa nd bed region w ill be a nalyze d using the sa me methodology used to anal yze the 1992, 1994, an d 1996 U T data. The res ults w ill then b e compa red to the 19 92, 19 94, an d 1996 UT resu lts to confirm the previ ous no corrosi on trend. Bec ause of surface roughness of the exterio r of the drywell shell, experience has shown that UT measurements can vary significantly unless the UT instrument is p ositioned o n the exac t point as the previous measurements. Thus, a cceptance criteria w ill be b ased on the s tandard dev iation of the p revious d ata (+/-11 mils) a nd instrument accuracy of (+/-10 mils) for a total of 21 mils. De viation from this value will be conside red unexp ecte d and r equ ires corr ecti ve act ions desc ribe d belo w.The applican t further stated in i ts response that if additional corrosion i s identified that exceeds acceptance cri teria describ ed above, Oyster Creek w ill ini tiate correctiv e actions tha t include one or all of the follow ing, dependin g on the exten t of identified co rrosion.a. P erfor m add iti onal UT me asur emen ts to con firm t he re adi ngs b. Notify NR C withi n 48 hours of con firmation of the ide ntified condi tion c. Conduct in spection of the c oatings in the sand bed regi on in areas where the additional corrosion w as detected.
: d. Perform engineerin g evaluatio n to assess the extent of the c ondition a nd to determine if addit ional inspe ctions a re req uired to assure dr ywell integr ity.e. Perf orm ope rability de termi nation an d justif ication f or cont inued oper ation unt il next scheduled i nspection.
These actions w ill be c ompleted before res tarting from an outage.
The project team noted that the abov e commitments are i ncluded i n Audit Co mmitment 3.0.3.2.22-5, w hich wa s discussed previousl y in thi s section.
Pitting Corro sion of the S uppression C hamber (Torus)
In review ing information i n the OCGS AM P B.1.27 dis cussion of opera ting experie nce for the suppression chamber (torus) and vent sy stem, the project team n oted that the ap plicant state d that the coating is inspected every outag e and repaired, as required, to protect the torus shell and the ve nt system from corrosi on. Reference i s made to program B.1.3 3 for additiona l details. The project team revi ewed OCGS A MP B.1.33 and noted th at, under operati ng experience , the appli cant stated that to rus and ve nt header v apor space Se rvice Lev el I coating inspe ction s perfor med in 2002 found th e coat ing in these areas to be in goo d cond ition. Inspection of the immersed coating i n the torus id entified bli stering. The bli stering occurred primarily in the shel l invert, but was al so noted on th e upper shel l near the w ater line.
The majorit y of th e bli sters r emaine d inta ct and conti nued t o prote ct the base me tal. H owev er, several blis tered ar eas includ ed pittin g dama ge where t he bliste rs were f ractur ed. A qua litative assessment of the i dentified pits was performed a nd conclude d that the measure d pit depths were signi ficantl y le ss than the es tabli shed a ccepta nce cri teria. The frac tured b liste rs we re repai red to reesta blis h the p rotecti ve co ating b arrier.
220 To clarify the above statemen ts, in audit question AM P-072, the projec t team asked the applicant to provide the followi ng information pertai ning to past op erating experi ence and lice nse re newa l agin g manageme nt for th e supp ressio n chamb er (toru s) and vent syste m: (1) Th e plant doc ument ation th at descr ibes the b listerin g and pit ting, the qua litative assessment performed, the established acceptance cri teria, and the corrective a ction taken, (2) Clarify w hether ASM E Section XI, S ubsection IWE was appl ied to dev elop the acceptance cri teria, (3) Clarify w hether the ins pection that d iscovered the blisteri ng and cracking w as conducted und er IWE, a coatings monitoring and maintenance program, or another program. If another program, id entify the program, an d (4) Clarify w hether both the IW E program (B.1.27) an d the coatings p rogram (B.1.33) are credited to manage loss of materi al due to c orrosion for the su ppression ch amber (torus) and ve nt system, for the ex tended period of operation. If not, provide th e technical b asis for conclu ding that both A MPs do n ot need to be credited.
In its response , the appli cant stated that i nspection of the suppression chamber (torus) and vent syste m coating is co nducted by divers ev ery other ou tage in accordan ce with engineering specification SP-1302-52-120. The specificati on provid es inspecti on and accep tance criteria for the co ating. It als o prov ides inspe ction and a ccepta nce cri teria for pitt ing, as a con tingen cy to be used in the event failure of the coati ng results in pitting. The coati ng is monitored for cracks, sags, runs, flaking, bli sters, bubbles, and other defects d escribed in the Protectiv e Coating Moni toring and M ainte nance Program (B.1.3 3).The applican t further stated that the specification requires insp ection of the torus and vent system surfaces f or coating integrit
: y. If pitting is observed, then isolated pits of 0.125" in diameter hav e an allo wed maxi mum depth of 0.261" an ywhere in the shel l, provid ed the center-to-center di stance betw een the subject pits and nei ghboring isolate d pits or area s of pitting corrosio n is greater that 20 inches.
Multipl e pits that ca n be encompass ed by a 2.5-inch diameter circl e are limite d to a maxi mum depth of 0.141 i nches provi ded the center-to-center distance betw een the subject pitted area an d neighboring i solated pits , or areas of pitti ng corrosion, is greater that 20 i nches.Plant documen tation that des cribes the bl istering and p itting, and quali tative asse ssment performed, the established acceptance criteria, and corrective actions taken, is included in PBD-AMP-B.1.27 Not eboo k and is avai lable for staf f re view.On Apri l 19, 2006, the ap plic ant su ppleme nted i ts resp onse t o inc lude the sta tement ?Pits greater that 0.040 i nches in de pth shall be documented a nd submitted to engineering for eval uatio n."The applican t further stated in i ts response that the torus and v ent system coa ting is class ified Service L evel I C oating as descri bed in the Protective Coating Mo nitoring and M aintenance Program (B.1.33). The pro gram was eva luated agains t the 10 ele ments of NUREG-1801 XI.S8, ?Protective Coating Mo nitoring and M aintenance P rogram"and found consi stent witho ut enhancements or exceptions. Acceptance criteria are e valuated in element 3
.6 of the Oyster Creek Protectiv e Coating M onitoring and Maintena nce Program (PBD-A MP-B.1.33).
The 221 inspection is performed by ASME S ection XI Lev el II and Le vel III in spectors. Accep tance criteria for pits are based on engineering anal ysis that u ses the method o f Code Case N-5 97 as guidance for calcu lation of pit depths that w ill not v iolate the local stress requirements of either ASME S ection III, 1977 Edition o r Section VIII, 1962 Editi on.On Apri l 19, 2006, the ap plic ant su ppleme nted i ts resp onse t o inc lude the sta tement ?In regar d to the use of Cod e Case N-597 for the evalu ation of pits, se e AMP-21 0 for additiona l information."
The applicant's response to audit quest ion AMP-210 is discussed below in this sectio n of the audi t and r evie w rep ort.The applican t also stated in its respo nse that the i nspection tha t discovere d the blis tering was conducted und er the Protectiv e Coating M onitoring and Maintena nce Program. Ex aminations are performed by A SME Sec tion XI Leve l II and Lev el III inspec tors. The appli cant further stated in its response that both the IWE program (B.1.27) and the coatings program (B.1.33
)are credited to manage loss of materi al due to c orrosion for the su ppression ch amber (torus) and the ve nt system for the e xtended pe riod of operatio n.On April 19 , 2006, the app licant supp lemented its response to cl arify that duri ng the period o f exten ded op eratio n, toru s coati ng insp ectio n wi ll be performe d in a ll 20 torus bays at a frequency of every other refueling ou tage for the current coati ng system. Shou ld the coati ng system be repl aced, the ins pection frequency and scope w ill be re-evaluated. The inspecti on scope will, as a minimum, meet the requirem ents of ASME, Subsection IW E. This specific commitment wil l be added to the LRA Appendix A.5 Commitment Li st, as part of Commitment 33 ass ociat ed w ith th e Prote ctiv e Coat ing M onito ring an d Ma inten ance P rogram.In its letter d ated May 1, 2006 (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to the follow ing: As noted i n AmerGen's 4/4/0 6 letter to NR C, AmerGen wi ll perform torus coating inspec tions in a ccordance w ith ASM E Section XI, S ubsection IWE every o ther refueling outage prior to a nd during the p eriod of exten ded operation. This new commitment clari fies that the scope of each of th ese inspections will include the wetted area of all 20 torus bays. Should the current torus c oating system b e replaced, th e inspectio n frequency and s cope wi ll be re-ev aluat ed. In specti on sco pe w ill, as a mi nimum, meet the requir ements of ASM E Sect ion XI, Subsection IWE. This is Aud it Commitment 3.0.3.2.22-7
.On April 19 , 2006, the app licant supp lemented its response, statin g that Conditio n Report No.
373695 Assi gnments 2 and 3 h ave been initiated to drive p rogram improvements for the monitoring and tre nding of torus desi gn margins, and to de velop refine d acceptance criteria and thresholds for ente ring coating defects a nd unacceptab le pit dep ths into the C orrective A ction process for further eva luation. Thes e improvements will be incorpora ted into the inspection implementing do cuments prior to the next pe rformance of these inspe ctions, wh ich is al so prior to the period of extended operation.
This commitment will be described in a letter to the NRC.
In its letter d ated May 1, 2006 (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to the follow ing: AmerGen wi ll deve lop refined ac ceptance criteri a and threshol ds for entering torus coating defects and unaccepta ble pit de pths into the corrective a ction process for further evaluati on. These improv ements wil l be inco rporated into th e inspectio n implementin g documents prior to the next performance of these in spections, w hich is al so prior to the period of extended op eration. This is Aud it Commitment 3.0.3.2.22-8
.
222 The project team found the applican t's commitment acce ptable sinc e it wi ll provi de additio nal criteria to determine whether deg radation of the suppress ion chamber is being adequately managed.On April 19 , 2006, the app licant supp lemented its response, statin g that the answ ers provid ed for audit question AMP-210 on torus wa ll thickness were w ritten to addres s specific con cerns of the AMP audit team and were cente red around w orse case torus thickness margins ex isting on the torus shell due to corrosion. The applicant stated that this supplementa l information is being provi ded to reinforce that, based on all ava ilable i nspection resu lts, the ave rage thickness of the torus remains at 0.385". Base d on the resul ts of the inspecti ons performed through 19 93 (14R), the appl icant concl uded that the to rus shell th ickness had remai ned virtua lly unc hanged following the repair and recoating efforts performed in 1984. The applicant also stated that this was communi cated to the N RC via letter C321-94
-2186 dated N ovember 3, 19 94, Amendment No. 17 7 to DP R-16 a nd SE R date d Febr uary 21, 19 95 for th e EM RV Tech Spec change. Coating inspe ctions performed sub sequent to 1993 (14R) continu e to confirm that the torus shell thickn ess ha s remai ned v irtual ly u nchan ged foll owi ng the r epair and re coati ng efforts performed in 1984, and that the av erage thickness of the to rus remains at 0
.385". Torus integrity w ill conti nue to be ev aluated duri ng future inspection s (performed every other refueling outage) into the period of exte nded operatio n.The app lica nt als o cla rified the ex tent of p ittin g corros ion. Pitti ng corro sion less t han or equal to 0.040" was not repaired during the 1984 tor us repair and recoating ef fort based on available margins and w as found to be a cceptable w ithout any size restri ction since it satisfied minimum uniform thickness requi rements. Inspectio n activi ties subsequent to 1984 hav e identified 5 isolated pi ts that excee d 0.040". The foll owing areas have bee n mapped for trendi ng and analysi s during future ins pections: 1 p it of 0.042" in bay 1; 1 p it of 0.0685" in bay 2; 2 pits of 0.050" in ba y 6; 1 pi t of 0.058" in ba y 10. She ll thicknesse s have be en evalu ated against cod e requirements and found to satisfy al l design and licensin g basis requirements. Therefore, the integri ty of th e torus shel l has been veri fied to have adequa te she ll th icknes s margin s to en sure design and l icensing basi s requirements can be maintaine d.As not ed abo ve, th e appl icant also suppl emented its re sponse to in clude the st atement ?Pits greater that 0.040 i nches in de pth shall be documented a nd submitted to engineering for eval uatio n."The project team noted that in the discussion of torus degradation on pages 25 to 31 of program basis docum ent PBD-AMP-B.1.27, the applicant stated t hat "Inspections perf ormed in 2002 fo und th e coat ing to be in good co nditi on in the v apor a rea of th e torus and v ent he ader, and in fair co ndition i n immersion. C oating deficienc ies in i mmersion incl ude blisteri ng, random and mechanica l damage. Bli stering occurs pri marily i n the shell invert bu t was al so noted on the upper shel l near the w ater line.
The fractured blisters were repa ired to reestab lish the protective c oating barrier.
This is anoth er example of objective ev idence that th e Oyster Creek ASME S ection XI, Subse ction IWE aging management program can id entify degradatio n and implement corrective actions to pre vent the loss of the containment' s intended function. W hile blistering i s considered a deficiency , it is signi ficant only when it is fractured and e xposes the base me tal to corros ion a ttack. Th e majori ty of th e bli sters r emain intac t and c ontin ue to protect the base metal; consequentl y the corrosi on rates are l ow. Quali tative asse ssment of the identified pits indi cate that the meas ured pit dep ths (50 mils max) are signi ficantly le ss than the criteria e stablished in Specifica tion SP-1302 120 (141- 26 1 mils, depe nding on dia meter of the p it and spaci ng betw een pi ts)."
223 In audit questi on AMP-2 10, the project tea m asked the appl icant to confirm o r clarify (1) th at only the frac tured b liste rs found in th is in specti on w ere rep aired; (2) pi ts we re ide ntifie d wh ere the blisters were fractured; (3) pit depths w ere measured and found to 50 mil s maximum; (4) the inspection Specification SP-1302-52-120 includes pit-depth acceptance criteria for rapid evaluati on of observed pitting; (5) the minimum pit de pth of concern is 141 mils (0
.141") and pits as deep as 261 mil s (0.261") may be acceptabl e.In its respo nse, th e appl icant stated that S pecifi catio n SP-1 302-52-120, ?Specification for Inspection and Localized Repair of the Torus and Vent System Coating," specif ies repair requirements for coatin g defects exposi ng substrate and fracture d blisters s howing si gns of corrosion. The re pairs referred to i n the inspec tion report i ncluded fractured blisters, as well a s any mechani cally d amaged areas, w hich hav e exposed bare metal sh owing signs of corrosion.
Therefor e, only fractured blisters would be candidates f or repair, not those blisters tha t remain intact. The numbe r and locati on of repairs are tabulated i n the final i nspection rep ort prepared by Underw ater Constructio n Corporation
.The applican t further stated in i ts response that coating deficien cies in the immersion regio n included blistering with minor mechanical damage. Blistering occurred primar ily in the shell inve rt but w as al so not ed on the up per sh ell n ear the wate r lin e. The majorit y of th e bli sters were inta ct. Intact bli sters were e xamined by removing the blister cap exposing the substrate.
Corrosion attac k under non-fractured bl isters was minimal an d was genera lly li mited to surface discoloration. Examination of the subst rate revealed slight discoloration and pitting with pit depths less than 0.001. Seve ral bl istere d area s incl uded p ittin g corros ion w here th e bli sters were fractured. The substrate bene ath fractured blis ters generally exhibi ted a slightl y heavi er magnetite oxid e layer a nd minor pitti ng (less than 0.0 10") of the substrate.
The applican t indicated that, in addi tion to bli stering, random defici encies that e xposed ba se metal were identified i n the torus immersi on region coati ng (e.g., minor mechanic al damage) during the 19R (2002) torus coa ting inspections. They range d in size from 1/16" to 1/2" in diameter. Pitting in these areas was qualitatively evaluated and ranged from less than 10 mils to sli ghtly more th an 40 mils i n a few isol ated c ases. Three qu antita tive pit d epth measurements we re taken in sev eral locati ons in the immersion area of Bay 1. Pi t depths at these sites ran ged from 0.008" to 0.042" and were judged to be repres entative o f typical condi tions found o n the s hell. Prio r to the 2002 inspe ction , 4 pi ts greate r than 0.040" were identified. The pit depths were 0.058" (1 pit in 1988), 0.05" (2 pits in 1991), and 0.0685" (1 pit in 19 92). Th e pits were eval uated agains t the l ocal pit de pth ac ceptan ce cri teria and fou nd to be acceptabl e.The app lica nt furthe r state d in i ts resp onse t hat Sp ecific ation SP-13 02-52-120, ?Specification for Inspection and Localiz ed Repair o f the Torus and Vent System Coati ng," includes th e pit-depth acceptance crit eria for rapid evaluation of observed pitting. The acceptance criteria are su pporte d by a cal culat ion C-1302-187-E3 10-038. Loca tions that d o not me et the pit-de pth acceptance cri teria are chara cterized ba sed on the si ze of the area, center to center distance between co rroded areas, the maximum pit depth and l ocation in the torus based on major structural features. The se details are sent to Oy ster Creek Engineeri ng for evaluati on.The applican t also stated that the acceptan ce criteria for pi t depth is as follows:
Isolated Pi ts of 0.125" in di ameter have a n allow ed maximum de pth of 0.261" any where in the shell provided the center-to-center distance betw een the subject pit and nei ghboring isolate d pits or area s of pitting corrosio n is greater than 20.0 inches. This incl udes old p its or old areas of pitting corros ion that have been f illed and/
or re-c oated. Multiple pits t hat can be encompa ssed by a 224 2-1/2" diameter ci rcle shall be limited to a maximu m pit depth of 0.14 1" provide d the center-to-center di stance betw een the subject pitted area an d neighboring i solated pits or areas of pitting corrosio n is greater than 20.0 inches. This incl udes old p its or old areas of pitting corrosion that have been filled and/o r re-coated.
In audit questi on AMP-2 10, the project tea m asked the appl icant to prov ide the follo wing information for the torus
: (1) nominal design, as-buil t, and minimum mea sured thickness o f the torus; (2) minimum th ickness required to meet ASME code accepta nce criteria; and (3) the technical b asis for the pitti ng acceptance cri teria inclu ded in Spe cification SP
-1302-52-120.
In its response, the applicant stat ed the following: For the submers ed area of the drywell (torus), the n ominal desi gn thic kness i s 0.38 5 inc hes, a nd the as-bu ilt th icknes s is 0.385 i nches. The minimum uniform meas ured thickness i s 0.343 inch es for the general s hell, 0.345 inches for the shell ring girde rs, 0.345 inches for the shell saddle flange, and 0.345 inches fo r the shell torus straps. The m inimum general thickne ss required to meet ASME Code Acceptance is 0.337 inches
.The applican t further stated in i ts response that the technical basis for pitti ng acceptance criteria inc luded in Specification SP-1302-52-12 0 is based on engineerin g calculatio n C-1302-187-E31 0-038. At the time of preparation of calculati on C-1302-187-E310-038 in 2002, there were no published methods to calculate acceptan ce standards for locally thinned areas in ASME S ection III or Se ction VIII Press ure Vessel codes. Therefore, the a pproach in C ode Case N-597 was used as guidance in assessing locally thinned areas in the torus. This is based on the similarity in approach es between Local Thinn ing Areas desc ribed in N
-597 and Local Prima ry Str ess are as des cribe d in P aragrap h NE3 213.10 of the A SME Code Secti on III, partic ularl y smal l area s of wa ll th inni ng whi ch do not ex ceed 1.0 x (square r oot of R t). In addition, the ASME Code Sectio n III, Subsectio n NB, Paragraph NB-3630 al lows the analysi s of pipe syste ms in accordan ce with the Vessel A nalysis rules descri bed in Para graph NB-3200 o f the same Subse ction as an alternate anal ysis appro ach. Therefore, the ap proach used i n    N-597 for loca l area s of thi nning was p robabl y dev elope d usi ng the r ules for Loca l Pri mary Membrane S tress from paragraph NB-32 00, in parti cular Subpa ragraph 3213.10.
The Local Primary Stress Limits in NB- 3213.10 are similar to th ose discussed in Subsection NE, Paragraph NE-321 3.10.Since the C ode Case ha d not yet b een invo ked into the Se ction XI program, the ca lculation provided a reconcili ation of the resul ts obtained from the code case a gainst the ASM E Section III code requirements, as discussed above. Thi s reconcili ation demonstrate d that the appro ach in Code C ase N-597 use d on a pressu re vessel such as the to rus would be acceptabl e since the results are conservative compared to the previous work performed in MPR-953, "GPU Nucle ar Cor porati on, Oy ster Cr eek Nuc lear Ge nerati ng Stati on Toru s Shel l Thic kness M argin", MPR Ass ociates INC, October 1986.
The applicant furth er stated that current ly, the maximum pit depth measured in the torus is 0.06 85" (mea sure d in 199 2 in bay 2). The a ppl ica nt fou nd i t acc epta ble bas ed o n the des ign calculations existing at that time and was not based on Calculation C-1302-187-E310-038. This remains the bo unding wal l thickness i n the torus. The criterion dev eloped in 2002 for local thickne ss acc eptanc e prov ides an eas ier me thod for eval uatin g as-foun d pits. The re sults were shown to b e conservati ve versu s the original ASME Section III and VIII Code requi rements for the torus. The torus inspection program is bein g enhanced per IR 373695 (au dit commitment 3.0.3.2.22-8) to i mprove the de tail of the acce ptance criteri a and margin mana gement requirements using th e ASME Section III cri teria. The appro ach used in C-1302-187-E3 10-038 225 will be clarified as to how it maintains the code requi rements. If Code Ca se N-597-1 i s required to dev elop these criter ia for fut ure in specti ons, N RC rev iew and a pprov al w ill be obt ained. It should al so be noted th at the program has e stablished corrosion rate criteria and the applica nt continues to periodical ly monitor the criteria to verify they remain bound ed.Containment D egradation Commit ments The project team ev aluated the applicant' s revised aging management commitments to address four (4) distinct issues:
monitoring/eliminating water leakage; corrosion in the upper drywell region; corrosion in the former sand bed region; an d pitting corrosi on in the s uppression chamber (torus). Ea ch area is d iscussed i n the follow ing paragraphs.
: 1. Monitoring/Eliminating W ater Leakage in the Ga p Between the Drywell and Shield Wall The applican t made a new license re newal c ommitment (3.0.3.2.22-1), to continue the use of the strippabl e coating for each refueling during the license re newal p eriod. Accord ing to the applicant, th is coating ha s been effective in elimin ating water i ntrusion into the annula r space between the drywel l shell and the concre te shield wall. In the LRA, the applican t had not committed to conti nue its use.
The applican t also made a new li cense renew al commitment (3.0.3
.2.22-2) to inv estigate the source of leakag e, take correct ive actions, evaluate the impact of the leakag e and, if necessary, p erform additional drywel l inspecti ons in the event w ater leakage from the former sand bed regio n is found duri ng the period o f extended ope ration. Unde r the current li cense term, Oyster Creek is committed to NR C to monitor the former sand bed regio n drains for w ater leakage. This com mitment was not previously identified in the LRA.
In its response to audit questi on AMP-2 05, the appl icant indi cated that there is no formal procedure in place to moni tor leakage from the sand bed drains, a nd stated
?Issue R eport#3485 45 w as sub mitted into t he cor rectiv e acti on pro gram wh en thi s was disco vered. Correc tive actio ns hav e been init iated to cre ate rec urring activ ities contro lled wit h the w ork management process an d procedures, to perform all future requi red inspecti ons to meet the presen t commi tment."The project team found tha t the absence of a leakage monitori ng program to meet the curre nt license term c ommitment raises a question abou t the basis for the applican t's claim tha t water is no longe r leaki ng into the an nular gap be twee n the d ryw ell s hell and th e conc rete sh ield wal l. The project team ide ntified the rev iew of appl icant information that confirms absen ce of water leakage into the annular gap be tween the drywel l shell and the concre te shield wall a s Open Item  3.0.3.2.22-1.
: 2. Upper Dryw ell Region The applican t made a new license re newal c ommitment (3.0.3.2.22-3), to continue pe rforming UT measurements of the u pper dryw ell region for th e period of ex tended operati on.The project team noted that the appl icant manages l oss of material d ue to corrosio n in the upper drywell region (spherical and cylindrical sections) using augm ented examinations in accordance w ith IWE-1240. An Ultrason ic thickness su rvey is performed every other refueling outage (4 ye ars) to detec t any addi tiona l los s of mate rial due to corros ion. The UT re sults are evaluated and trended to ensure that th e drywe ll shell is capabl e of performing its inte nded 226 function to the en d of plant li fe. The areas subject to periodic UT measurements w ere selected based on ex tensive e xploratory testing to establ ish the most se verely corroded loca tions in the drywell above the sand bed region. Corrosion of the upper drywell region is a TLAA, in accord ance w ith 10 CFR 5 4.21(c). The a ppli cant's TLAA is do cumente d in L RA Se ction 4.7.2. Th e a p p l i c a n t i s i m p l e m e n t i n g TL A A o p t i o n (i i i), a n d u s e s t h e U T i n s p e c t i o n r e s u l t s fr o m i t s I WE program t o moni tor rema inin g thickn ess; to perio dical ly u pdate the co rrosio n rate, and to periodical ly update the projected re maining thickness at the end of the license ren ewal pe riod.The project team did not revie w the app licant's TLA A. The NRR/DE staff has responsibi lity for this TL AA, an d submi tted forma l RAI s to th e appl icant. The p roject t eam coo rdina ted it s efforts with NR R/DE to av oid dupli cation.3. Former Sand Bed Region of Drywell In the LRA, the applican t's position was that co rrosion in the former sand bed region has bee n completely arrested by the remedial actions alre ady taken. The ori ginal LRA c ommitment was to inspect a section of coating every other outage (4 yrs) to confirm its soundness. The last UT readings we re taken in 199
: 6. As a resu lt of the audit, the applica nt made seve ral new commitments to manage agi ng of the former sand bed region of the dry well d uring the perio d of extended o peration. The a pplicant's re vised commi tments are as foll ows: (1) Monito r the protectiv e coating on th e exterior surfaces of the dryw ell in th e sand bed region in acc ordance wi th the requirements of ASME Se ction XI, Subsec tion IWE during the pe riod o f exten ded op eratio n (commi tment 3.0.3.2.2 2-4), (2) Conduct pe riodic UT i nspection of the former sand bed region before entering the lice nse re newa l peri od, an d eve ry ten year s there after (co mmitment 3.0.3.2.22-5), (3) Attempt a UT in spection of some o f the locally thinned are as identified in the 199 2 inspection from the exterior o f the drywel l, during the i nitial UT i nspections o f the sand bed region con ducted prior to entering the pe riod of extend ed operation (commitment 3.0.3.2.22-6), (4) Inspect the rema ining 50% of the e xternal coa ting in the former san d bed region before entering the l icense renew al period (to date, only 50% of this coati ng has been inspected si nce it w as applie d in the ea rly 1990s), and conduct a 100% re-insp ection of the co ating e very 10 y ears d uring t he li cense renew al pe riod (commitme nt 3.0.3.2.22-4), (5) If additional corrosion of the sand bed regio n is iden tified by the UT inspectio n to be conducted before e ntering the li cense renew al period, initiate co rrective acti ons that include o ne or all of the followi ng, depending on the extent o f identified corros ion: a. Perform addition al UT measurements to confirm the readi ngs.b. Notify NR C withi n 48 hours of con firmation of the ide ntified condi tion.c. Conduct in spection of the c oatings in the sand bed regi on in areas where the additional corrosion w as detected.
: d. Perfo rm engin eerin g eval uatio n to as sess th e ext ent of th e cond ition and to determ ine if add itional ins pection s are req uired to assure dr ywell integr ity.e. Perform oper ability determination and justificat ion for continued operation until next schedu led inspe ction.These actions w ill be c ompleted before res tarting from an outage (commitmen t 3.0.3.2.22-5).
227 The project team noted these new commitments for managing agin g of the former sand bed region , but a lso n oted th e ver y smal l rema inin g margin betw een th e mini mum repo rted un iform thickness and th e minimum required uniform thickness (0.8 00" vs. 0.736
"). This apparen t lack of margin led the proj ect team to ask the applicant for additional informa tion about (1) the UT inspection results and d ata reduction methods employ ed to determine the minimum remai ning thickness, and (2) the analy tical methodol ogy employ ed to determine the minimum requi red thickness, speci fically for l ocalize d areas wh ere the measured thickness is l ess than the minimum required u niform thickness. The a pplicant pro vided ad ditional information on the se subj ects in i ts re spon ses to au dit ques tion s AM P-35 6 an d AM P-21 0, re spec tiv ely. Du ring a follow-up o nsite audit conducted Apri l 19-20, 200 6, the project team discussed the se responses wi th th e ap pli cant in d etai l, to ens ure a comp lete und erst andi ng.The project team rev iewed th e detailed UT thickness read ings in the s and bed region taken from the inside s urface through 1996 a nd on the ou tside surface in 1992. The proje ct team pointed out a definite bi as in the 1 996 readings, b ecause the av erage thickness (bas ed on 49 rea di ngs/lo cat io n) i ncr eas ed at a lmo st a ll lo cat io ns. The pro jec t te am a nd the ap pl ica nt's st aff discussed po ssible cau ses for this bia s, but no conc lusions co uld be draw n.The project team's re view of the UT data confirmed that the remaini ng thickness in th e former sand bed regio n significantly exceeds th e minimum required thickness of 0.736" at most monito red lo catio ns. Se veral loca tions are cl ose to the or igina l des ign thi ckness of 1.154". Howeve r, in a few v ery local ized area s, primarily in Bay 1 and Bay 13, remainin g thicknesses less than 0.7 36" have b een measured.
The lowest measured poin t reading is 0.618", recorded in the 1992 outside surface inspection.
Based on p roject team's rev iew of the d ata, the low est measure d poi nt read ing from t he in side surface inspe ction s is 0.646".The pro ject tea m also revi ewed the te chnic al ba sis do cuments that e stabl ished compl iance wit h ASME C ode requirements.
In its response to audit questi on AMP-2 10, the appl icant stated th at the engineerin g analysis that demonstrated compliance to ASME code requirements w as performed in two parts, stress and stability analysi s with sa nd, and stress a nd stabili ty analy ses without sa nd. The analy ses are documen ted in GE Re ports Index N
: o. 9-1, 9-2, 9-3, a nd 9-4, whi ch we re tran smitted to the NRC i n Dece mber 19 90 and in 19 91, res pecti vely. Inde x No. 9-3 and 9-4 we re rev ised later to corr ect err ors id entifi ed dur ing an inter nal a udit, and w ere resubmitted to the staff in January 1992.The app lica nt stat ed tha t the d ryw ell s hell thickn ess in the sa nd bed region is ba sed on stabi lity analysi s without sand (GE Report 9-4). The analy sis is bas ed on a 36-d egree section mod el that takes advantag e of symmetry of the dr ywell with 10 v ents. The model includes the drywell shell from the ba se of the sand be d region to the top of ellipti cal head a nd the ven t and vent header. The torus is not included in this model because the bellows provide a very flexible connection, w hich does n ot allow significant structu ral interacti on betwee n the dryw ell and th e torus. The anal ysis assu med that the shel l thickness i n the entire sand bed regio n has been reduced uniformly to a thickness of 0.736 inches.
The app lica nt furthe r indi cated that GE Letter Repor t ?Sand Bed L ocal Thinni ng and Raisi ng the Fixity Height Anal ysis" prese nts results demo nstrating that a un iform reduction i n thickness of 27% to 0.536" ov er a one square foot area woul d only c reate a 9.5% redu ction in the load factor and theoretica l buckling stress for the whol e drywe ll. A sec ond buckling an alysis was performed for a wal l thickness red uction of 13.5% to 0.636" over a one square foot are a, which onl y re duce d the loa d fac tor a nd th eore tica l bu ckli ng st ress by 3.5% for th e w hol e dry wel l. To bring t hese r esult s into persp ectiv e, the appli cant's rev iew of the N DE rep orts i ndica te ther e are 228 20 UT measured a reas in the w hole sand bed region that have thic knesses less tha n the 0.736 inch thickness used in GE R eport 9-4, wh ich cover a total area of 0.68 square feet of the dryw ell s urface w ith an aver age thi ckness of 0.703" or a 4.5% red uctio n in w all t hickne ss. Furthermore, all of these very local wall areas are centered about the vents, which significantly stiffen the shell.
This stiffening effect limits the shell buckling to a po int in the shell sand bed region, whi ch is loca ted at the midp oint betw een two v ents.Based on i ts review of the detaile d UT thickness rea dings and the GE stability analyse s that considered (1) a uniform 0.736" th ick sand bed re gion, and (2) the effects of a local thi n area of 0.536" and 0.63 6" thickness, the N RC conclud ed in 1996 that the condi tion of the former sand bed region w as adequate to p erform its intended function in a ccordance w ith its desi gn basis.Howeve r, because there has been n o UT inspecti on conducted since 1996 and the remain ing corrosion margin in 1996 w as less than 0.1" at seve ral locatio ns, the project tea m initiated further evaluati on of the appli cant's aging managemen t commitment for UT inspe ction of the former sand bed region. The project team i dentified the re view of applicant i nformation that confirms the dr ywe ll sh ell i n the fo rmer san d bed region has th e mini mum requi red thi ckness to ensure no lo ss of intended functi on during the e xtended pe riod of operatio n as Open Item 3.0.3.2.22-2.
The applican t credited its Protective Coating M onitoring and Maintena nce Program (OCGS AMP B
.1.33) to monitor/mai ntain the prote ctive coati ng on the exte rior surface of the drywell in the former sand bed region. The proj ect team evaluated OCGS AMP B.1.33 in Section 3.0.3.1
.8 of this audi t and revi ew report.
The applican t's revise d aging management commitment (3.0.3.2.22-4) is to complete a 100% insp ection of the coa ting (initiate d in 1994 and currently 50% complete) p rior to the l icense renew al period, and to conduc t subsequent 100% re-inspecti ons every 10 years during the li cense renew al period.
Because of the mi nimal corrosi on margin remaini ng in the former sand bed region, and the applicant' s reliance on the coatin g to mitigate addi tional corros ion, the projec t team initia ted further r evie w of th e appl icant's in specti on pro gram to e nsure that th e coat ing w ill conti nue to perform its intende d function for the ex tended period of operation. The project team iden tified the review of applicant information that co nfirms the dryw ell shel l in the former sa nd bed region has th e mini mum requi red thi ckness and th at coa ting an d ins pecti ons ar e adequ ate to ensure no loss of in tended function d uring the exte nded period of operation as Open Item 3.0.3.2.22
-3.4. Suppressio n Chamber (Torus)
The applican t credited its Protective Coating M onitoring and Maintena nce Program (OCGS AMP B
.1.33) to monitor/mai ntain the prote ctive coati ngs inside th e suppressio n chamber (torus), in order to mitigate corrosion. The p roject team's detai led eval uation of the applicant's Protective Coating Monitoring and Maintenance Prog ram (OCGS AMP B.1.33) is in Secti on 3.0.3.1.8 of this audit report.The project team questio ned the appl icabili ty and impl ementation of Code Case N-597-1 for developing pit depth acceptance criteria f or the torus. Based on the acceptanc e criteria develope d by the a pplicant, an isolated pit of 0.125" di ameter on the i nner surface is c onsidered acceptable if its depth does not exceed 0.261". According to the applicant, the tor us as-built wall thickness is 0.385". Theref ore, a pit depth equal to 67% of the as-built thickness is considered a cceptable, i f it is isol ated. For a cl uster of pits w ithin a 2.5" diameter circl e, the accept able pit de pth is 0.141" or 37% of the a s-bui lt thi ckness. The ac ceptab le pi t depth 229 includes a llowan ce for an assumed 0
.0009"/yr corros ion rate ov er the 4 ye ar period be tween inspections. The project team al so identified that RG 1.147 s tipulates the followin g condition o n the use of Code Case N-597-1:
"(5) For corrosio n phenomena o ther than flow-accelerated corrosion, use of the Code Cas e is subject to NRC revi ew and a pproval.
Inspection pl ans and wal l thi nning rates ma y be difficul t to jus tify for certai n degra datio n mecha nisms such a s MIC and pi tting." In its response to audit quest ion AMP-210, the applicant stated that current ly, the maximum pit depth measured i n the torus is 0.0685" (measured in 1992 i n bay 2).
The applican t evaluate d this as accep table using th e design cal culations e xisting at th at time and w as not based on Calculati on C-1302-187-E310-038. This remains the b ounding wa ll thickness in the torus.
The criterion dev eloped in 2002 for local thickness accep tance provi des an easi er method for evalu atin g as-fou nd pit s. Th e res ults were sh own to be con serva tive ve rsus the or igin al ASME Section III and VIII Code requi rements for the torus. The applicant s tated that the toru s inspe ction program is be ing en hance d per I R 3736 95 [thi s is a udit c ommitmen t 3.0.3.2.22-8] to improve the detail of the a cceptance crite ria and margin management requirements us ing the ASM E Sect ion II I crite ria. Th e appr oach u sed i n C-13 02-187-E310-038 w ill be cl arifie d as to how it mai ntains the co de requirements. If Cod e Case N-597
-1 is required to develo p these criteria for future in spections, NR C review and approv al wil l be obtai ned. It shoul d also be noted that the progr am has established corrosion rate cr iteria and continues to periodically monitor to ve rify they rema in bounded
.The applican t's response clarified for the p roject team that pi t depth accepta nce criteria based on Code Ca se N-597-1 ha d not been i mplemented to da te, and if imple mentation shoul d be contemplated, the applicant will seek NRC review and approval. The project team found this acceptable to resolve its concern a bout the use o f Code Case N-5 97-1.Based on the applican t's response to audit questi on AMP-2 10, it appea red to the projec t team that there wa s minimal margin remaining betw een the current remaining thicknes s and the minimum required thick ness for the torus.
During a follow-up onsite audit conducted April 19-20, 2006, the project team dis cussed wi th the appli cant the current condition o f the torus, the pit de pth acce ptance criter ia, and th e scope of the coat ing insp ection c onduct ed every 4 years.The applican t explai ned that the av erage remaining thi ckness of the torus i s essential ly the as-bui lt thi ckness (0.385"). Fi ve (5) isol ated p its, ra nging from 0.042" to 0.0 68" in depth , are monitored and trended during e ach inspecti on. The appli cant supplemen ted its earli er response to au dit question A MP-072, to document this.
The app lica nt furthe r exp lain ed tha t pit d epth a ccepta nce cri teria based on Co de Cas e N-59 7-1 had never been used to disposition the acceptability of observed pitting. The current practice is to reco rd and monito r all pits exce eding 0.040 inche s in d epth. The app lica nt sup plemen ted it s earli er resp onse t o audi t questi on AM P-072 to ind icate that ?Pits greater than 0.04 0 inches in depth shall be do cumente d and submit ted to engine ering for eval uatio n."The app lica nt sup plemen ted it s earl ier re sponse to aud it ques tion A MP-0 72, co mmittin g to inspect the c oating in al l 20 bay s of the suppressi on chamber (torus) during the peri od of extended o peration. The frequency of inspection will be every other refueling ou tage for the current coating sy stem. Should the coating sy stem be replace d, the inspec tion frequency an d scope wi ll be re-ev aluated. The i nspection sco pe wil l, as a mini mum, meet the requirements of ASM E, Sub sectio n IWE (audit commit ment 3.0.3.2.22-7).
230 The app lica nt sup plemen ted it s earl ier re sponse to aud it ques tion A MP-0 72, co mmittin g to improve the monitoring and tre nding of torus desi gn margins, and to de velop refine d accept ance c riteri a and thresh olds for ente ring co ating d efects a nd una ccepta ble p it dep ths in to the Correctiv e Action pro cess for further eval uation. These improvements w ill be i ncorporated into the in spection impl ementing documents prior to the n ext performance of thes e inspectio ns, whi ch is also prior to the perio d of ex tended opera tion (audit commit ment 3.0.3.2.22-8).Based on the project team's u nderstanding of (1) th e current condi tion of the torus, (2) the applicant' s plan to refin e the pit de pth acceptance criteria, and (3) the scope o f the coating inspection conducted ev ery 4 ye ars, the project tea m determined that the applica nt's aging management pr ogram for the suppression chamber (tor us) ensures that the ef fects of ag ing will be adequately managed during the extended period of operati on.The project team rev iewed th ose portions of the ASME Section XI, Su bsection IWE program for which the applican t claims cons istency w ith GALL AM P XI.S1"ASME Section XI, Su bsection IWE," with an ex cepti on as descri bed be low and b ased o n that revi ew, i nitia ted the open items pertaining to th e aging management of primary containment (dry well s hell) dis cussed abov e.3.0.3.2.22.3 Exce ption s to th e GALL Repor t In the OCGS LRA , the appli cant stated the following e xception to the GALL Re port program elements: Eleme nt: Program Descriptio n Exception: NUREG-1801 e valuatio n is based on ASME Section XI, 200 1 Edition i ncluding 200 2 and 2003 Addenda. The current Oyster Creek ASME Section XI, Su bsection IWE program plan for the First Ten-Year i nspection i nterval effectiv e from September 9, 1998 through Septemb er 9, 2008, approved per 10CFR50.55a, is based on AS ME S ectio n XI, 19 92 Edi tion i nclud ing 19 92 add enda. The next 120-month inspection inter val for Oyster Creek will inco rpor ate t he re quir emen ts sp ecif ied in the ve rsio n of the AS ME Code i ncorpo rated i nto 10 CFR 5 0.55a 12 mont hs befor e the s tart of the inspection interval.
The GALL Report i dentified the foll owing recommend ations for the
?program description "program element asso ciated wi th the excep tion taken:
Program Descrip tion: 10 CF R 50.5 5a imp oses th e ins ervi ce in specti on (ISI)require ments o f the AS ME C ode, S ectio n XI, Su bsecti on IWE for stee l con tainme nts (Class M C) and steel liners for con crete containmen ts (Class CC
). The full scope of IW E include s steel conta inment shell s and their i ntegral attachments; s teel line rs for concrete contai nments and thei r integral attachme nts; containment hatches and airlocks; seals, gask ets and moisture barriers; and pressure-retaining bolting. This evaluati on covers th e 2001 edi tion1 incl uding the 2002 and 2003 A ddenda, as ap proved in 10 CFR 50.55a. ASM E Code Sec tion XI, Subsecti on IWE and the additiona l requirements speci fied in 10 C FR 50.55a(b)(2) constitute an existing mand ated program appli cable to mana ging agi ng of stee l con tainme nts, ste el li ners o f concre te containments, and other containment components for license renewal.
231 The project team noted that the 1992 ASME C ode, Section XI, Subsection IWE, includi ng 1992 adden da, w as in corpor ated i nto 10 CFR 5 0.55a at the time th e appl icant was require d to declare its inspection basis for the cur rent 10-year IW E inspection interval. The applicant will incorporate the requirements speci fied in the v ersion of the AS ME Code incorporated into 10 CFR 50.55a twelve months before the sta rt of the next 12 0-month inspecti on interva
: l. Since this is con sistent wi th the recommendati ons in the GALL Report, the project team does not consider this to be an actual exception to GALL. On this basis, the project team f ound this exception acceptable.
3.0.3.2.22.4 Enhan cements None.3.0.3.2.22.5 Operating Expe rience The applicant stated, in the OCG S LRA, that ASME Section XI, Subsection IW E as described in Oyster Creek First-10 Year Containment (IW E) Inservice Inspection Progr am Plan and Basis is effective September 9 , 1998 to Sep tember 9, 2008.
Base line inspection of containment surfaces was co mpleted in 2 000 and a s econd inspe ction was completed i n 2004. The 20 04 inspection identified (2) recor dable conditions, a loose locknut was identified on a spare drywell penetration an d a wel d rod was found stuck to the und erside of the dry well h ead. Engineeri ng evaluati on conclude d the stuck we ld rod has no adverse impact on dry well h ead structural integrity and the loose locknut did n ot affect the seal of the containment pen etration.The applican t stated that the upper region of dry well s hell has experience d loss of materia l, due to corrosion, a s a result of w ater leakage into the gap betwe en the contai nment and the re actor building i n the 1980'
: s. As a resul t the area is subject to augmented examinatio ns as required by ASM E Section XI, S ubsection IWE. The examin ation is b y ultrasoni c (UT) thickness measurements. UT measu rements taken in 2 004 showe d that the dry well s hell thic kness meets ASME criteria and that the rate of corrosion is in a declining trend. The applicant's engineering evaluation of the UT results also concluded that the containmen t drywell, cons ide ring the curr ent c orro sio n rat e, i s ca pabl e of p erfor ming its int ende d fun ctio n thr ough the pe riod o f exten ded op eratio n. Fur ther di scussi on is prov ided in LR A Sect ion 4.7.2, ?Drywell Corrosion" TLAA evaluati on.The app lica nt als o state d that the sa nd bed region also expe rienc ed lo ss of mat erial due to corrosion. Co rrosion wa s attributed to the presence o f oxygenated w et sand and e xacerbated by the prese nce of chloride and sulfate i n the sand be d region. As a corrective measure, the sand was removed and a protective coating wa s applied to the shell to mitigate further corrosion. The a pplicant sta ted that subsequen t inspection s confirmed that corro sion of the shell has been arrested.
The coating is mon itored perio dically under the Pro tective Co ating Monitori ng and Mai ntenance Program, B.1
.33. Refer to program B.1.3 3 for additiona l details.The applicant also stated that the sup pression chamber (toru s) and vent system were originally coated wi th Carbolin e Carbo-Zinc 11 paint.
The coating is i nspected ev ery outage and repai red, as requir ed, to protec t the to rus she ll an d the v ent sy stem from c orrosi on. Re fer to program B.1.33 for addi tional deta ils.The app lica nt stat ed tha t the o perati ng exp erien ce rev iew concl uded t hat AS ME S ectio n XI, Subsection IWE is effective for man aging aging effects of primary co ntainment surfaces.
232 In OCGS PBD-A MP-B.1.27, the ap plic ant ex pande d its discu ssion of oper ating e xperi ence t o include i ndustry opera ting experie nce and addi tional deta ils of the pl ant-specific conta inment degradation. The a pplicant sta ted that a rev iew of ind ustry operati ng experienc e has confirmed that corrosion has occurred i n containment s hells. NR C INs 86-99, 8 8-82 and 89-7 9 described occurrences of corros ion in ste el containme nt shells.
NRC GL 87-05 addressed the potential for corro sion of boil ing w ater re actor (BWR) Mark I s teel d ryw ells in th e "san d pocke t regio n." More recen tly, NRC IN 97-10 iden tified speci fic loc ation s whe re con crete c ontai nments are susceptible to liner p late corrosio
: n. A revi ew of plant operating exp erience at Oy ster Creek shows that corrosion has occurred in several co ntainment loca tions. These l ocations in clude the dryw ell shel l in the s and bed region , the dryw ell shel l above the sand bed region, and the suppression chamber and v ent system. In all cases after being implemen ted, the Oyster C reek ASME S ection XI, Subse ction IWE aging management program has id entified and c orrected t h e d e gr a d a t i o n. T h e e x p e r i e n c e w i t h t h e O y s t e r C r e e k A S M E S e c t i o n X I , S u b s e c t i o n I WE a gi n g m a n a ge m e n t p r o gr a m s h o w s t h a t t h e O y s t e r C r e e k A S M E S e c t i o n X I , S u b s e c t i o n I WE aging management program is effective in managi ng aging affects for the primary containment and its compon ents.The app lica nt inc luded the fol low ing di scussi on and three examp les o f operat ing ex perie nce to provide e vidence that the Oyster C reek ASME S ection XI, Subse ction IWE aging management program is effective i n assuring that i ntended function(s) will be maintain ed consisten t with the CLB for the peri od of extended operation:
Discussion
: The Oyster Creek AS ME Secti on XI, Subsectio n IWE aging management program as described i n Oyster Creek 10 Year Contai nment (IWE) Inservice Inspecti on Program Plan and B asis is i n effect from September 9,1998 to September 9, 2 008. Base l ine inspection of the drywe ll was completed du ring 2000, refueli ng outage. The suppression chamber (torus) v apor region bas e line i nspection w as completed d uring 2000, refueling ou tage.Although the Oy ster Creek ASM E Section XI, S ubsection IWE aging management program impleme ntation is recent, the potent ial for loss of material, due t o corrosion, in inaccessibl e areas of the con tainment dryw ell shel l was first recognized i n 1980 w hen water w as discov ered coming from the san d bed region d rains. Corrosi on was l ater confirmed by ul trasonic thicknes s (UT) measurements taken during the 1986 refueling outage. As a res ult, several corrective actions w ere initia ted to determine the extent of corrosion, ev aluate the i ntegrity of the dry well, mi tigate accelerate d corrosion, a nd monito r the con dition of containm ent sur faces. The cor rective a ctions in clude exte nsive UT measurements of the d rywell shell thi ckness, removal of the sand in the sand bed region, cleani ng and coating ex terior surfaces in areas whe re sand wa s removed, an d an engineerin g evaluatio n to confirm the dry well s tructural integrity. A corrosion monitoring program w as establis hed, in 198 7, for the dryw ell shel l above the sand bed region to ensure that the contai nment vessel is capabl e of performing its inte nded functio ns. El ements of the p rogram ha ve be en in corpor ated i nto the ASM E Sect ion XI, Subsection IWE and prov ide for (1) perio dic UT inspe ctions of the she ll thickness at critical l ocations, (2) ca lculations which establish c onservativ e corrosion ra tes, (3)projections of the shell thi ckness based on the conserva tive corrosi on rates, and (4
)demo nstr atio n tha t the minim um re quir ed sh ell th ick ness is in ac cord ance with AS ME code.
233 Additional ly, the NR C was no tified of this pote ntial generic issue that l ater became the subject of NRC IN 86-99 and GL 87-05. A summary of the operating ex perience, monito ring ac tivi ties, and co rrecti ve ac tions taken to ensur e that the pri mary cont ainm ent wil l perf orm its in tend ed f unct ions is disc usse d belo w.Examples o f Operating Experi ence: 1. Dryw ell Shel l in the S and Bed Re gion: The drywel l shell is fabricated from AS TM A-212-61T Gr. B steel pla te. The shell was coated on the inside surface with an inorganic z inc (Carbol ine carboz inc 11) and on the outside surface w ith "Red Lea d" primer iden tified as TT-P-86C Ty pe I. The red l ead coating covered the entire exterior of the vessel from elevation 8' 11.25" (Fill slab level) to elevati on 94' (belo w dryw ell flange). The sa nd bed region was fille d with d ry sand as specified by ASTM 633. Leakage of water from the sand bed d rains was observed during the 1980 and 1983 re fueling outages. A series of inv estigations w ere performed to identify th e source of the w ater and its l eak path. The resul ts concluded that the source of wat er wa s from the reacto r cav ity, whi ch is floode d duri ng refuel ing ou tages. As a result of the presence of w ater in the sa nd bed region, extensiv e UT thickness measurements (about 1000) of the dry well s hell w ere taken to determi ne if degradation was occurri ng. These measurements corresponded to known w ater leaks and i ndicated that wall thinning had occurred in this region.
Becau se of red uced t hickne ss read ings, a dditi onal thickne ss meas uremen ts we re obtained to determine the v ertical profil e of the thinni ng. A trench w as excav ated inside the dryw ell, in th e concrete floor, i n the area w here thinni ng at the floor lev el was most severe. M easurements taken from the e xcavated trench indi cated that thin ning of the embedded shel l in concre te were no more severe than those taken a t the floor lev el and became less sever e at the lowe r portio ns of t he sand be d regio n. Convers ely, measurements taken in areas whe re thinning w as not identi fied at the floor l evel sho wed no indica tion of significant thinning in the embedded sh ell. Asi de from UT thickness measurements performed by plant staff, indepe ndent analy sis was performed by the EPRI N DE Ce nter an d the GE Ultra Image III "C" sc an top ographi cal ma pping syste m. The independe nt tests confirmed the UT results. The GE Ultra Image resul ts were use d as baselin e profile to trac k continued corro sion.To val idate UT meas uremen ts and chara cteriz e the fo rm of dama ge and its ca use (i.e., due to the pres ence of contaminan ts, microbiolo gical specie s, or both) core samples of the drywell shell were obtained at seven locations. The core samples validated the UT measurements and c onfirmed that the co rrosion of the dry well i s due to the p resence of oxygenated wet sand a nd exacerba ted by the presence of chlo ride and sul fate in the sand bed regio
: n. A contamin ate concentratin g mechanism due to alternate w etting and drying of the san d may hav e also contri buted to the co rrosion pheno menon. It was therefore conclude d that the opti mum method for mitigating the corrosion i s by (1)removal of the sand to break up the galvani c cell, (2) re moval of the co rrosion produc t from t he s hel l an d (3) app lic atio n of a prot ecti ve c oati ng.Removal o f sand was i nitiated du ring 1988 by removing shee t metal from around the vent heade rs to provi de access to th e sand bed from the Torus room. Duri ng operating cycle 13 some sand w as removed a nd access hol es were cu t into the san d bed region through the shield wall. The work was finished in December 1992. Af ter sand removal, 234 the concrete surface below th e sand w as found to be u nfinished w ith improper provisio ns for water drai nage. Correctiv e actions taken in this regio n during 1992 included; (1) cleaning of lo ose rust from the dry well s hell, follow ed by app lication of epoxy c oating and (2) re moving the l oose debris from the concrete floor foll owed by rebuildin g and reshapin g the floor wi th epoxy to allow drainage of any water that ma y leak into the region. UT measuremen ts taken from the outside after cleaning v erified loss of material projections tha t had been mad e based on measurements taken from the inside of the drywell. There were, however, some areas thinner than proj ected; but in all case s eng ineer ing a nalys is det erm ined t hat t he dr ywell sh ell th ick ness sati sfi ed ASME code requirements.
The Protective Coating M onitoring and Maintena nce Program was revised to include monitoring of the coa tings of exterior surfaces of the dryw ell in th e sand bed region. The coated surfaces of the former sand bed region were subs equently in spected durin g refueling outages of 199 4, 1996, 2000, and 2004. The inspections showed no coating failure or signs of deterioration.
The applica nt has stated th at the inspec tions provi de objecti ve ev idenc e that the co ating i s in a good co nditi on and wil l prov ide a dequate protection to the drywell shell in the sand bed region. Likewise, the applicant's evaluati on of UT measurements ta ken from inside the drywel l, in the i n the former sand bed region, in 1992, 1994, and 1996, w as the basis for the applic ant to confirm that corrosion is mitigated. Therefore, the applican t concluded that corrosion in the sand bed region has been arrested and no further lo ss of material i s expected.
The applica nt also concl uded that moni toring of the coatin g in accordance with the Protective Coating Monitori ng and Mai ntenance Program, w ill conti nue to ensure that the contai nment drywel l shell maintains i ts intended functi on during the p eriod of exten ded operation
.2. Dryw ell Shel l above Sand Bed R egion: The UT i nves tigati on pha se (19 86 thro ugh 199 1) als o ide ntifie d los s of mate rial, due to corrosion, in the upper regio ns of the dryw ell shel l. These regions were han dled separately from the sand bed re gion because of the significant di fference in corrosion rate and phy sical difference i n design. Corre ctive acti on for these regions involv ed providin g a corrosion a llowan ce by demon strating, through anal ysis, that th e original drywel l design pres sure was c onservativ
: e. Amendment 165 to the Oyster Creek Techni cal S pecifi catio ns red uced t he dry wel l des ign pre ssure fro m 62 ps ig to 4 4 psi g. The new des ign pressure cou pled wi th measures to pre vent wa ter intrusion into the gap betw een th e dry wel l she ll an d the c oncret e all owed the up per po rtion of the d ryw ell t o meet ASME code requirements.
Origina lly , the kno wle dge of the exte nt of cor rosio n wa s base d on U T measur ements going completely around the i nside of the dry well a t several elevatio ns. At each elev ation , a bel t-lin e swe ep w as use d wi th read ings ta ken on a s lit tle as 1" cen ters whereve r thickness changed between successive nominal 6" centers. Six-by-six grids that exhibited the worst metal loss around each elevation were established using this approa ch and incl uded i n the D ryw ell C orrosi on Ins pecti on Pro gram.As experi ence increas ed with each data col lection campa ign, only grids showi ng evidence of a change we re retained i n the inspec tion program. Add itional a ssurance regarding the adeq uacy of this inspection plan was obtained by a completely randomized inspection, involv ing 49 grids that showed tha t all ins pection loc ations sati sfie d AS ME cod e req uire ment s. E val uati on o f UT me asur emen ts ta ken t hrou gh 235 2000 led th e applica nt to conclud e the follow ing: that corrosio n is no l onger occurring at two (2) ele vati ons, a nd the 3rd el evati on is under going a corros ion ra te of 0.6 mils/year, whi le the 4th el evati ons i s subje ct to 1.2 mil s/yea r. The r ecent UT measu rements (2004) confirmed tha t the corrosion rate continue s to declin
: e. The two e levation s that previ ously exhi bited no in crease in co rrosio n cont inue the no corros ion i ncreas e trend. The rate of corro sion for the 3 rd ele vati on dec reased from 0.6 mils/y ear to 0.4 mil s/yea r.The rate of corrosion for the 4th elev ation decreas ed from 1.2 mils/y ear to 0.75 mils/year.
After each UT exa mination campa ign, an enginee ring analys is is performed by the app licant to en sure the required minimum thickness is provi ded through the period of extended operation. Thu s corrosion of the drywell shell is considered a TLAA further described i n Section 4
.7.2.3. Suppressi on Chamber (Torus) a nd Vent Sy stem The Oyster Creek sup pression cha mber (torus) and v ent system w ere originall y coated with Carb oline Carb o-Zinc 11 p aint. The coati ng is inspecte d periodica lly and repaired to protect the Torus shell and the vent s ystem in ac cordance w ith specificati on SP-1302-52-120. As a resul t wall thinning of the toru s shell an d the vent system has no t been an is sue. A rev iew of past inspections of the torus shel l and the v ent system indicates th e majority of the problems found ha ve been a ttributed to bl istering of coatin g in small areas, localized pitting. In 1983, pitted surf aces of the immerse d torus shell were repai r by w eldi ng. The to rus she ll, th e inte rior o f down comers, and th e enti re interio r surf aces of the vent sys tem were recoat ed with Mobil 78-Hi Build Epoxy.
Inspection pe rformed in 2002 found the coating to b e in good con dition in the vapor area of the torus and vent header, and in f air condition in immersion. Coating def iciencies in immersi on in clude blis tering, rando m and me chani cal d amage. B liste ring oc curs primar ily in th e shel l inv ert but was also noted on the upper shel l nea r the w ater l ine. The fractur ed blisters were repaired to reestablish the protec tive coating barrier. This is anothe r exa mple o f objecti ve ev idenc e that the Oy ster Cr eek ASM E Sect ion XI, Subsection IWE aging management program ca n identify d egradation and implement corrective a ctions to prev ent the loss of the containment's intended functio n.While blistering is co nsidered a d eficiency, i t is significan t only w hen it is fractured and exposes the base metal to corrosion atta ck. The majority of the blisters remai n intact and co ntinu es to p rotect the ba se meta l; con sequent ly th e corro sion rates a re low. Qualitativ e assessment of the identified pi ts indicate that the measured pit depths (50 mils max) are significantly less than th e criteria es tablished i n Specificati on SP-1302-52-120 (141- 261 mil s, depending o n diameter of the p it and spaci ng between pits).In OCGS PBD-AM P-B.1.27, the ap plicant con cluded that th e operating ex perience of the Oyster Creek ASM E Section XI, S ubsection IWE aging management program di d not show any adverse trend in performance. P roblems iden tified woul d not cause s ignificant impact to the safe ope ration of the p lant, and ad equate correc tive actio ns we re taken to pre vent recurre nce. The implementati on of the Oyster C reek ASME S ection XI, Subse ction IWE aging management program will effectively identify con tainment aging effects prior to the loss o f the containment function. Approp riate guidance for evaluati on, repair, or re placement is provided for locations suscep tible to degr adati on. Pe riodi c self-a ssessme nts of th e Oyst er Cre ek ASM E Sect ion XI, Subsection IWE aging management program are performed to identi fy the areas tha t need improv ement to mainta in the quali ty pe rformance of the p rogram.
236 The project team rev iewed th e operating ex perience prov ided in th e LRA and the B.1.27 program basis docu ment, and also interview ed the appl icant's techni cal staff. The project team determined that the OCGS plant-sp ecific operatin g experience is unique, a nd is not b ounded by industry ex perience. A s discussed above, in Section 3.0
.3.2.22.2 of this au dit report, the project team's rev iew of opera ting experie nce led to questions about the applica nt's aging management commitments for the degraded contain ment, and resulte d in three a udit open items.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team ide ntified three au dit open i tems regarding the applicant's ASME Section XI, Subsection IW E program, to asses s whether the program will adequately man age the aging effects that are i dentified in the OCGS LRA a nd PBD-AMP-B.1.27, for whi ch this AM P is credi ted.3.0.3.2.22.6 UFSAR Sup plement Th e a p p l i c a n t p r o v i d e d i t s U F S A R S u p p l e m e n t fo r t h e A S M E S e c t i o n X I , S u b s e c t i o n I WE program i n OCGS LRA, A ppend ix A , Secti on A.1.27, w hich states that th e ASM E Sect ion XI, Subsection IWE program is an e xisting program b ased on ASM E Code and complies w ith the provi sions of 10 C FR 50.55a. Th e progra m consi sts of pe riodi c insp ectio n of pri mary containment surfaces and components, includin g integral attachments , and contain ment vacuum breakers s ystem pipi ng and components for loss of material, loss of seali ng, and loss of preload. Ex amination metho ds include visual and vol umetric testing as required by th e Code. Observ ed con ditio ns tha t hav e the p otenti al for i mpacti ng an i ntende d functi on are evaluated for acceptabili ty in acco rdance wi th ASME requirements or correc ted in accord ance with correc tive acti on process. P rocurement control s and instal lation practi ces, defined in plant proc edur es, e nsur e tha t onl y ap prov ed l ubri cant s an d ten sio n or torqu e are app lie d to bol ting.In i ts l ette r dat ed A pril 4, 2 006 (ML060970288), t he a ppl ica nt co mmit ted t o the foll owi ng:*The OCGS LRA w ill be rev ised to cred it the appl icati on of a stripp able coati ng prio r to flooding the drywell cavity for refueling dur ing the period of extended operation.
This is audit commitment 3
.0.3.2.22-1.
*The O CGS LRA wi ll b e rev ise d to cred it i nve stig atio n of t he s ourc e of l eaka ge, ta ke correc tive actio ns, ev aluat e the i mpact o f the le akage an d, if ne cessar y, pe rform additional drywel l inspecti ons in the event w ater leakage from the former sand bed region is found d uring the perio d of extended operation. Thi s is audit commitment 3.0.3.2.22-2.
*The OCGS LRA w ill be re vised to note continue d UT inspecti on of the dryw ell upper region during the period of exte nded operatio
: n. This is n ew commitment 3
.0.3.2.22-3.
*The OCGS LRA w ill be re vised to credit monitori ng of the protectiv e coating on th e exterior surfaces of the dryw ell in th e sand bed region in acc ordance wi th the requirements of ASM E Section XI, S ubsection IWE during the peri od of extended operat ion. The 5 d ryw ell b ays t hat ha ve no t yet been i nspect ed w ill be in specte d prio r to the period o f extended ope ration. This i s new commi tment 3.0.3.2.22-4.
*The OCGS LRA w ill be re vised to credit performing peri odic confirmatory UT inspectio ns of the drywe ll shell in the san d bed region.
The initial UT measurements w ill be ta ken 237 prior to ente ring th e peri od of ex tended opera tion a nd the n eve ry 10 year s there after. The UT me asureme nts w ill be taken from ins ide th e dry wel l at th e same locat ions wher e the UT measurements w ere taken in 19
: 96. During the initial UT inspection s of the sand bed region from insi de the dryw ell, conduc ted prior to e ntering the peri od of extended operation, an attempt wil l be made to locate and e valuate s ome of the local ly thinn ed areas identi fied in the 19 92 inspecti on from the exteri or of the dryw ell. This i s new commitment 3.0.3.2.22-5.
In its letter d ated May 1, 2006 (AmerGen Letter No. 2130 20328), the a pplicant co mmitted to th e fol low ing:*The OCGS LRA w ill be re vised to state that durin g the next UT i nspections o f the drywel l sand bed region, an attempt will be made to lo cate and ev aluate some o f the locally thinned are as identified in the 199 2 inspectio
: n. This is n ew commitment 3.0.3.2.22-6.
*The OCGS LRA w ill be re vised to credit inspe cting the coatin g on all 20 bays of the suppression chamber (torus) duri ng the period o f extended ope ration. The frequency of inspection will be every other refueling ou tage for the current coati ng system. Shoul d the coati ng sys tem be r eplac ed, the insp ectio n frequen cy an d scop e wi ll be re-ev aluat ed. The inspection scope wi ll, as a mi nimum, meet the requi rements of ASME , Subsection IW E. This is n ew commitment 3
.0.3.2.22-7.
*The OCGS LRA w ill be re vised to credit improv ing the monitori ng and trending of toru s design margins, and to devel op refined accep tance criteria and threshol ds for entering coating defects and unacceptable pit depths i nto the Correcti ve Action process for further evaluati on. These improv ements wil l be inco rporated into th e inspectio n implementing document s prior to the next perform ance of these inspections, which is also prior to the period of extended op eration. This is new commitment 3.0.3.2.22-8.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.27. Contingent up on the inclusi on of new co mmitments 3.0.3.2.22-1 th rough 3.0.3.2.22-8 an d the resoluti ons to open items, the project te am found that it w as consistent with the GALL Report, and determined tha t it provides an adequate summary descript ion of the program , as identified in the SRP-LR FSAR Suppl ement ta ble a nd as require d by 10 CFR 54.21 (d).3.0.3.2.22.7 Conclusio n On the basis o f its audit and review of the applic ant's program and the plant-speci fic operating experience , and discus sions wi th the appli cant's technica l staff, the staff initiated three open item s reg ardi ng t he pla nt-spec ific augm ente d insp ecti ons in clud ed in t he app lican t's AS ME Sect ion XI, S ubse ctio n IWE pro gram t o as sess wh ethe r the prog ram i s ad equa te to mana ge aging of the degraded pri mary contain ment during the ex tended period of operation.
The pro ject tea m also revi ewed the UF SAR S upple ment for t his A MP a nd foun d that, contingent upon the inclusi on of new co mmitments 3.0.3.2.22-1 th rough 3.0.3.2.22-8 an d the resolutions to the open i tems, it provi des an adequate summary descri ption of the program, as require d by 10 CFR 54.21 (d).
238 3.0.3.2.23 ASME S ection XI, Subse ction IWF (OCGS AMP B.1.28
)In OCGS LRA, Ap pendix B , Section B.1
.28, the appli cant stated that OC GS AMP B.1.28,"ASME S ection XI, Subse ction IWF," is an existi ng plant program that i s consistent w ith GALL AMP XI.S3, "A SME Sec tion XI, Subsecti on IWF," with an exce ption and e nhancements.
3.0.3.2.23.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program consi sts of periodic visual exami natio n of ASM E Sect ion XI Class 1, 2, 3 and M C comp onents and p ipin g suppo rt members for los s of mech anica l functi on and loss of materi al. B oltin g is al so in clude d wi th these components, inspecting for lo ss of material an d for loss of prelo ad by in specting for missing, detached , or loosened bolts. Procu rement controls a nd install ation practic es, defined in plant p rocedures, ensure that only approved lubricants a nd torque are app lied. The pro gram is implemente d through corporate and station p rocedures, w hich prov ide inspe ction and accept ance c riteri a cons isten t wi th the require ments o f ASME Secti on XI, 1 995 Ed ition wit h 1996 Addend a.3.0.3.2.23.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.28 is cons istent wi th GALL AMP XI.S3, w ith an ex ception and enhancements.
The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.28, includin g PBD-AMP-B.1.28 ?ASME S ection XI, Subse ction IWF," Rev. 0, whi ch provid es an assessment of the AM P elements' co nsistency with GALL AMP XI.S3.
The project team rev iewed th ose portions of the ASME Section XI, Su bsection IWF program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 6 and found th at they are cons iste nt wit h the GALL Repor t AMP. The pr ojec t tea m fo und t hat t he app lican t's AS ME Sect ion X I, Su bsec tion IW F pro gra m con for ms to the r ecom mend ed GA LL AMP X I.S3 , "AS ME Sect ion X I, Su bsec tion IW F," with th e exce ptio n and e nhan ceme nts a s des crib ed bel ow.3.0.3.2.23.3 Exce ption s to th e GALL Repor t The applican t stated, in the OCGS LRA, that an excepti on to the GALL Report program elements is a s follows:
Eleme nt: Program Descriptio n Exception: NUREG-1801 e valuatio n covers the 2001 editi on includ ing the 2002 and 20 03 Addenda, as approved in 10 CF R 50.55a. The current Oyster Cre ek ISI Program Plan for the fourth ten-year ins pect ion int erv al e ffecti ve fr om Oc tobe r 15, 200 2 thr ough October 14, 2012, approved p er 10CFR50.55 a, is based on the 1995 ASME Sect ion XI Cod e, includ ing 1996 addenda. The next 120-month inspe ction interv al for Oyster Cree k will i ncorporate the requirements speci fied in the v ersion of the AS ME Code incorporated i nto 10 CFR 50.55a twel ve months be fore the start of the inspection interval.
239 The GALL Report i ncludes the following re commendations for the
?program description
" related to the excep tion taken:
Program Descrip tion: 10 CF R 50.5 5a imp oses th e ins ervi ce in specti on (ISI)requirements of the AS ME Code , Section XI, for Cl ass 1, 2, 3, an d MC pi ping and comp onen ts an d the ir ass ocia ted s uppo rts. Ins ervic e insp ecti on of supp ort s fo r ASME piping and c omponents is a ddressed in Section XI, Sub section IWF. This evalu ation covers the 2 001 editio n1 includ ing the 2002 a nd 2003 Add enda, as appro ved in 1 0 CFR 50.55a. ASM E Code Sec tion XI, Subsecti on IWF constitutes an exi sting mandated program applicab le to managing agin g of ASME Cl ass 1, 2, 3, an d MC sup ports for license renewal.
The project team noted that the 1995 ASME S ection XI Code, includin g 1996 addenda , was the then-c urrent editi on in corpor ated i nto 10 CFR 5 0.55a at the time th e appl icant was require d to declare its inspection basis for the cur rent 10-year IW E inspection interval. The applicant will incorporate the requirements speci fied in the v ersion of the AS ME Code incorporated into 10 CFR 50.55a twelve months before the sta rt of the next 12 0-month inspecti on interva
: l. Since this is consistent with the intent of the GALL g uidance, the project team does not consider this to be an actua l excepti on to GALL. On this basis, the project team found this excep tion acceptable.
3.0.3.2.23.4 Enhan cements The app lica nt stat ed, in the OC GS  LRA , that t he enh anceme nt in meetin g the GAL L Repo rt program elements is as follow s: Eleme nt: 1. Scope of Program Enhan cement: Enhancement acti vities, w hich are i n addition to the exi sting Oyster Creek ASM E Section XI, S ubsection IWF program, consist of including ad ditional MC suppo rts inside th e Torus, Torus Support - Bas e Plate and Saddle, Inn er Support Col umn & Outer Support Colu mn) and inspe ction of underw ater MC su pports for loss of material due to corrosi on and los s of mechanical function (Torus Internal -
Downcomer B race Support (un derwater), Ve nt Header Rin g Header Suppo rt (above w ater), Vent Sy stem Inner Support Colu mn (above an d below water) and Vent Syste m Outer Support Colu mn (above an d below water)). En hancements w ill be implemented pri or to entering the period of ex tended operati on.The GALL Report i ncludes the following re commendations for the
?scope of program" program element relate d to the enha ncement stated:
: 1. Scope of P rogram: F o r C l a s s 1 p i p i n g a n d c o m p o n e n t s u p p o r t s , S u b s e c t i o n I WF (1989 editi on) refe rs to S ubsect ion IWB for th e ins pecti on sco pe and sched ule. Accord ing to Table IWB-2500-1, o nly 25% of no nexe mpt sup ports a re sub ject to exami natio n. Sup ports e xempt from exa minati on are the su pports for pip ing sy stems that ar e exe mpt from e xamin ation , accor ding to pipe diame ter or s ervi ce. The same supp ort s are inspe cted in eac h 10-year i nspe ctio n inte rval. For Cla ss 2, 3, and MC piping and c omponent supports , Subsection IW F (1989 edi tion) refers to Sub sections IW C, IW D, and IW E for the inspection scope and schedule. Accor ding to Table 240 IW C-2500-1, 7.5% of no nexempt supp orts are subject to examinati on for Class 2 systems. The same suppor ts are inspected in each 10-year inspection interval. No specific numeric al percentages a re identified in Subsecti ons IWD and IW E for Class 3 and Class MC, respec tively.The pro ject tea m asked the ap plic ant for c larifi catio ns abo ut thi s enha ncemen t, in o rder to bett er un ders tand what MC s uppo rts are cu rre ntly in the O CGS I W F pro gra m, wha t MC suppo rts are bein g added to the OCGS p rogram, a nd al so to c onfirm th at all MC s upport s under the juris diction of IWF are include d in the OCGS IW F program. In respon se, the applicant s tated that (a) The MC s upports that are currently i ncluded i n the exi sting IWF inspection program are: Existing Containment Progr am - IW E (above water line - internal)
E1.20  Dow ncomers E1.20 Ring He ader with in Torus E1.20 Vent Li nes - DW to Torus Vent Line s Exis ting Tor us Ex terior - IWF MC S upport s F1.40 Torus Supp ort - Sway Braces (b) The MC s upports that w ill be a dded to the sc ope of the IWF inspection pro gram for the license renewal period are:
Torus (I nterna l) - IWF MC Suppo rts Torus Support - Base Plate and Saddle Torus S upport - Inne r Supp ort Col umn Torus S upport - Outer Suppo rt Col umn Torus In ternal - Dow ncomer Brace Suppo rt (und erwa ter)Vent H eader Ring H eader Suppo rt (Abo ve w ater)Vent S ystem Inner S upport Colu mn (abo ve an d bel ow w ater)Vent S ystem Outer S upport Colu mn (abo ve an d bel ow w ater)OC-1 ISI Program Pla n Section 4
.0 Component S upport ISI Pla n contains th e current inspe ction detai ls for M C supp orts. A dditi onal work w ill be don e wi th the compon ents identified i n (b) above to confirm the curren t inspection practice. Al l MC s upports wi ll be included.(c) T h e s p e c i fi c u n d e r w a t e r s u p p o r t s t h a t w i l l b e a d d e d t o t h e s c o p e o f t h e I WF inspection program for the licens e renewal period are:
Down comer B race S upport s (und erwa ter)Vent S ystem Inner S upport Colu mn (abo ve an d bel ow w ater)Vent S ystem Outer S upport Colu mn (abo ve an d bel ow w ater)The cur rent i nspect ion p rogram an d ins pecti on det ails for the underw ater su pports identified i n (c) above are not formaliz ed. OCGS does p erform underwater i nspections of the toru s for remo val of sl udge or d ebri s (FM E), i nspe ct su ctio n str ain ers fo r dam age or obstruction, improve w ater clarity , assess coati ng and reestabl ish the coati ng barrier in deficient area. The appl icant stated th at implementin g procedures for the B
.1.28 inspection program for all unde rwater M C supports w ill be c omplete before the period of extended o peration. The p roject team determine d that the appl icant's resp onse sufficiently de fined the enhan ced scope for in spection of M C supports.
241 On this basis , the project team found this enhanc ement acceptabl e since w hen the enhancement is implemented, OC GS AMP B.1.28, "ASME Section XI, Su bsection IWF," will be consistent w ith GALL AM P XI.S3 and w ill prov ide additi onal assuran ce that the effects of aging will be adequately managed.3.0.3.2.23.5 Operating Expe rience The applican t stated, in the OCGS LRA and the program basis document, that the component support ISI program i nvokes the requi rements of the ASM E Section XI C ode. Because the ASME C ode is a co nsensus documen t that has been widel y used ov er a long peri od, it has been show n to be general ly effective in managing aging effects in Class 1, 2 , and 3 components and their integral attachments in l ight-water cool ed power plants. The Opera ting Expe rienc e (OE) o f the ISI program did n ot sho w an y adv erse tr end of i ts perfor mance. Problems ide ntified wou ld not cause significant impa ct to the safe opera tion of the pla nt, and adequate correctiv e actions w ere taken to prev ent recurrence.
There is sufficient c onfidence that the Component Support ISI program as descr ibed in the Oyster Creek ISI prog ram plan will effectiv ely monito r the c ondit ion o f the com ponen t supp orts w ithin LR bo undari es tha t are subject to an indoor air, containm ent atmosphere or tre ated water environment, so that their design function w ill be mai ntained duri ng the extende d license period. App ropriate guidan ce for reevaluati on, repair or replacement i s provide d for any ind ication of degrada tion detected by the OC ISI program. Peri odic self-assess ments of the ISI program are performed to identi fy the areas that ne ed imp rovem ent to mainta in the quali ty pe rformance of the p rogram.The applican t's operating e xperience review process incl udes both ex ternal and i nternal source s. Ex ternal opera ting ex perie nce may incl ude su ch thi ngs as I NPO do cuments (e.g., SOERs, SERs, SENs, etc.), NRC docum ents (e.g., G Ls, LERs, INs, etc.), General Electric documents (e.g., RCSIL s, SILs, TILs, etc.), and other documents (e.g., 10CFR Part 2 1 Reports, NERs, etc.). Inte rnal operati ng experienc e may incl ude such thi ngs as event investigati ons, trending reports, an d lessons l earned from in-hous e events a s captured in program notebooks, self-assessments, and in the 10 CFR Part 50, Appendix B correctiv e action proc ess.The app licant ide ntifie d the fo llowing exam ples of operati ng exper ience to p rovide obj ective evidence that the compone nt support ISI pro gram is effective in assuring that i ntended function(s) wi ll be main tained consi stent with the CLB for the p eriod of exten ded operation
: Challenges w ere identified in the NIS
-1 Owner's Da ta Report for Inserv ice Inspecti ons for the first period o f the Fourth Inserv ice Inspecti on interva l, submitted to the NRC on 2/16/2005. This report covered examinati ons conducted between Octob er 28, 2002, and November 22, 2004, in accordance with the ASME Code. From the initial sample size of 40 ro d hangers, 2.5% w ere found to be u nacceptable.
Scope ex pansion w as require d due to una ccepta ble a s-found condi tions on rod hanger s. The s ystems involv ed were: Iso lation Con denser, Core S pray Sy stem, Standby Liquid Control Shutdown Cooling, Rea ctor Water Clean Up, Reactor Recirc, Contro l Rod Dri ve, Containment S pray, Feedw ater and Reac tor Buildi ng Closed Co oling Water System piping suppo rts, ASME Code Class 1 & 2. Ro d hangers we re the initi al problems.
The second scope expa nsion of rod h angers fo und z ero fai lures. No It ems w ere ret urned to serv ice bas ed s ole ly on e val uati on. All we re re stor ed/r ewo rked to th eir inte nded des ign configuration.
Another chal lenge that w as corrected w as a loss o f preload (wi thout loss of mecha nical function) for 3 spring c ans. The load settings were found outside the tolerance 242 (Referen ce CAP's 020 04-331 1 and -3341 along with A2078 197). The spr ing can s wi th the lo ad set tings o ut of spe c did not affec t the s ample expa nsion. A "ro ot cau se" fai lure evaluati on was d ocumented in AR A207819 7 Eval. 2 3. Reinspe ctions hav e been scheduled a s part of ISI program for the n ext outage.
A focused-area sel f-assessment at OCGS in dicated that C ode Cases a nd Relief Reques ts we re not easil y foun d in t he pro gram doc uments and th e lis tings w ere incomplete.
The ISI Program plan was update d to inclu de a summary o f all Reli ef Requests in effect in Section 4 o f the ISI plan an d to inclu de a listi ng of all Code Cases invoked in the plan.
This exampl e provide s objective evidenc e that program deficie ncies are identified and entered into the cor rective action process and that the prog ram is updated as ne cessary to e nsure that it re mains effective for con dition moni toring of piping an d compon ents within the scop e of lice nse rene wal. The abo ve correc tive action issu e is iden tified in OCGS CAP O2004-173 6.A focused-area sel f-assessment at OCGS in dicated that a lthough a Rel ief Request for examinatio n of a reactor press ure vessel support skirt w eld had be en granted, no provision to augment the ASME Code-required sur face examination with a volumetric (UT) examinati on of the restricted area was addressed. A new ex am record wa s added to the ISI databa se to reflect the re quired UT exami nation. This example pro vides objective e vidence that program deficienc ies are id entified and e ntered into the corrective action process and that th e program is updated as necessa ry to ensure that it remains effective for co ndition moni toring of piping an d components w ithin the sc ope of license renewal. . The above corrective action issue is identified in OCGS CAP O2004-1736.
The applicant concluded that the Oyster Creek ASME Section XI, Subsection IW F program is effect ive in m anag ing t he e ffects of agi ng.The project team asked th e applica nt to provi de additio nal information about the findi ngs and resolution for the
?challenges" i dentified in the most recent IWF inspections (1st inspecti on perio d of the 4th i nspect ion i nterv al). I n resp onse, the ap plic ant sta ted tha t  the s ystems involve d were: Iso latio n Cond ense r, Co re Sp ray Sys tem , Sta ndby L iqui d Cont rol Sh utdo wn Cooling , Reacto r W ater Clea n Up, Reac tor Reci rc, Cont rol Rod Dri ve, Conta inment Spry, Feedwater and Reactor B uilding Cl osed Cooli ng Water System piping supports, ASME C ode Class 1 &
: 2. The initi al sample s ize w as 40 and p ercentage found to be unacceptabl e was 2.5%. Loss of materia l due to co rrosion wa s not identi fied. One case w as a loss o f preload whi ch wa s corre cted a nd the 3 spri ng cans had th e loa d setti ngs outs ide th e tole rance. However, there was not a compromise of intended f unction. The applicant ref erenced CAPs 02004-331, 020 04 -3341, and A2078197. The final sample s ize, after scope expansi on, was 51 and the percen tage found to be una cceptable w as 4%. No sup ports were re turned to serv ice based on ev aluation.
All we re restored/rew orked to its inte nded design c onfiguration. AR-E val A2078 197 E2 3 (prov ided to the project team) c ontai ns the "root c ause" failur e eva luati on. Re-inspectio ns have b een schedul ed as part of ISI p rogram at the next outage.The project team rev iewed s everal CA Ps and noted problems w ith supports i n the Core S pray System datin g back to 2000. The p roject team asked the applicant to provide information on correc tive actio n taken to prev ent rec urrenc e. In r espon se, the appl icant stated that th e Core Spra y ha d a l ong h isto ry o f hyd raul ic t rans ien ts, w hic h ov er th e ye ars c ause d su ppor t dam age of various de grees. Some of the corre ctive acti ons taken, whi ch mitigated these concerns are:
243 1. Installati on of a Keep F ull sys tem 2. Installati on of Frequency C ontrollers on the Test Valv es V-20-26 an d V-20-27, w hich slow do wn the op ening stroke.
: 3. Modifica tion of the pump re circulation piping to pro vide a c ontinuous v enting path and mini miz e the ris k of pi pin g vo idi ng.4. Implemented w eekly PM to verify the system is filled and vented.5. Modifica tion of the coun ter weight as sisted check v alves (i.e., V-20-51 and V-20-52)to minimiz e the risk of sticking o pen. They w ere converted to regular sw ing check valv es after malfunc tioni ng of V-2 0-51 w as det ermine d to be the ro ot cau se for so me water hammer tran sients exp erienced in Core Spray System 2 .
The applican t stated that al l the deficie nt supports found d uring 1R20 (20
: 04) are schedu led for re-ins pecti on dur ing 1R 21 (20 06) .The project team determi ned that the ap plicant's course of action for the 2 occurrence s discussed ab ove prov ide confirmation that its IWF program is effective.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d the program basis docu ment, and interv iewed th e applica nt's technical staff to confirm that the plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's ASME S ection XI, Subsection IWF program wil l adequately manage the aging effects that a re identified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.23.6 UFSAR Sup plement Th e a p p l i c a n t p r o v i d e d i t s U F S A R S u p p l e m e n t fo r t h e A S M E S e c t i o n X I , S u b s e c t i o n I WF program i n OCGS LRA, A ppend ix A , Secti on A.1.28, w hich states that th e ASM E Sect ion XI, Subsection IW F aging managem ent program is an existing prog ram that consists of periodic visu al ex aminat ion o f ASME Secti on XI Cl ass 1, 2, 3 an d MC compon ents a nd pi ping su pport members for los s of mech anica l functi on and loss of materi al. B oltin g whi ch is incl uded w ith these components is monitored for loss of material and loss of prel oad by i nspecting for missi ng, deta ched, or loo sened bolts. Iden tificat ion o f any a ging effect s wou ld in itiat e eval uatio n and establ ishmen t of corr ectiv e acti ons. Th e requi rements of ASM E Sect ion XI, Subsection IWF are implemen ted in accord ance wi th 10 CFR 5 0.55(a). The scope of the program will be enhanced to includ e addition al MC supports, and re quire inspecti on of underwater s upports for loss o f material due to corrosion and loss of mechani cal function an d loss of preload on boltin g by inspec ting for missing, detach ed, or loosen ed bolts. P rocurement controls and installati on practices, d efined in pl ant procedures, ensure that onl y approv ed lubri cants a nd torqu e are a ppli ed. En hance ments to the pr ogram w ill be imp lement ed pri or to entering the peri od of extended operation.
244 The project team also reviewed the License Renewal Commitment List contained in the LRA Table A.5, to confirm that th e scop e of the program wil l be e nhanc ed and the en hance ment implemented pri or to the ex tended period of operation. Thi s is item 28 in LRA Tabl e A.5.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.28 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as require d by 10 CFR 54.21 (d).3.0.3.2.23.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that those program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage t he agi ng effects for whi ch it is cre dited. Also, the pro ject team has rev iewed th e enhancements an d determined th at the implemen tation of the enh ancements prior to the period of exte nded o perati on w ould resul t in th e exi sting A MP b eing co nsiste nt wi th the GALL R eport AMP to w hich it w as compared. The project team also review ed the UFSA R Supplemen t for this AMP and found that i t provides an adequate summary description of the program, as require d by 10 CFR 54.21 (d).3.0.3.2.24 Structure Mo nitoring Program (OCGS A MP B.1.31)In OCGS LRA, Ap pendix B , Section B.1
.31, the appli cant stated that OC GS AMP B.1.31,"Structures Mo nitoring Program," is an exis ting plant program tha t is consis tent with GALL AMP XI.S6, "S tructures Mon itoring Program," w ith enhancemen ts.Subsequent to sub mittal of the LRA , the appli cant added the Forked Riv er Combustion Turbine (FRCT), the M eteoro logica l Tow er, and the Ra dio C ommuni catio ns Sy stem to the OCGS license ren ewal sco pe, in respon se to staff RAIs relate d to scoping a nd screening. The applicant c redited the stru ctures monitorin g program for aging management of structural components and the external surfaces of mechanica l components.
This is consi stent with the LRA. In AmerGen letter 2130-05-2 0239 dated D ecember 9, 2005, Appendix D, the appl icant provided its latest rev ision to the OCGS structures moni toring program, AMP B.1.31, to reflect the increased scope. Also included in the aforem entioned letter was a revised FSAR Suppl ement, S ectio n A.1.3 1 of the LRA, and a revi sed LR A commi tment l ist for A MP B.1.31, to ident ify t he inc reas ed sc ope of the pr ogr am. The pr ojec t tea m's a sses smen t of OCGS AMP B.1.31 is ba sed on the rev ised structures monitoring program prov ided in th e December 9, 2005 AmerGen l etter, which covers thes e new ad ditions to th e OCGS licen se renewal scope.3.0.3.2.24.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for aging management o f structures and stru ctural componen ts, includi ng structural bol ting, withi n the scope o f license renewal. The program was develope d based on guidance in Regulatory Gui de 1.160, Revi sion 2, ?Monitori ng the Effectiveness of Maintenan ce at Nucle ar Power P lants," and NUM ARC 9 3-01, ?Industry Guide lines for M onitoring the E ffectiveness of Ma intenance at Nucle ar Pow er Pla nts,"  R evis ion 2 , to sa tisfy t he requ iremen t of 10 C FR 50.65, ?Requir ements for Mo nitori ng the E ffective ness o f Mai ntenan ce at N uclea r Pow er Pla nts."
245 The applican t stated that the scope of the program al so include s condition monitoring of masonry walls and water-control structures as desc ribed in the Masonry Wall Progr am and in the RG 1.127, i nspection of w ater-control structu res associated with nu clear pow er plants, aging management program. As a result, the p rogram elements inc orporate the recomme ndati ons of N RC Bu lleti n 80-1 1, ?Maso nry Wall D esign," the gui dance in NR C IN 87-67, ?Lesson s Lear ned from Region al Ins pecti ons of L icens ee Act ions in Re sponse to Bull etin 8 0-11," and th e reco mmendat ions of NRC Regula tory Gu ide 1.127, ?Inspection of Water-Control Struct ures A ssoci ated w ith Nu clear Pow er Pla nts."The applican t further stated that the program relies o n periodic visual inspections by quali fied person nel to mon itor st ructur es and com ponent s for a pplicable aging eff ects. Specific ally, concrete structures are inspected for loss of material , cracking, and a ch ange in material proper ties. Steel compon ents a re ins pected for los s of mate rial due to corros ion. Maso nry walls are inspected for cracking, and ela stomers wil l be monitore d for a change in material properties. Ea rthen structures as sociated w ith water-co ntrol structures a nd the fire pond dam will be inspected for loss of material and loss o f form. Component supports will be inspected for loss of material, reduction or l oss of isolati on function, and reduction in anchor capac ity due to local concrete degradat ion. Exposed surfaces of bolting are monitored for loss of material, due to corrosi on, loose nu ts, missing bolts , or other ind ications of l oss of preload.
The program relie s on p rocure ment co ntrols and i nstal latio n prac tices, define d in p lant p rocedu res, to ensur e that only approved l ubricants and proper torque are applied c onsistent w ith the NUR EG-1801 Bolti ng Integri ty Pro gram.The applican t further stated that the scope of the program w ill be e nhanced to i nclude structures that are not monitored u nder the current term but require moni toring during the peri od ext ende d oper atio n. Det ails o f th e enha ncem ents are di scus sed b elow.The applican t stated that the inspection frequency is ev ery four (4) ye ars; except for su bmerged portions of w ater- control struc tures, whic h will be inspecte d when th e structures are d ewatered, or on a frequency not to excee d 10 years. The program contain s provisi ons for more frequent inspections to ensure that observed co nditions tha t have the potential for i mpacting an inte nded function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.3.0.3.2.24.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.31 is cons istent wi th GALL AMP XI.S6, w ith enhancemen ts. The project team no ted that the app licant di d not identi fy an exception in the OCGS LR A to AMP XI.S6 in the GAL L Report. The ex ception is discussed below. The pro ject tea m inter view ed the appl icant's tech nical staff and revi ewed , in w hole or in part, the documents l isted in A ttachment 5 of this a udit and rev iew repo rt for OCGS AMP B.1.31, incl uding PBD-A MP-B.1.31, ?Structures Mo nitoring program," Rev. 0, which provides an assessment of the AM P elements' co nsistency with GALL AMP XI.S6.
Specificall y, the project team re view ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report)contai ned i n OCGS AMP B.1.31 and a ssoci ated b asis d ocumen ts to d etermi ne con sisten cy w ith GALL AMP XI.S6.During the cours e of the audit, th e project team asked the applica nt to clarify a number of aspects of its struc tures monitoring p rogram. The applic ant's clari fications help ed the project team to assess the pr ogram's consi stency wit h the GA LL Rep ort.
246 The project team rev iewed th ose portions of the structures moni toring program for whi ch the applicant c laims consi stency w ith GALL AM P XI.S6 and found th at they are consistent w ith the GALL Report AM P. The project team found that the app licant's s tructures monitori ng program conforms to the recomme nded GA LL AM P XI.S6 , wi th the exce ption s and enhan cements desc ribe d belo w.3.0.3.2.24.3 Exce ption s to th e GALL Repor t The app lica nt did not i denti fy an e xcep tion i n the OC GS LRA to AM P XI.S6 in th e GALL Repor t. Howeve r, based on the reconcili ation from draft January 2005 NURE G-1801, Rev. 1 to the appr oved Se ptem ber 2 005 NU REG-1801 , Rev. 1, th e appl ican t iden tif ied an excep tion to AMP XI.M36 in the GALL Report, the external surf aces monitoring prog ram. This new exception is documented in PBD-AMP-B.1.31, whi ch is the pro gram basis documen t for the structures monitoring program. In PBD-AMP-B.1.31, the appl icant stated th e followi ng exception to the GALL R eport p rogram el ement: Eleme nt: 4. Dete ction of Agin g Effects Exception: The program takes excep tion to the i nspection frequency of at least once p er refueling cyc le specified in NURE G-1801, XI.M36, Rev. 1, for moni toring external surfaces of mechanica l components. The sp ecified frequency b y the Oyste r Creek (structures monitori ng) program is eve ry 4 yea rs.The GALL Report i dentified the foll owing recommend ations for the
?detection of aging effects" program element in AMP XI.S6 associated w ith the ex ception taken:
: 4. Detect ion o f Agin g Effec ts: For each structu re/aging effect combination, the inspe ction method s, ins pecti on sch edule , and i nspect or qual ificati ons ar e sel ected to ensure that aging d egradation w ill be d etected and quanti fied before there is loss of intended functio ns. Inspection methods, inspec tion schedul e, and inspe ctor qualifications are to be commensu rate with industry co des, standards a nd guidelin es, and are to al so consider industry an d plant-speci fic operating ex perience. A lthough not required, ACI 34 9.3R-96 and A NSI/ASCE 11
-90 provid e an acceptab le basis for addressing detec tion of aging effects. The pla nt-specific structure s monitoring program is to contain sufficient detail on detection to conclude that this prog ram attribute is satisfied.
In reviewing this exception, the project team re cognized that the applicant identified this exception to the recommendati ons in the GALL Report for the external su rfaces monitoring program, AMP XI.M 36, since the OCGS structures moni toring program was credited to moni tor the external surfaces of components.
Therefore, the project tea m also revi ewed the recommendations i n the GALL Re port for the
?detection of aging effects" program e lement for AM P XI.M36 , wh ich are the fo llo wi ng: 4. Detection of Aging E ffects: Degradation of stee l surfaces canno t occur wi thout the degradation of the p aint or coati ng. Confirmation of the integrity of the p aint or coati ng is an effectiv e metho d for man aging th e effects of corro sion on the steel surface. A visu al in specti on is condu cted for compon ent su rfaces a t leas t once per re fuelin g cycl e. This frequency acco mmodates inspecti ons of components th at may be i n locations that are normally only accessible during outages. System walkdowns are norm ally 247 performed on a fre quency that e xcee ds onc e per fu el cy cle. Surface s that are inacc essib le or not rea dily vis ible durin g plan t opera tions and re fuelin g outages are inspected at such intervals that would ensure the component s intended function is maintained.
The interval s of inspection s may be ad justed as neces sary based on plant-specific inspection results and i ndustry ex perience.The applican t provided the follow ing technical justifications for this excepti on in the p rogram basis docume nt: The frequency of 4 ye ars specified for mon itoring of exteri or surfaces of mechanic al components is consistent w ith the frequency specified for ex terior surfaces of supp orting structures. The 4-y ear frequency is consistent w ith industry guidelines and has prov en effective in dete cting loss of materi al due to c orrosion, and change in materi al propertie s of structural elas tomer on exteri or surfaces of structures.
Consequently this frequency will also be effectiv e for detecting los s of material and change in materi al propertie s on exterior surfaces of mechanical components before an intended functi on is impac ted.Industry and plant-specific operating exp erience rev iew has not identi fied any i nstances of significant loss of material or ch ange in material properties of ex ternal surfaces of mechan ical compon ents su bject to indo or air envi ronmen t.Mechanical components subject to outdoor air are constructed fr om stainless steel, aluminum, w hich are not susceptible to accelerate d corrosion, o r carbon steel components protecte d by protecti ve coatin gs such as galv anizing, or painting. Pl ant operating exp erience ind icates that moni toring of exterior surfaces of components mad e of these materials and protectiv e coatings on a frequency of 4 y ears provi des assurance that loss of materia l wil l be detected before an inten ded function i s affected.
Studies by EPRI prov ide a corrosi on rate curve for carbon steels. This curve was constructed fr om 55 individual tests representing at least f ive different steels and six different test locatio ns and env ironments. The cu rve show s 0.926 mils per year thickness loss during the first 1 1/2 years, decrea sing to 0.21 mil s per year after 15 1/2 years. EPR I also condu cted corrosion tests of ASTM A-3 6 structural stee l at four nuclear pla nts located i n Elma and Richland, Washington; and Midlan d, Michi gan. The tests were co nducted for up to 2 4 months. EPR I concluded that based on the test results the corrosion rate is 0.5 m ils per year. If the corrosion rate is conser vatively taken as 0.926 mi ls per ye ar, then the lo ss of material pro jected for 4 years is less th an 4 mils. This loss of material is insi gnificant and w ill not i mpact the intend ed function of mechanical c omponents.
The applican t was asked to confirm that the OCGS LRA wou ld be rev ised to in clude this new exception in the structure s monitoring program, A MP B.1.31. The applic ant stated that th is new exception would b e include d in the OCGS LRA for AMP B.1.31.In its lette r dated Marc h 30, 2 006 (M L0609 50408), the a ppli cant co mmitted to rev ise th e OCGS LRA to add the excepti on identified in its reco nciliati on document for the structures monitori ng program, which states that the pro gram takes exceptio n to the insp ection frequency of at least once per refueli ng cycle sp ecified in N UREG-1801, XI.M 36, Rev. 1, for monitoring exte rnal surfaces of mechanical components. The specified frequency by the Oy ster Creek (structures monito ring) p rogram i s eve ry 4 y ears. This is A udit Commitment 3.0.3.2.2 4-1.
248 On the basis th at monitoring the external su rfaces of mechanical components on a 4-year frequency is ade quate to provi de assurance of their structural integrity, the project team determined that this excep tion is acc eptable.3.0.3.2.24.4 Enhan cements The applican t identified, i n the program basi s document (PBD-AMP-B.1.31) for the structures monitoring program, the following e nhancements to th e GALL Report elements: Enhan cement 1 Eleme nt: 1. Scope of Program Enhan cement: The followi ng structures and co mponents wi ll be add ed to the scope of the p rogram.
* Chlorinati on facility , Exhaust Tunn el, Heating B oiler house
, Oyster Creek Subs tation, Fire Pond Dam, and Miscel laneous Ya rd Structures
* Panels and enclosures
* Exposed s urfaces of concrete anch ors and embedmen ts.
* Penetr ation seal s othe r than fire sea ls. F ire se als a re included with fire pro tection activ ities
* Doors other t han fir e rated doors. Fire rated doors are included with fire pro tection activ ities.
* Structural seal s (secondary containment, an d flood barriers)
* Components supp orts includi ng, electrical cable trays
, electrical conduit, tubi ng, HVAC ducts, instrument racks, battery racks, a nd sup ports for pipi ng and compon ents that ar e not w ithin the sc ope of A SME Secti on XI, Subsection IWF.
*Concrete surfaces e xposed to salt water and fire pond wate r (RG Gui des 1.127).*Miscel laneous stee l*Foundation and anchorage of equipment, tank s, panels and enclosu res.*Duct banks, and ma nholes*Offsite power transmiss ion towe r*Sub merge d ste el a nd w oode n co mpon ents at th e Int ake Structure and C anal, Dil ution Structure, and Fire Po nd Dam.*Liner for contai nment dryw ell and re actor buildi ng sumps*Steel and w ooden bulkhea ds 249 The scope of the pro gram will also be en hanced to in clude inspection of exterior surfaces of Oyster Creek and Forked Rive r Combus tion Tu rbine s (FRC T) mecha nical compon ents th at are not covered by other pro grams, includin g exterior surfaces of HVAC ducts, damper housin gs and duct clo sure bolting w ithin the scope of lice nse re newa l. Co mponen ts that wil l be a dded t o scope of the program i nclude pi ping components, v alves, tanks, vessels, e tc. located i n indoor or outdoor air e nvironments.
The scope of the program i s limited to components w hose exteri or surf aces are no t mon itor ed by ot her p rog ram s suc h as AS ME Section XI, ISI P rograms and fire protecti on activi ties.The program wil l also be enhanced to require periodi c sampling of groun d water to confir m that the enviro nment is non-ag gress ive for buried reinforced concrete duri ng the period o f extended operation.
The scope of the pro gram will be enhanced to include Station Blackout Sys tem (FRCT) structures, stru ctural componen ts, and phase bus enclosur e assem blies. In spectio n freq uency, inspection methods, and acc eptance criteri a will be the same a s those speci fied for o ther  s tructur es in scope of the p rogram.Con cret e fou ndat ion s for Stat ion Bla ckou t Sy stem (FR CT)structu res w ill be in specte d for cra cking an d dis tortio n due to increased stres s level from settlement that may result from degradation of the i naccessible wooden piles.The program wil l be enhan ced to incl ude Inspectio n of Meteorolo gical Tower Structures. Inspec tion and acc eptance criteria will be the same as those specified for ot her structures in the sco pe of th e progra m.The program wil l be enhan ced to incl ude inspecti on of exterior surfaces of piping an d piping compo nents associa ted with the Radio Communi cations sy stem, located at the meteorologica l tower site, for loss of material due to corrosi on. Inspectio n and acceptance cri teria wi ll be the same as those s pecified for other external su rfaces of mechanical components.
The GALL Report i dentifies the foll owing recommend ations for the
?scope of program" program element associ ated with the enhancemen t taken: 1. Scope of Prog ram: The applica nt specifies the structure/aging effect combinati ons that ar e manage d by its str ucture s moni toring program.In the program basi s document, PBD-AMP.B.1.31 , the appli cant provid ed the follow ing basis for these enhance ments: GALL sp ecifie s that the ap plic ant de fines th e scop e of thi s AM P for li cense renew al. The cur rent OC GS stru ctures monito ring pr ogram w as dev elope d and imple mented to 250 meet the regulator y requirements of 10 CFR 50.65, Maintenance Rule, USNRC Regula tory Gu ide 1.160, a nd NU MAR C 93-0 1, ?Industry Guide line for M onitoring the Effectiv eness of Mai ntenan ce at N uclea r Pow er Pla nts."  Th e progra m incl udes ma sonry wal ls ev aluat ed in accord ance w ith NR C IEB 80-11, ?Masonry Wall Design" and incor porate s guida nce i n NRC IN 87-67, ?Lessons Learne d from Regional Ins pection of Licensee Ac tions in R esponse to IE Bulletin 80-11."  The program el ements also incor porate the re commend ation s of NRC Regul atory Guide 1.127 , ?Inspection of Water-Control Struct ures A ssoci ated w ith Nu clear Pow er Pla nts."The program is impl emented through a s tation procedu re, which identifies the structures and structural components w ithin the sc ope of the Ma intenance R ule; how ever, some of the structures in the scope of Li cense Renew al are not co vered by the scope of the Maintena nce Rule.
Thus, the scope o f the program was en hanced to in clude addi tional structu res an d struc tural compon ents th at are in sco pe of l icens e rene wal. In so me cases the add ed structure or co mponent is i ncluded i n the exi sting inspecti ons; howev er there are no p rocedural requi rements to perform the i nspection for the particular structure or compone nt. In this ca se the enhanc ement consists o f revising proce dures to spe cifica lly addre ss the structu re or c ompone nt.The project team rev iewed th e enhancements to ?scope of program" and th e applica nt's basis, and determined that, with these enhance ments, the appli cant's structures monitoring program is con sisten t wi th GALL , for thi s progra m eleme nt.Enhan cement 2 Eleme nt: 3. Parameters M onitored or Ins pected Enhan cement: The existin g Oyster Creek Structure s Monito ring Program implementing pro cedure wi ll be rev ised to in clude the foll owing enhancements:
*For co ncrete structu res, th e progra m wil l be e nhanc ed to require visu al inspecti on for change in ma terial prope rties due to leac hing of calcium hyd roxide and aggr essive chemical attac
: k. The visual inspection consists of observing co ncrete surfaces for signi ficant leachin g or disintegration.
Concrete structu res wil l also be observed for a red uctio n in a nchor capaci ty du e to l ocal concre te degradation. This will be accompli shed by v isual inspection of concrete surfaces arou nd anchors for crac king, and spa lli ng.*The program wil l be enhan ced to add l oss of material d ue to corrosion for stru ctural steel members and other steel components, such as embedments, pan els and encl osur es, d oors , si din g, met al d eck, stru ctur al b olti ng, anchors, and miscellaneous steel.
*The program wil l be enhan ced to require i nspection of penetration seals and structur al seals, for change in 251 material prope rties by i nspecting the se als for cracking and hard eni ng.*The program wil l be enhan ced to require mon itoring of vibr ation isol ators, associ ated w ith co mponen t supp orts other than those covered b y ASM E XI, Subsection IWF, for reduction or l oss of isolati on function by inspecting the iso lato rs for crac king and hard eni ng.
* The program wil l be enhan ced to require v isual in spection of external su rfaces of mechanical steel componen ts that are not cove red by othe r programs for loss of materia l due to corr osion , and c hange ma terial prope rties, due to leaching of cal cium hydrox ide and aggressi ve chemica l attack for reinforced concrete. Accessibl e wooden piles and sheeting w ill be i nspected for loss of material and change in materi al propertie
: s. Concrete founda tions for Station Bla ckout System structu res wil l be insp ected for cracking and disto rtion due to increased stres s level from settlement that may result from degradatio n of the inaccessibl e wooden piles. M echanical elastomers, such as hoses, w ill be i nspected for a cha nge in material properties by observin g the elastomer for cracki ng and hardening. These enhanced requirements are applicable to both Oyster C reek and FRCT mecha nical compon ents.*Groundwater w ill be mon itored for pH, chl orides, and sulfates.*The program wil l be enhan ced to require v isual in spection of external su rfaces of mechanical steel componen ts that are not cove red by othe r programs for leakage from or onto external surfaces, worn, flaking, or oxide-coated surfaces, corrosion stains on the rmal insula tion, and protec tive coati ng degrad ation (cracki ng and flaking). These e nhanc ed requ iremen ts are appli cable to bot h Oyster Creek and FRCT mechanica l components.
Note: This is a new co mmitment based on the reconcilia tion of this agin g management program from draft January 20 05 NUREG-180 1, Rev. 1 to the approv ed September 2005 NUREG-1801, R ev. 1.*The program wil l be enhan ced to require re moval of pip ing and component i nsulation to permit vis ual inspe ction of insulated s urfaces. Removal of insulatio n will be on a sampling basi s that bounds insulation material ty pe, suscep tibil ity o f insul ated p ipin g or comp onent materi al to potential degradations that could result from being in contac t wi th ins ulati on, an d sys tem ope rating tempera ture.
252 These e nhanc ed requ iremen ts are appli cable to bot h Oyster Creek and FRCT mechanica l components.
*The program wil l be enhan ced to require i nspection of exterior surfaces of HVAC ducts, damper housin gs, for loss of material and HVAC closure bol ting for loss of material and loose or mis sing bolts nu ts. These enhanc ed requirements are ap plicable to both Oyste r Creek and FRCT components.
The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored or inspected" pro gram element associ ated with the enhancemen t taken: 3. Parameters Moni tored or Inspected
:  For each structure
/aging effect combination, th e specific parameters monitored or i nspected are se lected to ens ure that aging degradation le ading to loss of intended functi ons wil l be detected and the ex tent of degradation can be determined.
Parameters monito red or inspec ted are to be commensurate wi th industry codes, standards and guideli nes, and are to also consi der plant-specific operating exp erience. Al though not required, ACI 349.3R-96 and ANSI/ASCE 1 1-90 provi de an accepta ble basis for selection of pa rameters to be monitored or i nspected for concrete and steel structural ele ments and for steel liners, joints, coatings, a nd waterproo fing membranes (if appli cable). If necessa ry for managing settlement an d erosion of po rous concrete su bfoundations, the continued functionality of a site dewatering system is to be monitored. The plant-specif ic structures monitori ng program is to conta in sufficient deta il on para meters monitored o r inspected to conclude tha t this program attrib ute is satis fied.In its letter d ated March 30, 2006 (M L060950408), th e applica nt committed to en hance the structures monitori ng program (B.1.31) to requi re visual inspection of external s urfaces of mechan ical steel compon ents th at are not co vered by o ther pr ograms for leakage from or o nto external su rfaces, worn, flaking, or oxide-coate d surfaces, corrosio n stains on thermal insulation , and protectiv e coating degradati on (cracking and flakin g). These enhanced require ments a re app lica ble to both Oy ster Cr eek and FRCT me chani cal co mponen ts. This is Aud it Commitment 3.0.3.2.24-2
.As justification for the adequacy of the enhancements to this program el ement, the appl icant stated: For each structure and aging effect combina tion, the spec ific parameters moni tored or inspected are selected to ensure that aging d egradation lea ding to loss of intended functio ns wi ll be detec ted an d the e xtent of degrad ation can b e dete rmined. Para meters monitored or i nspected are b ased on aging effects id entified for Oyster C reek material and en viro nment c ombina tions docume nted i n PP-1 5, Stan dard M ateria ls, En viro nments and Agi ng Effects.
Where requi red, th e exi sting a ging man agement activ ities are enhanced to e nsure that paramete rs monitored w ill detec t degradations tha t could le ad to a loss of an intended functi on.Para mete rs mo nito red u nder the exi stin g pro gram i ncl ude the fo llo wi ng:*Reinforced concre te structures are mon itored for loss o f material, and cra cking. The aging effects are monitored b y inspecti ng concrete surfaces for spa lling, scal ing, rebar 253 corrosion, rust s tain, water stains, wa ter intrusion, rebar exposu re, disintegratio n, and cracking*Structural steel members and con nections are monitored for loos e or missing bo lts, which a re considered loss of prelo ad, cracked we lds, and l oose or disto rted structural members.*Mas onry blo ck w all s are moni tore d for crac ks, a nd l oose blo cks*The intake canal slopes and embankments are moni tored for loss of form by inspecting for cracks, sink holes, a nd embankment coll apse.Program enhancements required to ensu re that parameters mon itored wi ll detect degrada tions that c ould lead to a l oss of a n inte nded fu nctio n are s ummariz ed bel ow. In some ca ses the enhan cement is in clude d as p art of ex istin g activ ities. How ever, there are no procedu ral requirements o r commitment to perform the a ctivity. For these ca ses, the en hance ment co nsists of rev isin g the pr ogram im plemen ting pr ocedu re to proceduraliz e the performed ins pections.Parameters monitore d or inspecte d are deve loped to i mplement the require ments of 10 CFR 5 0.65, ?Mai ntenan ce Rul e," US NRC R egulat ory Gu ide 1.160, I EB 80-11, an d RG.1.127 for water control structures. The parameters moni tored or inspe cted are based on in dustry stand ards, i nclud ing AC I 349.3 R-96, ?Evaluati on of Existi ng Nuclear Safety-Rela ted Co ncrete Struct ures," NEI 96-03, ?Guideline for Monitorin g the Conditi on of Struc tures a t Nucl ear po wer P lants ," NUM ARC 9 3-01, ?Industry Guide line for Monitori ng the Effectiveness of Maintenan ce at Nucle ar Power P lants," and NURE G-1522, ?Assessment of Inserv ice Condi tions of Safety-Re lated Nucl ear Plant Structu res."Concrete parameters monitored or i nspected are b ased on ACI 349.3R-96. Stru ctural steel and ste el liner inspection parameters are bas ed on desi gn codes and sta ndards includin g American Institu te of Steel Con struction (AISC
). ANSI/ASCE 11-90 is n ot speci ficall y refer enced in pr ogram im plemen ting do cuments , how ever its el ements are incor porate d in t he pro gram.Oyster Creek s tructur es are founde d on h ighly dense soil and s ettleme nt is not a concern. Observ ed total settl ements of the reactor b uilding founda tion have ranged from 2/3 to 3/4  inche s, which compares wel l with the predicted settlement of less that one inch.
Thus a settlement monitoring is n ot required; nor i s a de-wate ring system relied upo n to control s ettlement. Porou s concrete is not incorporate d into the d esign of Oyster Creek sub-found ation.The enhanced Oy ster Creek Structures Monitori ng Program contains s ufficient detail on parameters monitored or inspected to conclude with rea sonable ass urance that NURE G-1801 XI.S6 an d XI.M 36, ?Exter nal S urfaces Moni toring Program," attri butes are satisfied.The project team rev iewed th e enhancements to ?parameters monitored or inspected
" and the applicant' s justification for its adequacy, and determined that, with these enhance ments, the appli cant's struc tures mo nitori ng progra m is co nsiste nt wi th GALL , for thi s progra m eleme nt.
254 Enhan cement 3 Eleme nt: 4. Dete ction of Agin g Effects Enhan cement: The program wil l be enhan ced to require i nspection of sub merged wate r-contr ol str ucture s whe n dew atered , or on a frequen cy no t to exceed 10 years.The GALL Report i dentifies the foll owing recommend ations for the
?Detection of Agin g Effects" program element asso ciated wi th the enhance ment taken:
: 4. Detection of Aging Effects:  For each structure
/aging effect combination, th e inspectio n methods, inspec tion schedul e, and inspe ctor qualificatio ns are selec ted to ensure th at aging degradation w ill be d etected and quanti fied before there is loss of inten ded functions. Inspecti on methods, ins pection sche dule, and i nspector qualifica tions are to b e commensurate wi th industry codes, standards and guideli nes, and are to also consi der plant-specific operating exp erience. Al though not required, ACI 349.3R-96 and ANSI/A SCE 1 1-90 p rovi de an accept able basis for add ressin g detect ion o f aging effec ts. The plant-speci fic structures monitori ng program is to conta in sufficient deta il on detection to c onclude that this program attribu te is satisfied
.The pro ject tea m noted that th e 10 y ear in specti on freque ncy for submer ged por tions of wat er-control structures was not consistent w ith a new commitment identi fied in PBD-AMP-B.1.32 for the OCGS submer ged wa ter-con trol s tructur es agin g manageme nt progr am, wh ich st ates th at a baseline inspection of submerged water c ontrol structures will be performed prior to entering the period of exte nded operatio
: n. A second inspection will be performed 6 ye ars after this base line inspection and a third 8 years after the second. After ea ch inspecti on an eva luation w ill be performed to determine if the identified degradations w arrant more frequent insp ections or corrective a ctions. The app licant w as asked to ex plain w hy B.1.31 w as not consi stent with the new B.1.32 commit ment. In respo nse to the pr oject te am's i nquiry , the a ppli cant st ated th at both the program basis document, PBD-A MP-B.1.31, a nd the OCGS LRA will be revis ed to add an enhancement to th e OCGS structures mon itoring program, AM P B.1.31, to i nclude an inspection frequency for submerged w ater-control structu res that is co nsistent w ith the enha ncement described i n PBD-AM P-B.1.32, Secti on 2.4 Summary of Enhancements.
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the structure s monitoring program (AM P B.1.31) in the OCGS LRA to include an inspecti on frequency for submerged portions of water control structures that i s consistent w ith the new commitment identified i n PBD-AM P-B.1.32 for the sub merged water con trol structures pro gram. The new commitment states that a baselin e inspectio n of submerged wate r control structure s will be performed prior to en tering the perio d of extended operation. A second ins pection w ill be performed 6 years after this baseli ne inspecti on and a thi rd 8 years after the second. A fter each inspection an evalu ation wi ll be performed to determine if the identified de gradations w arrant more frequ ent in specti ons or correc tive actio ns. This is A udit Commitment 3.0.3.2.2 4-3.The applican t stated that the program basis docu ment PBD-AM P-B.1.31 for the structu res monitoring program (AM P B.1.31) w ill als o be revi sed to incl ude an ins pection frequency for submerged portions of water control structures that i s consistent w ith the new commitment identified i n PBD-AM P-B.1.32 for the sub merged water con trol structures pro gram. The new commitment states that a baselin e inspectio n of submerged wate r control structure s will be performed prior to en tering the perio d of extended operation. A second ins pection w ill be 255 performed 6 years after this baseli ne inspecti on and a thi rd 8 years after the second. A fter each inspection an evalu ation wi ll be performed to determine if the identified de gradations w arrant more frequent inspecti ons or correctiv e actions.
The project team
's assessment of AMP B.1.32 is document ed in Section 3.0.3.2.25 of this audit report. The project te am found the revi sed inspecti on frequency to be acceptable, because the applicant's baseline inspection schedule an d its commitment to evaluate the identi fied degradations prov ides assuran ce that the effects of aging w ill be a dequately mana ged for the perio d of ex tended opera tion. The project team rev iewed th e revised enhancement to
?detection of aging effects," and determined that, with this enhancem ent, the applicant's structur es monitoring prog ram is consi stent w ith GA LL, for t his p rogram el ement.Enhan cement 4 Eleme nt: 6. Acceptance Criteria Enhan cement: The existin g Oyster Creek Structure s Monito ring Program implementing pro cedure wi ll be rev ised to require that qualified indivi duals ev aluate ide ntified degradatio ns on exte rnal surfaces of mechanical c omponents. Acce ptance criteri a will be consiste nt with in dustry standa rds, design code s and guidel ines, incl uding ANSI or ASM E as appli cable. This is appli cable to Oy ster Creek and FRCT ex terior surfaces of mechan ical compone nts.Acceptance cri teria to establ ish if groundw ater is aggressiv e for concrete structures (pH <5.5, or chl orides > 500 ppm, or sulfates >
1500 ppm) w ill be c onsistent w ith industry standards, and NUREG-1801.
The GALL Report i dentifies the foll owing recommend ations for the
?acceptance cri teria" program element associ ated with the enhancemen t taken: 6. Acceptance Criteria
: For each structu re/aging effect combination, the acceptance criter ia are sele cted to ensur e that the ne ed for co rrecti ve ac tions wil l be i denti fied be fore loss o f inten ded fun ction s. Acc eptanc e crit eria a re to b e comme nsurat e wi th ind ustry codes, standards and guideli nes, and are to also consi der plant-spec ific operating experience. Although not required, ACI 34 9.3R-96 prov ides an acc eptable basi s for developi ng acceptance cri teria for concrete s tructural elemen ts, steel li ners, joints, coatings, and w aterproofing membranes. The plant-speci fic structures monitori ng program is to contain suf ficient detail on acceptance criter ia to conclude that this program attribute is satisfied.
The applican t provided the follow ing basis for the enhancements:
Inspection results are evaluated by qualified eng ineers based on acceptance criteria selected for each structure/aging effect to ensure that the need for corrective ac tions would b e identified before loss of inte nded functions.
Identified degradati on are eva luated by qualified in dividua ls based on industry codes, standards, and guidelines includin g ACI 318, ACI 349.3R, and A ISC. Deve lopment of 256 accept ance c riteri a cons iders plan t speci fic ope rating expe rienc e. Thes e crit eria a re directed at i dentification and eval uation of degradati ons that may affect the ability of the structure or compone nt to perform its in tended function.
ACI 349.3R-96 was used to devel op acceptance criteria for concre te structural el ements.The enhanced Oy ster Creek Structures Monitori ng Program requires that i dentified degradations be assessed and evaluated by quali fied engineering p ersonnel, con sidering the extent of the degr adation using design basis codes and standar ds that include ACI 318, A CI 349.3R, A ISC, a nd AS ME/A NSI. Th e progra m impl ementi ng proce dure provides sufficient detail s on acceptan ce criteria for stru ctures and ex terior surfaces of mechanical c omponents to ens ure that significa nt degradations a re identified and corrected before a l oss of an intend ed function.
The project team rev iewed th e enhancements to ?acceptance cri teria" and the applicant' s basis, and determined that, with these enhancem ents, the applicant's struct ures monitoring prog ram is consi stent w ith GA LL, for t his p rogram el ement.The project team finds th at, with the enhancements d escribed abo ve, the app licant's s tructures monitoring program w ill meet the intent of the pro gram described i n GALL AM P XI.S6.3.0.3.2.24.5 Operating Expe rience The applican t stated, in the OCGS LRA and PBD-AM P-B.1.31, that i t review s operating experience from both external and interna l (also referred to as in-hous e) sources. Ex ternal operating exp erience may include such things as INPO documents (e.g., SOE Rs, SERs, SE Ns, etc.), N RC do cuments (e.g., GL s, LER s, INs, etc.), Westinghouse docume nts (e.g., TBs, e tc.), General Elec tric documents (e.g., RCSILs, SILs, TILs, e tc.), and other do cuments (e.g., 10CFR Part 21 Reports , NERs, etc.). In ternal operati ng experienc e may incl ude such thi ngs as event investigations, trending reports, and lessons learned f rom in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction process.The applican t further stated that de monstration that th e effects of aging are effectively managed is achiev ed through objecti ve evi dence that the structures monitori ng program has been effective in id entifying aging effects of structures and structural components throu gh visual detection of degradi ng components, and plant mainten ance activ ities in place prior to the implementation of the structures moni toring program. The enha nced program wi ll provi de the same effectiveness for man aging the aging effects of structures, e xterior surfaces of mechanical compon ents, a nd comm oditi es add ed to t he sco pe of th e progra m.The app licant de scribed the fol lowing exam ples of operati ng exper ience to p rovide obj ective evidence that the structures monitoring program i s effective in a ssuring that inte nded function(s) will be maintaine d consistent with the CLB for the peri od of extended operation:
Con cret e Cr acki ng: Reactor Buil ding Exteri or - a revi ew of documenta tion going back to e arly 1997 indicates the identificatio n of cracking on the e xterior surfaces of the Reactor Bui lding. Notab le cracking has been observ ed on the w est wall with min or cracking on the east and south walls. The docume nted re view of the c ondit ion i ndica tes the cause to be from combi natio n of con crete 257 shrinkage and tempera ture changes. The re ason for the differences i n degree of cracking on the west w all as op posed to the e ast and south walls is attributed to the fact the w est wall does not have a scored exte rior wal l at the contro l joints unl ike the east and south wal ls. The condition h as been moni tored during M aintenance R ule structure mon itoring inspe ctions;documented, and dispositio ned not to be a structural c apability concern, but a concern ov er the life of the plan t because of rebar corrosion. Re pairs were completed on areas deemed to be of concern for long-term op eration of the pl ant. The condi tions contin ue to be moni tored and assessed through ro utine structure inspections. This examp le provi des objectiv e eviden ce that concre te crac king w ill be det ected, and th at engi neeri ng eva luati ons an d corre ctiv e acti ons ar e performed prior to the loss of inten ded function.
Reactor Building Interior - on the interior of the west wall above 95-foot elevation there is documented crack i n the proxi mity to the S tandby Li quid Control System. This c rack has been cosmetically repaired an d occurred in the score joi nt. No structural concerns w ere documented in the ins pection reports. This examp le provi des objectiv e eviden ce that cracking is detected, and that engine ering evalu ations and c orrective ac tions are performed prior to any loss of intended functio n.Drywel l Shield Wall - Cracking of the dryw ell shie ld wal l is docume nted in the NRC SEP re view of the plant und er Topic III-7B. The cracking is loca ted above elevatio n 95 foot on the cylindri cal portion of the shi eld wal l. The cracking is attributed to e levated te mperatures expe rienced ov er the life of the pl ant at this l ocation. The cra ck patterns have been mapped, and inspecte d repeatedly. There have been no chan ges in the con dition, w hich wo uld indi cate a structural concer n wa s prese nt or i mpendi ng. This examp le pro vide s objec tive evi dence that c oncret e crackin g wil l be d etecte d, and that u pdates to the program are mad e as n ecessa ry to ensure that any corre ctive acti ons are performed pri or to the loss of intended functi on.Spent Fuel Pool Supp ort Beams - In th e middle of 19 80's cracking arou nd the spent fuel pool area o f the rea ctor bu ildi ng was iden tified. Subs equentl y cra ck moni tors w ere in stall ed to monito r crack gr owth and a finite eleme nt ana lysi s was performe d to ev aluat e the d esign. Conclusions were drawn the cracking was predictable fr om the stresses f ound and further NDT determined the cracks not to be d eep. The concl usion draw n was there was no structural concer n, crac k change s wer e not d iscern able, and th at furthe r moni toring of the cr ack moni tors was n ot justi fied. B ut, con tinua l moni toring of the a reas i s wi thin t he sco pe of th e Struc ture Monitoring Program, and would be conducted on a periodic basis per the program. This example pro vides ob jective ev idence that a ny detected cracking wil l be eva luated, and that the progr am will be upda ted as nec essary to enhance m onitori ng such that any re quired correc tive actions are p erformed prior to the loss of intende d function.
Inta ke St ruct ure a nd C anal - In spec tion of th e in take cana l, p erfor med i n 20 01, i dent ifie d cra cks and fissures, v oids, holes , and local ized w ashout of coatings th at protect embankment sl opes from erosion. The degrad ations we re evalua ted and determi ned not to i mpact the intend ed function of the inta ke canal. These degradations are tracked for repair in accordance w ith the corrective a ction process.
This exampl e provide s objective evidenc e that any detected deficiencies will be evalu ated to determin e if correctiv e actions are necessary to prevent l oss of intended function, and that deficiencies are entered into the 10 CFR Part 50, Append ix B, Corrective Action proces s.Ventilatio n Tunnel - A recent inspe ction identi fied locali zed spal ling of the colu mns beneath the fan pad structur e in the ventilation tunnel. The spalling has been attributed to f ailure to install the en gineer ed con figurati on dur ing con structi on. Thi s cond ition is be ing mon itored on a mo re 258 frequent basis and corrective a ctions hav e been ide ntified. The M echanical/S tructural Group on site is acqui ring funding for the repai rs. This exa mple provi des objectiv e eviden ce that defic iencies ar e detect ed, evalua ted, an d track ed on an enh anced sc hedule to ensure co rrect ive action prior to loss of inten ded function.
Inspec tions condu cted i n 2002 , concl uded t hat de gradati ons di scusse d abov e hav e not b ecome worse and remain essenti ally the same as ide ntified in pre vious i nspections.
In addition minor crackin g, rust s tains , wat er stai ns, lo cali zed e xpos ed reb ars an d reba r corro sion, and d amage to siding we re observed.
The degradations were ev aluated and determined no t to have a n impact on the structural integrity of affected struc tures. AR #A2 050926 w as generated to trac k painting of the steel plat form near the top of t he ventilat ion stac k. The se example s provide ob jective evidence that deficienci es are eva luated and corrective a ctions taken pri or to loss of i ntended function.Additional searches of Oyste r Creek correctiv e action proc ess (CAP) data base identi fied 217 insta nces o f corrosi on cas es on exter ior su rfaces o f mechan ical compon ents a nd stru ctures. For 21 6 case s, engi neeri ng eva luati on con clude d that the ob serve d corro sion is li mited t o surface rust and do es not impact th e intended function of the compon ent or structure. F or the remain ing on e case , a uni strut su pport m ember for 3/8" d iamete r tubi ng, corr osion was more extensiv e but the uni tstrut was ev aluated and determined ca pable of performing its intended function. These ex amples prov ide objectiv e eviden ce that deficien cies are ente red into the corrective action process and that eng ineering evaluations are perfor med to determine what if any correcti ve action s need to be taken prior to l oss of intended function.The applicant concluded that the operat ing experience of the struct ures monitoring prog ram did not show a ny adve rse trend in p erformance. Problems identified w ould not cau se significant impact to the sa fe operation of the p lant, and ad equate correctiv e actions w ere taken to prev ent recurrence. There i s sufficient confidenc e that the impl ementation of Structu res Moni toring Program as described in the implem enting procedures (125.
6 and 2400-GMM-3900.52) will effectively man age aging effects through the peri od of extended operation.
The project team noted that the appl icant's di scussion of ope rating experi ence identi fied three conditions of concrete deg radation: cracking of the RB walls; cracking of t he drywell shield wall due to high t empera ture; a nd cra cking of t he spe nt fuel storage pool concre te sup port be ams. A fourth condition, degradation of the i ntake canal, is also addres sed in LRA Section B.1
.32, in the operating exp erience dis cussion for w ater-control structu res. For each of the first three conditions of concrete degradatio n, the project team asked the appli cant to provi de additio nal information descr ibing the degradation, t he assessment perf ormed, the acceptance criteria applied, future monitoring recommenda tions, and an y correctiv e action taken.
The project team also asked the applicant to describe the monitoring acti vities th at are, or w ill be c onducted unde r the structures moni toring program for each of the three regions. In its response, th e applica nt indicated that the request ed information is included in the Structur es monitoring prog ram basis document (PBD-A MP-B.1.31) n otebook, and w ould be av ailable for the staff's review during the second AMP audi t. The p roject t eam rev iew ed thi s inform ation durin g the se cond A MP a udit. The pro ject tea m condu cted a dditi onal revi ews o f these c ondit ions as par t of the AMR audi t. See Section 3.5.2 of this au dit report for docume ntation of the pro ject team's rev iew and assess ment.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d PBD-AMP-B.1.31, and interviewed the applicant's technical staf f to confirm that the plant-specific operating exp erience did not reveal any degradati on not bound ed by in dustry ex perience.
259 On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Structures Moni toring Program wil l ade quatel y mana ge the a ging effect s that are id entifi ed in the OC GS LRA for whi ch this AM P is credi ted.3.0.3.2.24.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he stru ctures monito ring pr ogram in OCGS LRA, Append ix A, Se ction A.1.31.
The applican t subsequently revised the UFSAR s upplement in it respon se to staff RAI 2.5.1.15-1 , which states that the stru ctures monitorin g program is an existing program that was developed to implement the requirements of 10 CFR 50.65 and is based on NU MAR C 93-0 1, ?Industry Guide line for M onitoring the E ffectiveness of Ma intenance at Nuc lear P ower Plan ts," Re visi on 2 a nd Regu latory Guide 1.160 , ?Monitori ng the Effectiveness of Maintenan ce at Nucle ar Power P lants," Rev ision 2.
The program includ es elements of the Masonry Wall Program and the RG 1.127 , Inspection o f W ater-Control Stru ctures Associa ted With Nuclear Power P lants aging management program. The program relie s on periodi c visual ins pect ion s to moni tor t he c ondi tion of st ruct ures and stru ctur al c ompo nent s, st ruct ural bol ting , component suppo rts, masonry bl ock walls, water-control structures, the Fi re Pond Dam, e xterior surfaces of mechanical components that are not cove red by othe r programs, and HVA C ducts, damper housin gs, and HVAC closure bol ting. The program reli es on procuremen t controls and installati on practices, d efined in pl ant procedures, to ensure that o nly appro ved lubri cants and proper torque are ap plie d to bo lting in sco pe of th e progra m.The scope of the pro gram will be enhanced to include structures and stru ctural componen ts that are not currentl y monitored, includin g Station Bla ckout System structu res and phase bus enclosure as semblies, and Meteorol ogical Tower Structures; but de termined to be in the scope of license rene wal, subme rged structures, compone nt supports not covered by other programs, the Fire Pon d Dam, exteri or surfaces of Oyster C reek and Forked Ri ver Combusti on Turbine mechanical c omponents that are not covered by other p rograms, includi ng exterior su rfaces of HVAC ducts, damper housi ngs, and closu re bol ting. Th e progra m wil l als o be e nhanc ed to require removal of piping and component insu lation on a sampling bas is to all ow vi sual inspection of insulated su rfaces. The program wi ll also be enhanced to require sampli ng and testin g of ground wate r eve ry 4 y ears to confirm that th e soi l env ironme nt is non-aggr essiv e to below-grade concrete structures.
Other program scope e nhancements in clude insp ection of piping and p iping componen ts associated with the Radio Communi cations sy stem located at the meteorological tower site.
The enhancements will be made prio r to entering the period of extended o peration.Inspection cri teria wi ll be enh anced to prov ide reasonab le assurance that change in material properties, crackin g, loss of material, loss of form, reduction or loss of isol ation function, reduction in anchor capac ity due l ocal degradati on, and loss of preload are adequately man aged so tha t the i ntende d functi ons of s tructur es and compon ents w ithin the sc ope of t he pro gram are maintained c onsistent w ith the current licensing b asis during the period of ex tended operati on.Inspection frequency is every four (4) years; e xcept for submerged p ortions of the w ater-control structures, whi ch wil l be insp ected when dewatered or on a frequency not to excee d ten (10) years. The pro gram contains prov isions for more frequent i nspections to ensure that obs erved conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.
260 In Section 3
.0.3.2.24.1 of this a udit report, the project team iden tified Audit C ommitment 3.0.3.2.24-3, to rev ise the in spection frequency for submerged portions of the water-con trol structures.
The pro ject tea m revi ewed the UF SAR S upple ment to confirm that i t prov ides an ade quate summary descrip tion of AMP B.1.31, incl uding the enha ncements. The projec t team also review ed the lic ense renew al commitment li st Table A.5, w hich wa s also rev ised in th e response to staff RAI 2.5.1.15-1, to confirm that all enhancements are identified.
*In its letter d ated March 30, 2006 (M L060950408), th e applica nt committed t the following: E nhance the stru ctures monitorin g program (B.1.31) to require visual inspection of external su rfaces of mechanical steel componen ts that are not c overed by other programs.  (Audi t Commitment 3.0.3.2.24
-2)*Add the ex ception ide ntified in i ts reconcili ation document for the structures moni toring program, which states that the pro gram takes exceptio n to the insp ection frequency of at least once p er refueling cyc le specified in NURE G-1801, XI.M36. ( Audit Commitment 3.0.3.2.24-1)
In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the structure s monitoring program (AM P B.1.31) in the OCGS LRA to include an inspecti on frequency for submerged portions of water control structures that i s consistent w ith the new commitment identified in PBD-AMP-B.1.32 for the subm erged water control struct ures program.
(Audit Commitment 3.0.3.2.24-3
)The applican t's licens e renewal commitment list and UFSAR update are to b e revised to reflect these new commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.31. Contingent up on the inclusi on of audit commitmen ts 3.0.3.2.24-1 throu gh 3, the project tea m found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).3.0.3.2.24.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. Also, the project team ha s review ed the enhan cements and determined that the implementati on of the enhanc ements prior to th e period of ex tended operation w ould result in the ex isting AM P being consi stent with the GALL Repo rt AMP to which it was co mpared. The project te am also rev iewed th e UFSAR S upplement for this AMP an d, contingent upon the inclusi on of audit commitmen ts 3.0.3.2.24-1 to 3
.0.3.2.24-3, the pro ject team found that it p rovides a n adequate summary description of the program, as required by 10 CFR 54.21 (d).3.0.3.2.25 RG 1.127, Inspecti on of Water-Control Structures Assoc iated wi th Nuclear P ower Plants (OCGS AM P B.1.32)In OCGS LRA, Ap pendix B , Section B.1
.32, the appli cant stated that OC GS AMP B.1.32,"RG 1.127, Inspecti on of Water-Control Structures Assoc iated wi th Nuclear P ower Pla nts," is an 261 existing pl ant program that is consistent w ith GALL AM P XI.S7, "RG 1.127, In spection of Water-control Structures Associa ted with Nuclear Pow er Plants," w ith enhancemen ts.3.0.3.2.25.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program is p art of the Structures M onitoring Program (OCGS AMP B.1.31). It is based on the guidance prov ided in R G 1.127 and ACI 349.3R a nd wil l provid e for periodic inspection of the Intake Structure an d Canal (U HS), the Fire Pond D am, and the Di lution structu re. The program wi ll be use d to manage loss of material, cracking, an d change in mate rial properti es for concrete compo nents, loss o f material and ch ange i n mater ial p roperti es for w ooden compon ents, a nd lo ss of mat erial , and l oss of for m for the dam, and the canal slop es.The applican t also stated that inspecti on frequency is every four (4) years; ex cept for submerged portions of the stru ctures, whi ch wil l be insp ected when the structures are de-watered, or on a frequency not to ex ceed 10 y ears. The program w ill be e nhanced, as n oted below , to provid e assurance that w ater-control structu res aging effects are adequatel y managed duri ng the period of extended op eration.3.0.3.2.25.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.32 is cons istent wi th GALL AMP XI.S7, w ith enhancemen ts.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for OCGS AMP B.1.32, incl uding PBD-A MP-B.1.32 " RG 1.12 7, Insp ectio n of Water-Con trol S tructur es Ass ociat ed w ith Nuclear Pow er Plants," Re
: v. 0, wh ich provi des an assess ment of the AMP elements' cons istency with GALL AMP XI.S7.
Specificall y, the project team review ed the program ele ments (see Section 3.0.2.1 of this audit and revie w report) con tained in OCGS AMP B
.1.32 and asso ciated bases documents to determine c onsistency with GALL AMP XI.S7.
During the first on-s ite AMP audit on Octo ber 3-7, 2005, th e project team requeste d addition al informat ion a bout A MP B.1.32, and th e appl icant prov ided writ ten res ponse s. Thes e are disc usse d belo w.The project team noted that the Program De scription for AM P B.1.32 stated that the insp ection frequency is ev ery four (4) ye ars, except for su bmerged portions o f the structures, wh ich wi ll be inspected w hen the structures are dewa tered, or on a frequency not to ex ceed 10 y ears. GALL AMP XI.S7 i dentifies an i nspection frequency of 5 years. The project team asked th e applica nt to explai n why the 10 yea r inspection frequency is no t identified a s an excep tion to the GAL L AMP, and to provide the technical basis for concluding that a 10 year inspection f requency is sufficient for submerged porti ons of structures.
In response, the applicant s tated: The 5 y ear in specti on freque ncy i denti fied i n GALL AMP XI.S7 i s base d on R egulat ory Guide 1.127, In spection of Water-Control Structures Associated with Nuc lear Pow er Plants. Oys ter Creek is not committed to insp ect underwa ter structures on a frequency of 5 years as explain ed below. The Oyster Cre ek RG 1.127, Inspecti on of Water Control Structures Associ ated with Nuclear Po wer Plan ts was rev iewed b y NRC a nd approve d
262 the pro gram. Fo r this reaso n the 1 0 yea r frequen cy w as not iden tified as an exce ption to the GALL AMP.
The Oyster Creek ori ginal design did not commit to the requirements of RG 1.127, Inspection of Water-Control Structure s Associated with Nu clear Pow er Plants. H owever in response to NUREG-0822, Integrated Plant S afety Assessment S ystematic Ev aluation Program (SEP) Topic III-3.C, Oyster Cree k evaluated water control structure consi stent with the recommendations o f RG 1.127, Inspecti on of Water-Control Structures Associ ated w ith Nu clear Pow er Pla nts, an d pres ented to the NRC th e eva luati on res ults and the propos ed Oyster Cree k RG. 1.127, Inspecti on of Water-Control Structures Associated w ith Nuclea r Power P lants surve illance program. In a letter dated June 24
, 1982, the NRC provided the results o f its review and comments on the proposed surve illa nce pr ogram. Th is le tter an d NUR EG-138 2, Safet y Ev aluat ion R eport r elate d to the full-term operati ng license for Oy ster Creek Nucle ar Generating Stati on formed the basis for the ex isting Oyster C reek RG 1.127, Inspe ction of Water-Control Structures Associ ated w ith Nu clear Pow er Pla nts agi ng manage ment pr ogram.The existin g Oyster Creek RG 1.12 7, Inspection of W ater-Control Stru ctures Associa ted with Nuc lear Pow er Plants agin g management program did n ot commit to the i nspection frequency of 5 yea rs specified i n Regulatory Guide 1.127 revision 1. Inspectio n of water control structures is incl uded in the Oyster Creek Struc tures Moni toring Program (B.1.31); excep t for the Fire Pon d Dam, whi ch is insp ected under the New Jers ey Dam Safe ty S tand ards , N.J.A.C 7:20-1.1 et s eq.The Oyster Creek Stru ctures Moni toring Program (B.1.31) re quires inspecti on of accessible water control structures on a 4 year frequency consistent w ith the frequency for implementing the requirements of the 10 CFR Part 50.6 5, Mainte nance Rule. The program considers u nderwater stru ctures inacces sible and requires insp ection only when they become acces sibl e. For lice nse re newa l, w e enha nced t he pro gram to re quire inspection of underwater stru ctures before enteri ng the period o f extended ope ration, and on a frequency of 10 years duri ng the period o f extended ope ration. After each inspection, the identified degradations w ill be e valuated to determine i f more frequent inspections are warran ted to ensure th at the intende d function of the w ater control structures is no t adversely impacted. The 1 0 year frequency is selecte d based on plant operating exp erience w ith the Intake Stru cture and Can al. This ope rating experi ence identified co ncrete degradation s, howev er none w ere significant e nough to impact th e intended functio n of the structure.
The project team als o noted that LR A Appendi x B, Secti on B.0.5 ide ntifies AM P B.1.32 as a n existing pro gram. The Program Descrip tion stated tha t this AM P is part of the Structures Monitori ng Program. The scope o f the six enh ancements lis ted for AMP B
.1.32 encompass many of the el ements that normall y woul d be part of an e xisting in spection program for water-control structu res. Consequently, the proje ct team asked the applicant to (a) specifically describe the scope of the curr ently existing program, including t he structures and compon ents in the scope of the e xisting program; the aging effects that are moni tored; the insp ection methods employed; a nd the inspe ction frequency; a nd (b) specifica lly des cribe the sco pe of AMP B
.1.32, incl uding the str ucture s and compon ents i n the s cope o f AMP B.1.32 , the a ging effect s that are monito red, th e inspect ion meth ods empl oyed, and t he inspec tion fr equenc y.In response, the applicant s tated:
263 (a) RG 1.127, Insp ection of Water-Control Structures i s implemented through the Stru ctur es M oni tori ng Pr ogram , B.1.31. The scop e of t he p rogra m in clu des the i ntake structure and can al, and the dilution structure. Componen ts monitored i nclude earthe n control structures (intake canal, embankment) and rein forced concrete structure
: s. The aging effects monitored in clude cracks, si nkholes, and emb ankment collapse of the intake canal embankment. Concrete structures are moni tored for cracks, spall ing and scaling, rebar e xposure, rust stain, structural settlement, and rebar corrosion. The method of inspection is visual inspection. Inspect ion frequency of acce ssible areas is every 4 years. Inacc essible are as of the structures a re inspected whenev er an opportunity occurs.(b) The scope of the enha nced program includes str uctures and components t hat are in scope of the e xist ing pro gram. In addit ion, t he sco pe is enhan ced to incl ude th e fire pond dam ins pection, ins pection of submerged components of the i ntake structure and cana l, th e di luti on s truc ture , the fire pon d da m, an d the eart hen dike betw een the i ntake and the disc harge canal. The aging effects monitored in clude cracks, si nkholes, and embankme nt col lapse of the i ntake ca nal e mbankmen t. Con crete s tructur es are monitored for cracks, spa lling and scaling, rebar e xposure, rust stain, structural settlement, and re bar corrosion.
Enhancement to the aging effects inclu de the addi tion of monitoring concrete structures for change i n material pro perties due to leaching of calcium hydroxide, inspection of wooden components f or loss of material and chang e in material prope rties, and lo ss of material du e to corrosion for steel compone nts. The method of inspection is visual inspection. Inspect ion frequency of acce ssible areas is every 4 years. Inacc essible are as are inspe cted whene ver an opp ortunity occ urs.In an update to its response , the appli cant stated:
The program wil l be enhan ced to require p erforming a baselin e inspectio n of submerged water control structures prior to entering the p eriod of exten ded operation. A second inspe ction wil l be p erformed 6 yea rs after this b aseli ne in specti on and a thi rd 8 y ears after the second.
After each inspection an evaluation will be performed to deter mine if the identified degradat ions warrant more freq uent inspections or corrective actions.
This constitutes a new enhancement not previously identified in the LRA.
The project team also noted that the first enhanc ement to B.1.32 identif ied that the program will provide for moni toring of trash racks. In L RA Table 3.5.2
.1.11, the Structure s Monito ring Program is credite d for aging management of trash rac ks. The project team asked the applica nt to explain t his appar ent disc repanc y.In response, the applicant s tated:?The trash racks are no t identified i n NRC Regul atory Guide 1.127, Inspectio n or Water-Control Structures Associ ated with Nuclear Po wer Plan ts, as component of the water control structures. The CL B does not cre dit the trash ra cks for the safety-related intended functio n of the Ultimate Heat Sink (UH S). Howe ver, we recognize tha t the trash racks pr ovid e a fil ter funct ion th at prev ents d ebris from pote ntial ly c logging ESW pumps.
For this reaso n, we in cluded the tra sh racks in the scope of the Rul e and credit the Structures Monitoring Prog ram for manag ing their aging. Also as stated in Appendix B.1.32, RG 1.127, Inspection or Water-Control Structures Associ ated with Nuclear Po wer Plant s, the program i s impl emented through the St ructure s Mo nitori ng Progra m B.1.3 1.
264 Thus the aging e ffects of th e trash racks a re moni tored b y the same p rogram us ed to monito r wat er con trol s tructur es."Follow ing the first AM P on-site au dit in Octobe r 2005, the app licant prepa red PBD-AM P- B.1.32, which p rovides a n assessment of cons istency be tween the program elements of AM P B.1.32 and the program el ements of GALL AM P XI.S7. The appl icant incorp orated its resp onses to the project team's audit q uestions into PBD-AMP- B.1.32. Consequent ly, the project team's assess ment of A MP B.1.32 w as sub stanti ally based on rev iew of PBD-AMP-B.1.32 , in a dditi on to the LR A. PB D-AM P-B.1.32 id entifi ed an exce ption and o ne add ition al en hance ment, bo th relate d to th e ins pecti on freque ncy for submer ged stru ctures, that w ere no t iden tified in th e LRA. These are discu ssed below , under exce ptions and e nhancements.
The project team rev iewed th ose portions of the RG 1.127, Insp ection of Water-Control Structures Associ ated with Nuclear Po wer program for w hich the app licant cla ims consisten cy with GALL AMP XI.S7 a nd found that they are consiste nt with th e GALL Report AMP. The project team found that the applica nt's RG 1.127, Inspection of Water-Control Structure s Associated w ith Nuclea r Power pro gram conforms to the recommende d GALL AM P XI.S7,"RG 1.127, Inspecti on of Water-Control Structures Assoc iated wi th Nuclear P ower," w ith the excep tion and en hanc emen ts as desc ribe d belo w.The project team noted that the appl icant did not state an ex ception to the GALL program in th e OCGS LR A as s tated i n OCGS PBD-A MP-B.1.32. 3.0.3.2.25.3 Exce ption s to th e GALL Repor t The followi ng exception is stated i n OCGS PBD-AM P-B.1.32 to the GALL Report program elements: Eleme nt: 4. Dete ction of Agin g Effects Exception: The Oyster Creek RG 1
.127, Inspection of Water Control Structures Associ ated With Nuclear Pow er Plants takes e xception to the inspection freq uency specified in NUREG-1801 XI.S7, RG 1.127, Inspe ction of Water-Contr ol Str ucture s Asso ciate d wi th Nucle ar Pow er Pla nts. Thi s exc eptio n is a ppli cable only to submerged str uctures. This is a new exception not previously identified in the LRA.
The GALL Report i ncludes the following re commendations for the
?detection of aging effects" program e lement: 4. Det ectio n of Ag ing E ffects: RG 1.127 desc ribes period ic inspecti ons, to be performed at least once every fiv e years.As justification for the excepti on, the appl icant stated:
Durin g the NR C agin g manageme nt progr am (AM P) rev iew audi t (Octob er 23-2 7, 200 5), the staff indicated th at the 10-ye ar inspectio n frequency is n ot consistent w ith the 5-y ear frequency specified in NURE G-1801 Program XI.S7, RG 1.1 27, Inspection of Water-Control Structures Associ ated with Nuclear Po wer Plan ts and requested th e technical b asis for conclu ding a 10 y ear inspecti on frequency is sufficient for submerged 265 portions of w ater control struc tures. Oyster C reek indicated that the revi ew of the CL B concluded th at the exi sting Oyster Cree k RG 1.127, Inspecti on of Water Control Structu res As socia ted With Nuc lear P ower Plan ts progr am is b ased o n SEP Topic III-3.C commitments, whi ch do not add ress submerged structure
: s. The 10-yea r inspection frequency was determined sufficien t, based on op erating experi ence, to detect significant age related degradat ions before an intended func tion of the water control struc tures is adversely impacted. Ad ditionall y Oyster Cre ek will perform a baselin e inspectio n of underwater structures and evaluate identified age related degr adations to establish if there i s a ne ed for mo re freque nt ins pecti on to p rovi de ass urance that a ging effect s are adequately man aged. The staff noted that the present exi sting operating ex perience related to und erwater structure is not sufficien t for the staff to conclude that the 10-ye ar inspection frequency is ade quate.As a result of the staff's concern, Oyster Creek agreed to perform a b aseline i nspection of submerged water c ontrol structures prior to enteri ng the period o f extended peri od of operat ion. A seco nd in specti on w ill be per formed 6 years after th e base line insp ectio n. A third ins pection w ill be p erformed 8 years a fter the second in spection. Fo llowi ng each inspection, the identified degradations w ill be e valuated to determine i f more frequent ins pect ion s are wa rran ted o r the re i s a n eed for co rrec tiv e ac tion s to ensu re th at ag e related degradati ons are adequatel y managed. This constitutes a new ex ception  not previously identified in the LRA.
In its lette r dated Marc h 30, 2 006 (M L0609 50408), the a ppli cant co mmitted to rev ise th e OCGS LRA to add the exception to the inspection freq uency specified in NUREG-1801 XI.S7 sta ted in program basis docu ment PBD-AM P-B.1.32. The ap plicant has committed to a b aseline inspection prior to enteri ng the period o f extended peri od of operation, a second in spection 6 years after the b aseline i nspection, an d a third i nspection 8 years after the se cond inspec tion, and has committed to evalu ate the iden tified degradation s to determine if more frequent inspections are warranted. The proj ect team determined th at the exception was acceptable because the a pplicant's baseline inspection schedule for su bmerged water co ntrol structures and its commitment to evaluate the ident ified degradations ensur es that the eff ects of aging will be adequately managed for the ex tended period of operation. The project team iden tified the applicant' s revised commitment to insp ect submerged w ater control struc tures as A udit Commitment 3.0.3.2.25-1.
3.0.3.2.25.4 Enhan cements The applicant stated, in the OCG S LRA and/or in PBD-AMP-B.1.32, that the enhancemen ts in meeting the GALL R eport program elements are as follow s: (1) The program wi ll provi de for monitoring of sub merged structural compo nents and trash racks.
(2) Parameters moni tored wil l be enhan ced to incl ude change in material prop erties, due to l each ing o f cal ciu m hy drox ide , and aggre ssi ve c hemi cal atta ck.(3) Add the re quireme nt to i nspect steel compon ents for loss o f materia l, due to corrosion.
(4) Add the requi rement to inspec t wooden piles and sheeting for loss of material and change in mate rial proper ties.\
266 (5) The progra m will provide for periodic inspection of components subm erged in salt water (intake structure and can al, diluti on structure) and in the w ater of the fire pond dam.(6) The program wi ll be enh anced to inc lude perio dic inspec tion of the fire pon d dam for loss o f materia l and loss of form.(7) The program wi ll be enh anced to require performing a baseli ne inspecti on of submerge d wa ter con trol s tructur es pri or to e nterin g the pe riod o f exten ded op eratio n. A second insp ection wi ll be performed 6 years after thi s baseline inspection and a third 8 years after th e seco nd. Afte r each insp ectio n an e valu ation wil l be p erformed to determ ine if th e identif ied degr adation s warrant more f reque nt inspec tions or correc tive actio ns. [Thi s cons titute s a ne w en hance ment no t prev iousl y id entifi ed in the LR A.]The applican t identified th e GALL program ele ments affected by the enhancements to be 1.Scope of Program; 3. Pa rameters Moni tored or Inspected
; and 4. Detec tion of Aging Effects.
The pro ject tea m noted that ?enhan cement" (7) is not an enhan cement to meet the GAL L Repo rt recommendations. The applican t's new commitment for inspecti on of submerged wa ter control structures, whi le a significa nt improvement over the ori ginal LRA c ommitment, is stil l an exception to the GALL Report recomm endations. The project team evaluated this
?enhancement" as an excepti on, in 3.0.3.2.2 5.3 of this audi t report. Since
?enhancement" 7 is the on ly e nhanc ement th at affects program elemen t 4, ?detection of aging effects," there was no need for the project team to revie w any enhancements for program e lement 4.Eleme nt: 1. Scope of Program Enhan cement: The O CGS AM P w ill be e nhan ced to i ncl ude the fo llo wi ng: (1) The program wi ll provi de for monitoring of sub merged structural components and trash racks.
(5) The program w ill provi de for p eriod ic in specti on of co mponen ts submerged in sal t water (in take structure and ca nal, dilu tion structu re) and in th e wa ter of th e fire p ond da m.(6) The program wi ll be enh anced to inc lude perio dic inspec tion of the fire pond dam for l oss of ma terial and l oss of for m.The GALL Report i ncludes the following re commendations for the
?scope of program" program elemen t rela ted to this e nhanc ement: 1. Scope of P rogram: RG 1.1 27 app lies to w ater-co ntrol structu res ass ociat ed w ith emergency cool ing water sy stems or flood protec tion of nuclea r power pl ants. The water-control structures incl uded in the RG 1.127 program are concrete structure s;embankment structures; spi llway structures and o utlet works; res ervoirs; coo ling water channels an d canals, an d intake and d ischarge structures; and safety and performance instrumentation.
The appli cant provi ded it s bas is fo r con clud ing t hat, with th e iden tif ied en hanc emen ts, AMP B.1.32 wi ll be con sistent wi th GALL program ele ment 1. Scope o f Program. The applica nt stated 267 that the Oyster R G 1.127, Inspecti on of Water-Control Structures Assoc iated wi th Nuclear Power Pl ants applie s to water c ontrol structures associated w ith the emergency cooling w ater system. Water control structures in scope of l icense renew al are inc luded in the scope of B.1.32. These struc tures are the i ntake structure and canal (ulti mate heat sink), the dilution structure, and the intake structure trash racks. Structural components and commodities of the structures that are monitored unde r the exis ting program includ e reinforced conc rete members, and earthen water control struct ures (intake canal, emban kments. The enha nced program will include the fire pond dam a nd its va rious componen ts, includi ng the spill way, an d embankments.
The applican t further indicated that there are n o water con trol structures tha t are credited for flood protection, and th ere are no safety and perf ormance instrument ation such as seismic instrumentation, horizontal and verti cal movement instrumentation, uplift instrumenta tion, and other instrumentati on incorporate d in the de sign of Oyster Cree k water control structures.
The app lica nt stat ed tha t the i mpleme nting d ocumen ts for thi s aging manageme nt progr am are listed in PBD-AM P- B.1.32, Table 5.1. The commitment numbers under w hich these implementing do cuments are bei ng revised a re also li sted in Table 5.1.The project team compare d the program scope of AMP B.1.32 , includi ng enhancements, agai nst the pro gram sco pe of GAL L Repo rt AM P XI.S7 , and fo und th em to be consi stent.On this basis , the project team found the enhancemen ts to the
?scope of program" elemen t acceptable s ince wh en enhancements are implemente d, OCGS AMP B.1.32, "RG 1.127
, Inspec tion o f Water-Control Struct ures A ssoci ated w ith Nu clear Pow er," w ill be con sisten t wi th GALL AMP XI.S7 and w ill prov ide additi onal assuran ce that the effects of aging w ill be adequately man aged.Eleme nt: 3. Parameters M onitored or Ins pected Enhan cement: The O CGS AM P w ill be e nhan ced to i ncl ude the fo llo wi ng: (2) Parameters moni tored for concrete w ill be e nhanced to i nclude change in materi al propertie s, due to lea ching of calciu m hyd rox ide , and aggre ssi ve c hemi cal atta ck.(3) Parameters moni tored wil l includ e inspectio n of steel comp onen ts for los s of ma teri al d ue to corr osi on a nd p itti ng.(4) Parameters moni tored wil l includ e inspectio n of wooden piles and sheeting for l oss of material a nd change in material prope rties.The GALL Report i ncludes the following re commendations for the
?parameters monitored or inspe cted" p rogram el ement r elate d to th is en hance ment: 3. Parameters Mon itored or Inspe cted: RG 1.127 ide ntifies the parame ters to be monitored and inspected for w ater-control structu res. The parameters v ary depend ing on the parti cular structu re. Par ameters to be monito red an d ins pected for conc rete structures incl ude cracking, move ments (e.g., settlement, he aving, deflecti on), conditio ns at junctions w ith abutments an d embankments, erosio n, cavitati on, seepage, and leakage. Parameters to be monitored and inspecte d for earthen embankment s tructures include settlement, depress ions, sink holes, slope stability (e.g., irregularities in 268 alignment and v ariances from origin ally co nstructed slope s), seepage, proper functioning of drainage syste ms, and degradatio n of slope prote ction features. Furth er details o f parameters to be mo nitored and inspected for thes e and other w ater-control structu res are specified i n Section C
.2 of RG 1.127.
The appli cant provi ded it s bas is fo r con clud ing t hat, with th e iden tif ied en hanc emen ts, AMP B.1.32 wi ll be con sistent wi th GALL program ele ment 1. Scope o f Program. The applica nt stated that pa rameter s moni tored o r insp ected are co nsiste nt wi th the guidan ce spe cified in Se ction C.2 of RG 1.127. For re inforced concrete components, it i ncludes lo ss of material du e to vario us aging me chani sms, in cludi ng erosi on and cavi tation , cracki ng due to va rious aging me chani sms incl uding settle ment, an d chan ge in ma terial prope rties due to leac hing o f calci um hyd roxi de. Steel components associated with earthen water cont rol structures (intak e canal, embankments), fire pond d am, and trash racks a re monitored for lo ss of material du e to pitting and corr osi on. Wood en c ompo nent s are moni tore d or ins pect ed fo r lo ss o f mate rial and cha nge in mate rial proper ties. Slop es for ea rthen w ater co ntrol structu res at juncti on w ith ab utments are monito red for l oss of ma terial and l oss of for m (cracks , sinkh oles, erosi on, an d slo pe in stabi lity).The applican t further stated that pa rameters monitored a nd inspected for earthen wa ter control structures include settlem ent, depressions, sink holes, slope stability (e.g., irregular ities in align ment an d var iance s from ori ginal ly c onstru cted sl opes), and l oss of s lope protec tion l iner. These parameters are considered l oss of material a nd loss of form. Earthe n water con trol structures have no drainage s ystems, and thu s monitoring of drai nage systems i s not appli cable.The project team compare d the parameters mo nitored or i nspected in AMP B.1.3 2, includi ng enhancements, agai nst the parameters monitored or i nspected in GALL Report AM P XI.S7, and found th em to be consi stent.On this basis , the project team found the enhancemen ts to the
?parameters monitored or inspe cted" p rogram el ement a ccepta ble s ince when enhan cements are i mpleme nted, OC GS AMP B.1.3 2, "RG 1.127, Inspe ction of Water-Control Structures A ssociated w ith Nuclea r Power," w ill be c onsistent w ith GALL AM P XI.S7 and w ill prov ide additi onal assuran ce that the effects of aging will be adequately managed.3.0.3.2.25.5 Operating Expe rience The applican t stated, in the OCGS LRA, that the operating hi story of the in take structure and canal, and th e dilutio n structure ind icates that the structures are no t experien cing significant degradation. Lo calized cracking and spal ling of the Intake structu re concrete w as identified and repaired in mid 1980's. Recent in spection (200
: 2) of the intake structu re and the di lution structu re note d some concre te spa llin g and cr acking. How ever, these aging e ffects w ere determined in significant and have no a dverse impa ct on the inte nded functions o f the structures.
Inspection of the intake canal, p erformed in 2001, i dentified some c racks and fissures, v oids, holes, and l ocalize d washout of coatings that protec t embankment slopes from erosion. The degra dati ons wer e ev alu ated and dete rmin ed n ot to imp act t he i nten ded funct ion of th e in take canal (UHS
). The degradations are inspected periodical ly and e valuated to ensure that th e intended functio n of the intake can al is not adversely impacted. The a pplicant's operating experience review concluded that the program is effective for managing aging effects of water-control structures.
During the first AM P on-site au dit on October 3
-7, 2005, the pro ject team noted tha t the operating exp erience dis cussion in the LRA for AM P B.1.32 ind icated that OCGS has experience d (1) degradation of the intake structure concrete that re quired repair i n the 1980s; 269 (2) cracking and spa lling of intake s tructure and di lution structu re concrete id entified in 2 002;and (3) degrad ation of the i ntake ca nal i denti fied i n 2001. The tw o rece nt find ings w ere dispositioned as acceptable, because the intended functions had not been impacted.
For all three occurrences , the project team a sked the appli cant to provi de the plan t documentation that descri bes th e degra datio n, the assess ment pe rformed, t he acc eptanc e crit eria a ppli ed, futu re monitoring recommenda tions, and an y correctiv e action taken.
In response, the applicant s tated that the reques ted documentatio n is incl uded in Oy ster Creek RG 1.12 7, ?Inspection of Water-Control Structure s Associated with Nu clear Pow er Plants" program basis docu ment (PBD-AM P-B.1.32) Notebo ok and wil l be ava ilable for the staff's review durin g the AM P audi t wee k (secon d AM P on-s ite au dit, J anuary 23-27 , 2006).During the seco nd AMP on-site audi t on January 23-27, 2006, th e project team rev iewed th e discussion of operating expe rience in PBD-AMP-B.1.32.The applican t stated, in PB D-AMP-B.1.3 2, that its rev iew of ind ustry operati ng experienc e noted that degradations have occurre d in wa ter control structu res associated with nu clear pow er plants. The de gradations w ere detected tho ugh the RG 1.127, Inspection of Water Control Structures Associ ated With Nuclear Pow er Plants agin g management program and corre cted bef ore a loss o f an inten ded f unct ion. The pl ant s peci fic oper atin g exp erie nce r eview al so sh ows that degradations have occurre d and hav e been ide ntified through the Structures Mo nitoring aging management program w hich imple ments Oyster Cree k RG 1.127, Inspecti on of Water Control Structu res Associate d With Nuclear Powe r Plants recommen dations. The d egradations were general ly minor; b ut some required c orrective ac tions to ensu re that the inte nded function is maintain ed.The applican t stated that it review s operating ex perience from both external a nd internal (also referred to as in-ho use) sources. E xternal op erating experi ence may i nclude such things as INPO documents (e.g., SOE Rs, SERs, SE Ns, etc.), NRC d ocuments (e.g., GLs, LER s, INs, etc.), Ge neral Elec tric d ocumen ts (e.g., RCSIL s, SILs , TILs, e tc.), an d othe r docu ments (e.g., 10CFR Part 2 1 Reports, NER s, etc.). Internal operating exp erience may include such things as event investigations, trending re ports, and lessons learned fr om in-house events as captured in program notebooks, self-asse ssments, and in the 10 CFR Part 50, Appe ndix B corrective a ction process.The applican t described th e followi ng examples o f operating experi ence, as objecti ve evi dence that th e RG 1.127, In specti on of Water-Co ntrol Structu res As socia ted w ith Nu clear Pow er Pla nts program is effective i n assuring that i ntended function(s) will be maintain ed consisten t with the CLB for the peri od of extended operation:
: 1. In 198 5, GP UN l aunc hed an i nve stig atio n to eva lua te th e str uctu ral cond iti on o f the inta ke structure. Cracking attri buted to freeze-th aw and s ome corrosion o f rebar were ob served on the operating deck und erside. In the 1986 refueling ou tage, GPUN dew atered the north bay of the intake structure, cl eaned up the marine growth on the concrete surface under the water li ne and performed addi tiona l ins pecti ons, i nclud ing taki ng core-bores for compr essiv e stren gth testi ng. Only a few areas wi th minor degradati ons were foun d under the w ater line.
Degraded areas were repai red before the north bay wa s returned to se rvice. The re paired areas were insp ected again durin g the 19 94 refue ling o utage. A few areas of re-oc currin g rebar corros ion w ere observed an d repaired.
270 Similar de gradations w ere observed on the opera ting deck of the south bay. The degrad ations were repai red during the 1 988, 1989 refuel ing outage and re-i nspected duri ng the 1994 refueli ng outage. The inspe ction results of the south bay during the 199 4 refueling outage sh owed that the structure is in good condi tion. Inspecti ons performed in 2 002 noted l ocal spall ing and cracking of concrete in addition to some rusted su pport members. The i nspector concl uded that the ov erall condi tion o f the in take stru cture i s struc turall y sou nd and accep table to per form its intended functio
: n. The 2002 i nspection al so identified minor cracks on th e lower deck wall s of the diluti on structure. The c racks were dete rmined not to h ave an ad verse impac t on the intended functio n of the structure.
Inspection of the intake canal, p erformed in 2001, i dentified some c racks and fissures, v oids, holes, and l ocalize d washout of coatings that protec t embankment slopes from erosion. The degra dati ons wer e ev alu ated and dete rmin ed n ot to imp act t he i nten ded funct ion of th e in take canal (ulti mate he at sin k). The d egradat ions are in specte d peri odica lly and e valu ated to ensur e that the intend ed function of the i ntake canal i s not adve rsely impa cted.2. The 1992 "Re gular Inspection" of the fire pond da m identified tw o areas of the do wnstream sheeting that w ere bulging outw ard from the dam. To stabi lize the situation, a pproximatel y 130 cubic yard s of riprap w as placed i n the scour are as and alo ng the entire do wnstream le ngth of the sp illw ay. I nspect ions performed in 20 01 foun d no a reas o f erosio n or st ructura l ins tabil ity. The inspection concluded that repairs made in 1992 s eemed to hav e stabili zed the sp illwa y and no additio nal movemen t was noted during the in spection.The 2004 "Informal Insp ection" of the fire p ond dam noted signs of erosion downstream of the right spillway wing wall, whi ch has exposed the lower part of the bulkhead. Th is could comprom ise th e inte grity of the sp illw ay w ing w all a nd furth er trigge red ero sion of the a rea. Howeve r the dam and a ppurtenant structure s are in a safe condition.
: 3. CAP 0036 0630 was issued in August 2005 as a result of low level in the north structure. The cause of the low water le vel w as attributed to debris accu mulation on the trash racks. Al so the trash racks colla psed due to e xcessiv e load of the d ebris and hy drostatic pressu re. Inspection and eva lua tion of th e fai lure mech ani sm of t he tr ash rack conc lud ed th at th e fai lure is n ot ag e degra dati on re late d. In stea d, th e fai lure wa s du e to a de sign featu re of the t rash rack s purp osel y pr ovi ded to fai l un der e xce ssi ve l oad to av oid cata stro phi c fai lure of th e in take structure.
The project team rev iewed s everal ap plicant's reports (see Attach ment 5) documenti ng cited degradation occu rrences and the ir resolutio n, and concl uded that appro priate courses of action were taken.
The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d PBD-AMP-B.1.32, and interviewed the applicant's technical staf f to confirm that the plant-specific operating exp erience did not reveal any degradati on not bound ed by in dustry ex perience.On the basis o f its review of the above industry an d plant-speci fic operating ex perience and discussions with the applican t's technical staff, the project team determin ed that the app licant's RG 1.12 7, Insp ectio n of Water-Con trol S tructur es Ass ociat ed w ith Nu clear Pow er Pla nts program will adequately manage the aging effects that are identified i n the OCGS LRA for which this AMP is credited
.
271 3.0.3.2.25.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the RG 1.127, Inspe ction of Water-Control Structures Associ ated with Nuclear Po wer Plan ts program in OCGS LR A, Appendix A, Section A.1.32. It stated that the ?RG 1.12 7, Insp ectio n of Water-Con trol S tructur es Ass ociat ed w ith Nuclear Pow er Plants," agin g management program is an existing co ndition moni toring program that is a part of the Structures M onitoring Program. The program requires perio dic inspec tion of the Intake Struct ure and Canal (UHS), and the Dilution structure concr ete for loss of ma terial, cracking, and changes in material properties. Ste el components are inspected for loss of material due to corrosion, a nd the earthen dike and cana l slopes a re monitored for lo ss of material and loss of form. The program w ill be e nhanced to i nclude peri odic inspe ction of the Fire Pond Dam for loss of mat erial and loss of form.
Other enhancements include periodic inspe ction of subme rged con crete, wood , and s teel c ompone nts for a ge rela ted de gradati ons. Inspection frequency is every four (4) years; e xcept for submerged p ortions of the struc tures, which w ill be i nspected w hen the structures are dewa tered, or on a frequency not to ex ceed 10 years. Enh ancements to the program will be implemen ted prior to e ntering the peri od of extended o peration.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.32 , and noted tha t the FSAR Suppl ement in the L RA does not reflect the appli cant's lates t revisio n to the insp ection frequency for submerged structure
: s. As part of Aud it Commitment 3.0.3.2
.25-1, the appl icant needs to upda te the LRA A ppendix A and Commitment Table A.5 in formation, to be con sistent with this change. See Section 3.0.3.2.25.
3 of this audit report. Af ter revision, the FSAR supplement w ill prov ide an ade quate summary desc ription of the p rogram, as identified in the SRP-L R FSA R Sup plemen t tabl e and as requi red by 10 CF R 54.2 1(d).3.0.3.2.25.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. Also, the project team ha s review ed the enhan cements and determined that the implementati on of the enhanc ements prior to th e period of ex tended operation w ould result in the ex isting AM P being consi stent with the GALL Repo rt AMP to which it was co mpared.The project team als o review ed the UFSA R Supplemen t for this AMP and found that a fter revision it wil l provid e an adequate s ummary descrip tion of the program, as required by 10 CFR 54.21 (d).3.0.3.2.26 Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Qualification Requirements Used in Instrument C ircuits (OCGS A MP B.1.35)In OCGS LRA, Ap pendix B , Section B.1
.35, the appli cant stated that OC GS AMP B.1.35,?Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements Used i n Instr ument C ircui ts," is an ex istin g plan t progra m that i s cons isten t wi th GALL A MP XI.E2, ?Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Environmenta l Qualificati on Requirements U sed in Instrumen t Circuits," w ith enhancemen ts.3.0.3.2.26.1 Program Descriptio n In the OCGS LRA , the appli cant stated that th is program provi des aging management for cab les and connecti ons used in sensitiv e instrumentatio n circuits w ith low-level s ignals.
272 The applican t stated that the cables of the i ntermediate range mon itoring (IRM
), local pow er range monitoring/av erage power ra nge monitoring (LPR M/APRM), reactor buil ding high-radia tion monitoring, and a ir ejector offgas radiatio n monitoring sy stems are sensi tive ins trumentation circuits with low-level signals and are located in areas where the cables and connections could be expose d to adverse localiz ed enviro nments caused b y heat, radi ation, or mois ture. These adverse localized environments can result in reduced insulation resistance, caus ing increases in leakage current
: s. This program cons iders the technical informat ion and guidance provided in NURE G/CR-56 43, ?Insights Gained From Aging Research
," issued M arch 1992; IEE E Std.P1205-2000, ?IEEE Guide for A ssessing, Mo nitoring, and M itigating Aging Effects on C lass 1E Equipm ent Us ed in Nucl ear Po wer Ge nerati ng Stati ons"; S AND96-0344, ?Aging Management Guideline for Commerc ial Nuclear Power Plants-Electrical Cable and Terminations"; and EPRI TR-1096 19, ?Guideline for the Management of Adverse Loc alized Equipment Env ironments, Electric Po wer Resea rch Institute," is sued June 19 99.For the IRM and LPRM/APRM sy stems, the program is i mplemented by station proce dures that are currently used to perfor m current/voltage (I/V) and time domain ref lectometry (TDR) cable testing and have proven eff ective in determining the cable insulation condition. Test ing is per form ed ev ery ref uel in g ou tag e. Cor rec tiv e a cti on, suc h a s ca bl e re pl ace men t, i s ta ken if a cable fails to meet the accep tance criteria of the cable te st procedure. A s recommended by GALL AMP XI.E2, a revi ew of the cab le testing resul ts for cable aging de gradation wi ll be performed before the pe riod o f exten ded op eratio n and every 10 y ears th ereafter.For the reactor b uilding hi gh-radiation moni toring and air ejector offgas radiation mon itoring syste ms, the program i s curre ntly imple mented by st ation proce dures that ar e used to per form calibration testing req uired by the technical specifications. W hen an instrumentation channel is found to be out o f tolerance or ou t of calibratio n, corrective action is taken, such as reca libration and circuit troubleshooting of the instrumentation cable system.
As GALL AMP XI.E2 recommends, a rev iew of the c alibration testing results for cable aging degrada tion wi ll be performed before the pe riod o f exten ded op eratio n and every 10 y ears th ereafter.3.0.3.2.26.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.1.35 is cons istent wi th GALL AMP XI.E2, w ith enhancemen ts.The project team inte rviewe d the appli cant's techni cal staff and revi ewed, in whole or in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for OCGS AMP B.1.35, incl uding PBD-A MP-B.1.35, ?Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 Environmenta l Qualificati on Requirements U sed in Instrumen tation Circu its," Revi sion 0, w hich assesses AM P elements' consistency with GALL AMP XI.E2.
Specificall y, the project team reviewed the program elements (see Sect ion 3.0.2.1 of this audit and review report) cont ained in OCGS AMP B
.1.35 and asso ciated bases documents to de termine their co nsistency with GALL AMP XI.E2.
The project team rev iewed th ose portions of the Electrica l Cables and Connecti ons Not Subje ct to 10 CFR 5 0.49 Envi ronmental Quali fication Requireme nts Used in Instrument Circui ts Program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.E2 and fou nd tha t they are consistent w ith the GALL R eport AMP. Furthermore, the p roject team conclu des that the applicant' s Electrical Cables an d Connectio ns Not Subject to 10 CFR 5 0.49 Envi ronmental Qualification Requirements Used in Instrument C ircuits Program pro vides ass urance that the aging management of conducto r insulatio n resulting from heat, radiation, or moisture for 273 electrical cables used in instrumen tation circui ts will be adequately performed. The project tea m found that the app licant's E lectrical C ables and Connections Not Subject to 1 0 CFR 50.49 Environmenta l Qualificati on Requirements U sed in Instrumen t Circuits P rogram  conforms to the reco mme nded GALL AMP XI.E2, with th e enha ncem ents desc ribe d belo w.3.0.3.2.26.3 Exce ption s to th e GALL Repor t None.3.0.3.2.26.4 Enhan cements In the OCGS LR A, the appli cant n oted th e foll owi ng enha ncemen ts in meetin g the GAL L Repo rt program elements:
Enhan cement 1 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g Enhan cement: Section XI.E2 o f NUREG-1801 recommen ds a revi ew of the cali bratio n resu lts for c able aging de gradati on onc e eve ry 10 year s. Calibratio n results are not currently review ed for cable agin g degradation. This program wil l be revi sed to incl ude a revi ew of the reactor bui lding high-radi ation monitori ng and air ejecto r offgas radiation mon itoring systems calibration results for cabl e aging degradation before th e period of ex tended operati on and ev ery 10 years therea fter.The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detection of aging effects," and
?monito ring an d trend ing" pr ogram el ements associ ated w ith th e enha ncemen t: 3. Parameters Mon itored or Inspe cted:  The parameters moni tored are determi ned from the specific calibration, surveillance, or tes ting perform ed and are based on the specific instrumentation circuit unde r surveil lance or bei ng calibrated, as documented i n plant procedures.
: 4. Dete ction of Agi ng Effe cts:  A revi ew of cali bration resul ts or findings of surv eillance programs can prov ide an in dication of the existence of aging effects based on acceptance cri teria related to instrumentatio n circuit pe rformance. In cases i n which a calibration or survei llance program d oes not incl ude the cabl ing system in the testing circuit, or as an alternati ve to the re view of calibration results descri bed above , the appl ica nt w ill perfo rm ca ble sys tem t esti ng.5. Monitorin g and Trendi ng:  Trending action s are not inc luded as p art of this program becau se the abil ity t o trend test re sults is de pende nt on t he spe cific t ype o f test ch osen. Howeve r, test results tha t are trendable provide additional information on th e rate of degradation.
274 In the OCGS LRA , the appli cant stated that, a s recommended by GALL AMP XI.E2, a revi ew of the calibrati on testing resul ts for cable aging de gradation wi ll be performed b efore the period of extended o peration and every 10 years therea fter. By revi ewing the re sults obtain ed during calibration , severe agin g degradation w ill be d etected before the l oss of the cable
's and/or connection' s intended functi on.On this basis , the project team found this enhanc ement acceptabl e because on ce these enhancements are implemen ted, OCGS AMP B.1.35 will be consistent with GALL AMP XI.E2 and wil l provid e addition al assurance that the effects of aging w ill be a dequately mana ged.Enhan cement 2 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g Enhan cement: Section XI.E2 o f NUREG-1801 recommen ds a revi ew of test results for cable aging degradation once every 10 years. Cable test re sults are no t curre ntly revi ewed for cabl e agin g degrada tion. This program wi ll be rev ised to in clude a rev iew of the LPRM/AP RM and IRM sys tem cable testi ng results for cable aging degradation before th e period of ex tended operati on and ev ery 10 years therea fter.The GALL Report i dentified the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detection of aging effects," and
?monito ring an d trend ing" pr ogram el ements associ ated w ith th e enha ncemen t: 3. Parameters Mon itored or Inspe cted:  The parameters moni tored are determi ned from the specific calibration, surveillance, or tes ting perform ed and are based on the specific instrumentation circuit unde r surveil lance or bei ng calibrated, as documented i n plant procedures.
: 4. Dete ction of Agi ng Effe cts:  A revi ew of cali bration resul ts or findings of surv eillance programs can prov ide an in dication of the existence of aging effects based on acceptance cri teria related to instrumentatio n circuit pe rformance. In cases i n which a calibration or survei llance program d oes not incl ude the cabl ing system in the testing circuit, or as an alternati ve to the re view of calibration results descri bed above , the appl ica nt w ill perfo rm ca ble sys tem t esti ng.5. Monitorin g and Trendi ng:  Trending action s are not inc luded as p art of this program becau se the abil ity t o trend test re sults is de pende nt on t he spe cific t ype o f test ch osen. Howeve r, test results tha t are trendable provide additional information on th e rate of degradation.
In the OCGS LRA , the appli cant stated that, a s recommended by GALL AMP XI.E2, a revi ew of cable test resu lts for cable agi ng degradation w ill be p erformed before the perio d of extended oper atio n an d ev ery 10 y ears ther eafte r. B y re vie wi ng th e res ults obta ine d du ring cab le t esti ng, severe aging degradat ion will be detected before the loss of the cable's and/or conne ction's intended functio
: n.
275 On this basis , the project team found this enhanc ement acceptabl e because on ce enhancements are implemen ted, OCGS AMP B.1.35 will be consistent with GALL AMP XI.E2 and wil l provid e addition al assurance that the effects of aging w ill be a dequately mana ged.3.0.3.2.26.5 Operating Expe rience In the OCGS LRA , the appli cant stated that th e cable testi ng and calib rations that are used for this program are pe rformed currently, a nd have p roven effective in identi fying the exi stence of degradation in the performance of the s ystem tested. OC GS has expe rienced failu res of monitoring sys tem cables and connectors that were ide ntified during the conduct of routin e testing. For ex ample, a step change in the air ejector offgas radiati on monitor read ings was correc ted by repla cing th e cabl es for bo th cha nnels. When equip ment ca nnot b e brou ght int o calibration , or when cable sys tem tests indic ate unacceptab le results, e valuatio ns are performed in accordanc e with th e corrective action program, an d appropriate actions are ta ken.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA an d intervi ewed the applica nt's technic al staff to confirm that the plant-specific operating exp erience did not reveal an y degradation not bounded by indu stry expe rience.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technic al staff, the project team d etermined that the applican t's Electric al Cables and Connecti ons Not Subje ct to 10 CFR 50.49 Envi ronmental Quali fication Requireme nts Used in Instrument Ci rcuits Program w ill adequate ly manage the aging effects that are ide ntified in the OCGS LRA for wh ich this A MP is credited.3.0.3.2.26.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Electrical Cables an d Connectio ns Not Subjec t to 10 CFR 5 0.49 E nvir onmenta l Qual ificati on Requ iremen ts Use d in I nstrume nt Cir cuits Program in Secti on A.1.35 of App endix A to the OCGS LRA , which states that the E lectrical Cables and Connection s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requirements Used in Instrument C ircuits Program i s an exi sting program that manages a ging of the cables of the IRM, LPR M/APRM , reactor buil ding high-radia tion monitori ng, and air ejecto r offgas radiation monitori ng systems that are sensitiv e instrumentatio n circuits w ith low-level signal s, and are l ocated in ar eas w here th e cabl es and conne ction s coul d be e xpos ed to adverse l ocalize d environ ments caused by heat, radiati on, or moisture.
These adverse localiz ed environments can result i n reduced in sulation res istance, causi ng increases i n leakage currents.
Cali bratio n testi ng and curren t/vol tage (I/V) and TD R testi ng are c urrentl y per formed to ensur e that the cable insulation resistance is adequat e for the instrument ation circuits to perfor m their intended functio ns. Based on acceptance cri teria related to instrumentatio n loop performance and cable testing set for th in the calibration and testing procedur es, evaluation of unacceptable results is i nitiated un der the correcti ve action program. The cali bration testin g and cable te sting used for this program a re performed currently , and have proven effectiv e in iden tifying the existence of degradation in the performance of the teste d systems. The program will be enhanced to i nclude a rev iew of the c alibration and cable testing results for cable aging degradation, as recom mended by Section XI.E2 of NUREG-1801. The enhanced progr am will be implemented before the perio d of extended operation and will include a review of the calibration and cable testing results for cable aging degrada tion before the p eriod of exten ded operat ion a nd ev ery 1 0 yea rs ther eafter.
276 The pro ject tea m also revi ewed the l icens e rene wal commit ment li st in Secti on A.5 of the OC GS LRA to confirm tha t the program enhanc ements wil l be imple mented before the pe riod of extended o peration, and noted that it i s Item 35 on the list of commitments.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.35 , found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).3.0.3.2.26.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the enhan cements and determined that their implemen tation before the period of exte nded operatio n would result in the existing AM P being consi stent with the GALL Repo rt AMP to which i t was compare
: d. The project team also review ed the UFSA R Supplemen t for this AMP and found that i t provides an adequa te summa ry de script ion o f the pro gram, as require d by 10 CFR 54.21 (d).3.0.3.2.27 Metal Fa tigue of Reactor Co olant Pressure Boundary (OCGS AMP B
.3.1)In the OCGS LRA , Appendix B, Section B.3.1, the appl icant stated th at OCGS AMP B.3.1,"Metal Fatigue of Reactor Coolant Pres sure Boundary," is an existing plant program that is consi stent w ith GA LL AM P X.M1 , "Me tal Fa tigue o f Reacto r Cool ant Pre ssure Boundary,"(M FRCPB) w ith enhancemen ts.3.0.3.2.27.1 Program Descriptio n The applican t stated, in the OCGS LRA, that this program prov ides for monitori ng select components in the reactor cool ant pressure bo undary by tracking and ev aluating key plant events. Ev ents were s elected base d upon pla nt-specific ev aluations o f the most fatigue-limited locat ions for crit ical compon ents, i nclud ing tho se di scusse d in N UREG/C R-6260 , ?Applicati on of NUREG/CR-5999 , Interim Fatigue C urves to Se lected Nucl ear Power Plant Compon ents."  The metal fa tigue o f reactor cool ant pre ssure b ounda ry pro gram moni tors op eratin g transi ents to-dat e, calcu lates f atigue usage f actors to-dat e, and per mits im plement ation of correc tive measures in ord er not to ex ceed the desi gn limit on fatigue usage. The effects of reactor coolant env ironment wi ll be con sidered through the evalu ation of, as a mi nimum, those compon ents se lecte d in N UREG/C R-6260 usin g the ap propri ate en viro nmental fatigue factors. The des ign ba sis me tal fati gue ana lyse s for the reacto r cool ant pre ssure b ounda ry are considered TLA As for license renewal. The program provi des an anal ytical b asis for confirming that the number o f cycles estab lished by the analy sis of record w ill not b e exceede d before the end of the perio d of extended operation. In order to determin e cumulativ e usage factors (CUFs
)more ac curate ly, t he pro gram wi ll i mpleme nt Fati guePro fatigue m onito ring so ftware. Fatigu ePro c alcul ates cu mulati ve fati gue usi ng both cycl e-base d and stress-based monito ring. This provid es an anal ytical b asis for confirming that the number of cyc les establi shed by th e analysi s of record wi ll not be exceeded before the end of the period of exte nded operatio n.3.0.3.2.27.2 Consi stency wit h the GA LL Rep ort In the OCGS LRA , the appli cant stated that OC GS AMP B.3.1 is consi stent with GALL AMP X.M 1, with e nhancements.
277 The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for OCGS AMP B.3.1, includ ing PBD-A MP-B.3.01, ?Metal Fa tigue of Reactor Co olant Pressure Boundary,"
Rev. 0, w hich provides an assess ment of the AMP eleme nts' co nsisten cy with GALL AMP X.M1. Specif ically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this aud it and rev iew report) contained in OCGS AMP B.3.1 and associated bas es documents to determ ine their consistency with GALL AMP X.M 1.In review ing this program the project team noted that, on page 4-36 of the OCGS LRA, th e applicant s tated that the al lowabl e cumulativ e fatigue usage factor (CUF) value i s 1.0. The licensing b asis for acceptabl e CUF for the rea ctor pressure v essel is c urrently state d in the Oyster Creek UFS AR to be 0.8.
The applica nt responded th at OCGS is curren tly in th e process of changi ng the C UF acc eptanc e limi t for the RPV t o 1.0 u sing th e appr oach d escrib ed in 4.3.1 of the OCGS LRA. The applican t stated that, at the end of the audi t review , the current li censing basis CUF limit for the RP V is changed to 1.0 in acc ordance wi th10 CFR 50
.59. The appli cant stated that A merGen w ill revi se the OCGS U FSAR to upd ate the curren t lic ensin g basis to reflect that a cumul ative usa ge factor of 1.0 wil l be used in fatigue anal yses for reactor c oolant pressure bound ary componen ts, as endorsed by the NR C in 10 C FR 50.55a, be fore the period of extended op eration as sta ted in a l etter dated Dece mber 9, 2005, (AD AMS Acc ession Number ML053490219). The staff' s TLAA revi ew i s disc ussed in Se ction 4 of the SER r elate d to the OCGS LRA.
The applicant was asked to provide the backup docum entation to support the f atigue analysis results and th e associated design cyc les for the isol ation conden sers. The project tea m confirmed that the a pplicant co mpleted its fatigue analysi s backup documenta tion.The pro ject tea m revi ewed OCGS P ower Operati ons Re view Commit tee (PO RC) mee ting re port (06-03) and s pecifi catio n OC-20 06 E-0 01, ?Revised Method for De termination of Fati gue Cumulative Usage Factor," Revision 0. The proj ect team noted that PORC appr oved the CUF limit change w ith some recommend ations and c onditions.
The project team asked th e applica nt to clarify the methodology used for the determi nation of the Fa tigue CUF. A lso, the project team asked the appli cant to clari fy the original design inten t to limit the CUF limi t to 0.8 and w hether the new d esign analy sis and the revised fatigue analysi s will be certified b y  a professi onal engine er wi th sign ifican t exp erien ce wi th ASM E Cod e Sect ion II I fatigue anal yses to demonstrate compli ance to ASM E Section III Class 1 an alysis. In response, the applicant s tated the fo llo wi ng: From UFSAR s ection 5.3.1.1, the followi ng statement provi des the basi s for the General Elect ric met hod of p erformin g fatigue analy sis for the Oy ster Cr eek reac tor ve ssel; ?For reactor pressure v essels desi gned and buil t prior to the adoption of the ASME C ode Section III, the General Elec tric Company develop ed a method for performin g a fatigue analysis which would provide assurance that vessels installed in General Electric designed nucl ear power plants wo uld safely withstand all antic ipated operati ng and transient cond itions, both normal and emergen cy conditi ons. This method was base d upon the method of analysis developed for Naval reactor s and upon industry's experience using it."  The UFSAR al so conclude s that the General Electric S pecification defined analy sis results i n a completed vessel for the Oyster Creek pl ant, which has safety margins that a re generally equivale nt to those w hich wo uld result from us ing Section III method ology. General Electric' s selection of a cumulativ e usage factor limi t of 0.8 (versus 1.0) was to assure the Oyster Cree k reactor pressur e vessel design would remain bound ed by the pe nding ASM E Sect ion II I method ology and a ccepta nce cri terion.
278 There is no ev idence that c onsideration was giv en to reservi ng margins for any oth er reason (e.g., for system transient s or unspecified cyclic conditions not considered in orig inal a nalys is). The r eana lyzed f atig ue us age fac tor s were perf orm ed to the AS ME Section III requi rements to demonstrate acceptabil ity to the corresponding ac ceptance limit of 1.0.
The Exelon 50.59 eva luations rev iewed i f using ASME Section III i nstead of the methods by GE to cal culate fatigue usa ge represented a departure from a method of evaluatio n described i n the UFSAR used in e stablishin g design bases.
The OC procedure for pre par in g 50.59 ev al uat io ns, ba sed on NE I 96-07 , pr ov id es t he gui dan ce t hat: Us e o f a new NRC-approved meth odology (e.g., AS ME Secti on III) to reduce uncertainty, provide more precise res ults, or other re ason is not a departure from a metho d of evaluati on described i n the UFSAR , provided such use i s (a) based on sound engine ering practice, (b) appropriate fo r the intended application, and (c) within the limitations of the applicable SER. Oy ster Cre ek is usi ng th e AS ME Cod e Se ctio n III meth odol ogy to re vis e it s de sign basis fatigue ana lyses for the reactor vesse l; and the N RC has appro ved the us e of ASME C ode Section III via 10 CFR50.55a, w hich is w ithin the l imitations o f the Oyster Creek Licensi ng Basis. Therefore, i mplementing the A SME Cod e Section III me thod for analyzing fatigue is not considered a departu re from a metho d of evaluation described in the UFSAR.
The licensi ng change allow s Oyster Creek to revise de sign basis an alysis from the methods describ ed in GE spe cification 21A 1105 to the N RC-approve d methods of the ASM E Cod e Sect ion II I. The l icens ing ba sis ch ange pr ovid es Oys ter Cre ek the a bili ty to implement rev ised anal ysis to es tablish new allow able cycl es [N(I)], using the methods described in ASME Code Section III. The diffe rence in methodology is primarily associ ated w ith th e differe nce be twee n the s-N fatigu e curv e prov ided in the GE specification and the fatigue curv e in the AS ME Secti on III code. The process of summing transient p airs to determin e total fatigue usa ge remains uncha nged.As part of the prep aration of the Oy ster Creek Licens e Renewa l applic ation, limi ting fatigue analyse s of the reactor pres sure vessel prepared per the original GE purchase specification for the RPV hav e been rev ised in a ccordance w ith the NRC approved ASME Code Section III as permitted by Appendix L of ASME Section XI. As stated in App endi x L the n ew fatig ue u sage val ues are c ompa red t o 1.0. Thi s is not onl y a chan ge in an accep tance limit but al so a ch ange i n metho dology , sinc e fatigue usage fa ctors were revise d using t he fat igue cur ve in ASME Sectio n III ins tead of the fat igue cur ve provided in the GE spe cification. Oy ster Creek has ass umed the respons ibility of the RPV d esign b asis a naly sis i n acco rdance wit h the C ode re quireme nts, an d there fore, GE concurrence of the changes is not required nor w as it requested.
Oyster Creek has revised the f atigue analysis for the limiting RPV locations in accordance w ith the methods established in NRC approved A SME Cod e Section III, a s permitted by ASME S ection XI IWB-3740. As stated i n ASME XI Appendix L the revi sed usage factors are compare d to 1.0. Si nce all o f the revised usage factors are les s than the acceptance limit, there ar e no adverse effects.
The GE specification (21A1105) is still the current specificati on for the RPV.
This specificati on wil l be update d to reflect the change in method ology as pa rt the design cha nge process.
As part of the eff ort for License Renewal, the current licensing basis RPV fatigue analysis was e valu ated to demons trate s atisfac tory r esult s for the perio d of ex tended opera tion.
279 When the current licensin g basis RPV fatigue analysi s was reev aluated, usi ng actual thermal cycl es based on plant data, i t was determi ned that for some l ocations the forty-y ear fati gue usa ge may exce ed the 0.8 ac ceptan ce li mit imp osed b y the GE spe c. These location s required a more refined analy sis. Under the rules of 10C FR50.55a and Secti on XI, S ubsect ion IWB, the appl icant is al low ed to u se App endix L of Se ction XI to analy ze th e effects of fatigue on co mponen ts. Ap pendi x L d irects that A SME Secti on III fatigue usag e factor evaluation procedures be used to determine if they are acceptable for continued serv ice. The fatigue usa ge factors for the reanaly zed compone nts are less than 0.8 befor e env ironme ntal e ffects are incl uded fo r Lice nse Re newa l. Ho wev er, the re is no tech nical basis not to com pare the usage f actors to 1.0 sin ce Append ix L establis hes 1.0 as the appr opriate accepta nce limit. The re vised analysi s for t he above components can be found in E xelon D esign Analy sis SIA No.
OC-05Q-303 Rev ision 1.The applican t stated that al l supporting ca lculations and reports pre pared by S tructural Integrity Associ ates (SIA) for the fatigue activiti es associated with the Oyster Creek License Renewal Applic ation were approved (and in man y cases pre pared) by a registered Profession al Engineer.
The registered Professi onal Engine er has significa nt experience with AS ME Code Section III fatigue analyses, and is app roved in accordance with SIA's Quality Assurance Program to be a quali fied certifier of ASM E Code, Sec tion III, Divisi on 1 Design Specification s and Desi gn Reports. The ap proval of the Professional E ngineer signifies acknowledgment th at all doc uments are correct and complete to the best of his know ledge and that he or she i s competent to ap prove the documents accordi ngly, and tha t all docu ments meet the in tent of the pertinen t sections of Section III, Sub section NB of the ASME Code (in a ccordance w ith the referenced Edition an d Addenda) for C lass 1 fatigue an alysis. In its letter d ated May 1, 2006, the applicant c ommitted to certificati on by a P rofessional En gineer of the reactor vessel design speci ficatio n and design report s prep ared for the fati gue acti viti es ass ociat ed w ith the LR A. Thi s wi ll be performe d by July 31, 20 06. This is A udit Commitment 3.0.3.2.27-1.
The pro ject tea m revi ewed those porti ons of th e metal fatigue of reacto r cool ant pre ssure boundary p rogram for which the applican t claims cons istency w ith GALL AM P X.M1 and found that they are consistent with the GALL Report AMP. The proje ct team found that the applicant's metal fatigue of reactor co olant pressure boundary program conforms to the recommen ded GALL AMP X.M1, "Me tal Fatigue of Re actor Coolan t Pressure Bou ndary," w ith the enha ncem ents desc ribe d belo w.3.0.3.2.27.3 Exce ption s to th e GALL Repor t None.3.0.3.2.27.4 Enhan cements In the OCGS LRA , the appli cant identifie d the follow ing enhancement in order to mee t the GALL Report program ele ments: Elements: 3: Parameters M onitored/ Inspe cted 4: Dete ction of Agin g Effects 5: Monito ring and Trendin g 6: Acceptance Criteria 280 Enhan cement: The program wil l be enhan ced to use the EPRI-lice nsed FatiguePro cy cle countin g and fatigue usage factor trackin g computer program. The compute r program provide s for calculati on of stress cycles and fatigue usage factors from operating cycl es, automated counti ng of fatigue stress cycl es and automated calculatio n and tracking of fatigue cumu lative u sage factors.
The program wil l provid e for calculati ng and tracking of the cumulative usage factors for boundi ng locations for the reactor pressure ves sel, Class I piping, the to rus, torus ven ts, torus attach ed pi ping a nd pen etrati ons, a nd the isol ation conde nser. The monitoring sampl e will include those locati ons where the predi cted 4 0-yea r cumul ativ e fatigue usage h ad bee n pred icted to be 0.4 or greater, including the locations specified in NUREG/CR-6260 , when ap plicable to Oyster Cree k The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored or inspe cted," ?detect ion o f aging effec ts," ?monitoring and tre nding," and acce ptance criteri a"program e lement s asso ciate d wi th the stated enhan cement: 3. Parameters Moni tored or Inspected
:  The program monitors all plan t transients that cause cycl ic strains, w hich are si gnificant contributo rs to the fatigue usage factor. The number of plant tran sients that cau se significant fatigue usage for each criti cal reactor coolant pressu re boundary component is to be monitored. Alternativ ely, more de tailed loc al m oni tori ng of t he p lan t tra nsi ent m ay b e us ed to comp ute t he a ctua l fat igue usa ge for each transi ent.4. Detect ion o f Agin g Effec ts: The program provi des for periodi c update of the fatigue usage calcula tions.5. Monitoring and Trendin g: The prog ram m oni tors a sa mple of hi gh fat igue usa ge locations.
This sample i s to includ e the locati ons identifie d in NURE G/CR-6260, as minimum, or propos e alternativ es based on plant configuratio n.6. Acceptance Criteria
: The acc epta nce crit eria inv olv es ma inta ini ng th e fati gue u sage below th e design code limit cons idering env ironmental fatigue effects as described u nder the program descripti on.In review ing this enha ncement, the project team noted that, i n the OCGS LRA , the appli cant stated that the E PRI-license d FatiguePro co mputer program provi des for calcula tion of stress cycles an d fatigue usage factors from operati ng cycles, au tomated counting o f fatigue stress cycles, an d automated cal culation an d tracking of fatigue cumulati ve usage factors. The applican t also st ated th at the pr ogram will provide f or calcul ating a nd trac king of the c umulat ive usage factors for boundin g locations for the reactor pressure vessel, C lass I pipi ng, the torus, torus vents, to rus attached pi ping and pene trations, and th e isolati on condenser.
The monitoring sample wi ll incl ude those lo cations w here the predi cted 40-year cumulative fatigue usage had been predicte d to be 0.4 o r greater, includi ng the locatio ns specified i n NUREG/CR-62 60, when appl ica ble to Oy ster Cre ek.During the audi t and revi ew, the proje ct team eval uated the appl icant's ex isting fatigue monitoring program and noted that i t had correctly identified th e need for more sop histicated 281 methods to demonstra te adequate margin to fatigue limits. Improv ed calcula tion of environmenta l fatigue factors is a lso necessary. The project team de termined that the use of FatiguePro is an appropria te method to impro ve monitori ng, and, taken together w ith the improved metho dology for calc ulation of env ironmental fatigue factors, this enhanc ement provides assurance that fatigue damage wil l be adequatel y managed.
On this basis , the project team found this enhanc ement acceptabl e since w hen the enhan cement is imp lement ed, OCGS AMP B.3.1, "Met al Fa tigue o f Reacto r Cool ant Pre ssure Boundary," w ill be c onsistent w ith GALL AM P X.M1 and will provide a dditional assurance that the effects of aging wil l be adequatel y managed.
3.0.3.2.27.5 Operating Expe rience The applicant stated, in the OCG S LRA, that Oyster Creek has reviewed both plant-spec ific operat ing ex perie nce re latin g to the metal fatigue o f reactor cool ant pre ssure b ounda ry (MFRCPB) program. In instan ces where the potential existed to exceed CUFs before the end of plant life, the engineering analyses showed that actual margins were larger than initially estimated.
The applicant also stated that the MFRCPB progr am has been revised to incorporate change s in des ign ba sis an al ys is cy cle s to ref le ct r eal ity. In res pon se t o N RC con cer ns t hat ea rly-li fe operat ing cy cles a t some u nits h ad cau sed fati gue usa ge factors to in crease at a gre ater ra te than anticip ated in the design analy ses, the indu stry sponsore d the deve lopment of the FatiguePro compute r program. The program is d esigned to ensu re that the Cod e limits are not exceeded for the remainder of the licensed l ife, and provi des for incorporati on of operating experience
.The project team rev iewed th e operating ex perience prov ided in th e OCGS LRA, an d interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience. At OCGS, the fatigue evaluati ons confirm that si gnificant margin remain s to reach the CUF limit, and implementa tion of the p ropose d progra m wil l ena ble th e appl icant to pre vent exce eding the li mit.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e, and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's metal fatigue of reacto r cool ant pre ssure b ounda ry pro gram wi ll ad equatel y mana ge the a ging effect s that are identified i n the OCGS LRA for which th is AMP is credited
.3.0.3.2.27.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he meta l fatigu e of rea ctor co olant pressu re boundary p rogram in OCGS LRA , Appendix A, Section A.3.1, whi ch states that the metal fatigue of reactor coolant pressure bound ary aging management program is an ex isting program that ensures that the design fatigue usage factor l imit wil l not be ex ceeded durin g the period of ext ende d op erat ion. The prog ram w ill be e nhan ced to ca lcu late and trac k cumu lati ve u sage factors for bounding lo cations in the reactor cool ant pressure bo undary (reacto r pressure ve ssel and Cl ass I p ipin g), conta inment torus, torus vents , and t orus a ttache d pip ing an d pene tratio ns. The program also tracks i solation co ndenser fatigue stress cycles.The program wil l be enhan ced to use the EPRI-lice nsed FatiguePro cycle co unting and fatigue usage factor tracking computer p rogram, which p rovides for ca lculation of stress cycles and 282 fatigue usage factors from operatin g cycles, auto mated counting of fatigue stre ss cycles, and automated calcu lation and tracking of fatigue cumulati ve usage factors. F atiguePro calc ulates cumulative fatigue using both cycle-base d and stress-bas ed monitoring. The program wil l be enhan ced pr ior to the pe riod o f exten ded op eratio n."The pro ject tea m also revi ewed the l icens e rene wal commit ment li st in Secti on A.5 of the OC GS LRA to confirm that this pr ogram will be enhanced to use the EPRI-licensed FatiguePr o cycle counting and fatigue usage factor tracking computer p rogram prior to the p eriod of exten ded operation, and noted that i t is item 44 on the lis t of commitments.
In its lette r dated May 1, 200 6 (Amer Gen Let ter No. 2130-06-203 28), th e appl icant commit ted to cert ific atio n by a Pr ofess ion al E ngin eer o f the reac tor v esse l de sign spe cifi cati on a nd d esi gn reports prepa red for t he fati gue acti viti es. This is A udit Commitment 3.0.3.2.2 7-1.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.3.1.
Contingent upo n incl usion of audi t commi tment 3.0.3.2.2 7-1, th e proje ct team, found t hat it was consi stent w ith the GALL Repo rt, and determined that it prov ides an ad equate summary des cription of the program, as identi fied in the S RP-LR FSAR Supplement ta ble and as required by 10 CFR 54.21(d).3.0.3.2.27.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. Also, the project team ha s review ed the enhan cement and commitme nt 3.0.3.2.27-1 and determ ined that th e impl ementat ion o f the en hance ment pr ior to the period o f extended ope ration wo uld result i n the exi sting AMP being consiste nt with th e GALL Report AMP to which it was compared. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that, conti ngent upon the i nclusion o f audit commitment 3.0.3.2.27-1, it p rovides a n adequate summary description of the program, as required by 10 CFR 54.21 (d).3.0.3.3 OCGS AMPs That A re Not Consis tent with the GALL Report or Not Addressed in the GALL Repo rt 3.0.3.3.1 Periodic Testi ng of Containment Sp ray Noz zles (OCGS A MP B.2.1)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.3.2 Lubricating Oil Monitori ng Activiti es (OCGS AM P B.2.2)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.3.3 Generator Stator Water Chemistry A ctivitie s (OCGS AMP B.2.3)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.
283 3.0.3.3.4 Periodic In spection of Ven tilation S ystems (OCGS AM P B.2.4)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.3.5 Periodic In spection Program (OCGS AMP B.2.5)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.3.6 Wooden Utility Pol e Program (OCGS AM P B.2.6)Thi s A MP is ass ign ed to t he Offi ce o f Nu cle ar R eac tor Re gul ati on, Di vi sio n o f En gin eer in g st aff and will be addressed separately in Section 3.0.3.3 of the SER related to the OCG S LRA.3.0.3.3.7 Periodic M onitoring of Combus tion Turbine P ower Pla nt (OCGS AMP B.2.7)In response to RAI 2.5.1.19-1, w hich is do cumented in A merGen letter 2130 20214 titl ed?Response to N RC Request for Add itional In formation (RAI 2.5.1.19
-1), dated Septemb er 28, 2005, Relate d to Oyster Cre ek Generating Station License R enewal Applicati on (TAC No.
MC7624)," d ated October 12, 2 005, the appl icant stated th at it had rev ised its ap proach to aging manageme nt for th e Oyst er Cre ek Stati on bl ackout s ystem combus tion t urbin e pow er pla nt. Specificall y, AmerGen has taken a more detai led approach to scoping, scre ening, aging manageme nt rev iew s and AMP s. As a resu lt, agi ng manage ment pr ogram B.2.7, ?Periodic Monitori ng of Combustion Turbi ne Power Plant," has b een deleted. Therefore, the project te am did n ot rev iew this program.3.1 OCGS LRA Section 3.1 -
Ag ing Management o f Reactor Ves sel, Internals, and Reacto r Cool ant Sy stems This section o f the audit and review report documents the project team's review and eval uation of OCGS aging management rev iew (AM R) results for the aging management of the reacto r vessel, i nternals, and reactor coolan t system compone nts and compone nt groups associ ated with the following sy stems: (1) isola tion condens er system; (2) nu clear boil er instrumentatio n system; (3) reacto r head cooli ng system; (4) reacto r internals; (5) reactor pressure vessel; an d (6) rea ctor re circul ation syste m.3.1.1 Summary o f Technical Information in the A pplication In the OCGS LRA Section 3.1 , the appli cant provid ed the results of its AMR s for the reactor vessel, i nternals, and reactor coolan t system compone nts and compone nt groups.
In OCGS LRA Ta ble 3.1.1, ?Summary of Aging Management Evaluations for the Reactor Vessel, Interna ls, an d Reac tor Coo lant S ystem," the a ppli cant p rovi ded a summary compar ison of its AMR line-items with the AMR line-items evaluated in the GALL Report for the reactor vessel, internals, an d reactor cool ant system compo nents and compo nent groups. The ap plicant al so ident ified, for each compon ent ty pe in the OC GS LRA Table 3.1.1, those AMR s that are consistent w ith the GALL R eport, those for w hich the GALL Report recommends further evaluati on, and those AMRs tha t are not addres sed in the OCGS LRA together w ith the basi s for their excl usion.
284 In the OCGS LRA , Tables 3.1.2.1.1 through 3.1.2.1.6, the applicant p rovided a summary of the AMR resu lts for component ty pes associate d with th e (1) isola tion condens er system; (2) nu clear boiler in strumentation sy stem; (3) reactor hea d cooling sy stem; (4) reactor in ternals; (5) reac tor pressure ves sel; and (6) re actor recircula tion system.
Specificall y, the informatio n for each component type included intended functi on, material, e nvironment, a ging effect requiring management, AMPs, the GALL Report Volume 2 item, cross ref erence to the OCGS LRA Table 3.1.1 (Table 1), and generic and plant-sp ecific notes rel ated to consi stency w ith the GALL Report.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of aging effects requiring management (AE RMs). These review s included evaluati on of plant-spe cif ic and indus try op erat ing e xperi ence. The plant-spe cif ic eval uati on inc luded revie ws of condition re ports and dis cussions w ith appropri ate site perso nnel to id entify AERM
: s. The applicant' s review of industry o perating expe rience incl uded a rev iew of the GA LL Report and operat ing ex perie nce i ssues ident ified since the i ssuanc e of the GALL R eport.3.1.2 Project T eam Evaluatio n The project team rev iewed OC GS LRA Secti on 3.1 to determi ne if the appl icant provi ded sufficient information to demonstrate that th e effects of aging for the reactor v essel, intern als, and reactor coo lant system c omponents that are within the scope of l icense renew al and sub ject to an AM R wil l be adequatel y managed so th at the intende d function(s) w ill be mai ntained consi stent w ith th e CLB for the perio d of ex tended opera tion, as requi red by 10 CF R 54.2 1(a)(3).The project team rev iewed c ertain iden tified AMR line-items to confirm the appl icant's cl aim that these AMR line-items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line-items. The project team's audit evaluation is documente d in Section 3.1.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line-items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in SRP-LR. The projec t team's audit eval uatio n is d ocumen ted in Secti on 3.1.2.2 of t his a udit a nd rev iew report.The project team did not revie w the remai ning AMR line-items that were no t consistent w ith or not ad dresse d in t he GAL L Repo rt base d on N RC-ap prove d prec edents. These AMR s wer e review ed by NR R/DE staff and the res ults were documented in the SER rel ated to the Oy ster Creek p lant.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the re actor vessel , internals, a nd reactor cool ant systems co mponents.Table 3.1-1 bel ow prov ides a summary of the project team's evaluati on of components, agi ng effects/aging mechanisms, and AMPs l isted in L RA Section 3.1 that are ad dressed in th e GALL Report. It also includes the section of the audit and review report in which the project team's evaluati on is documen ted. It should be noted tha t the line items in thi s table corres pond to the line items in Table 3.1-1 of the Septem ber 2005 Revision 1 SRP-LR document; theref ore, in 285 many cases, th ey do not match the lin e items in Tabl e 3.1.1 of the OCGS L RA. The SRP-L R line item n umber i s deno ted pa renthe tical ly i n the c olumn 1 entry. Als o, li ne ite ms that are applicabl e only to PWR plants are not incl uded in thi s table; therefore, c ertain SRP-L R line i tem numbers do not appear in th is table.Table 3.1-1 Project T eam's Evalua tion for LRA Section 3.1 -
Reactor Ves sel, Internals, and Reactor Coolant Sy stems Componen ts in the GA LL Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on Steel pressure vessel supp ort skirt and att achment welds (It em 3.1.1-1)
Cum ulat ive fat igue damage TLAA, eval uated in acc orda nce with 10 CFR 54.21(c)
TLAA TLA As we re re vi ewe d by NRR DE s taff.(See Au dit Report Secti on 3.1.2.2.1)Steel; st ainl ess stee l; steel w ith nickel-al loy or stai nless st eel claddi ng;nickel-al loy react or vessel components:
fl anges; noz zl es;penetrations; safe ends; t hermal sleev es; vesse l shell s, heads an d welds (It em 3.1.1-2)
Cum ulat ive fat igue damage TLAA, eval uated in acc orda nce with 10 CFR 54.21(c) and envi ronmental effect s are t o be addressed f or Class 1 components TLAA BW R Feedwater Nozzle (B.1.5), BW R C RD Return Line Noz zl e (B.1.6)TLA As we re revi ewed by NR R/DE staff.Ac ce pta ble-C ra ck in g due to fati gue for FW and CRDRL nozz le t hermal sleev es wil l be m an ag ed in accordance wi th 10 CFR 54.21(c)(1)(iii
).(See Au dit Report Secti on 3.1.2.2.1)Steel; st ainl ess stee l; steel w ith nickel-al loy or stai nless st eel claddi ng;nickel-al loy react or coolant pressu re boundary pipi ng, pipi ng components, and piping elem ents exposed to react or coolant (It em 3.1.1-3)
Cum ulat ive fat igue damage TLAA, eval uated in acc orda nce with 10 CFR 54.21(c) and envi ronmental effect s are t o be addressed f or Class 1 com pon ents TLAA TLA As we re revi ewed by NR R/DE staff.(See Au dit Report Secti on 3.1.2.2.1)Steel pump and valve closure bolt ing (It em 3.1.1-4)
Cum ulat ive fat igue damage TLAA, eval uated in acc orda nce with 10 CFR 54.21(c) che ck Co de lim its fo r allo wa ble cycl es (l ess than 7000 cycl es) of ther mal stress range TLAA TLA As we re revi ewed by NR R/DE staff.(See Au dit Report Secti on 3.1.2.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 286 Stai nless st eel an d nickel all oy r eactor ve ss el in ter na ls com pon ents (It em 3.1.1-5)
Cum ulat ive fat igue damage TLAA, eval uated in acc orda nce with 10 CFR 54.21(c)
TLAA BW R Vessel Int ernal s (B.1.9)TLA As we re revi ewed by NR R/DE staff Acceptabl e-Cra ck ing du e to fati gue wil l be m an ag ed in accordance wi th 10 CFR 54.21(c)(1)(iii
).(See Au dit Report Secti on 3.1.2.2.1)Steel top head enclosur e (wi thout claddi ng) t op head nozz les (vent, top head spray or RCIC, and spare) exposed to react or coolant (It em 3.1.1-11)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on W ater Chem istry an d O ne-T im e Inspect ion N ot A pp lica ble N ot A pp lica ble since Oy ster Creek top head en closure is clad with sta inle ss ste el.(See Au dit Report Secti on 3.1.2.2.2.1)Steel and stai nless steel isol ati on condenser com pon ents exposed to react or coolant (It em 3.1.1-13)
Loss of materi al due to ge neral (stee l onl y), pi tt ing and crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and an augmented inspect ion pr ogram to ASME S ect i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1) Acceptabl e- The augmented inspect ion pr ogram is equ ivalent to G AL L's on e-tim e inspect ion pr ogram and hence, con siste nt with GALL.(See Au dit Report Secti on 3.1.2.2.2.2)Sta inle ss ste el, nickel-al loy , and stee l with nickel-al loy or stai nless st eel claddi ng react or vessel fl anges, nozz les, penetrations, safe ends, v essel she ll s, heads and wel ds (It em 3.1.1-14)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem ist ry and One-Time Inspecti on Co nsis tent w ith GALL, which recomm ends furt her eval uati on.(See Au dit Report Secti on 3.1.2.2.2.3)Sta inle ss ste el;stee l with nickel-al loy or stai nless st eel claddi ng; and nickel-al loy react or Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion N ot A pp lica ble N ot a pp lica ble since no GALL AMR line i tems re late d to this component group/
aging effect Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 287 coolant pressu re bounda ry com pon ents exposed to react or coolant (It em 3.1.1-15) com bination were credi ted i n the OCGS LRA.(See Au dit Report Secti on 3.1.2.2.2.3)Steel (wi th or wit hout st ainl ess steel claddi ng)react or vessel be ltline sh ell, nozz les, and wel ds (It em 3.1.1-17)
Loss of frac ture toug hne ss d ue to neutr on ir radi ati on embritt lement TLAA, eval uated in acc orda nce with Appendix G of 10 CFR Part 50 and RG 1.99.
Appli cant may demonstrate t hat no zzle m ate ria ls are not contr oll ing for the TLAA eval uati ons.T LA A, e va lua ted in acc orda nce with Appendix G of 1 0 CFR Pa rt 50 a nd RG 1.99. TLA As we re revi ewed by NR R/DE staff.(See Au dit Report Secti on 3.1.2.2.3.1)Steel (wi th or wit hout st ainl ess steel claddi ng)react or vessel be ltline sh ell, nozz les, and wel ds;safety inj ecti on nozz les (It em 3.1.1-18)
Loss of frac ture toug hne ss d ue to neutr on ir radi ati on embritt lement Reactor Vessel Survei ll ance Reactor Vessel Survei ll ance (B.1.23)Co nsis tent w ith GALL, which recomm ends furth er ev alua tion. AMP was reviewed by NRR/DE staff.(See Au dit Report Secti on 3.1.2.2.3.2)Stai nless st eel an d nickel all oy t op head en closure vessel fl ange l eak detect ion l ine (It em 3.1.1-19)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng A p lan t-s pe cif ic AMP is to be eval uated.ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1)Ac ce pt ab l e- AS ME ISI pro gr am will adequatel y manage the agi ng effect s;the re fo re , this is con siste nt with GALL.(See Au dit Report Secti on 3.1.2.2.4.1)Stai nless st eel isol ati on condenser com pon ents exposed to react or coolant (It em 3.1.1-20)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng Inser vice Insp ecti on (I W B, IW C, and IW D), W ate r C he m istr y, an d p lan t-s pe cif ic veri fi cati on program ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1), W ater Chem istry (B.1.2), and an augmented inspect ion pr ogram Co nsis tent w ith GALL, which recomm ends furth er ev alua tion. The augm ented inspect ion pr ogram wil l v eri fy that no cracking has occurred.(See Au dit Report Secti on 3.1.2.2.4.2)Stai nless st eel j et pump sensing l ine (It em 3.1.1-25)
Cra ck ing du e to cycl ic l oading A p lan t-s pe cif ic AMP is to be eval uated.N ot a pp lica ble Not appl icabl e, since Oy ster Creek does not h ave jet pumps and jet pump sensing l ines.
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 288 (See Au dit Report Secti on 3.1.2.2.8.1)Steel and stai nless steel isol ati on condenser com pon ents exposed to react or coolant (It em 3.1.1-26)
Cra ck ing du e to cycl ic l oading Inser vice Insp ecti on (I W B, IWC, an d I W D)an d p lan t-s pe cif ic veri fi cati on program ASME Se ct i on XI Inser vice  Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1), W ater Chem istry (B.1.2), and an augmented inspect ion pr ogram Co nsis tent w ith GALL, which recomm ends furth er ev alua tion. The augm ented inspect ion pr ogram wil l v eri fy that no cracking has occurred.  (See Audit Report Secti on 3.1.2.2.8.2)Stai nless st eel steam dryers exposed to react or coolant (It em 3.1.1-29)
Cra ck ing du e to fl ow-i nduced vib rati on A p lan t-s pe cif ic AMP is to be eval uated.BW R Vessel Intern als (B.1.9), w ith GE SI L-644 , R1 recomm endati ons as inc lud ed in BW RVIP-139 Acceptabl e-Consist ent wi th t he current li censing ba sis an d w ill adequatel y manage cracking; t herefor e, thi s is con sist ent wit h GALL.(See Au dit Report Secti on 3.1.2.2.11)Steel (wi th or wit hout st ainl ess steel claddi ng)control rod drive retu rn l ine no zzl es exposed to react or coolant (It em 3.1.1-38)
Cra ck ing du e to cycl ic l oading BW R C R D rive Return Li ne N ozz le BW R C RD Return Line Noz zl e (B.1.6)SS T herm al Sleeve by BW R Vessel Internals (B.1.9)
Co nsis tent w ith GALL Acceptabl e (t hermal sleeves).(See Au dit Report Secti on 3.1.2.1)Steel (wi th or wit hout st ainl ess steel claddi ng)feedwate r noz zl es exposed to react or coolant (It em 3.1.1-39)
Cra ck ing du e to cycl ic l oading BW R Feedwater N ozz le BW R Feedwater Nozzl e (B.1.5)Nickel All oy Thermal Sle eves b y BWR Ve ss el In ter na ls (B.1.9) Co nsis tent w ith GALL.Acceptabl e (t hermal sleeves).(See Au dit Report Secti on 3.1.2.1)Stai nless st eel an d nickel all oy penetr ati ons for control rod drive stub t ubes inst rumentati on, jet pump inst rumentati on, sta nd by liq uid contr ol, fl ux m on itor , an d d ra in line ex pos ed to react or cool ant Cra ck ing du e to stress corrosi on cracking , Int ergranul ar st ress corrosi on cracki ng, cycl ic l oading BW R Penetrat ions and W ater Chem istry BW R Penetrat ions (B.1.8), W ater Chem istry (B.1.2), and BW R Vessel Int ernal s (B.1.9)ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1), W ater Chem istry (B.1.2) Co nsis tent w ith GA LL. A MP B.1.9 provi des addi ti onal assurance.(See Au dit Report Se ction 3.1.2.1.6 and 3.1.2.1.7)Accept abl e - CS &LA S D ra in N ozz le Penetrat ion.(See Au dit Report Secti on 3.1.2.1.8)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 289 (It em 3.1.1-40)
Stai nless st eel an d nickel all oy pi ping, pipi ng components, and piping elem ents great er t han or equal to 4 NPS;nozz le saf e ends and associ ated welds (It em 3.1.1-41)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng BW R Stress Corrosi on Cracking and W ater Chem istry BW R Stress Corrosi on Cracking (B.1.7) and W ater Chem ist ry (B.1.2)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Stai nless st eel an d nickel all oy v essel shell att achment weld s ex pos ed to react or cool ant (It em 3.1.1-42)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng BW R V ess el ID Att achment W elds and W ater Chem istry BW R V ess el ID Att achment W elds (B.1.4) and W ater Chem ist ry (B.1.2)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Stai nless st eel f uel support s and control rod drive assemblies cont rol rod dri ve housi ng exposed to react or coolant (It em 3.1.1-43)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng BW R Vessel Int ernal s and W ater Chem istry BW R Vessel Int ernal s (B.1.9) and W ater Chem istry (B.1.2)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Stai nless st eel an d nickel alloy core shroud, core pl ate, core pl ate bol ts, support str uctur e, top guide, core spray li nes, spargers, jet pump assemblies, contr ol rod dri ve housi ng, nuclear inst rumentati on guide tubes (It em 3.1.1-44)
Cra ck ing du e to stress corrosi on cracking , int ergranul ar st ress corrosi on cracki ng, ir radi ati on-assi sted stress corrosi on cracking BW R Vessel Int ernal s and W ater Chem istry BW R Vessel Int ernal s (B.1.9) and W ater Chem istry (B.1.2) Co nsis tent w ith GALL. Enhanced inspect ions of cracked react or components wil l be conti nued.(See Au dit Report Secti ons 3.1.2.1.3, 3.1.2.1.4, and 3.1.2.1.5)Steel pipi ng, pi ping components, and piping elem ents exposed to react or coolant (It em 3.1.1-45)
W all thinning due to fl ow-accel erat ed corrosi on Flow-Accel erat ed Corrosi on Flow-Accel erat ed Corrosi on (B.1.11)Co nsis tent w ith GALL.(See Au dit Report Section 3.1.2.1)
Nickel alloy core shroud a nd core pla te a cc es s h ole cover (mechanical covers)Cra ck ing du e to stress corrosi on cracking , int ergranul ar st ress corrosi on cracki ng, Inser vice Insp ecti on (I W B, IW C, and IW D), and W ater Chem istry N ot a pp lica ble Not appl icabl e, since Oy ster Creek does no t have access hol e covers.(See Au dit Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 290 (It em 3.1.1-46) ir radi ati on-assi sted stress corrosi on cracking Secti on 3.1.2.3.1)Stai nless st eel an d nickel-al loy react or ve ss el in ter na ls exposed to react or coolant (It em 3.1.1-47)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Inser vice Insp ecti on (I W B, IW C, and IW D), and W ater Chem istry BW R Vessel Int ernal s (B.1.9)Acceptabl e - The OCG S BW R vessel inte rn als AM P is pa rt of t he OCGS ISI program. Al so, all RV I com pon ents will be ex pos ed to trea ted r eactor water; ther efore, the OCGS water ch em istr y AM P w ill be inv oked.(See Au dit Report Section 3.1.2.1.11)
Steel and stai nless steel Class 1 pi ping, fi tt ings an d branch connecti ons< N PS 4 ex pos ed to react or cool ant (It em 3.1.1-48)
Cra ck ing du e to stress corrosi on cracking , int ergranul ar st ress corrosi on cracki ng (for stai nless st eel only), and ther mal and mechanical loadi ng Inser vice Insp ecti on (I W B, IW C, and IW D), W ate r c he m istr y, an d O ne-T im e Inspect ion of ASME C ode Class 1 Sm all-bore Pi ping ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1), W ater Chem istry (B.1.2), an d O ne-T im e Inspection (B.1.24).
Co nsis tent w ith GALL.(See Au dit Report Se ction 3.1.2.1.1 and 3.1.2.1.2)Nickel alloy core shroud a nd core pla te a cc es s h ole cover (welded covers)(It em 3.1.1-49)
Cra ck ing du e to stress corrosi on cracking , int ergranul ar st ress corrosi on cracki ng, ir radi ati on-assi sted stress corrosi on cracking Inser vice Insp ecti on (I W B, IW C, and IW D), W ate r C he m istr y, and , fo r B W Rs with a c re vic e in the ac ce ss ho le covers, augmented inspect ion usi ng UT or other demonstrated ac ce pta ble inspect ion of the access hol e cover welds N ot a pp lica ble Not appl icabl e, since Oy ster Creek does no t have access hol e covers.(See Au dit Report Secti on 3.1.2.3.1)High-st rengt h low all oy st eel t op head closur e studs and nu ts e xp os ed to a ir wit h react or cool ant leakage (It em 3.1.1-50)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar st ress corrosi on cracki ng Reactor Head Closure Studs Reactor Head Closure Studs (B.1.3)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)C as t au ste nitic stai nless st eel j et Loss of frac ture toug hne ss d ue to Thermal Aging and Neutron Thermal Aging and Neutron I rradi ati on Revi ewed by DE.(See Au dit Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 291 pu m p a ss em bly casti ngs; or if iced fuel support (It em 3.1.1-51) ther mal aging a nd neutr on ir radi ati on embritt lement Irr adiat ion Em bri tt lement of CASS Em bri tt lement of CASS (B.1.10)
Secti on 3.1.2.1)Steel and stai nless steel react or cool ant pressure bounda ry (RCPB) pump and valve closure bolt ing, manway and hol ding b olt ing, fl ange bol ti ng, and clo su re bo lting in high-pressure a nd high-tem perature syst ems (It em 3.1.1-52)
Cra ck ing du e to stress corrosi on cracking , l oss of m ateria l due to wear, loss of prelo ad d ue to ther mal effect s, gasket cree p, and self-l oosening Bo lting Integ rity Bo lting Integ rity (B.1.12)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Steel pipi ng, pi ping components, and piping elem ents exposed to closed cycl e cooli ng water (It em 3.1.1-53)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on C los ed-C ycle Cooli ng W ater Syst em N ot a pp lica ble Not appl icabl e, since Oy ster Creek has no such co m po ne nts with in the scope o f l icense re ne wa l.(See Au dit Report Secti on 3.1.2.3.1)Copper al loy pipi ng, pipi ng components, and piping elem ents exposed to closed cycl e cooli ng water (It em 3.1.1-54)
Loss of materi al due to pi tt ing, crevi ce, and galv anic cor rosi on C los ed-C ycle Cooli ng W ater Syst em N ot a pp lica ble Not appl icabl e, since Oy ster Creek has no such co m po ne nts with in the scope o f l icense re ne wa l.(See Au dit Report Secti on 3.1.2.3.1)C as t au ste nitic stai nless st eel Class 1 pump casings, and va lve bod ies an d bo nne ts exposed to react or coolan t > 250&deg;C (> 4 82&deg;F)(It em 3.1.1-55)
Loss of frac ture toug hne ss d ue to ther mal aging embritt lement Inser vice in spect io n (I W B, IW C, and IW D).Thermal aging sus cep tibility screeni ng is not ne ce ss ar y, inser vice inspect ion requirem ents are suffi cient for managing these aging effect s.ASME C ode Case N-481 also provi des an alt ernat ive for pump casings.
Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1). Thermal agin g su sce ptibility screeni ng is not necessary , i nservi ce inspect ion requirem ents are suffi cient for managing these ag i ng ef fe ct s. AS ME Code Case N-481 also pr ovi des an alt ernat ive for pump casings Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 292 Copper al loy> 15% Zn pipi ng, pipi ng components, and piping elem ents exposed to closed cycl e cooli ng water (It em 3.1.1-56)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls N ot a pp lica ble Not appl icabl e, since Oy ster Creek has no such co m po ne nts with in the scope o f l icense re ne wa l.(See Au dit Report Secti on 3.1.2.3.1)C as t au ste nitic stai nless st eel Class 1 pi ping, piping com pon ent, and piping elem ents and contr ol r od drive pressure housings exposed to r eactor coolan t> 250&deg;C (> 482&deg;F)(It em 3.1.1-57)
Loss of frac ture toug hne ss d ue to ther mal aging embritt lement Thermal Aging Em bri tt lement of CASS Thermal Aging and Neutron I rradi ati on Em bri tt lement of CASS (B.1.10) used for R VI co m pon ents Co nsis tent w ith GALL (RVI com ponents).(See Au dit Report Secti on 3.1.2.1)For pum p and valve bodies in I CS and RR systems - see It em 3.1.1-55 RHCS val ve bodi es are not ident if ied f or thi s aging effect since they are exposed to lower tem pera ture. Nickel all oy pi ping, pipi ng components, and piping elem ents expos ed to air -
indoor uncontr oll ed (e xte rn al)(It em 3.1.1-85)
None None None Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Stai nless st eel pipi ng, pi ping components, and piping elem ents expos ed to air -
indoor uncontr oll ed (Ex terna l); air with borat ed water leakage; concret e;gas (I tem 3.1.1-86)None None None Co nsis tent w ith GALL.(See Au dit Report Secti on 3.1.2.1)Steel pipi ng, pi ping components, and pip ing ele m en ts in con cre te (It em 3.1.1-87)
None None N ot a pp lica ble Not appl icabl e, since Oy ster Creek has no such components in t he RCSs  withi n the scope of l icense re ne wa l.(See Au dit Report Secti on 3.1.2.3.1) 293 3.1.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant stated are consistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA is a cceptable.
In OCGS LRA Se ction 3.1.1.2.1, the applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging effec ts rel ated to the i solat ion c onden ser sy stem; nu clear boil er ins trument ation syste m;reactor head co oling syste m; reactor internal s; reactor pressure vessel; a nd reactor reci rculation system componen ts and componen t groups:
* ASME S ection XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD (B.1.1)
* Water Chemistry (B.1.2)
* Reactor Head Closure Stud s (B.1.3)
* BWR Vessel ID Attachment Welds (B.1.4)
* BWR Feedwater Nozz le (B.1.5)
* BWR CRD Return Line N ozzle (B.1.6)
* BWR SCC (B.1.7)
* BWR Penetrations (B.1.8)
* BWR Vessel Internals (B.1.9
)
* Thermal Aging and N eutron Irradiati on Embrittlement of CASS (B.1.10)
* Bolting Integrity (B.1.12)
* Reactor Vessel Surveil lance (B.1.23)
* One-Time Inspection (B.1.24)
* Structures Mo nitoring Program (B.1.3
: 1)
* Lubricating Oil Monitori ng Activiti es (B.2.2)
Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line-items to determine tha t the applicant (1) provides a brief descri ption of the sy stem, components, materi als, and environment; (2) states that the applicabl e aging effects have b een revie wed and are evalu ated in the GALL R eport; and (3) iden tifies those aging effec ts for the isol ation conde nser sy stem;nuclear boi ler instrumentati on system; reac tor head cool ing system; reacto r internals; re actor pressure vessel; and reactor recir culation system components that are subject to an AMR.
3.1.2.1.1 Cracking Due to Thermal and Mec hanical L oading in C lass 1 Smal l Bore Pi ping In the OCGS LRA , Section 3.1.2
.2.12, the appl icant provi ded its further ev aluation to address cracking due to thermal and mechani cal loadi ng in Class 1 small-bore steel, steel with stai nless steel cladd ing, and stain less steel reactor coolan t system and c onnected sy stem piping le ss than NPS 4, in accordance with the draft January 2005 SRP-LR.
In th e OCG S LRA, Sect ion 3.1.2.2.12 , the appli cant stat ed th at Oy ster Cree k will u se th e ASME Secti on XI, i nserv ice i nspect ion, S ubsect ions IWB, IW C, and IWD program (B
.1.1) to mitiga te cracking due to thermal and mechani cal loadi ng of steel and sta inless stee l piping, pi ping components, f ittings and branch connections exposed to re actor coolant within the RCPB, 294 includin g those components in core spray , the reactor reci rculation, sh utdown coo ling, control rod drive, feedwater, main steam, standby liquid contro l, nuclear b oiler ins trumentation, post-accident s ampling syste m, reactor head co oling syste m, reactor water cleanup, and isolation condenser sy stems. Oyster Cree k will a lso use the One-Time Inspection Program (B.1.24) to ve rify that serv ice-induced weld c racking is not occ urring in the s mall-bore pi ping less than NPS 4, includin g pipe, fittings, and branch connecti ons. LRA S ection 3.1.2.2.1 2 further stated that o bserv ed con ditio ns tha t hav e the p otenti al for i mpacti ng the i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's ASM E Section XI In service Ins pection, Subs ections IW B, IWC, and IW D program ( AM P B.1.1), One-Time Ins pection Program ( A MP  B.1.2 4) and verified that these programs are co nsistent w ith the recommend ations in the GALL Repo rt for AMPs XI.M1 and XI.M32, respectively. The project team determined that these prog rams would provide additional assurance that the aging effects ar e adequately managed; ther efore, it is acceptable. On the basis of its review, the projec t team found that the applicant appropriately addressed crackin g due to thermal a nd mechanical loading i n Class 1 small-bore stee l, steel with stai nless steel cladding, an d stainless steel reactor coolant sy stem and connec ted system piping less than NPS 4
.3.1.2.1.2 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking 3.1.2.1.2.1 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking [Item 1]
In the OCGS LRA , Section 3.1.2
.2.4.1, the appl icant provi ded its further ev aluation to address crac king due to S CC a nd IG SCC in C las s 1 s mall-bor e ste el, stee l w ith stai nle ss s teel cla ddi ng, and stainless steel reactor coolant system and connected system piping less than NPS 4, in accordance with the draft Januar y 2005 SRP-LR.
In the OCGS LRA , Section 3.1.2
.2.4.1, the appl icant stated th at Oyster Creek w ill use the Water Chemistry P rogram, B.1.2, to mitigate aging due to stress corrosion crackin g and intergranula r stress corrosion cracking of stainle ss steel pi ping, piping co mponents, fittings and branch connection c omponents ex posed to reacto r coolant w ithin the R CPB, incl uding those components in core spray, th e reactor recircu lation, shutd own cool ing, control rod drive, feedwater, main steam, standby liquid contro l, nuclear b oiler ins trumentation, reacto r head cooling sy stem, reactor wa ter cleanup, p ost-accident sa mpling, and i solation co ndenser s y s t e m s. T h e A S M E S e c t i o n X I I n s e r v i c e I n s p e c t i o n , S u b s e c t i o n s I WB , I WC , a n d I WD program, B.1.1, wi ll be use d with th e Water Chemistry Program to manage th e effects of stress corros ion c racking. Oyste r Cree k wil l als o use the One-Time In specti on Pro gram, B.1.24, to verify that s ervice-in duced wel d cracking is not occurring in smal l-bore pipi ng less than N PS 4, includin g pipe, fittings, and branch connecti ons. The ASM E Section XI In service Ins pection, Subsections IW B, IWC, and IW D programs wi ll also be used for Cla ss 1 stainl ess steel pi pe, pipi ng compo nents, fittin gs, and branch conne ction s that are grea ter tha n or equ al to NPS 4 to verify stress corrosion crackin g is not occurri ng and to ensure the component i ntended function will be maintaine d during the ex tended period of operation. Obs erved condi tions that hav e the potential for i mpacting the inte nded function a re evalua ted or corrected in accordanc e with th e corrective a ction process.
The project team rev iewed th e applica nt's ASM E Section XI In service Ins pection, Subs ections IW B, IWC, and IW D program (AMP B.1.1), Water Chemistry Program (AM P B.1.2), and 295 One-Time Inspection Program (AMP B.1.24), and v erified that these programs are consi stent with the re commend ation s in t he GAL L Repo rt for AM Ps XI.M 1, XI.M 2,and XI.M32 , respe ctiv ely. The project team determi ned that these programs would provide additional assurance that the agin g ef fec ts ar e adeq uate ly man age d; th eref ore, it is ac cept able. On th e bas is of its re view, the project team found that the appli cant appropria tely addre ssed cracking due to SCC and IGSCC in Cl ass 1 small-b ore steel, stee l with stainless ste el claddi ng, and stainl ess steel rea ctor coolant sy stem and connec ted system pi ping less tha n NPS 4.3.1.2.1.2.2 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking [Item 2]
In the OCGS LRA , Table 3.1.2.1.1 for the isolati on condenser system, Table 3
.1.2.1.2 for the nuclear boi ler instrumentati on, and Table 3.1.2.1.6 for the reacto r recirculati on system i nclude AM R li ne i tems for c racki ng du e to SCC and IGSC C of s tain les s ste el p ipi ng an d fit ting s exposed to treated water or steam (internal
). The applic ant proposed to manage this agin g effect using the OCGS BWR stress corrosion cracking program (AM P B.1.7), the Water Chemistry P rogram (AMP B.1
.2), and the AS ME Secti on XI ISI, Subsecti ons IWB, IW C, and IW D program (AMP B.1.1). Generic note E w as cited for these AMR l ine items, i ndicating that the mate rial, envi ronmen t, and aging effec t wer e cons isten t wi th the GALL R eport; howe ver, a d i ff e r e n t a gi n g m a n a ge m e n t p r o gr a m w a s c r e d i t e d. T h e G A L L R e p o r t r e c o m m e n d e d t h e B WR str ess c orr osio n cra cki ng pr ogr am (A MP XI.M7) an d the W ater Chem istr y Prog ram (AMP XI.M2). Pl ant s peci fic note s were also in clud ed in t he OC GS LR A indic atin g th at th e ASME Section XI ISI p rogram was inc luded in addition to the programs recommende d by GALL.
The project team rev iewed th e applica nt's BWR stress corrosion cra cking program (AMP B.1.7)and Water Ch emistry Program (AMP B.1.2), and v erifie d that these programs are co nsiste nt wi th the recommendation s in the GALL Report for AM Ps XI.M7 and XI.M2, respecti vely. The project team determined that the addition of the ASME Section XI ISI progr am (AMP B.1.1) would provide additional assurance that the aging effects ar e adequately managed; ther efore, it is acceptable.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed cracking due to SC C and IGSCC for stainless stee l piping a nd fittings expo sed to treated w ater in the reactor vessel, i nternals, and reactor coolan t systems.
3.1.2.1.2.3 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking [Item 3]
In the OCGS LRA , Table 3.1.2.1.5 for the reactor pressure vessel includes A MR li ne items for crackin g due to SCC a nd IGSC C of sta inle ss stee l CRD stub t ube pe netrati ons ex posed to t r e a t e d w a t e r. T h e a p p l i c a n t p r o p o s e d t o m a n a ge t h i s a gi n g e ff e c t u s i n g t h e O C G S B WR vessel internals program (AMP B.1.9) and the W ater Chemistry Program (AMP B.1.2). Generic note E wa s cited for these AMR li ne items, ind icating that the material, env ironment, and a ging effect were consis tent with the GALL Repo rt; howev er, a different aging management program was credi ted. The GALL Re port recommended the BWR penetrations program (AM P XI.M8)and the Water Chemistry Pro gram (AMP XI.M 2). Plant sp ecific notes w ere also i ncluded i n the OCGS LRA ind icating that the OCGS BWR penetrations program does not address C RD stub tubes; whi ch are addre ssed i n the OC GS BWR vess el in ternal s progra m.The project team rev iewed th e applica nt's eval uation and determined that the BWR vessel internals pro gram (AMP B.1.7) is appropri ate to address the CRD stub tubes. This A MP w as 296 review ed for technical adequacy by the NRR/DE staff, and their ev aluation i s documented i n the SER re lated to the OCGS L RA. Th e proje ct team also revi ewed the OC GS Water Chemi stry Program (AMP B
.1.2), and veri fied that it is consistent w ith the recommend ations in the GALL Rep ort fo r AM P XI.M2. The proj ect t eam d eter mine d tha t the prog rams cred ited to ma nage cracking of he CRD s tub tubes are a ppropriate.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed cracking due to SCC and IGSCC f or stainless steel CRD stub tubes exposed to treated water in the reactor ve ssel, interna ls, and reacto r coolant sy stems.3.1.2.1.3 Cracking Due to IA SCC of Top Guide In the OCGS LRA , Table 3.1.2.1.4 for the reactor intern als, the appl icant credits BWR vessel internals (B
.1.9) and wa ter chemistry (B
.1.2) aging management program to manage cracking due to SCC, IGSCC and IA SCC i n stai nless steel and n ickel allo y cor e shro ud, co re pla te, cor e plate bolts, support structure, to p guide, core sp ray line s, spargers, jet pump as semblies, con trol rod drive housing, nucle ar instrumentatio n guide tubes.
During the audi t and revi ew, the proje ct team noted that several N RC INs, incl uding IN 95-17, addr esse d cra ckin g of BWR to p gui des wi thin the oper atin g ex peri ence of do mest ic a nd fo reig n reactors. The top g uide at Oyster Creek has experienced problem s with cracking since the early nineties. The refore, the appli cant was a sked to describe how crackin g of the top guide w ill be managed by the BW R vessel internals and water chemistry AMPs, as stated in LRA Table 3.1.2.1.4, during the period of ex tended operati on. In its res ponse, the app licant stated that during the 13R refueling outage in 1991, Oyster Creek found a crack on the underside of a top guid e be am. D urin g the 14R and 15R refue lin g out ages in 1 992 and 1994 , add iti onal crac ks were discovered on the underside of top guide beams. As a result of these finding s, UT inspe ction s wer e perfor med for th e compl ete top guide durin g the 16 R refuel ing ou tage in 1996. This comprehensi ve inspe ction identi fied 5 mid-span cracks and 12 UT i ndications in the notches used to interlock th e beams. The majorit y of the cracks and indications were located in the NE quadrant of the top guide. A dditional ly, a sampl e of the top guide was remov ed for metallurgical examinatio n during the 16 R refueling outage a nd the aging mechan ism was determined to b e irradiati on-assisted stre ss corrosion c racking (IASCC). Fu rthermore, a flaw growth eval uation w as prepared for the most significant crac k to predict future crac k growth and to evalua te its effects upon struc tural integrity of the top guide.
The flaw ev aluation p redicted a maximum crack g rowth of 1.6 inches within two cycles of operation and determined that even if this occurred, th e structural i ntegrity of the top guide woul d not be compro mised.The applican t also stated that visual inspection s of the top guide were performed agai n during the 18R refueling outag e in 2000. The visual inspection of the limiting flaw determined that it had g rown a ppro ximat ely hal f of the m aximu m pre dict ed cr ack gro wth val ue dur ing t he two operat ing cy cles s ince the pre viou s insp ectio n. The crack w as sti ll w ell w ithin eval uated limit s and di d not i mpair the str uctura l int egrity of the t op gui de. Ad ditio nal v isual insp ectio ns we re made during the 2 0R refueling outa ge in 2004 to monitor crack growth.
These inspecti ons indicated th at there was no additi onal crack grow th during the pre vious tw o operating cy cles.The app licant f urther stated that it is curren tly planning to inspec t the to p guide du ring th e next refueling outage usi ng UT examinati on. As a min imum, the complete NE quadrant of the top guide wil l be insp ected to determin e if the cracking has been mitigated.
If significant crack growth is i denti fied i n the N E quadr ant, ad ditio nal i nspect ions wil l be p erformed as nec essary to charac teriz e crack growth. As d iscus sed i n BWRVIP-26-A, Oy ster Cr eek is a lea d pla nt wi th 297 respect to top gui de cracking due to its age and top guide fluence a nd all i nspections w ill be performed in accor dance with BWRVI P-26-A. Theref ore, the results of t he 2006 inspections will provide key information in developi ng top guide in spection guide lines, and the frequency and scope of future inspe ctions may be adjusted ba sed on these inspection results. This p rogram provides assurance that th e top guide w ill perform its intended functio ns during the p eriod of extended o peration.As stated in the September 20 05 GALL Repo rt, item IV.B1.17 -9 8), for top guides w ith neutron fluence exce eding the IASC C threshold prior to the p eriod of exten ded operation , the appli cant will inspect 10% o f the top guide l ocations usi ng enhanced v isual in spection techn ique, EVT-1, within 12 years, w ith one-hal f of the inspection s (i.e., 5% of loca tions) to be c ompleted w ithin 6 years af ter ent ering t he period of exten ded oper ation. The applic ant sta ted tha t corre ctive actions will be taken, including repair or replacement of the top guide, if f ound necessary. This is con sisten t wi th the GALL re commend ation s (commi tment 9).On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism, a s recom mended by th e GALL Repor t.3.1.2.1.4 Cracking Due to IA SCC of Core Sh roud In the OCGS LRA, Table 3.1.2.
1.4 for the reacto r internals credits the BW R vessel internals (B.1.9) and water chemistry (B.1.
: 2) AMPs to manage cracking due to SCC, IGSCC and IASCC in stainl ess steel an d nickel al loy core shroud, core pl ate, core plate bolts, suppo rt structure, top guide, core spray lines, spa rgers, jet pump assembl ies, control rod drive housing, nucle ar instrumentation guide tubes.
During the audi t, the project team n oted that a rev iew of ind ustry exp erience has confirmed that cracking has been observed i n core shrouds at both hori zontal (NR C GL 94 03) a nd vertical (NRC IN 97-17) welds. The core shroud at Oyster Cre ek has cracked and has been oper ating in its repaired configuration. In l ight of this, the ap plicant w as asked to descri be how c ontinued aging of the cracked core shroud and i ts repair hardw are wil l be managed b y the BWR vessel internals an d water che mistry AM Ps, as stated i n LRA Table 3.1.2.1.4, during the period of extended o peration. In i ts response, the applicant s tated that cracking ha s affected shrouds fabricated from Type 30 4 and Type 304L stainl ess steel. In 1994 Oyster Creek performed a comprehensiv e examinati on of the shroud and discov ered significant cracking in the co re shroud H4 circumferential weld. Additional minor cracking w as found in the H2 and H6 welds. The examinatio ns consisted of visual e xamination s with cl eaning and U T examinatio ns wherev er practical. D uring the same refuel ing outage, shroud repair hardw are was i nstalled to ensure the shroud could continue to perform its intende d function. The rep air consiste d of 10 tie rods anchored at the top and bottom of the shroud. Details of the repair design were sent to the NRC in 1994. The shroud repair system structural ly repla ces all ho rizontal welds. Therefore, as discussed B WRVIP-76, no further inspection of the horizon tal wel ds is required. Subsequent inspections focused on the v ertical w elds.The applican t also stated that subsequent i nspections o f the repair hardw are have c onfirmed that the tie rod s are in good condition a nd continue to provide reliable structural supp ort for the shroud. Foll owing the gui delines o f BW RVIP-76, Oyster Creek has chosen to implement th e option to inspect all vertical welds. The accessible length of all vertical welds was inspected in 1998 and 2000. All inspected welds were found free of indications, except t hat the V-9 weld indicated a small flaw (less than 2
"), which w as acceptabl e using the ac ceptance criteri a of BWRVIP-76.
298 The applicant furth er stated that Oyster Cree k will complete inspection of all vertical welds in accord ance w ith BWRVIP-76 gui deli nes by 2008. Curre ntly , the v ertica l we lds a re sche duled to be inspected using UT techni ques in 2006.
For the p eriod of extended o peratio n, the ap plicant s tated t hat the inspect ions ident ified ab ove will be continued in accordan ce with BWRVIP-76 guidelines. A ll verti cal wel ds wil l be insp ected every ten years usi ng either EVT-1 or UT examinati on methods. Re pair assembli es wil l be inspected using VT-3 of locking devices, critical gap or contac t areas, bolting and the overall component. The repair anch orage inspections include an EVT-1 inspect ion of the most highly stressed accessi ble load bearing wel d every 10 years.
If indications are identified , they w ill be evaluated and appropri ate correctiv e actions w ill be ta ken.The project team rev iewed th e current status o f the repaired ha rdware and the overal l structural integrity of the s hroud. No pa rticular degradati on was n oted since th e shroud w as repaired.
The appli cant i s perfor ming au gmented inspe ction s of the shroud as w ell a s the r epair ed har dwar e following th e BWRVIP recommendations.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism.3.1.2.1.5 Cracki ng Due to SCC , IGSCC , AND IASCC of Core Spray Sparge rs In the OCGS LRA , Table 3.1.2.1.4 for reactor internal s, the appli cant credits the BWR vessel internals (B
.1.9) and wa ter chemistry (B
.1.2) AMPs to manage cracking due to SCC, IGSCC and IASCC in st ainl ess ste el an d nic kel al loy core sh roud, c ore pl ate, co re pla te bol ts, sup port stru ctur e, to p gui de, c ore s pray lin es, s parge rs, j et pu mp as semb lie s, co ntro l ro d dri ve h ousi ng, nuclear ins trumentation guide tubes.Durin g the au dit, th e proje ct team noted that i nstanc es of cra cking i n BWR core s pray sparger s have been r eviewed in NRC Bulle tin 80-1 3. Core sp ray sparg ers at O yster Cr eek have expe rienc ed cra cking si nce th e late seve nties. In l ight of th is, th e appl icant was asked to descri be how the co ntinu ed agi ng of the cracked  core spray sparger s and their repai r hardw are will be managed by the BWR vessel internals and water chemist ry AMPs, as stated in LRA Table 3.1.2.1.4, du ring the period of extended o peration. In i ts response, the applicant s tated that Oyster Cree k identified crack i ndications in the core s pray spargers i n 1978. One mechan ical clamp was insta lled durin g that re fuelin g outage to prov ide s tructur al su pport fo r a crack i denti fied i n one of the co re spra y spa rgers. Th e ins talle d cla mp ensu res lo ng-term structural inte grity of the sparger, bu t no credit i s taken as a le akage limiter. In 1980, additi onal linear in dications w ere reported. A s a result of the indication s, nine addi tional mecha nical clamps were installe d. All four te e boxes o n both spargers w ere clamped.
The primary roo t cause of the crackin g problems iden tified in 197 8 and 1980 was reported to be high res idual stresses from forcing the spa rger pipes into position during instal lation. Co nsistent w ith this root cause, the crackin g was exp ected to reli eve the resi dual stresses and stop any further growth, as we ll as the i nitia tion o f new c racks. N o furthe r cracki ng or ot her de gradati on of th e spar gers has been repo rted since 19 80.The applican t also stated that recent ins pections in 1998, 2000, 2002, and 20 04 have c onfirmed that the repair clamps are i n good conditi on. Inspectio n of the core spray piping w elds has confirmed that the mi tigation efforts provi ded by the reactor wate r chemistry pro gram have been succes sful, as no ne w cra ck indi catio ns hav e been found. The cor e spra y pi ping a nd spa rgers inside the reactor vesse l at Oyster C reek are inspecte d in accorda nce with BWRVIP-18-A, which 299 speci fies in specti on of co re spra y in ternal s, inc ludi ng pip ing, sp argers, nozz les, a nd bra ckets. There are no AS ME Secti on XI requirements for the Core spray internals. A s prescribed by BWRVIP-18-A, during each refueli ng outage, the follow ing components a re evalua ted using EVT-1 enhanced visual examinatio n methods: access ible core spray pip ing fillet w elds; 25% of the core spray piping brackets; 2 5% of the core spray piping butt w elds; end ca p welds; and T-box cover plate we lds. The follow ing components a re examined using VT-1 vi sual examinatio n methods duri ng each refueling o utage:  nozz le-to-pipe w elds, noz zle-to-orifice welds, sp arger brackets, and repa ir clamps.
For the period of extended operation, the applicant stated that inspections identif ied above will be continued in accordance with BW RVIP-18-A guidelines. If indicat ions are identified, they will be evalu ated and app ropriate correcti ve action s will be taken.
The project team rev iewed th e current status o f the repaired ha rdware and the overal l structural integrity of the c ore spray p iping and sp argers. No partic ular degradatio n was no ted since the core spray s pargers were re paired. The ap plicant i s performing augmented in spections of the core spray p iping and the repaired ha rdware follo wing the B WRVIP recommendations accepted by the staff. On this basis, the p roject team found that th e applica nt is adequatel y managing aging of the core spray spargers.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism.3.1.2.1.6 Cracking Due to S CC of CRD Stu b Tubes In the OCGS LRA , Table 3.1.2.1.5 for the reactor pressure vessel, th e applica nt credits the BWR penetra tions (B.1.8), BWR Vesse l int ernal s (B.1.9) and wate r chemi stry (B.1.2) AMP s to manage cracking due to SCC, IGSCC, an d cycli c loading i n stainless steel and nickel all oy penetrations for co ntrol rod dri ve stub tube s instrumentatio n, jet pump instru mentation, standb y liqui d cont rol, fl ux mon itor, a nd dra in li ne ex posed to rea ctor co olant.During the audi t, the project team n oted that sev eral CRD s tub tubes at OCGS have been leaking recently , and roll expansio n repairs w ere performed to li mit this lea kage. In light of this, the applica nt was asked to describe h ow the con tinued aging of the leaking CRD s tub tubes and their repairs will be managed by the BWR penetrations, BWR vessel i nternals and water chemis try AM Ps, as stated in LR A Tabl e 3.1.2.1.5, d uring t he per iod o f exten ded op eratio n. In its re sponse , the a ppli cant st ated th at duri ng the 1 974 4R refuel ing ou tage, on e spar e inc ore housing was repaired at location 28-05 by roll expansion. During the 18R refueling outage in 2000, whi le performing the RP V pressure test, leakage was o bserved from CRD housing locations 42-43 and 46-39 at the bottom head interface. The stu b tube welds to these CRD housings w ere found to be c racked and leaki ng. A roll e xpansion repair desi gn was engine ered in a ccor danc e w ith BWRVIP-17. UT i nspe ctio ns w ere p erfor med i nsi de th e CR D ho usi ngs where they meet the bottom he ad and als o in the bo re area of the upp er J wel d between the CRD housi ngs and the top of the stub tubes.
No indica tions were identified i n any of these locations.
CRD Housi ng locations 42-43 and 46
-39 were ro ll expa nsion repai red and the leakage was stopped. A post-repa ir UT inspection was performed to verif y that the rolling did not damage the CRD housing mat erial. No indications were found in the roll expansion repair area of either co re location.
The applicant also stated that the spa re incore housing that had been roll expansion repaired in 1974 was last inspec ted in 1983 and no further i ndication o f degradation wa s found. No si gns of 300 leakage have been ident ified for this repai red in core h ousin g since the ro ll re pair w as per formed. This showe d the effectivenes s of the roll e xpansion repair method.
During the 19 R refueling outage in 2002, the two CRD stub tube penetrations that had been roll expansion repaired in 2000 were reinspected by removi ng one control rod guide tube to allow access to the lower plenum area o f the RPV. No cracking were i dentified. No under vesse l leakage w as observed from these location
: s. These inspe ctions demonstra ted that the rol l expans ion repairs have been effective in sea ling the pene trations and p reventing le akage.The applican t further stated that BWRVIP-47 ind icates that i nspection of the stub tubes and CRD housi ngs is not require
: d. Howev er, BWRVIP-17 specifies in-se rvice in spection recommendations for a ll roll-e xpanded C RD housings.
ASME S ection XI speci fies inspectio n requirements for the reacto r vessel p ressure bounda ry. A VT-2 v isual ex amination i s performed during the RPV pressure test to satisfy the requi rements of ASME Section XI. The examinatio ns are performed at the n ominal opera ting pressure of the Class 1 pre ssure boundary. Due to the stub tu be le akage in the bo ttom hea d ide ntifie d in 2 000, Oy ster Cr eek has commit ted to perform inspect ions fo r leaka ge whenever the drywell is m ade acce ssible dur ing out ages. Current ly a minimal amount of leak age is permitted f or rolled repaired housing. This leak age allowance is valid only through the next refueling outag e (2006). If the ASME Code Case N-730 on roll expansio n repair is approved and adopted at Oyster Creek, the n weld repairs wi ll be made for leakin g stub tu bes th at can not be made l eak tigh t usin g a rol l repa ir pri or to re starti ng the p lant.The a ppl ica nt al so s tate d tha t Oy ster Cre ek is purs uin g Cod e Ca se N-730 wi thin ASM E to make these roll e xpansion repairs perman ent. Once the A SME and NRC approv e the Code C ase, the Oyster Creek B WR reactor i nterna ls pro gram wi ll be revi sed to make the se rep airs p ermane nt. If Code Case N-7 30 is not a pproved, the program will be changed to require wel d repair for the previousl y roll e xpansion repaired comp onents prior to the period of extended op eration.The applican t stated that the current program wi ll be con tinued duri ng the period o f extended operation i n accordance with the requirements of the app roved Code Case N-730.
If Code Case N-730 is not approved, the current prog ram will be continued except any leaking components will be w eld re paire d. Ins pecti ons for l eakage w ill be per formed i n acco rdance wit h the r equire ments of the C ode Ca se. VT-2 vi sual exami natio ns wi ll be performe d duri ng the R PV pre ssure t est to satisfy the requi rements of ASME Section XI. If le akage is detected o n a CRD ho using, the leakage wil l be stopped using a roll expansi on repair, prov ided the Co de Case is approved at the time. If leakag e from a stub tube can not be sto pped with an approved roll repair, a weld repair will be made prior to plant restart. If the Code Case is not appr oved, an ASME and NRC approved w eld repair will be made. UT ex aminations o f roll repaired CRD housi ngs bore wi ll be made in accord ance wi th the requirements of the Code Cas e.The project team reviewed the current status of the stu b tubes and their repair, and the overall structural inte grity of the ve ssel bottom hea
: d. No degradati on was n oted since th e stub tubes were repai red. The appli cant is performing au gmented inspectio ns of these stub tu bes follow ing the BWRVI P re com men dat io ns a cce pte d b y t he sta ff.In its letter d ated April 18, 2006, in response to th e staff's RAI B1.9-3 (ML061100138), the applicant c ommitted to revi se LRA Secti on B.1.9 to cl arify its pos ition rela ted to the use of roll/ex pans ion tech niqu es fo r the repa ir o f lea king CRD stub tube s w hic h w ill resu lt i n no lea kage of the CRD of the stu b tubes durin g the extended period of opera tion as follo ws: If Code Case N-7 30 is not a pproved, Oy ster Creek wi ll deve lop a permane nt ASME code repai r plan. This perman ent AS ME c ode re pair c ould be per formed i n acco rdance wit h 301 BW RVIP-5:3-A, which has been approved by the NRC, or an alternate ASME code repair plan which would be submitted for prior NRC approval. If it is determined that the repair plan needs prior NRC a pprov al, Oy ster Cr eek wi ll su bmit th e repa ir pl an tw o yea rs befor e entering the peri od of extended operation.
After the implementa tion of an appro ved permanent roll repair (draft Code Case N-730), if there is a l eak in a CRD stub tube, Oyster Creek w ill w eld repair any leakin g CRD stub tube s during the ex tended period of operation by implementing a permanent NRC approved ASME C ode repair for l eaking stub tu bes th at can not be made l eak tigh t usin g a rol l ex pansi on meth od pri or to restarting the pla nt. Appendi x A.1.9 and item number 9 o f Table A.5 Commitment List will be updated to reflect the abov e commitments. This is Aud it Commitment 3.1.2.1.6-1.
On this basis , the project team found that the appl icant is ad equately managi ng aging of the CRD stub tub es.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism b ased o n the c ommitmen t.3.1.2.1.7 Cracking Due to IA SCC of In-Core N eutron Mon itor Dry Tube s I n t h e O C G S L R A , T a b l e 3.1.2.1.4 fo r t h e r e a c t o r i n t e r n a l s , t h e a p p l i c a n t c r e d i t s t h e B WR pene trat ion s (B.1.8), BWR v esse l in tern als (B.1.9) a nd w ater che mist ry (B.1.2) A MP s to mana ge cracking due to SC C, IGSCC, and c yclic l oading in sta inless stee l and nic kel alloy penetrations for control rod drive stub tubes instrumentation, jet pump instrumentation, standby liquid control, flux mo nitor, and d rain l ine e xpos ed to r eactor cool ant.Durin g the au dit, th e proje ct team noted that se veral reacto r ves sel i n-core neutro n moni tor dry tubes at Oyster Creek have cra cked and been replaced. In light of this, the applicant w as asked to describe h ow the con tinued aging of the cracked in-core n eutron monitor d ry tubes w ill be managed by the BW R vessel internals and water chemistry AMPs, as stated in LRA Table 3.1.2.1.4, during the period of extended operation. In its resp onse, the applicant stated that in 1984 cracking w as identified on 8 of the 12 original in-core dry tube s at OCGS. The cracki ng was found i n the non-press ure retainin g plunger shaft area an d was de termined to hav e been caused by IGSCC as the re sult of a crev ice conditi on associate d with th e original d ry tube design. In 198 4, two of the 1 2 dry tubes were repl aced wi th a new crevice-free si ngle piece plunger shaft desi gn. The other 6 crac ked tubes were technicall y justified a s acceptable for one addit ional opera ting cy cle. In 198 6, the remain ing 10 dry t ubes w ere rep laced so tha t all of dry tubes in serv ice have the same crev ice-free single p iece plun ger shaft design.
The applican t also stated that in 1988 , all dry tubes were inspected a nd no cracking w as identified. IRM-17 was replaced due to a bent tip. In 1991 and 1992, all dry tubes were visually exami ned w ith no findi ngs. In 1994, four dry tubes were vis uall y ex amined wit h no fi ndings. In 1996, IRM-1 5 was v isually examined with no findings. In 1998 , IRM-15 w as examine d with n o findings. In 2000 , five dry tubes were visuall y exami ned to VT-1 stand ards. No crackin g was ident ified, but on e tip was s lightl y ben t. In 2 004, th ree dry tubes were exami ned w ith no findi ngs. These inspection results demo nstrate that the replacem ent design has been eff ective in preventing cracking due to IGSCC.
The applican t further stated that the inspection plan requires inspection s to be condu cted on the in-core dry tubes in acc ordance wi th the requirements of GE SIL-409, Rev ision 2 a nd BWRVIP-47. BWRVIP-47 describes the in spection recommen dations for the l ower ple num 302 region of the ve ssel. BWRVIP-47 indic ates that insp ection of the i n-core housin g and dry tube s are not required, due to the good field history , significant ope rating experi ence, and min imal safety signifi cance. Regard less, at Oys ter Cre ek, the i nspect ions of the i n-core dry t ubes a re performed consistent with the recommendations o f GE SIL-409, Rev ision 2, w hich recommends replacement after 20 years of serv ice. This i s due to the h igh neutron flux where the se components are l ocated, whi ch increases the potential for cracking due to IAS CC after long periods of serv ice. Therefore, six of the dry tube s are schedul ed for replacement in 2006 an d the remaining si x are sched uled for replac ement in 2008
.Durin g the pe riod o f exten ded op eratio n, the appli cant st ated th at Oys ter Cre ek wi ll co ntinu e to follow the guidance of GE SIL-4 09, includi ng periodic v isual ex aminations.
This, in combi nation with the replacement of the entire set of dry tubes wi th new on es of the improv ed design, prov ide s  as sura nce that the dry tube s w ill con tinu e to perfo rm th eir inte nded func tion thro ugh the period o f extended ope ration.The project team rev iewed th e current status o f the in-core neu tron monitor dry tubes. The applicant i s going to replac e these tubes as recommended i n the BWRVIP recommendations and accepted by the staff. On this basis, the project team found that the applicant is adequat ely managing aging of the in-c ore neutron moni tor dry tubes.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism.3.1.2.1.8 Cracking Due to SCC, IGSCC, and Cyclic Loading of Vessel Drain Nozzle In the OCGS LRA , Table 3.1.2.1.5 for the reactor pressure vessel, th e applica nt credits the BWR penetra tions (B.1.8), BWR vess el in ternal s (B.1.9) and wate r chemi stry (B.1.2) AMP s to manage cracking due to SCC, IGSCC, an d cycli c loading i n stainless steel and nickel all oy penetrations for co ntrol rod dri ve stub tube s instrumentatio n, jet pump instru mentation, standb y liqui d cont rol, fl ux mon itor, a nd dra in li ne ex posed to rea ctor co olant.During the audi t, the project team n oted that, in th e OCGS LRA, Tabl e 3.1.1, lin e item 31 di d not include the vessel drain nozzle penetration. The applicant was asked to explain why this nozzle penetr ation is no t incl uded s ince all o ther v essel nozz les a re add ressed in th is li ne ite m. In i ts response, the a pplicant sta ted that the botto m head nozz le is a tw o-inch partia l weld penetration that is made o f carbon steel an d is, therefore, not included with the stainless ste el and ni ckel alloy p enetrations i n LRA Table 3.1.1-31. How ever, the agin g management of this bottom h ead drain noz zle is included in LRA Tabl e 3.1.2.1.5  for the re actor pressure v essel. The pro ject team verified this and found th at ASME Section XI Inservice Inspection, Subsections I W B, IW C, and IWD (B.1.1) and water c hemistry (B.1.2) AMPs a re appropriatel y credited for managing cracking of the vesse l drain no zzle.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism.3.1.2.1.9 Cracking Due to S CC, IGSCC, and Cyclic Loading of Val ve Bodie s During the audi t and revi ew, the proje ct team noted that OCGS LRA Table 3.1.2.1.3 for the reactor head co oling syste m includes line items for restricting orifice and valv e bodies, an d cracking of these compone nts is managed b y the w ater chemistry and one-time i nspection AMPs. Plant specific note 5 to this table stated that ASME Section XI ISI, Subsections IW B,
303 IW C, and IWD, does not apply to these compon ents. The appl icant was asked to clari fy why ASME S ection XI ISI, Sub sections IWB, IW C, and IWD, does not apply to valv es. Also, the applicant w as asked to prov ide the techn ical basi s for concludin g that the wate r chemistry an d one-time ins pect ion prog rams alo ne, w itho ut pe riod ic i nspe ctio ns, w ill ade quate ly mana ge cracking of these compone nts during the p eriod of exten ded operation
.I n i t s r e s p o n s e , t h e a p p l i c a n t s t a t e d t h a t A S M E S e c t i o n X I I S I , S u b s e c t i o n s I WB , I WC , a n d I WD does apply to valv es, but not for miti gation of cracking, exc ept for the Electro matic Relie f Valves (EMRVs) i n the main ste am system. In l ine items R-0 3 and R-55 (s ubsequently deleted from the September 2005 Revision 1 to GALL) which address cracking in piping, GALL does not credit ASME S ection XI ISI, Sub sections IWB, IW C, and IWD for managing cracking in v alves. In the ISI program, only Category B-1, which requi res UT testing of w elds in v alve bod ies, could detect cracks in val ve bodie s. At Oyster C reek, this is ap plied onl y to the EM RVs in the main steam syste m. ISI i nspect ion o f valv es per B-2 i s by VT-3, w hich visu ally insp ects for corros ion, w ear, or erosion, bu t is not credi ted for crack detection
.The applican t also stated that ISI addresse s the wel ds (includi ng the weld between pipe and valve body) and BWRSCC addresses cracking in the heat affected z one. The ISI program i s not credited for crack miti gation in v alves (ex cept for the EM RVs in mai n steam as dis cussed abov e, whi ch is speci ficall y add ressed in th e OC IS I progra m plan).The applican t further stated that Jan uary 2005 draft GALL line item R-55 stated that AMP s for managing cracking are to be augmented to v erify that cracking i s not occurrin g, and stated that one-time insp ection is a n acceptable verificatio n method. The one-time inspecti on aging management program is use d to verify the system-w ide effectivenes s of AMPs su ch as wate r chemistry that are designed to prevent or minimize aging to the ex tent that it w ill not c ause a loss of intende d function duri ng the period o f extended ope ration. The program p rovides inspections that either v erify that unac ceptable degrada tion is no t occurring or that trigger additional actions that will assure the in tended function o f affected components wi ll be maintained d uring the perio d of extended operation. The one-time insp ection aging manageme nt progr am is u sed to confirm the effec tive ness o f the w ater ch emistry program to manage crack initi ation and grow th aging effects during the p eriod of exten ded operation
.The project team found tha t small va lve bodi es do not hav e any w elds to be inspected us ing the inser vice insp ectio n progra m, exc ept the wel ds at t he pi ping co nnecti on lo catio ns, w hich are routin ely inspe cted b y the plan t ISI pr ogram. A lso, t he ex plana tion p rovi ded for using o ne-tim e inspection to verify the effectiveness of Water Chemistry P rogram is consiste nt with GAL L Report recommendati on.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism.3.1.2.1.10 Loss of Materi al Due to Ge neral Corrosi on of External Surface or Carbon and Low Allo y Ste el Co mponen ts In OCGS LRA Tabl e 3.1.2.1.1 for the i solation co ndenser sys tem, Table 3.1.2.1.3 for the reactor head cooli ng system, and Tabl e 3.1.2.1.6 for the rea ctor recirculati on system, the applicant proposed to mana ge loss of material for the external surfaces of carbon an d low a lloy ste el comp onen ts exp osed to an a ir env iron ment using the s tru ctur es mo nito ring prog ram (AMP B.1.31). How ever, the pro ject team noted tha t the GALL Rep ort recommends the e xternal surfaces monito ring agi ng manage ment pr ogram (A MP XI.M36) to mana ge this aging e ffect.
304 The proj ect t eam e valua ted t he app lican t's u se of the s tru ctur es mo nito ring prog ram (AMP B.1.31) as a substitute f or GALL AMP XI.M36 to manage this aging effect, and found it acceptable. The project team's ev aluation i s documented i n Section 3
.3.2.1.6.3 of this au dit and revi ew re port.3.1.2.1.11 Loss of Materi al Due to P itting and Crev ice Corrosi on in Stai nless Steel and Nickel-Allo y Rea ctor Ve ssel I nterna ls Co mponen ts The project team noted that the appl icant did not credit the GALL Report AM R for loss of material due to pitting and crevice co rrosion in stainless ste el and ni ckel-alloy reactor vess el internals co mponents exp osed to reactor water, wh ich is ass ociated w ith Table 1, i tem 3.1.1-47 in the GALL R eport. This w as a n ew A MR th at wa s not i n the d raft Janu ary 2 005 GA LL Rep ort.In Attachment 7, Item R P-26, of its reconc iliation document, the ap plicant state d that loss o f material due to pitting and crevice co rrosion in stainless ste el and ni ckel alloy reactor vess el internal components will be addressed by using the BW R vessel internals AMP to manage this aging effec t.In its letter d ated March 30, 2006 (M L060950408), th e applica nt committed to rev ising the OCGS LRA, Section 3.1, to address loss of material due to pitting and cr evice corrosion in stainless steel and nickel alloy reactor vessel internal components. The BW R vessel internals AMP wil l be u sed to manage this a ging effect. This is A udit Commitment 3.1.2.1.1 2-1.The pro ject tea m revi ewed the ap plic ant's commit ment an d note d that the GAL L Repo rt recommends both the inservi ce inspecti on and w ater chemistry AMPs to manage loss of material for these RVI components. The proj ect team reviewed the OCGS BW R vessel internals AMP and determined tha t this is pa rt of the OCGS ISI AM P. In additi on, although the applican t did not spec ifically identify the water chemi stry AMP as one of the A MPs to mana ge this aging effect, the projec t team r ecogni zed t hat the se RVI compon ents a re ex posed to rea ctor w ater, and the quali ty of this w ater is treated in accordanc e with B WRVIP-130. Thus, the water chemistry AM P is also applicab le to these R VI component. On this basis, the project team found the a pplic ant's com mitm ent t o use the BW R vess el int erna ls ag ing m anag emen t pro gra m (AMP B.1.9) to manage thi s aging effect acceptable
.3.1.2.1.12 Reduction o f Heat Transfer Due to Fo uling In OCGS LRA Ta ble 3.1.2.1.1 for the isol ation conde nser sy stem, th e appl icant propo sed to manage reduction of heat transfer due to fouling for the intern al and ex ternal surfaces of the stainless ste el isola tion condens er heat exch anger tubes ex posed to treated water usi ng the Water Chemis try Pr ogram (A MP B.1.2). Howe ver, t he pro ject tea m noted that th e GALL Repor t recommends both the Water Chemistry Program (XI.M2) an d the One-Time Inspe ction Program (XI.M32) to manage th is aging effect. The appl icant was asked to justify u sing the Water Chemi stry P rogram al one to manage this a ging effect
.In Attachment 3, Item E P-34 of its recon ciliatio n document, the a pplicant sta ted that this l ine item for stainles s steel heat exchanger tube s in treated w ater, addressin g reduction of heat transfer due to fouli ng, invoked the Water Chemistry Program with no further eval uation required in Ja nuary 2005 and ha s been change d in S eptembe r 2005 to w ater ch emistry and o ne-tim e inspection, with a further evaluati on of aging effects. There are 2 instances of thi s line i tem being used i n the Oyster C reek license re newal a pplication , both in the isolatio n condenser system, for heat ex changer tubes, in ternal and e xternal. Tw o new l ine items i nvoking the 305 One-Time Inspection Program for reduction of heat transfer due to fouling wil l be added to the OCGS LR A as a resul t of the change to the GALL R eport.The project team noted that the abov e revisi on to the LRA is incl uded in au dit commitment 3.2.2.2.4-1, w hich is di scusse d in S ectio n 3.2.2.2.4.2 of this audit and re view report.Conclusio n The project team has evaluated the appli cant's claim o f consistency with the GALL Report an d the above commitments. The project team also has review ed information pe rtaining to the applicant's consideratio n of recent operati ng experienc e and proposa ls for managing associ ated aging effects. On the basis of its revie w, the projec t team found that the AMR resu lts, whic h the applicant c laimed to be consistent w ith the GALL R eport, are consi stent with the AMRs in the GALL R eport.3.1.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In OCGS LRA Se ction 3.1.2.2, th e applica nt provide d further evalu ation of aging management as recommended by the GALL Rep ort for the isola tion condens er system; nucl ear boiler instrumentation system
; reactor head cooling system; reactor internals; react or pressure vessel; and reactor reci rculation sy stem components an d component groups.
The applica nt also provided information concern ing how i t will manage the relate d aging effects.
Project Team Eval uation For some AM R line-ite ms assigned to the project team in the OCGS LRA Tabl e 3.1.1, the GALL Report recommends further evaluati on. When further evaluation is recommended , the project team review ed these further ev aluations p rovided i n OCGS LRA Se ction 3.1.2.2 a gainst the criteria prov ided in th e SRP-LR S ection 3.1.2.2.
The project team's assessments of these evaluati ons is docu mented in thi s section. Thes e assessments are applicab le to each Table 2 AMR li ne-item in Se ction 3.1 ci ting the item in Table 1.3.1.2.2.1 Cumu lati ve F atig ue D amage In OCGS LRA Section 3.1.2.2.1 , the applicant stated that f atigue is a TLAA, as defined in 10 CFR 54.3. Appl icant s must e valu ate TLA As in accord ance w ith 10 CFR 5 4.21(C)(1).During the audi t, the project team d etermined that so me of the TLAAs for the rea ctor vessel and its internal s may not ha ve expl icit fatigue anal ysis cal culations (th erefore, they may not have the calc ulat ed cu mula tive u sag e fa ctor s), since the pl ant wa s orig inall y desig ned ba sed o n ASME Power Pi ping Code B3 1.1. Specifica lly, in LRA Table 3
.1.2.1.4 for the reactor internals, an d Tabl e 3.1.2.1.5 for the reac tor p ress ure v esse l, th e ap pli cant cred ited TLAA to ma nage cumulative fatigue damage for certain components. The a pplicant w as asked to confirm tha t the cumulative usage factors for these co mponents are av ailable, and that fatigue cy cles are tracked in order to man age the cumulati ve fatigue damage by TLAA in acc ordance wi th 10 CFR 54.21(c)(1)(I) or (ii), as claimed in the LRA.
In its response, the applicant stat ed that the use of TLAA as an ag ing management program in LRA Table 3.1
.2.1.4 and Table 3.1.2.1.5 indi cates that the cu rrent licensi ng basis w as review ed 306 for TLAAs and th e fatigue anal ysis was eval uated wher e one exis ted for t hat co mponen t. Howeve r, several components for wh ich TLAA w as identified as the aging mana gement program for the cumulativ e fatigue aging effect do not ha ve fatigue anal yses. These c omponents incl ude the reactor internals (T able 3.1-1, item 5) and the contro l rod drive return line (CRDRL) nozzle and feedwater nozzle thermal sleeves (Table 3.1-1, item 2). In the absence of a fat igue analysis for these compone nts, the eff ects of cumulative fat igue are managed by other AMPs, in accord ance w ith 10 CFR 5 4.21(c)(1)(ii i).In its letter d ated April 17, 2006 (M L 061150320
), the appli cant committed to re vise the AMR li ne items in LRA Table 3.1.2.1.4 for the reactor intern als, and Tabl e 3.1.2.1.5 for the rea ctor pressu re ve ssel t o del ete the referen ce to TL AA for c ompone nts w here a TLAA d oes no t exi st. Furthe r, the a ppropr iate a ging man agement program w ill be id entifi ed w ith an "E" i ndustr y standa rd note and a plan t speci fic note stati ng: "Ther e is n o fatigue anal ysis for thi s compo nent. The aging effect of cumulativ e fatigue is managed by the BWR Vessel Inte rnals aging management program."  Simi larly for the feedwater noz zle and CRD return l ine nozz le thermal sleeves, th e note wi ll read: "There is no fatigue ana lysis for thi s component. The aging effect of cumulative fatigue is managed b y the BWR Feedwater Nozzl e (or BWR CRD Return Li ne Nozz le, as appl icabl e) agin g manageme nt progr am."  This is A udit Commitment 3.1.2.2.1
-1.The project team rev iewed th e applica nt's response and found that, i n the absence of a fatigue analysi s for  components for w hich a TLAA was credi ted, the effects of cumulativ e fatigue wil l be managed by othe r AMPs i n accordance with 10 CFR 54.21(c)(1)(i ii) and  i s acceptable
.The evaluation of the TLAAs was perf ormed by NRR/DE staff and is addres sed separately in Section 4 of the SER related to the OCG S LRA.3.1.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion 3.1.2.2.2.1 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 1]The project team rev iewed OC GS LRA Secti on 3.1.2.2.2.1 agai nst the criteri a in SRP-L R Section 3.1.2.2
.2.1.SRP-LR Secti on 3.1.2.2.2.1 state d that loss o f material due to general, pittin g, and crevic e corros ion c ould occur i n the s teel P WR steam gener ator sh ell a ssembl y ex posed to sec ondary feedwater and steam. Loss of materia l due to genera l, pitting, and crevice c orrosion coul d also occur for the steel top head en closure (w ithout cladd ing) top head n ozzles [vent, top h ead spray or reactor core i solation co oling (RCIC), a nd spare] ex posed to reacto r coolant. The existing program relies on control of reactor water chemi stry to mitigate corrosion. Ho wever, co ntrol of water chemi stry does no t preclude l oss of material d ue to pittin g and crevic e corrosion a t locations o f stagnant flow cond itions. Therefore, the effectiveness of the ch emistry control program s hould be v erifie d to en sure th at corr osion is no t occur ring. Th e GALL Repor t recommends further ev aluation o f programs to verify th e effectiveness of the chemistry co ntrol program. A one-tim e inspection of select component s at susceptible locations is an acceptable method to determin e whether an aging effect is not o ccurring or an agi ng effect is progressing very sl owly such that the co mponent's in tended function w ill be mai ntained duri ng the period o f extended o peration.In Sec tion 3.1.2.2.2.1 of th e OCGS LRA, t he app lica nt stat ed tha t loss of materi al du e to general, pitting, and crevice corrosion in a PW R steel steam generator shell assembly is 307 applicable to PW Rs only. The project team concurr ed with the applicant's evaluation that this aging effec t is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.With regard to loss of material du e to general, pi tting, and crev ice corrosio n for the steel top head enclos ure (witho ut cladding) to p head noz zles, the applicant s tated that the Oy ster Creek top head enclosure is clad with stainless steel and not subject to loss of material from g eneral, pitting and cre vice corros ion and the refore, no aging program is required. The project te am concurred with the applicant's evaluation since the stainless steel cladding precludes general, pitting, and crev ice corrosio n.3.1.2.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 2]The project team rev iewed OC GS LRA Secti on 3.1.2.2.2.2 agai nst the criteri a in SRP-L R Section 3.1.2.2
.2.2.SRP-LR Section 3.1.2.2.2.2 st ated that loss of mate rial due to pitting and crevice corrosion could occur in stai nless steel BWR isolation conden ser components e xposed to reactor coolan
: t. Loss of material due to general, pitti ng, and crevi ce corrosion could occur in steel B WR isolation conde nser co mponen ts. The exis ting pr ogram rel ies o n cont rol of r eactor wate r chemi stry t o mitigate corrosion. Howev er, control of w ater chemistry does not precl ude loss of materi al due to pitting and crevice co rrosion at lo cations of stagnant flow conditions. Therefore, the effectiveness of the ch emistry control program should b e verified to ensure that co rrosion is n ot occurring. The GALL Report recommends further evaluati on of programs to veri fy the effectiveness of the ch emistry control program. A one-ti me inspection of select compone nts at susceptible locations is an accep table method to determine w hether an aging effect is not occurring or an a ging effect is progressing v ery slow ly such that the componen t's intended function wi ll be main tained duri ng the period o f extended ope ration.In the OCGS LRA , Section 3.1.2
.2.2.2, the appl icant stated th at Oyster Creek w ill use the Water Chemistry P rogram, B.1.2, to manage agin g of stainless stee l tube sid e components of the isolation condenser sy stem exposed to reactor cool ant. The program activ ities prov ide for monitoring and c ontrolling of w ater chemistry using station p rocedures and processes for the prevention or mitigation of loss of material aging effects. The ASME Section XI Inse rvice Inspection, Su bsections IWB, IWC, and IW D program, B.1.1, w ill be u sed with the Water Chemistry P rogram to manage loss o f material. The AS ME Secti on XI Inservic e Inspection program will be enhanced to perform inspecti on of the isol ation conden ser tube side components, inc luding temperature and radioa ctivity monitoring of the sh ell-side water, eddy curren t testi ng of the tubes, and i nspect ion (V T or UT) o f the tub eshee t and c hanne l hea d to ensure that si gnificant degradation is not occu rring and the co mponent intend ed function w ill be maintained d uring the exte nded period of operation. Obs erved condi tions that hav e the potentia l for im pacting the inten ded fun ction ar e evaluate d or corr ected in a ccorda nce with the correc tive action process
.During a tele conference on Feb ruary 2, 200 6, the appli cant indica ted that, thus far no augmented inspecti ons have been performed on c omponents associ ated with the isola tion condenser, and that the propos ed augmented ins pections w ill be a pplicabl e as a part of an aging management program (AM P) during the ex tended period of operation. In RAI-3.1.1-1, date d March 20, 2006 (ML060550419), the staff requested that the appl icant provi de the follow ing information so tha t an assessment c an be made as to the effectivene ss of the future augmented inspection program of the isolati on condenser and its compon ents.
308 (1) Previou s experie nce related to the frequency of occu rrence of pitting an d crevice corrosion in the isola tion condens er and its co mponents.(2) Previou s inspectio n methods and the inspecti on frequency that w ere implemented prior to the rep lacement of some of the isolation condenser compo nents.(3) Crit eria fo r estab lishing futur e augm ented ins pection freq uency.In its letter d ated April 18, 2006 (M L061100138), th e applica nt provide d the follow ing response to the RAI.The carbon steel Isolation C ondenser shel ls were fabricated wi th a nominal thickness of 0.375 inche s, wi th a co rrosio n all owan ce of 0.1 00 in ches. In 199 6, NDE tests w ere performed on the Isol ation Conde nser "B" shell to determine th e existen ce and ex tent of pitting corrosio
: n. Plant ex perience has indicated that the condi tion of the "B" i solation conde nser i s the mo re li miting of the tw o cond ensers. The re sults of the N DE tes ts showed an average shel l thickness of 0.38 9 inches w ith a standard deviati on of 0.014 inches. In 2 002, the "B" i solation co ndenser shel l was a gain examin ed. Visual examination results indicated blistering of the coating at or near the waterline. NDE results from tests performed a t locations just below the waterl ine judged to h ave the highes t proba bili ty for a ccele rated c orrosi on yi elded readi ngs we ll w ithin the co ntrol limit s computed from the 1996 readings, and above or c lose to the fabri cation nomin al thickness of 0.375 i nches.Prior to tube bundle repl acement in the Oyster Creek iso lation cond ensers, the stai nless steel tube bu ndles w ere found to be s ubject to crevi ce corrosion.
Tube OD crevi ce corrosion located in the crevice form ed by the roll expansion process during tube bundle fabrica tion w as acc elera ted by elev ated i solat ion c onden ser temp erature s due in pa rt to condensate return valve leakage. In addi tion, numerous th ermal cycl es were ca used by isolation condenser w ater level oscillati on due to the valve leakage conditi on, and sy stem service as the primary heat sink durin g reactor shutdow ns employi ng opening and closing of the co ndensate return valves as needed to limit coo ldown ra te. Subsequent correction of the c ondensate return valve leakage conditi on and changes to isolatio n condenser ope ration strategy during reactor coo ldown h ave significa ntly reduce d the thermal cycl ing that exac erbated the crev ice corrosio n condition s which existed i n the original tube bundle as semblies.In 1996 and again in 200 2, VT and UT in spection method s were use d to eval uate the condition o f the isolatio n condenser s hell. Duri ng the evalu ation of the is olation conde nser tu be le akage co nditi ons, U T and th ermograp hy te sting w ere us ed to determine the condensate/
steam interfac e in the isolation condensers, and acoustic monitoring of boil ing intensity was used to determine th e presence of strati fied tube intern al co nditi ons. Weekly temper ature m onito ring of i solat ion c onden ser temp erature and mont hly radioac tivity sam pling of the shell wat er (sub seque ntly chang ed to week ly)have been performed since before tube b undle repla cement.Correction of the valve leakage conditi on has signi ficantly redu ced the number of isolation condenser w ater level oscillati ons and resul tant thermal cy cles appli ed to the isolation condenser compo nents. The Oyste r Creek isolati on condenser tube bundle s were replaced in the "A" isolation condenser in 2000 and in the "B" isolation condenser in 1998, utili zing improv ed materials that are more resi stant to intergranul ar stress corrosi on 309 cracking. The phys ical configurati on of the isol ation conden sers and inte rnal surfaces of the channel head require cu tting and re-w elding of pressure boundary piping. Beca use of the significant red uction in frequency of initi ating conditi ons, and the re lativel y recent replacement of the tube bundle s with i mproved materia ls, these in spections w ill be performed once durin g the firs t ten y ears o f the pe riod o f exten ded op eratio n. Radioactiv ity and te mperature monitori ng of the shell s ide wate r, as specified in the GALL recommendatio ns for isolatio n condenser a ging management, are curren tly bein g performed wee kly, a nd w ill conti nue th roughou t the p eriod of ext ended opera tion. Additional ly, durin g the NRC Regi on 1 Inspecti on, AmerGen has c ommitted to performing a one-time UT i nspection of the "B" Isolation Condenser sh ell for pittin g corrosion, prio r to the period of extended op eration. Pl ant experi ence has in dicated that th e condition of the "B" isol ation conden ser is the more limiting of the tw o condensers.
This commitment wil l be a dded t o the Ta ble A.5 Lic ense R enew al Co mmitment List Item No. 24. This is Au dit Co mmitment 3.1.2.2.2-1.In a follow-up discussi on, the staff asked the app licant to cl arify its pl anned correcti ve action activiti es if there any tube leakage obs erved. In i ts letter (2130-0 6-20331) dated May 3, 2006, the ap plic ant sta ted tha t: Should any of the monitoring a ctivitie s conducted o n the isol ation conden sers reveal conditions potentiall y indic ative of a tub e leak, initi ation of the correc tive acti on process would re sult in an engineering ev aluation o f the observed condition.
Confirmatory testi ng could be p erformed, which may inclu de controlle d-inventory testing of the shel l water volume with the bundle side pressurized, and enhanced radioactivity analysis of shell side water. Upon confirmation of tube leakage, repair or plug ging of leaking tubes would be performed, and i f warranted, edd y current testi ng of the bundles to determine ex tent of condition would be considered. Conceivably, depending on the extent, repair could consist of tube b undle repl acement. Approp riate correctiv e action to c orrect a tube leakage condition in the isolation condensers would be taken, regardless of when it occurred durin g the period of ex tended operati on.The proj ect t eam r eviewe d the appli cant's res pons e to t he RAI , W ater Chem istr y Prog ram (AMP B.1.2) and AS ME Secti on XI ISI, Subsecti on IWB, IW C and IWD program (AMP B.1.1) and det erm in ed tha t th ese pro gra ms a nd the com mit men t to pe rfor m on e-t ime UT i nsp ect io n o f ?B"Isolation C ondenser inc lude activ ities that are adequate to manage loss of material due to pitti ng and crevi ce corrosion in stainl ess steel BWR isolati on condenser components. The p roject team determined that the loss of materi al in the isolation condenser compo nents expos ed to reactor coolant w ill be a dequately mana ged by the i nservice i nspection an d water che mistry programs.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.1.2.2.2.2 for further ev aluation.3.1.2.2.2.3 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 3]The applicant addressed loss of material due to pitting and crevice corrosion f or stainless steel, nickel all oy, and stee l with nickel all oy or stai nless steel cladding rea ctor vessel flanges, nozz les, penetrations, saf e ends, vessel shells, heads and welds exposed to reactor coolant in , Item RP
-25 of its reconci liation d ocument. The appl icant also addressed lo ss of material due to pitting and crevice co rrosion for stainl ess steel, stee l with nickel all oy or stai nless steel clad ding, a nd ni ckel al loy reacto r cool ant pre ssure b ounda ry co mponen ts ex posed to reactor coolan t in Attachment 7, Item RP-27 of its reconcilia tion document. The refore, the 310 project team revi ewed those evaluati ons against the criteria in SRP-LR Secti on 3.1.2.2.3. R P-25 and RP-27 w ere ne w AM R lin e items that w ere no t in th e draft J anuary 2005 GALL R eport.SRP-LR Section 3.1.2.2.3 stat ed that loss of material due to pitt ing and crevice corrosion could occur for stainle ss steel, ni ckel alloy , and steel w ith stainle ss steel or n ickel allo y claddi ng flanges, nozzl es, penetration s, pressure hous ings, safe ends, and vessel shells, hea ds and welds e xposed to reactor coolan
: t. The existi ng program relies o n control of reacto r water chemistry to mi tigate corrosion.
Howev er, control of w ater chemistry does not precl ude loss of material due to pitting and crevice co rrosion at lo cations of stagnant flow conditions. Therefore, the effect iveness of the chemistry control prog ram should be verified to ensure that cor rosion is not occurring. The GALL Report reco mmends further eval uation of programs to v erify the effectiveness of the ch emistry control program. A one-ti me inspection of select compone nts at susceptible locations is an accep table method to determine w hether an aging effect is not occurring or an a ging effect is progressing v ery slow ly such that the componen t's intended function wi ll be main tained duri ng the period o f extended ope ration.In Attachment 7, Item R P-25 of its recon ciliatio n document, the a pplicant sta ted that the specifications of new li ne item RP-25 will be addressed as follow s: The aging effect of loss of material due to pitting and crevice co rrosion in reactor vesse l flanges, nozz les, penetrati ons, pressure housi ngs, safe ends, and v essel shel ls, heads an d welds will be managed through the use of the water chemistry and one-tim e inspection programs.
The selection of susceptible locations for on e-time inspecti ons wil l be based on severi ty of conditi ons, time of serv ice, and lowest de sign margin.
In its lette r dated Marc h 30, 2 006 (M L0609 50408), the a ppli cant co mmitted to rev ise th e OCGS LRA Sectio n 3.1 to addres s loss of material due to pitti ng and crevi ce corrosion for stainless steel, nickel alloy, a nd steel w ith stainle ss steel or n ickel allo y claddi ng flanges, nozz les, penetr ation s, pres sure h ousin gs, safe e nds, a nd ve ssel s hell s, hea ds and wel ds ex posed to reactor coolan
: t. The aging effect wil l be managed thro ugh the use of the w ater chemistry and one-time insp ection programs. The selection o f susceptible l ocations for one-ti me inspection s wil l be b ased o n sev erity of cond ition s, time of serv ice, a nd lo west design margin. This is A udit Commitment 3.1.2.2.2-2.
The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill manage l oss of ma terial due to pitti ng and crevi ce corr osion. In ad ditio n, the project team re view ed the appl icant's One-Time Inspection Pro gram (B.1.24) and v erified that thi s aging management program i ncludes inspections of the reactor v essel intern als to detect loss of material as a means o f verifying the effect iveness of the W ater Chemistry Program. The project team det ermined that these AMPs will adequately man age loss of material due to pitti ng and crevi ce corrosion in reactor v essel flanges, nozzl es, penetration s, pressure hous ings, safe ends, and vessel shells, hea ds and welds.In A ttac hmen t 7, I tem R P-27 of it s rec onci lia tion doc umen t, th e ap pli cant stat ed th at for pip ing, piping compone nts, and pipi ng elements in reactor coolan t pressure boun dary syste ms and systems wi th RCPB i nterface, the Oyster C reek LRA used l ine items EP
-32, A-58, and AP-57 for loss of material due to pitti ng and crevi ce corrosion of stainless ste el in treate d water (i ncluding reactor coolant), using the water chemistry and one-time inspection prog rams. This is in conformance wi th the September 2005 Revi sion 1 of GALL.
311 The project team rev iewed l ine items EP
-32, A-58, and AP-57 in the GALL Report a nd determined that these line items address l oss of material d ue to pittin g and crevic e corrosion o f stain less s teel i n treat ed w ater, a nd rec ommend using t he w ater ch emistry and o ne-tim e inspection programs to manage this aging. Therefore, the project team f ound the applicant's evaluati on acceptabl e since it is consisten t with GALL
.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.1.2.2.2.3 for further ev aluation.3.1.2.2.2.4 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 4]Loss of material due to general, pitting, and crev ice corrosio n in the stee l PWR steam generator upper and lower shell and transition cone exposed to secondary feedwater and steam is applicable to PW Rs only. The project team determ ined that this aging ef fect is not applicable since Oyste r Cree k is a B WR plant.3.1.2.2.3 Loss of Fracture Toughne ss Due to Ne utron Irradiatio n Embrittlement 3.1.2.2.3.1 Loss of Fracture Toughne ss Due to Ne utron Irradiatio n Embrittlement [Ite m 1]The project team rev iewed OC GS LRA Secti on 3.1.2.2.3.1 agai nst the criteri a in SRP-L R Section 3.1.2.2
.3.1.SRP-LR Secti on3.1.2.2.3.1 stated that neutron i rradiation e mbrittlement is a TLAA to be evaluated for the period o f extended ope ration for all ferritic materials that have a neutron fluence greater than 10 17 n/cm2 (E >1 MeV) at the end of the license renewal term. Cert ain aspect s of neu tron i rradia tion e mbrittl ement a re TLAA s as de fined i n 10 C FR 54.3. TLAA s are required to be e valuated in accordanc e with 1 0 CFR 54.21 (c)(1). This TLAA i s addressed separa tely in Se ction 4.2, ?Reactor Vessel Neutron Embritt lement Analysis," of this SRP-LR.
In the OCGS LRA Section 3.1
.2.2.3.1, the appl icant stated th at for Oyster Creek, the effects of increased ne utron fluence on the fracture toughness o f the reactor vess el beltli ne plates an d welds i s discussed in Section 4.2 of the OCGS LR A. Also di scussed in Section 4.2 is the impact on the ves sel's temperatu re - pressure c urves and weld ex am requirements.
TLAAs were evaluated by the N RR/DE staff and w ill be d ocumented in the SER rel ated to the OCGS LRA.3.1.2.2.3.2 Loss of Fracture Toughne ss Due to Ne utron Irradiatio n Embrittlement [Ite m 2]The project team rev iewed OC GS LRA Secti on 3.1.2.2.3.2 agai nst the criteri a in SRP-L R Section 3.1.2.2
.3.2.SRP-LR Secti on 3.1.2.2.3.2 state d that loss o f fracture toughness due to neutron irradi ation embrittlement coul d occur in B WR and PW R reactor ve ssel beltl ine shell , nozzl e, and we lds exposed to reactor coolan t and neutron flu
: x. A reacto r vessel ma terials surv eillance program monitors neutron irradiation embrittlement of the reactor vesse
: l. Reactor v essel surv eillance program is plant-s pecific, depend ing on matters such as the composi tion of limiti ng materials, availab ility o f surveilla nce capsule s, and projected fluence lev els. In acco rdance wi th 10 CFR Part 50, Appen dix H, a n applica nt is required to submit its p roposed wi thdrawal schedule for approval prior to impl ementation. Un tested capsule s placed i n storage must be mai ntained for 312 future insertion.
Thus, further staff evaluation is requir ed for license renewal. Specific recommendations for a n acceptable AMP are provided in Chapter XI, Section M 31 of the GALL Report.In the OCGS LRA Section 3.1
.2.2.3.2, the appl icant stated th at the Oyster C reek reactor vess el surveill ance program, B.1.23, is based on the BWR integrated survei llance program (IS P) and satisfies the requi rements of 10 CFR Part 50, Appen dix H. The reactor vess el survei llance aging ma nagemen t progra m incl udes p eriod ic tes ting of me tallu rgical surv eill ance s amples to monitor the progress of neutron embrittle ment of the reactor pres sure vessel as a function of neutro n fluen ce, in accord ance w ith Re gulato ry Gui de (RG) 1.99, ?Radiation Embrittlement of Reactor Vessel Material s," Revisi on 2. BWRVIP-116 identi fies and schedu les additi onal capsules to be withdrawn and tested during the license renewal period. Oyster Creek will continue to p articipate i n using the i ntegrated survei llance program d uring the perio d of extended operation by implementing th e recommendation s of BWRVIP-116, and by ad dressing any additional actions required by the associated NRC Safe ty Evaluation with BWRVIP-116, onc e it is ap prove d. Obse rved condi tions that h ave t he pot entia l for i mpacti ng the i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's further eva luation an d determined th at the reactor vesse l surv eill ance p rogram (A MP B.1.23) is ap propri ate to manage t he lo ss of frac ture toughness due to neutron irradi ation embrittl ement in reactor vessel be ltline sh ell, noz zle, and wel ds ex posed to rea ctor co olant and n eutron flux  The tec hnica l ev aluat ion o f this p rogram to determi ne its adequa cy w as per formed by NRR/D E staff, an d is a ddress ed in the SE R rela ted to the OCGS LRA.
3.1.2.2.4 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking 3.1.2.2.4.1 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking [Item 1]
The applican t addressed crac king due to SCC and IGSCC i n the top hea d enclosure vessel flange leak detectio n lines i n LRA Secti on 3.1.2.2.4.2, i n accordance with the draft January 20 05 SRP-LR. Therefore th e project team rev iewed OC GS LRA Secti on 3.1.2.2.4.2 agai nst the criteria in SRP-LR Secti on 3.1.2.2.4.1.
SRP-LR Secti on 3.1.2.2.4.1 state d that cracking due to SCC and IGSCC could occur in the stainless ste el and ni ckel alloy BWR top head enclosure vessel flan ge leak detection lines. The GALL R eport r ecommen ds tha t a pl ant-sp ecific AMP be ev aluat ed bec ause e xist ing pro grams may not be capable of mitigating or detecting crack ing due to SCC and IGSCC.
In th e OCG S LRA Se ctio n 3.1.2.2.4.2, th e appl ican t sta ted t hat O yste r Cre ek wil l use t he ASME Section XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD program, B.1.1, to ensure the reactor vesse l flange leak dete ction lin es are not ex periencing agin g effects caused by S CC and IGSCC. The Oy ster Cr eek ISI program u tili zes a VT-2 v isual exami natio n on th e lin e prio r to reactor cavi ty drain d own duri ng each refueling o utage. This exa mination w ill be c redited for managing cracking. Observ ed conditio ns that have the potential for impacting the i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's ASM E Section XI In service Ins pection, Subs ections IWB, IW C, and IWD program, B
.1.1, a nd det ermine d that it w ill adequa tely manage the effect s
313 of stress corros ion c racking in the stain less s teel v essel flange l eak dete ction line. Mo reove r, a VT-2 visual examinati on of the line prior to reacto r cavity drain dow n during each refueling outage wil l provid e an additi onal method for detecting any incipien t degradation.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.1.2.2.4.1 for further ev aluation.3.1.2.2.4.2 Cracking Due to S tress Corrosion Cracking and Intergranu lar Stress Co rrosion Cracking [Item 2]
The applican t addressed crac king due to SCC and IGSCC i n the stainl ess steel i solation condenser compo nents in LR A Section 3
.1.2.2.4.3, in ac cordance w ith the draft Janua ry 2005 SRP-LR. Therefore th e project team rev iewed OC GS LRA Secti on 3.1.2.2.4.3 agai nst the criteria in SRP-LR Secti on 3.1.2.2.4.2.
SRP-LR Secti on 3.1.2.2.4.2 state d that cracking due to SCC and IGSCC could occur in stai nless steel BWR isolation c ondenser compon ents expose d to reactor coo lant. The ex isting program relie s on co ntrol of reacto r wat er che mistry to miti gate SC C, and on AS ME S ectio n XI ISI. Howe ver, t he ex istin g program shoul d be a ugmented to det ect cra cking du e to SC C and IGSCC. The GAL L Repo rt reco mmends an augme nted p rogram to incl ude te mperatu re and radio activ ity monitoring of the she ll-side w ater, and eddy current testing of tube s to ensure tha t the component's i ntended function will be maintaine d during the pe riod of extend ed operation.
In the OCGS LRA Section 3.1
.2.2.4.3, the appl icant stated th at Oyster Creek w ill use the Water Chemistry P rogram, B.1.2, to manage agin g of stainless stee l tube sid e components of the isolation condenser sy stem exposed to reactor cool ant. The program activ ities prov ide for monitoring and c ontrolling of w ater chemistry using station p rocedures and processes for the preve ntio n or m itig atio n of crac king due to stre ss co rro sion crac king and IG SCC. The AS ME Section XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD program, B.1.1, wil l be used with the Water Chemistry Program to manage the aging effects of stress corrosion cracking and IGSCC. The AS ME S ectio n XI Ins ervi ce Insp ectio n progra m wil l be e nhanc ed to p erform inspection of the isolati on condenser tube side co mponents, incl uding temperature a nd radioactiv ity monitori ng of the shell-si de water, ed dy current tes ting of the tubes, an d inspectio n (VT or UT) of the tubeshe et and channe l head to e nsure that signi ficant degradation is not occurring and the component in tended function w ill be mai ntained duri ng the extende d period of operat ion. Observ ed con ditio ns tha t hav e the p otenti al for i mpacti ng the i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
During the tele conference dated F ebruary 2, 2 006, the appl icant indi cated that thus far no augmented inspecti ons were p erformed on components associated w ith an iso lation cond enser and that the pro posed augmented i nspections w ill be a pplicabl e as a part of an AMP du ring the extended p eriod of operati on. The staff requested that th e applica nt provide the follow ing information so tha t an assessment c an be made as to the effectivene ss of the future augmented inspection program of the isolati on condenser and its compon ents.(1) Previou s experie nce related to the frequency of occu rrence of SCC an d IGSCC in th e isolation condenser and its components
.(2) Previou s inspectio n methods and the inspecti on frequency that w ere implemented prior to the rep lacement of some of the isolation condenser compo nents.
314 (3) Crit eria fo r estab lishing futur e augm ented ins pection freq uency.In its letter d ated April 18, 2006 (M L061100138), th e applica nt provide d the follow ing response to the RAI.Prior to tube bundle repl acement in the Oyster Creek iso lation cond ensers, the stai nless steel tube bu ndles w ere found to be s ubject to stress co rrosion cracking. F atigue propagated cracks on the OD surface of the tub es initia ted by trans-granu lar stress corrosion crackin g, and fatigue cracks at the seal we ld and porti ons of the tubeshe et adjacent to the seal we ld were caused by oscillati ng conditions internal to the tubes due to condensate return valv e leakage. Numerous thermal cycl es were ca used by i solation condenser w ater level oscillati on due to the valve leakage conditi on, and sy stem service as the primary heat sink duri ng reactor shutdow ns employi ng opening and closing of the condensate return valve s as needed to limit coo ldown ra te. Subsequent co rrection of the condensate return valve leakage conditi on and changes to isolatio n condenser o peration strategy during rea ctor cooldow n have si gnificantly red uced the thermal cyclin g that exacerbated the stress corrosi on cracking condi tions whi ch existed in the ori ginal tube bundle asse mblies.During the ev aluation o f the isolatio n condenser tu be leakage condi tions, UT and thermography testi ng were used to determine th e condensate/ste am interface in th e isolation condensers, and acoustic moni toring of boili ng intensity was used to determine the presence o f stratified tube in ternal condi tions. Weekly temperature moni toring of isolation condenser tempera ture and monthl y radioac tivity sampling of the she ll wate r (subsequently changed to weekly) has been performed since bef ore tube bundle repla cement.Correction of the valve leakage conditi on has signi ficantly redu ced the number of isolation condenser w ater level oscillati ons and resul tant thermal cy cles appli ed to the isolation condenser compo nents. The Oyste r Creek isolati on condenser tube bundle s were replaced in the "A" isolation condenser in 2000 and in the "B" isolation condenser in 1998, utili zing improv ed materials that are more resi stant to intergranul ar stress corrosi on cracking. Due to th e physica l configuration o f the isolatio n condensers and pipin g at Oyster Creek, eddy current inspe ction of the tubes and access to the tubeshee t and intern al su rfaces o f the cha nnel head r equire cutti ng and re-we ldin g of press ure boundary p iping. Becau se of the significan t reduction i n frequency of ini tiating conditions, and the rela tively recent replac ement of the tube bu ndles w ith improve d materials, these inspection s will be performed once during the first ten years of the period of exte nded operatio
: n. Radioac tivity and temperature mon itoring of the shel l side water as sp ecified in th e GALL recommendati ons for isolati on condenser aging management are currentl y being pe rformed weekly and wil l continue throughout the period of exte nded operatio
: n. Additio nally, d uring the NRC Region I Inspec tion, AmerGen has committed to performing a one-ti me UT inspectio n of the "B" Isola tion Condenser she ll for pitting co rrosion, prior to the period of extended op eration. Pl ant expe rienc e has indi cated that th e cond ition of the " B" iso latio n cond enser is the more limiting of the tw o condensers.
This commitment w ill be a dded to the Tabl e A.5 Licen se Renewal Commitment List Item No. 24. Se e commitment iden tified in 3.1.2
.2.2.2-1.In a follow-up discussi on, the staff asked the app licant to cl arify its pl anned correcti ve action activiti es if there any tube leakage obs erved. In i ts letter (2130-0 6-20331) dated May 3, 2006, the ap plic ant sta ted tha t:
315 Should any of the monitoring a ctivitie s conducted o n the isol ation conden sers reveal conditions potentiall y indic ative of a tub e leak, initi ation of the correc tive acti on process would re sult in an engineering ev aluation o f the observed condition.
Confirmatory testi ng could be p erformed, which may inclu de controlle d-inventory testing of the shel l water volume with the bundle side pressurized, and enhanced radioactivity analysis of shell side water. Upon confirmation of tube leakage, repair or plug ging of leaking tubes would be performed, and i f warranted, edd y current testi ng of the bundles to determine ex tent of condition would be considered. Conceivably, depending on the extent, repair could consist of tube b undle repl acement. Approp riate correctiv e action to c orrect a tube leakage condition in the isolation condensers would be taken, regardless of when it occurred durin g the period of ex tended operati on.The proj ect t eam r eviewe d the appli cant's res pons e to t he RAI , W ater Chem istr y Prog ram (AMP B.1.2) and AS ME Secti on XI ISI, Subsecti on IWB, IW C and IWD program (AMP B.1.1) and det erm in ed tha t th ese pro gra ms a nd the com mit men t to pe rfor m on e-t ime UT i nsp ect io n o f ?B"Isolation C ondenser inc lude activ ities that are adequate to manage cracking due to SC C and IGSCC in stai nless steel BWR isolation conden ser components e xposed to reactor coolan
: t. The project team determin ed that the agin g effects due to SCC, IGSC C associated with i solation condenser sy stems components w ill be a dequately mana ged by the i nservice i nspection an d water chemi stry programs.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.1.2.2.4.2 for further ev aluation.3.1.2.2.5 Crack Growth Due to Cycli c Loading In Section 3
.1.2.2.5 of the OCGS LR A, the appli cant stated that c racking due to cy clic load ing of PW R vessel shells is applicable to PWRs only. The project team concurred with the applicant's eval uatio n that this a ging effect is no t appl icabl e sin ce Oys ter Cre ek is a BWR plant.
3.1.2.2.6 Loss of Fracture T oughness Due to Neutron Irr adiation Embrittlement and Void Swelli ng In Section 3
.1.2.2.6 of the OCGS LR A, the appli cant stated that l oss of fracture toughness o f PWR reactor internals is applicabl e to PWRs only. The proje ct team concurred with the appli cant's eva luati on tha t this aging e ffect is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.3.1.2.2.7 Cracking Due to S tress Corrosion Cracking 3.1.2.2.7.1 Cracking Due to S tress Corrosion Cracking [Item 1]
In Section 3
.1.2.2.7.1 of the OCGS LR A, the appli cant stated that c racking due to stress corros ion c racking for PWR compon ents ma de out of stai nless steel is ap plic able to PWRs onl
: y. The project team concurred with the applicant's evaluation that this aging ef fect is not applicable since Oyste r Cree k is a B WR plant.3.1.2.2.7.2 Cracking Due to S tress Corrosion Cracking [Item 2]
In Section 3
.1.2.2.7.2 of the OCGS LR A, the appli cant stated that c racking due to stress corrosion cracking of PW R Class 1 CASS piping, piping components, and piping element s is 316 applicable to PW Rs only. The project team concurr ed with the applicant's evaluation that this aging effec t is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.3.1.2.2.8 Cracking Due to C yclic L oading 3.1.2.2.8.1 Cracking Due to C yclic L oading [Item 1]
The project team rev iewed OC GS LRA Secti on 3.1.2.2.8.1 agai nst the criteri a in SRP-L R Section 3.1.2.2
.8.1.SRP-LR Secti on 3.1.2.2.8.1stated that cracking due to cyclic loading coul d occur in th e stainless steel BWR jet pump sensing l ines. The GALL Report recommends that a plan t specific AM P be evaluated to ensure that this aging effect is ade quately managed.
In the OCGS LR A Sect ion 3.1.2.2.8.1, th e appl icant stated that th is it em is n ot app lica ble to Oyster Creek. Oy ster Creek does no t have jet pu mps or jet pump sen sing lines.
The project team determi ned that the OCGS reactor does n ot have jet p umps and therefore, concurred w ith the appl icant's ev aluation th at this aging effect/mechani sm is not appl icable.3.1.2.2.8.2 Cracking Due to C yclic L oading [Item 2]
The applicant addressed crack ing due to cyclic loading in the isolation condenser components in LRA Sectio n 3.1.2.2.4.3, in accordance w ith the draft Janua ry 2005 SR P-LR. Therefore, the project team revi ewed OCGS L RA Section 3.1.2.2.4.3 agains t the criteria in SRP-LR Section 3.1.2.2
.8.2.SRP-LR Secti on 3.1.2.2.8.2 state d that cracking due to cyclic loading cou ld occur in steel and stainless ste el BWR isolation co ndenser compone nts exposed to reactor cool ant. The exis ting program r elie s on A SME Secti on XI IS I. How ever, the ex istin g program shoul d be a ugmented to detect cracki ng due to cy clic loadi ng. The G ALL R eport r ecommen ds an augmente d progra m to include temp erature and radi oactivity monitoring of the sh ell-side water, and e ddy current te sting of tubes to ensure that the componen t's intended function wi ll be main tained duri ng the period o f extended o peration.The proj ect t eam r eviewe d the appli cant's W ater Chem istr y Prog ram (AMP B.1.2) and AS ME Sect ion XI IS I pro gram (AM P B.1.1), and dete rmin ed  t hat t hey are adeq uate to ma nage crackin g due to cycl ic lo ading in the isol ation conde nser co mponen ts ex posed to rea ctor co olant. In addition , the project team found that the augmented inspections proposed by the appli cant for the OCGS ASM E Sect ion XI ISI, Su bsecti ons IWB, IWC, and IWD progr am are consi stent w ith the GALL Repo rt recommendations.
The project team found tha t, based on the programs identified above, the applican t has met the criteria of SRP-LR Section 3.1.2.2.8.2 for further eva luation.3.1.2.2.9 Loss of Preload Due to Stress Relaxa tion In Section 3
.1.2.2.9 of the OCGS LR A, the appli cant stated that l oss of preload d ue to stress relaxatio n of PWR RVI components is ap plicable to PWRs only. The projec t team concurred with the applicant' s evalua tion that this aging effect is not app licable since Oyster Creek is a BWR plant.
317 3.1.2.2.10 Loss of Materi al Due to E rosion In Section 3
.1.2.2.10 of the OCGS L RA, the appl icant stated th at loss of materia l due to ero sion of PWR steam generator components is a pplicabl e to PWRs only. The proje ct team concurred with the applicant' s evalua tion that this aging effect is not app licable since Oyster Creek is a BWR plant.
3.1.2.2.11 Cracking Due to F low-Induce d Vibration The project team rev iewed OC GS LRA Secti on 3.1.2.2.11 agai nst the criteri a in SRP-L R Section 3.1.2.2
.11.SRP-LR Secti on 3.1.2.2.11 sta ted that cracking due to flow-ind uced vib ration could occur for the BWR stainless steel stea m dryers ex posed to reacto r coolant. The GALL Report reco mmends further evaluation of a plant-specific AMP to ensure that this aging effect is adeq uately managed.In the OCGS LRA Section 3.1
.2.2.11, the appl icant stated th at Oyster Creek w ill use the reactor internals pro gram, B.1.9, to manage to th e effects of cracking of the steam dry er. The appli cant also stated that i t wi ll i mpleme nt the guidel ines of BWRVIP-139 for the steam d ryer w hen i ssued. Observed cond itions that h ave the po tential for impac ting the intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The applican t was asked to describe ho w cracking in the steam dry er will be managed by the BWR vessel inter nals and w ater ch emistry AMP s duri ng the p eriod of ext ended opera tion. In its respon se, the appl icant stated that Oy ster Cr eek has been inspe cting th e stea m drye r eve ry refueling outage for many years. In 1984 (10R) a cracked brace w eld was found in bank 4-5
, which w as underwa ter weld repaired in the equipment sto rage pool. In 1 986 a cracked bra ce wel d wa s found in ba nk 5-6, w hich was u nderw ater w eld re paire d in t he equi pment s torage p ool. No indica tions of cracking w ere found in the 1989 and 1 991 refueling outa ges. In 1992 the previousl y repaired brace wel d (bank 5-6) w as found cracked and a second w eld repair was imple mented by un derw ater w eldi ng in t he equi pment s torage p ool. Stiffene rs we re add ed to the v ertica l pla tes w here c racked. In 199 4 the s ame ban k 5-6 br ace w eld w as found cracked. A different repai r metho d, ?stop d rill ing", w as imp lement ed to e limin ate cra cking pr opagati on. Visual i nspections o f the Steam Dryer performed in 1996, 1998, 2000, 20 02, and 2004 found no signs of cracking, wh ich indi cates the stop d rilling repa ir has been effective.
The applican t further stated that curre ntly, the ste am dryer is inspected i n accordance with the recommendation o f SIL 644, Rev ision 1.
Inspections i n 2006 w ill conti nue to follow the inspe ction s of SIL 644. The Oys ter Cre ek insp ectio n is n ot impa cted b y the commen ts on S IL 644 pr ovid ed the NRC s taff to the BWR Owners Group (BWROG) in Jan 2005 [Letter Repor t from Robert A Gramm of NRC to Kenneth S Putnam of BWROG, dated January 12 , 2005]. The NRC c omments prima rily addre ss con cerns a ssoci ated w ith ex tended pow er upra te (EP U). Oyster Creek has not implemented EPU, nor i s such an up rate planned.
For the perio d of extended operation, the applicant s tated that the BWRVIP-139 dry er inspections already performed are meant to e stablish a baseline.
The results of these inspe ction s wi ll be eval uated to esta blis h future scope and s chedu le for s team dr yer i nspect ions. Oyster Creek w ill compl y with the recommendati ons of the BWRVIP regarding steam dry er inspections. Any flaws found during inspections will be evaluated and reinspection performed, if 318 required. Performing the inspections in accordan ce with BWRVIP-139 provides as surance that the steam drye r will perform its intend ed function duri ng the period o f extended ope ration.The project team rev iewed th e applica nt's response and determined that it represe nts an adequate method of mana ging cracking in the steam dryers du ring the period of extended operation. The use of baseli ne inspecti ons to compare future inspection results wi ll provi de a means of determinin g if any new cracking is occu rring, which would require further action. The project team determin ed that the app licant's a pproach is a cceptable.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.1.2.2.11 for further ev aluation.3.1.2.2.12 Cracking Due to S tress Corrosion Cracking and Irradi ation-Assiste d Stress Corrosion Cracking (I ASCC)In Section 3
.1.2.2.12 of the OCGS L RA, the appl icant stated th at cracking due to S CC and IASCC of PWR RVI co mponen ts is a ppli cable to PWRs onl
: y. The projec t team c oncurr ed w ith t h e a p p l i c a n t's e v a l u a t i o n t h a t t h i s a gi n g e ff e c t i s n o t a p p l i c a b l e s i n c e O y s t e r C r e e k i s a B WR plant.3.1.2.2.13 Cracking Due to Primar y Wate r Stress Corrosion Crack ing (PW SCC)In Section 3
.1.2.2.13 of the OCGS L RA, the appl icant stated th at cracking due to p rimary wa ter SCC of PWR components insi de the reactor v essel is a pplicabl e to PWRs only. The proje ct team concurred w ith the appl icant's ev aluation th at this aging effect is n ot applicab le since Oyster Creek i s a BWR pla nt.3.1.2.2.14 Wall Thinning Due to Fl ow-Accele rated Corrosion In Sec tion 3.1.2.2.14 of th e OCGS LRA, t he app lica nt stat ed tha t wal l thi nning due to flow-accelerated corros ion of PW R steam generator feedwater inlet ring and supports is applicable to PW Rs only. The project team concurr ed with the applicant's evaluation that this aging effec t is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.3.1.2.2.15 Changes in D imensions D ue to Void Swelli ng In Sec tion 3.1.2.2.15 of th e OCGS LRA, t he app lica nt stat ed tha t chan ges in dimens ions due to void sw elling of PWR RVI components is appli cable to PWRs only.
The project team con curred with the applicant' s evalua tion that this aging effect is not app licable since Oyster Creek is a BWR plant.
3.1.2.2.16 Cracking Due to S tress Corrosion Cracking and Pri mary Water Stress Corrosion Cracking 3.1.2.2.16.1 Cracking Due to S tress Corrosion Cracking and Pri mary Water Stress Corrosion Cracking [Item 1]
In Section 3
.1.2.2.16.1 of the OCGS L RA, the appl icant stated th at cracking due to S CC and primary w ater SCC of PWR CRD penetra tion components is appli cable to PWRs only.
The project team concur red with the applicant's evaluation that this aging eff ect is not applicable since Oyste r Cree k is a B WR plant.
319 3.1.2.2.16.2 Cracking Due to S tress Corrosion Cracking and Pri mary Water Stress Corrosion Cracking [Item 2]
In Section 3
.1.2.2.16.2 of the OCGS L RA, the appl icant stated th at cracking due to S CC and primar y w ater SC C of PWR press uriz er hea d spra y comp onents is ap plic able to PWRs onl
: y. The project team concurred with the applicant's evaluation that this aging ef fect is not applicable since Oyste r Cree k is a B WR plant.3.1.2.2.17 Cracking Due to S tress Corrosion Cracking, Primary Water Stress Corrosion Cracking, and Irradi ation-Assiste d Stress Corrosi on Cracking In Sec tion 3.1.2.2.17 of th e OCGS LRA, t he app lica nt stat ed tha t cracki ng due to SCC , prima ry water SCC , and IASCC of PWR RVI components is appl icable to PWRs only. The project team concurred w ith the appl icant's ev aluation th at this aging effect is n ot applicab le since Oy ster Creek i s a BWR pla nt.3.1.2.2.18 Quali ty As suranc e for Agi ng Ma nagemen t of Non-safety-Rela ted Co mponen ts OCGS LRA Section 3.1.2.2.18 is reviewed by NRR/DE staff and will be addressed separately in Section 3 of the SER related to the OCG S LRA.Conclusio n On the basis o f its review , for component groups e valuated in the GALL R eport for whic h the GALL Report reco mmends further eval uation, the pro ject team determined that the appl icant adequately a ddressed the i ssues that w ere further eval uated.3.1.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Summary of Information i n the Appli cation In OCGS LRA Table 3.1.1, Sum mary of Aging Managem ent Evaluations for the Reactor Vessel, Internals, and Reactor Cool ant System, the applican t provided information regardi ng components or materi al/enviro nment combinati on in the GAL L Report that i t evaluate d and ident ified as not appl icabl e to i ts pla nt.In OCGS LRA Tabl es 3.1.2.1.1 through 3.1.2.1.6, the app licant prov ided addi tional deta ils of the resu lts o f th e AMRs f or ma ter ial, e nviro nmen t, ag ing e ff ect r equ iring mana gem ent, and AMP combinations that are not con sistent wi th the GALL Re port. Specifica lly, the applicant i ndicated, via Notes F through J, that neither the i dentified compon ent nor the materi al/enviro nment combination is eval uated in the GALL Report a nd provid ed information co ncerning how the aging effect requiring management wi ll be managed
.Project Team Eval uation The project team reviewed additional details of the results of the AMRs for mat erial, environment, aging effect requiring management, and AMP co mbinations tha t the appli cant ident ified as not appl icabl e to i ts pla nt.
320 The project team did not revie w the resul ts of the AMR s for material, env ironment, aging effect requiring management, and AMP co mbinations tha t are not consi stent with the GALL Repo rt or are no t ad dre sse d i n th e GA LL Rep ort. Th ese AM R l in e i tem s w ere rev ie we d b y N RR/DE sta ff, and are discussed in the SER related to the OCGS LRA.
3.1.2.3.1 Aging E ffects/mech anisms in Tab le 3.1.1 That Are No t Appl icabl e for OCGS The project team rev iewed OC GS LRA Table 3.1.1, whic h provide s a summary of agin g manageme nt ev aluat ions for the r eactor vess el, i nterna ls, an d reac tor coo lant s ystems eval uated in the GALL R eport.In OCGS LRA Ta ble 3.1.1, It ems 3.1.1-39 a nd 3.1.1-41, the ap plic ant sta ted tha t cracki ng due to stress corrosion cracking, intergranul ar stress corrosi on cracking, or irrad iation-assi sted stress corrosion crackin g of nickel allo y core shrou d and core pl ate access hol e cover (w elded and mechanical covers) in the reactor vessel, internals, and reactor coolant system is not applicable at OCGS. Oyster C reek has no acce ss holes or hole cov ers in the sh roud support pl ate in the reacto r ves sel, i nterna ls, or reacto r cool ant sy stem.The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items i n the OC GS LRA and d etermi ned th at Oys ter Cre ek has n o acce ss hol es or h ole c overs in the shroud support plate. Ther efore, the proj ect team concurred with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.1.1, It em 3.1.1-40, th e appl icant stated that l oss of ma terial due to general, pittin g and crevic e corrosion o f steel top head enclosure (w ithout cladd ing) top head nozzle s (vent, top h ead spray or RCIC, and spare) expos ed to reactor co olant in th e reactor vessel, i nternals, and reactor coolan t system is n ot applicab le at OCGS. The Oyster Creek top head enclosure is clad with stainless steel and not subject to loss of m aterial from ge neral, pitting and cre vice corros ion. No agi ng program is required.
The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items in the OCGS LRA and determined that the top head enclosure i s clad w ith stainle ss steel and not subject to loss of materia l from general, pitti ng and crevi ce corrosion.
Therefore, the project team concurre d with th e applica nt's conclu sion that no aging program is required
.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.1.1 , Ite m 3.1.1-4 5, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevi ce and galv anic corros ion o f copper allo y pi ping, p ipin g compon ents, a nd pi ping e lement s exposed to closed-cycl e cooling w ater in the re actor vessel , internals, a nd reactor cool ant system is no t applicabl e at OCGS. Oyste r Creek has no c opper allo y pipin g, piping components, or pi ping elements e xposed to a closed cy cle cooli ng water env ironment in th e reacto r ves sel, i nterna ls, or reacto r cool ant sy stem.
321 The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items in the OCGS LRA and determined that Oyster Creek has no copper al loy pip ing, piping components, and piping eleme nts exposed to closed-cy cle cooli ng water. Therefore, the project team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.1.1, It em 3.1.1-46, th e appl icant stated that l oss of ma terial due to general , pitti ng and crevi ce corr osion of steel pipi ng, pip ing com ponen ts, and pipi ng ele ments exposed to closed-cycl e cooling w ater in the re actor vessel , internals, a nd reactor cool ant system is no t applicabl e at OCGS. Oyste r Creek has no s tainless ste el pipin g, piping components, or pi ping elements e xposed to a closed cy cle cooli ng water env ironment in th e reacto r ves sel, i nterna ls, or reacto r cool ant sy stem.The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items in the OCGS LRA and determined that Oyster Creek has no steel pi ping, piping components, and piping eleme nts exposed to closed-cy cle cooli ng water. Therefore, the project team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.1.1, It em 3.1.1-48, th e appl icant stated that l oss of ma terial due to selec tive leac hing o f copper allo y >15% Zn pi ping, p ipin g compon ents, a nd pi ping e lement s exposed to closed-cycl e cooling w ater in the re actor vessel , internals, a nd reactor cool ant system is no t applicabl e at OCGS. Oyste r Creek has no c opper allo y >15% Zn p iping, pipi ng components, and piping element s exposed to closed-cycle cooling water in the reactor vessel, intern als, o r react or coo lant s ystem.The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine item s in the OCGS LRA and dete rmin ed th at Oy ster Cre ek ha s no cop per a llo y >1 5% Zn pip ing, piping compone nts, and pipi ng elements ex posed to clo sed-cycle cooling w ater in the re actor vessel, i nternals, or rea ctor coolant sy stem. Therefore, the project team concurred w ith the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.1.1, Item 3.1.1-49 , the appli cant stated that l oss of fracture toughness due to therma l agin g embrit tlemen t of cast auste nitic stain less s teel p ipin g and C RD pre ssure housi ngs in the rea ctor v essel , inte rnals , and r eactor cool ant sy stem is not ap plic able at OCGS. Oyster Creek h as no cast au steni tic sta inle ss stee l pip ing tha t is su bject to loss of fracture toughness due to thermal aging embrittl ement in the re actor vessel , internals, o r reactor coola nt system 322 The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items in the OCGS LRA and determined that Oyster Creek has no cast austeni tic stainle ss steel piping that i s subject to lo ss of fracture toughness du e to thermal agin g embrittlement in the reacto r ves sel, i nterna ls, or reacto r cool ant sy stem. Th erefore, the pr oject te am conc urred w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.1.1, Item 3.1.1-70 , the appli cant stated that th e AMR i dentifying no aging effect for s tainl ess ste el pi ping, p ipin g compon ents, a nd pi ping e lement s exp osed t o air with borated wate r leakage or gas in the reactor v essel, intern als, and reac tor coolant sy stem is not applicabl e at OCGS. Oyste r Creek has no s tainless ste el pipin g, piping componen ts, or piping elements ex posed to air with bora ted water l eakage or gas in the reactor vesse l, internal s, or reactor coolan t system The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine items in the OCGS LRA and determined that Oyster Creek has no stainles s steel pip ing, piping components, or pi ping elements e xposed to air with borated w ater leakage or gas i n the reactor vessel, i nternals, or rea ctor coolant sy stem. Therefore, the project team concurred w ith the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.1.1, Item 3.1.1-72 , the appli cant stated that th e AMR i dentifying no aging effect for steel and stainless steel piping, piping components, and piping element s in concrete in the reactor ve ssel, interna ls, and reacto r coolant sy stem is not app licable at OCGS. Oyster Creek h as no steel or sta inle ss stee l pip ing, pi ping co mponen ts, or p ipin g eleme nts in concre te in the reacto r ves sel, i nterna ls, or reacto r cool ant sy stem.The project team rev iewed th e reactor ves sel, internal s, and reactor co olant syste m AMR l ine item s in the OCGS LRA and dete rmin ed th at Oy ster Cre ek ha s no stee l or stai nle ss s teel pip ing, piping compone nts, or pipin g elements in c oncrete in the reactor vess el, internal s, or reactor coolant system. Theref ore, the project team concurred with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
3.1.2.3.2 Reactor Vessel , Internals, and Reactor Cool ant Systems A MR Lin e Items That Have No Aging Effect (OCGS LRA Table s 3.1.2.1.1 Through 3.1.2
.1.6)In LRA Tables 3.1.2.1.1 through 3.1
.2.1.6, the appl icant identi fied line-ite ms where no aging effects were identi fied as a resul t of its aging revi ew process
.In OCGS LRA Ta bles 3.1.2.1.1 thro ugh 3.1.2.1.6, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in 323 whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s tainl ess ste el, ca st aust eniti c stai nless steel , and n ickel allo y w ere ex posed to an ai r-indo or unc ontrol led e nvir onment.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the reactor v essel, intern als, and reac tor coolant sy stem, and determine d that no significant aging effects w ere identified for components w ith this materi al/enviro nment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that stain less steel, cast austeniti c stainless steel, and ni ckel alloy exposed to an air-indoor u ncontrolled environment will not result in aging that wi ll be of conc ern during the period of exte nded operatio
: n. Therefore, the project team determined th at there are no applicabl e aging effects requiring management for this material/e nvironment c ombination.
Conclusio n On th e bas is of its re view, t he pr ojec t tea m fo und t hat t he app lican t app ropr iate ly iden tif ied AMR resu lts in volving mate rial, envir onme nt, agin g ef fec ts re quir ing m anag emen t, an d AMP combinations that are not app licable to OCGS, and AM R results i nvolvi ng material and environment combinations that do not have aging effect s requiring manag ement at OCGS.
3.1.3 Conclusion On the basis o f its review , the project team d etermined that the applican t has demonstrated that the aging effects associate d with th e reactor ves sel, internal s, and reactor co olant syste m components w ill be a dequately mana ged.The project team als o review ed the appl icable UF SAR suppl ement program summaries a nd concluded th at they ade quately desc ribe the AM Ps credited for man aging aging of the reactor vesse l, in ternal s, and reacto r cool ant sy stems c ompone nts, as requir ed by 10 CF R 54.2 1(d).3.2 OCGS LRA Section 3.2 -
Ag ing Management o f Engineered S afety Fe atures This section o f the audit and review report documents the project team's review and eval uation of OCGS aging management rev iew (AM R) results for the aging management of the engin eered safety features compone nt and componen t groups associa ted with the followi ng systems: (1) contai nment s pray syste m, (2) co re spra y sy stem, an d (3) s tandby gas trea tment sy stem.3.2.1 Summary o f Technical Information in the A pplication In the OCGS LRA Section 3.2 , the appli cant provid ed the results of its AMR s for the engineered safety features compone nts and compone nt groups.
In OCGS LRA Ta ble 3.2.1, ?Summary of Aging M anagement Engineere d Safety Feature s," the appli cant p rovi ded a summary compar ison of its A MR l ine-i tems w ith th e AM R lin e-item s evaluated in the GALL Report for the engin eered safety features components and component groups. The ap plic ant al so id entifi ed for e ach co mponen t type in th e OCGS LRA Ta ble 3.2.1 324 those AMR s that are co nsiste nt wi th the GALL R eport, those for whi ch the GALL R eport recommends f urther evaluation, and those AMRs that are not addressed in the OCGS LRA together with the basis for thei r exclusi on.In the OCGS LRA Tables 3.2.2.1.1 through 3.2.2.1.3, the applicant p rovided a summary of the AMR resu lts for component ty pes associate d with (1) containment sp ray system, (2) core spray system, and (3) standby gas trea tment system. Sp ecifically , the information for ea ch component type incl uded i ntende d functi on, mate rial, envi ronmen t, agin g effect requ iring manageme nt, AMPs, the GALL Report Volume 2 item, cross ref erence to the OCGS LRA Table 3.2.
1 (Table 1), and generi c and plant-speci fic note s rela ted to consi stency wit h the GA LL Rep ort.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of aging effect requiring managements (AE RMs). These review s included evaluati on of plant-spe cif ic and indus try op erat ing e xperi ence. The plant-spe cif ic eval uati on inc luded revie ws of condition re ports and dis cussions w ith appropri ate site perso nnel to id entify AERM
: s. The applicant' s review of industry o perating expe rience incl uded a rev iew of the GA LL Report and operat ing ex perie nce i ssues ident ified since the i ssuanc e of the GALL R eport.3.2.2 Project T eam Evaluatio n The project team rev iewed OC GS LRA Secti on 3.2 to determi ne if the appl icant provi ded sufficient information to demonstrate that th e effects of aging for the engineered safety features components that a re withi n the scope o f license renew al and sub ject to an AM R wil l be adequately man aged so that the intended functio n(s) wil l be maintai ned consiste nt with th e CLB for the p eriod of ext ended opera tion, as requi red by 10 CF R 54.2 1(a)(3).The project team rev iewed c ertain iden tified AMR line-items to confirm the appl icant's cl aim that these AMR line-items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line-items. The project team's audit evaluation is documente d in Section 3.2.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line-items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in SRP-LR. The projec t team's audit eval uatio n is d ocumen ted in Secti on 3.2.2.2 of t his a udit a nd rev iew report.The project team did not revie w the remai ning AMR line-items that were no t consistent w ith or not addressed in the GALL R eport based on NRC-approv ed precedents.
These were re viewe d by th e NRR/DE sta ff and doc umented in th e SER for the Oyster Creek p lant.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the e ngineered safety features components.
Table 3.2-1 bel ow prov ides a summary of the project team's evaluati on of components, agi ng effects/aging mechanisms, and AMPs l isted in L RA Section 3.2 that are ad dressed in th e GALL Report. It also includes the section of the audit and review report in which the project team's evaluati on is documen ted. It should be noted tha t the line items in thi s table corres pond to the 325 line items in Table 3.2-1 of the Septem ber 2005 Revision 1 SRP-LR document; theref ore, in many cases, th ey do not match the lin e items in Tabl e 3.2.1 of the OCGS L RA. The SRP-L R line item n umber i s deno ted pa renthe tical ly i n the c olumn 1 entry. Als o, li ne ite ms that are applicabl e only to PWR plants are not incl uded in thi s table; therefore, c ertain SRP-L R line i tem numbers do not appear in this table Table 3.2-1 Staff Evalua tion for Enginee red Safety Features Co mponents in the GALL Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on Steel and stai nless st eel pipi ng, pi ping components, and pi ping elements i n emergency core cool ing sy stem (It em 3.2.1-1)
Cum ulative fati gue damage TLAA, eval uated in accor dance wi th 10 C FR 54.21(c)TLAA TLAAs were revi ewed by NRR/DE staff.
(See Audit Report Sect ion 3.2.2.2.1)Stai nless st eel contai nment isol ati on piping and com pon ents int ernal surfaces exposed to trea ted water (It em 3.2.1-3)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2), and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.3.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents ex po se d to so il (It em 3.2.1-4)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.3.2)Stai nless st eel an d aluminum pipi ng, pi ping components, and pi ping elem ents exp ose d to trea ted wat er (It em 3.2.1-5)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.3.3)Stai nless st eel an d copper al loy pipi ng, pipi ng components, and piping elem ents exposed to lubr icat ing oil (I tem 3.2.1-6)Loss of materi al due to pi tt ing an d crevi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.3.4)Parti all y encased st ai nl ess s te el ta nks with breached m oisture barri er exposed t o raw water (It em 3.2.1-7)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated f or pit ti ng and crev ice corrosi on of t ank bott oms because moisture an d water can egress under t he tank Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.3.5)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 326 due to cr acking of the per imeter seal from weatheri ng.Stai nless st eel pi ping, pipi ng components, pipi ng ele ments, and tank i nter nal sur faces exp ose d to co nd en sa tion (int er na l)(It em 3.2.1-8)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.3.6)Ste el, s tain les s s tee l, and copper al loy heat exchanger t ubes exposed to lubr icat ing oil (I tem 3.2.1-9)Reducti on of heat trans fer d ue to foul ing Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.4.1)Stai nless st eel he at exchanger t ubes exposed to trea ted water (It em 3.2.1-10)
Reducti on of heat trans fer d ue to foul ing W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.4.2)Elast omer seals and components in st andby gas tr eatment sy stem exposed to air - in door uncontr oll ed (It em 3.2.1-11)
Hardenin g and loss of stre ngth due to el astomer degradat ion A p lan t-s pe cif ic AMP is to be eval uated.Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)Consist ent wi th GALL, which r ecomm ends fu rt he r ev al ua t i on. AMP B.2.4 was revi ewed by NRR/DE staff.
(See Audit Report Sect ion 3.2.2.2.5)Steel dry well and suppressi on chamber sp ra y sys tem no zzle and fl ow ori fi ce int ernal su rfa ce s e xp os ed to a ir- indo or uncont rol led (i nter nal) (I tem 3.2.1-13)Loss of materi al due to ge neral corrosi on and foul ing A p lan t-s pe cif ic AMP is to be eval uated.Not ap plic ab le Not appl icabl e, si nce Oyster Creek has stai nless st eel spr ay nozz les and ori fi ces.(See Au dit Report Secti on 3.2.2.2.7)Steel pipi ng, pi ping components, and pi ping elem ents exp ose d to trea ted wat er (It em 3.2.1-14)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.8.1)Steel contai nment isol ati on pip ing, pipi ng components, and pi ping elements i nter nal sur fac es e xpo sed to trea ted wat er (It em 3.2.1-15)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.8.2)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 327 Steel pipi ng, pi ping components, and pi ping elem ents exp ose d to lub ric atin g o il (It em 3.2.1-16)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.2.8.3)Steel (wi th or wit hout coati ng or wrap ping)pipi ng, pi ping components, and pi ping ele m en ts b ur ied in s oil (It em 3.2.1-17)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and m icr ob iolo gic ally-inf luenced corrosi on Buri ed Pipi ng and Tanks Survei ll ance or Buri ed Pipi ng and Tanks Inspecti on Buri ed Pipi ng Inspect ion (B.1.26)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.  (See Audit Report Sect ion 3.2.2.2.9)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to trea ted wat er > 60&deg;C (> 1 40&deg;F)(It em 3.2.1-18)
Cra ck ing du e to stress corrosi on cracking and int ergranul ar stress corrosi on cracking BW R Stress Corrosi on Cracking and W ater Chem istry Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel pipi ng, pi ping components, and pi ping elem ents exp ose d to steam or tr eated wat er (It em 3.2.1-19)
W all thi nning due to f lo w-acceler ated corrosi on Flow-Accel erat ed Corrosi on Flo w-Acceler ated Corrosi on (B.1.11) Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.2.2.1)Cast aust enit ic st ainl ess steel pipi ng, pi ping components, and pi ping elem ents exp ose d to trea ted wat er (bor ated or unb orated) > 250&deg;C (> 4 82&deg;F)(It em 3.2.1-20)
Loss of frac ture toug hne ss d ue to ther mal aging embritt lement Thermal Aging Em bri tt lement of CASS Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)High-st rengt h steel closur e bolt ing exp osed to ai r wi th st eam or water leakage (It em 3.2.1-21)
Cra ck ing du e to cycl ic l oading, stress corrosi on cracking Bo lting Integ rity Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel closur e bolt ing exp ose d to a ir with steam or water leakage (It em 3.2.1-22)
Loss of materi al due to ge neral corrosi on Bo lting Integ rity Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel bolt ing an d closur e bolt ing exp osed Loss of materi al du e to ge ne ra l, Bo lting Integ rity Bolt ing Integ rity Co nsis tent w ith GA LL. (See Au dit Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 328 to ai r - out door (external), or air
-indoor uncontr oll ed (e xte rn al)(It em 3.2.1-23) pit ti ng, and crevi ce corrosi on (B.1.12)Secti on 3.2.2.1)Steel closur e bolt ing exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.2.1-24)
Loss of pr eload due to t hermal effect s, gasket creep, and self-l oosening Bo lting Integ rity Bolt ing Integ rity (B.1.12)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.2.2.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents ex po se d to clo se d c ycle cooling w ater > 60&deg;C (> 1 40&deg;F)(It em 3.2.1-25)
Cra ck ing du e to stress corrosi on cracking C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel pipi ng, pi ping components, and pi ping elem ents exp ose d to closed cy cle cool ing water (It em 3.2.1-26)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel heat excha nger com pon ents exp ose d to closed cy cle cool ing water  (I tem 3.2.1-27)Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, an d g alv an ic corrosi on C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F  co m pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Stai nless st eel pi ping, pipi ng components, pipi ng ele ments, and heat exchang er com pon ents exp ose d to closed-cycl e cooli ng water  (I tem 3.2.1-28)Loss of materi al due to pi tt ing an d crevi ce corrosi on C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Copper al loy pipi ng, pipi ng components, pipi ng ele ments, and heat exchang er com pon ents exp ose d to closed cy cle cool ing water  (I tem 3.2.1-29)Loss of materi al due to pi tt ing, crevi ce, and galv anic cor rosi on C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Stai nless st eel an d copper al loy heat exchanger t ubes ex po se d to clo se d c ycle Reducti on of heat trans fer d ue to foul ing C los ed-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 329 cooli ng water (It em 3.2.1-30)
Audit Report Sect ion 3.2.2.3.1)External surfaces o f stee l com pon ents incl uding ducti ng, piping, ducting closure bolt ing, and contai nment isol ati on pipi ng exter nal sur faces exposed to air - in door uncon troll ed (external);
co nd en sa tion (ex ter na l)and ai r - out door (external) (It em 3.2.1-31)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing Struct ures Monitor ing (B.1.31)Ac ce pt ab l e-The OCGS Struct ures Monit ori ng AM P is c ons istent w ith the GALL Exter nal Surfaces Moni tori ng AMP for thi s component group/ aging effect co m bin atio n.  (Se e A ud it Report Sect ion 3.2.2.1.1)Steel pipi ng and duct ing components and int ernal surfaces exposed to air - in door un co ntr olle d (I nte rn al)(It em 3.2.1-32)
Loss of materi al due to ge neral corrosi on Inspect ion of Int ernal Surfaces in Mi scell aneous Pipi ng and Ducti ng Co m pon ents Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)Ac ce pt ab l e - The OCGS Peri odic I nspecti on of Vent il ati on Sy stems AMP is consi stent wit h the GALL Inspecti on of Inte rn al S ur fa ce s in Miscel laneous Pipi ng and Du cting C om pon ents AMP for thi s component group/ aging effect co m bin atio n.  (Se e A ud it Report Sect ion 3.2.2.1.1)Steel encapsul ati on com pon ents exp ose d to air - in door uncont rol led (in ter na l)(It em 3.2.1-33)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on Inspect ion of Int ernal Surfaces in Mi scell aneous Pipi ng and Ducti ng Co m pon ents Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of lice ns e re ne wa l.(See Au dit Report Secti on 3.2.2.3.1)Steel pipi ng, pi ping components, and pi ping elem ents exp ose d to co nd en sa tion (int er na l)(It em 3.2.1-34)
Loss of materi al du e to ge ne ra l, pit ti ng, and crevi ce corrosi on Inspect ion of Int ernal Surfaces in Mi scell aneous Pipi ng and Ducti ng Co m pon ents Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of lice ns e re ne wa l.(See Au dit Report Secti on 3.2.2.3.1)Steel contai nment isol ati on pip ing an d components int ernal sur fac es e xpo sed to raw water (It em 3.2.1-35)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and m icr ob iolo gic ally-inf luenced corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em Not ap plic ab le N ot A pp lica ble sin ce , in ESF, the dry well fl oor and equi pment drai n li ne is t he onl y component subject to t his agi ng effect , and i t i s managed by One-Ti me Inspecti on.(See Au dit Report Secti on 3.2.2.1.2)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 330 Steel heat excha nger com pon ents exp ose d to raw water (It em 3.2.1-36)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, galv anic, and m icr ob iolo gic ally-inf luenced corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to raw water (It em 3.2.1-37)
Loss of materi al due to pi tt ing, crevi ce, and m icr ob iolo gic ally-inf luenced corrosi on O pe n-C ycle Cooli ng W ater Syst em N ot U se d in ESF Table 2 it ems Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Stai nless st eel contai nment isol ati on piping and com pon ents int ernal surfaces exposed to raw water (It em 3.2.1-38)
Loss of materi al due to pi tt ing, cre vice, a nd M IC corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em Not Ap plic ab le N ot A pp lica ble sin ce , in ESF, the dry well fl oor and equi pment drai n li ne is t he onl y component subject to t his agi ng effect and i t i s managed by One-Ti me Inspecti on.(See Au dit Report Secti on 3.2.2.1.4)Stai nless st eel he at exc han ger c om pon ents exposed to raw water (It em 3.2.1-39)
Loss of materi al due to pi tt ing, crevi ce, and m icr ob iolo gic ally-inf luenced corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Steel and stai nless st eel heat exchang er t ubes (s er vic ed by o pe n-cyc le cooli ng water) exposed to r aw water (It em 3.2.1-40)
Reducti on of heat trans fer d ue to foul ing O pe n-C ycle Cooli ng W ater Syst em Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Coppe r al lo y > 15% Zn pipi ng, pi ping components, pi ping elements, and heat exc han ger c om pon ents ex po se d to clo se d c ycle cooli ng water (It em 3.2.1-41)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Gray cast ir on pip ing, pipi ng components, piping elem ents ex po se d to clo se d-cyc le Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Selective Leaching of M ate ria ls (B.1.25)Consist ent wi th GALL.(See Au dit Report Secti on 3.2.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 331 cooling water (It em 3.2.1-42)
Only in Fire Protect ion Syst em Gray cast ir on pip ing, pipi ng components, and piping elem ents ex po se d to so il (It em 3.2.1-43)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)
Gray cast ir on motor coo ler ex pos ed to trea ted wat er (It em 3.2.1-44)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Selective Leaching of M ate ria ls (B.1.25)Consist ent wi th GALL.(Se e Au dit Re port Secti on 3.2.2.1)Aluminum pipi ng, pi ping components, and pi ping ele m en ts e xp os ed to a ir- indo or uncont rol led (in ter na l/ex ter na l)(It em 3.2.1-50)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.2.2.1)Galvani zed st eel ducting expos ed to air -
indoor contr oll ed (e xte rn al)(It em 3.2.1-51)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.2.2.1)Gla ss p iping e lem ents exposed to air - in door uncon troll ed (external), lubr icat ing oi l, raw water, tr eated wat er, or trea ted bor ated wat er (It em 3.2.1-52)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.2.2.1)Stai nless st eel, copper all oy, and ni ckel al loy pipi ng, pi ping components, and pi ping ele m en ts e xp os ed to a ir- indo or uncont rol led (e xte rn al)(It em 3.2.1-53)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.2.2.1)Steel pipi ng, pi ping components, and pi ping ele m en ts e xp os ed to a ir- indo or cont rol led (e xte rn al)(It em 3.2.1-54)
None None Not ap plic ab le Not appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of lice ns e re ne wa l.(See Au dit Report Secti on 3.2.2.3.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 332 Steel and stai nless st eel pipi ng, pi ping components, and pi ping elem ents in con cre te (It em 3.2.1-55)
None None Not ap plic ab le Not Appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)Ste el, s tain les s s tee l, and copper al loy pipi ng, pipi ng components, and piping elem ents exposed to gas (It em 3.2.1-56)
None None Not ap plic ab le Not Appl icabl e, si nce Oyster Creek has no suc h ES F c om pon ents wit hin t he scope of li cense renewal.  (See Audit Report Sect ion 3.2.2.3.1)3.2.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant stated are consistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA wa s acceptable
.In OCGS LRA Se ction 3.2.1.2.1, the applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging effects related to the containment sp ray system, core spray s ystem, and stan dby gas treatment system co mponents and co mponent groups:
*ASME S ection XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD (B.1.1)
*Water Chemistry (B.1.2)
*BWR SCC (B.1.7)
*Bolting Integrity (B.1.12)*One-Time Inspection (B.1.24)*Selectiv e Leaching of M aterials (B.1.2 5)*Buried Pi ping Inspection (B.1.26)*Structures Mo nitoring Program (B.1.3 1)*Periodic Testi ng of Containment Sp ray Noz zles (B.2.1
)*Periodic In spection of Ven tilation S ystems (B.2.4)
Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line-items to determine tha t the applicant (1) provides a brief descri ption of the sy stem, components, materi als, and environment; (2) states that the applicabl e aging effects have b een revie wed and are evalu ated in the GALL R eport; and (3) iden tifies those aging effec ts for the conta inment spray syste m, core spray system, and standby gas trea tment system componen ts that are subject to an AMR.
333 3.2.2.1.1 Loss of Materi al Due to Ge neral Corrosi on on Internal and Extern al Surfaces Expo sed to Air a nd M oistu re In the OCGS LRA , Section 3.2.2
.2.2, the appli cant provid ed its further ev aluation to address los s of material due to general corrosi on  for the intern al and ex ternal surfaces of BWR steel components exposed to air and moisture, in accordance with the draft January 2005 SRP-LR.
In review ing this further ev aluation, the project team recogni zed that the approved September 2005 GA LL Rep ort rec ommende d AM P XI.M 36, ?External S urfaces Moni toring,"  or XI.M38
,?Insp ecti on o f Inte rnal Sur faces in M isc ell aneo us P ipi ng an d Du ctin g Com pone nts" to ma nage this aging effect wi th no further eva luation requi red. Therefore, the projec t team review ed the applicant' s further evalu ation against the recommendation s in the aforementi oned GALL AM Ps, as appropriate
.In the O CGS LRA, the applic ant sta ted tha t Oyster Creek will us e the 10CF R50 Appen dix J program, B.1.29 , in a ssoci ation wit h the A SME Secti on XI, S ubsect ion IWE progr am, B.1.27, to inspect pip ing and fittings i n the contain ment vacuum bre aker system. The pri mary contain ment leakage rate testing p rogram provides for aging management of pressure b oundary de gradation due to loss of material in systems penetra ting primary co ntainment. The pri mary contain ment inservice inspection (ISI) program utili zes inspe ctions for degradatio n of accessibl e surface areas. Together, these programs detect degradati on of the vacu um breaker system p rior to the loss of intende d function. Observ ed conditio ns that have the potential for impacting the i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's 10 CFR Part 50, Appe ndix J p rogram (AMP B.1
.29)and verified that this agin g management program inclu ded activ ities that are consistent w ith the recomme ndati ons i n GALL AMP XI.M3 6 to man age lo ss of mat erial in co mponen ts ex posed to an ind oor a ir int erna l envir onme nt. In add ition , the proj ect t eam r eviewe d the appli cant's ASME Section XI ISI p rogram (B.1.1) and v erified that thi s aging management program i ncludes inspections of components to de tect loss of materia l as a means of verifying the effectiveness of the 10 CFR Part 50, Appendix J program. The pr oject team determ ined that OCGS AMPs B.1.29 and B.1
.1, together, wil l adequately manage loss of materi al in pi ping and fittings i n the contai nment v acuum b reaker s ystem expo sed to an in door a ir and moistu re env ironme nt.In the OCGS LR A, the appli cant st ated th at the perio dic i nspect ion o f venti latio n sys tems program, B.2.4, wi ll be use d to perform visu al inspecti ons of piping, pi ping components, p iping elements, and fan and damper hou sings for the standby gas treatment syste
: m. Program activities include periodic visual inspections and system tests to ensure aging degradation is detected prior to loss of inten ded function. Obse rved condi tions that hav e the potentia l for impact ing the intended funct ion are evalu ated or c orrect ed in accor dance with t he corr ective action process
.The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is appropriate to manage the loss of material in ventilati on system stee l piping, pi ping components, and pipin g elements exp osed to an i ndoor air i nternal or ex ternal env ironment. The tech nical evaluation of this program to determine its adequacy was perfor med by NRR/DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.In the OCGS LRA , the appli cant stated that th e One-Time Inspecti on Program, B.1.24, w ill be used to insp ect the isol ation conden ser shell a nd shell side componen ts and the in ternal 334 surfaces of carbon steel vent pip ing in an i ndoor air en vironment i n the isol ation conden ser system. When not in serv ice, portions of the isolati on condenser shell and the venti lation pi ping contain ind oor air, and inspection of the internal surfaces verifies that unacceptabl e degradation is not occurri ng and that the c omponent inten ded function w ill be mai ntained duri ng the extended p eriod of operati on. Observed conditions that have the potential for impacting the intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.The project team rev iewed th e applica nt's One-Time Inspe ction Program (AM P B.1.24) and verified that this aging management p rogram included activiti es that are con sistent wi th the recomme ndati ons i n GALL AMP XI.M3 8 to man age lo ss of mat erial in co mponen ts ex posed to an indoor air internal environment. The proj ect team determined th at OCGS AMP B.1.24 will adequately manage loss of material in the isolation condenser components exposed to an air envi ronmen t.In the OCGS LRA , the appli cant further stated that the structures moni toring program, B.1.31, will be used to i nspect the ex ternal surfaces of stee l piping, pi ping components, p iping elemen ts, and du cting i n an i ndoor air or outdo or air envi ronmen t for the conta inment spray syste m, core spray sys tem, standby gas treatment system, co ntainment va cuum breakers sys tem, isolation condenser sy stem, post-acciden t sampling sy stem, and dryw ell floor and equipment drain s system whe n there are no other AMP s that inspec t the items. The s tructures monitori ng program directs peri odic vi sual inspe ctions to id entify and ev aluate the d egradation of the inspected i tems to ensure tha t there is no loss of intende d function. Observ ed conditio ns that have the p otential for impa cting the inten ded function are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's structures mon itoring program (AM P B.1.31) and verified that this aging management p rogram included activiti es that are con sistent wi th GALL AMP XI.M36 to manage the loss of mat erial in components exposed to an indoor or outdoor air external environment. The project team determined that O CGS AMP B.1.31 will adequately manage the loss of material on the external surfaces of steel pi ping, piping co mponents, pipi ng elements, and d ucting in an indoor air or outdoor ai r environmen t for the containmen t spray syste m, core spray syste m, stand by gas treatme nt sy stem, co ntain ment v acuum b reakers system, isol ation conden ser system, pos t-accident sampl ing system, and drywel l floor and equipme nt drai ns sy stem .Final ly, i n the OC GS LRA , the a ppli cant st ated th at the exter nal s urfaces of the re actor p ressur e vessel no zzles in an env ironment of contai nment atmosphere do not require an aging management program. The aging effect of loss of material due to general corrosi on in the primar y con tainme nt atmos phere does n ot nee d to be consi dered for carb on ste el co mponen ts in a contai nment nitrogen env ironment becaus e of negligible amounts of free oxy gen (less than 4 percent by volume du ring normal opera tion). Both o xygen and moisture must be present for gene ral corr osi on to occ ur be caus e ox ygen alo ne o r wa ter fr ee o f dis sol ved oxy gen (high humidi ty in a nit rogen a tmosphe re) doe s not c orrode carbo n stee l to a ny pr actica l ex tent.Therefore, there is no loss of material for carbon steel components ex posed to a co ntainment nitrogen envi ronment because, with the negligible a mounts of free oxy gen, anodic rea ctions do not take plac e and the co rrosio n cel l doe s not for m.The pro ject tea m revi ewed the ap plic ant's further eval uatio n rela ted to loss o f materia l due to general corrosio n in the pri mary contain ment atmosphere for carbo n steel compon ents and concurred w ith the appl icant's con clusion tha t this is no t a credible aging effect. The Oyster Creek containment is inerted d uring normal ope ration; therefore, there are negligibl e amounts of 335 free ox ygen p resent. Sin ce ox ygen a nd moi sture mu st be p resent for gener al co rrosio n to occur, general corros ion o f carbon steel compon ents i s not a credi ble e vent.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism, a s recom mended by th e GALL Repor t.3.2.2.1.2 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Micro biological ly Influence d Corros ion S teel C ontai nment Is olati on Com ponen ts Ex posed Intern ally to Untreated Water In the OCGS LRA , Section 3.2.2
.2.4, the appli cant provid ed its further ev aluation to address los s of mat eria l du e to gene ral, pit ting , cre vic e, an d M IC fo r ste el B WR conta inme nt i sol atio n pi pin g, piping compone nts, and pipi ng elements ex posed interna lly to u ntreated wate r in systems that are no t addre ssed i n othe r chap ters of th e GALL Repor t.In the OCGS LRA , the appli cant stated that Oy ster Creek wi ll use the One-Time Inspectio n Program, B.1.24, to mana ge the loss of materi al in the steel portion of drywel l floor and equipment drains system pip ing that provi des the contai nment isolati on barrier. The program elements incl ude determinati on of appropriate inspection sample siz e, identificati on of inspectio n locat ions, sele ction of exa minati on tec hnique s wi th acce ptance crite ria, a nd ev aluat ion o f result s. Observed cond itions that h ave the po tential for impac ting the intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The applican t was asked to justify how the One-Time Inspec tion Program w ould manage the contai nment i solat ion c ompone nt surfac es tha t are e xpos ed to u ntreate d or ra w w ater. I n its response, the a pplicant sta ted that aging effects of the dry well floo r and equipment d rains system pipi ng providin g a containment i solation functi on are managed w ith the structures monitoring program for ex ternal surfaces, an d the One-Time Inspe ction Program for intern al surfaces. The One-Time Insp ection Program con firms the absence o f aging effects in pooled or potentiall y stagnant flow areas of drain piping and p iping elemen ts. The water in reactor bui lding floor d rain s ump con sists primar ily of formerl y trea ted w ater so urce fro m conta inment syste ms. This relativ ely high quality w ater, along w ith a lack of ope rating experi ence citing a ge-related issues w ith this pi ping indica ted that a one-ti me inspection program was ap propriate for ensuri ng the piping an d components w ill perform thei r intended functi on during the p eriod of exten ded operation. A ny observ ed conditio ns that have the potential for impacting the i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The pro ject tea m revi ewed the ap plic ant's respo nse an d dete rmined that th e One-Ti me Inspection Pro gram would b e adequate to moni tor the internal surfaces of the dryw ell floor and equipme nt drai ns sy stem si nce th e wa ter in the re actor b uild ing floo r drai n sump consi sts primar ily of formerl y trea ted w ater from the co ntain ment sy stems. This re lativ ely high qua lity water is n ot expected to cause signi ficant aging effects, whic h is supporte d by pla nt operating experience
.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nism, a s recom mended by th e GALL Repor t.
336 3.2.2.1.3 General, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion and Fouli ng in Stainl ess Steel C ontainment Isol ation Compone nt Exposed to Raw o r Untreated Water In the OCGS LRA , Section 3.2.2
.2.7.1, the appl icant provi ded its further ev aluation to address loss of material due to pitti ng, crevice a nd MIC, an d fouling for the in ternal surfaces of stai nless steel contai nment isolati on piping, pi ping components, a nd piping el ements in conta ct with raw or untr eated wate r.In the OCGS LRA , the appli cant stated that Oy ster Creek wi ll use the One-Time Inspectio n Program, B.1.24, to ev aluate for loss of material of the stai nless steel portion of dry well floo r and equipment drains system pip ing that provi des the contai nment isolati on barrier. The program elements incl ude determinati on of appropriate inspection sample siz e, identificati on of inspectio n locat ions, sele ction of exa minati on tec hnique s wi th acce ptance crite ria, a nd ev aluat ion o f result s. Observed cond itions that h ave the po tential for impac ting the intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team rev iewed th e applica nt's One-Time Inspe ction Program (AM P B.1.24) and ver ifie d tha t thi s agi ng ma nage ment prog ram i ncl uded acti vit ies that are adeq uate to ma nage loss of material for the stainle ss steel porti on of drywe ll floor and equipment drains system pip ing that provid es containment isolation barrier and i s exposed to raw or u ntreated wate
: r. The project team noted that, while the environment is stated to be raw or untreated water, it is actually formerly treated w ater that is l ikely stil l of high quality. Therefore, the project te am dete rmin ed th at OC GS A MP B.1.24 w ill ade quate ly mana ge lo ss o f mate rial due to p itti ng, crevice an d MIC, and fouling for the inte rnal surfaces of stai nless steel containment i solation pipi ng, pip ing com ponen ts, and pipi ng ele ments i n cont act w ith ra w or untrea ted w ater.On the basis o f its review , pending sati sfactory resoluti on of the open i ssue, the project team found that the app licant appro priately addressed the aging effect/mechanism, as recommen ded by th e GALL Repor t.3.2.2.1.4 General, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion and Fouli ng in Steel C ontainment Isol ation Compone nt Exposed to Raw Water In the OCGS LRA , Section 3.2.2
.2.7.2 the appl icant provi ded its further ev aluation to address loss of material due to general , pitting, crev ice and M IC and foulin g that could occ ur for steel contai nment i solat ion p ipin g, pipi ng compo nents, and p ipin g eleme nts in conta ct wi th raw wate r.In the OCGS LRA , the appli cant stated that th is Item number i s not used at Oyster Creek. Item Number 3.2.1-5 discussed in 3.2.
2.2.4 above addresses loss of mat erial for steel components in an untreated w ater enviro nment due to pi tting, crevice and MIC, a nd fouling, and was used for Oyster Creek compon ents in li eu of Item Number 3.2.1-9
.The project team rev iewed S ection 3.2.2.2.4 in the OCGS L RA and found th at this aging effect/mech anism is si milar to tha t disc ussed abov e in S ectio n 3.2.2.2.4 for untrea ted w ater. Therefore, the project team d etermined that the applican t's use of the A MR assoc iated wi th the further evaluati on presented i n Section 3
.2.2.2.4 of the OCGS LR A in li eu of this further evaluati on is accep table.
337 3.2.2.1.5 Loss of Materi al Due to Ge neral Corrosi on of External Surface of Carbon a nd Low Allo y Ste el Co mponen ts In LRA Table s 3.2.2.2.1 for the co ntain ment sp ray s ystem, 3.2.2.2.2 for t he cor e spra y sy stem, and Tabl e 3.2.2.2.3 for the stan dby gas t reat ment sys tem, the a ppl ica nt pr opos ed to mana ge loss o f materia l  for th e ext ernal surface s of carb on and low allo y ste el co mponen ts ex posed to an air env ironment usin g the OCGS structures mon itoring program (AM P B.1.31). Ho wever, th e project team noted that the GALL Re port recommends the external su rfaces monitoring program (AMP XI.M3 6) to ma nage th is agi ng effect.
The project team rev iewed th e applica nt's structures mon itoring program (AM P B.1.31) and verified that this aging management p rogram included activiti es that are con sistent wi th GALL AMP XI.M 36 to manage the l oss of material i n components ex posed to an a ir external environment.
The project team dete rmined that OCGS A MP B.1.31 will adequately manage the loss o f materia l on t he ex ternal surface s of carb on and low allo y ste el co mponen ts ex posed to an air ex ternal env ironment in th e engineered s afety features syste ms.On the basis o f its review , the project team found that the appl icant appropri ately add ressed the loss of material due to general corrosion for ex ternal surfaces of carb on and low alloy steel components.
3.2.2.1.6 Loss of Materi al Due to Ge neral, Pitti ng and Crevi ce Corrosion 3.2.2.1.6.1 Loss of Materi al due to Gen eral, Pittin g and Crevi ce Corrosion
[Item 1]In the OCGS LRA , Section 3.2.2
.2.8.2, the appl icant provi ded its further ev aluation for l oss of material due to general, pitti ng, and crevi ce corrosion for steel components in the engin eered safety featur es systems exposed to condensation, treat ed water, or air-indoor uncontrolled, in accordance with the draft Januar y 2005 SRP-LR.
In the OCGS LRA , the appli cant stated that th e Oyster Creek en gineered safety feature s systems hav e no steel piping, pipi ng components, or pi ping elements (i nternal surfaces) exposed to condensation , treated wate r, or air-indo or uncontroll ed enviro nments.The project team noted that the contai nment isolati on system at Oy ster Creek incl udes steel components that a re exposed to treated wa ter on the in ternal surface. Therefore, th e applica nt was asked to clarify the c redited AM Ps for loss of materia l due to genera l, pitting and crevice corros ion i n stee l pip ing, pi ping co mponen ts, and pipi ng ele ments i n cont act w ith tre ated w ater, and to clari fy the discre pancy in th e state ment, ?Oyster Creek Engin eered Safety Fe atures Systems hav e no steel piping, pipi ng components, or pi ping elements (i nternal surfaces) expo sed to conde nsati on, tre ated w ater, o r air-i ndoor uncon troll ed env ironme nts."In its response , the appli cant stated that th e Oyster Creek LR A used li ne item 3.2.1-10 (E-08)and associa ted further eval uation secti on 3.2.2.2.8.1 for stee l piping i n contact w ith treated w ater in the engine ered safety features (E SF) systems.
In the GALL Re port, this li ne item inv oked the water chemi stry and one-time inspecti on programs wi th further evalu ation recommende d, and was clea rly the ap plicable choice for managin g aging effects in water-ca rrying process piping for the ESF sy stems. Line i tem 3.2.1-10 w as only used for Oyster Cre ek as related i tem E-40 for steel closure bolting in the standby gas trea tment system. In the Januar y 2005 draft GALL, this line item s pecifi es a p lant s pecifi c progra m for agin g manageme nt.
338 The applican t also stated that the statement i n the associ ated further eval uation Secti on 3.2.2.2.8.2 for item 3.2.1
-10 (that the ES F systems hav e no carbon s teel pipi ng, piping components, or pi ping elements (i nternal surfaces) e xposed to condensation , treated wate r, or air-indoor u ncontrolled environments) was made within the context o f this line i tem's appli cation to a wetted-air internal environment, and was not used for the steel piping lines of the ESF sy ste ms.  "Tr eat ed Water" wa s i ncl ude d to mat ch t he wo rdi ng i n S ect io n 3.2.2.2.8.2 o f th e d raft January 200 5 SRP-LR. To correct this di screpancy, thi s statement wi ll be rev ised in a suppl ement d ocumen t.In its letter d ated April 17, 2006 (M L061150320), th e applica nt committed to rev ise the further eval uatio n in S ectio n 3.2.2.2.8.2 of the OC GS LRA to sta te that Oyste r Cree k engine ered s afety features systems ha ve no stee l piping, pi ping components, o r piping ele ments (internal surfaces)exposed to condensation , treated wate r (in the form of conden sation we tting the interna l surface), or ai r-indo or unc ontrol led e nvir onments. This is A udit Commitment 3.2.2.1.6
-1.The project team rev iewed Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 in the OCGS LR A for the ESF sy stems a nd con firmed th at no s teel c ompone nts ex posed to con densa tion a re ide ntifie d. Therefore, the project team found that the appl icant's commitmen t to revise the further evaluati on in Secti on 3.2.2.2.8.2 of the OCGS LRA is acceptable.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed the loss of material due to general , pitting and c revice corro sion for interna l surfaces of carbon and low al loy steel components.
3.2.2.1.6.2 Loss of Materi al due to Gen eral, Pittin g and Crevi ce Corrosion
[Item 2]In the OCGS LRA , Table 3.2.2.1.3 for the standby gas treatment system i ncludes AM R line items fo r loss of materi al du e to gen eral, pitti ng, and crev ice co rrosio n of stee l bol ting ex posed to air with steam or wa ter leakage. The app licant propo sed to manage thi s aging effect using the OCG S str uctu res m onit orin g pr ogr am (A MP B.1.31). Gene ric no te E was cite d fo r the se AMR line items, indicating th at the material , environmen t, and aging effect were consistent w ith the GALL R eport; howe ver, a differen t aging m anageme nt progr am wa s credi ted. Th e GALL Repor t recomme nded t he Bol ting In tegrity Program (AMP XI.M1 8).The project team rev iewed th e applica nt's structures mon itoring program (AM P B.1.31) and determined that it is consi stent with the recommendation s in the Bo lting Integrity P rogram (XI.M18) recommended by the GAL L Report for this aging effect. On this basi s, the project team determined that the program credite d to manage loss of mat erial of the steel bolting is appropriate.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of materi al du e to gen eral, pitti ng, and crev ice co rrosio n for ste el bo lting expo sed to air w ith steam or water leakage in the e ngineered safety features systems.
Conclusio n The project team has evaluated the appli cant's claim o f consistency with the GALL Report. The project team also has revi ewed in formation pertaini ng to the appli cant's conside ration of recent operat ing ex perie nce an d prop osals for mana ging ass ociat ed agi ng effects.
On the basi s of its review , the project team found that the AM R results, w hich the app licant cla imed to be consi stent w ith th e GALL Repor t, are c onsis tent w ith th e AM Rs in the GA LL Rep ort.
339 3.2.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In OCGS LRA Se ction 3.2.2.2, th e applica nt provide d further evalu ation of aging management as recommended by the GALL Rep ort for the aging effects related to the contain ment spray system, core sp ray system, and standby gas treatment syste m components and component groups. The appli cant also pro vided i nformation concerni ng how it w ill manage th e related agin g effects.Project Team Eval uation For some AM R line-ite ms assigned to the project team in the OCGS LRA Tabl es 3.2.1, the GALL Report reco mmends further eval uation. When further evalua tion is reco mmended, the project team revi ewed these further evalua tions provi ded in OCGS L RA Section 3.2.2.2 against the criteria p rovided i n the SRP-LR Section 3.2
.2.2. The project tea m's assessments o f these evaluati ons are documen ted in this section. These assessments are a pplicabl e to each Tabl e 2 AMR li ne-item in Se ction 3.2 ci ting the item in Table 1.3.2.2.2.1 Cumu lati ve F atig ue D amage In LRA Secti on 3.2.2.2.1, the applicant s tated that fatigue is a TLAA, as de fined in 10 C FR 54.3.Applicants must evalua te TLAAs in a ccordance w ith 10 CFR 54.21(c)(1). The ev aluation o f the TLAAs was performed by NRR/DE staf f and is addressed separately in Section 4 of the SER related to the OCGS LRA.
3.2.2.2.2 Loss of Materi al due to C ladding Loss of material due to cladd ing breach coul d occur for  PWR steel pump cas ings with stainless steel cladding exposed to treated borat ed water. The staff concurred with the applicant's eval uatio n that this a ging effect is no t appl icabl e sin ce Oys ter Cre ek is a BWR plant.
3.2.2.2.3 Loss of Materi al Due to P itting and Crev ice Corrosi on 3.2.2.2.3.1 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 1]
The project team rev iewed OC GS LRA Secti on 3.2.2.2.3.1 agai nst the criteri a in SRP-L R Section 3.2.2.2
.3.1.SRP-LR Section 3.2.2.2.3.1 st ated that loss of mate rial due to pitting and crevice corrosion could occur for internal surfaces of stainle ss steel conta inment isol ation pipi ng, piping compone nts, and pipin g elements exp osed to treated water. The ex isting AM P relies o n monitoring and control of wa ter chemistry to mitigate degradati on. Howe ver, control of water chemis try does not preclude lo ss of material du e to pitting an d crevice corrosion at l ocations of stagnant flow condi tions. There fore, the effectiv eness of the ch emistry contro l progr am shou ld be veri fied to ensure that corros ion is no t occurring. The GALL Report recommends further evalua tion of programs to verify the effectiveness of the chemistry control program. A one-time insp ection of select compone nts at suscepti ble locati ons is an a cceptable metho d to determine whether an aging effect is not occurri ng or an aging effect is pro gressing very slowly such that the component's i ntended function will be maintaine d during the pe riod of extend ed operation.
340 In the OCGS LRA Section 3.2
.2.2.3.1, the appl icant stated th at Oyster Creek w ill use the Water Chemistry P rogram, B.1.2, to manage agin g of stainless stee l piping a nd components e xposed to trea ted in the co ntain ment sp ray s ystem, conta inment vacu um brea kers sy stem, co ndens ate transfer system, core spray sys tem, isolation condenser sy stem, nuclear bo iler instrume ntation system, post-acci dent samplin g system, and rea ctor recirculati on system. The program activiti es provid e for monitoring and controllin g of water chemistry using station procedures and proces ses for t he pre venti on or m itigat ion o f loss o f materia l agin g effects.
The One-Time Inspec tion P rogram, B.1.24, wil l be u sed i n each of these syste ms for v erifica tion o f chemis try control and c onfirmation of the abs ence of loss of materi al. Observe d condition s that have the potential for i mpacting the inte nded function a re evalua ted or corrected in accordanc e with th e corrective a ction process.
The applicant furth er stated that the ASME Section XI Inser vice Inspection, Subsections IW B, IW C, and IWD program, B.1.1, wil l be used to inspect the isolatio n condenser s tainless ste el tubes and tube side compone nts to ensure th at significant de gradation is n ot occurring and the component inten ded function w ill be mai ntained duri ng the extende d period of ope ration.Observed cond itions that h ave the po tential for impac ting the intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The app lica nt wa s asked to cl arify whi ch AM Ps are credi ted for ma naging l oss of ma terial due to pitting and cre vice corros ion in sta inless stee l components o f the containment i solation sy stem exposed to treated water.
In its respon se, the appli cant stated that th e September 200 5 Revision 1 SRP-LR changed line item E-33 to apply specifically to Stainless steel (SS) contai nment i solat ion p ipin g in a treated wate r env ironme nt, and now speci fies Water Ch emistry and One-Time Inspec tion as the A MPs to be used, in l ieu of a plan t-specific program as specified in the January 2005 draft SRP-L R. The Oyster C reek LRA speci fies this same l ine item E-33 for SS piping and c omponents in a treated wa ter environ ment, and lis ts the Water Chemistry an d One-Time Inspecti on AMPs , in accordan ce with the September 20 05 Revi sion 1 SRP-L R. Li ne Item EP-32 is al so use d in t he Oys ter Cre ek LRA for loss of materi al du e to pitting and cre vice corros ion in SS piping and components in containment is olation pi ping in a treated water environment.
This line item, whic h specified p lant-specific p rograms in the January 200 5 draft SRP-LR a nd now s pecifies Water Chemistry and One-Time Inspectio n Programs in the S eptember 2005 R evision 1 SRP-LR, i s used at Oy ster Creek wi th the AMP s of W ater Chemistry and One-T ime Inspection, in accordance with the SRP-LR. Thus , this is consistent w ith the SRP-LR recommendatio ns.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.3.1 for further ev aluation.3.2.2.2.3.2 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 2]
The project team rev iewed OC GS LRA Secti on 3.2.2.2.3.2 agai nst the criteri a in SRP-L R Section 3.2.2.2
.3.2.SRP-LR Section 3.2.2.2.3.2 st ated that loss of mate rial from pitting and cr evice corrosion could occur for stainle ss steel pi ping, piping co mponents, and pi ping elements e xposed to soil. The GALL Report reco mmends further eval uation of a pl ant-specific AM P to ensure th at the aging effect is adequately managed.In the OCGS LRA Section 3.2.2.2.
3.2, the applicant stated that the AMR associated with this further evaluati on is not u sed at Oyster C reek. The engineered safety features sys tems have no 341 stainless ste el pipin g, piping componen ts or piping e lements in co ntact with soil, untreate d, or raw wa ter (includi ng internal co ndensation).
Oyster Creek has no external or partiall y encased stainless steel tanks in the scope of license renewal.
The project team rev iewed th e AMR l ine items for the engineered safety feature systems an d verified that no stainless steel piping, piping components or piping elements in contact with soil, untreated, or raw water (in cluding inte rnal condens ation) we re identified as being w ithin the scope of licen se renewal. Therefore, the project te am concurred w ith the appl icant's con clusion that thi s AM R is not appl ica ble to Oy ster Cre ek.3.2.2.2.3.3 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 3]
The applican t addressed the further evalua tion for loss of materi al due to p itting and crev ice corrosion for stai nless steel piping, pip ing components, an d piping el ements expose d to treated wate r in L RA Se ction 3.2.2.2.3.1, in ac cordan ce wi th the draft Jan uary 2005 S RP-LR. There fore The project team rev iewed OC GS LRA Secti on 3.2.2.2.3.1 agai nst the criteri a in SRP-L R Section 3.2.2.2
.3.3.SRP-LR Section 3.2.2.2.3.3 st ated that loss of mate rial from pitting and cr evice corrosion could occur fo r BWR stainl ess ste el an d alu minum p ipin g, pipi ng compo nents, and p ipin g eleme nts expo sed to treate d wa ter. The exi sting A MP re lies on mon itori ng and contro l of w ater ch emistry for BWRs to mitigate degradation. Ho wever, co ntrol of water chemistry doe s not preclud e loss of material due to pitting and c revice corro sion at lo cations of stagnant flow conditions
.Therefore, the effectiveness of the chemistry control program shou ld be ve rified to ensure that corros ion i s not o ccurri ng. The G ALL R eport r ecommen ds furthe r eva luati on of pr ograms to verify the e ffectiveness of the w ater chemistry control program. A one-time insp ection of selec t components at su sceptible l ocations is an acceptabl e method to dete rmine wheth er an aging effect is not occurring or an aging ef fect is progres sing very slowly such that the component's intended functio n will be maintain ed during the p eriod of exten ded operation
.In the OCGS LRA , Section 3.2.2
.2.3.1, the appl icant stated th at the Water Chemistry Program (AMP B.1.2) and the One-Time Ins pection Program (AMP B.1.24) will be used to manage th is a gi n g e ff e c t. T h e p r o j e c t t e a m's e v a l u a t i o n o f O C G S L R A S e c t i o n 3.2.2.2.3.1  f o r B WR stainless steel piping, piping componen ts, and piping elements exposed to treat ed water is discu ssed i n Sect ion 3.2.2.2.3.1 of th is au dit an d rev iew report.The project team noted that the appl icant did not provid e a further eval uation for alumi num piping ex posed to treated. The project team rev iewed th e AMR l ine items i n Tables 3.2.2.1.1
, 3.2.2.1.2, and 3.2
.2.1.3 in the OC GS LRA and d etermined that the re is no al uminum pipi ng exposed to treated water in the engine ered safety features s ystems. Therefore, there was no need to perform a f urther evaluation for this mat erial.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.3.3 for further ev aluation.3.2.2.2.3.4 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 4]
The project team noted that the appl icant did not credit the GALL Report AM R for loss of material due to pitting and crevice co rrosion for stainl ess steel an d copper all oy pipi ng, piping components, and piping eleme nts exposed to lubricati ng oil, wh ich is ass ociated w ith this further 342 evaluati on, for the Oyster C reek engineered sa fety features systems.
This was a new AM R that was n ot in the dra ft Janua ry 20 05 GAL L Repo rt.The applican t was asked to clarify w hich AM Ps are credite d for loss of material from pitting and crevice co rrosion for stainl ess steel an d copper all oy pipi ng, piping compone nts, and pipi ng elements ex posed to lub ricating oil in the engin eered safety features systems.In its response , the appli cant stated that l ine items EP
-45 and EP-51 , addressed i n the September 2005 Revisio n 1 SRP-LR, Section 3.2.2.2
.3.4, are new line ite ms that were not contained in the January 2005 draft SRP-LR used in prepar ing the Oyster Creek LRA. T his MEA combination is not present in ESF systems at Oyster Creek. The Oyster Creek LRA addres ses lo ss of mat erial in SS in a lubri catin g oil envi ronmen t for oth er sy stems w ith l ine i tems AP-59 (LRA Secti on 3.3.2.2.12.2) and SP-38 (LRA Secti on 3.4.2.2.8).The applican t further stated that, for ES F systems, Oy ster Creek LRA Tabl e item 3.2.1-34 (EP-21) indi cates no aging effect for SS p iping, pipi ng components, and piping eleme nts in a lubricating o il envi ronment. This is consistent w ith the Janua ry 2005 dra ft SRP, Table 3.2-1 item 34. Howe ver, since this material
/environment is not presen t in the Oys ter Creek ESF sy stems, LRA Table 3.2
.1, Item 3.2.1-34 w ill be re vised to state that the M EA combinati on is not applicabl e to the Oyste r Creek ESF sy stems.In its letter dated April 17, 2006 (ML061150320), the applicant committed to revise OCGS LRA Table 3.2.1, li ne item 3.2.1-34 related to sta inless stee l piping, pi ping components, a nd piping elements exposed to lubricating oil in the engineered saf ety features systems to state that this materi al/en viro nment c ombina tion i s not a ppli cable to Oys ter Cre ek. This is A udit Commitment 3.2.2.2.3-1.
The project team rev iewed th e AMR l ine items i n Tables 3.2.2.1.1 , 3.2.2.1.2, and 3
.2.2.1.3 in the OCGS LR A for the ESF s ystems , and v erifie d that no sta inle ss stee l or c opper allo y comp onents exposed to lubricating o il are pres ent in ESF systems at Oy ster Creek. Therefore, the p roject team found the applicant's com mitment acceptable, and this further evaluation is not applicable to Oy ster Cre ek.3.2.2.2.3.5 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 5]
The applicant addressed loss of material due to pitting and crevice corrosion f or partially encased stai nless steel tanks in Secti on 3.2.2.2.3.2 of the OCGS LRA, in accordance w ith the draft January 20 05 SRP-LR.
Therefore, the project team re viewe d Section 3
.2.2.2.3.2 of the OCGS LRA agains t the criteria in SRP-LR Section 3.2.2.2
.3.5.SRP-LR Secti on 3.2.2.2.3.5 state d loss of materia l from pitting and crevice co rrosion coul d occur for of partially encased stai nless steel tanks exposed to raw w ater due to crac king of the perime ter sea l from w eather ing. The GALL R eport r ecommen ds furthe r eva luati on to e nsure that th e agin g effect is adequa tely managed. The GA LL Rep ort rec ommends that a plant-specific AMP be evaluated because mois ture and w ater can egress un der the tank if the perimeter seal is degraded In the OCGS LRA , the appli cant stated that th e Oyster Creek en gineered safety feature s syste ms hav e no s tainl ess ste el pi ping, p ipin g compon ents o r pipi ng ele ments i n cont act w ith soil, untreate d, or raw w ater (includi ng internal co ndensation).
Oyster Creek has no external or partially encased stainless steel tanks in the scope of license renewal.
343 The project team rev iewed th e AMR l ine items i n OCGS LRA Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 for the ESF systems and confirmed that the Oy ster Creek engineere d safety features syste ms hav e no s tainl ess ste el pi ping, p ipin g compon ents o r pipi ng ele ments i n cont act w ith soil, untreate d, or raw w ater (includi ng internal co ndensation).
Therefore, the project team concurred w ith the appl icant's con clusion tha t this further ev aluation i s not appli cable to Oy ster Cree k.3.2.2.2.3.6 Loss of Materi al due to P itting and Crev ice Corrosi on [Item 6]
The applicant addressed loss of material due to pitting and crevice corrosion f or partially encased stai nless steel tanks in Secti on 3.2.2.2.3.2 of the OCGS LRA, in accordance w ith the draft January 20 05 SRP-LR.
Therefore, the project team re viewe d Section 3
.2.2.2.3.2 in the OCGS LRA agains t the criteria in SRP-LR Section 3.2.2.2
.3.6.SRP-LR Section 3.2.2.2.3.6 st ated that loss of mate rial from pitting and cr evice corrosion could occur fo r stai nless steel pipi ng, pip ing com ponen ts, pi ping e lement s, and tanks e xpos ed to inte rnal cond ensa tion. The GALL Repor t rec omm ends fur ther evalua tion of a p lant-spe cif ic AMP to ensure that th e aging effect is adequatel y managed In the OCGS LRA , the appli cant stated that th e Oyster Creek en gineered safety feature s syste ms hav e no s tainl ess ste el pi ping, p ipin g compon ents o r pipi ng ele ments i n cont act w ith soil, untreate d, or raw w ater (includi ng internal co ndensation).
Oyster Creek has no external or partially encased stainless steel tanks in the scope of license renewal.
The project team rev iewed th e AMR l ine items i n OCGS LRA Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 for the ESF systems and confirmed that the Oy ster Creek engineere d safety features syste ms hav e no s tainl ess ste el pi ping, p ipin g compon ents o r pipi ng ele ments i n cont act w ith soil, untreate d, or raw w ater (includi ng internal co ndensation).
Therefore, the project team concurred w ith the appl icant's con clusion tha t this further ev aluation i s not appli cable to Oy ster Cree k.3.2.2.2.4 Reduction o f Heat Transfer Due to Fo uling 3.2.2.2.4.1 Reduction o f Heat Transfer due to Fo uling [Item 1]
The project team noted that the appl icant did not credit the GALL Report AM R for reduction o f heat tr ansfer d ue to fo ulin g for stai nless steel and c opper allo y hea t exc hanger tubes expo sed to lubricating o il, whi ch is associ ated with this further ev aluation, for the Oyster Creek engi neered safety features sys tems. This wa s a new AMR that was not i n the draft January 2005 GALL Report.The app lica nt wa s asked to cl arify whi ch AM Ps are credi ted for r educti on of he at tran sfer due to fouling  for steel, sta inless stee l, and coppe r alloy heat exchan ger tubes expo sed to lubri cating oil in th e engineered s afety features syste ms. In its respo nse, the appl icant stated th at the September 2005 Revisio n 1 SRP, Se ction 3.2.2.2.4.1, addresses li ne items EP-40 , EP-47, and EP-50 , whi ch are all new line items and w ere no t incl uded i n the J anuary 2005 draft SR P. Consequently, these items were not used in the Oyster Creek LRA. This MEA combination is not present in ESF systems at Oyster Creek. The Oyster Creek LRA used the lubricat ing oil monitoring activ ities (B.2.2) p rogram for reduction of heat transfer in alumi num heat exc hanger fins, cast iron b earing cooler housings, and c opper allo y heat ex changer tubes ex posed to a lubricating o il envi ronment in the EDG, RBCCW, and fire protection systems. The Ja nuary 2005 344 draft SRP did n ot contain the se MEA combinations, therefore plant-spec ific notes w ere applie d to these lin e items.The project team rev iewed th e AMR l ine items i n OCGS LRA Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 for the ESF systems and confirmed that the Oy ster Creek engineere d safety features syste ms hav e no s tainl ess ste el or coppe r all oy he at ex changer tubes expo sed to lubri catin g oil. Therefore, the project team c oncurred wi th the appli cant's concl usion that thi s further evalu ation is n ot ap pli cabl e to Oys ter C reek.3.2.2.2.4.2 Reduction o f Heat Transfer due to Fo uling [Item 2]
The applican t addressed red uction of heat tran sfer due to fouling for stai nless steel heat exchanger tube s exposed to treated wa ter in Attachmen t 3, Item EP-34 of i ts reconcili ation of the AMPs in the draft Janua ry 2005 GAL L Report to the approved September 2005 GALL Report. The project team reviewed the applicant's further evaluation against the criteria in SRP-LR Secti on 3.2.2.2.4.2.
SRP-LR Secti on 3.2.2.2.4.2 state d that reductio n of heat transfer due to fouling could occur for stainless ste el heat ex changer tubes ex posed to treated water. The e xisting program re lies on control of wa ter chemistry to manage reduction of heat transfer due to fouling. How ever, control of water chemis try may hav e been ina dequate. Therefore, the GALL Report recommends that the effectiveness o f the chemistry co ntrol program shoul d be veri fied to ensure tha t reduction of heat tr ansfer d ue to fo ulin g is no t occur ring. A one-ti me ins pecti on is an ac ceptab le meth od to ensure that redu ction of heat trans fer is not occurri ng and that the c omponent's i ntended function wi ll be main tained duri ng the period o f extended ope ration.In Attachment 3, Item E P-34 of its recon ciliatio n document, the a pplicant sta ted that the li ne item for stainless stee l heat ex changer tubes in treated wate r, addressing redu ction of heat trans fer due to fouling, i nvoked the Water Chemistry Program with n o further evalu ation required in the draft Jan uary 2005 GA LL Rep ort. Thi s has b een ch anged i n the S eptembe r 2005 GALL R eport to wa ter che mistry and o ne-tim e ins pecti on, w ith  a n eva luati on of agi ng effects require d. Ther e are 2 i nstanc es of thi s lin e item being used i n the Oy ster Cr eek li cense renew al ap plic ation , both in the isolation condenser system, for heat exchanger tubes, internal and external.
The applican t further stated that, i n the Oyster C reek LRA, there are 132 line item instance s of one-time insp ection of stainl ess steel comp onents in a treated water environment.
While these instances are applied to aging ef fects of loss of material or cracking , they provide ample inspection opportunity for the condition of the components -
observed conditions that have th e potential for impacting an intended function are evaluated and correct ed as necessary in accordance w ith the correcti ve action process. Si nce one of the functi ons of the Water Chemistry P rogram is to prev ent or mitigate red uction of heat tran sfer due to fouling, a detected fouling conditi on on any of the components i nspected for loss of material or crac king would also be identified and entered into the correc tive acti on process. Thus , there is hi gh confidence that any insta nce of the wa ter chemistry p rogram's failure to prev ent fouling w ould be i dentified during the ins pections for los s of material due to corrosion and cracking. How ever, since the isol ation conde nser tu bes sp ecific ally wil l und ergo ed dy cu rrent te sting d uring t he first ten y ears of the period of ex tended operati on, a one-time inspection for fouling of the interna l surface of the tub es can be pe rformed a t that t ime. Th e iso latio n cond enser shell side compon ents undergo inspecti on for loss of materia l under the One-Time Inspection Program; an inspe ction of the external surface of the tubes for red uction of heat tran sfer due to fouling w ill als o be performed.
345 In its letter dated March 30, 2006 (ML060950408), the applicant committed to revise OCGS LRA Table 3.1.2.1.1 for the isolatio n condenser s ystem to incl ude two n ew lin e items inv oking one-time insp ection to sup plement the Water Chemistry Program for reduction of he at transfer due to fouling for the internal a nd external surfaces of the isol ation conden ser heat exc hanger tubes. These are n ew addi tions based on the reconci liation o f the Oyster Creek LR A between the Ja nuary 2005 draft GAL L and the ap prove d Sept ember 2 005 Re visi on 1 GA LL. This is Aud it Commitment 3.2.2.2.4-1.
The project team found tha t based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.4.2 for further ev aluation.3.2.2.2.5 Hardening and Loss of Strength Due to Elastomer De gradation The project team rev iewed OC GS LRA Secti on 3.2.2.2.5 agai nst the criteri a in SRP-L R Section 3.2.2.2
.5.SRP-LR Secti on 3.2.2.2.5 stated that hardenin g and loss of strength due to elasto mer degradation coul d occur in e lastomer seals and componen ts associated with the BWR Standby Gas Treatment System d uctwork and fil ters exposed to air-indo or uncontroll ed. The GALL Report recommends further evaluation of a plant specif ic AMP to ensure that the aging eff ect is adequately man aged.In the OCGS LRA Section 3.2.2.2.
5, the applicant stated that Oyste r Creek will use the periodic inspection of ventilation systems prog ram, B.2.4, to evaluate elastom er door seals and flexible connections in the standb y gas treatment sy stem. Periodi c inspectio ns are performed on elastomer door seals and flexible connections to ident ify leakage or detrim ental changes in material prope rties, as ev idenced by cracking, perforations i n the material. Observed co nditions that have the potential for impact ing an intended function are evaluated or cor rected in accordance w ith the correcti ve action process.The applicant was asked to confirm that door seals and flexible connections are the only components in this system w ith elastomer seals. In i ts response, the applicant s tated that regula rly o pened door s eals and fle xibl e conn ectio ns at t he fans are the only elas tomers requiring aging management i n the standby gas treatment syste
: m. Installed gaskets, component seals and o-rings are considered consumables not subje ct to an AMR, see LRA Section 2.1.6.4. The bi-we ekly SGTS surv eillance test, see PBD-AMP-B.2.04 , Table 5.1, confirms proper function of each SGTS train with acce ptance criteri a for flow rate an d reactor building di fferential pressure.
The applican t further stated that LR A Section 2
.1.6.4 states "The ev aluation p rocess for consumables i s consistent w ith the guidan ce provid ed in NUR EG-1800 Table 2
.1-3.Consumables have been divide d into the foll owing four categori es for the purpose of license renewal: (a) packing, g askets, compon ent seals, and O-rings; (b) structural sealants; (c) oil, grease, and component filters; and (d) system f ilters, fire extinguishers , fire hoses, and air packs. Group (a) sub compon ents (p acking, gaskets, seals , and O-rings): Based on AN SI B31.1 and t he ASME Code S ecti on II I, t he su bcom pone nts o f pr essu re re tain ing c ompo nent s as sh own abov e are n ot pres sure-re taini ng parts. There fore, the se sub compon ents a re not relie d on to form a pre ssure-retain ing func tion a nd are not su bject to an AM R." The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is 346 appropriate to detect hardeni ng and loss o f strength of elastomer seal s and componen ts. The tec hni cal ev al uat io n o f th is pro gra m to de ter min e i ts a deq uac y w as p erfo rme d b y N RR/DE sta ff, and i s addr essed in the SER r elate d to th e Oyst er Cre ek plan t.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.5 for further ev aluation.3.2.2.2.6 Loss of Materi al Due to E rosion In Section 3
.2.2.2.6 of the OCGS LR A, the appli cant stated that l oss of material d ue to erosion of the PWR HPSI pump mini flow orifice is a pplicabl e to PWRs only. The proje ct team concurred w ith the appl icant's ev aluation th at this aging effect is n ot applicab le since Oy ster Creek i s a BWR pla nt.3.2.2.2.7 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion, an d Fouling The applican t addressed l oss of material d ue to general, p itting, crevi ce, and M IC for steel drywell and suppression chamber spray system nozzles in Section 3.2.2.2.9 of the O CGS LRA, in accordanc e with th e draft January 2005 SRP-LR. Therefore, the project te am review ed OCGS LRA Secti on 3.2.2.2.9 agai nst the criteri a in SRP-L R Section 3
.2.2.2.7.SRP-LR Secti on 3.2.2.2.7 stated that loss of materi al due to gene ral corrosion and fouling can occur for steel dry well a nd suppressi on chamber spray system noz zle and flow orifice i nternal surfaces expose d to air - i ndoor uncontrol led. This co uld result i n plugging of the spray nozzl es and flow ori fices. This aging mech anism and effect w ill appl y since the spray no zzles and flow orific es are occ asionally wet ted, even though the maj ority of the time this syste m is on sta ndby.The wetting and drying of these components can accelerate corro sion and foul ing. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that the aging effect is adequately man aged.In OCGS LRA Se ction 3.2.2.2.9, the applica nt stated that the AMR as sociated w ith this further evaluati on is not u sed at Oyster C reek since the c ontainment spray nozzl e and orifice assemblies used at Oyster Creek are stainless steel.
The project team rev iewed th e AMR l ine items i n Tables 3.2.2.1.1 , 3.2.2.1.2, and 3
.2.2.1.3 in the OCGS LRA for the eng ineered safety feat ures and verified that the containm ent spray nozzle and orifice ass emblies used at Oyster Cree k are stainless steel; not ste el. Therefore, the pro ject team co ncurre d wi th the appli cant's conc lusi on tha t this further eval uatio n is n ot app lica ble to Oys ter C reek.3.2.2.2.8 Loss of Materi al Due to Ge neral, Pitti ng and Crevi ce Corrosion 3.2.2.2.8.1 Loss of Materi al due to Gen eral, Pittin g and Crevi ce Corrosion
[Item 1]The project team rev iewed OC GS LRA Secti on 3.2.2.2.8.1 agai nst the criteri a in SRP-L R Section 3.2.2.2
.8.1.SRP-LR Secti on 3.2.2.2.8.1 state d that loss o f material due to general, pittin g and crevic e corros ion c ould occur fo r BWR steel pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to treated water. The existing AMP relies on monitoring and cont rol of water chemistry for BWRs 347 to mitigate degradati on. Howe ver, control of water chemis try does not preclude lo ss of material due to general, pitting, and crev ice corrosio n at locatio ns of stagnant flow conditions.
Therefore, the effect iveness of the chemistry control prog ram should be verified to ensure that cor rosion is not occurring. The GALL Report reco mmends further eval uation of programs to v erify the effectiveness of the w ater chemistry control program. A one-time insp ection of selec t components at su sceptible l ocations is an acceptabl e method to dete rmine wheth er an aging effect is not occurring or an aging ef fect is progres sing very slowly such that the component's intended functio n will be maintain ed during the p eriod of exten ded operation
.In the OCGS LRA Section 3.2
.2.2.8.1, the appl icant stated th at Oyster Creek w ill use the Water Chemistry P rogram, B.1.2, to manage agin g of steel pipin g, piping componen ts, and pipi ng elements ex posed to a trea ted water en vironment i n the contain ment spray sy stem, core spray syste m, isol ation conde nser sy stem, po st-acci dent s ampli ng sys tem, and reacto r press ure vessel. The program activi ties provi de for monitoring an d controlli ng of water chemis try using station proced ures and proce sses for the prev ention or miti gation of loss of materi al aging effects. The One-Time Inspectio n Program, B.1.24, w ill be u sed in each of these systems for verification of chemist ry control and confirmation of the absence of loss of mat erial. The periodic inspection of containment spray nozzl es program, B.2.1, w ill als o be used to manage corrosion of steel pipi ng and pipin g components in the containment spray sys tem. Observed c onditions that have the potential for impact ing the intended function ar e evaluated or corrected in accordance w ith the correcti ve action process.The project team noted in the AM R technical basis docu ment, OC-AMR-2.3
.2.2 for the containment spra y system, tha t the appli cant has credi ted the period ic testing of contai nment spray nozzles AMP (B.2.1) to manage plugging by rust f rom carbon steel piping compone nts in the containment (drywel l and torus) s pray syste
: m. In accordance with the OCGS AMP B.2.1, the periodi c containment s pray noz zle flow testing is pe rformed every fifth refueli ng outage. The AMP al so stated that the OCGS containmen t spray noz zles are stainless ste el, and there are no carbon steel flow orifices in the system piping. However, the upstream carbon steel piping is subject to general corrosion. F rom the operatin g experience , it was noted that duri ng the last test in 2000, two noz zles di d indicate no flow due to plugging by rust particles from the carbon steel piping components, indicating that the test freq uency may not provide reasonable assurance that th ese spray n ozzles will remain operati onal to perform thei r intended functi on between tes ting periods.
In light of this, th e applica nt was asked to provide the technica l justification for performing th e periodic containment spra y nozz le flow tes ting every fifth refueling outage.In its response , the appli cant stated that d uring the last regularly sc heduled con tainment spray nozzle air test performed d uring outage 18R in 2000, tw o suppressio n chamber noz zles indi cated some de gree of flo w bl ockage. No dry wel l spra y noz zles were found t o be b locked. The cause w as suspected to be deposi tion of corrosion particles from carb on steel pi ping upstream of the noz zles. That c orrosion w as suspected to be a resul t of the cycli c wetting an d drying of the piping that had occur red when the system was tested monthly using torus water in the pa st.The applican t also stated that in order to schedule a subsequent repa ir, an anal ysis w as performed regarding the op erability of the suppressi on chamber spray system w ith the blo cked nozzle s. The analy sis determined that the SAR containment ac cident anal yses are un affected by suppress ion chamber n ozzle blockage. The anal ysis assu med that all ten suppressio n chamber nozz les were blocked, and de monstrated that the plant design basis acci dents could be successfully mitigated. GE pro vided co ncurrence to the conclusio n that the conta inment 348 accident ana lysis i s not significan tly impacte d by blo ckage of the suppressio n chamber noz zles (Letter, N. Trikouros [GE] to D. Robare [GE], Impact of Operation of Oy ster Creek wi th Partial Clogging of Torus Spray Nozzl es, NSA00416 , DRF T23-00787
-00, November 8, 2000). Bas ed on these anal yses, repai r of the two bl ocked nozz les was scheduled for the next refueli ng outage, 19R, in 2002.The applican t further stated that i n 2002, duri ng refueling outage 19R , the suppressi on chamber spray heade r was flushed with w ater, such as w ould occur d uring an actuati on of the suppression chamber spray.
Subsequent to th is, the noz zle air flow test w as re-performed, and all noz zles show ed clear, mean ing that the w ater spray ha d dislodged the particles that caused the pre viou s ind icati on of no zzl e plu gging dur ing the 2000 air te st.The applican t further stated that  te sting interva l of once ev ery fifth refueling outa ge for perfo rmin g the noz zle air test is j usti fied bas ed o n the foll owi ng: 1.Monthly water testi ng of the piping i s no longer pe rformed, removing the so urce of regular wetti ng and dryin g of the carbon steel piping upstre am of the nozz les whi ch fa cil itat ed c orro sio n of t he p ipi ng.2.Flushing of the s ystem wi th water, as would o ccur during an actuation of the suppression chamber spray, discharged and cleared the n ozzles that did sho w as plugged during the air test in 2 000.3.The analyse s performed to determin e operabil ity of the sy stem with tw o plugged nozzle s showed that SAR conta inment accide nt analys es are unaffected by suppression chamber nozz le blockage, ev en when all ten su ppression ch amber noz zle s w ere a ssum ed to be b loc ked, and demo nstr ated that the pla nt de sign basis acci dents could be successfully mitigated.
The project team rev iewed th e applica nt's response and determined that the test i nterval for performing the containment spray nozzle flow testing of once every fif th refueling outag e is acceptable s ince action s have be en taken to mitigate the possibi lity of corros ion products from upstream steel p iping blockin g the spray no zzles.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.8.1 for further ev aluation.3.2.2.2.8.2 Loss of Materi al due to Gen eral, Pittin g and Crevi ce Corrosion
[Item 2]The project team noted that the appl icant did not credit the GALL Report AM R for steel containment is olation comp onents expo sed to treated w ater, which is associ ated with this further evaluati on, for the Oyster C reek engineered sa fety features systems.
This was a new AM R that was n ot in the dra ft Janua ry 20 05 GAL L Repo rt.The project team rev iewed Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 in the OCGS LR A for the ESF systems and noted that other GALL AMR line items that address same material/
environment combinations were appro priately credited. Therefore, the project team determi ned that thi s furt her e val uati on i s no t app lic abl e to Oys ter C reek.
349 3.2.2.2.8.3 Loss of Materi al due to Gen eral, Pittin g and Crevi ce Corrosion
[Item 3]The p roje ct te am no ted t hat t he a ppl ica nt di d no t cre dit the G ALL Rep ort A MR for s teel pip ing, piping components, and piping elem ents exposed to lubricating oil, which is associated with this further evaluati on, for the Oyster C reek engineered sa fety features systems.
This was a new AMR that w as not in th e draft J anuary 2005 GALL R eport.The applicant was asked to clarify which AMPs are credited for loss of material due to general, pitting and cre vice corros ion for steel p iping, pipi ng components, and piping eleme nts exposed to lubricati ng oil in the engineered safety features sys tems. In its resp onse, the appl icant stated that September 20 05 Revi sion 1 SRP Section 3.2
.2.2.8.3 addressed line ite m EP-46. This i s a new li ne item that w as not in the January 2 005 draft SRP. Thi s MEA co mbination i s not present in ESF sy stems at Oyster C reek. The Oyster Cre ek LRA used l ine items AP
-30 (3.3.1-16) and SP-25 (3.4.1-3) for c arbon steel pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to lubricating o il in oth er systems.
The project team rev iewed Tabl es 3.2.2.1.1, 3.2.2.1
.2, and 3.2.2.1.3 in the OCGS LR A for the ESF sy stems a nd con firmed th at no s teel c ompone nts ex posed to lu brica ting oi l we re ide ntifie d. Therefor e, the project team found the applicant's response accept able, and concluded that this furth er ev alu atio n is not appl ica ble to Oy ster Cre ek.3.2.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion The applicant addressed loss of material due to general corros ion for steel piping buried in soil in Secti on 3.2.2.8.3 of the OC GS LRA , in a ccorda nce w ith th e draft J anuary 2005 SRP-L R. Therefor e, the project team reviewed OCGS LRA Section 3.2.2.2.8.3 against the criteria in SRP-LR Secti on 3.2.2.2.9.
SRP-L R Sect ion 3.2.2.2.9 state d that loss o f materia l due to gene ral, p ittin g, crev ice, a nd M IC could occur for steel (wi th or with out coating or w rapping) pipi ng, piping compone nts, and pipi ng elemen ts buri ed in soil. The b uried pipi ng and tanks i nspect ion p rogram re lies on in dustry practice, frequency of pipe exca vation, an d operating ex perience to ma nage the effects of loss of material from general, p itting, and crev ice corrosio n and MIC. The effectiveness of the buried piping and ta nks inspection program should b e verified to evaluate an appli cant's inspecti on frequency and operat ing experience with buried components, ensuring that loss of material is not o ccur ring.In the OCGS LR A Sect ion 3.2.2.2.8.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a Buried Pi ping Inspection Program, B.1.26, to man age the loss o f material in ste el pipin g, piping components, and piping eleme nts exposed to soil i n the contain ment spray sy stem. The Buried Piping Inspection Progra m includes preventive measures to mitigat e corrosion and periodic inspection to manage the effects of corrosio n on the press ure-retaining cap acity of buri ed steel piping, pipi ng components, and piping eleme nts. Observed conditions that have th e potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process. Oyster Creek engineered safety f eatures systems have no buried steel tanks in the scope of license renewal.
The applicant was asked to clarify which AMPs are credited for loss of material due to general, pitting, crevi ce, and M IC in steel (with or without co ating or wrap ping) piping, p iping componen ts, and pipin g elements burie d in soil. In its respo nse, the appl icant stated th at September 200 5
350 Revision 1 SRP Section 3.2.2.2.9 addressed line item E-42 for loss of material in steel piping in a soil en vironment du e to general, pi tting, and crev ice corrosio
: n. MIC w as added to th e aging mechanisms in the September 20 05 Revi sion 1 SRP. This item i s addressed i n the Oyster Creek LRA in the ESF secti on (E-42, Table 3.2.1-12, LRA S ection 3.2.2.2.8
.3). The Buried Piping Inspec tion Program B.1.26 addresses agin g effects from the MIC aging mecha nism as referenced in the reconcilia tion document, A ttachment 5, Item No.
: 17. The Septembe r 2005 Revisio n 1 GALL now specifies v erification that at least one focused or opportun istic insp ection in historic ally or suspected susce ptible area s be performed prio r to the perio d of extended operation but within the past 10 y ears. This is addressed in the Oyster Cre ek LRA descrip tion of the Bu ried P ipin g Inspec tion P rogram B.1.26 a s refere nced i n the r econci liati on doc ument, Attachment 1, OC P rogram No. B.1.26.
The project team rev iewed th e applica nt's response and determined that the appl icant's agin g manageme nt rev iew is co nsiste nt wi th the recomme ndati ons i n the GA LL Rep ort.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.2.2.2.9 for further ev aluation.3.2.2.2.10 Quali ty As suranc e for Agi ng Ma nagemen t of Non-Safety-Rela ted Co mponen ts OCGS LRA Section 3.2.2.2.10 is reviewed by NRR/DE staff and will be addressed separately in Section 3 of the SER related to the OCG S LRA.Conclusio n On the basis o f its review , for component groups e valuated in the GALL R eport for whic h the GALL Report reco mmends further eval uation, the pro ject team determined that the appl icant adequately a ddressed the i ssues that w ere further eval uated. The project team found that the applicant h as demonstrated th at the effects of aging wi ll be ade quately managed so that the intended functio ns wil l be maintai ned for the perio d of extended operation, as required by 10 CFR 54.21 (a)(3).3.2.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Summary of Information i n the Appli cation In OCGS LRA Tabl e 3.2.1, Summary of Aging Management E valuatio ns for the Engineere d Safety Features, the applicant provided information regar ding components or mat erial/envi ronmen t combi natio n in t he GAL L Repo rt that it ev aluat ed and iden tified as no t appl icabl e to its pl ant.In OCGS LRA Tabl es 3.2.2.1.1 through 3.2.2.1.3, the app licant prov ided addi tional deta ils of the resu lts o f th e AMRs f or ma ter ial, e nviro nmen t, ag ing e ff ect r equ iring mana gem ent, and AMP combinations that are not con sistent wi th the GALL Re port. Specifica lly, the applicant i ndicated, via Notes F through J, that neither the i dentified compon ent nor the materi al/ envi ronment combination is eval uated in the GALL Report a nd provid ed information co ncerning how the aging effect requiring management wi ll be managed
.
351 Project Team Eval uation The project team reviewed additional details of the results of the AMRs for mat erial, environment, aging effect requiring management, and AMP co mbinations tha t the appli cant ident ified as not appl icabl e to i ts pla nt.The project team did not revie w the resul ts of the AMR s for material, env ironment, aging effect requiring management, and AMP co mbinations tha t are not consi stent with the GALL Repo rt or are no t ad dre sse d i n th e GA LL Rep ort. Th ese AM R l in e i tem s w ere rev ie we d b y N RR/DE sta ff, and are discussed in the SER related to the OCGS LRA.
3.2.2.3.1 Aging E ffect/mecha nism i n Tabl e 3.2.1 That Ar e Not A ppli cable for OCGS The project team rev iewed OC GS LRA Table 3.2.1, whic h provide s a summary of agin g manageme nt ev aluat ions for the e nginee red sa fety feat ures e valu ated i n the GA LL Rep ort.In OCGS LRA Tabl e 3.2.1, Item 3.2.1-14 , the appli cant stated that l oss of fracture toughness due to thermal aging embrittlement for ca st austenitic stainless ste el pipin g, piping componen ts, and pi ping e lement s exp osed t o treat ed w ater >2 50&#xba;C (>482&#xba;F) is no t appl icabl e at OC GS. Oyster Creek has no CASS component s susceptible to thermal aging embrittlement located in the po rtions of the E SF Sy stems go verne d by Group B Quali ty Sta ndards. CAS S comp onents locat ed in the po rtions of the E SF Sy stems go verne d by Group A Quali ty Sta ndards are discussed i n Item Number 3.1.1-4 3 and Item Numbe r 3.1.1- 47.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and con firmed that Oyster Creek has no CA SS components susceptible to thermal aging e mbrittlement loc ated in the portions of the ESF Systems . Ther efore, the proj ect team concurred with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-15 , the appli cant stated that c racking due to SC C and IGSCC for stainle ss steel pi ping, piping co mponents, and pi ping elements e xposed to treated wat er >6 0&#xba;C (>14 0&#xba;F) is n ot ap pli cabl e at OCGS. Oy ster Cre ek ha s no stai nle ss s teel pip ing, piping compone nts, or pipin g elements suscep tible to stres s corrosion cra cking or intergranula r stress corrosion cracking located in the porti ons of the ESF Systems govern ed by Group B Quality S tandards. These i tems located i n the portions of the ESF Sy stems governed b y Group A Quality Standards are discussed i n Item Number 3.1.1-9
.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek h as no stain less s teel p ipin g, pipi ng compo nents, or pi ping e lement s susc eptib le to stress corrosion cracking or intergranu lar stress corros ion cracking lo cated in the portions of the ESF Syste ms governed by Group B Quali ty Standards. Therefore, the project te am concurred wi th th e ap pli cant's c oncl usi on th at th is a ging effect is n ot ap pli cabl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
352 In OCGS LRA Tabl e 3.2.1, Item 3.2.1-16 , the appli cant stated that w all thinn ing due to flow accelerated corrosion f or steel piping, piping component s, and piping elements exposed to air and steam or treate d water i s not appli cable at OCGS.
Oyster Creek has no steel p iping, pipi ng components, or pi ping elements s usceptible to flow accel erated corrosio n in the po rtions of the ESF sy stems go verne d by Group B Quali ty Sta ndards , as th ese po rtions of the E SF sy stems a re low-temperature systems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel pi ping, piping co mponents, or pip ing elements su sceptible to flow accel erated corros ion l ocated in th e porti ons of th e ESF Syst ems gov erned by Gro up B Qu ality Standards. Therefore, th e project team con curred with the appli cant's concl usion that thi s aging effect is n ot ap pli cabl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.2.1 , Ite m 3.2.1-1 7, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevice, an d galvani c corrosion for co pper alloy piping, pip ing components, an d piping el ements, and he at ex changer tubes expo sed to close d-cyc le co olin g wate r is n ot app lica ble a t OCGS. Oyster Creek h as no coppe r all oy pi ping, p ipin g compon ents, o r pipi ng ele ments e xpos ed to closed-cycl e cooling w ater in the E SF systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek h as no coppe r all oy pi ping, p ipin g compon ents, o r pipi ng ele ments e xpos ed to closed-cycl e cooling w ater in the E SF systems.
Therefore, the project team c oncurred wi th the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.2.1, It em 3.2.1-18, th e appl icant stated that l oss of ma terial due to selective leaching for cop per alloy >15% Zn pip ing, piping comp onents, and pi ping elements, and he at ex changer tubes expo sed to close d-cyc le co olin g wate r is n ot app lica ble a t OCGS. Oyster Creek has no copper al loy pip ing, piping comp onents, or pip ing elements co ntaining>15% Zn exp osed to clos ed-cycle c ooling wa ter in the ES F systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no copper al loy pip ing, piping comp onents, or pip ing elements co ntaining>15% Zn exp osed to clos ed-cycle c ooling wa ter in the ES F systems. There fore, the project team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Table 3.2.1, It em 3.2.1-20, the applicant st ated that cracking due to cyclic loadi ng, stres s corro sion crackin g for high-strengt h stee l clo sure b oltin g expo sed to air w ith 353 steam or water leakage is not a pplicabl e at OCGS. Oyste r Creek has no h igh-strength steel closure bol ting in the E SF systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no high strength stee l closure b olting in the ESF syste ms. Therefore, the project team co ncurre d wi th the appli cant's conc lusi on tha t this aging e ffect is n ot app lica ble to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-21 , the appli cant stated that l oss of material d ue to pittin g and crevi ce corrosion for stainless stee l piping, pi ping components, a nd piping el ements, and heat exchan ger shell si de components (i ncluding tube s) serviced by clos ed-cycle c ooling sys tem is not appl icable at OCGS. Oyster Cree k has no stainl ess steel pi ping, piping co mponents, or piping eleme nts, or heat ex changer shell side componen ts, includi ng tubes, expo sed to a closed-cycl e cooling w ater enviro nment in the E SF systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no stainles s steel pip ing, piping comp onents, or pip ing elements or heat exchanger shel l side comp onents, incl uding tubes ex posed to clo sed-cycle cooling w ater in the ESF systems. Theref ore, the project team concurred with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-22 , the appli cant stated that re duction of heat transfer due to fouling for stainl ess steel he at exchanger tu bes expose d to closed-c ycle cool ing water i s not applicabl e at OCGS. Oyste r Creek has no s tainless ste el heat ex changer tubes ex posed to a closed-cycl e cooling w ater enviro nment in the E SF systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no stainles s steel heat exchanger tube s exposed to closed-cy cle cooli ng water in the ESF systems. Therefore, the project team concu rred with the applica nt's conclu sion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.2.1 , Ite m 3.2.1-2 3, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevice, an d MIC an d fouling for stainl ess steel he at exchanger sh ell side components (in cluding tubes) expos ed to raw water is n ot applicab le at OCGS. Oy ster Creek has no stainless ste el heat exchanger shell side components, including tubes, exposed to a raw water environment in the ESF sy stems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no stainles s steel heat exchanger shel l side comp onents, incl uding tubes 354 exposed to raw wa ter in the ES F systems. There fore, the project team con curred with the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.2.1, It em 3.2.1-26, th e appl icant stated that l oss of ma terial due to general, pittin g, and crevic e corrosion for ste el heat ex changer shell side componen ts exposed to closed-cy cle cooli ng water is not applica ble at OCGS. Oy ster Creek has no steel heat exchanger shel l side comp onents expo sed to close d-cycle co oling wate r in the ES F systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel heat exchang er shell side components exposed to closed-cycle cooling water in the ESF systems. Theref ore, the project team concurred with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.2.1, It em 3.2.1-27, th e appl icant stated that l oss of ma terial due to general , pitti ng, crev ice, a nd M IC, and fouli ng for ste el he at ex changer shel l sid e compo nents (including tu bes) expose d to raw w ater is not ap plicable at OCGS. Oyster Creek has no stee l heat exchanger shell side components, including tubes, exposed to raw water in the ESF systems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel heat exchang er shell side components exposed to closed-cycle cooling water in the ESF systems. Theref ore, the project team concurred with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-28 , the appli cant stated that re duction of heat transfer due to fouling for steel a nd stainles s steel heat exchanger tube s (serviced by open-c ycle cool ing water) ex posed to raw water is not applica ble at OCGS. Oy ster Creek has no steel or stai nless steel heat exchanger tubes exposed to open-cycle cooling water or raw water in the ESF systems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel or s tainless ste el heat ex changer tubes ex posed to raw water in the ESF systems. Theref ore, the project team concurred with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
355 In OCGS LRA Tabl e 3.2.1, Item 3.2.1-36 , the appli cant stated that th e AMR s tating no aging effect for steel piping, pi ping components, a nd piping el ements expose d to air-ind oor uncontrolled (external), or concrete is not appli cable at OCGS.
Oyster Creek has no steel piping, piping components, or piping elements exposed to air-indoor uncontr olled in the ESF systems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel pi ping, piping co mponents, or pip ing elements ex posed to air-i ndoor uncontrolled in the ESF systems. Theref ore, the project team concurred with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-37 , the appli cant stated that th e AMR s tating no aging effect for s teel a nd cop per al loy pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to lubricating o il (no w ater poolin g) is not appl icable at OCGS. Oyster Cree k has no steel or copper allo y pipin g, piping componen ts, or piping e lements exp osed to lubri cating oil (n o water pooling) in the ESF sy stems.The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek h as no steel or cop per al loy pipi ng, pip ing com ponen ts, or p ipin g eleme nts exposed to lubricating o il (no w ater poolin g) in the ESF systems. Therefore, the project team conc urre d w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.2.1, Item 3.2.1-38 , the appli cant stated that th e AMR s tating no aging effect for s teel, stain less s teel a nd cop per al loy pipi ng, pip ing com ponen ts, and pipi ng ele ments exposed to gas is not app licable at OCGS. Oyster C reek has no steel , stainless steel or copp er alloy p iping, pipi ng components, or pi ping elements e xposed to gas in the ES F systems.
The project team rev iewed th e ESF AM R line i tems in the OCGS LRA and de termined that Oyster Creek has no steel, stai nless steel or copper al loy pip ing, piping comp onents, or pip ing elements ex posed to gas i n the ESF sy stems. Therefore, the project team concurred w ith the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
3.2.2.3.2 Engine ered S afety F eature s AM R Lin e Items That Ha ve No Aging E ffect (OCGS LRA Tables 3
.2.2.1.1 Through 3.2.2.1.3)
In OCGS LRA Tabl es 3.2.2.1.1 through 3.2.2.1.3, the app licant id entified lin e-items whe re no aging effects were ide ntified as a re sult of its aging rev iew proce ss.
356 In OCGS LRA Ta bles 3.2.2.1.1 thro ugh 3.2.2.1.3, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from a lumin um we re ex posed to an air-i ndoor uncon troll ed env ironme nt.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the enginee red safety features sy stems, and determin ed that no si gnificant aging effects were identi fied for ESF sys tem components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team found that alum inum exposed to an air-indoor uncontrolled environment will not result in aging that wi ll be of conc ern during the p eriod of exten ded operation. Therefore, the project team determined that there are no applicable aging eff ects requiring ma nagement f or this material/env ironment combin ation.In OCGS LRA Ta bles 3.2.2.1.1 thro ugh 3.2.2.1.3, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from gl ass w ere ex posed to an air-i ndoor uncon troll ed env ironme nt.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the enginee red safety features sy stems, and determin ed that no si gnificant aging effects were identi fied for ESF sys tem components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team found that glass exposed to an air-indo or uncontroll ed enviro nment wil l not result in aging that wil l be of concern during the peri od of extended operation.
Therefore, the project team determined that there are no applicable aging eff ects requiring ma nagement f or this material/env ironment combin ation.In OCGS LRA Ta bles 3.2.2.1.1 thro ugh 3.2.2.1.3, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s tainl ess ste el w ere ex posed to a c oncret e or l ubric ating o il en viro nment.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the enginee red safety features sy stems, and determin ed that no si gnificant aging effects were identi fied for ESF sys tem components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team found that st ainless steel exposed to a concrete or lubricating oil environment will not result in aging that w ill be o f concern during the period of ex tended operati on. Therefore, the projec t
357 team determined that there are no applicable aging eff ects requiring ma nagement f or this material/env ironment combin ation.In OCGS LRA Ta bles 3.2.2.1.1 thro ugh 3.2.2.1.3, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabricated from stainl ess steel, cas t austenitic stainless ste el, galvani zed steel , copper all oy, and nickel allo y w ere ex posed to an air-i ndoor uncon troll ed env ironme nt.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the enginee red safety features sy stems, and determin ed that no si gnificant aging effects were identi fied for ESF sys tem components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team f ound tha t stainle ss steel , cast au stenit ic stainle ss steel , galvani zed steel, copper al loy, and nickel alloy exposed to an air-indoor uncontrolled environment will not result in aging that will be of concern duri ng the period o f extended ope ration. Therefore, the project team determin ed that there are no applicab le aging effects requiring man agement for this material
/environment combination.
Conclusio n On th e bas is of its re view, t he pr ojec t tea m fo und t hat t he app lican t app ropr iate ly iden tif ied AMR resu lts in volving mate rial, envir onme nt, agin g ef fec ts re quir ing m anag emen t, an d AMP combinations that are not app licable to OCGS, and AM R results i nvolvi ng material and environment combinations that do not have aging effect s requiring manag ement at OCGS.
3.2.3 Conclusion On the basis o f its review , the project team d etermined that the applican t has demonstrated that the aging eff ects associated with the engineered saf ety features componen ts will be adequately managed. The project team also revi ewed the applicabl e UFSAR su pplement program summaries and co ncluded that they adequatel y describe the AMP s credited for managi ng aging of the e nginee red sa fety feat ures co mponen ts, as r equire d by 10 CFR 54.21 (d).3.3 OCGS LR A Sectio n 3.3 - A ging Ma nageme nt of A uxiliar y S yst ems This section o f the audit and review report documents the project team's review and eval uation of the OCGS aging management re view (AMR) resul ts for the aging management of the components and component groups as sociated w ith the follow ing auxil iary sy stems: (1)
?C" battery roo m heating & v entilation , (2) 4160 V s witchgear roo m ventilati on, (3) 480 V switchgear roo m ventilati on, (4) battery and MG set room ventil ation, (5) chl orination sy stem, (6)circulating w ater system, (7) c ontainment in erting system, (8) containment v acuum breakers, (9) control rod dri ve system, (10) control roo m HVAC, (11) d rywell floor and equip ment drains, (12) emergency dies el generator and auxili ary system, (13) emergency se rvice w ater system, (14) fire protection sy stem, (15) fuel storage a nd handli ng, (16) equipment, (17) hardened v ent system, (18) hea ting & process steam system, (19) hydrogen & o xygen moni toring system, (20) instrument (control) air system, (2
: 1) main fuel oi l storage & trans fer system, (22) misce llaneous 358 floor and equipmen t drain sy stem, (23) nitrogen su pply sy stem, (24) noble metals monitori ng system, (25) pos t-accident sampl ing system, (26) process sampli ng system, (27) rad iation monitoring sys tem, (28) radwa ste area heati ng and venti lation sy stem, (29) reactor bu ilding closed cool ing water sy stem, (30) reactor bu ilding floor a nd equipment drai ns, (31) reactor buil ding v entil ation syste m, (32) reacto r wat er cle anup s ystem, (33) ro of drai ns and over board disch arge, (3 4) san itary wast e sys tem, (35) serv ice w ater sy stem, (3 6) shu tdow n cool ing sy stem, (37) sp ent fuel pool cool ing sy stem, (3 8) stan dby l iquid contro l sy stem (l iquid pois on sy stem), (39) traveli ng in-core probe system, (40) turb ine buil ding closed cooling w ater system, and (41)wate r treatm ent & d istri butio n sys tem.3.3.1 Summary o f Technical Information in the A pplication In the OCGS LR A, Sec tion 3.3, the appl icant prov ided the res ults o f its AM Rs for th e aux ilia ry system componen ts and componen t groups.In OCGS LRA Ta ble 3.3.1, ?Summary of Agin g Man agement Eval uatio ns for th e Aux ilia ry Syste ms," the appli cant provi ded a s umm ary co mpar ison of it s AMR lin e-it ems wi th th e AMR line-items e valuated in the GALL R eport for the aux iliary system componen ts and componen t groups. The appli cant also i dentified, for each component type in the OCGS L RA Table 3.3.1
, those AMR s that are co nsiste nt wi th the GALL R eport, those for whi ch the GALL R eport recommends f urther evaluation, and those AMRs that are not addressed in the OCGS LRA, together with the basis for thei r exclusi on.In the OCGS LR A Tabl es 3.3.2.1.1 through 3.3.2.1.41, t he app lica nt prov ided the AM R resu lts for compo nent ty pes as socia ted w ith (1) ?C" battery roo m heating & v entilation , (2) 4160 V switchgear roo m ventilati on, (3) 480 V switchgear roo m ventilati on, (4) battery and MG set room venti latio n, (5) c hlori natio n sys tem, (6) circu latin g wate r syst em, (7) contai nment i nertin g syste m, (8) containment vacuum break ers, (9) control rod drive system, (10) control room HVAC, (11) dr ywe ll flo or and equip ment dr ains, (12) e mergency dies el gen erator and au xil iary syste m, (13) emergency se rvice w ater system, (14) fire protection sy stem, (15) fuel storage a nd handl ing, (1 6) equi pment, (17) ha rdened vent syste m, (18) heati ng & pro cess s team sy stem, (19) hydrogen &
oxygen mon itoring system, (20) instrument (co ntrol) air sy stem, (21) main fuel oil storage &
transfer system, (22) mi scellaneou s floor and equip ment drain sy stem, (23) nitrogen suppl y system, (2
: 4) noble metal s monitoring sy stem, (25) post-acci dent samplin g system, (26) proc ess sampling sy stem, (27) radiati on monitoring sy stem, (28) radwa ste area heating and v entilation system, (29) rea ctor buildi ng closed cool ing water sy stem, (30) reactor building floo r and equipment d rains, (31) reac tor buildi ng ventilati on system, (32) reactor water clean up sy stem, (3 3) roof d rains and o verbo ard di scharge , (34) s anita ry w aste sy stem, (35) se rvic e wa ter sy stem, (3 6) shu tdow n cool ing sy stem, (3 7) spe nt fuel pool cool ing sy stem, (38) st andby liqui d cont rol sy stem (l iquid pois on sy stem), (3 9) trav elin g in-co re prob e sys tem, (40) turbine bu ilding clo sed coolin g water sys tem, and (41) w ater treatment & di stribution system. Speci fically, the information for each component type included the intende d function, material, env ironment, aging effect requirin g management, AMPs , the GALL Rep ort Volume 2 item, cross ref erence to the OCGS LRA Table 3.3.
1 (Table 1), and generic and plant-specific notes relate d to co nsiste ncy w ith th e GALL Repor t.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of the aging effec ts requi ring man agement (AERM s). The se rev iew s incl uded t he ev aluat ion o f both plant-spe cif ic and indus try op erat ing e xperi ence. The plant-spe cif ic eval uati on inc luded revie ws of condition re ports and dis cussions w ith appropri ate site perso nnel to id entify AERM
: s. The 359 applicant' s review of industry o perating expe rience incl uded a rev iew of the GA LL Report and operat ing ex perie nce i ssues ident ified since the i ssuanc e of the GALL R eport.3.3.2 Project T eam Evaluatio n The project team rev iewed OC GS LRA Secti on 3.3 to determi ne if the appl icant provi ded sufficient information to demonstrate that th e effects of aging for the auxi liary sy stem components that a re withi n the scope o f license renew al and sub ject to an AM R wil l be adequately man aged so that the intended functio n(s) wil l be maintai ned consiste nt with th e CLB for the p eriod of ext ended opera tion, as requi red by 10 CF R 54.2 1(a)(3).The project team rev iewed c ertain iden tified AMR line-items to confirm the appl icant's cl aim that these AMR line-items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line-items. The project team's audit evaluation is documente d in Section 3.3.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line-items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in the SRP-LR. The proj ect team's audit eval uatio n is d ocumen ted in Secti on 3.3.2.2 of t his a udit a nd rev iew report.The project team did not revie w the remai ning AMR line-items that were no t consistent w ith or not addressed in the GALL R eport. These w ere review ed by the NRC DE sta ff and documented in the SER fo r the Oy ster Cr eek pla nt.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the a uxilia ry systems.
Table 3.3-1 bel ow prov ides a summary of the project team's evaluati on of the componen ts, aging effects/aging mechanisms, and AMPs l isted in L RA Section 3.3 that are ad dressed in th e GALL Report. It a lso inclu des the secti on of the audit and revie w report i n which the project team's eval uation is documented. It sh ould be no ted that the li ne items in this table c orrespond to the line items in Tabl e 3.3-1 of the Sep tember 2005 Rev ision 1 S RP-LR documen t; therefore, in many ca ses, they do not match the l ine items i n Table 3.3.1 o f the OCGS LRA. The SRP-LR line item n umber i s deno ted pa renthe tical ly i n the c olumn 1 entry. Als o, li ne ite ms that are applicabl e only to PWR plants are not incl uded in thi s table; therefore, c ertain SRP-L R line i tem numbers do not appear in th is table.Table 3.3-1 Staff Evalua tion for A uxiliary S ystem Co mponents in the GALL Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on Steel cranes -structural girders exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-1)
Cum ulat ive fat igue damage TLAA to be eval uated f or struct ural gir ders of cranes. See the TLAA TLAAs were revi ewed by NRR/DE staf
: f.  (See Audit Report Sect ion 3.3.2.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 360 Standard Review Pl an, Secti on 4.7 f or ge ne ric guidance for meeting t he requi rements of 10 CF R 54.21(c)(1)Steel and stai nless steel pipi ng, pi ping components, pi ping elements, and heat exchanger components exposed to ai r - i ndoor uncontr oll ed, t reat ed borat ed water or trea ted wat er (It em 3.3.1-2)
Cum ulat ive fat igue damage TLAA, ev alu ate d in accordance with 10 CF R 54.21(c)TLAA TLAAs were revi ewed by NRR/DE staf
: f. (See Audit Report Sect ion 3.3.2.2.1)Stai nless st eel he at exchanger t ubes exposed to trea ted water (It em 3.3.1-3)
Reducti on of heat trans fer d ue to foul ing W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2)Acceptabl e, si nce on e-tim e in sp ec tion is credi ted f or ot her agi ng effect s in t he same sys tem s. (Se e A ud it Report Sect ion 3.3.2.2.2)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to sodium pentabor ate sol uti on> 60&deg;C (> 1 40&deg;F)(It em 3.3.1-4)
Cra ck ing du e to stress corrosi on cracking W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.3.1)Stai nless st eel an d stai nless cl ad steel heat exchang er components exposed to treated w ater > 60&deg;C (> 1 40&deg;F)(It em 3.3.1-5)
Cra ck ing du e to stress corrosi on cracking A p lan t-s pe cif ic AMP is to be eval uated.On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.3.2)Stai nless st eel di esel engine exhaust pi ping, pipi ng components, and piping elem ents exposed to diesel exhaust (It em 3.3.1-6)
Cra ck ing du e to stress corrosi on cracking A p lan t-s pe cif ic AMP is to be eval uated.N ot A pp lica ble Not appl icabl e since the di esel en gine ex ha us t pip ing is carbon st eel. (See Audit Report Sect ion 3.3.2.2.3.3)High-st rengt h steel closur e bolt ing exp ose d to a ir with Cra ck ing du e to stress corrosi on cr ac kin g, c yclic Bo lting Integ rity AMP to be augmented by Bo lting Integ rity (B.1.12)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 361 steam or water leakage.(It em 3.3.1-10) loadi ng app ropr iate insp ection to detect cracki ng if t he bolts are not ot herwi se repl aced duri ng maintenance.
Audit Report Sect ion 3.3.2.2.4.4)Elast omer seals and components exposed to ai r - i ndoor uncontr oll ed (in ter na l/ex ter na l)(It em 3.3.1-11)
Hardenin g and loss of stre ngth due to el astomer degradat ion A p lan t-s pe cif ic AMP is to be eval uated Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Rev i ewe d by NRR/DE Sta ff. (Se e A ud it Report Sect ion 3.3.2.2.5.1)Elast omer li ning exposed to trea ted water or t reat ed borat ed water (It em 3.3.1-12)
Hardenin g and loss of stre ngth due to el astomer degradat ion A p lan t-s pe cif ic AMP is to be eval uated.Pe rio dic Inspect ion (B.2.5)Rev i ewe d by NRR/DE Sta ff. (Se e A ud it Report Sect ion 3.3.2.2.5.2)Boral , bor on steel spent f uel st orage rac ks neutr on-absorbi ng she ets e xpo sed to trea ted wat er or trea ted bor ated wat er (It em 3.3.1-13)
Reducti on of neutr on-absorbi ng capacit y and loss of m ateria l due to general corrosi on A p lan t-s pe cif ic AMP is to be eval uated None Acceptabl e since operat ing exp eri ence shows that aging ef fe cts for this com ponent are insi gnif icant. (See Audit Report Sect ion 3.3.2.2.6)Steel pipi ng, pi ping component, and pi ping elem ents exp ose d to lub ric atin g o il (It em 3.3.1-14)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Activit ies (B.2.2) an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends fu rt he r ev al ua t i on AMP B.2.2 was revi ewed by NRR/DE staff. (See Audit Report Sect ion 3.3.2.2.7.1)Steel react or cool ant pump oil col lect ion syst em piping, tubi ng, and val ve bodi es exposed to lubr icat ing oil (I tem 3.3.1-15)Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion N ot A pp lica ble Not appl icabl e since Oyster Creek does not have a re actor coolan t pump oil col lect ion sys tem. (S ee Au dit Report Sect ion 3.3.2.2.7.1)Steel react or cool ant pump oil col lect ion syst em tank exposed to lu br ica ting oil (It em 3.3.1-16)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Insp ection to eval uate t he thi ckness of th e lower port ion of the t ank N ot A pp lica ble Not appl icabl e since Oyster Creek does not have a re actor coolan t pump oil col lect ion sys tem. (S ee Au dit Report Sect ion 3.3.2.2.7.1)Steel pipi ng, pi ping components, and Loss of materi al du e to ge ne ra l, W ater Chem ist ry and W ater Chem istry (B.1.2) and Consist ent wi th GALL, which r ecomm ends Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 362 piping elem ents exposed to trea ted water (It em 3.3.1-17) pit ti ng, and cr evi ce corrosi on On e-Ti me Inspect ion On e-Ti me Inspect ion (B.1.24)furt her eval uati on (See Audit Report Sect ion 3.3.2.2.7.2)Stai nless st eel an d steel diesel engin e exhaust pi ping, pipi ng components, and piping elem ents exposed to diesel exhaust (It em 3.3.1-18)
Loss of material/gener al (stee l onl y), pi tt ing and crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated Pe rio dic Inspect ion (B.2.5)Rev i ewe d by NRR/DE Sta ff. (Se e A ud it Report Sect ion 3.3.2.2.7.3)Steel (wi th or wit hout coati ng or wrap ping)pipi ng, pi ping components, and piping elem ents ex po se d to so il (It em 3.3.1-19)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC Buri ed Pipi ng and Ta nks Survei ll ance or Buri ed Pipi ng and Ta nks Inspect ion Buri ed Pipi ng Inspect ion (B.1.26)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.8)Steel pipi ng, pi ping components, pi ping el ements , a nd t anks ex po se d to fue l oil (It em 3.3.1-20)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC, and foul ing Fu el O il Chem ist ry  and On e-Ti me Inspect ion Fu el O il Chem istry (B.1.22) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.9.1)Steel heat excha nger components exposed to lu br ica ting oil (It em 3.3.1-21)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC, and foul ing Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.AMP B.2.2 was re vi ewe d by NRR/DE sta ff. (Se e A ud it Report Sect ion 3.3.2.2.9.2)Steel wit h elast omer li ning o r st ainl ess steel claddi ng pip ing, pipi ng components, and piping elem ents exposed to trea ted water and tr eated borat ed water (It em 3.3.1-22)
Loss of materi al due to pi tt ing an d crevi ce corrosi on (onl y f or st eel af ter li ning/claddi ng degradat ion)W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.10.1)Stai nless st eel an d steel wit h stai nless steel claddi ng heat exchanger components exposed to t reat ed water (It em 3.3.1-23)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.10.2)Stai nless st eel an d aluminum pipi ng, pipi ng components, Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem ist ry and On e-Ti me W ater Chem istry (B.1.2) and On e-Ti me Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 363 and piping elem ents exposed to trea ted water (It em 3.3.1-24)
Inspect ion Inspect ion (B.1.24)Audit Report Sect ion 3.3.2.2.10.2)Copper al lo y HVAC pipi ng, pi ping components, pi ping elem ents exp ose d to condensati on (e xte rn al)(It em 3.3.1-25)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Rev i ewe d by NRR/DE Sta ff. (Se e A ud it Report Sect ion 3.3.2.2.10.3)Copper al loy pipi ng, pipi ng components, and piping elem ents exposed to lubr icat ing oil (I tem 3.3.1-26)Loss of materi al due to pi tt ing an d crevi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.AMP B.2.2 was re vi ewe d by NRR/DE sta ff.  (Se e A ud it Report Sect ion 3.3.2.2.10.4)Stai nl ess st eel HVAC ducti ng and al uminum HVAC piping, pipi ng components and pi ping elem ents exp ose d to condensati on (It em 3.3.1-27)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.O ne-tim e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.10.5)Copp er alloy fire prot ecti on pip ing, pipi ng components, and piping elem ents exp ose d to co nd en sa tion (int er na l)(It em 3.3.1-28)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LR A. (Se e A ud it Report Sect ion 3.3.2.2.10.6)Stai nless st eel pi ping, pipi ng components, and piping elem ents ex po se d to so il (It em 3.3.1-29)
Loss of materi al due to pi tt ing an d crevi ce corrosi on A p lan t-s pe cif ic AMP is to be eval uated.N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LR A. (Se e A ud it Report Sect ion 3.3.2.2.10.7)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to sodium pentabor ate sol uti on Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.10.8)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 364 (It em 3.3.1-30)
Copper al loy pipi ng, pipi ng components, and piping elem ents exposed to trea ted water (It em 3.3.1-31)
Loss of materi al due to pi tt ing, crevi ce, and galv anic cor rosi on W ater Chem ist ry and On e-Ti me Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on. (See Audit Report Sect ion 3.3.2.2.11)Sta inle ss ste el, aluminum and copper all oy pi ping, pipi ng components, and piping elem ents ex po se d to fue l oil (It em 3.3.1-32)
Loss of materi al due to pi tt ing, cre vice, a nd M IC Fu el O il Chem ist ry and On e-Ti me Inspect ion Fu el O il Chem istry (B.1.22) and On e-Ti me Inspect ion (B.1.24)(al uminum and copper al loy)  or Fu el O il Chem istry (B.1.22) (st ainl ess ste el)Consist ent wi th GALL (al uminum and copper all oy), whi ch recomm ends furt her ev alu atio n. A cc ep tab le (stai nless st eel) since on e-tim e in sp ec tion is perfor med for other material s in t he same environm ent that are leadi ng ind icat ors of co rro sio n.  (Se e A ud it Report Sect ion 3.3.2.2.12.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to lubr icat ing oil (I tem 3.3.1-33)Loss of materi al due to pi tt ing, cre vice, a nd M IC Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.AMP B.2.2 was re vi ewe d by NRR/DE sta ff. (Se e A ud it Report Sect ion 3.3.2.2.12.2)Elast omer seals and components exposed to ai r - i ndoor uncontr oll ed (i nter nal or ex ter na l)(It em 3.3.1-34)
Loss of materi al due to Wear A p lan t-s pe cif ic AMP is to be eval uated.Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Rev i ewe d by NRR/DE Sta ff. (Se e A ud it Report Sect ion 3.3.2.2.13)Borafl ex spent f uel st ora ge r acks neutr on-absorbi ng she ets e xpo sed to trea ted wat er (It em 3.3.1-36)
Reducti on of neutr on-absorbi ng cap acity du e to borafl ex degradat ion Borafl ex Monitor ing Borafl ex Rack Managem ent (B.1.15)Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to trea ted wat er > 60&deg;C (> 1 40&deg;F)(It em 3.3.1-37)
Cra ck ing du e to stress corrosi on cracking , int ergranul ar stress corrosi on cracking BW R Reactor W ater Cleanup Syst em BW R Reactor W ater Cleanup Syst em (B.1.18)
Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to trea ted Cra ck ing du e to stress corrosi on cracking BW R Stress Corrosi on Cracking and W ater N ot A pp lica ble Not appl icabl e since Oyster Creek has no stai nless st eel non-RCPB shu tdo wn Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 365 wat er > 60&deg;C (> 1 40&deg;F)(It em 3.3.1-38)
Chem istry cooli ng syst em piping exposed to trea ted water >140F. (See Audit Report Sect ion 3.3.2.3.1)Stai nl ess st eel BW R spent f uel st orage rac ks exp ose d to treated w ater > 60&deg;C (> 1 40&deg;F)(It em 3.3.1-39)
Cra ck ing du e to stress corrosi on cracking W ater Chem istry N ot A pp lica ble Not appl icabl e since stai nless st eel spe nt fuel storage racks are exposed to trea ted water <140F. (See Audit Report Sect ion 3.3.2.3.1)Steel tanks i n diese l fuel oil syst em expos ed to air -
ou tdo or (ex ter na l)(It em 3.3.1-40)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Aboveground Ste el Tanks Aboveground Outd oor Tanks (B.1.21)Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)High-st rengt h steel closur e bolt ing exp ose d to a ir with steam or water leakage (It em 3.3.1-41)
Cra ck ing du e to cycl ic l oading, stress corrosi on cracking Bo lting Integ rity N ot A pp lica ble Not appl icabl e since auxil iar y sy stem high strength steel closure bo lting is o nly app l i cab l e t o t he CRD sys tem , an d th is is addressed i n it em 3.3.1-7. (Se e A ud it Report Sect ion 3.3.2.3.1)Steel closur e bolt ing exp ose d to a ir with steam or water leakage (It em 3.3.1-42)
Loss of materi al due to ge neral corrosi on Bo lting Integ rity N ot A pp lica ble Not appl icabl e since no auxil iar y sy stem steel clo su re bo lting is exp ose d to a ir with steam or water leakage, except t he C R D sys tem , wh ich is addressed i n it em 3.3.1-7. (Se e A ud it Report Sect ion 3.3.2.3.1)Steel bolt ing an d closur e bolt ing exposed to air - in door un co ntr olle d (e xte rn al)or ai r - out door (E xte rn al)(It em 3.3.1-43)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Bo lting Integ rity Bo lting Inte gr ity, or ASME Sectio n XI, Subsect ion IW E, or Inspect ion of Overh ead H eavy Load and Li ght Load Handli ng System , or Struct ures Monitor ing Acceptabl e since the AS ME Sec tion X I, Subsect io n IWE, inspect ion of overhead heavy load and li ght load h andli ng syst em, and str uctur es monitori ng progr ams are consi stent wit h the Bo lting Integ rity Pr og ra m for this component group/
aging effect Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 366 combinati on. (See Audit Report Sect ion 3.3.2.1.6.1)Ste el c om pr es se d a ir syst em closure bol ti ng exp ose d to condensati on (It em 3.3.1-44)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Bo lting Integ rity N ot A pp lica ble Not appl icabl e since inst rument air syst em ste el c los ur e b oltin g is not e xpo sed to condensati on. (See Audit Report Sect ion 3.3.2.3.1)Steel closur e bolt ing exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-45)
Loss of pr eload due to t hermal effect s, gasket creep, and self-l oosening Bo lting Integ rity Bo lting Integ rity (B.1.12), or AS ME Sec tion X I, Su bse ction IW E (B.1.27)Consist ent wi th GALL for AMRs credi ti ng bolting integrity.
Acce pt abl e f or AMRs cr ed i t i ng AS ME Secti on XI, Subsecti on IW E, s inc e it is consist ent wi th t he Bo lting Integ rity Pr og ra m for this component group/
aging effect combinati on.  (See Audit Report Sect ion 3.3.2.1.7)Stai nless st eel an d stai nless cl ad steel pipi ng, pi ping components, pi ping elements, and heat exchanger components exposed to cl osed cycl e cooli ng wat er > 60&deg;C (> 1 40&deg;F)(It em 3.3.1-46)
Cra ck ing du e to stress corrosi on cracking C los ed-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel pipi ng, pi ping components, pi ping elements, tanks, and heat exchang er components exposed to cl osed cycl e cooli ng water (It em 3.3.1-47)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14) an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL.Ad ditio n o f on e-tim e inspect ion pr ovi des addit ional assurance that aging effects are adequatel y managed.(See Au dit Report Secti on 3.3.2.1.6.2)Steel pipi ng, pi ping components, pi ping elements, tanks, and heat exchang er components exposed to cl osed cycl e cooli ng water (It em 3.3.1-48)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, an d g alv an ic corrosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 367 Stai nless st eel; steel wit h stai nless st eel claddi ng heat exchanger components exposed to cl osed cycl e cooli ng water (It em 3.3.1-49)
Loss of materi al due to M IC C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to closed cycl e cooli ng water (It em 3.3.1-50)
Loss of materi al due to pi tt ing an d crevi ce corrosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Copper al loy pipi ng, pipi ng components, pipi ng ele ments, and heat exchang er components exposed to cl osed cycl e cooli ng water (It em 3.3.1-51)
Loss of materi al due to pi tt ing, crevi ce, and galv anic cor rosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL (See Au dit Report Secti on 3.3.2.1)Ste el, s tain les s s tee l, and copper al loy heat exchanger t ubes exposed to closed cycl e cooli ng water (It em 3.3.1-52)
Reducti on of heat trans fer d ue to foul ing C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Co nsis tent w ith GA LL..(See Au dit Report Secti on 3.3.2.1)Ste el c om pr es se d a ir syst em piping, pipi ng components, and piping elem ents exp ose d to co nd en sa tion (int er na l)(It em 3.3.1-53)
Loss of materi al due to ge neral and pit ti ng corrosi on Com pressed Air Monitor ing N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Stai nless st eel compressed air sy stem pipi ng, pi ping components, and piping elem ents exposed to int ernal condensati on (It em 3.3.1-54)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Com pressed Air Monitor ing N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel ducting closure bolting exposed to air -
indoor uncontr oll ed (e xte rn al)(It em 3.3.1-55)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 368 Steel HVAC ducting and com pon ents exter nal sur faces exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-56)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing Struct ures Monitor ing (B.1.310) or Pe rio dic Inspect ion (B.2.5)or Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Acceptabl e since the OCG S struct ures m on itor ing pro gr am is consist ent wi th t he GALL external surfaces monit ori ng pr og ra m for this component group/
aging effect combinati on. The O C G S p er iod ic ins pe ctio n a nd pe rio dic inspect ion of venti lat ion system s program s are ap pr op ria te f or this component group/
aging effect combinati on. These AMPs were revi ewed by NRR/DE staf
: f.  (See Audit Report Sect ion 3.3.2.1.6.3)Steel pipi ng and components extern al su rfa ce s e xp os ed to a ir- indo or uncont rol led (E xte rn al)(It em 3.3.1-57)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing Fire Protect ion (B.1.19) or Fire W ater Syst em (B.1.20) or Struct ures Monitor ing (B.1.31) or Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Acceptabl e since the OCG S fi re prot ecti on, fi re wat er sy stem, and struct ures monito ri ng program s are consist ent wi th t he GALL external surfaces monit ori ng pr og ra m for this component group/
aging effect combinati on. The O C G S p er iod ic inspect ion of venti lat ion sys tem s p ro gr am is ap pr op ria te f or this component group/
aging effect co mbi na t i on. Thi s A MP was revi ewed by NRR/DE staff.
(See Audit Report Sect ion 3.3.2.1.10)Steel exter nal sur faces exposed to air - in door uncon troll ed (external), air - outdoo r (exte rnal), and condensati on (e xte rn al)(It em 3.3.1-58)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing Fire Protect ion (B.1.19), or Fire W ater Syst em (B.1.20), or Struct ures Monitor ing (B.1.31), or Pe rio dic Acceptabl e since the OCG S fi re prot ecti on, fi re wat er sy stem, and struct ures monito ri ng program s are consist ent wi th t he GALL external surfaces monit ori ng Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 369 Inspect ion of Venti lat ion Syst ems (B.2.4) pr og ra m for this component group/
aging effect combinati on. The O C G S p er iod ic inspect ion of venti lat ion sys tem s p ro gr am is ap pr op ria te f or this component group/
aging effect co m bin atio n. T his AMP was reviewed b y NRR/DE staff.
(See Audit Report Sect ion 3.3.2.1.10)Steel heat excha nger components exposed to ai r - i ndoor un co ntr olle d (e xte rn al)or ai r -out door (e xte rn al)(It em 3.3.1-59)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on External Surfaces Monitor ing N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel pipi ng, pi ping components, and piping elem ents expos ed to air -
ou tdo or (ex ter na l)(It em 3.3.1-60)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on External Surfaces Monitor ing 10 CFR Part 50, Appendix J (B.1.29) pl us On e-Ti me Inspect ion (B.1.24) or On e-Ti me Inspect ion (B.1.24) or Fire Protect ion (B.1.19) or Fire W ater Syst em (B.1.20) or Struct ures Monitor ing (B.1.31) or Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Acceptabl e since the OC GS 10 CF R Pa rt 50, Appendi x J plu s one-t ime inspect ion, or the on e-tim e inspection, or the fir e protection, or the fi re water syst em, or the struct ures monito ri ng program s are consist ent wi th t he GALL external surfaces monit ori ng pr og ra m for this component group/
aging effect combinati on. The O C G S p er iod ic inspect ion of venti lat ion sys tem s p ro gr am is ap pr op ria te f or this component group/
aging effect co mbi na t i on. Thi s A MP was re vi ewe d by NRC D E s taf f.  (S ee Au dit Report Sect ion 3.3.2.1.6.3)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 370 Elast omer fir e barri er pe ne tra tion se als expos ed to air -
outdoor or ai r - i ndoor uncontr oll ed (It em 3.3.1-61)
Incre ased hardness, shri nkage and l oss of str eng th du e to weather ing Fire Protect ion Fire Protect ion (B.1.19) or Struct ures Monitor ing (B.1.31)Consist ent wi th GALL for AMRs credi ti ng the fire pro tection prog ram. Acce pt abl e f or AMRs credi ti ng the st ructu res monitori ng progr am si nc e t he OCGS struct ures monito ri ng program is consi stent with the GALL fire prot ecti on progr am for thi s component group/
aging effect combinati on.  (See Audit Report Sect ion 3.3.2.1)Aluminum pipi ng, pipi ng components, and piping elem ents exposed to raw water (It em 3.3.1-62)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Fire Protect ion Fire W ater Syst em (B.1.20)
Rev i ewe d by NRR/DE Staff.Steel fire rat ed doors expos ed to air -
outdoor or ai r - i ndoor uncontr oll ed (It em 3.3.1-63)
Loss of materi al due to Wear Fire Protect ion Fire Protect ion (B.1.19)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Steel pipi ng, pi ping components, and piping elem ents ex po se d to fue l oil (It em 3.3.1-64)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Fire Protect ion an d F ue l O il Chem istry Fire Protect ion (B.1.19) and Fuel Oil Chem istry (B.1.20)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Re inforc ed c onc rete struct ural fi re barr ier s -wall s, cei li ngs and floors expose d to air -
indoor uncontr oll ed (It em 3.3.1-65)
Concrete cr acking and spa lling due to aggress ive chemi cal at ta ck, and reac tion with aggregat es Fire Protect ion and Str uctur es Monitor ing Fire Protect ion (B.1.19) and Struct ures Monitor ing (B.1.31)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Re inforc ed c onc rete struct ural fi re barr ier s -wall s, cei li ngs and floors expose d to air -
outdoor (I tem 3.3.1-66)Concrete cr acking and spa lling due to fre eze tha w, aggress ive chemi cal at ta ck, and reac tion with aggregat es Fire Protect ion and Str uctur es Monitor ing Fire Protect ion (B.1.19) and Struct ures Monitor ing (B.1.31)Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Re inforc ed c onc rete struct ural fi re barr ier s -wall s, cei li ngs and floors expose d to air -
Loss of materi al due to cor rosi on of embedded steel Fire Protect ion and Str uctur es Monitor ing Fire Protect ion (B.1.19) and Struct ures Monitor ing (B.1.31)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 371 outdoor or ai r - i ndoor uncontr oll ed (It em 3.3.1-67)
Steel pipi ng, pi ping components, and piping elem ents exposed to raw water (It em 3.3.1-68)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC, and foul ing Fire W ater Syst em Fire W ater Syst em (B.1.20)
Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to raw water (It em 3.3.1-69)
Loss of materi al due to pi tt ing an d crevi ce corrosi on, and foul ing Fire W ater Syst em Fire W ater Syst em (B.1.20)
Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)Copper al loy pipi ng, pipi ng components, and piping elem ents exposed to raw water (It em 3.3.1-70)
Loss of materi al due to pi tt ing, cr ev i ce, and MIC, and foul ing Fire W ater Syst em Fire W ater Syst em (B.1.20)
Consist ent wi th GALL (See Au dit Report Secti on 3.3.2.1)Steel pipi ng, pi ping components, and piping elem ents exposed to moist ai r or co nd en sa tion (In ter na l)(It em 3.3.1-71)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Inspect ion of Int ernal Su rfa ce s in Miscel laneous Pipi ng and Ducti ng Co m pon ents N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LR A..Steel HVAC ducting and com pon ents int ernal surfaces exp ose d to co nd en sa tion (In ter na l)(It em 3.3.1-72)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and (for dri p pans and drai n li nes)MIC Inspect ion of Int ernal Su rfa ce s in Miscel laneous Pipi ng and Ducti ng Co m pon ents Pe rio dic Inspect ion of Venti lat ion Syst ems (B.2.4)
Rev i ewe d by NRC DE st af f. The OCGS peri odic i nspecti on of venti lat ion sy stems prog ram is app ropr iate for t his component group/ aging effect co mbi na t i on. Thi s A MP was revi ewed by NRR/DE staff. (See Audit Report Sect ion 3.3.2.1.6.3)Steel crane st ructu ral gir ders i n load handl ing sys tem ex po se d to air- indo or uncont rol led (e xte rn al)(It em 3.3.1-73)
Loss of materi al due to ge neral corrosi on Inspect ion of Overhead Heavy Load and Li ght Load (Re lated to Refueli ng)Handli ng Syst ems Inspect ion of Overh ead H eavy Load and Li ght Loa d (R elated to Refueli ng)Handli ng Syst ems (B.1.16)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Ste el c ra ne s - rails exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-74)
Loss of materi al due to Wear Inspect ion of Overhead Heavy Load and Li ght Load Inspect ion of Overh ead H eavy Load and Li ght Loa d (R elated to Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 372 (Re lated to Refueli ng)Handli ng Syst ems Refueli ng)Handli ng Syst ems (B.1.16)Elast omer seals and components exposed to r aw water (It em 3.3.1-75)
Hardenin g and loss of stre ngth due to el astomer degradat ion; loss of m ateria l due to erosi on O pe n-C ycle Cooli ng W ater Syst em Pe rio dic Inspect ion (B.2.5)Rev i ewe d by NRR/DE staff.Steel pipi ng, pi ping components, and piping elem ents (wi thout li ning/ coati ng or wi th degr aded li ning/coati ng) exposed to r aw water (It em 3.3.1-76)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC, fo uli ng, and li ning/coati ng degradat ion O pe n-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel heat excha nger components exposed to r aw water (It em 3.3.1-77)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, gal va ni c, and MIC, and foul ing O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13)
Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Stai nless st eel, nickel all oy, and copper al loy pipi ng, pi ping components, and piping elem ents exposed to raw water (It em 3.3.1-78)
Loss of materi al due to pi tt ing an d crevi ce corrosi on O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13) or O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL for AMRs credi ti ng the O C G S o pe n-cyc le coo ling wa ter sys tem. Acce pt abl e f or AMRs cr ed i t i ng t he OCGS one-t ime inspect ion pr og ra m sin ce it is consist ent wi th t he G AL L o pe n-cyc le cooli ng water syst em pr og ra m for this component group/
aging effect combinati on.  (See Audit Report Sect ion 3.3.2.1.9)Stai nless st eel pi ping, pipi ng components, and piping elem ents exposed to raw water (It em 3.3.1-79)
Loss of materi al due to pi tt ing an d crevi ce corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13)
Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Stai nless st eel an d copper al loy pipi ng, pipi ng components, and piping elem ents Loss of materi al due to pi tt ing, cre vice, a nd M IC O pe n-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not appl icabl e since no GALL AM R li ne it ems re late d to this component group/
aging effect Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 373 exposed to raw water (It em 3.3.1-80) com bination were cr ed i t ed i n t he OCGS LRA.Copper al loy pipi ng, pipi ng components, and pi ping e lements, exposed to raw water (It em 3.3.1-81)
Loss of materi al due to pi tt ing, cr ev i ce, and MIC, and foul ing O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13) or Pe rio dic Inspect ion (B.2.5)Consist ent wi th GALL for AMRs credi ti ng the O C G S o pe n-cyc le coo ling wa ter sys tem. Rev i ewe d by NRR/DE Sta ff P er iod ic ins pe ctio n p ro gr am is ap pr op ria te f or this component group/
aging effect combinati on.  (See Audit Report Sect ion 3.3.2.1.9)Copper al loy heat exchanger components exposed to r aw water (It em 3.3.1-82)
Loss of materi al due to pi tt ing, crevi ce, gal vani c, and MIC, and foul ing O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13) or Fi re W ater Syst em (B.1.20)
Consist ent wi th GALL for AMRs credi ti ng the O C G S o pe n-cyc le coo ling wa ter sys tem. Acce pt abl e f or AMRs crediting the OCG S fire water syst em program since i t i s consist ent wit h the GALL open-cy cle cool ing water syst em program for t his component group/ aging effect combinati on.  (See Audit Report Sect ion 3.3.2.1.9)Stai nless st eel an d copper al loy heat exchanger t ubes exposed to raw water (It em 3.3.1-83)
Reducti on of heat trans fer d ue to foul ing O pe n-C ycle Cooli ng W ater Syst em O pe n-C ycle Cooli ng W ater Syst em (B.1.13)
Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Coppe r al lo y > 15% Zn pipi ng, pi ping components, pi ping elements, and heat exchanger components exposed to r aw water, tr eated wa ter , or clo se d c ycle cooli ng water (It em 3.3.1-84)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Selective Leaching of Materi als (B.1.25)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Gray cast ir on pip ing, pipi ng components, and piping elem ents exposed to soil , r aw Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Selective Leaching of Materi als (B.1.25)Consist ent wi th GALL.(See Au dit Report Secti on 3.3.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 374 water, tr eated wat er, or closed-cycl e cooli ng water (It em 3.3.1-85)
Struct ural steel (new fuel stor age rack ass em bly) exp ose d to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-86)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Struct ures Monitor ing Program Struct ures Monitor ing Program (B.1.
31)Co nsis tent w ith GA LL. (See Au dit Report Secti on 3.3.2.1)Galvani zed st eel pipi ng, pi ping components, and piping elem ents exposed to air - in door uncontr oll ed (It em 3.3.1-92)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2)Gla ss p iping e lem ents expos ed to air, ai r -indoor uncontr oll ed (e xte rn al), fu el o il, lubr icat ing oi l, raw water, treated water, and tr eated bor ated water (It em 3.3.1-93)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2)Stai nless st eel an d nickel all oy pi ping, pipi ng components, and piping elem ents exposed to air - in door un co ntr olle d (e xte rn al)(It em 3.3.1-94)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2)Steel and al uminum pipi ng, pi ping components, and piping elem ents exposed to air - in door co ntr olle d (e xte rn al)(It em 3.3.1-95)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2)Steel and stai nless steel pipi ng, pi ping components, and pip ing ele m en ts in con cre te (It em 3.3.1-96)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 375 Ste el, s tain les s s tee l, aluminum, and copper all oy pi ping, pipi ng components, and piping elem ents exposed to gas (It em 3.3.1-97)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this component group.(See Au dit Report Secti on 3.3.2.3.2)Ste el, s tain les s s tee l, and copper al loy pipi ng, pi ping components, and piping elem ents ex po se d to drie d a ir (It em 3.3.1-98)
None None None Acceptabl e - No aging managem ent pr ogram is need ed since no ag ing eff ec t is ide ntif ied for this com pon ent g roup. (See Au dit Report Secti on 3.3.2.3.2) 3.3.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant stated are consistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA is a cceptable.
In OCGS LRA Se ction 3.3.1.2.1, the applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging effects related to the
?C" battery roo m heating & v entilation , 4160 V sw itchgear room ventilati on, 480 V sw itchgear room ve ntilation, battery and MG set room v entilation , chlorinati on system, circul ating water s ystem, contain ment inerting sy stem, containment v acuum breakers, control rod dri ve system, control room HV AC, dryw ell floor and equipment drain s, emergency diese l gene rator a nd aux ilia ry sy stem, em ergency serv ice w ater sy stem, fir e prote ction syste m, fuel sto rage an d hand ling e quipmen t, hard ened v ent sy stem, he ating & proce ss stea m syst em, hydrogen & o xygen moni toring system, i nstrument (control) air system, mai n fuel oil storage &transfer system , miscellaneous floor and equipm ent drain system, nitrogen supply system, noble metals monitori ng system, post-acci dent samplin g system, process sampling sys tem, radiation monitoring sys tem, radwaste a rea heating and ventila tion system, re actor buildi ng closed cool ing wate r syst em, rea ctor bu ildi ng floor and equ ipment drain s, reac tor bui ldin g vent ilati on sy stem, reacto r wat er cle anup s ystem, roof dra ins a nd ov erboar d dis charge, sanit ary w aste sy stem, service water system, shutdown cooling system, spent f uel pool cooling system, standby liquid control sys tem (liquid po ison syste m), traveling i n-core probe sy stem, turbine bui lding close d cooling w ater system, and water treatment
& distributi on system compo nents and compo nent groups:
* ASME S ection XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD (B.1.1)
* Water Chemistry (B.1.2)
* BWR SCC (B.1.7)
* Bolting Integrity (B.1.12)
* OCCWS (B.1.13) 376
* CCCWS (B.1.14)
* Boraflex Rac k Management Program (B
.1.15)
* Compressed Ai r Monitori ng (B.1.17)
* BWR RW CU System (B
.1.18)
* Fire Protecti on (B.1.19)
* Fire Water System (B.1.20)
* Aboveground Outdoor Tanks (B.1.21)
* Fuel Oil C hemistry (B.1.2
: 2)
* One-Time Inspection (B.1.24)
* Selectiv e Leaching of M aterials (B.1.2
: 5)
* Buried Pi ping Inspection (B.1.26)
* ASME S ection XI, Subse ction IWE (B.1.27)
* 10 CFR Part 50, Appendi x J (B.1.29)
* Inspection of Ov erhead Heav y Load an d Light Load (R elated to Re fueling) Handli ng Systems (B.1.16
)
* Structures Mo nitoring Program (B.1.3
: 1)
* Lubricating Oil Monitori ng Activiti es (B.2.2)
* Periodic In spection of Ven tilation S ystems (B.2.4)
* Periodic In spection Program (B
.2.5)Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line-items to determine tha t the applicant (1) provided a brief descri ption of the sy stem, components, materi als, and environment; (2) stated that the applicab le aging effects have been revi ewed and are eval uated in the GALL R eport; and (3) i dentified those aging effects for the
?C" b atte ry r oom h eati ng &ventilati on, 4160 V s witchgear roo m ventilati on, 480 V sw itchgear room ve ntilation, battery and MG set room v entilation , chlorinati on system, ci rculating w ater system, con tainment inerti ng system, containment vacuum br eakers, contro l rod drive system, control room HVAC, drywell floor and equipmen t drains, emergency diesel gene rator and aux iliary system, emergency service w ater system, fire pro tection sys tem, fuel storage and h andling equip ment, hardened vent syste m, heati ng & pro cess s team sy stem, hy drogen & oxy gen moni toring syste m, instrument (control) air system, ma in fuel oil storage & transfer sy stem, miscellan eous floor and equipment drain system, nitrogen supply sy stem, noble metal s monitoring sy stem, post-acciden t sampling sys tem, process sampl ing system, radi ation monitori ng system, radw aste area heati ng and venti lation sy stem, reactor buil ding closed cooling w ater system, reac tor buildi ng floor and equipment drains , reactor buil ding ventil ation syste m, reactor water cleanup sy stem, roof drains and overbo ard discharge, sa nitary w aste system, serv ice water system, shutdow n cooling syste m, spen t fuel p ool c ooli ng sys tem, sta ndby liqui d cont rol sy stem (l iquid pois on sy stem), traveling i n-core probe sy stem, turbine bui lding close d cooling w ater system, and water treatment & distribut ion system components that are subject to an AMR.
3.3.2.1.1 Loss of Materi al Due to P itting and Crev ice Corrosi on The project team noted that the OCGS LR A, Table 3.3.2.1.1 8 for the heating an d process steam system, incl udes AMR line ite ms for loss of material in heat ex changers constructed of copper that ar e exp osed t o aux ilia ry ste am, and steam t raps co nstruct ed of co pper a lloy that a re expo sed to boil er trea ted w ater on the i nterna l surfac e. The appli cant cr edite d the OC GS one-time insp ection aging managemen t program (AMP B
.1.24) to manage lo ss of material for these components.
The applica nt was asked to provide the justificatio n for concludin g that the 377 One-Time Inspection Program alone w as sufficient to manage loss of material for these components.
In its letter dated April 17, 2006 (ML061150320), the applicant committed to revise Table 3.3.2.1.18 in the OC GS LRA to in clude the w ater ch emistry aging ma nagemen t progra m to address loss of material due to pitting and c revice corro sion for componen ts constructed of coppe r and c opper allo y in the he ating a nd pro cess s team sy stem tha t are e xpos ed to a uxil iary steam a nd boi ler tre ated w ater. This is A udit Commitment 3.3.2.1.1
-1.The project team rev iewed th e applica nt's response and determined that the addi tion of the W ater Chemistry Program would make these line items consistent with the recomm endations in the GAL L Repo rt to ma nage l oss of ma terial due to pitti ng and crevi ce corr osion , and t herefore was accep table.The pro ject tea m found t hat, by usin g the Water Ch emistry Program togethe r wi th the One-Time Inspection Pro gram to manage loss of materi al due to p itting and crev ice corrosio n, the appli cant has demonstrated that the effects of aging wi ll be ade quately managed.
The project team als o noted that, i n the OCGS LRA , Table 3.3.2.1.41 for the water treatme nt and distribu tion system i ncluded AM R line i tems for loss of material in val ve bodie s constructed of brass and bronz e that are ex posed to treated water on the internal surface. The appli cant credi ted the OCGS se lecti ve l eachi ng of mate rials aging ma nagemen t progra m (AM P B.1.25) to manag e loss of mater ial for these co mponen ts. Th e proje ct team reviewed the OCGS Sele ctive Leaching of Mater ials Prog ram and determ ined that it manag es loss of mater ial due to se lective leaching; how ever, it do es not manage lo ss of material du e to pitting an d crevice corrosion. The applicant w as asked to cla rify how l oss of material d ue to pittin g and crevic e corrosion w ould be managed for these compon ents.In its letter dated April 17, 2006 (ML061150320), the applicant committed to revise Table 3.3.2.1.41 in th e OCGS LRA to address aging managemen t of loss of material due to pitti ng and crevice co rrosion for val ve bodie s constructed of bras s and bronz e exposed to treated w ater on the internal surface by addi ng the follow ing AMR line items:
*Valve B ody - le akage boundary -
brass - treated water (in ternal) - lo ss of material - w ater chemistry (B.1.2) - VII.E4-8 (AP-64) 3.3.1-38
*Valve B ody - le akage boundary -
brass - treated water (in ternal) - lo ss of material - on e-time inspecti on (B.1.24) - V II.E4-8 (AP-64) 3.3
.1-38*Valve B ody - le akage boundary -
bronze -
treated water (internal) -
loss of material - w ater chemistry (B.1.2) - VII.E4-8 (AP-64) 3.3.1-38
*Valve B ody - le akage boundary -
bronze -
treated water (internal) -
loss of material - on e-time inspecti on (B.1.24) - V II.E4-8 (AP-64) 3.3
.1-38 This is A udit Commitment 3.3.2.1.1
-2.The project team rev iewed th e applica nt's response and determined that the li ne items to be added we re consistent w ith the recommend ations in the GALL Repo rt to manage loss of material due to pitting and crevice co rrosion; therefore, the y are accep table.The pro ject tea m found t hat, by usin g the Water Ch emistry Program togethe r wi th the One-Time Inspection Pro gram to manage loss of materi al due to p itting and crev ice corrosio n, the appli cant has demonstrated that the effects of aging wi ll be ade quately managed.
378 3.3.2.1.2 Cracking Initiati on and Grow th Due to Thermal and Mec hanical L oading The pro ject tea m noted that, i n the OC GS LRA , Table 3.3.2.1.9 for t he con trol ro d driv e sys tem, Table 3.3.2.1.24 for the noble metal s monitoring sy stem, Table 3.3.2.1.25 for the post-accid ent sampling sys tem, Table 3.3.2.1.32 for the reactor w ater cleanup system, Table 3
.3.2.1.36 for the shutdown c ooling sys tem, and Table 3.3
.2.1.38 for the standb y liquid control sy stem included AMR li ne items for pipi ng, fittings, and val ve bodie s less than NPS 4 constru cted of variou s materials and exposed to treated wa ter on the in ternal surface. The applicant c redited the OCGS One-Time In specti on Pro gram (AM P B.1.24) to manage c racking initi ation and gro wth due to thermal and mechanica l loadin g of these components.
The project team rev iewed th e applicants One-Time Inspection Program and ve rified that it i s consistent w ith the recommendations in the GALL Report for AMP XI.M32. The projec t team determined that this program would provide a dditional assurance that the aging effects are adequatel y managed; therefore, it is acceptable. The project team
's evaluation of OCGS AMP B.1.24 is discussed in Secti on 3.0.3.1.4 of this audit and re view report.On the basis o f its review , the project team found that the appl icant appropri ately add ressed cracking initia tion and grow th due to thermal and mechani cal loadi ng for components in the control rod dri ve, post-acci dent samplin g, reactor water c leanup, shutd own cool ing, and standb y liquid contro l systems.
3.3.2.1.3 Hardening and Loss of Strength Due to Elastomer De gradation In the OCGS LRA , Table 3.3.2.1.14 for the emergency serv ice water system, Table 3
.3.2.1.17 for the ha rden ed ven t syst em, and T able 3.3.2.1.35 f or th e ser vice wat er sys tem , inc lude A MR line items for hardening and l oss of strength due to elastomer degradati on. The appli cant proposed to mana ge hardening and loss of strength due to elastomer degrad ation using th e OCGS structures moni toring program (AMP B.1.31) for extern al surfaces of elas tomer components ex posed to ind oor or outdoor a ir. Generic n ote E was cited for these A MR li ne items, indica ting that the materi al, envi ronment, and aging e ffect were consiste nt with th e GALL Report; how ever, a differe nt agin g manageme nt progr am wa s credi ted. Th e GALL Repor t recomme nded a plan t speci fic progr am be e valu ated for this aging effec t.The project team rev iewed th e applica nt's structures mon itoring program (AM P B.1.31), and verified that this program incl udes visu al inspecti ons of component ex ternal surfaces to detect aging degradat ion of elastomer compone nts. The project te am determined that this AMP is adequate to detect hardening and loss of strength due to elastomer degrad ation prior to a loss of inte nded fu nctio n, and that th is AM P wi ll ad equatel y mana ge this aging e ffect.On the basis o f its review , the project team found that the appl icant appropri ately add ressed hardening and loss of strength due to elastomer degrad ation for elastome r components in the emergency serv ice water, hardened v ent, and serv ice water systems.3.3.2.1.4 Cracking Initiati on and Grow th Due to Stres s Corrosion Cracking 3.3.2.1.4.1 Cracking Initiati on and Grow th due to Stress Corrosion C racking [Item 1]
In the OCGS LRA , Table 3.3.2.1.24 for the noble metal s monitoring sy stem, the appli cant proposed to mana ge cracking initia tion and grow th due to stress corrosion crackin g of stainless steel pipi ng and fittings less than NPS 4 in a treated water env ironment usin g the OCGS Water Chem istr y Prog ram (AMP B.1.2) tog ethe r with the O CGS O ne-T ime I nspe ctio n Pro gra m (AMP 379 B.1.24). In pl ant specific no te 1 to Table 3
.3.2.1.24 in the OCGS LRA, the applicant s tated that the BWR reactor water cle anup system p rogram does not app ly to pi ping and pip ing welds less than N PS 4; therefor e, the wate r chemi stry a nd one-time i nspect ion p rograms w ill be use d to confirm that cr acking due to stress corrosion cracking
/intergrannular st ress corrosion crack ing is not occurring in piping and piping we lds less th an NPS 4.
Generic note E was cite d for these AMR line items, indi catin g that th e mater ial, envi ronmen t, and aging effec t wer e cons isten t wi th the GALL Repo rt; howev er, a different aging management program was cred ited. The GALL Report recommended the BWR reactor water cl eanup syste m program (XI.M25) for this aging effect.The pro ject tea m revi ewed the ap plic ant's Water Chemi stry P rogram (A MP B.1.2), On e-Time Inspection Pro gram (B.1.24) and v erified that these programs are consi stent with the recommendations i n the GALL Re port for AMPs XI.M2 and XI.M 32, respectiv ely. The p roject team also v erified that these programs includ e activi ties that w ill mitigate cracking initi ation and growth due to stress corrosion cracking in stai nless steel components. The project team determi ned th at thes e progra ms wo uld p rovi de add ition al as suranc e that the agi ng effects are adequately man aged; therefore, it is acceptable.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed cracking due to stres s corrosion cra cking of stainless s teel pipi ng and fittings less than NPS 4 for the n oble metals monito ring sy stem.3.3.2.1.4.2 Cracking Initiati on and Grow th due to Stress Corrosion C racking [Item 2]
In the OCGS LRA , Table 3.3.2.1.36 for the shutdown cooling sy stem and Table 3
.3.2.1.32 for the reactor w ater cleanup system, the app licant propo sed to manage crackin g due to stress corrosion crackin g of stainless stee l piping a nd fittings greater than or equal to NP S 4 in a treated water environment using the Water Chemistry Pro gram (AMP B.1.2) together with the BWR stress corrosion cracking program (A MP B.1.7) and the ASM E Section XI In service Inspection, Su bsections IWB, IWC and IW D program (AMP B.1.1). In pl ant specific no tes 1 and 4 to Tables 3.3
.2.1.36 and 3.3.2
.1.32 in the OCGS LRA, respec tively , the appli cant stated that the ASME Section XI Inse rvice Inspe ction, Subsec tion IWB, IW C, and IWD program was appl ied in additi on to the GALL Report recommended programs for this aging effect. Generi c note E was cited for these AMR line ite ms, indicatin g that the material , environmen t, and aging effect were consi stent with the GALL Repo rt; howev er, a different aging management program was credited. The GAL L Report recommend ed the Water Chemistry Program an d the BWR stress corros ion c racking program t o manage this aging effec t.Th e p r o j e c t t e a m r e v i e w e d t h e a p p l i c a n t's Wa t e r C h e m i s t r y P r o gr a m (A M P B.1.2) a n d B WR stress corrosion cracking program (AM P B.1.7) and v erified that these programs are consi stent with the recommendations i n the GALL Re port. Therefore, the projec t team determined that the applicant's proposed inclusion of the ASME Section XI Inservice Inspec tion, Subsections IW B, IW C and IWD program, in additi on to the GALL recommended programs, w ill prov ide additi onal assurance that th is aging effect wil l be adequatel y managed, and was accep table.On the basis o f its review , the project team found that the appl icant appropri ately add ressed cracking due to stres s corrosion cra cking for stainless s teel components in a treated water environment in the reactor water clea nup and shutd own cool ing systems.
380 3.3.2.1.5 Components Ex posed to Dry Air wi th No Aging Effect Identi fied In th e OCG S LRA, Tabl e 3.3.2.1.20 for the in str umen t air syste m, t he app lican t inc luded AMR line items for various co mponents exp osed to a dry gas environ ment for which no aging effect was identified. The applicant cited the Compres sed Air Monitoring program (AMP B.1.17) in these AMR line ite ms. Generic note E was ci ted for these AM R line i tems, indicati ng that the materi al, en viro nment, a nd agi ng effect w ere co nsiste nt wi th the GALL R eport; howe ver, a different aging management program w as credited.
Plant speci fic note 1 to Tabl e 3.3.2.1.20 was also cited, in which the applican t stated that the Compressed Ai r Monitori ng program was applied to the instrument a ir system compo nents to confirm the internal en vironment remai ns sufficiently dry to preclude aging effects. The GALL Repo rt does not reco mmend an aging management program whe n no aging effect has be en identified
.In review ing these AM R line i tems, the project team re cognized tha t, in Branch Technical Position R LSB-1, the staff noted th at an aging effect should be identi fied as appli cable for license ren ewal ev en if there is a preventi on or mitigation program associated with tha t aging effect. Therefore, the applic ant was as ked to clarify w hy no agin g effect was identi fied for these components. The a pplicant res ponded that the Compressed Ai r Monitori ng Program provide s confirmation of the en vironment, an d is not con sidered a pre vention o r mitigation program to an aging effect, as defined in NUREG-1800, Rev. 1, Ap pendix A.1.2.1.5. NURE G-1801, Rev. 1
, Chapter IX, Sectio n D, Envi ronments defines the environmen t of dry air as
?air that has b een treated to reduce the dew point we ll below the system op erating temperature."
The plant specific note w as added to e xplain why the Compressed Ai r Monitori ng program was i ncluded for these line items.The project team reviewed the applicant's response and determined that the Compr essed Air Monitori ng program was i ncluded to c onfirm the specified atmosphere; not a s a preven tion or mitigation program. There fore, the project team found the AMR line items acceptable.
On the basis o f its review , the project team found that the appl icant appropri ately id entified no aging effect for components in the instrument ai r system ex posed to a dry air envi ronment, and the inclusi on of the Compresse d Air M onitoring program for these AMR l ine items i s acceptable
.3.3.2.1.6 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion 3.3.2.1.6.1 Loss of Materi al due to Gen eral, Pittin g, and Crevi ce Corrosion
[Item 1]In the OCGS LRA, Table 3.3.2.
1.1 for the C-batt ery room heating and ventilation system, Ta ble 3.3.2.1.2 for the 4160 V switchgea r room ventil ation syste m, Table 3.3.2.1.3 for the 480V switchgear roo m ventilati on system, Tabl e 3.3.2.1.4 for the ba ttery room and MG set room ventilati on system, Tabl e 3.3.2.1.8 for the co ntainment va cuum breakers, Table 3.3.2.1.10 for the control roo m HVAC sy stem, Table 3.3.2.1.11 for the cranes and hoists, Table 3.3.2.1.28 for the radwaste area heatin g and ventil ation syste m, and Table 3.3.2
.1.31 for the reactor b uilding ventilati on system, the applicant p roposed to manage loss of material due to general , pitting, and crevice co rrosion of the ex ternal surfaces of structu ral and cl osure boltin g constructed of carbon a n d l o w a l l o y s t e e l e x p o s e d t o i n d o o r o r o u t d o o r a i r u s i n g t h e A S M E S e c t i o n X I , S u b s e c t i o n I WE Program (AMP B
.1.27), Inspection of Overhead He avy Loa d and Light Lo ad Handli ng System Program (AMP B
.1.16), or the Struc tures Moni toring Program (AM P B.1.31). Generi c note E was cited for these AMR line ite ms, indicatin g that the material , environmen t, and aging effect were consi stent with the GALL Repo rt; howev er, a different aging management program was 381 credited. The GALL Report r ecommended the Bolting In tegrity Program (AMP XI.M18) for this aging effec t.The proj ect t eam r eviewe d the appli cant's ASME Sect ion X I, Su bsec tion IW E Prog ram (AMP B.1.27), Insp ecti on of Over head Heavy Lo ad and Ligh t Loa d Hand ling Syste m Pro gra m (AMP B.1.16), and the Str ucture s Mo nitori ng Progra m (AM P B.1.31) an d ver ified that th ese pr ograms include i nspections tha t will detect loss of material due to general, pitti ng, and crevi ce corrosion on the exte rnal surfaces of structura l and clo sure bolting.
The project team determi ned that these AMP s were con sistent wi th the Bolti ng Integrity Program in the GALL Rep ort for detecting loss of material due to general , pitting, and c revice corro sion prior to a loss of i ntended function for the a ppli catio ns cit ed, an d that these AMP s wi ll ad equatel y mana ge this aging e ffect.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material due to general, pitti ng, and crevi ce corrosion on the exte rnal surfaces of structura l and closure bolting exp osed to indo or or outdoor ai r in the aux iliary systems.3.3.2.1.6.2 Loss of Materi al due to Gen eral, Pittin g, and Crevi ce Corrosion
[Item 2]In the OCGS LR A, Tabl e 3.3.2.1.13 fo r the e mergency dies el gen erator and au xil iary syste m, Table 3.3.2.1.26 for the process sampl ing system, Table 3.3.2.1.29 for the rea ctor buildi ng closed cool ing water sy stem, and Table 3
.3.2.1.40 for the turbi ne buildi ng closed cool ing water system, the app licant propo sed to manage lo ss of material du e to general, pi tting and crev ice corrosion of the i nternal surfaces o f piping, fittings, and tanks constructed of carb on and low alloy s teel, and cas t iron, exp osed to clos ed coolin g water usin g the closed-coo ling water system program (AMP B
.1.14) and the One-Time Inspection Program (AMP B
.1.24). Generic n ote E was cited for the One-Time Inspecti on Program for these AM R line i tems, indicati ng that the materi al, en viro nment, a nd agi ng effect w ere co nsiste nt wi th the GALL R eport; howe ver, a different aging management program w as credited.
The GALL Report re commended the closed-cool ing water sy stem program (XI.M21) al one for this aging e ffect. In plant speci fic notes to the aforemen tione d tabl es in the OC GS LRA , the a ppli cant st ated th at the One-Time Inspec tion P rogram w as add ed to t he GAL L reco mmended Water Chemi stry P rogram to confirm the absence o f this aging effect in stagnant flow areas.
The project team rev iewed th e applica nt's closed-cooling w ater system program (A MP B.1.14)and verified that it is consistent w ith the clos ed-cooling w ater system program (XI.M 21)recommended in the GALL Repo rt to manage this a ging effect. The project team determi ned that the additi on of the One-Time Inspe ction Program w ould prov ide additi onal assuran ce that this aging effect wi ll be ade quately managed, therefore, it is ac ceptable.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of mat eria l du e to gene ral, pit ting , and crev ice corr osi on o n the int erna l su rface s of p ipi ng, fittings and tanks ex posed to clo sed-cooling w ater in the e mergency diese l generator and auxili ary, process sampling, reactor b uilding cl osed cooli ng water, and turbine bui lding close d cooling w ater systems.
3.3.2.1.6.3 Loss of Materi al due to Gen eral, Pittin g, and Crevi ce Corrosion
[Item 3]In the OCGS LRA , Section 3.3.2
.2.7.3, the appl icant provi ded its further ev aluation for l oss of material due to general, pitti ng, and crevi ce corrosion for steel pipi ng, piping compone nts, piping elements, ducti ng, closure bol ting and heat e xchanger tubes exposed to air-indoor u ncontrolled, 382 ai r-o utd oor , co nde nsa tio n, m oi st a ir, tre ate d w ate r, o r l ubr ica tin g oi l, in acc ord anc e w ith the dra ft January 2005 SRP-LR.
In review ing this further ev aluation, the project team recogni zed that the approved September 2005 GA LL Rep ort rec ommende d AM P XI.M 36 XI.M 38, ?Inspection of Inter nal Surfaces in Miscel laneous Pi ping and Ducti ng Components,"or XI.M 39,?Lubr ica ting Oil Ana lys is" to ma nage this aging effect wi th no further eva luation requi red. Therefore, the projec t team review ed the applicant' s further evalu ation against the recommendation s in the aforementi oned GALL AM Ps, as appropriate
.In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a One-Time Inspection Program, B.1.24, for susce ptible lo cations to v erify the effectiven ess of the 10 CFR Part 5 0, App endix J progr am, B.1.29, to manage the lo ss of mat erial in pr imary containment bou ndary steel piping, pip ing components, an d piping el ements expose d to an indoor air internal en vironment i n the reactor w ater cleanup system and rea ctor buildi ng ven til atio n sy stem. The 10 C FR P art 5 0, A ppen dix J pr ogram prov ide s for the d etec tion of age related degradation due to loss of material. The progr am consists of test s performed in accordance w ith the regulati ons and guida nce provi ded in 10 CFR Part 50 Appendix J, Option B and stat ion proc edur es. Con tain ment lea k rate test s are perfo rmed to a ssur e tha t le akage through the primary containment an d systems and components pen etrating primary containment does not ex ceed allo wable l eakage limits spe cified in the technical specifications. An integrated leak rate test (ILRT) i s performed during a p eriod of reactor sh utdown at the frequency speci fied in 10 CFR Part 50, Appe ndix J, Opti on B. Local leak rate tests (L LRT) are performed on isolation valves and contain ment access pene trations at frequencie s that comply with the requirements of 10 CF R Part 50 Ap pendix J , Option B. Obse rved condi tions that hav e the potential for i mpacting an inte nded function a re evalua ted or corrected in accordanc e with th e corrective a ction process.
The project team rev iewed th e applica nt's 10 CFR Part 50, Appe ndix J p rogram (AMP B.1
.29)and verified that this agin g management program inclu ded activ ities that are consistent w ith the recomme ndati ons i n GALL AMP XI.M3 6 to man age lo ss of mat erial in co mponen ts ex posed to an indoor air internal environment. In addition, the proj ect team reviewed the applicant's One-Time Inspection Program (B.1.24) and verified tha t this aging management program includes i nspections o f components to detec t loss of material as a means o f verifying the effectiveness of the 1 0 CFR Part 5 0, Appendix J program. The project team determined th at OCGS AM Ps B.1.29 an d B.1.2 4, toget her, w ill adequa tely manage loss o f materia l in primar y containment bou ndary steel piping, pip ing components, an d piping el ements expose d to an indoor air internal en vironment i n the reactor w ater cleanup system and rea ctor buildi ng venti latio n sys tem.In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a fire protection pro gram, B.1.19, to insp ect the interna l surfaces of steel piping, pipi ng components, and piping eleme nts with a n indoor ai r internal e nvironment for ha lon/carbon dioxide fire suppressio n systems. The program provides for periodic s ystem operabi lity testi ng and visual aging degradation inspections of internal surfaces that ensure aging degra dation is detected prior to the loss o f intended function. Observed co nditions tha t have the potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process
.The project team rev iewed th e applica nt's fire protecti on program (AMP B.1.19) and v erified that this aging management p rogram included activiti es that are con sistent wi th the 383 recommendations i n GALL AM P XI.M38 to man age loss of material in componen ts with an indoor air internal environment. The proj ect team determined th at OCGS AMP B.1.19 will adequa tely manage loss o f materia l in steel pipi ng, pip ing com ponen ts, and pipi ng ele ments w ith an indoor a ir internal environmen t for halon/carbon dioxide fire suppressio n systems.
In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a fire water sy stem program, B.1.20, to i nspect the in ternal surfaces of stee l piping, pi ping compon ents, a nd pi ping e lement s wi th an i ndoor air i nterna l env ironme nt for w ater-ba sed fire protection sy stems. Program activ ities incl ude system mon itoring, period ic inspecti ons, surveillance testing, and system mainte nance activities that ensure aging deg radation is detected prior to the loss o f intended function. Observed co nditions tha t have the potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process
.The project team rev iewed th e applica nt's fire wa ter system program (AM P B.1.20) and verified that this aging mana gement program includ ed activi ties that are c onsistent w ith the recommendations i n GALL AM P XI.M38 to man age loss of material on the inte rnal surfaces of compon ents w ith an indo or air inter nal e nvir onment. The pr oject te am dete rmined that OC GS AM P B.1.20 wi ll a dequ atel y ma nage los s of ma teri al o n the int erna l su rface s of s teel pip ing, piping compone nts, and pipi ng elements w ith an ind oor air inte rnal envi ronment for water-ba sed fire pro tectio n sys tems In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a One-Time Inspection Program, B.1.24, for susce ptible lo cations to v erify the effectiven ess of the generator stat or water chemistry activities program , B.2.3, to manage the loss of material in steel pipi ng, piping compone nts, piping el ements, and heat exchangers ex posed to a trea ted water intern al envi ronment in the main generator and auxili ary system.
Observed con ditions that have the p otential for impa cting an inten ded function are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's further eva luation an d determined th at the generator stator water chemistry activities prog ram (AMP B.2.3) is a plant specific progr am that is appropriate to manage the loss of material in steel pipi ng, piping compone nts, piping el ements, and heat ex changers. The techni cal eval uation of this program to determine i ts adequacy w as performed by N RR/DE staff, and is ad dresse d in t he SE R rela ted to the Oy ster Cr eek pla nt. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging management p rogram includes inspections of steel pipi ng, piping components, pip ing elements, an d heat exc hangers to detect l oss of material a s a means of veri fying th e effecti vene ss of the genera tor sta tor w ater ch emistry activ ities program.In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a Periodic In spection Program, B
.2.5, to manage the l oss of material i n emergency di esel generator venti lation sy stem steel compon ents expose d to an ind oor air inte rnal or ex ternal environment or an oil external e nvironment.
The Periodic Inspection Pro gram will also be use d to mana ge the l oss of ma terial in eme rgency dies el gen erator venti latio n sys tem duc twork exposed to an indoor a ir internal environmen
: t. The Periodi c Inspection Program relies on periodic i nspections to identify and evaluate the degradation of steel compone nts exposed to an indoor air internal or external environment or an oil external environment to ensure th at there is no loss of in tended function.
Observed cond itions that h ave the po tential for impac ting an intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.
384 The project team reviewed the applicant's further evaluation and determined that the Periodic Inspection Pro gram (AMP B.2.5) is a pla nt specific program tha t is appropri ate to manage the loss o f materia l in emergenc y di esel generat or ve ntila tion s ystem steel compon ents e xpos ed to an indoor a ir internal or external environmen t or an oil external environment.
The technical evaluation of this program to determine its adequacy was perfor med by NRR/DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a periodic inspection of ventilation systems prog ram, B.2.4, to ma nage the loss of mate rial in ventilation system steel piping, piping component s, and piping elements exposed to an indoor air internal or external e nvironment i n the ?C" battery roo m heating and v entilation system, 480V switchgear roo m ventilati on system, batte ry and M G set room venti lation sy stem, control room HVAC sys tem, radwaste a rea heating and ventila tion system, a nd reactor bui lding ven tilation system. The program w ill ins pect internal and extern al steel su rfaces of ventila tion system components to identif y and assess aging eff ects that may be occurring.
The program will incl ude su rface in specti ons of s teel c ompone nts for i ndica tions of loss of materi al, su ch as r ust, corrosion, and pitting. Observ ed conditio ns that have the potential for impacting an i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is appropriate to manage the loss of material in ventilati on system stee l piping, pi ping components, and pipin g elements exp osed to an i ndoor air i nternal or ex ternal env ironment. The tech nical evaluation of this program to determine its adequacy was perfor med by NRC DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.In the OCGS LR A, Sec tion 3.3.2.2.7.3, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a structures monitori ng program, B.1.31, to i nspect the ex ternal surfaces of stee l piping, pi ping components, piping element s, and ductwork exposed to an indoor air external or outdoor air external e nvironment i n the emergency diesel genera tor and aux iliary system, chlori nation system, and control room HVAC system.
The structures monit oring program relies on periodic vis ual ins pect ion s by qual ifie d in div idu als to i dent ify and eva lua te th e de grada tion of pi pin g, pipi ng compo nents, and p ipin g eleme nts to ensure that th ere is no lo ss of in tended functio n. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team rev iewed th e applica nt's structures mon itoring program (AM P B.1.31) and verified that this aging management p rogram included activiti es that are con sistent wi th GALL AMP XI.M36 to manage the loss of mat erial in components exposed to an indoor or outdoor air external environment. The project team determined that O CGS AMP B.1.31 will adequately manage the loss of material on the external surfaces of steel pi ping, piping co mponents, pipi ng elements, and ductwork exposed to an indoor air external or out door air external environment in the emergency di esel generator a nd auxil iary sy stem, chlorinati on system, and control room HVAC syste m.In the OCGS LRA , Section 3.3.2
.2.7.3, the appl icant stated th at at Oyster Cre ek, the aging effect of loss of material du e to general co rrosion in the primary c ontainment atmosph ere is not considered a credible aging effect for carbon steel c omponents in a containment n itrogen envi ronmen t beca use of n egligi ble a mounts of free ox ygen (less t han 4 percen t by v olume durin g normal opera tion). Both oxy gen and moistu re must be pre sent for general corros ion to occur because oxygen al one or wa ter free of dissolv ed oxygen (high humidi ty in a n itrogen 385 atmosphere) does not corrode carb on steel to a ny practica l extent.
Therefore, there is no loss of material for carbon steel compone nts exposed to a contain ment nitrogen env ironment becaus e, with the negligible a mounts of free oxy gen, anodic rea ctions do no t take place and the corrosion cell does not form.The pro ject tea m revi ewed the ap plic ant's further eval uatio n rela ted to loss o f materia l due to general corrosio n in the pri mary contain ment atmosphere for carbo n steel compon ents and concurred w ith the appl icant's con clusion tha t this is no t a credible aging effect. The Oyster Creek containment is inerted d uring normal ope ration; therefore, there are negligibl e amounts of free ox ygen p resent. Sin ce ox ygen a nd moi sture mu st be p resent for gener al co rrosio n to occur, general corros ion o f carbon steel compon ents i s not a credi ble e vent.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material due to general, pitti ng, and crevi ce corrosion for steel pipi ng, piping compone nts, piping eleme nts, ducting, clo sure bolting a nd heat ex changer tubes ex posed to air-i ndoor uncontrolled , air-outdoor, co ndensation, moi st air, treated w ater, or lubric ating oil i n the aforementioned aux iliary systems.3.3.2.1.7 Loss of Preload Due to Stress Relaxa tion In the OCGS LRA , Table 3.3.2.1.8 for containment v acuum breakers, Table 3.3.2.1.11 for cranes and ho ists, and Table 3.3.2.1.16 for fuel stora ge and handli ng equipment, the app licant proposed to mana ge loss of preloa d due to stress relaxatio n of structural and closure bol ting constru cted o f carbon and l ow a lloy steel expo sed to indo or air usin g the AS ME S ectio n XI, Subsection IWE program (AMP B.1.27) and th e inspectio n of overhead heavy l oad and li ght load handling sy stem program (AMP B.1.16). Generic note E wa s cited for these AMR li ne items, indicating th at the material , environmen t, and aging effect were consistent w ith the GALL Report; how ever, a differe nt agin g manageme nt progr am wa s credi ted. Th e GALL Repor t recomme nded t he Bol ting In tegrity Program (AMP XI.M1 8) for th is agi ng effect.
The proj ect t eam r eviewe d the appli cant's ASME Sect ion X I, Su bsec tion IW E pro gra m (AMP B.1.27) a nd ins pect ion of overh ead he avy load and lig ht loa d hand ling syste m pro gra m (AMP B.1.16), and veri fied th at thes e progra ms inc lude activ ities that w ill detect loss of prel oad du e to stress relaxation of struc tural and closure bolting. The proj ect team determined th at these AMPs will assure detectio n of loss of prelo ad due to stres s relaxati on prior to a loss of inten ded functio n, and that th ese AM Ps w ill adequa tely manage this a ging effect
.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of preload due to stress relax ation of structural and closure bolting ex posed to ind oor air in the aforementioned aux iliary systems.3.3.2.1.8 Loss of Materi al Due to P itting, Crevi ce, and Galv anic Corrosi on In the OCGS LRA , Table 3.3.2.1.29 for the reactor buil ding closed cooling w ater system, the applicant p roposed to manage loss of material due to pitti ng, crevice, an d galvani c corrosion o f the in ternal surface s of the shutdo wn co olin g pump c ooler s cons tructed of copp er ex posed to treated water using the Water Chemistry Pro gram (AMP B.1.2) and the One-Time Inspection Program (AMP B
.1.24). In plan t specific note 5 to Table 3.3.2
.1.29 in the OCGS LRA, the applicant s tated that the cl osed-coolin g water sys tem program does not a pply to a treated wate r envi ronmen t; there fore, the appro priate programs for mana ging the iden tified aging e ffects are water chemi stry and one-time inspecti on. Generic n ote E was cited for these A MR li ne items, 386 indicating th at the material , environmen t, and aging effect were consistent w ith the GALL Report; how ever, a di fferent aging management program was credited.
As part of its reco nciliati on of the AM Ps in the d raft January 200 5 GALL Report with the approved September 2005 GALL Report , the applicant determined that t he recommendations in the GALL Repo rt for this aging effect were revised.
Previousl y, the GALL R eport recommended the closed-coo ling water system program (AM P XI.M21); how ever, the ap proved Sep tember 2005 GA LL Rep ort now recomme nds th e Water Chemi stry P rogram (XI.
M2) a nd the One-Tim e Inspec tion P rogram (XI.
M32) for thi s aging effect. The refore, t he app lica nt con clude d that its AMR was consi stent w ith th e GALL Repor t.The pro ject tea m revi ewed the ap plic ant's Water Chemi stry P rogram (A MP B.1.2) a nd One-Time Inspection Pro gram (AMP B.1.2 4), and veri fied that these pro grams are consisten t with the recomme ndati ons i n the GA LL Rep ort. The projec t team d etermi ned th at thes e AM R lin e items are consistent with the recommend ations in the GALL Report and the applicant's AMPs will adequa tely manage this a ging effect
.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material due to pitting, crev ice, and galv anic corrosi on on the i nternal surfaces o f the shutdown c ooling pump co olers.3.3.2.1.9 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion, an d Fouling In the OCGS LR A, Tabl e 3.3.2.1.6 for the ci rcula ting w ater sy stem, Tab le 3.3.2.1.15 for the fire protec tion s ystem, Table 3.3.2.1.22 for the mi scell aneou s floor and equ ipment drain syste m, Table 3.3.2.1.30 for the reactor buil ding floor and e quipment drains, and Table 3.3.2
.1.34 for the sanitary w aste system, the applican t proposed to man age loss of material due to pitti ng, crevice, and MIC, a nd fouling, of the i nternal surfaces o f piping and fittin gs constructed of carbon and low alloy s teel, cast iro n, copper all oy, bronz e and brass e xposed to raw wa ter-salt wate r or raw water-fresh wa ter using the fire w ater system program (A MP B.1.20), the One-Time Inspec tion Program (AMP B
.1.24), or the Peri odic Inspecti on Program (AMP B.2.5). Generic note E w as cited for thes e AM R lin e items , indi catin g that th e mater ial, envi ronmen t, and aging effec t wer e consi stent w ith th e GALL Repor t; how ever, a differe nt agin g manageme nt progr am wa s credi ted. The GALL Report re commended the op en-cycle c ooling wa ter system program (AM P XI.M20)for this aging e ffect.The project team rev iewed th e applica nt's Fire Water System Program (A MP B.1.20) and the One-Time Inspection Program (AMP B.1.24), and v erified that these programs includ e activi ties that wil l detect los s of material due to pitting, crev ice, and M IC, and fouling, o n the internal surfaces of pip ing an d fitti ngs. The projec t team d etermi ned th at thes e AM Ps are adequa te to detect loss o f material due to pitting, crevi ce, and M IC, and fouling, p rior to a lo ss of intended functio n, and that th ese AM Ps w ill adequa tely manage this a ging effect
.The project team rev iewed a pplicant's the Periodi c Inspection Program (AMP B
.2.5) and determined that it is a pl ant specific pro gram that is approp riate to manage the loss of material due to pitti ng, crevice, an d MIC, and fouling, on the internal surfaces of piping and fittings. The tec hni cal ev al uat io n o f th is pro gra m to de ter min e i ts a deq uac y w as p erfo rme d b y N RR/DE sta ff, and i s addr essed in the SER r elate d to th e Oyst er Cre ek plan t.
387 On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material due to pitting, crev ice, and M IC, and fouling, o n the internal surfaces of piping a nd fittings exposed to raw w ater-salt wa ter in the ci rculating w ater, fire protection , miscellane ous floor a nd equi pment d rain, reacto r buil ding flo or and equip ment dr ains, and s anita ry w aste systems.3.3.2.1.10 Loss of Materi al Due to Ge neral Corrosi on In the OCGS LRA , Section 3.3.2
.2.6, the appli cant provid ed its further ev aluation for l oss of material of steel piping, bol ting, and compone nt external surfaces expos ed to air-in door uncontrolled (external), air-outdoor (ex ternal), or cond ensation (ex ternal) due to general corrosion, in accordance with the draf t January 2005 SRP-LR.
In review ing this further ev aluation, the project team recogni zed that the approved September 2005 GALL Re port recommended a ging management program XI.M36 to manage this aging effect with no further evaluation required. Th erefore, the pr oject team reviewed the applicant's further evaluati on against the recommendations i n GALL AM P XI.M36 to man age this aging effect.In the OCGS LR A, Sec tion 3.3.2.2.6, the appli cant st ated th at Oys ter Cre ek wi ll i mpleme nt a Fi re Protection Pro gram, B.1.19, to insp ect the interna l and ex ternal surfaces of stee l piping, pi ping components, and piping eleme nts exposed to an indo or air intern al or exte rnal envi ronment, or an outdoor ai r external environment, for halon/carbon d ioxide fire suppression systems. The program provides for periodic s ystem operabi lity testi ng and visu al aging degradati on inspe ction s of int ernal and e xtern al su rfaces th at ens ure agi ng degrad ation is de tected prior to the loss of in tended function.
Observed cond itions that h ave the po tential for impac ting an intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.The project team rev iewed th e applica nt's Fire P rotection Program (AM P B.1.19) again st the recommendations i n GALL AM P XI.M36. The applicant w as asked to cla rify the frequency of the inspections to be performed und er OCGS AMP B.1.19; wh en the inspe ctions wi ll be in itiated;and ho w in specti ons of i nsula ted co mponen ts and inac cessi ble c ompone nts w ill be per formed. The applican t stated that the inspections will be performed eve ry 18 months.
Some of the inspections are ongoing; how ever, the en hanced insp ections for lic ense renew al  wi ll be in itiated prior to peri od of ex tended opera tion. The ap plic ant furth er stat ed tha t none of the c ompone nts in the scope of these inspec tions are in sulated. With regard to inac cessible l ocations, the applicant s tated that NFPA 25 (nationa l fire protectio n associati on standard 25 for inspection, testing, and main tenance of wa ter-based fire protec tion systems) allows an excep tion from inspe ction for pip e in c oncea led s paces or othe r inac cessi ble a reas. Most of the c ompone nts included in the scope of these inspections are acces sible, and there is sufficient accessible pipi ng to pr ovid e a rep resent ativ e asse ssment of the d egree o f exter nal s urface d egradat ion. The project team reviewed the applicant's response and determined that it is acceptable since it is consisten t with the recommendations in GALL AM P XI.M36.The project team determi ned that OCGS AM P B.1.19 inc luded ins pections that will detect loss o f material due to general corrosi on that are con sistent wi th the recommendati ons in the external surfaces monitoring pro gram in the GALL R eport (AMP XI.M36). The pro ject team determined that this AM P will adequately manage loss of materia l due to genera l corrosion for internal and external su rfaces of steel pipi ng, piping compone nts, and pipi ng elements ex posed to an i ndoor air internal or external environmen t, or an outdoor air externa l enviro nment, for halon/carbo n dioxide fire suppressio n systems.
388 In the OCGS LR A, Sec tion 3.3.2.2.6, the appli cant st ated th at Oys ter Cre ek wi ll i mpleme nt a fir e water sys tem program, B.1.20, to i nspect the ex ternal surfaces of stee l piping, pi ping components, and piping eleme nts exposed to an indo or air exte rnal or outdo or air exte rnal environment for water-based fire protection sy stems. Program activ ities incl ude system monitoring, perio dic inspec tions, surve illance testing, and sy stem maintenance activiti es that ensure aging degradati on is detecte d prior to the loss of inten ded function. Obse rved condi tions that have the potential for impact ing an intended function are evaluated or cor rected in accordance with the corrective action process.
The Fire W ater System Program is described in Appendix B.
The project team rev iewed th e Applica nt's Fire Water System Program (A MP B.1.20) against the recommendations i n GALL AM P XI.M36. The applicant w as asked to cla rify the frequency of the inspections to be performed und er OCGS AMP B.1.20; wh en the inspe ctions wi ll be in itiated;and ho w in specti ons of i nsula ted co mponen ts and inac cessi ble c ompone nts w ill be per formed. The applican t stated that the external su rfaces of the spray a nd sprinkler sy stems in the sc ope of license rene wal are visuall y inspecte d every 12 months. The co ndenser bay sprinkler sy stem is located in a high rad iation area and is i nspected ev ery 24 months. Fire hy drant external surfaces are v isual ly i nspect ed ev ery 6 months. Some of the i nspect ions are on going; h owev er, the enhanced inspections for license re newal w ill be i nitiated pri or to the peri od of extended operation. The applicant further stated that none of the components i n the scope o f these inspections are insulated. W ith regard to inaccessible locations, t he applicant stated that NFPA 25 (national fire protection association standard 25 for i nspection, testi ng, and maintenan ce of water-based fire protection sy stems) allow s an excep tion from inspecti on for pipe in concealed spaces or other inaccessibl e areas. M ost of the components included in the scop e of these inspect ions are a ccessib le, and th ere is suf ficien t access ible piping to provide a repres entati ve assessment of the de gree of external surface degradation.
The project team rev iewed th e applicant' s response an d determined th at it is acc eptable sin ce it is co nsistent w ith the recommendations i n GALL AM P XI.M36.The project team determi ned that OCGS AM P B.1.20 inc luded ins pections that will detect loss o f material due to general corrosi on that are con sistent wi th the recommendati ons in the external surfaces monitoring pro gram in the GALL R eport (AMP XI.M36). The pro ject team determined that this AM P will adequately manage loss of materia l due to genera l corrosion for external surfaces of steel piping, piping components, and piping elements exposed to an indoor air external o r outdoor air external e nvironment for w ater-based fire prote ction syste ms.In the OCGS LR A, Sec tion 3.3.2.2.6, the appli cant st ated th at Oys ter Cre ek wi ll i mpleme nt a periodic i nspection of v entilation systems program, B.2
.4, to inspect the internal and externa l surfaces of steel pi ping, piping co mponents, pipi ng elements, and ventilati on equipment ex posed to an indoo r air interna l or extern al envi ronment, or an ou tdoor air ex ternal env ironment in th e 480V s witc hgear ro om ven tilat ion s ystem, batter y and MG se t room v entil ation syste m, radw aste area heating and ventilation system and reactor building ventilation system. The program will inspect inte rnal and ex ternal steel surfaces of ventil ation syste m components to i dentify and assess aging effects that may be occurring.
The program wil l includ e surface inspec tions of steel compon ents for indi catio ns of lo ss of mat erial , such as rust , corro sion, and p ittin g. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is appropriate to inspect the i nternal and external su rfaces of steel pipi ng, piping compone
: nts, 389 piping eleme nts, and ven tilation e quipment expos ed to an in door air in ternal or ex ternal envi ronmen t, or an outdo or air exte rnal e nvir onment. The te chnic al ev aluat ion o f this p rogram to determi ne its adequa cy w as per formed by NRR/D E staff, an d is a ddress ed in the SE R rela ted to the Oy ster Cr eek pla nt.In the OCGS LR A, Sec tion 3.3.2.2.6, the appli cant st ated th at Oys ter Cre ek wi ll i mpleme nt a structures monitori ng program, B.1.31, to i nspect the ex ternal surfaces of stee l piping, pi ping components, and piping element s in an indoor air external or outdoor air external environment in the chlor ination s ystem, circulat ing water system, containm ent iner ting sys tem, c ontrol r od drive syste m, dry wel l floo r and e quipmen t drai ns, eme rgency dies el gen erator and au xil iary syste m, emergenc y ser vice wate r syst em, fire protec tion s ystem (dikes only), hard ened v ent sy stem, instrument (control) air system, ma in fuel oil storage & transfer sy stem, miscellan eous floor and equipment drain system, nitrogen supply sy stem, primary co ntainment, proces s sampling system, reactor b uilding cl osed cooli ng water sy stem, reactor buil ding floor and e quipment drains, reactor building v entilation system, reactor head cooli ng system, reactor re circulation syste m, react or wa ter cl eanup syste m, roof dr ains and ov erboar d dis charge, sanit ary w aste system, servi ce water sy stem, shutdown cooling sy stem, spent fuel poo l coolin g system, standby liquid contro l system (l iquid poiso n system), turbi ne buildi ng closed cool ing water sy stem, and water treatment & distribution system. The structures m onitoring progra m relies on periodic vis ual ins pect ion s by qual ifie d in div idu als to i dent ify and eva lua te th e de grada tion of pi pin g, pipi ng compo nents, and p ipin g eleme nts to ensure that th ere is no lo ss of in tended functio n. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team rev iewed th e applica nt's Structures Monitori ng Program (AMP B
.1.31) against the recommendation s in GALL A MP XI.M3 6. The appli cant was a sked to clarify when the inspections to be performed und er OCGS AMP B.1.31 wi ll be in itiated; and how ins pections of inaccessibl e components w ill be p erformed. The appli cant stated that s ome of the inspec tions are ongoing; how ever, the en hanced insp ections for lic ense renew al wil l be ini tiated prior to the period of exte nded operatio
: n. The appli cant further stated that inaccessibl e components w ill not be routi nely inspec ted. Th ere are s uff icient ac cessible compone nts to pr ovide a repr esenta tive assessment of the de gree of external surface degradation.
Degraded condi tions identi fied as a result of these i nspections w ill be e valuated using the Oyste r Creek correctiv e actions pro cess, which w ill ev aluate ex tent of condition includi ng consideratio n of inaccessi ble locati ons. The project team reviewed the applicant's response and det ermined that it is acceptable since it is consistent w ith the recommend ations in GALL AMP XI.M36.The project team determi ned that OCGS AM P B.1.31 inc luded ins pections that will detect loss o f material due to general corrosi on that are con sistent wi th the recommendati ons in the external surfaces monitoring pro gram in the GALL R eport (AMP XI.M36). The pro ject team determined that this AM P will adequately manage loss of materia l due to genera l corrosion for external surfaces of steel pi ping, piping co mponents, and pi ping elements i n an indoo r air extern al or outdoo r air e xtern al en viro nment i n the c hlori natio n sys tem, ci rcula ting w ater sy stem, containment in erting system, con trol rod driv e system, dry well floo r and equipment d rains, emergenc y di esel generat or and auxi liary syste m, emerge ncy s ervi ce wa ter sy stem, fir e protection sy stem (dikes only
), hardened v ent system, in strument (control) a ir system, mai n fuel oil storage & transfe r system, miscellaneous floor and equipment drain system, nitr ogen supply system, primary containment, pro cess samplin g system, reactor bu ilding clo sed coolin g water system, reactor b uilding floor and equipment dra ins, reactor bu ilding v entilation system, reactor head cooli ng system, reactor re circulation system, reactor water clea nup system, roo f drains and overb oard d ischa rge, san itary wast e sys tem, ser vice wate r syst em, shu tdow n cool ing sy stem, 390 spent fuel pool cooling sy stem, standby l iquid control system (li quid poison system), turbine buil ding cl osed c ooli ng wat er sy stem, an d  wa ter trea tment & distr ibuti on sy stem.In the OCGS LRA , Section 3.3.2
.2.6, the appli cant stated that a t Oyster Creek, the aging effect of loss of material due to general corrosion in the primary containment atmosp here is not considered a credible aging effect for carbon steel c omponents in a containment n itrogen envi ronmen t beca use of n egligi ble a mounts of free ox ygen (less t han 4 percen t by v olume durin g normal opera tion). Both oxy gen and moistu re must be pre sent for general corros ion to occur because oxygen al one or wa ter free of dissolv ed oxygen (high humidi ty in a n itrogen atmosphere) does not corrode carb on steel to a ny practica l extent.
Therefore, there is no loss of material for carbon steel compone nts exposed to a contain ment nitrogen env ironment becaus e, with the negligible a mounts of free oxy gen, anodic rea ctions do no t take place and the corrosion cell does not form.The pro ject tea m revi ewed the ap plic ant's further eval uatio n rela ted to loss o f materia l due to general corrosio n in the pri mary contain ment atmosphere for carbo n steel compon ents and concurred w ith the appl icant's con clusion tha t this is no t a credible aging effect. The Oyster Creek containment is inerted d uring normal ope ration; therefore, there are negligibl e amounts of free ox ygen p resent. Sin ce ox ygen a nd moi sture mu st be p resent for gener al co rrosio n to occur, general corros ion o f carbon steel compon ents i s not a credi ble e vent.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material of steel piping, bolti ng, and component external su rfaces exposed to air-indoo r uncontrolled (external), air-outdoor (ex ternal), or cond ensation (ex ternal) due to general corrosion.
3.3.2.1.11 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion In the OCGS LRA , Section 3.3.2
.2.8.2, the appl icant provi ded its further ev aluation for l oss of materi al in the i nterna l surfac es of ste el v entil ation syste m expo sed to conde nsati on due to general, pitting, crevice, and MIC, in accordance with the draft January 2005 SRP-LR.
In review ing this further ev aluation, the project team recogni zed that the approved September 2005 GA LL Rep ort rec ommende d agin g manageme nt progr am XI.M 38, ?Inspection of Intern al Surfaces in M iscellane ous Pipin g and Ducting Co mponents" to manage th is aging effect with no further evaluati on required. Therefore, th e project team rev iewed th e applica nt's further eval uatio n agai nst the recomme ndati ons i n GALL AMP XI.M3 8 to man age thi s aging effect.In the OCGS LRA, the applicant state d that at Oyster Creek, ventilation system components in the scope of li cense renew al are not su bject to internal condensatio
: n. A revi ew of the maintenance hi story of these co mponents has no t identified d egradation due to the presence of interna l condens ation. Preventive m aintena nce acti vities and s ystem m anager walkdowns ha ve not identified or reported i nternal conde nsation or res ulting interna l ventil ation syste m degradation in these componen ts. Therefore, the intern al envi ronment for ventil ation syste m components in the scope of li cense renew al does no t include condensation. This appli es to the follow ing v entil ation syste ms:  ?C" battery roo m heating and v entilation system, 480V switchgear room ventil ation syste m, 4160V sw itchgear room ve ntilation system, battery and MG se t room venti latio n sys tem, con trol ro om HVA C sys tem, rad waste area h eatin g and v entil ation syste m, and re actor b uild ing v entil ation syste m.
391 In the OCGS LRA, the applicant f urther stated that Oyster Creek will implement a Periodic Insp ecti on P rogra m, B.2.5, to ma nage the los s of ma teri al i n no n-v enti lati on s yst em st eel pip ing, piping compone nts, and pipi ng elements ex posed to a co ndensation i nternal env ironment in th e containment in erting system an d the emergency diesel genera tor and aux iliary system. The Periodic In spection Program i ncludes peri odic condi tion monitori ng examinati ons to assure that existing en vironmental conditions are not resul ting in material degradation tha t could resul t in the loss of system i ntended functions. Observed co nditions tha t have the potential for i mpacting an intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.The project team reviewed the applicant's further evaluation and determined that the Periodic Inspection Pro gram (AMP B.2.5) is a pla nt specific program tha t is appropri ate to manage the loss o f materia l in non-v entil ation syste m steel pipi ng, pip ing com ponen ts, and pipi ng ele ments expo sed to a con densa tion i nterna l env ironme nt. The techn ical eval uatio n of thi s progra m to determi ne its adequa cy w as per formed by NRR/D E staff, an d is a ddress ed in the SE R rela ted to the Oy ster Cr eek pla nt.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of materi al in the i nterna l surfac es of ste el v entil ation syste m expo sed to conde nsati on due to general, pitting, crevice, and MIC.
3.3.2.1.12 Reduction o f Heat Transfer Due to Fo uling In the OCGS LRA , Table 3.3.2.1.13 for the emergency di esel generator a nd auxil iary sy stem incl udes A MR l ine i tems for t he lu be oi l coo ler an d radi ator he at ex changer s exp osed t o closed-cycl e cooling w ater. The project tea m noted that the aging effect for reduction of heat transfer due to fouli ng is not addre ssed. The appl icant was asked to clari fy why this aging effect was not i dentified for these components.
In Attachment 7, Item A P-80 of its recon ciliatio n document, the a pplicant sta ted that the emergency dies el generator and auxili ary system brass lube o il coole r and radiato r tubes exposed to a closed co oling wate r environmen t do not incl ude the reducti on of heat transfer aging effect based on i ndustry stand ards. In these standards, foulin g is not iden tified as a signifi cant a ging effect for copp er all oy he at ex changer s in a close d cool ing w ater en viro nment. Addition of this line item to the emerg ency diesel generator and auxiliary system AMR is required.In its letter dated April 17,2006 (ML061150320), the applicant committed to revise Table 3.3.2.1.13 in th e OCGS LRA for the emergency dies el generator and auxili ary system to address the aging effect for reduction o f heat transfer due to foul ing for the brass l ube oil c ooler and radia tor tub es ex posed to a c losed cool ing w ater en viro nment b y cre ditin g the OC GS close d-cyc le co olin g wate r progra m (AM P B.1.14). This is A udit Commitment 3.3.2.1.1 2-1.The project team rev iewed th e applica nt's commitment an d determined th at the additi on of line items to address reduction of he at transfer due to foul ing using the cl osed-cycle cooling w ater program (AMP B.1.14) is consisten t with the recommendations in the GALL Report , and is acceptable.
Conclusio n The project team has evaluated the appli cant's claim o f consistency with the GALL Report. The project team also has revi ewed the above commitmen ts and information pertaining to the 392 applicant's consideratio n of recent operati ng experienc e and proposa ls for managing associ ated aging effects. On the basis of its revie w, the projec t team found that the AMR resu lts, whic h the applicant c laimed to be consistent w ith the GALL R eport, are consi stent with the AMRs in the GALL R eport.3.3.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In OCGS LRA Se ction 3.3.2.2, th e applica nt provide d further evalu ation of aging management as recommended by the GALL Rep ort for the
?C" battery roo m heating & v entilation , 4160 V switchgear roo m ventilati on, 480 V sw itchgear room ve ntilation, battery and MG set room venti latio n, chl orina tion s ystem, circu latin g wate r syst em, con tainme nt ine rting sy stem, containment v acuum breakers, control rod drive system, control room HVAC, d rywell floor and equipment drains , emergency die sel generator an d auxil iary sy stem, emergency serv ice water syste m, fire p rotecti on sy stem, fue l stor age and handl ing equi pment, h ardene d ven t syst em, heating & process steam system , hydrogen & oxygen monitoring system, instrument (contro l) air system, main fuel oil storag e & transfer system, miscellaneous floor and equipmen t drain system, nitrogen supply sy stem, noble metal s monitoring sy stem, post-acciden t sampling system, process sampling sys tem, radiation monitoring sys tem, radwaste a rea heating and ventilati on system, reac tor buildi ng closed cool ing water sy stem, reactor buil ding floor and equipment drains , reactor buil ding ventil ation syste m, reactor water cleanup sy stem, roof drains and overbo ard discharge, sa nitary w aste system, serv ice water system, shutdow n cooling syste m, spen t fuel p ool c ooli ng sys tem, sta ndby liqui d cont rol sy stem (l iquid pois on sy stem), traveling i n-core probe sy stem, turbine bui lding close d cooling w ater system, and water treatment & distri bution sy stem components an d component groups.
The applica nt also provided information concern ing how i t will manage the relate d aging effects.
Project Team Eval uation For some AM R line-ite ms assigned to the project team in Table 3.3.1 of the OC GS LRA, the GALL Report reco mmends further eval uation. When further evalua tion was recommended, the project team revi ewed these further evalua tions provi ded in OCGS L RA Section 3.3.2.2 against the criteria p rovided i n the SRP-LR Section 3.3
.2.2. The project tea m's assessment o f these evaluati ons is docu mented in thi s section. Thes e assessments are applicab le to each Table 2 AMR li ne-item in Se ction 3.3 ci ting the item in Table 1.3.3.2.2.1 Cumu lati ve F atig ue D amage In LRA Secti on 3.3.2.2.1, the ap plic ant sta ted tha t fatigue is a TLAA, a s defin ed in 10 CF R 54.3. Appli cants m ust ev aluat e TLAAs in ac cordan ce wi th 10 C FR 54.21(c)(1).The project team noted that the OCGS LR A contains n umerous AMR line ite ms with reference s to TLAAs. All but a few ci te cumulativ e fatigue damage as the aging effect requiring management, howev er it is no t clear wh ether a CLB fatigue analysi s actually exists or whether the TLAA is a ddressed by the assumed 7,0 00 cycles in accordan ce with B31.1 or equiv alent design methods. The applicant was asked to identify the applicable disposition for each T LAA line item re lated to cumul ative fatigue d amage of mechanical components.
393 In its response, the applicant stat ed that there are two categor ies of fatigue TLAAs identified in the AMR tables. The first categ ory is for components f or which an explicit fatigue analysis exists, such as one performed i n accordance with AS ME Secti on III, Class 1 rules (or equivalent), with an associated Cumulative Usage Factor (CUF) value. The second category is for components that were designed in accordance with implicit fatigue design rules from ANSI B31.1 (or equiv alent). The app licant prov ided a tabl e that identi fies whether a system or compon ent ha s an e xpli cit (E) or im plic it (I) fa tigue a naly sis as socia ted w ith i t.The app lica nt furthe r state d that, for li cense renew al, ad ditio nal e xpli cit fati gue ana lyse s wer e prepared to consider the ef fects of environm ental fatigue f or the components identif ied in NUREG/CR-6260. These com ponents are denoted in the table as also having an explicit environmenta l (E-env) fati gue analysi s in addi tion to the o riginal anal ysis. The c omponents within each system b ounded by the appli cable env ironmental fatigue analysi s are also d enoted with a (E-env) in th e table.The applican t further stated that the table als o include s a column d enoting the di sposition method used t o manage the TLA A for the perio d of ex tended opera tion. The no tation (I)indicates th e existi ng analysi s was dete rmined to remain valid for the period of ex tended operation. The notation (ii) indicates the analy sis was revised to become val id for the perio d of extended o peration. The n otation (ii i) indica tes fatigue monitorin g will be used to as sure the fatigue analysi s will remain val id during the period of exte nded operatio n or wil l be reanal yzed as necess ary p rior to exce eding the de sign l imit.The project team rev iewed th e applica nt's response, along with the table th at identifies whether the TLA As are impli cit or expl icit, and fou nd it accept able since it cl arifie s whi ch TLAA s are based on an explici t calculati on.The evaluation of the TLAAs was perf ormed by NRR/DE staff and is addres sed separately in Section 4 of the SER related to the OCG S LRA.3.3.2.2.2 Reduction o f Heat Transfer Due to Fo uling The applican t addressed red uction of heat tran sfer due to fouling i n Attachment 3, Item AP-62 of its reconcil iation docu ment. Therefore, the project team review ed that eva luation agai nst the criteria in SRP-LR Secti on 3.3.2.2.2.
SRP-LR Secti on 3.3.2.2.2 stated that reduction of heat transfer due to fouling could occur for stainless ste el heat ex changer tubes ex posed to treated water. The e xisting program re lies on control of wa ter chemistry to manage reduction of heat transfer due to fouling. How ever, control of water chemis try may hav e been ina dequate. Therefore, the GAL L Report recommend s that the effectiveness o f the water chemi stry control program should be verified to ensure that reduction of heat tra nsfer due to fouling is not occurring. A one-time inspect ion is an acceptable method to ensure that red uction of heat transf er is not occurring and that the com ponent's intended functio n will be maintain ed during the p eriod of exten ded operation
.In Attachment 3, i tem AP-62 of its re conciliati on document, the applicant s tated that the SR P-LR line item for sta inless stee l heat ex changer tubes in treated wate r, addressing redu ction of heat transfer due to fouli ng, recommended the Water Chemistry Program with no further eval uation required in Ja nuary 2005 , and has bee n changed in September 2005 to recommend both the wate r chemi stry a nd one-time i nspect ion p rograms, with an ev aluat ion o f aging effec ts. Ther e are 2 instanc es of this li ne item bein g used in the LRA that are a pplicabl e to the treated water 394 side of heat ex changer components in the reactor building cl osed cooli ng water sy stem (RBCC W).The applican t further stated that, i n the Oyster C reek LRA, there are 229 line item instance s of one-time insp ection of stainl ess steel comp onents in a treated water environment.
While these instances are applied to aging ef fects of loss of material or cracking , they provide ample inspection opportunity for the condition of the components.
Observed cond itions that h ave the potential for impacting an intended function are evaluated and correct ed, as necessary, in accordance w ith the correcti ve action process. Si nce one of the functi ons of the Water Chemistry P rogram is to prev ent reduction of heat transfer due to fouling, a noted foul ing condition o n any of the i nspected items would b e identified and entered i nto the correcti ve action proces s. Thus , there is hi gh confi dence that a ny i nstanc e of the Water Chemi stry P rogram's failur e to pr even t fouli ng wou ld be iden tified durin g the i nspect ions for loss of materi al du e to corrosion and cracking. In addi tion, for the shutdo wn cool ing system hea t exchangers i nvoking this line item, the treated water env ironment is re actor coolant.
The Water Chemistry Program requir ement s for r eactor quality wat er provide added ass urance that an en vironmen t conduc ive to foul ing do es not exi st. The appli cant co nclud ed tha t there is no change requir ed to t he OCGS LRA d ue to t his i tem.The project team reviewed the applicants reconciliation document, as well as Table 3.3.2.1.29 in the OCGS LRA for the reactor buil ding closed cooling w ater system. The project team noted that the one-time inspection is cited to manage loss of materia l for the stainl ess steel he at exchanger compo nents expos ed to treated w ater in this system; therefore, al though the one-time insp ection is n ot noted for the AM R that addresse s the reductio n of heat transfer aging effect, it is credited as part of the agin g management for loss of materia
: l. On this b asis, the project team determin ed that the app licant is adequately man aging reduction o f heat transfer due to fouling for stai nless steel heat exch anger components ex posed to treated water in the RBCCW system, and no change is required to the OCGS LRA.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.2 for further ev aluation.3.3.2.2.3 Cracking Due to S tress Corrosion Cracking 3.3.2.2.3.1 Cracking Due to S tress Corrosion Cracking [Item 1]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.3.1 agai nst the criteri a in SRP-L R Section 3.3.2.2
.3.1.SRP-LR Secti on 3.3.2.2.3.1 state d that cracking due to SCC coul d occur in th e stainless steel piping, pipi ng components, and piping eleme nts of the BWR standby li quid control sy stem that are exposed to sodium pe ntaborate solu tion greater than 60/C (>140/F). The exi sting aging management program relie s on monitori ng and control of water chemis try to manage the aging effects of cracking due to SCC. Howev er, high concentra tions of impuriti es at crevi ces and locat ions of stagna nt flow condi tions coul d caus e SCC. There fore, the GALL R eport recomme nds th at the effectiv eness of the w ater ch emistry contro l progr am shou ld be veri fied to ensure that SCC is not occurring.
A one-time inspection of select compon ents at susceptible locations is an acceptable method to ensure tha t SCC is not occurring and that the comp onent's intended functio n will be maintain ed during the p eriod of exten ded operation
.
395 In th e OCG S LR A Se ctio n 3.3.2.2.3.1 , the app lic ant a ddre ssed crac king of sta inl ess stee l pi pin g, pipi ng compo nents, and p ipin g eleme nts du e to SC C in t he BWR stand by l iquid contro l sy stem. The OCGS LRA s tated t hat Oy ster Cr eek wi ll i mpleme nt a One-Time In specti on Pro gram, B.1.24 , for sus cepti ble l ocati ons to veri fy the effectiv eness of the Water Ch emistry Program , B.1.2, to manage stress corrosion cra cking of stainless s teel components exposed to a sodium pentaborate env ironment in th e standby liquid contro l system (l iquid poiso n system). The manageme nt of stre ss corr osion cracki ng of stan dby l iquid contro l sy stem (l iquid pois on sy stem)components ex posed to sodi um pentaborate rel ies on moni toring and control of liquid poi son tank makeu p wa ter che mistry. The ma keup w ater i s moni tored i n lie u of the sodi um pent aborat e solution si nce the sodi um pentaborate w ould mask most of the c hemistry para meters monitored by th e Water Chemi stry P rogram. Th e effecti vene ss of thi s appr oach i s ver ified by a one-ti me inspection of susceptible locations.
Observed cond itions that h ave the po tential for impac ting an intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill mitigat e cracki ng due to SCC. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging management p rogram includes inspections of the standby liquid con trol system to detec t cracking due to S CC as a mean s of verifyin g the effectiveness o f the Water Che mist ry P rogra m. Th e pro ject team con curr ed w ith the a ppl ica nt's app roac h to mana ge stress corros ion c racking of stand by l iquid contro l sy stem (l iquid pois on sy stem) co mponen ts exposed to sodium pentabo rate by rel ying on moni toring and control of liquid poi son tank makeup w ater ch emistry since the so dium p entabo rate w ould mask most of the c hemist ry parameters monitored by the Water Chemistry Program. The project team d etermined that these AMP s will adequately manage cracking due to SCC for stainl ess steel pi ping, piping compon ents, a nd pi ping e lement s in t he BWR stand by l iquid contro l sy stem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.3.1 for further ev aluation.3.3.2.2.3.2 Cracking Due to S tress Corrosion Cracking [Item 2]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.3.2 agai nst the criteri a in SRP-L R Section 3.3.2.2
.3.2.SRP-LR Secti on 3.3.2.2.3.2 state d that cracking due to SCC coul d occur in s tainless ste el and stainless cl ad steel hea t exchanger comp onents expo sed to treated w ater greater than 60
/C (>140/F). The GALL Rep ort recommends further ev aluation o f a plant-specific aging management program to ensure that these agin g effects are adequately managed.In the OCGS LRA Section 3.3
.2.2.3.2, the appl icant addresse d cracking of stainl ess steel an d stainless cl ad steel hea t exchanger comp onents due to SCC. The OCGS L RA stated that, at Oyster Creek, stai nless steel components in closed coo ling water systems are ex posed to a closed cy cle cooli ng water env ironment <140
/F and are no t susceptibl e to cracking due to stress corrosion crackin
: g. The reactor wa ter cleanup (R WCU) system non-regenerative heat exch anger sh ell s ide c ompone nts are carbo n stee l and are no t susce ptibl e to cr acking d ue to stress corrosion cracking. Reactor water clea nup system regen erative he at exchanger sta inless steel tube an d shell si de components, a nd non-regenerati ve heat ex changer stainle ss steel tube side componen ts are expos ed to a treated water env ironment >140
/F and are su scepti ble to cracking due to stres s corrosion cra cking. Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for sus cepti ble l ocati ons to veri fy the effectiv eness of the Water Ch emistry 396 Program, B.1.2, to manage s tress corrosion cracking of stainless steel RWCU heat exch anger components ex posed to a trea ted water en vironment >14 0/F. Obser ved condit ions that have the po tentia l for i mpacti ng an i ntende d functi on are eval uated or corr ected in ac cordan ce wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill mitigat e cracki ng due to SCC. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging management p rogram includes inspections of the reactor w ater cleanup system regenerativ e heat exc hanger stainle ss steel tube and shell side compone nts, and non-re generat ive heat e xcha nger sta inle ss stee l tube side compon ents to detec t cracki ng due to SCC as a mea ns of verifyi ng the effectiveness of the Water Chemistry Program. The projec t team determined th at these AM Ps wil l adequately manage cracking due to SCC for stainl ess steel heat e xcha nger com ponen ts in the rea ctor w ater cl eanup syste m.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.3.2 for further ev aluation.3.3.2.2.3.3 Cracking Due to S tress Corrosion Cracking [Item 3]
The applican t addressed the further evalua tion for cracking due to SCC of stain less steel diesel engine exha ust piping i n LRA Secti on 3.3.2.2.3.2, i n accordance with the draft January 20 05 SRP-LR. Therefore, th e project team rev iewed OC GS LRA Secti on 3.3.2.2.3.2 agai nst the criteria in SRP-LR Secti on 3.3.2.2.3.3.
SRP-LR Secti on 3.3.2.2.3.3 state d that cracking due to SCC coul d occur in s tainless ste el diesel engine exha ust piping, pi ping components, a nd piping el ements expose d to diesel exhaust.
The GALL R eport r ecommen ded furt her ev aluat ion o f a pla nt-spe cific a ging man agement program t o ensure that these aging effects are adequatel y managed.
In the OCGS LRA , Section 3.3.2
.2.3.2, the appl icant addresse d cracking of diesel engine exhaust pi ping due to S CC. The OCGS LR A stated that, for Oy ster Creek, Table 3.3
.1, item number 5 for stainl ess steel di esel engine exhaust pi ping, piping co mponents, and pi ping elements ex posed to die sel exha ust gases is no t used. Emergency diesel gene rator compon ents e xpos ed to d iesel exha ust gase s are c arbon steel and a re not suscep tible to crac king due to st ress corr osi on c racki ng.The project team rev iewed Tabl e 3.3.2.2.1.13 i n the OCGS LRA , which addresses aging management of the emergency diesel gene rator and aux iliary system, and co nfirmed that the diesel en gine exhaus t piping is identified as being constructe d of carbon and low al loy steel; not stainless steel. Theref ore, the project team concurred with the applicant's conclusion that this furth er ev alu atio n is not appl ica ble to Oy ster Cre ek.3.3.2.2.4 Cracking Due to S tress Corrosion Cracking and Cy clic Loadi ng 3.3.2.2.4.1 Cracking Due to S tress Corrosion Cracking and Cy clic Loadi ng [Item 1]
In Section 3
.3.2.2.4.3 of the OCGS LR A, the appli cant stated that c racking due to stress corrosion crackin g and cycli c loading of stai nless steel components ex posed to treated borated water is a pplicabl e to PWRs only. The proje ct team concurred with the applicant' s evalua tion that th is agi ng effect i s not a ppli cable since Oyste r Cree k is a B WR plant.
397 3.3.2.2.4.2 Cracking Due to S tress Corrosion Cracking and Cy clic Loadi ng [Item 2]
In Section 3
.3.2.2.4.3 of the OCGS LR A, the appli cant stated that c racking due to stress corrosion crackin g and cycli c loading of stai nless steel components ex posed to treated borated water is a pplicabl e to PWRs only. The proje ct team concurred with the applicant' s evalua tion that th is agi ng effect i s not a ppli cable since Oyste r Cree k is a B WR plant.3.3.2.2.4.3 Cracking Due to S tress Corrosion Cracking and Cy clic Loadi ng [Item 3]
In Section 3
.3.2.2.4.2 of the OCGS LR A, the appli cant stated that c racking due to stress corrosion crackin g and cycli c loading of stai nless steel components in the PWR chemical and volume con trol system i s applicab le to PWRs only. The project team concurre d with th e appli cant's eva luati on tha t this aging e ffect is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.3.3.2.2.4.4 Cracking Due to S tress Corrosion Cracking and Cy clic Loadi ng [Item 4]
The applican t addressed the further evalua tion for cracking due to SCC and cyclic l oading for high-st rength s teel c losur e bol ting i n Sect ion 3.3.2.2.4.1 of th e OCGS LRA, i n acco rdance wit h the draft January 2005 SRP-LR. Therefore, the project te am review ed OCGS LRA S ection 3.3.2.2.4.1 against the criteria i n SRP-LR S ection 3.3.2.2.4
.4. The project team n oted that Section 3.3.2.2
.4.4 was i nadvertently omitted from the Sep tember 2005 SR P-LR, Rev.
1, altho ugh it is refer enced in Tab le 3.3-1, li ne ite m 10, of t hat do cument.SRP-LR Secti on 3.3.2.2.4.4 state d that cracking due to SCC and cyclic l oading could occur for high-strength steel c losure bolti ng in auxi liary sy stems exposed to air w ith steam or w ater leakage. The GALL Report recommended the bolt ing integrity progra m be used to manage this aging effect, and that this AMP is to be augmented b y appropri ate inspecti on to detect cra cking if the bolts are not otherwi se replaced during maintenan ce.In the OCGS LRA , Section 3.3.2
.2.4.1, the appl icant addresse d cracking of high-strength stee l closure bol ting due to SC C and cyc lic load ing. The OCGS LRA stated that, at Oy ster Creek the only aux iliary system that con tains high-strength s teel closure bolting ex posed to air with steam or water l eakage is the con trol rod driv e system. The B olting Integrity Program, B.1.12, addres ses agi ng manage ment re quireme nts for th is AS ME C lass 1 high-s trength steel closu re bolti ng. Bol ting i ntegrit y mana gement fol low s publ ished EPRI guidel ines and ot her in dustry recommendations for mate rial sele ction and tes ting, inservi ce inspecti on (ISI), and pl ant surveill ance and mai ntenance practi ces. The exte nt and schedu le of the insp ections for the Class 1 high-strengt h stee l clo sure b oltin g in th e cont rol ro d driv e sys tem is in ac cordan ce wi th ASME S ection XI and a ssures that detec tion of leakage or fastene r degradation w ill occur prior to loss of sys tem or component i ntended function.
Observed con ditions that have the p otential for im pacting an intende d func tion are evaluated or corr ected in a ccorda nce with the correc tive action process
.The project team rev iewed th e applica nt's Bolti ng Integrity Program (AM P B.1.12) and verified that this aging mana gement program includ ed activi ties that w ill manage cra cking of high-strength steel c losure bolti ng due to SCC and cycli c loading. Thi s program includ es inservice inspection of high-strength bolti ng as part of the AS ME Secti on XI ISI requirements; therefore, the requirements for augmented inspecti on are met. The pro ject team determined that this AMP will adequately manage cracking of high-strengt h steel closure bolting due to SCC and cy clic loadi ng in t he con trol ro d driv e sys tem.
398 The project team found tha t, based on the program identified above, the applican t has met the criteria of SRP-LR Section 3.3.2.2.4.4 for further eva luation.3.3.2.2.5 Hardening and Loss of Strength Due to Elastomer De gradation 3.3.2.2.5.1 Hardening and Loss of Strength Due to Elastomer De gradation [Item 1]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.5.1 agai nst the criteri a in SRP-L R Section 3.3.2.2
.5.1.SRP-LR Secti on 3.3.2.2.5.1 state d that hardeni ng and loss o f strength due to ela stomer degrada tion c ould occur i n ela stomer s eals and co mponen ts of hea ting an d ven tilat ion s ystems exposed to air - indo or uncontroll ed (internal
/external).
The GALL Report re commended further eval uatio n of a p lant-s pecifi c aging manageme nt progr am to en sure th at thes e agin g effects a re adequately man aged.In the OCGS LRA Section 3.3
.2.2.5.1, the appl icant addresse d hardening an d loss of strength of elastomer seal s and componen ts due to ela stomer degradation.
The OCGS LRA state d that Oyster Creek w ill impl ement a period ic inspecti on of ventil ation syste ms program, B.2.4, for the internal an d external inspection of elastomer compon ents expose d to an ind oor air inte rnal or external e nvironment i n the ?C" battery roo m heating and v entilation system, 480V switchgear room ventilation system, battery and MG set room ventilation system , control room HVAC syste m, radw aste a rea he ating a nd ve ntila tion s ystem, and re actor b uild ing v entil ation syste m. Per io di c i nsp ect io ns a re p erfo rme d o n e la sto mer do or s eal s an d fl ex ib le con nec tio ns t o i den tif y detrimental cha nges in material properties, as evidenc ed by crackin g, perforations in th e material, or l eakage. Observed c onditions th at have the potential for impacting an i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is approp riate to ins pect th e inte rnal a nd ex ternal insp ectio n of el astomer compon ents e xpos ed to an in door a ir in ternal or ex ternal envi ronmen t. The t echni cal e valu ation of this program to determi ne its adequa cy w as per formed by NRC D E staff, an d is a ddress ed in the SE R rela ted to the Oy ster Cr eek pla nt.Oyster Creek w ill impl ement a structures mo nitoring program, B.1.31 , for the external inspections of expansion joint and flexible connection elastom ers exposed to an indoor air exter nal e nvir onment in the circu latin g wate r syst em, hea ting & proces s steam syste m, fire protection sy stem, process sampl ing system, cond ensate syste m, and condensa te transfer system. Oyster Creek utiliz es the structures monitoring program to i nspect the ex ternal surfaces of piping, pipi ng components, and piping eleme nts when th ere are no agin g management programs that specifica lly in spect the compon ent in questio
: n. The structures mon itoring program relies on periodic visual inspections by quali fied indiv iduals to identify and evaluate the degrada tion o f elasto mer comp onents to ens ure tha t there is no loss of inte nded fu nctio n. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team rev iewed th e applica nt's structures mon itoring program (B.1.31) and veri fied that this aging mana gement program includ ed external inspection s of expansi on joint and flexible connection e lastomers exp osed to an i ndoor air ex ternal env ironment. The proje ct team determined that these AMP s will adequately manage hardening a nd loss of strength o f
399 elastomer seal s and componen ts due to ela stomer degradation in elastomer components in the aforementioned aux iliary systems in th e circulati ng water sy stem, heating & pro cess steam syste m, fire p rotecti on sy stem, pr ocess sampli ng sys tem, con densa te sy stem, an d cond ensate transfer syste m.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.5.1 for further ev aluation.3.3.2.2.5.2 Hardening and Loss of Strength Due to Elastomer De gradation [Item 2]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.5.2 agai nst the criteri a in SRP-L R Section 3.3.2.2
.5.2.SRP-LR Secti on 3.3.2.2.5.2 state d that hardeni ng and loss o f strength due to ela stomer degradation coul d occur in e lastomer lin ings of the filters, v alves, an d ion ex changers in spe nt fuel po ol co olin g and cl eanup syste ms exp osed t o treat ed w ater. Th e GALL Repor t recommended that a plant-specific aging management program be e valuated to determine an d assess the qua lifie d life of the l inin gs in th e env ironme nt to e nsure that th ese agi ng effects are adequately man aged.In the OCGS LRA Section 3.3
.2.2.5.2, the appl icant addresse d hardening an d loss of strength of elastomer li nings of the filters, v alves, an d ion ex changers in spe nt fuel pool c ooling and c leanup systems due to elastomer degrada tion. The OCGS L RA stated that Oyster Creek w ill impl ement a Periodic Inspection Program , B.2.5, for the internal inspection of expansion joint and flexible conne ction elas tomers e xpos ed to a treate d wa ter in ternal envi ronmen t in th e cond ensate system, conden sate transfer system, h eating & proces s steam system, a nd process samp ling system. Oyster Creek utiliz es the Perio dic Inspecti on Program to peri odically monitor component aging ef fects when the component is not covered by other existing periodic mon ito rin g pr ogr ams. Th e P eri odi c In spe cti on Pro gra m re li es o n p eri odi c i nsp ect io ns t o i den tif y and eval uate the intern al degradation of elastomer compon ents expose d to a treated w ater internal en vironment to ensure that there is no lo ss of intended functi on. Observed conditions that have the potential for impact ing an intended function are evaluated or cor rected in accordance w ith the correcti ve action process.The project team reviewed the applicant's further evaluation and determined that the Periodic Insp ecti on P rogra m (AM P B.2.5) is a pla nt sp eci fic p rogra m tha t is app ropr iate to ma nage hardening and loss of stre ngth of elastom er linings of the filter s, valves, and ion exchangers in spent fuel pool cooling and cleanup sy stems due to el astomer degradation.
The technical evaluation of this program to determine its adequacy was perfor med by NRC DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.The project team found tha t, based on the program identified above, the applican t has met the criteria of SRP-LR Section 3.3.2.2.5.2 for further eva luation.3.3.2.2.6 Reduction o f Neutron-Absorbin g Capacity and Loss of M aterial Due to General Corrosion The app lica nt add ressed reduc tion o f neutro n-abso rbing c apaci ty an d los s of mate rial due to general corrosio n in the ne utron absorbin g sheets of the spent fuel storage racks in LRA Sectio n 3.3.2.2.14, in a ccordance w ith the draft Janua ry 2005 SR P-LR. Therefore, the p roject team review ed OCGS LRA S ection 3.3.2.2.1 4 against the cri teria in SR P-LR Section 3.3.2.2.6.
400 SRP-LR Secti on 3.3.2.2.6 stated that reduction of neutron-absorbi ng capacity and loss of material due to general corrosi on could o ccur in the n eutron-absorbin g sheets of BWR spent fuel sto rag e ra cks ex pos ed to t rea ted wa ter. Th e GA LL Rep ort rec omm end ed furt her ev al uat io n o f a plant-specific aging management prog ram to ensure that these aging eff ects are adequately managed.In the OCGS LRA Section 3.3
.2.2.14, the appl icant addresse d neutron-absorb ing capacity and loss of material of the neutron-abso rbing sheets of BWR spent fuel storage racks due to general corrosion. The OC GS LRA stated that, at Oyster C reek, the aging effects of the Boral spent fuel storage racks expos ed to a treated water env ironment are i nsignificant and require no agin g manageme nt. The poten tial aging effec ts resu lting from sust ained irrad iatio n of Bor al w ere previously evaluated by the staff (BNL-NUREG-2558 2, dated January 1979; NUREG-1787, VC Summer SER, para graph 3.5.2.4.2) and determined to b e insignifican
: t. Oyster Creek i nstalled four (4) spent fuel stora ge racks, manufactured by HOLTEC Internation al, that util ized Bora l neutron absorbi ng material, in the year 20
: 00. The Boral coupons kept i nside the sp ent fuel storage pool were remov ed and insp ected in 20 02, an d agai n in 2 004. I nspect ion re sults showed no blisters, pi ts, dimensiona l changes, or oth er age related d egradations. Ne utron transmission tests on the irr adiated coupon showed that the average Boron-10 ar eal density in the irradiated coupon is 0.0209 grams/cm 2 , which mea ns that , within the experime ntal acc uracy, no Boron-10 h as been lo st from the coupons.
Plant operati ng experienc e is therefore con sistent with the staff's previous con clusion, an d an aging management program is not require d.The project team rev iewed H oltec Internati onal Report No. HI-2043279 , "Summary Repo rt of the Exami natio n of Oys ter Cre ek Nucl ear Sta tion B oral S urvei llan ce Cou pon No. HO910 070-2-6," 10/19/04, w hich concl uded t hat the coupo n teste d show ed no blis ters, p its, o r other degrad ation. Neutro n trans missi on tes ts on t he irr adiat ed cou pon sh owed the av erage B oron-1 0 area l den sity is 0.0209 grams/cm 2 , whi ch mean s that Boron-10 has not be en lo st from th e coup on. In addition, the project team rev iewed H oltec Internati onal Report No. HI-2033000 , "Examinati on of Oyster Creek Nucl ear Station B oral Surve illance Coupon No.
HO920023-2-6," Re vision 1, 04/08/03, w hich concl uded t hat the coupo n teste d show ed no blis ters, p its, o r other degrad ation. Neutro n trans missi on tes ts on t he irr adiat ed cou pon sh owed the av erage B oron-1 0 area l den sity is 0.0194 grams/cm2, w hich means B oron-10 has no t been lost from the coupon. Ba sed on these reports, the project team determin ed that the resu lts of the Boral coupon tests support the applicant' s conclusi on that the agin g effects of the Boral spent fuel storage racks ex posed to a treated wate r env ironme nt are insi gnifica nt and requir e no a ging man agement.The project team found tha t, based on the information dis cussed abov e, the appli cant has met the criteria o f SRP-LR Secti on 3.3.2.2.6 for further ev aluation.3.3.2.2.7 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion 3.3.2.2.7.1 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 1]The applican t addressed l oss of material d ue to general, p itting, and crev ice corrosio n for components exposed to lubricating oil in OCGS LRA Sections 3.
3.2.2.7.1 and 3.3.2.
2.7.3, in accord ance w ith th e draft J anuary 2005 SRP-L R. Ther efore, th e proje ct team revi ewed OCGS LRA Sectio ns 3.3.2.2.7.1 an d 3.3.2.2.7.3 again st the criteria in SRP-LR Section 3.3
.2.2.7.1.SRP-LR Secti on 3.3.2.2.7.1 state d that loss o f material due to general, pittin g, and crevic e corrosion cou ld occur in steel pip ing, piping comp onents, and pi ping elements, i ncluding the tubin g, val ves, and ta nks in the rea ctor co olant pump o il co llec tion s ystem, expo sed to 401 lubricating o il (as part of the fire protection system). The ex isting aging management program relies on the periodic sampling and analysis of lubricating oil to maint ain contaminants within acceptable l imits, thereby preservin g an environ ment that is not conducive to corrosion.
Howeve r, control of lub e oil con taminants may not alwa ys have been adequate to preclude corrosion. Therefore, th e effectiveness of l ubricating oi l control sh ould be v erified to ensu re that corros ion i s not o ccurri ng. The G ALL R eport r ecommen ded furt her ev aluat ion o f programs to manage c orrosi on to v erify the effect iven ess of th e lub ricati ng oil program. A one-time inspe ction of sele cted co mponen ts at su scepti ble l ocati ons i s an a ccepta ble me thod to ensur e that corrosion is not occurri ng and that the c omponent's i ntended function will be maintaine d during the peri od of extended operation.
In add ition , the S RP-LR stated that c orrosi on may occur at loc ation s in t he rea ctor co olant pump oil coll ection tank w here water from wash dow ns may accumu late. Therefore, the e ffectiveness of the p rogram sh ould be ve rified to ens ure tha t corro sion is no t occur ring. Th e GALL Repor t reco mmen ded furth er ev alu atio n of p rogra ms to mana ge lo ss o f mate rial due to ge nera l, p itti ng, and cr evic e corro sion, to in clude determ inin g the th icknes s of the low er port ion o f the tan k. A one-time insp ection is a n acceptable method to ensure that corrosion is not occu rring and that the component's intended functi on wil l be maintai ned during the period of exte nded operatio n.In th e OCG S LR A Se ctio n 3.3.2.2.7.1 , the app lic ant a ddre ssed los s of ma teri al o f stee l pi pin g, piping compone nts, and pipi ng elements, inc luding the tub ing, valv es, and tanks in the reactor coola nt pump oil coll ectio n sys tem due to gene ral, p ittin g, and c revi ce corr osion . The OC GS LRA stated tha t Item numbers 3.3.1-13 and 3.3.1-14 (i n Table 3.3.1) a re not appli cable to Oy ster Creek. Appendi x R Secti on III.O does not a pply si nce the contai nment is ine rt during normal operation.
The project team recogni zed that the Oyster Creek con tainment is i nert during normal operation, which effectively eliminates the possibility of a fire. T herefore, the requirements of Appendix R, Section III.O to ha ve a reactor coolant pump oil coll ection sys tem do not appl
: y. The project team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.In th e OCG S LR A, S ecti on 3.3.2.2.7.3, t he a ppl ica nt ad dres sed los s of ma teri al fo r ste el p ipi ng, piping compone nts, piping el ements, ducting, cl osure boltin g and heat ex changer tubes ex posed to lubricati ng oil due to general, pitti ng, and crevi ce corrosion.
The applica nt stated that Oy ster Cre ek w il l i mpl eme nt a One-Ti me I nsp ect io n P rog ram , B.1.2 4, f or s usc ept ib le lo cat io ns t o v eri fy the effectiveness o f the lubricati ng oil monito ring activi ties program, B.2.2, to manage the loss of material in steel piping, piping component s, and piping elements exposed to lubricating oil intern al or exter nal e nvir onments in th e emerge ncy d iesel genera tor and auxi liary syste m, reactor recircul ation syste m, reactor water cleanup sy stem, reactor buil ding closed cooling w ater system, control rod drive system, fire protec tion system, mi scellaneou s floor and equip ment drain syste m, and servi ce water sy stem. The lubric ating oil mon itoring activ ities program manages phys ical and c hemica l prop erties of lub ricati ng oil by s ampli ng, testi ng, and trendi ng to identify spe cific wear mechanisms, conta mination, and oil degradati on that could affect intended functio ns. Obs erved condi tions that h ave t he pot entia l for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram(AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage t he lo ss of mat erial in st eel p ipin g, pipi ng compo nents, and p ipin g eleme nts ex posed to lubri catin g oil intern al or exter nal e nvir onments. The te chnic al ev aluat ion o f this p rogram to 402 determi ne its adequa cy w as per formed by NRC D E staff, an d is a ddress ed in the SE R rela ted to the Oy ster Cr eek pla nt.The project team found tha t, based on the information dis cussed abov e, the appli cant has met the criteria o f SRP-LR Secti on 3.3.2.2.7.1 for further ev aluation.3.3.2.2.7.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 2]The project team rev iewed OC GS LRA Secti on 3.3.2.2.7.2 agai nst the criteri a in SRP-L R Section 3.3.2.2
.7.2.SRP-LR Secti on 3.3.2.2.7.2 state d that loss o f material due to general, pittin g, and crevic e c o r r o s i o n c o u l d o c c u r i n s t e e l p i p i n g, p i p i n g c o m p o n e n t s , a n d p i p i n g e l e m e n t s i n t h e B WR reactor water cleanup and shutdown cooling sy stems exposed to treated w ater. The exi sting aging ma nagemen t progra m reli es on monito ring an d cont rol of r eactor wate r chemi stry t o manage the aging effects of loss of material from general, p itting and crev ice corrosio n.Howeve r, high concentrati ons of impuritie s at crevic es and loca tions of stagnant flow conditions could cause genera l, pi tting, o r crev ice co rrosio n. Ther efore, th e effecti vene ss of the chemi stry contro l progr am shou ld be veri fied to ensur e that corros ion i s not o ccurri ng. The G ALL R eport reco mmen ded furth er ev alu atio n of p rogra ms to mana ge lo ss o f mate rial from g ener al, pitt ing, and cr evic e corro sion to ve rify th e effecti vene ss of the Water Chemi stry P rogram. A one-ti me inspection of select componen ts at susceptib le locati ons is an a cceptable metho d to ensure tha t corrosion is not occurring an d that the compon ent's intend ed function w ill be mai ntained duri ng the period o f extended ope ration.In th e OCG S LR A, S ecti on 3.3.2.2.7.2, t he a ppl ica nt ad dres sed los s of ma teri al o f stee l pi pin g, piping compone nts, and pipi ng elements due to general, pitti ng, and crevi ce corrosion . The OCGS LRA stated that Oyster Cree k will i mplement a One-Time In spection Program, B
.1.24, for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in steel and al uminum pipi ng, piping compone nts, and pipi ng elements ex posed to a trea ted water en vironment i n the control rod drive system, post-acci dent sampling sys tem, process sampl ing system, reacto r head cooli ng system, reactor re circulation syste m, react or wa ter cl eanup syste m, shutd own cooli ng sys tem, spe nt fuel pool cool ing sy stem, standby l iquid control system (li quid poison system), wate r treatment & dis tribution sy stem, and in aluminu m fuel pool gates and fuel storage an d handlin g equipment and struc tures in the fuel storage and handl ing equipment sy stem exposed to a treated w ater enviro nment. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The OCGS LRA further sta ted that, whe n applied to steel AS ME Cla ss MC co mponents in a treated water environment and to steel ASME C lass 2 and 3 piping and components in a treated wa ter en vi ron men t, O ys ter Cre ek w il l u se A SM E S ect io n XI , Su bse cti on IWF, B.1.28, to ve rif y the effectiveness o f the Water Chemistry Program, B.1.2, to mi tigate loss of materi al. Observe d conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll mi tigate loss o f materia l due to general, pitting, and crevice corrosion. In addition, the project team reviewed the applicant's One-Tim e Ins pect ion Pr ogr am (B.1.24) a nd ASME Sect ion X I, Su bsec tion IW F pro gra m (AMP B.1.28), and veri fied th at thes e AM Ps in clude d ins pecti ons to detec t loss of materi al du e to 403 general, pittin g, and crevic e corrosion a s a means of ve rifying the effective ness of the Water Chemistry P rogram. The project team de termined that thes e AMPs will adequately man age loss of material due to general, pitti ng, and crevi ce corrosion for steel pipi ng, piping compone nts, and piping eleme nts in the co ntrol rod dri ve system, post-accident s ampling syste m, process sampling sys tem, reactor head c ooling sys tem, reactor recircul ation syste m, reactor water cleanup sy stem, shutdown cooling sy stem, spent fuel poo l coolin g system, standby liquid con trol system (liqui d poison sy stem), water treatmen t & distribu tion system, a nd in alu minum fuel pool gates and fuel storage and handli ng equipment and stru ctures in the fuel storage and ha ndling equipme nt sy stem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.7.2 for further ev aluation.3.3.2.2.7.3 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 3]The project team rev iewed OC GS LRA Secti on 3.3.2.2.7.3 agai nst the criteri a in SRP-L R Section 3.3.2.2
.7.3.SRP-LR Secti on 3.3.2.2.7.3 state d that loss o f material due to general (steel only) pi tting and crevice co rrosion coul d occur for steel and stainle ss steel di esel exh aust piping, p iping components, and piping eleme nts exposed to diesel exhaust.
The GALL Report re commended further evaluati on of a plant-sp ecific aging management p rogram to ensure that these aging effects are adequately managed.In the OCGS LRA Section 3.3
.2.2.7.3, the appl icant addresse d loss of materia l of steel and stainless ste el diesel exhaust p iping, pipi ng components, and piping eleme nts due to general (steel only) pitting and crevice corrosion. The O CGS LRA stated that Oyster Creek will implement a P eriodic Insp ection Program, B.2.5 , to manage the lo ss of material i n steel emergenc y di esel generat or ex haust pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to a diesel exhaust env ironment. The Pe riodic Inspe ction Program inc ludes perio dic conditi on monitoring examinations to assur e that existing environmental conditions are not res ulting in material degradati on that could result in the loss of sy stem intended functi ons. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team reviewed the applicant's further evaluation and determined that the Periodic Inspection Pro gram (AMP B.2.5) is a pla nt specific program tha t is appropri ate to manage the loss of material in steel piping, pipi ng components, and piping eleme nts exposed to lubricati ng oil i nterna l or e xtern al en viro nments. The te chnic al ev aluat ion o f this p rogram to determ ine i ts adequacy w as performed by N RC DE staff, and i s addressed i n the SER re lated to the Oyster Creek p lant.The project team found tha t, based on the program identified above, the applican t has met the criteria of SRP-LR Section 3.3.2.2.7.3 for further eva luation.3.3.2.2.8 Loss of Material Due to Gener al, Pitt ing, Cr evice, and Microbiolog ically-Influenced Corrosion (MIC)
The applican t addressed l oss of material d ue to general, p itting, crevi ce corrosion, and MIC for steel (wi th or w ithou t coati ng or w rappi ng) pip ing, pi ping co mponen ts, and pipi ng ele ments buried in soil in Section 3.3.2.2
.8.1 of the OCGS LRA , in accordan ce with the draft January 2005 404 SRP-LR. Therefore, th e project team rev iewed OC GS LRA Secti on 3.3.2.2.8.1 agai nst the criteria in SRP-LR Secti on 3.3.2.2.8.
SRP-LR Secti on 3.3.2.2.8 stated that loss of materi al due to gene ral, pitting, crev ice corrosio n, and MIC could occur for steel (wi th or with out coating or w rapping) pipi ng, piping compone nts, and pipin g elements burie d in soil. The buried p iping and tan ks inspection program relies on indus try pr actice , frequenc y of pi pe ex cava tion, and op eratin g expe rienc e to man age the effects of loss of material from general, pitting, an d crevice corrosion and MIC. The e ffectiveness of the buried piping and tanks inspection prog ram should be verified to evaluate an applicant's inspection frequency and ope rating experi ence wi th buried comp onents, ensuri ng that loss of mate rial is n ot oc curr ing.In th e OCG S LR A Se ctio n 3.3.2.2.8.1 , the app lic ant a ddre ssed los s of ma teri al o f stee l pi pin g, pipi ng compo nents, and p ipin g eleme nts du e to gen eral, pitti ng, crev ice co rrosio n, and MIC. The OCGS LRA s tated t hat Oy ster Cr eek wi ll i mpleme nt a Bu ried P ipin g Inspec tion P rogram, B.1.26 , to man age the loss of materi al in steel pipi ng, pip ing com ponen ts, and pipi ng ele ments exposed to soil in the service water sy stem, emergency serv ice water system, fire protecti on system, drywell floor and equipment drain system , miscellaneous floor and equipm ent drain system, spent fuel pool cool ing system, reacto r buildin g closed cool ing water sy stem, and roof drains and o verboard di scharge system. The Buried Pi ping Inspection Program includ es preventiv e measures to mi tigate corrosion and periodi c inspectio n to manage the effects of corrosion on the pressure-retai ning capacity of buried steel piping, pip ing components, an d piping eleme nts. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's Buried Piping Inspe ction Program (AM P B.1.26) and verified that this aging management p rogram included inspections to detect los s of material of steel pipi ng, piping compone nts, and pipi ng elements due to general, pitti ng, crevice co rrosion, and MI C. See Sect ion 3.0.3.2.21 of t his au dit r epor t fo r tea m's A MP B.1.26 re view.The applican t was asked to confirm that, for each o f the material/env ironment combin ations for which the Buried Pi ping Inspection Program wil l be credi ted, at least o ne inspecti on (opportunistic or focused) has b een, or wi ll be performed p rior to enterin g the extended period of operation, in addition to a focused ins pection w ithin the 1 0-year peri od after entering the ext ende d pe riod of op erat ion. In resp onse , the app lic ant s tate d the foll owi ng: a) Carbon stee l/soil - ECR 05-0034 4 is schedu led to repl ace underground carbon steel service w ater piping i n [refueling outage] 1R 21 (2006). Du ring this repl acement the service w ater piping w ill be e xcavated and inspe ctions of the ex ternal coatin g of the carbon steel service w ater piping w ill be c onducted.b) Cast iron/so il - Buri ed cast iron components in the scope of li cense renew al are va lves and fir e hyd rants i n the fi re prot ectio n sys tem. The se bur ied c ompone nts are coate d wi th coal tar and epox y coa ting i n the s ame fash ion a s the b uried carbo n stee l pip ing. A buried cast i ron fire hydran t was repl aced in 20
: 03. The hydra nt that was removed w as found to have seat degradation and plugged drai n holes, but there were no identified indication s of external surface or coating de gradation.
c) Stainless steel / soil - The stainless steel piping in the scope of this program is potentiall y used i n the heatin g and process ste am system. This system is i n scope for 10 CFR 54.4(a)(2) s patial in teraction onl
: y. Normall y, buried pipe is n ot in scope for (a)(2) 405 spati al in teracti on bec ause l eakage fro m a bur ied p ortion of pip e cann ot spra y ont o safety-related com ponents. However, this "buried" heating & proces s steam piping in scope is lo cated in the pipe vaul t. The p ipe v ault i s prima rily an ou tdoor a ir env ironme nt, but is conse rvativel y conside red buried b ecause it ca n accumulate d ebris. The Buri ed Piping Inspection Progra m includes an enhancement to inspect the piping inside this vault in conjunction with the preventativ e maintenance activity to inspect th e vault, a nd pump out accumul ated water e very 6 mo nths. This acti vity w ill be p erformed within the 10-ye ar peri od imme diate ly p rior to enteri ng the l icens e rene wal perio d. See Secti on 3.3 of program basis docu ment PBD-AM P-B.1.26, Burie d Piping Insp ection.d) Bron ze/so il - The bur ied b ronze compon ents i n the s cope o f this p rogram ar e thre aded fitti ngs < 2.5 inc hes, pote ntia lly use d in the roof d rain s an d ov erbo ard d isc harge syste m. These burie d fitti ngs are coated wit h coal tar an d epox y coa ting i n the s ame fashion as the b uried carbon steel pipi ng. These fittings are a ssociated w ith an unpres suriz ed dra in sy stem w hose fun ction is to drain wate r in th e eve nt of a fi re protection w ater system in itiation.
As such, the p ressure bounda ry integrity is not criti cal so long as the fitting does not b ecome blocked su ch that draina ge is preven ted. These fittings wil l not be spe cifica lly iden tified for ex cava tion a nd in specti on, as they are adequately a ddressed by the inspecti ons that hav e been or w ill be p erformed for the buried carbon steel pip ing external coating insp ection.e) Alu minu m/s oil - AR A2116 126 is sche duled to ins pect the c oati ngs on two underground alu minum condensa te transfer lines in 2006.Upon enterin g the period of ex tended operati on, focused insp ection of burie d piping and compon ents w ill be per formed w ithin ten y ears, u nless an op portun istic insp ectio n occu rs within this ten-yea r period. The i nspections w ill inc lude at le ast one carbon steel, one aluminum, and one cast iron pipe or co mponent. In add ition, for each of these materials, the location s selected for i nspection w ill inc lude at le ast one loca tion whe re the pipe or compon ent ha s not b een pr evio usly repla ced or re-coa ted, i f any s uch l ocati ons re main. The stainless steel pipi ng in the v ault wi ll contin ue to be peri odically inspected, a nd the bronze materi al is add ressed by th e buried carb on steel pi pe coating in spections, as described ab ove.The project team rev iewed th e applica nt's response and determined that, for each of the material/env ironment combin ations for wh ich the Buri ed Piping In spection Program w ill be credi ted, at leas t one i nspect ion (o pportu nisti c or focu sed) h as bee n, or w ill be per formed pr ior to entering the ex tended period of operation, i n addition to a focused i nspection w ithin the 1 0-year period after enteri ng the extende d period of ope ration that w ould prov ide objectiv e eviden ce that the component co atings were in acceptabl e condition and that no significant aging w as present for these buried compo nents. On this basis, the projec t team determined that the applicant's response w as acceptabl e.The p roje ct te am de termi ned that the Buri ed P ipi ng In spec tion  AM P w ill ade quate ly mana ge loss of material in steel piping, pipi ng components, and piping eleme nts exposed to soil i n the service w ater system, emergency service w ater system, fire pro tection sys tem, drywel l floor and equipment drain system, miscel laneous floor and equipment dra in system, sp ent fuel pool cooli ng sys tem, rea ctor bu ildi ng clos ed coo ling w ater sy stem, an d roof d rains and o verbo ard discharge sys tem, and loss o f material from the bottom o f outdoor steel tan ks supported by earthen foundation s in the fire p rotection sy stem 406 The O CGS LRA furth er st ated that Oys ter C reek wi ll i mple ment an a bov egrou nd o utdo or ta nks progr am, B.1.2 1, to mana ge th e lo ss o f mate rial from t he b otto m of o utdo or st eel tank s supp orte d by eart hen found atio ns i n the fire prot ecti on s yst em. T he a bov egrou nd o utdo or ta nks program provides for periodic i nternal UT in spections on the bottom of abov eground outdoor steel tanks supp orted by ea rthen foundations.
Observed con ditions that have the p otential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process. Oyster Creek do es not hav e any buri ed tanks wi thin the scop e of License Renewal.The project team rev iewed th e applica nt's abov eground outdoor ta nks program (AMP B
.1.21)and verified that this agin g management program inclu ded inspecti ons to manage the loss of materi al from t he bot tom of ou tdoor s teel t anks su pporte d by earthe n found ation s in t he fire protection sy stem. The project team d etermined that thi s AMP w ill adequate ly manage l oss of materi al from t he bot tom of ou tdoor s teel t anks su pporte d by earthe n found ation s in t he fire protection sy stem The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.8 for further ev aluation.3.3.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, M icrobiologi cally In fluenced Corrosion an d Fouling 3.3.2.2.9.1 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, M icrobiologi cally In fluenced Corrosion an d Fouling [Item1]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.9.1 agai nst the criteri a in SRP-L R Section 3.3.2.2
.9.1.SRP-LR Secti on 3.3.2.2.9.1 state d that loss o f material due to general, pittin g, crevice, M IC, and foulin g could occur for steel pipi ng, pip ing com ponen ts, pi ping e lement s, and tanks e xpos ed to fuel oil. The existing agi ng management program reli es on the fuel oil chemis try program for monitoring and c ontrol of fuel oil contamination to manage loss of material due to corrosion or fouling. Corrosi on or fouling may occur at loc ations wh ere contaminants accumulate. The effectiveness of the fuel oil chemi stry control should be verified to e nsure that corrosi on is not occurring. The GALL Report recommended further evalua tion of programs to manage loss of material due to general, pitt ing, crevice, MIC, and fouling to verif y the effectiveness of the fuel oil chemistry program.
A one-time in spection of sel ected components at susceptibl e locations is an acceptable meth od to ensure th at corrosion i s not occurrin g and that the co mponent's in tended function wi ll be main tained duri ng the period o f extended ope ration.In th e OCG S LR A Se ctio n 3.3.2.2.9.1 , the app lic ant a ddre ssed los s of ma teri al o f stee l pi pin g, pipi ng compo nents, pipi ng ele ments, a nd tan ks due t o gener al, pi tting, c revi ce, M IC, and fouli ng. The OCGS LRA s tated t hat Oy ster Cr eek wi ll i mpleme nt a One-Time In specti on Pro gram, B.1.24 , for sus cepti ble l ocati ons to veri fy the effectiv eness of the fue l oil chemi stry p rogram, B.1.22 , to man age the loss of materi al in steel pipi ng, pip ing com ponen ts, and pipi ng ele ments expo sed to a fuel oil intern al en viro nment i n the e mergency dies el gen erator and au xil iary system, main fuel oil storage &
transfer system, and fire protection system. The v erification of the fuel oil chemistry progra m to manage the loss of material in steel fuel oil tanks is implemented thro ugh the fuel oil chemistry p rogram tank inspection activiti es which requires that fuel oil tanks be periodically drained, cleaned, and internally inspected to ensur e that corrosion is not occurring and that there is no loss of in tended function.
Observed cond itions that h ave the 407 potential for i mpacting an inte nded function a re evalua ted or corrected in accordanc e with th e corrective a ction process.
The project team rev iewed th e applica nt's fuel oil chemistry p rogram (AMP B.1
.24) and ve rified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll mi tigate loss o f materia l due to general, pitting, crevice, MIC, and fouling. In addition, the proj ect team reviewed the applicant's One-Time Inspection Program (B.1.24) and verified tha t this aging management program included inspections to detect los s of material due to general, pi tting, crevice, MIC, and foul ing as a means of v erifying the effectiv eness of the fuel o il chemistry program. The project tea m dete rmin ed th at th ese AM Ps w ill ade quate ly mana ge lo ss o f mate rial due to ge nera l, p itti ng, crev ice , MI C, a nd fo uli ng for stee l pi pin g, pi pin g comp onen ts, p ipi ng el emen ts, a nd ta nks exp osed to fu el o il i n the emer genc y di esel gene rato r and aux ili ary sys tem, main fuel oil stor age& trans fer sys tem, and fire pr otecti on sy stem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.9.1 for further ev aluation.3.3.2.2.9.2 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, M icrobiologi cally In fluenced Corrosion an d Fouling [Item 2
]The project team rev iewed OC GS LRA Secti on 3.3.2.2.9.2 agai nst the criteri a in SRP-L R Section 3.3.2.2
.9.2.SRP-LR Secti on 3.3.2.2.9.2 state d that loss o f material due to general, pittin g, crevice, M IC, and fouling could o ccur for steel hea t exchanger comp onents expo sed to lubri cating oil.
The existin g aging ma nagemen t progra m reli es on the pe riodi c sampl ing an d anal ysis of lub ricati ng oil to maintain con taminants wi thin acceptab le limits, thereby prese rving an env ironment that i s not conducive to corrosion.
Howev er, control of lu be oil co ntaminants may not alw ays hav e been adequate to precl ude corrosion. Therefore, the effectivene ss of lubricati ng oil control should be verified to e nsure that corrosi on is not o ccurring. The GALL Report recommended further eval uatio n of pro grams to manage c orrosi on to v erify the effect iven ess of th e lub e oil program. A one-time in spection of sel ected components at susceptibl e locations is an acce ptable method to ensure that c orrosion is not occurring and that the compone nt's intende d function w ill be maintained d uring the perio d of extended operation.
In the OCGS LRA , Section 3.3.2
.2.9.2, the appl icant addresse d loss of materia l of steel hea t exchanger components due to g eneral, pitting, crevice, MIC, and fo uling. The OCGS LRA stated that Oyster Creek will implement a One-Time Inspection Prog ram, B.1.24, f or susceptible locat ions to ve rify th e effecti vene ss of the lubri catin g oil monito ring ac tivi ties p rogram, B.2.2, to manage t he lo ss of mat erial in st eel h eat ex changer shel l sid e compo nents expo sed to lubricating o il in the emergency die sel generator an d auxil iary sy stem, reactor wa ter cleanup system, and rea ctor recirculati on system. The lubricating o il monitori ng activiti es program manages phys ical and c hemica l prop erties of lub ricati ng oil by s ampli ng, testi ng, and trendi ng to identify spe cific wear mechanisms, conta mination, and oil degradati on that could affect intended functio ns. Obs erved condi tions that h ave t he pot entia l for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram (AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage t he lo ss of mat erial in st eel h eat ex changer shel l sid e compo nents expo sed to 408 lubricating o il. The techn ical ev aluation o f this program to determin e its adequacy was performed by N RC DE staff, and is ad dresse d in t he SE R rela ted to the Oy ster Cr eek pla nt.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.9.2 for further ev aluation.3.3.2.2.10 Loss of Materi al Due to P itting and Crev ice Corrosi on 3.3.2.2.10.1 Loss of Materi al Due to P itting and Crev ice Corrosi on in Steel with El astomer Lining or Sta inless Stee l Claddi ng Exposed to Treated Water  [Item 1]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.10.1 a gainst the criteri a in SRP-L R Section 3.3.2.2
.10.1.SRP-LR Secti on 3.3.2.2.10.1 s tated that loss of material due to pitting and crevice co rrosion could occur in BWR stee l pip ing w ith el astomer lini ng or sta inle ss stee l cla dding that ar e exposed to treated water if the claddi ng or lining i s degraded. The ex isting aging management program r elie s on mo nitori ng and contro l of rea ctor w ater ch emistry to mana ge the a ging effect s of loss of material from pitting and crev ice corrosio
: n. Howev er, high concentra tions of impuriti es at crev ices a nd lo catio ns of sta gnant flo w con ditio ns cou ld ca use pi tting, o r crev ice co rrosio n. Therefore, the effectiveness of the chemistry control program shou ld be ve rified to ensure that corros ion i s not o ccurri ng. The G ALL R eport r ecommen ded furt her ev aluat ion o f programs to manage loss of materia l from pitting and crevice co rrosion to v erify the effectiven ess of the Water Chemistry Program. A one-ti me inspection of select compone nts at suscepti ble locati ons is an acceptable method to ensure that corrosion is not occurring and that the component's intended functio n will be maintain ed during the p eriod of exten ded operation
.In the OCGS LRA Section 3.3
.2.2.10.1, the app licant addre ssed loss o f material of steel p iping with elas tomer l inin g or stai nless steel clad ding d ue to p ittin g and cr evic e corro sion. The OC GS LRA stated tha t Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in stainless ste el or elas tomer lined s teel pipi ng, piping compone nts, piping eleme nts, and heat e xchanger tube side componen ts exposed to a treated w ater environment in the control rod drive system, post-acc ident sampli ng system, process sampling syst em, reac tor build ing c lose d coo ling water syste m, r eact or wat er cle anup syste m, sh utdo wn cooling sy stem, spent fuel poo l coolin g system, standby liquid con trol system (l iquid poiso n syste m), wa ter trea tment & distr ibuti on sy stem, re actor h ead co olin g syste m, and i n the p rimary contai nment. Observ ed con ditio ns tha t hav e the p otenti al for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
Oyster Creek w ill imple ment a O ne-Time Inspe ction Program , B.1.2 4, for su scepti ble l ocati ons to verify the e ffectiveness of the Water Chemistry P rogram, B.1.2, to manage the loss of material in stainl ess steel fuel storage and handl ing equipment and structures ex posed to a trea ted water environment in the fuel sto rage and handl ing equipment sy stem, and, to manage th e loss of material in the stainles s steel fuel p ool skimmer surge tank l iner expo sed to a treated water environment in the reactor building stru cture. Observed conditions that have the potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process
.When applied to stainl ess steel AS ME Cla ss MC co mponents in a treated wate r environmen t and to stainl ess steel AS ME Cla ss 2 and 3 p iping and co mponents in a treated wate r
409 environment, Oyster Creek w ill use ASME S ection XI, Subse ction IWF, B.1.28, to verify the effectiveness of the Water Chemistry Program, B.1.2, to miti gate loss of material. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll man age lo ss of mat erial due to pitti ng and crevi ce corr osion. In ad ditio n, the project team re view ed the appl icant's One-Time Inspection Pro gram (B.1.24) and AS ME Secti on XI, Subsectio n IWF (AMP B.1.28), and v erified that these AM Ps includ ed inspecti ons to detect l oss of material d ue to pittin g and crevic e corrosion as a means of veri fying the effectivene ss of the Water Chemistry Program. The project team determin ed that these A MPs w ill adequate ly manage l oss of material d ue to pittin g and crevi ce corrosion for the aforementioned a uxilia ry systems.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.1 for further e valuatio n.3.3.2.2.10.2 Loss o f Mate rial Due to Pitti ng and Crevi ce Cor rosio n Stai nless Steel Expo sed to Treated Water [Item 2]
The applican t addressed l oss of material d ue to pittin g and crevic e corrosion o f stainless stee l and al uminum pipi ng, pip ing com ponen ts, pi ping e lement s, and for stai nless steel and s teel w ith stainless ste el claddi ng heat excha nger components ex posed to treated water in Sections 3.3.2.2.10.1 and 3.3.2.2.7.2 of the OCGS L RA, in acco rdance wi th the draft January 2005 SRP-LR. Therefore, th e project team rev iewed OC GS LRA Secti ons 3.3.2.2.10.1 and 3.3.2.2.7.2 against the criteria i n SRP-LR S ection 3.3.2.2.1 0.2.SRP-LR Secti on 3.3.2.2.10.2 s tated that loss of material due to pitting and crevice co rrosion could occur for stainless stee l and alu minum pipin g, piping componen ts, piping el ements, and for stai nless steel and s teel w ith st ainl ess ste el cl addin g heat e xcha nger com ponen ts ex posed to treated water.
The existi ng aging management program reli es on monitori ng and control of reactor water chemistry to ma nage the aging effects of loss of material from pittin g and crevic e corrosion. Ho wever, h igh concentratio ns of impurities at crevice s and locati ons of stagnant flow conditions could cause pitting, or crev ice corrosio
: n. Therefore, the effectiven ess of the chemistry con trol program shoul d be veri fied to ensure tha t corrosion i s not occurrin
: g. The GALL Report reco mmended further eval uation of programs to man age loss of material from pitti ng and crevi ce corr osion to ve rify th e effecti vene ss of the Water Chemi stry P rogram. A one-ti me ins pecti on of se lect c ompone nts at suscep tible loca tions is an accep table method to ensure that corros ion is no t occurring and th at the component' s intended functi on wil l be maintained d uring the perio d of extended operation.
In the OCGS LRA Section 3.3
.2.2.10.1, the app licant addre ssed loss o f material of steel p iping with elas tomer l inin g or stai nless steel clad ding d ue to p ittin g and cr evic e corro sion. The OC GS LRA stated tha t Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in stainless ste el or elas tomer lined s teel pipi ng, piping compone nts, piping eleme nts, and heat e xchanger tube side componen ts exposed to a treated w ater environment in the control rod drive system, post-acc ident sampli ng system, process sampling syst em, reac tor build ing c lose d coo ling water syste m, r eact or wat er cle anup syste m, sh utdo wn cooling sy stem, spent fuel poo l coolin g system, standby liquid con trol system (l iquid poiso n syste m), wa ter trea tment & distr ibuti on sy stem, re actor h ead co olin g syste m, and i n the p rimary 410 contai nment. Observ ed con ditio ns tha t hav e the p otenti al for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
Oyster Creek w ill imple ment a O ne-Time Inspe ction Program , B.1.2 4, for su scepti ble l ocati ons to verify the e ffectiveness of the Water Chemistry P rogram, B.1.2, to manage the loss of material in stainl ess steel fuel storage and handl ing equipment and structures ex posed to a trea ted water environment in the fuel sto rage and handl ing equipment sy stem, and, to manage th e loss of material in the stainles s steel fuel p ool skimmer surge tank l iner expo sed to a treated water environment in the reactor building stru cture. Observed conditions that have the potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process
.When applied to stainl ess steel AS ME Cla ss MC co mponents in a treated wate r environmen t and to stainl ess steel AS ME Cla ss 2 and 3 p iping and co mponents in a treated wate r environment, Oyster Creek w ill use ASME S ection XI, Subse ction IWF, B.1.28, to verify the effectiveness of the Water Chemistry Program, B.1.2, to miti gate loss of material. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll man age lo ss of mat erial due to pitti ng and crevi ce corr osion. In ad ditio n, the project team re view ed the appl icant's One-Time Inspection Pro gram (B.1.24) and AS ME Secti on XI, Subsectio n IWF (AMP B.1.28), and v erified that these AM Ps includ ed inspecti ons to detect l oss of material d ue to pittin g and crevic e corrosion as a means of veri fying the effectivene ss of the Water Chemistry Program. The project team determin ed that these A MPs w ill adequate ly manage l oss of material d ue to pittin g and crevi ce corrosion for the fuel storage and handling equi pment system, for the stainless ste el fuel pool skimmer su rge tank liner, and for the stainle ss steel AS ME Cla ss MC an d Class 2 and 3 pip ing an d compo nents expo sed to a trea ted w ater en viro nment.In th e OCG S LR A, S ecti on 3.3.2.2.7.2, t he a ppl ica nt ad dres sed los s of ma teri al o f stee l pi pin g, piping compone nts, and pipi ng elements due to general, pitti ng, and crevi ce corrosion . The OCGS LRA stated that Oyster Cree k will i mplement a One-Time In spection Program, B
.1.24, for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in steel and al uminum pipi ng, piping compone nts, and pipi ng elements ex posed to a trea ted water en vironment i n the control rod drive system, post-acci dent sampling sys tem, process sampl ing system, reacto r head cooli ng system, reactor re circulation syste m, react or wa ter cl eanup syste m, shutd own cooli ng sys tem, spe nt fuel pool cool ing sy stem, standby l iquid control system (li quid poison system), wate r treatment & dis tribution sy stem, and in aluminu m fuel pool gates and fuel storage an d handlin g equipment and struc tures in the fuel storage and handl ing equipment sy stem exposed to a treated w ater enviro nment. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The OCGS LRA further sta ted that, whe n applied to steel AS ME Cla ss MC co mponents in a treated water environment and to steel ASME C lass 2 and 3 piping and components in a treated wa ter en vi ron men t, O ys ter Cre ek w il l u se A SM E S ect io n XI , Su bse cti on IWF, B.1.28, to ve rif y the effectiveness o f the Water Chemistry Program, B.1.2, to mi tigate loss of materi al. Observe d conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.
411 The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll mi tigate loss o f materia l due to general, pitting, and crevice corrosion. In addition, the project team reviewed the applicant's One-Tim e Ins pect ion Pr ogr am (B.1.24) a nd ASME Sect ion X I, Su bsec tion IW F pro gra m (AMP B.1.28), and veri fied th at thes e AM Ps in clude d ins pecti ons to detec t loss of materi al du e to general, pittin g, and crevic e corrosion a s a means of ve rifying the effective ness of the Water Chemistry P rogram. The project team de termined that thes e AMPs will adequately man age loss of material due to general, pitti ng, and crevi ce corrosion for steel pipi ng, piping compone nts, and piping eleme nts in the co ntrol rod dri ve system, post-accident s ampling syste m, process sampling sys tem, reactor head c ooling sys tem, reactor recircul ation syste m, reactor water cleanup sy stem, shutdown cooling sy stem, spent fuel poo l coolin g system, standby liquid con trol system (liqui d poison sy stem), water treatmen t & distribu tion system, a nd in alu minum fuel pool gates and fuel storage and handli ng equipment and stru ctures in the fuel storage and ha ndling equipme nt sy stem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.2 for further e valuatio n.3.3.2.2.10.3 Loss o f Mate rial Due to Pitti ng and Crevi ce Cor rosio n for Co pper A lloy Expo sed to External C ondensation
[Item 3]The applican t addressed l oss of material d ue to pittin g and crevic e corrosion o f copper alloy HVAC piping, piping components, and piping elements exposed to condensation (external) in Secti on 3.3.2.2.10.2 of the OCGS L RA, i n acco rdance wit h the d raft Janu ary 2 005 SR P-LR. Therefor e, the project team reviewed OCGS LRA Section 3.3.2.2.10.2 against the criteria in SRP-LR Secti on 3.3.2.2.10.3.
SRP-LR Secti on 3.3.2.2.10.3 s tated that loss of material due to pitting and crevice co rrosion could occur for copp er all oy HV AC pi ping, p ipin g compon ents, a nd pi ping e lement s exp osed t o condensation (external). The G ALL Report recommended f urther evaluation of a plant-specif ic aging management program to en sure that these aging effects are adequately managed.In the OCGS LRA Section 3.3
.2.2.10.2, the app licant addre ssed loss o f material of copper a lloy HVAC pip ing, piping comp onents, and pi ping elements d ue to pittin g and crevic e corrosion.
The OCGS LRA stated that Oyster Cree k will i mplement a One-Time In spection Program, B
.1.24, for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in stainless ste el and cop per alloy piping, pip ing components, an d pip ing e leme nts e xpo sed to a trea ted w ater int erna l or ext erna l en vir onme nt i n the hea ting &process steam sy stem, reactor wa ter cleanup s ystem, noble metals monitori ng system, and control rod dri ve system.
Observed con ditions that have the p otential for impa cting an inten ded function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll man age lo ss of mat erial due to pitti ng and crevi ce corr osion. In ad ditio n, the project team re view ed the appl icant's One-Time Inspection Pro gram (B.1.24), and v erified that thi s aging management program i ncluded inspections to detect los s of material due to pitting and crevice c orrosion as a means of verify ing the effectiveness o f the Water Chemistry Program. The project team determined th at these AMPs w ill adequate ly manage l oss of material d ue to pittin g and crevic e corrosion for the heating & proce ss steam system, reactor water cleanup sy stem, noble metal s monitoring syste m, and c ontrol rod dr ive syste m.
412 The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.3 for further e valuatio n.3.3.2.2.10.4 Loss o f Mate rial Due to Pitti ng and Crevi ce Cor rosio n for Co pper A lloy Expo sed to Lubricating Oil
[Item 4]
The applican t addressed l oss of material d ue to pittin g and crevic e corrosion for co pper alloy piping, pipi ng components, and piping eleme nts exposed to lubricati ng oil in Section 3.3.2.2
.11 of the OCGS LRA, i n accordance with the draft January 20 05 SRP-LR.
Therefore, the project team review ed OCGS LRA S ection 3.3.2.2.1 1 against the cri teria in SR P-LR Section 3.3.2.2.10.4.
SRP-LR Secti on 3.3.2.2.10.4 s tated that loss of material due to pitting and crevice co rrosion could occur for copp er all oy pi ping, p ipin g compon ents, a nd pi ping e lement s exp osed t o lubricating o il. The ex isting aging management program relies on the periodi c sampling and analysi s of lubricatin g oil to main tain contamina nts withi n acceptable limits, there by preserv ing an env ironme nt that is no t cond uciv e to co rrosio n. How ever, contro l of lu be oi l con tamina nts may not alw ays hav e been adequate to preclude corrosion. Therefore, th e effectiveness of lubricating o il control should be verified to e nsure that corrosi on is not o ccurring. The GALL Report recommended further evalua tion of programs to manage corrosion to v erify the effectiveness of the l ubricating oi l program. A one-time inspecti on of selected c omponents at susceptible locations is an accep table method to ensure that co rrosion is n ot occurring and that the component's intended functi on wil l be maintai ned during the period of exte nded operatio n.In the OCGS LRA Section 3.3
.2.2.11, the appl icant addresse d loss of materia l of copper al loy piping, pipi ng components, and piping eleme nts exposed to lubricati ng oil due to pitting and crevi ce corr osion. The OC GS LRA stated that Oy ster Cr eek wi ll i mpleme nt a One-Time Inspection Pro gram, B.1.24, for susceptib le locati ons to veri fy the effectiveness of the lubrica ting oil moni tori ng ac tiv iti es p rogra m, B.2.2, to ma nage the los s of ma teri al i n co pper all oy p ipi ng, piping components, piping elem ents, and heat exchangers exposed to a lubricating oil environment in the serv ice water system, reactor w ater cleanup system, emergency diesel generator and aux iliary system, and fire protection sy stem. The lubric ating oil mon itoring acti vit ies prog ram m anag es p hys ica l an d ch emic al p rope rtie s of l ubri cati ng oi l by samp lin g, testing, and trendi ng to identify specific we ar mechanisms, co ntamination, a nd oil de gradation that could affect inte nded functions.
Observed cond itions that h ave the po tential for impac ting an intended function are ev aluated or co rrected in acc ordance wi th the correctiv e action process.The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram (AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage the loss of material in copper allo y pipin g, piping componen ts, piping el ements, and heat exchangers exposed to a lubricating oil environment.
The technical evaluation of this program to determine i ts adequacy w as performed by N RC DE staff, and i s addressed i n the SER re lated to the Oyste r Cree k plant.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.4 for further e valuatio n.
413 3.3.2.2.10.5 Loss of Materi al Due to P itting and Crev ice Corrosi on for Stainles s Steel Ex posed to Condensati on [Item 5]
The applican t addressed l oss of material d ue to pittin g and crevic e corrosion for sta inless stee l ducting and components exposed to cond ensation in Section 3.3.2.2.10.2 of the OCGS LRA, in accord ance w ith th e draft J anuary 2005 SRP-L R. Ther efore, th e proje ct team revi ewed OCGS LRA Sectio n 3.3.2.2.10.2 agai nst the criteri a in SRP-L R Section 3
.3.2.2.10.5.
SRP-LR Secti on 3.3.2.2.10.5 s tated that loss of material due to pitting and crevice co rrosion could occur for HVAC alumi num piping, pi ping components, a nd piping el ements, and stai nless steel ductin g and components exposed to condensation. The GALL Repo rt recommended further evaluati on of a plant-sp ecific aging management p rogram to ensure that these aging effects are adequately managed.In the OCGS LRA , Section 3.3.2
.2.10.2, the appl icant addresse d loss of materia l of stainles s steel ducting, due to pitting and crevice corrosion. The OCGS LRA stated t hat Oyster Creek will implement a One-Time Inspection Program, B.1.24, to mana ge the loss of materi al in stai nless steel pipi ng, piping compone nts, and pipi ng elements ex posed to a co ndensation i nternal envi ronmen t in th e hyd rogen & oxy gen moni toring syste m, and n itrogen suppl y sy stem. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process.The project team rev iewed th e applica nt's one-time inspection aging management program (AMP B.1.2 4), and determin ed that it i ncludes acti vities th at are adequate to manage loss of material of stain less steel components ex posed to cond ensation. The project team determin ed that the appli cant appropria tely addre ssed loss o f material in sta inless stee l piping, pi ping components, and piping eleme nts exposed to a condens ation interna l enviro nment in the hydrogen & o xygen moni toring system, an d nitrogen supp ly sys tem The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.5 for further e valuatio n.3.3.2.2.10.6 Loss o f Mate rial Due to Pitti ng and Crevi ce Cor rosio n for Co pper A lloy Expo sed to Internal Cond ensation [Item 6]
The project team noted that the appl icant did not credit the GALL Report AM R for loss of material due to pitting and crevice co rrosion for copper alloy fire protection pi ping, piping compon ents, a nd pi ping e lement s exp osed t o cond ensati on (in ternal), wh ich i s asso ciate d wi th this further eva luation, for the Oyster Creek aux iliary systems. This w as a new AMR tha t was not in the dr aft Janu ary 2 005 GA LL Rep ort.The project team rev iewed Tabl es 3.3.2.1.1 through 3.3.2.1.41 in th e OCGS LRA for the auxi liary syste ms and noted that ot her GAL L AM R lin e items that a ddress same material/env ironment combin ations we re appropriatel y credited.
Therefore, the project tea m dete rmin ed th at th is fu rthe r ev alu atio n is not appl ica ble to Oy ster Cre ek.3.3.2.2.10.7 Loss of Materi al Due to P itting and Crev ice Corrosi on for Stainles s Steel Ex posed to Soil [Item 7
]The project team noted that the appl icant did not credit the GALL Report AM R for loss of material due to pitting and crevice co rrosion for stainl ess steel pi ping, piping co mponents, and 414 piping eleme nts exposed to soil, w hich is as sociated w ith this further ev aluation, for the Oyster Creek auxil iary sy stems. This w as a new AMR tha t was not i n the draft January 2005 GALL Report.The project team rev iewed Tabl es 3.3.2.1.1 through 3.3.2.1.41 in th e OCGS LRA for the auxi liary syste ms and noted that ot her GAL L AM R lin e items that a ddress same material/env ironment combin ations we re appropriatel y credited.
Therefore, the project tea m dete rmin ed th at th is fu rthe r ev alu atio n is not appl ica ble to Oy ster Cre ek.3.3.2.2.10.8 Loss of Materi al Due to P itting and Crev ice Corrosi on for Stainles s Steel Ex posed to Sodium Pe ntaborate Sol ution [Item 8]
The applican t addressed l oss of material d ue to pittin g and crevic e corrosion for sta inless stee l piping, pipi ng components, and piping eleme nts of the BWR standby li quid control sy stem that are exposed to sodium pentaborate solution in Section 3.3.
2.2.10.1 of the O CGS LRA, in accord ance w ith th e draft J anuary 2005 SRP-L R. Ther efore, Th e proje ct team revi ewed OCGS LRA Sectio n 3.3.2.2.10.1 agai nst the criteri a in SRP-L R Section 3
.3.2.2.10.8.
SRP-LR Secti on 3.3.2.2.10.8 s tated that loss of material due to pitting and crevice co rrosion c o u l d o c c u r fo r s t a i n l e s s s t e e l p i p i n g, p i p i n g c o m p o n e n t s , a n d p i p i n g e l e m e n t s o f t h e B WR standby l iquid control system that are exposed to sodium pen taborate soluti on. The exi sting aging management program reli es on monitori ng and control of water chemis try to manage the agin g effec ts of los s of ma teri al d ue to pit ting and crev ice corr osi on. How eve r, hi gh concentrations of impurities at crevices a nd location s of stagnant flow c onditions c ould cause loss of material due to pitti ng and crevi ce corrosion.
Therefore, the GALL Re port recommended that the eff ectiveness of the water chemistry contr ol program should be verified to ensur e this aging is not occ urring. A one-ti me inspection of select compone nts at suscepti ble locati ons is an acceptable meth od to ensure th at loss of materia l due to pi tting and crev ice corrosio n is not occurring and tha t the component' s intended functi on wil l be maintai ned during the period of extended o peration.In the OCGS LRA Section 3.3
.2.2.10.1, the app licant addre ssed loss o f material of steel p iping with elas tomer l inin g or stai nless steel clad ding d ue to p ittin g and cr evic e corro sion. The OC GS LRA stated tha t Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in stainless ste el or elas tomer lined s teel pipi ng, piping compone nts, piping eleme nts, and heat e xchanger tube side componen ts exposed to a treated w ater environment in the control rod drive system, post-acc ident sampli ng system, process sampling syst em, reac tor build ing c lose d coo ling water syste m, r eact or wat er cle anup syste m, sh utdo wn cooling sy stem, spent fuel poo l coolin g system, standby liquid con trol system (l iquid poiso n syste m), wa ter trea tment & distr ibuti on sy stem, re actor h ead co olin g syste m, and i n the p rimary contai nment. Observ ed con ditio ns tha t hav e the p otenti al for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that this aging mana gement program includ e activi ties that w ill manage l oss of material o f steel piping in the standby liquid contro l system du e to pitting an d crevice corrosion. In addition, the project team revi ewed the applicant' s One-Time Inspectio n Program (B.1.24) an d verified th at this a ging man agement program i nclud es in specti ons of th e stan dby l iquid contro l sy stem to detect loss of materi al as a mean s of ve rifyi ng the e ffective ness o f the Water Che mistry Program. The project team d etermined that the se AMPs will adequately man age loss of 415 material due to pitting and crevice co rrosion for stainl ess steel pi ping, piping co mponents, and pipi ng ele ments i n the B WR standby liqui d cont rol sy stem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.10.8 for further e valuatio n.3.3.2.2.11 Loss of Materi al Due to P itting, Crevi ce, and Galv anic Corrosi on for Copper Al loy Exposed to Treated Water The applican t addressed l oss of material d ue to pittin g, crevice, and galvanic corrosion for copper alloy piping, piping components, and piping elements exposed to treated water in , Item AP
-64 of its reconci liation o f the AMPs i n the draft January 2005 GALL Report to the a pproved Se ptember 2005 GALL Report. The proje ct team revie wed the applicant' s evalua tion against th e criteria i n SRP-LR S ection 3.3.2.2.1 1.SRP-LR Section 3.3.2.2.11 stat ed that loss of material due to pitt ing, crevice, and galvanic corrosion cou ld occur for copp er alloy piping, pip ing components, an d piping el ements expose d to treated wa ter. Therefore, the GALL R eport recommended that the effectivene ss of the water chemis try co ntrol program s hould be v erifie d to en sure th is agi ng is n ot occu rring. A one-time inspection of select componen ts at susceptib le locati ons is an a cceptable metho d to ensure tha t loss of material due to pitting and crevice corrosion is not occurring and that t he component's intended functio n will be maintain ed during the p eriod of exten ded operation
.In Attachment 3, Item A P-64 of its recon ciliatio n document, the a pplicant ad dressed loss of material of coppe r alloy piping, pipi ng components, and piping eleme nts exposed to treated water due to pitting, crev ice, and galv anic corrosi on. The appli cant stated that th e AMR l ine item for copper allo y pipin g elements in tre ated water, a ddressing loss of material due to corrosion, recommended the C losed-Cyc le Cooli ng Water System program with no further evaluati on required in Ja nuary 2005 , and has bee n changed in September 2005 to recommend the w ater chemistry and one-time ins pection, w ith further eval uation of detected aging effects. There are 4 instances of thi s line i tem being used i n the condens ate transfer and reac tor buildi ng closed cooling w ater systems. In the Oyster Cre ek LRA, these 4 instances al ready speci fy the water chemistry and one-time ins pection programs (w ith a standard
'E' note stating that a di fferent aging ma nagemen t progra m than w as spe cified in Ja nuary 2005 GALL w as cred ited). Therefor e, the Oyster Creek LRA implemen ts the One-Time In spection Program and is consistent w ith GALL. Si nce observe d condition s that have the potential for impacting an Intended function are evalu ated or corrected in accordanc e with th e corrective action proce ss, there is high confidence that th e aging effect will be adequately managed.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that this aging mana gement program includ e activi ties that w ill manage l oss of material o f coppe r all oy pi ping, p ipin g compon ents, a nd pi ping e lement s exp osed t o treat ed w ater du e to pitting, crevice, and galvanic corrosion.
In addition, the project team re viewed the applicant's One-Time Inspection Program (B.1.24) and verified tha t this aging management program includes i nspections to detect loss o f material as a mea ns of verifyi ng the effectiveness of the W ater Chemistry Program. The project team det ermined that these AMPs will adequately manage l oss of ma terial for copp er all oy pi ping, p ipin g compon ents, a nd pi ping e lement s expo sed to treate d wa ter due to pi tting, c revi ce, an d galv anic corros ion i n the c onden sate transfer and reactor b uilding cl osed cooli ng water sy stems.
416 The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.11 for further ev aluation.3.3.2.2.12 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion 3.3.2.2.12.1 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion for Aluminum, Copper Alloy and Stainless Steel Exposed to Fuel Oil
[Item 1]The applican t addressed l oss of material d ue to pittin g, crevice, and microbiolo gically i nfluenced corros ion for alumi num and coppe r all oy pi ping, p ipin g compon ents, a nd pi ping e lement s exposed to fuel oil i n Section 3
.3.2.2.12.1 of the OCGS L RA, and stai nless steel piping, pip ing compon ents, a nd pi ping e lement s exp osed t o fuel oil i n Attac hment 3 , Item A P-54 o f its reconcilia tion of the AM Ps in the d raft January 200 5 GALL Report to the approv ed September 2005 GALL Re port. The project tea m review ed the appl icant's further ev aluations a gainst the criteria in SRP-LR Secti on 3.3.2.2.12.1.
SRP-LR Section 3.3.2.2.12.1 st ated that loss of mate rial due to pitting, crevice, and MIC could occur in stai nless steel , aluminum, and copper all oy pipi ng, piping compone nts, and pipi ng elements exposed to fuel oil. The existing aging management prog ram relies on the fuel oil chemistry program for moni toring and control of fuel oil co ntamination to manage loss of materi al due to corros ion. Howe ver, c orrosi on may occur at loc ation s whe re con tamina nts acc umulat e and the effect iveness of fuel oil chemistry control should be verified to ensu re that corrosion is not o ccur ring. The GALL Rep ort r ecom mend ed fu rthe r ev alu atio n of p rogra ms to mana ge corros ion to veri fy the effectiv eness of the fue l oil chemi stry c ontrol program. A one-time inspe ction of sele cted co mponen ts at su scepti ble l ocati ons i s an a ccepta ble me thod to ensur e that corrosion is not occurri ng and that the c omponent's i ntended function will be maintaine d during the peri od of extended operation.
In the OCGS LRA Section 3.3
.2.2.12.1, the app licant addre ssed loss o f material of alumin um and co pper a lloy pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to fu el oi l due to pitti ng, crev ice, a nd M IC. The OCGS L RA sta ted tha t Oyste r Cree k wil l impl ement a One-Tim e Inspection Program , B.1.24, for susc eptible locations to verify the eff ectiveness of the fuel oil chem istr y pr ogram , B.1.22, to ma nage the los s of ma teri al i n al umin um an d co pper all oy p ipi ng, piping compone nts, and pipi ng elements ex posed to a fuel oil env ironment in th e emergency diesel genera tor and aux iliary system, main fuel oil storage &
transfer system, and fire protection syste m. Obse rved condi tions that h ave t he pot entia l for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's fuel oil chemistry p rogram (AMP B.1
.24) and ve rified that th is agi ng manage ment pr ogram in clude d acti viti es tha t wi ll mi tigate loss o f materia l due to pitti ng, crev ice, a nd M IC. In addit ion, t he pro ject tea m revi ewed the ap plic ant's One-Tim e Inspection Pro gram (B.1.24) and v erified that thi s aging management program i ncluded inspections to detect los s of material due to pitting, crev ice, and M IC as a means of verifying the effect iveness of the fuel oil chemistry prog ram. The project team determined that th ese AMPs will adequately man age loss of material due to pitti ng, crevice, an d MIC for steel piping, pip ing components, pip ing elements, an d tanks expose d to fuel oil in the emergency diesel gene rator and au xil iary syste m, main fuel o il st orage & transfer syste m, and fi re prot ectio n sys tem.
417 In Attachment 3, Item A P-54 of its recon ciliatio n document, the a pplicant ad dressed loss of material of stainless steel piping , piping components, and piping elem ents exposed to fuel oil due to pitti ng, crevice, an d MIC. The applicant s tated that the l ine item for stai nless steel piping elements in fuel oil, addressing loss of material due to corrosion, recom mended the fuel oil chemis try pr ogram w ith no further eval uatio n requi red in the Ja nuary 2005 draft GAL L Repo rt, and ha s been change d in t he Sep tember 2005 GA LL Rep ort to r ecommen d the fu el oi l che mistry and One-Time Inspec tion Program, w ith a further ev aluation o f detected aging effects, to be consistent with other line items applicable to fuel oil environments. T here are 6 instances of this line item b eing used, in the EDG and auxili ary systems, and in the main fuel oil storage and transfer syste m.The applicant furth er stated that numero us items in the EDG and auxiliary systems, and main fuel oi l stor age sy stems a re alr eady subjec t to bo th the fuel oi l che mistry and o ne-tim e inspection requirements for determina tion of loss o f material due to corrosion. The b asis for sample siz e for the One-Time Inspec tion Program w ould not be significantly affected by the addit ion o f the (co mparati vely few) A P-54 l ine i tems. E valu ation s of any detec ted agi ng effects from inspections o f those components, w ith observe d condition s that have the potential for impacting an i ntended function evaluated and corrected as necessary in accordan ce with the corrective a ction process, provide a mple opportuni ty for verificati on of the effectivenes s of the fuel oil che mistry program w ith the One-Time Ins pection Program i n these two systems. The appli cant co nclud ed tha t no ch ange w as nec essary to the OCGS L RA du e to th is it em.The pro ject tea m revi ewed Table 3.3.2.1.13 i n the OC GS LRA for the EDG an d aux ilia ry sy stem, and Tab le 3.3.2.1.21 in th e OCGS LRA for the mai n fuel oil t ransfer syste m, and n oted th at ther e are multiple line ite ms for components cons tructed of carbon stee l, copper, and aluminum expo sed to fuel o il th at alr eady credi t both the fuel oil chemis try pr ogram an d the On e-Time Inspec tion P rogram to manage loss o f materia l. Si nce sta inle ss stee l is expe cted to be mor e resistant to corro sion than ca rbon steel, co pper, and al uminum, the late r materials can be consi dered leadi ng ind icato rs and are ex pected to be incl uded i n the s cope o f the on e-time inspection sample basis. Including one-t ime inspection for the stainless st eel components would not significantl y change the one-time insp ection sample basis. On thi s basis, the project team determi ned th at the fuel oi l che mistry program is ad equate to mana ge loss of materi al du e to corros ion for the st ainl ess ste el co mponen ts ex posed to fuel oil in the EDG an d aux ilia ry sy stem, and the main fuel oil transfer system. The project team concurred with the applicant's concl usion that n o chan ge was neede d to th e OCGS LRA d ue to t his i tem.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.12.1 for further e valuatio n.3.3.2.2.12.2 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion i n Stainles s Steel Ex posed to Lubri cating Oil [Item 2]
The project team rev iewed OC GS LRA Secti on 3.3.2.2.12.2 a gainst the criteri a in SRP-L R Section 3.3.2.2
.12.2.SRP-LR Section 3.3.2.2.12.2 st ated that loss of mate rial due to pitting, crevice, and MIC could occur in stai nless steel piping, pip ing components, an d piping el ements expose d to lubrica ting oil. The ex istin g program relie s on th e peri odic sampli ng and analy sis of l ubric ating o il to maintain con taminants wi thin acceptab le limits, thereby prese rving an env ironment that i s not conducive to corrosion.
Howev er, control of lu be oil co ntaminants may not alw ays hav e been adequate to precl ude corrosion. Therefore, the effectivene ss of lubricati ng oil control should be 418 verified to e nsure that corrosi on is not o ccurring. The GALL Report recommended further evaluation of programs to manage corrosion to verif y the effectiveness of the lubricating oil program. A one-time inspection of selected compon ents at suscepti ble locati ons is an acceptable meth od to ensure th at corrosion i s not occurrin g and that the co mponent's in tended function wi ll be main tained duri ng the period o f extended ope ration.In the OCGS LRA Section 3.3
.2.2.12.2, the app licant addre ssed loss o f material of stainl ess stee l pi pin g, pi pin g comp onen ts, a nd p ipi ng el emen ts ex pose d to lub rica ting oil due to p itti ng, crevi ce, an d MIC. The OC GS LRA stated that Oy ster Cr eek wi ll i mpleme nt a One-Time Inspection Pro gram, B.1.24, for susceptib le locati ons to veri fy the effectiveness of the lubrica ting oil moni tori ng ac tiv iti es p rogra m, B.2.2, to ma nage the los s of ma teri al i n sta inl ess stee l pi pin g, piping compone nts, and pipi ng elements ex posed to a l ubricating oi l enviro nment in the emergency dies el generator and auxili ary system.
The lubricati ng oil monito ring activi ties program manages physi cal and che mical properti es of lubricati ng oil by sampling, testi ng, and trending to identify specif ic wear mechanisms, contamination, and oil degradation that could affect intended functions. Observed co nditions tha t have the potential for i mpacting an inte nded function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram (AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage t he lo ss of mat erial in st ainl ess ste el pi ping, p ipin g compon ents, a nd pi ping e lement s exposed to a lubricati ng oil env ironment. The tech nical ev aluation o f this program to determin e its adequacy was performed b y NRC D E staff, and is addre ssed in the SER related to the Oyster Creek p lant.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.12.2 for further e valuatio n.3.3.2.2.13 Loss of Materi al Due to Wear The project team rev iewed OC GS LRA Secti on 3.3.2.2.13 agai nst the criteri a in SRP-L R Section 3.3.2.2.13.
SRP-LR Secti on 3.3.2.2.13 sta ted that loss of material due to wear coul d occur in th e elastomer seals and c omponents ex posed to air indoor uncon trolled (in ternal or ex ternal). The GALL Report recommended further evaluation to ensure that these aging eff ects are adequately managed.In the OCGS LRA , Section 3.3.2
.2.13, the appl icant addresse d loss of materia l of elastomer seals and c omponents ex posed to air indoor uncon trolled (in ternal or ex ternal) due to wear. The OCGS LR A state d that Oyster Creek w ill imple ment a p eriod ic in specti on of v entil ation syste ms program, B.2.4, for the ins pection of ela stomer door seal s exposed to an indoo r air interna l or external e nvironment i n the ?C" battery roo m heating and v entilation system, 480V switchgear room ventilation system, battery and MG set room ventilation system , control room HVAC system, radw aste area heati ng and venti lation sy stem, reactor buil ding ventil ation syste m, and standb y gas t reatmen t syst em. Pe riodi c insp ectio ns are performe d on e lasto mer doo r seal s to identify detri mental changes i n material pro perties, as ev idenced by cracking, perforations i n the material, or l eakage. Observed c onditions th at have the potential for impacting an i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.
419 The project team reviewed the applicant's further evaluation and determined that the periodic inspection of ventilation systems prog ram (AMP B.2.4) is a plant specific progr am that is appropriate to detect loss o f material of elastomer seals and c omponents. The tech nical evaluation of this program to determine its adequacy was perfor med by NRC DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.3.2.2.13 for further ev aluation.3.3.2.2.14 Loss of Materi al Due to C ladding Brea ch Loss of material due to cladd ing breach for PWR steel charging p ump casings w ith stainle ss s t e e l c l a d d i n g e x p o s e d t o t r e a t e d b o r a t e d w a t e r i s n o t a p p l i c a b l e s i n c e O y s t e r C r e e k i s a B WR plant.3.3.2.2.15 Quali ty As suranc e for Agi ng Ma nagemen t of Non-Safey-Rela ted Co mponen ts OCGS LRA Section 3.3.2.2.15 is reviewed by NRR/DE staff and will be addressed separately in Section 3 of the SER related to the OCG S LRA.Conclusio n On the basis o f its review , for component groups e valuated in the GALL R eport for whic h the GALL Report reco mmended further eval uation, the pro ject team determined that the appl icant adequately a ddressed the i ssues that w ere further eval uated.3.3.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Summary of Information i n the Appli cation In OCGS LRA Ta ble 3.3.1, S ummary of Agin g Man agement Eval uatio ns for th e Aux ilia ry Systems, the a pplicant pro vided i nformation regarding compo nents or material
/environment combin ation in th e GALL Repor t that i t eva luate d and ident ified as not appl icabl e to i ts pla nt.In OCGS LRA Tabl es 3.3.2.1.1 through 3.3.2.1.41, the ap plicant prov ided addi tional deta ils of the r esul ts of the AMR s fo r mat eria l, env iron ment , ag ing e ff ect r equ iring mana gem ent, and AMP combinations that are not con sistent wi th the GALL Re port. Specifica lly, the applicant i ndicated, via Notes F through J, that neither the i dentified compon ent nor the materi al/enviro nment combination is eval uated in the GALL Report a nd provid ed information co ncerning how the aging effect requiring management wi ll be managed
.Project Team Eval uation The project team reviewed additional details of the results of the AMRs for mat erial, environment, aging effect requiring management, and AMP co mbinations tha t the appli cant ident ified as not appl icabl e to i ts pla nt or a s hav ing no aging e ffect.The project team did not revie w the resul ts of the AMR s for material, env ironment, aging effect requiring management, and AMP co mbinations tha t are not consi stent with the GALL Repo rt or 420 are no t ad dre sse d i n th e GA LL Rep ort. Th ese AM R l in e i tem s w ere rev ie we d b y N RR/DE sta ff, and are discussed in the SER related to the OCGS LRA.
3.3.2.3.1 Aging E ffects/mech anisms in Tab le 3.3.1 That Are No t Appl icabl e for OCGS The project team rev iewed OC GS LRA Table 3.3.1, whic h provide s a summary of agin g manageme nt ev aluat ions for the a uxil iary syste ms eva luate d in t he GAL L Repo rt.In OCGS LRA Tabl e 3.3.1, Item 3.3.1-32 , the appli cant stated that c racking due to stress corrosion crackin g for stainless stee l and cast a ustenitic stai nless steel piping, pip ing components, and piping eleme nts exposed to treated w ater >140/F is not applicable at OCGS.
Oyster Creek h as no stain less s teel n on-RC PB shu tdow n cool ing sy stem pi ping e xpos ed to treated water
>140/F The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that Oyster Creek has no stainles s steel non-R CPB shutdow n cooling sy stem piping exposed to treated water
>140/F. Therefore, the project team concur red with the applicant's conc lus ion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Table 3.3.1, It em 3.3.1-34, the applicant st ated that cracking due to cyclic loadi ng, stres s corro sion crackin g for high-strengt h stee l clo sure b oltin g expo sed to air w ith steam o r wat er lea kage is not ap plic able at OCGS. Aux ilia ry sy stem hi gh-stren gth stee l clo sure bolti ng exp osed t o air with steam o r wat er lea kage app lies only to the contro l rod driv e sys tem. Control rod d rive sy stem high strength steel closure bol ting is eva luated in Item Number 3.3.1-7.
The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that auxili ary system high-strength steel c losure bolti ng exposed to air wi th steam or water lea kage applies on ly to the control rod dri ve system.
Therefore, the project tea m conc urre d w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.3.1, It em 3.3.1-37, th e appl icant stated that l oss of ma terial due to general corrosio n for steel clos ure bolting ex posed to air with steam or water l eakage is not appl ica ble at OC GS. E xce pt for con trol rod driv e sy stem high-stre ngth stee l cl osur e bo lti ng, which i s evalua ted in Item Numb er 3.3.1-7, aux iliary system steel closure bol ting is not ex posed to air wi th steam or w ater leakage.
The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that, except f or control rod drive system high-str ength steel closure bolting which is eval uated in it em numb er 3.3.1-7, au xil iary syste m steel closu re bol ting i s not e xpos ed to a ir w ith steam or water leakage. Therefore, the proje ct team concurred with the applicant' s conclusi on that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.
421 On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.3.1, It em 3.3.1-44, th e appl icant stated that l oss of ma terial due to general, pittin g, and crevic e corrosion for ste el compressed air system cl osure boltin g exposed to condensati on is not a pplicabl e at OCGS. Instrument (control) air s ystem steel c losure bolti ng is no t exp osed t o cond ensati on. In strumen t (cont rol) a ir sy stem ste el cl osure bolti ng exp osed t o an indoor a ir (external) environmen t is discus sed in Item Nu mber 3.3.1-35.
The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determi ned th at ins trument (contr ol) ai r syst em stee l clo sure b oltin g is no t exp osed t o condensation. Theref ore, the project team concurred with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.3.1, It em 3.3.1-45, th e appl icant stated that l oss of ma terial due to general and pi tting corrosion for ste el compressed air system p iping, pipi ng components, and piping eleme nts exposed to condensati on (internal) is not appl icable at OCGS. Instrument (control) air p iping, pipi ng components, and piping eleme nts are not ex posed to a co ndensation (internal) env ironment. Instrument (control) air s ystem pipi ng, piping compone nts, and pipi ng elements ex posed to a dry gas (internal) environment are discussed in Item Number 3.3.1-79 and 3.3.1-80.
The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determi ned th at ins trument (contr ol) ai r syst em pip ing, pi ping co mponen ts, and pipi ng ele ments are not exp osed to a con densation (i nternal) env ironment. Therefore, the project team conc urre d w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.3.1 , Ite m 3.3.1-5 9, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevice, an d MIC for stai nless steel and copper a lloy pi ping, piping co mponents, and pi ping elements ex posed to raw water is not applica ble at OCGS. The re are no in-scope steel or copper allo y pipin g, piping componen ts, and pipi ng elements ex posed to raw water in the Oyster Creek emergency di esel generator a nd auxil iary sy stem. The diesel s are cooled by radia tors in a close d cool ing w ater sy stem.The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that there are no i n-scope steel or copper all oy pipi ng, piping compone nts, and piping eleme nts exposed to raw w ater in the Oy ster Creek emergency diesel genera tor and auxiliary system. Therefore, the project team concurr ed with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.
422 On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.3.1, Item 3.3.1-64 , the appli cant stated that l oss of material d ue to lini ng or coating degradati on for steel pi ping, piping co mponents, and pi ping elements w ith internal lining or co ating expose d to raw w ater is not ap plicable at OCGS. The prese nce of internal lin ings for c orro sio n pro tect ion is c onse rva tiv ely not cred ited. De grada tion of in tern al c oati ngs can contribute to potential downstream flow blockage. H owever NUREG-1801 Tabl e IX.F under the agi ng m ech ani sm o f ?foulin g" sta ted tha t reduc tion of system f low rate is co nsidere d active and thus not i n the purvi ew of lice nse renewa
: l. Therefore credit is not bei ng taken for internal coating inspec tions.The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that the presence o f internal li nings for corrosion protection is conservati vely n ot credi ted. D egradat ion o f intern al co atings can co ntribu te to p otenti al do wnstr eam flow bloc kage. How ev er N URE G-1 801 Tab le IX.F u nde r th e a gin g me cha ni sm o f ?fouling" stated that reduction of system flow rate is considered act ive and thus not in the purview of license renewal.
Therefore credit is not being taken for in ternal coatin g inspections.
Therefore, the project tea m conc urre d w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.3.1, Item 3.3.1-70 , the appli cant stated that c racking due to stress corrosion crackin g for stainless stee l spent fuel s torage racks expose d to treated w ater or treated borated w ater, >60/C (>140/F) is not ap plicable at OCGS. Stain less steel spent fuel storage racks are ex posed to a trea ted water <14 0/F env ironme nt and are no t susce ptibl e to cracking. The loss of materi al aging effect for spent fuel s torage racks expose d to a treated water <140
/F environ ment is eva luated in Item Number 3.3.1-22.
The project team rev iewed th e auxil iary sy stem AMR l ine items i n the OCGS LRA and determined that stainless ste el spent fuel storage racks are ex posed to a trea ted water <14 0/F environment and are not su sceptible to cracking. Therefore, the pro ject team concurred with the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
3.3.2.3.2 Auxi liary Syst ems AM R Lin e Items That Ha ve No Aging E ffect (OCGS LRA Tables 3
.3.2.1.1 Through 3.3.2.1.41
)In OCGS LRA Tabl es 3.3.2.1.1 through 3.3.2.1.41, the ap plicant i dentified li ne-items wh ere no aging effects were ide ntified as a re sult of its aging rev iew proce ss.In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from ga lvan ized steel were expo sed to an ai r-indo or unc ontrol led e nvir onment.
423 The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th this material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that galv anized s teel expo sed to an ai r-indoor uncon trolled env ironment wi ll not result in agi ng that wil l be of concern during the peri od of extended operation.
Therefore, the project team determin ed that there are no appli cable aging effects requiri ng management for this material
/environment combination.
In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabricated from glass w ere exposed to an air, fuel oil, lub ricating oil , raw w ater, or treated w ater envi ronmen t.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that glass exposed to an air, fuel oi l, lubricati ng oil, raw water, or trea ted water environment will not result in aging that wi ll be of conc ern during the p eriod of exten ded operat ion. Therefore , the p roject t eam det ermine d that there a re no a ppli cable aging e ffects requiring management for these material/env ironment combin ations.In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s tainl ess ste el, ca st aust eniti c stai nless steel , and n ickel allo y w ere ex posed to an ai r-indo or unc ontrol led e nvir onment.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that stain less steel, cast austeniti c stainless steel, and ni ckel alloy exposed to an air-indoor u ncontrolled environment will not result in aging that wi ll be of conc ern during the period of exte nded operatio
: n. Therefore, the project team determined th at there are no applicabl e aging effects requiring management for these material/en vironment co mbinations.
424 In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s teel a nd al uminum were expo sed to an ai r-indo or con troll ed env ironme nt.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that steel and alumin um exposed to an air-in door controll ed enviro nment wil l not result in agi ng that wil l be of concern during the peri od of extended operation.
Therefore, the project team determin ed that there are no appli cable aging effects requiri ng management for these material/e nvironment c ombinations.
In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s teel a nd sta inle ss stee l we re ex posed to a c oncret e env ironme nt.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that st eel and stainless steel exposed to a concrete environment will not result in aging that wi ll be of conc ern during the p eriod of exten ded operation. Therefore, the project team determined th at there are no applicabl e aging effects requiring management for these material/env ironment combin ations.In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabricated from steel, sta inless stee l, aluminum, a nd copper al loy w ere exposed to a gas envi ronmen t.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that steel , stainless steel, alumi num, and copper alloy e xposed to a gas enviro nment 425 will not result in aging that wi ll be of conc ern during the p eriod of exten ded operation. Therefore, the project team de termined that there are no appl icable agin g effects requiring management for these material/e nvironment c ombinations.
In OCGS LRA Ta bles 3.3.2.1.1 thro ugh 3.3.2.1.41 , the a ppli cant i denti fied AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabricated from steel, sta inless stee l, and coppe r alloy were ex posed to a l ubricating oi l (no wate r pool ing) or dried air e nvir onment.The project team rev iewed th e recommendation s in the GALL Report for these materi al/en viro nment c ombina tions , and d etermi ned th at the appli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the aux iliary systems, and d etermined that n o significant agin g effects were identi fied for auxilia ry system co mponents wi th these material
/environment combination.
On the basis o f its review of current industry research and operating exp erience, the p roject team found that steel , stainless steel, and co pper alloy exposed to a lubrica ting oil (no water pooling) or dri ed air env ironment wi ll not resul t in aging that w ill be o f concern during the period of extended operation. Ther efore, the proj ect team determined th at there are no applicable aging effects requiring management for thes e material/env ironment combin ations.Conclusio n On th e bas is of its re view, t he pr ojec t tea m fo und t hat t he app lican t app ropr iate ly iden tif ied AMR resu lts in volving mate rial, envir onme nt, agin g ef fec ts re quir ing m anag emen t, an d AMP combinations that are not app licable to OCGS, and AM R results i nvolvi ng material and environment combinations that do not have aging effect s requiring manag ement at OCGS.
3.3.3 Conclusion On the basis o f its review , the project team d etermined that the applican t has demonstrated that the aging effects associate d with th e auxil iary sy stem components w ill be a dequately mana ged.The project team als o review ed the appl icable UF SAR suppl ement program summaries a nd concl uded t hat the y ade quatel y des cribe the AM Ps cre dited for mana ging agi ng of the auxi liary syste m compo nents, as requ ired b y 10 CFR 5 4.21(d).3.4 OCGS LRA Section 3.4 -
Ag ing Management o f Steam and Po wer Conversion System This section o f the audit and review report documents the project team's review and eval uation of the OCGS aging management re view (AMR) resul ts for the aging management of the steam and powe r conversio n system compon ent and compone nt groups associ ated with the follow ing systems: (1) cond ensate syste m, (2) condensate transfer system, (3) feedw ater system, (4) main condenser, (5) main g enerator and auxiliary system, (6) main steam system , and (7) main turbin e and auxi liary syste m.
426 3.4.1 Summary o f Technical Information in the A pplication In the OCGS LRA Section 3.4 , the appli cant provid ed the results of its AMR s for the steam and power conv ersion sys tem components and component groups.
In OCGS LRA Ta ble 3.4.1, ?Summary of Aging M anagement Eval uations for Steam a nd Power Conv ersio n Sys tem," th e appl icant prov ided a summa ry co mparis on of i ts AM R lin e-item s wi th the AMR line-items e valuated in the GALL R eport for the steam and power con version sy stem components and component groups. The applicant also identif ied for each component type in the OCGS LRA Tabl e 3.4.1 those A MRs that a re consistent w ith the GALL R eport, those for which the GALL Report re commends further eva luation, an d those AM Rs that are no t addressed in the GALL R eport together w ith the basi s for their exc lusion.In the OCGS LRA Tables 3.4.2.1.1 through 3.4.2.1.7, the applicant p rovided a summary of the AMR resul ts for co mponen t type s asso ciate d wi th (1) c onden sate sy stem, (2) cond ensate transfer syste m, (3) fee dwat er sy stem, (4) main conde nser, (5) mai n gener ator an d aux ilia ry system, (6) main steam system, an d (7) main turbi ne and aux iliary system. Speci fically, the information for each c omponent type included intended functi on, material, e nvironment, a ging effect requiring management, AM Ps, the GALL R eport Volume 2 item, cross reference to the OCGS LRA Table 3.4.1 (Table 1), a nd generic and plant-speci fic notes related to consisten cy with the GA LL Rep ort.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of the aging effec ts requi ring man agement (AERM s). The se rev iew s incl uded t he ev aluat ion o f both plant-spe cif ic and indus try op erat ing e xperi ence. The plant-spe cif ic eval uati on inc luded revie ws of condition re ports and dis cussions w ith appropri ate site perso nnel to id entify AERM
: s. The applicant' s review of industry o perating expe rience incl uded a rev iew of the GA LL Report and operat ing ex perie nce i ssues ident ified since the i ssuanc e of the GALL R eport.3.4.2 Project T eam Evaluatio n The project team rev iewed OC GS LRA Secti on 3.4 to determi ne if the appl icant provi ded sufficient information to demonstrate that th e effects of aging for the steam and power conversion system compone nts that are w ithin the sc ope of licens e renewal and subject to an AMR w ill be a dequately mana ged so that the i ntended function(s) will be maintain ed consisten t with the CL B for the perio d of ex tended opera tion, as requi red by 10 CF R 54.2 1(a)(3).The project team rev iewed c ertain iden tified AMR line-items to confirm the appl icant's cl aim that these AMR line-items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line-items. The project team's audit evaluation is documente d in Section 3.4.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line-items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in the SRP-LR. The proj ect team's audit eval uatio n is d ocumen ted in Secti on 3.4.2.2 of t his a udit a nd rev iew report.
427 The project team did not revie w the remai ning AMR line-items that were no t consistent w ith or not addressed in the GALL R eport. These w ere review ed by the NRC DE sta ff and documented in the SER fo r the Oy ster Cr eek pla nt.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the s team and pow er conversi on system compo nents.Table 3.4-1 bel ow prov ides a summary of the project team's evaluati on of the componen ts, aging effects/aging mechanisms, and AMPs l isted in L RA Section 3.1 that are ad dressed in th e GALL Report. It a lso inclu des the secti on of the audit and revie w report i n which the project team's eval uation is documented. It sh ould be no ted that the li ne items in this table c orrespond to the line items in Tabl e 3.4-1 of the Sep tember 2005 Rev ision 1 S RP-LR documen t; therefore, in many ca ses, they do not match the l ine items i n Table 3.4.1 o f the OCGS LRA. The SRP-LR line item n umber i s deno ted pa renthe tical ly i n the c olumn 1 entry. Als o, li ne ite ms that are applicabl e only to PWR plants are not incl uded in thi s table; therefore, c ertain SRP-L R line i tem numbers do not appear in th is table.Table 3.4-1 Staff E valua tion fo r Stea m and P ower Conv ersion Sy stem Co mponen ts in the GA LL Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on Steel pipi ng, pi ping components, and piping elem ents exposed to steam or t reat ed water (It em 3.4.1-1)
Cum ulat ive fat igue damage T LA A e va lua ted in acc orda nce with 10 CFR 54.21(c)
TLAA Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See SER Secti on 3.4.2.2.1)Steel pipi ng, pi ping components, and piping elem ents exposed to steam (It em 3.4.1-2)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.2.1)Steel pipi ng, pi ping components, and piping elem ents exposed to trea ted water (It em 3.4.1-4)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.2.1)Steel heat exchanger com pon ents exposed to trea ted water (It em 3.4.1-5)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and galv anic cor rosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.9)Steel and stai nless steel tanks exposed to t reat ed water (It em 3.4.1-6)
Loss of materi al due to ge neral (stee l onl y) pit ti ng and crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Se ction 3.4.2.2.7.1 and 3.4.2.2.2.1 f or steel tanks)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 428 Steel pipi ng, pi ping components, and piping elem ents exp ose d to lub ric atin g o il (It em 3.4.1-7)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.AMP B.2.2 rev iewed by NRC DE staff.(See Au dit Report Secti on 3.4.2.2.2.2)Steel pipi ng, pi ping components, and piping elem ents exposed to raw water (It em 3.4.1-8)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC corrosi on, and foul ing Pla nt s pe cif ic N ot A pp lica ble Not applicable, refers to auxi li ary feedwat er syst em of a PW R and is not a pplica ble to Oyster Creek. (See Audit Report Sect ion 3.4.2.2.3)Stai nless st eel an d copper al loy heat exchanger t ubes exposed to trea ted water (It em 3.4.1-9)
Reducti on of heat trans fer d ue to foul ing W ater Chem istry an d O ne-T im e Inspect ion N ot A pp lica ble Not applicable, there are no i n-scope stai nless st eel he at exchanger t ubes exposed to trea ted water wit h a heat tran sfer i ntended functi on in the st eam and power conv ersi on syst em at Oyster C re ek (S ee Au dit Report Sect ion.3.4.2.2.4.1)Steel , st ainl ess steel , and copp er all oy heat exchanger t ubes exp ose d to lub ric atin g o il (It em 3.4.1-10)
Reducti on of heat trans fer d ue to foul ing Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)AMR reviewed by NRR/DE staff. (See Audit Report Sect ion.3.4.2.2.4.2)Buri ed steel pipi ng, pipi ng components, pipi ng ele ments, and tanks (wit h or wit hout coat ing or wrappi ng) exposed to s oil (It em 3.4.1-11)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC corrosi on Buri ed Pipi ng and Tanks Survei ll ance or Buri ed Pipi ng and Tanks Inspecti on Buri ed Pipi ng Inspect ion (B.1.26)Consist ent wi th GALL, which r ecomm ends furt her eval uati on (See Au dit Report Secti on. 3.4.2.2.5.1)Steel heat exchanger com pon ents exp ose d to lub ric atin g o il (It em 3.4.1-12)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and MIC corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion N ot A pp lica ble Not App li cable - there are no st eel he at exchanger components exposed to l ubri cati ng oil in t he steam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 429 3.4.2.2.5.2)Stai nless st eel pipi ng, pi ping components, pi ping elements exposed to st eam (It em 3.4.1-13)
Cra ck ing du e to stress corrosi on cracking W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.6)Stai nless st eel pipi ng, pi ping components, pi ping elements, tanks, and heat exchanger com pon ents exposed to trea ted water > 60&deg;C (> 1 40&deg;F)(It em 3.4.1-14)
Cra ck ing du e to stress corrosi on cracking W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.6)Aluminum and copper al loy pipi ng, pipi ng components, and pi ping elements exposed to t reat ed water (It em 3.4.1-15)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.(See Au dit Report Secti on 3.4.2.2.7.1)Stai nless st eel pipi ng, pi ping components, and pipi ng ele ments;tanks, and heat exchanger com pon ents exposed to trea ted water (It em 3.4.1-16)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry an d O ne-T im e Inspect ion W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on (See Au dit Report Secti on 3.4.2.2.7.1)Stai nless st eel pipi ng, pi ping components, and piping elem ents ex po se d to so il (It em 3.4.1-17)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Pla nt s pe cif ic Buri ed Pipi ng Inspection (B.1.26)
Consist ent wi th GALL, which r ecomm ends furth er ev alua tion..(See Au dit Report Secti on 3.4.2.2.7.2)Copper al loy pipi ng, pipi ng components, and pi ping elements exposed to lu br ica ting oil (It em 3.4.1-18)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion N ot a pp lica ble Not applicable, there are no i n-scope copper al loy pipi ng, pipi ng components, or pipi ng ele ments in t he steam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion 3.4.2.2.7.3)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 430 Stai nless st eel pipi ng, pi ping components, pi ping elements, and heat exchanger com pon ents exp ose d to lub ric atin g o il (It em 3.4.1-19)
Loss of materi al due to pi tt ing, cre vice, a nd M IC corrosi on Lu br ica ting O il Analy sis and On e-Ti me Inspect ion Lu br ica ting O il Monitor ing Acti vit ies (B.2.2)an d O ne-T im e Inspect ion (B.1.24)Consist ent wi th GALL, which r ecomm ends furt her eval uati on.AMP B.2.2 rev iewed by NR DE staff. (See Audit Report Sect ion 3.4.2.2.8)Ste el ta nks expos ed to air -
ou tdo or (ex ter na l)(It em 3.4.1-20)
Lo ss of m ate ria l/general , pi tt ing, and crevi ce corrosi on Aboveground Ste el Tanks Aboveground Outd oor Tanks (B.1.21)Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)High-st rengt h steel closur e bolt ing exp ose d to a ir with steam or water leakage (It em 3.4.1-21)
Cra ck ing du e to cycl ic l oading, stress corrosi on cracking Bo lting Integ rity N ot A pp lica ble Not appl icabl e since no GALL AMR li ne item s r ela ted to th is component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel bolt ing an d closur e bolt ing exp ose d to a ir with steam or water leakage, air -
outdoor (external), or ai r - i ndoor uncontr oll ed (external);(It em 3.4.1-22)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on; l oss of prelo ad d ue to ther mal effect s, gasket cree p, and self-l oosening Bo lting Integ rity Bo lting Integ rity (B.1.12)Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)Stai nless st eel pipi ng, pi ping components, and piping elem ents exp ose d to clo se d-cyc le cooli ng water> 60&deg;C (> 1 40&deg;F)(It em 3.4.1-23)
Cra ck ing du e to stress corrosi on cracking C los ed-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not appl icabl e since no GALL AMR li ne item s r ela ted to th is component group/
aging effect com bination were cr ed i t ed i n t he OCGS LRA.Steel heat exchanger com pon ents exposed to closed cycl e cooli ng water (It em 3.4.1-24)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, and galv anic cor rosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)Stai nless st eel pipi ng, pi ping components, pi ping elements, and heat Loss of materi al due to pi tt ing an d crevi ce corrosi on C los ed-C ycle Cooli ng W ater Syst em C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 431 exchanger com pon ents exposed to closed cycl e cooli ng water (It em 3.4.1-25)
Copper al loy pipi ng, pipi ng components, and pi ping elements exposed to c los ed cyc le cooli ng water (It em 3.4.1-26)
Loss of materi al due to pi tt ing, crevi ce, and galv anic cor rosi on C los ed-C ycle Cooli ng W ater Syst em Not Appl icabl e.Not applicable, there are no i n-scope copper al loy components exposed to CCCW in t he steam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion 3.4.2.3.1)Steel , st ainl ess steel , and copp er all oy heat exchanger t ubes exposed to closed cycl e cooli ng water (It em 3.4.1-27)
Reducti on of heat trans fer d ue to foul ing C los ed-C ycle Cooli ng W ater Syst em No t App licable. Not applicable, there ar e n o in-s co pe ste el, stai nless st eel, or copper al loy heat exchanger t ubes exp ose d t o CCCW wit h heat t ransfer inte nd ed fun ctio n in the st eam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion 3.4.2.3.1)Steel exter nal surfaces exp osed to ai r - i ndoor uncontr oll ed (external), condensati on (e xte rn al), or air ou tdo or (ex ter na l)(It em 3.4.1-28)
Loss of materi al due to ge neral corrosi on External Surfaces Monitor ing Struct ures Monitor ing (B.1.31)Acceptabl e - the OCG S struct ures m on itor ing pro gr am is consist ent wi th t he GALL external surfaces monit ori ng pr og ra m for this component group/
aging effect combinati on. (See Audit Report Sect ion 3.4.2.1)Steel pipi ng, pi ping components, and piping elem ents exposed to steam or t reat ed water (It em 3.4.1-29)
W all thinning due to fl ow-accel erat ed corrosi on Flow-Accel erat ed Corrosi on Flow-Accel erat ed Corrosi on (B.1.11)Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)Steel pipi ng, pi ping components, and piping elem ents ex po se d to air outdoor (i nter nal) or Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on Inspect ion of Int ernal Surfaces in Mi scell aneous Pipi ng and Ducti ng Peri odic I nspecti on (B.2.5)Acceptabl e - the O C G S p er iod ic ins pe ctio n p ro gr am is ap pr op ria te f or this component group/
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 432 condensati on (in ter na l)(It em 3.4.1-30)
Co m pon ents aging effect co mbi na t i on. AMP B.2.5 revi ewed by NRR/DE staff. (See Audit Report Sect ion 3.4.2.1)Steel heat exchanger com pon ents exposed to raw water (It em 3.4.1-31)
Loss of materi al du e to ge ne ra l, pit ti ng, cr evi ce, galva nic, an d M IC corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em Not Appl icabl e Not applicable, there are no i n-scope st eel heat exchang er components  exposed to r aw water in t he steam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion 3.4.2.3.1)Stai nless st eel an d copper al loy pipi ng, pipi ng components, and pi ping elements exposed to r aw water (It em 3.4.1-32)
Loss of materi al due to pi tt ing, cre vice, a nd M IC corrosi on O pe n-C ycle Cooli ng W ater Syst em Not Appl icabl e Not applicable, there are no i n-scope stai nless st eel or copper al loy pipi ng, pipi ng components, or piping elem ents exposed to raw water in t he steam and power conver sion syst em at Oyster Cre ek Co nsis tent w ith G AL L. (Se e A ud it Report Sect ion 3.4.2.3.1)Stai nless st eel he at exchanger com pon ents exposed to raw water (It em 3.4.1-33)
Loss of materi al due to pi tt ing, cre vice, a nd M IC corrosi on, and foul ing O pe n-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not applicable, there are no i n-scope stai nless st eel he at exchanger components  exposed to r aw water in t he steam and power conversi on syst em at Oyster Creek. (See Audit Report Sect ion 3.4.2.3.1)Steel , st ainl ess steel , and copp er all oy heat exchanger t ubes exposed to raw water (It em 3.4.1-34)
Reducti on of heat trans fer d ue to foul ing O pe n-C ycle Cooli ng W ater Syst em N ot A pp lica ble Not applicable, there ar e n o in-s co pe ste el, stai nless st eel, or copper al loy heat exchanger t ubes exposed to raw water in t he steam and power conver sion syst em at Oyster C re ek. (S ee Au dit Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 433 Report Sect ion 3.4.2.3.1)Copper al loy> 15% Zn pipi ng, pipi ng components, and pi ping elements exposed to c los ed cyc le cooli ng water , r aw water, or t reat ed water (It em 3.4.1-35)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Not Appl icabl e Not applicable, there are no i n-scope copp er a ll oy >15% Zn components  exposed to CCCW or raw water in t he steam and power conv ersi on syst em at Oyster C re ek. (S ee Au dit Report Sect ion 3.4.2.3.1)Gray cast ir on pipi ng, pi ping components, and piping elem ents ex po se d to so il, trea ted wat er, or raw water (It em 3.4.1-36)
Loss of materi al due to selective leachi ng Selective Leaching of M ate ria ls Select ive Leachi ng of M ate ria ls (B.1.25)Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)Steel , st ainl ess steel , and nickel-based al loy pipi ng, pi ping components, and piping elem ents exposed to steam (It em 3.4.1-37)
Loss of materi al due to pi tt ing an d crevi ce corrosi on W ater Chem istry W ater Chem istry (B.1.2) and On e-Ti me Inspect ion (B.1.24)Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.1)Glass pi ping elements exposed to a ir, lu br ica ting oil, raw water , and trea ted wat er (It em 3.4.1-40)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.3.2)Sta inle ss ste el, copper al loy , and nickel all oy pi ping, pipi ng components, and pi ping elements exposed to ai r - i ndoor uncontr oll ed (e xte rn al)(It em 3.4.1-41)
None None None Consist ent wi th GALL.(See Au dit Report Secti on 3.4.2.3.2)Steel pipi ng, pi ping components, and piping elem ents expos ed to air -
indoor contr oll ed None None N ot A pp lica ble Not Appl icabl e C on tro lled air envi ronments are not credi ted at Oyster Cre ek. Com pon ents Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 434 (e xte rn al)(It em 3.4.1-42) are evaluated as pa rt of t he uncontr oll ed ind oo r air envi ronment. (See Audit Report Sect ion 3.4.2.3.1)Steel and stai nless steel pipi ng, pi ping components, and pip ing ele m en ts in con cre te (It em 3.4.1-43)
None None Not Appl icabl e Not applicable. There are no i n-scope st eel or st ainl ess steel pipi ng, pi ping components, and pipi ng ele ments in a concret e envi ronment in t he Steam and Power Conversi on syst ems at Oyster C re ek. (S ee Au dit Report Sect ion 3.4.2.3.1)Steel , st ainl ess steel , al uminum , and copper al loy pipi ng, pi ping components, and piping elem ents exposed to gas (It em 3.4.1-44)
None None Not Appl icabl e Not applicable. There ar e n o in-s co pe ste el, sta inle ss ste el, aluminum, or cop per all oy pi ping, pipi ng components, and piping elem ents exposed to a gas envi ronment in the Steam and Power Conversi on syst ems at Oyst er Creek. (See Audit Report Sect ion 3.4.2.3.1)3.4.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant stated are consistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA is a cceptable.
In OCGS LRA Se ction 3.4.1.2.1, the applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging effec ts rel ated to the co ndens ate sy stem, co ndens ate tra nsfer sy stem, fee dwat er sy stem, main condense r, main generator an d auxil iary sy stem, main steam sy stem, and main tu rbine and auxi liary sy stem components an d component groups:
*ASME S ection XI Inserv ice Inspecti on, Subsectio ns IWB, IW C, and IWD (B.1.1)
*Water Chemistry (B.1.2) 435*FAC (B.1.11)
*Bolting Integrity (B.1.12)*CCCWS (B.1.14)
*Aboveground Outdoor Tanks (B.1.21)
*One-Time Inspection (B.1.24)*Selectiv e Leaching of M aterials (B.1.2 5)*Buried Pi ping Inspection (B.1.26)*Structures Mo nitoring Program (B.1.3 1)*Lubricating Oil Monitori ng Activiti es (B.2.2)
*Generator Stator Water Chemistry A ctivitie s (B.2.3)*Periodic In spection Program (B
.2.5)Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line-items to determine tha t the applicant (1) provides a brief descri ption of the sy stem, components, materi als, and environment; (2) stated that the applicab le aging effects have been revi ewed and are eval uated in the GALL R eport; and (3) iden tifies those aging effec ts for the conde nsate syste m, conde nsate transfer syste m, feedw ater sy stem, ma in co ndens er, mai n gener ator an d aux ilia ry system, main ste am system, and main turbine and auxi liary sy stem components tha t are subject to an AMR.
Loss of Materi al Due to P itting and Crev ice Corrosi on In the OCGS LRA , Table 3.4.2.1.6 for the main steam sy stem included AMR l ine items for lo ss of materi al du e to pi tting a nc crev ice co rrosio n for car bon an d low allo y ste el co mponen ts exposed to steam internal.
The applica nt proposed to manage this aging effect by crediting the OCGS Water Chemistry Program (AM P B.1.2) together w ith the OCGS One-Ti me Inspection Program (AMP B
.1.24). In plan t specific notes to Table 3.4.2.1
.6 in the OCGS LRA, the applicant s tated that the One-Ti me Inspection P rogram was appl ied in ad dition to th e GALL Repo rt r ecom mend ed pr ogr am f or th is ag ing e ff ect. Gene ric no te E was cite d fo r the se AMR line items, indicating th at the material , environmen t, and aging effect were consistent w ith the GALL R eport; howe ver, a differen t aging m anageme nt progr am wa s credi ted. Th e GALL Repor t recomme nded t he Water Che mistry Program (XI.M2) alon e to man age thi s aging effect.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2), veri fied that this p rogram w as con sisten t wi th the recomme ndati ons i n the GA LL Rep ort for A MP XI.M2. Therefore , the p roject t eam det ermine d that the ap plic ant's propo sed i nclus ion o f the One-Time Inspection Pro gram, in additio n to the GALL re commended program, w ill prov ide additi onal assurance that th is aging effect wil l be adequatel y managed, and was accep table.On the basis o f its review , the project team found that the appl icant appropri ately add ressed loss of material due to pitting and c revice corro sion for steel c omponents in a steam internal environment in the steam a nd power conversion systems.Conclusio n The project team has evaluated the appli cant's claim o f consistency with the GALL Report. The project team also has revi ewed in formation pertaini ng to the appli cant's conside ration of recent operat ing ex perie nce an d prop osals for mana ging ass ociat ed agi ng effects.
On the basi s of its 436 review , the project team found that the AM R results, w hich the app licant cla imed to be consi stent w ith th e GALL Repor t, are c onsis tent w ith th e AM Rs in the GA LL Rep ort.3.4.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In OCGS LRA Se ction 3.4.2.2, th e applica nt provide d further evalu ation of aging management as reco mmended by th e GALL Repor t for the conde nsate syste m, cond ensate transfer syste m, feedwa ter sy stem, ma in co ndens er, mai n gener ator an d aux ilia ry sy stem, ma in ste am sys tem, and main turbi ne and aux iliary system componen ts and componen t groups. The appl icant also provided information concern ing how i t will manage the relate d aging effects.
Project Team Eval uation For some AM R line-ite ms assigned to the project team in Table 3.4.1 of the OC GS LRA, the GALL Report reco mmends further eval uation. When further evalua tion was recommended, the project team revi ewed these further evalua tions provi ded in OCGS L RA Section 3.4.2.2 against the criteria p rovided i n the SRP-LR Section 3.4
.2.2. The project tea m's assessments o f these evaluati ons is docu mented in thi s section. Thes e assessments are applicab le to each Table 2 AMR li ne-item in Se ction 3.4 ci ting the item in Table 1.3.4.2.2.1 Cumu lati ve F atig ue D amage In LRA Secti on 3.4.2.2.1, the ap plic ant sta ted tha t fatigue is a TLAA, a s defin ed in 10 CF R 54.3. Appli cants m ust ev aluat e TLAAs in ac cordan ce wi th 10 C FR 54.21(c)(1).The project team noted that the OCGS LR A contains n umerous AMR line ite ms with reference s to TLAAs. All but a few ci te cumulativ e fatigue damage as the aging effect requiring management, howev er it is no t clear wh ether a CLB fatigue analysi s actually exists or whether the TLAA is a ddressed by the assumed 7,0 00 cycles in accordan ce with B31.1 or equiv alent design methods. The applicant was asked to identify the applicable disposition for each T LAA line item re lated to cumul ative fatigue d amage of mechanical components.
In its response, the applicant stat ed that there are two categor ies of fatigue TLAAs identified in the AMR tables. The first categ ory is for components f or which an explicit fatigue analysis exists, such as one performed i n accordance with AS ME Secti on III, Class 1 rules (or equivalent), with an associated Cumulative Usage Factor (CUF) value. The second category is for components that were designed in accordance with implicit fatigue design rules from ANSI B31.1 (or equiv alent). The app licant prov ided a tabl e that identi fies whether a system or compon ent ha s an e xpli cit (E) or im plic it (I) fa tigue a naly sis as socia ted w ith i t.The app lica nt furthe r state d that, for li cense renew al, ad ditio nal e xpli cit fati gue ana lyse s wer e prepared to consider the ef fects of environm ental fatigue f or the components identif ied in NUREG/CR-6260. These com ponents are denoted in the table as also having an explicit environmenta l (E-env) fati gue analysi s in addi tion to the o riginal anal ysis. The c omponents within each system b ounded by the appli cable env ironmental fatigue analysi s are also d enoted with a (E-env) in th e table.
437 The applican t further stated that the table als o include s a column d enoting the di sposition method used t o manage the TLA A for the perio d of ex tended opera tion. The no tation (I)indicates th e existi ng analysi s was dete rmined to remain valid for the period of ex tended operation. The notation (ii) indicates the analy sis was revised to become val id for the perio d of extended o peration. The n otation (ii i) indica tes fatigue monitorin g will be used to as sure the fatigue analysi s will remain val id during the period of exte nded operatio n or wil l be reanal yzed as necess ary p rior to exce eding the de sign l imit.The project team rev iewed th e applica nt's response, along with the table th at identifies whether the TLA As are impli cit or expl icit, and fou nd it accept able since it cl arifie s whi ch TLAA s are based on an explici t calculati on.The evaluation of the TLAAs was perf ormed by NRR/DE staff and is addres sed separately in Section 4 of the SER related to the OCG S LRA 3.4.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion 3.4.2.2.2.1 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 1]The project team rev iewed OC GS LRA Secti on 3.4.2.2.2.1 agai nst the criteri a in SRP-L R Section 3.4.2.2
.2.1.SRP-LR Secti on 3.4.2.2.2.1 state d that loss o f material due to general, pittin g and crevic e corrosion cou ld occur for steel piping, pip ing components, pi ping elements, ta nks, and heat exchanger compo nents expos ed to treated w ater, and for steel piping, pipi ng components, and piping eleme nts exposed to steam. The ex isting aging management program relies on monito ring an d cont rol of w ater ch emistry to mana ge the e ffects of l oss of ma terial due to general, pittin g, and crevic e corrosion.
Howeve r, control of w ater chemistry does not precl ude loss of material due to general , pitting, and c revice corro sion at lo cations of stagnant flow conditions.
Therefore, the effectivenes s of the water chemistry con trol program shoul d be verified to e nsure that corrosi on is not o ccurring. The GALL Report recommends further eval uatio n of pro grams to veri fy the effectiv eness of the w ater ch emistry contro l progr am. A one-ti me ins pecti on of se lect c ompone nts an d susc eptib le lo catio ns is an acc eptabl e metho d to ensure that corros ion is no t occurring and th at the component's intended functi on wil l be maintained d uring the perio d of extended operation.
In the OCGS LR A Sect ion 3.4.2.2.2.1, th e appl icant addre ssed th e los s of mate rial due to general, pittin g, and crevic e corrosion o f steel and al uminum pipi ng, piping compone nts, and pipi ng ele ments e xpos ed to t reated wate r, for ste el he at ex changer shel l sid e compo nents exposed to treated water, and for steel pi ping, piping co mponents, and pi ping elements e xposed to steam. The OCGS LR A stated that Oy ster Creek wi ll impleme nt a One-Time Inspec tion Program, B.1.24 , for sus cepti ble l ocati ons to veri fy the effectiv eness of the Water Ch emistry Program, B.1.2, to manage th e loss of materia l in steel and alumin um piping, pi ping components, and piping eleme nts exposed to a treated w ater enviro nment, steel hea t exchanger components ex posed to steam o r a treated w ater enviro nment, and steel piping, pip ing compon ents, a nd pi ping e lement s exp osed t o a ste am env ironme nt in the co ndens ate sy stem, conde nsate transfer syste m, feedw ater sy stem, ma in ste am sys tem, mai n turbi ne and auxi liary system, emergency service w ater system, reac tor buildi ng closed cool ing water sy stem, and heating and pro cess steam sys tem. Observed c onditions th at have the potential for impacting an intended function are ev aluated or co rrected in acc ordance wi th the correctiv e action process.
438 The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude d acti viti es tha t monit or and contro l wa ter che mistry to mana ge the e ffects of l oss of ma terial due to genera l, pi tting, a nd cre vice corros ion. In addition, the project team ve rified that the One-Time Inspection Program (AMP B
.1.24) includ ed inspection activiti es to veri fy the effectiveness of the Water Chemistry Program to mana ge loss of materi al du e to gen eral, pitti ng, and crev ice co rrosio n at l ocati ons of s tagnant flow condi tions. The pro ject tea m deter mined that th ese AM Ps w ill adequa tely manage loss o f materia l due to general, pittin g and crevic e corrosion for ste el pipin g, piping componen ts, piping el ements, tanks, and heat ex changer components exposed to treated water and for steel pi ping, piping compon ents, a nd pi ping e lement s exp osed t o stea m.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.2.1 for further ev aluation.3.4.2.2.2.2 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
[Item 2]The project team rev iewed OC GS LRA Secti on 3.4.2.2.2.2 agai nst the criteri a in SRP-L R Section 3.4.2.2
.2.2.SRP-LR Secti on 3.4.2.2.2.2 state d that loss o f material due to general, pittin g and crevic e corros ion c ould occur fo r steel pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to lubricating o il. The ex isting aging management program relies on the periodi c sampling and analysi s of lubricatin g oil to main tain contamina nts withi n acceptable limits, there by preserv ing an env ironme nt that is no t cond uciv e to co rrosio n. How ever, contro l of lu be oi l con tamina nts may not alw ays hav e been adequate to preclude corrosion. Therefore, th e effectiveness of lub rica ting oil con tami nant con trol sho uld be v erifi ed to ens ure t hat c orro sio n is not occu rrin g.The GALL Report re commends further eva luation of programs to manage corrosion to verify the effectiveness of the l ube oil c hemistry contro l program. A one-time inspecti on of selected components at su sceptible l ocations is an acceptabl e method to ensu re that corrosio n is not occurring and tha t the component's intended functio n will be maintain ed during the p eriod of extended o peration.In the OCGS LRA Section 3.4.2.2.
2.2, the applicant addressed loss of material due to general, pitting and cre vice corros ion for steel p iping, pipi ng components, and piping eleme nts exposed to lub rica ting oil or stea m. T he OC GS LR A sta ted t hat a One-Tim e Ins pect ion Pr ogr am (A MP B.1.24 wi ll be impl emented for suscepti ble locati ons to veri fy the effectiveness of the lubrica ting oil monitoring activities program (AMP B.2.2) to manage the loss of m aterial due to general, pitting and cre vice corros ion for steel p iping, pipi ng components, and piping eleme nts exposed to lub ricati ng oil inter nal e nvir onment in the conde nsate syste m, cond ensate transfer syste m, feedwater sy stem, main steam sy stem, main turbin e and aux iliary system, emergency service water sys tem, reactor buil ding closed cooling w ater system, and heating and p rocess steam system. The lu bricating oil monitoring acti vities p rogram manages the phy sical and chemical properties of lu bricating oil by sampli ng, testing, and trendi ng to identify specific we ar mechanisms, conta mination, and oil degradati on that could affect intended functio ns. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram (AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage the loss of material due to general, pitti ng and crevi ce corrosion for steel pipi ng, piping components, and piping eleme nts exposed to lubricati ng oil intern al envi ronment. The techni cal 439 evaluation of this program to determine its adequacy was perfor med by NRC DE staff, and is addres sed i n the S ER rel ated to the Oy ster Cr eek pla nt.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.2.2 for further ev aluation.3.4.2.2.3 Loss of Material Due to Gener al, Pitt ing, Cr evice, and Microbiolog ically-Influenced Corrosi on and Foul ing In Section 3.4.2.2.3 of the OCGS LRA, the applicant stated that loss of material due to genera l, p i t t i n g, c r e v i c e , a n d M I C , a n d fo u l i n g o f s t e e l c o m p o n e n t s e x p o s e d t o r a w w a t e r i n a P WR auxili ary feedwate r system is a pplicabl e to PWRs only. The proje ct team concurred with the appli cant's eva luati on tha t this aging e ffect is n ot app lica ble s ince Oyster Creek i s a BWR pla nt.3.4.2.2.4 Reduction o f Heat Transfer Due to Fo uling 3.4.2.2.4.1 Reduction o f Heat Transfer Due to Fo uling [Item 1]
The project team noted that the appl icant did not credit the GALL Report AM R for reduction o f heat tr ansfer d ue to fo ulin g for stai nless steel or cop per al loy heat e xcha nger tub es ex posed to treated water, which i s associated with thi s further evalu ation, for the Oys ter Creek steam and power conv ersion sys tems.The project team rev iewed Tabl es 3.4.2.1.1 through 3.4.2.1.7 in the OCGS LRA for the s team and powe r conversio n systems and noted that thi s component group/en vironment co mbination was not i dentified as b eing in the s cope of licen se renewal. Therefore, the project te am dete rmin ed th at th is fu rthe r ev alu atio n is not appl ica ble to Oy ster Cre ek.3.4.2.2.4.2 Reduction o f Heat Transfer Due to Fo uling [Item 2]
The project team noted that the appl icant did not credit the GALL Report AM R for reduction o f heat transfer due to fouling for steel, stai nless steel , and copper a lloy he at exchanger tu bes exposed to lubricating o il, whi ch is associ ated with this further ev aluation, for the Oyster Creek steam a nd pow er con versi on sy stems. This w as a n ew A MR th at wa s not i n the d raft Janu ary 2005 GA LL Rep ort.The project team rev iewed OC GS LRA Table 3.3.2.1.13 for the emergency diesel gene rator and auxili ary system, Table 3.3.2.1.15 for the fire protection system, and Tabl e 3.3.2.1.29 for the RBCC W system and noted that th e appl icant iden tified coppe r all oy co mponen ts ex posed to lubricating o il for whi ch the lubri cating oil mon itoring activ ities program (AM P B.2.2) wa s credited to manage reductio n of heat transfer. Generi c Note G wa s cited ind icating that the environment was n ot in GALL for that c ompone nt and materi al, th erefore, these AMR line items were revi ewed by N RC DE staff and are ad dresse d in t he SE R for the Oyste r Cree k plant.
440 3.4.2.2.5 Loss of Material Due to Gener al, Pitt ing, Cr evice, and Microbiolog ically Influenced Corrosi on 3.4.2.2.5.1 Loss of Material Due to Gener al, Pitt ing, Cr evice, and Microbiolog ically Influenced Corrosi on [Item 1]
The applican t addressed l oss of material d ue to general, p itting, crevi ce and M IC in steel compon ents e xpos ed to s oil i n OCGS Secti on 3.4.2.2.5.2, in accord ance w ith th e draft J anuary 2005 SRP-LR. Therefore, the project te am review ed OCGS LRA S ection 3.4.2.2.5
.2 against the criteria in SRP-LR Secti on 3.4.2.2.5.1.
SRP-LR Secti on 3.4.2.2.5.1 state d that loss o f material due to general, pittin g and crevic e corrosion, and MIC coul d occur in s teel (wi th or with out coating or w rapping) pipi ng, piping components, pip ing elements an d tanks expose d to soil.
The buried pi ping and tanks i nspection program r elie s on i ndustr y pra ctice, frequenc y of pi pe ex cava tion, and op eratin g expe rienc e to manage the effects of loss of materi al from general corros ion, pittin g and crevic e corrosion, a nd MIC. The effect iven ess of th e buri ed pi ping a nd tan ks insp ectio n progra m shoul d be v erifie d to evaluate an applic ant's inspecti on frequency and operating exp erience w ith buried components, ensu ring that los s of ma teri al i s no t occ urri ng.In the OCGS LRA Section 3.4
.2.2.5.2, the appl icant addresse d loss of materia l of steel (w ith or without w rapping) pipi ng, piping compone nts, piping el ements and tanks i n soil du e to general pitti ng and crevi ce corr osion , and M IC. The appl icant stated that Oy ster Cr eek wi ll i mpleme nt a burie d pip e ins pecti on pro gram, B.1.26, to manage the lo ss of mat erial in st eel p ipin g expo sed to soil in the heating and process steam sy stem. The Buried Piping Inspec tion Program incl udes preventiv e measures to mi tigate corrosion and periodi c inspectio n to manage the effects of corrosion on the pressure-retai ning capacity of buried steel piping, pip ing components, an d piping eleme nts. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's Buried Piping Inspe ction Program (AM P B.1.26) and verified that this aging management p rogram included inspections to detect los s of material of steel pipi ng, piping compone nts, and pipi ng elements due to general, pitti ng, crevice co rrosion, and MIC.
The project team confirmed that, for each of the materi al/enviro nment combinati ons for which the Buried Pi ping Inspection Program wil l be credi ted, at least o ne inspecti on (opportunistic or focused) has b een, or wi ll be performed p rior to enterin g the extended period of operation, and a focused insp ection wi ll be performed w ithin the 1 0-year peri od after entering the exten ded pe riod o f operat ion. Th e proje ct team's eva luati on is docume nted i n Sect ion 3.3.2.2.8 of this audit and re view report.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.5.1 for further ev aluation.3.4.2.2.5.2 Loss of Material Due to Gener al, Pitt ing, Cr evice, and Microbiolog ically Influenced Corrosi on [Item 2]
The project team noted that the appl icant did not credit the GALL Report AM R for loss of material due to general, pitti ng and crevi ce corrosion, and MIC in steel h eat exchanger components ex posed to lub ricating oil , which is associa ted with this further eva luation, for the Oyster Creek steam a nd power conversion systems.
441 The project team rev iewed Tabl es 3.4.2.1.1 through 3.4.2.1.7 in the OCGS LRA for the s team and po wer c onve rsion syste ms and noted that ot her GAL L AM R lin e items that a ddress same material/env ironment combin ations we re appropriatel y credited.
Therefore, the project tea m dete rmin ed th at th is fu rthe r ev alu atio n is not appl ica ble to Oy ster Cre ek.3.4.2.2.6 Cracking Due to S tress Corrosion Cracking The applican t addressed crac king due to SCC for stainless s teel components exposed to treated wate r or ste am in S ectio n 3.4.2.2.6.1 of the OC GS LRA , in a ccorda nce w ith th e draft J anuary 2005 SRP-LR. Therefore, the project te am review ed OCGS LRA S ection 3.4.2.2.6
.1 against the criter ia in SRP-L R Sect ion 3.4.2.2.6 SRP-LR Secti on 3.4.2.2.6 stated that cracking due to SCC coul d occur in th e stainless steel pipi ng, pip ing com ponen ts, pi ping e lement s, tanks , and h eat ex changer compon ents e xpos ed to treated water greater than 60
/C (>140/F), and for stainl ess steel pi ping, piping co mponents, and piping eleme nts exposed to steam. The ex isting aging management program relies on monitoring and control of water chemistry to manage the ef fects of cr acking due to SCC.
Howeve r, high concentrati ons of impuritie s at crevic es and loca tions of stagnant flow conditions could cause SCC. Therefore, the GALL Report reco mmends that the effectiv eness of the w ater chemis try co ntrol program s hould be v erifie d to en sure th at SCC is no t occur ring. A one-ti me inspe ction of sele cted co mponen ts at su scepti ble l ocati ons i s an a ccepta ble me thod to ensur e that SCC is not occurring an d that the compon ent's intended function wi ll be main tained duri ng the period o f extended ope ration.In the OCGS LR A Sect ion 3.4.2.2.6.1, th e appl icant stated that Oy ster Cr eek wi ll i mpleme nt a One-Time Inspection Program, B.1.24, for susce ptible lo cations to v erify the effectiven ess of the Water Ch emis try Prog ram, B.1.2, to mana ge st ress corr osi on c racki ng of s tain les s ste el p ipi ng, piping compone nts, piping el ements, and cool ers exposed to treated w ater > 140
/F, or expos ed to a steam env ironment in th e feedwater sy stem, heating & pro cess steam sys tem, main steam syste m, isol ation conde nser sy stem, sh utdow n cool ing sy stem, an d main turbi ne aux ilia ry syste m. Obse rved condi tions that h ave t he pot entia l for i mpacti ng an i ntende d functi on are evaluated or corrected i n accordance with the corrective a ction process.
The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill mitigat e cracki ng due to SCC. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging management p rogram includes inspections of the stainle ss steel steam and powe r conversio n system compon ents to detect cra cking as a means o f verifying the effect iveness of the W ater Chemistry Program. The project team det ermined that these AMPs will adequately manage cracking due to SCC f or stainless steel heat exchanger com ponents in the steam and po wer conv ersion sys tems.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.6 for further ev aluation.3.4.2.2.7 Loss of Materi al Due to P itting and Crev ice Corrosi on 3.4.2.2.7.1 Loss of Materi al Due to P itting and Crev ice Corrosi on [Item 1]
The project team rev iewed OC GS LRA Secti on 3.4.2.2.7.1 agai nst the criteri a in SRP-L R Section 3.4.2.2
.7.1.
442 SRP-LR Section 3.4.2.2.7.1 st ated that loss of mate rial due to pitting and crevice corrosion could occur for stainle ss steel, al uminum, and cop per alloy piping, pip ing components a nd piping elements and for stainless stee l tanks and he at exchanger co mponents exp osed to treated water. The ex isting aging management program relies on monitoring and control of wa ter chemistry to ma nage the effects of loss of materi al due to p itting, and crev ice corrosio n.Howeve r, control of w ater chemistry does not precl ude corrosion at location s of stagnant flow conditions.
Therefore, the GALL Re port recommends that the effectiveness o f the Water Chemi stry P rogram sh ould be ve rified to ens ure tha t corro sion is no t occur ring. A one-ti me inspection of select componen ts at susceptib le locati ons is an a cceptable metho d to ensure tha t corrosion is not occurring an d that the compon ent's intended function wi ll be main tained duri ng the period o f extended ope ration.In the OCGS LRA Section 3.4.2.2.
7.1, the applicant addressed loss of material of stainless steel, aluminum, and copper allo y pipin g, piping componen ts and pipi ng elements and for stainless steel tanks a nd hea t exc hanger compon ents d ue to p ittin g and cr evic e corro sion . The OC GS LRA stated tha t Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for suscep tible loca tions to ve rify th e effecti vene ss of the Water Chemi stry P rogram, B.1.2, to manage the loss of material in stainless ste el, pipin g components, pipi ng elements, tanks, and heat exchan ger shell-sid e components ex posed to a trea ted water en vironment i n the conde nsate syste m, feedw ater sy stem, ma in ste am sys tem, mai n turbi ne and auxi liary syste m, and reactor w ater cleanup system. Observ ed conditio ns that have the potential for impacting an intended functio n are eval uated or corrected in accordan ce with the correctiv e action proc ess.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill mitigat e cracki ng due to SCC. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging m anagement prog ram includes inspections of the st ainless steel, aluminum, and copper allo y steam and power conv ersion sys tem components to d etect cracking as a means of v erifying the effectiv eness of the Water Chemistry Pro gram. The project team determined that these AMPs will adequately manage crack ing due to SCC for stainless steel, piping compone nts, piping el ements, tanks, and he at exchanger sh ell-side components ex posed to a treated w ater enviro nment  in the steam and pow er conversi on systems.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.7.1 for further ev aluation.3.4.2.2.7.2 Loss of Materi al Due to P itting and Crev ice Corrosi on [Item 2]
The project team rev iewed OC GS LRA Secti on 3.4.2.2.7.2 agai nst the criteri a in SRP-L R Section 3.4.2.2
.7.2.SRP-LR Section 3.4.2.2.7.2 st ated that loss of mate rial due to pitting and crevice corrosion could occur for stainle ss steel pi ping, piping co mponents, and pi ping elements e xposed to soil. The GALL R eport r ecommen ds furthe r eva luati on of a plant-speci fic agin g manageme nt to e nsure that this aging effect is adequately man aged.In the OCGS LRA Section 3.4
.2.2.7.2, the appl icant addresse d loss of materia l of stainles s steel pipi ng, pip ing com ponen ts, and pipi ng ele ments d ue to p ittin g and cr evic e corro sion. The OC GS LRA st ated th at Oys ter Cre ek wi ll i mpleme nt a Bu ried P ipin g Inspec tion P rogram, B.1.26, to manage the loss of material in stainless ste el pipin g exposed to soil in the heating and process steam s ystem. The Bu ried P ipin g Inspec tion P rogram i nclud es pre venti ve mea sures t o miti gate 443 corrosion and periodic inspection to manage the effects of corrosio n on the press ure-retaining capacity o f buried stainl ess steel pi ping. Observed conditions that have the potential for impact ing an int ended f unction are evaluat ed or cor rected in accord ance with th e corre ctive action process
.The project team rev iewed th e applica nt's Buried Piping Inspe ction Program (AM P B.1.26) and verified that this aging management p rogram included inspections to detect los s of material of stainless ste el pipin g due to pittin g and crevic e corrosion.
The project team confirmed that, for each of the materia l/environ ment combinatio ns for which the Buried P iping Inspecti on Program will be credited, a t least one i nspection (op portunistic o r focused) has bee n, or wil l be performed prior to enteri ng the extende d period of ope ration, and a focused inspecti on wil l be performed within the 10-year period after entering the extended period of operation. The project team's eval uatio n is d ocumen ted in Secti on 3.3.2.2.8 of this audit and re view report.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.7.2 for further ev aluation.3.4.2.2.7.3 Loss of Materi al Due to P itting and Crev ice Corrosi on [Item 3]
The applican t addressed l oss of material d ue to pittin g and crevic e corrosion for co pper alloy compon ents e xpos ed to l ubric ating o il i n Sect ion 3.4.2.2.9 of the OCGS L RA, i n acco rdance wit h the draft January 2005 SRP-LR. T herefore, the project team reviewed OCGS LRA Section 3.4.2.2
.9 against the cri teria in SR P-LR Section 3.4.2.2.7.3.
SRP-LR Section 3.4.2.2.7.3 st ated that loss of mate rial due to pitting and crevice corrosion could occur fo r copp er all oy pi ping, p ipin g compon ents, a nd pi ping e lement s exp osed t o lub ricati ng oil. The existin g aging management program reli es on the peri odic sampli ng and analy sis of lubricating o il to mainta in contamina nts withi n acceptable limits, there by preserv ing an environment that is not co nducive to corrosion.
Howeve r, control of lub e oil con taminants may not alwa ys have been adequate to preclude c orrosion. Therefore, the effectiveness of lub rica ting oil con tami nant con trol sho uld be v erifi ed to ens ure t hat c orro sio n is not occu rrin g.The GALL Report re commends further eva luation of programs to manage corrosion to verify the effectiveness of the l ube oil c hemistry contro l program. A one-time inspecti on of selected components at su sceptible l ocations is an acceptabl e method to ensu re that corrosio n is not occurring and tha t the component's intended functio n will be maintain ed during the p eriod of extended o peration.In the OCGS LRA Section 3.4
.2.2.9, the appl icant stated th at this li ne item is n ot used at Oy ster Creek. At Oyster C reek, there are no i n-scope copper alloy p iping, pipi ng components, and piping eleme nts in a l ubricating oi l enviro nment in the s team and pow er conversi on systems.
The project team rev iewed Tabl es 3.4.2.1.1 through 3.4.2.1.7 in the OCGS LRA for the s team and powe r conversio n systems and verified tha t no copper al loy pip ing, piping comp onents, or piping eleme nts were i dentified in the scope of li cense renew al. Therefore, the pro ject team concurred w ith the appl icant's con clusion tha t this further ev aluation i s not appli cable to Oy ster Cree k.
444 3.4.2.2.8 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion The project team rev iewed OC GS LRA Secti on 3.4.2.2.8 agai nst the criteri a in SRP-L R Section 3.4.2.2
.8.SRP-LR Section 3.4.2.2.8 stat ed that loss of material due to pitt ing, crevice, and MIC could occur in stai nless steel piping, pip ing components, pi ping elements, a nd heat ex changer components ex posed to lub ricating oil. The existi ng aging management program reli es on the periodic sampling and analysis of lubricating oil to mainta in contaminants within acceptable limits, thereby preservin g an environ ment that is not conducive to corrosion.
Howev er, control of lube oil contaminants may not alw ays hav e been adequate to preclude corrosion. Therefore, th e effect iveness of lubricating oil contaminant cont rol should be verified to ensure that corros ion is not o ccur ring. The GALL Rep ort r ecom mend s furt her e val uati on o f prog rams to ma nage corros ion to veri fy the effectiv eness of the l ube oi l che mistry contro l progr am. A o ne-tim e inspe ction of sele cted co mponen ts at su scepti ble l ocati ons i s an a ccepta ble me thod to ensur e that corrosion is not occurri ng and that the c omponent's inten ded function w ill be mai ntained during the peri od of extended operation.
In the OCGS LRA Section 3.4
.2.2.8, the appl icant addresse d loss of materia l of stainles s steel pipi ng, pip ing com ponen ts, and pipi ng ele ments d ue to p ittin g, crev ice, a nd M IC. The OCGS LRA stated tha t Oyster Creek w ill impl ement a One-Time Inspe ction Program, B.1.24 , for susceptible locations to verify the effectiveness of the lubricating o il monitori ng activiti es program, B.2.2, to manage the loss of material in stainl ess steel pi ping, piping co mponents, and pipi ng ele ments e xpos ed to l ubric ating o il i nterna l env ironme nt in the mai n turbi ne and auxi liary system. The lu bricating oil monitoring acti vities p rogram manages physi cal and che mical properties of lu bricating oil by sampli ng, testing, and trendi ng to identify specific we ar mechanisms, conta mination, and oil degradati on that could affect intended functio ns. Observed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordanc e with th e corrective action proce ss.The project team rev iewed th e applica nt's further eva luation an d determined th at the lubri cating oil mo nitori ng acti viti es pro gram (AM P B.2.2) is a pla nt spe cific p rogram th at is approp riate to manage t he lo ss of mat erial in st ainl ess ste el pi ping, p ipin g compon ents, a nd pi ping e lement s expo sed to lubri catin g oil intern al en viro nment. The tech nical eval uatio n of thi s progra m to determi ne its adequa cy w as per formed by NRC D E staff, an d is a ddress ed in the SE R rela ted to the Oy ster Cr eek pla nt.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.8 for further ev aluation.3.4.2.2.9 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Galvani c Corrosion The applican t addressed l oss of material d ue to general, p itting, crevi ce, and galv anic corrosi on for steel heat ex changer components in OCGS LRA Section 3.4.2.2
.2.1, in accord ance wi th the draft January 2005 GALL Report. Therefore, the project team reviewed OCGS LRA Section 3.4.2.2
.2.1 against the c riteria in SRP-LR Secti on 3.4.2.2.9.
SRP-LR Secti on 3.4.2.2.9 stated that loss of materi al due to gene ral, pitting, crev ice, and galva nic co rrosio n can occur fo r steel heat e xcha nger com ponen ts ex posed to trea ted w ater.The ex istin g aging ma nagemen t progra m reli es on monito ring an d cont rol of w ater ch emistry to 445 manage t he effects of loss of materi al du e to gen eral, pitti ng, and crev ice co rrosio n. How ever, control of wa ter chemistry d oes not precl ude loss of materi al due to gene ral, pitting, an d crevice corrosion at l ocations of stagnant flow condi tions. Therefore, the effectiveness of the w ater chemistry con trol program shoul d be veri fied to ensure tha t corrosion i s not occurrin
: g. The GALL Report reco mmends further eval uation of programs to v erify the effectiven ess of the wate r chemistry control progr am. A one-time inspection of select components and susceptible locations i s an acceptab le method to e nsure that corrosi on is not o ccurring and that the component's inte nded function w ill be mai ntained duri ng the period o f extended ope ration.In the OCGS LRA Section 3.4
.2.2.2.1, the appl icant addresse d loss of materia l of steel and aluminum pi ping, piping co mponents, and pi ping elements due to general, pitting, and crev ice corrosion. The OC GS LRA stated that Oyster Cree k will i mplement a One-Time In spection Program, B.1.24 , for sus cepti ble l ocati ons to veri fy the effectiv eness of the Water Ch emistry Program, B.1.2, to manage th e loss of materia l in steel and alumin um piping, pi ping components, and piping eleme nts exposed to a treated w ater enviro nment, steel hea t exchanger components ex posed to a ste am or treated w ater enviro nment, and steel piping, pip ing compon ents, a nd pi ping e lement s exp osed t o a ste am env ironme nt in the co ndens ate sy stem, conde nsate transfer syste m, feedw ater sy stem, ma in ste am sys tem, mai n turbi ne and auxi liary system, emergency service w ater system, reac tor buildi ng closed cool ing water sy stem, and heati ng and proces s steam syste m. The On e-Time I nspect ion P rogram al so wi ll be used to verify the e ffectiveness of the Water Chemistry P rogram to manage the lo ss of material i n steel shell and shell si de components e xposed to a treated wa ter environ ment in the i solation condenser sy stem. Observed conditions that have th e potential for impacting an i ntended function are ev aluated or co rrected in acc ordance wi th the correctiv e action proc ess.The project team rev iewed th e applica nt's Water Chemistry Program (AM P B.1.2) and v erified that th is agi ng manage ment pr ogram in clude activ ities that w ill manage l oss of ma terial due to general , pitti ng, crev ice, a nd gal vani c corro sion for steel heat e xcha nger com ponen ts. In addition, the project team rev iewed th e applica nt's One-Time Inspe ction Program (B.1.24) and verified that this aging management p rogram includes inspections to detect cracking a s a means of verifying the effectiveness of the Water Chemistry Program. The project team d etermined that th ese AM Ps w ill adequa tely manage loss o f materia l for ste el he at ex changer compon ents exposed to a treated wa ter environ ment in the stea m and powe r conversio n systems.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.4.2.2.9 for further ev aluation.3.4.2.2.10 Quali ty As suranc e for Agi ng Ma nagemen t of Non-Safety-Rela ted Co mponen ts OCGS LRA Section 3.4.2.2.10 was reviewed by NRR/DE staff and was addressed sepa rately in Section 3 of the SER related to the OCG S LRA.Conclusio n On the basis o f its review , for component groups e valuated in the GALL R eport for whic h the GALL Report reco mmends further eval uation, the pro ject team determined that the appl icant adequately a ddressed the i ssues that w ere further eval uated.
446 3.4.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Summary of Information i n the Appli cation In OCGS LRA Tabl e 3.4.1, Summary of Aging Management E valuatio ns for the Steam and Power Co nversion System, the ap plicant prov ided information regarding components or material/env ironment combin ation in th e GALL Report that it eva luated and identified as not appli cable to its plan t.In OCGS LRA Tabl es 3.4.2.1.1 through 3.4.2.1.7, the app licant prov ided addi tional deta ils of the resu lts o f th e AMRs f or ma ter ial, e nviro nmen t, ag ing e ff ect r equ iring mana gem ent, and AMP combinations that are not con sistent wi th the GALL Re port. Specifica lly, the applicant i ndicated, via Notes F through J, that neither the i dentified compon ent nor the materi al/ envi ronment combination is eval uated in the GALL Report a nd provid ed information co ncerning how the aging effect requiring management wi ll be managed
.Project Team Eval uation The project team reviewed additional details of the results of the AMRs for mat erial, environment, aging effect requiring management, and AMP co mbinations tha t the appli cant ident ified as not havi ng any aging e ffect, or a s not a ppli cable to its plan t.The project team did not revie w the resul ts of the AMR s for material, env ironment, aging effect requiring management, and AMP co mbinations tha t are not consi stent with the GALL Repo rt or are no t ad dre sse d i n th e GA LL Rep ort. Th ese AM R l in e i tem s w ere rev ie we d b y N RR/DE sta ff, and are discussed in the SER related to the OCGS LRA.
3.4.2.3.1 Aging E ffect/Me chani sm in Ta ble 3.4.1 Tha t Are N ot App lica ble for OCGS The project team rev iewed OC GS LRA Table 3.4.1, whic h provide s a summary of agin g management eval uations for the ste am and pow er conversi on system ev aluated in the GALL Report.In OC GS LR A Tab le 3.4.1 , Ite m 3.4.1-1 4, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevi ce and galv anic corros ion for coppe r all oy pi ping, p ipin g compon ents, a nd pi ping e lement s exposed to closed-cycl e cooling w ater is not ap plicable at OCGS. There are no in-scope copper alloy c omponents ex posed to clo sed cycle cooling w ater in the ste am and pow er conversi on sys tems at Oy ster Cre ek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1 through 3.4.2.7 in t he OCGS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope cop per alloy components ex posed to clo sed cycle cooling w ater. Therefore, the projec t team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
447 In OCGS LRA Ta ble 3.4.1, It em 3.4.1-15, th e appl icant stated that l oss of ma terial due to selec tive leac hing for coppe r all oy >1 5% Zn p ipin g, pipi ng compo nents, and p ipin g eleme nts exposed to closed-cycl e cooling w ater or raw water is n ot applicab le at OCGS. There are no in-scope cop per alloy components ex posed to clo sed cycle cooling w ater or raw water in the steam a nd pow er con versi on sy stems a t Oyste r Cree k, exce pt the main c onden ser tub eshee t. In the LRA, ap plicant state d that based o n past precede nce (NUREG-179 6, Dresden an d Quad Ci tie s S ER, Se cti on 3.4.2.4.4 an d N URE G-1 769 , Pe ach Bo tto m SE R, S ect io n 3.4.2.3), t he sta ff concluded th at the main co ndenser integri ty is conti nually verified duri ng normal plan t operation and no aging mana gement program is required to assure the post-accident i ntended function.
The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-sco pe cop per al loy >15% Zn compon ents e xpos ed to c losed cycl e cool ing w ater or raw wate r. Therefore, the project team c oncurred wi th the appli cant's concl usion that thi s aging effect is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.4.1, Item 3.4.1-18 , the appli cant stated that re duction of heat transfer due to fouling for stainl ess steel he at exchanger tu bes expose d to closed-c ycle cool ing water i s not applicabl e at OCGS. There are no in-scope stainless steel heat ex changer tubes ex posed to a closed cy cle cooli ng water env ironment wi th a heat transfer i ntended function in the steam a nd pow er co nve rsio n sy stem s at Oys ter C reek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope stai nless steel heat exch anger tubes ex posed to clo sed cycle cooling w ater. Therefore, the project team conc urred with the applicant's conclusion that this aging effect is not applicable to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.4.1 , Ite m 3.4.1-1 9, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevice, an d MIC for stai nless steel heat exch anger tube side components ex posed to raw water is not appl icable at OCGS. There are no in-scope stai nless steel heat exch anger tube side comp onen ts ex pose d to a raw wa ter e nvi ronm ent a t Oy ster Cre ek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-sco pe sta inle ss stee l hea t exc hanger tube s ide c ompone nts ex posed to raw wate r. Therefore, the project team c oncurred wi th the appli cant's concl usion that thi s aging effect is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
448 In OCGS LRA Tabl e 3.4.1, Item 3.4.1-20 , the appli cant stated that c racking due to stress corros ion c racking for stai nless steel pipi ng, pip ing com ponen ts, and pipi ng ele ments e xpos ed to steam is not applicable at OCGS. This item applies to the main steam system of a PW R, and is not a ppl ica ble to Oy ster Cre ek.The project team concurred with the applicant's conclusion that this item applies to the ma in stea m sy stem of a P WR, and is n ot ap pli cabl e to Oys ter C reek.In OCGS LRA Tabl e 3.4.1, Item 3.4.1-21 , the appli cant stated that re duction of heat transfer due to fouling for stainl ess steel he at exchanger tu bes expose d to treated w ater is not ap plicable at OCGS. There are no in-scope stai nless steel heat exch anger tubes ex posed to a trea ted water envi ronmen t wi th a he at tran sfer int ended functio n in t he ste am and powe r conv ersio n sys tems at Oy ster Cre ek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope stai nless steel heat exch anger tubes ex posed to treated water. Therefore, th e project team concurred w ith the appl icant's con clusion tha t this aging effect is no t applicabl e to Oyster Cree k.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OC GS LR A Tab le 3.4.1 , Ite m 3.4.1-2 2, th e ap pli cant stat ed th at l oss of mat eria l du e to pitt ing, crevice an d MIC for stai nless steel and copper a lloy pi ping, piping co mponents, and pi ping elements ex posed to raw water is not applica ble at OCGS. The re are no in-scope stainl ess steel or cop per al loy compon ents e xpos ed to r aw w ater i n the s team an d pow er con versi on sy stems at Oyster Creek, ex cept the main condenser tube sheet. Based on past preced ence (NUREG-1796, D resden and Quad Cities SE R, Section 3
.4.2.4.4 and NU REG-1769, Peach Bottom SER, Section 3.4.2.
3), the staff concluded that the main condenser integ rity is continuall y verifie d during normal plant operati on and no a ging management program is re quired to assure the p ost-accident i ntended function.
The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1 through 3.4.2.7 in t he OCGS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope stai nless steel or copper al loy pip ing, piping comp onents, and pi ping elements e xposed to raw water. Therefore, the project team concur red with the applicant's conclusion that this agin g effec t is not appl ica ble to Oy ster Cre ek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Ta ble 3.4.1, It em 3.4.1-25, th e appl icant stated that l oss of ma terial due to general, pittin g, crevice an d MIC for steel heat exch anger tube side components ex posed to raw water is n ot applicab le at OCGS. There are no in-sco pe steel hea t exchanger tub e side comp onen ts ex pose d to raw wa ter a t Oy ster Cre ek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1 through 3.4.2.7 in t he OCGS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no 449 in-scope steel heat exch anger tube side components ex posed to raw water. Therefore, th e project team co ncurre d wi th the appli cant's conc lusi on tha t this aging e ffect is n ot app lica ble to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.4.1, Item 3.4.1-28 , the appli cant stated that re duction of heat transfer due to fouling for steel a nd stainles s steel heat exchanger tube s exposed to raw w ater is not applicabl e at OCGS. There are no in-scope steel or stai nless steel heat exch anger tubes exposed to a raw w ater enviro nment in the s team and pow er conversi on systems at Oyster Cree k.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope steel or stainles s steel heat exchanger tube s exposed to raw w ater. Therefore, the project team co ncurre d wi th the appli cant's conc lusi on tha t this aging e ffect is n ot app lica ble to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.4.1, Item 3.4.1-33 , the appli cant stated that s teel pipi ng, piping components, and piping eleme nts exposed to air-indo or controlled (external) is not appl icable at OCGS. C ontrol led a ir env ironme nts are not cr edite d at Oy ster Cr eek. Co mponen ts are eval uated as par t of the uncon troll ed in door a ir env ironme nt.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no steel pipi ng, piping compone nts, or pipin g elements exp osed to an ai r-indoor control led (external) e nvironment.
Therefore, the project team c oncurred wi th the appli cant's concl usion that thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.4.1, Item 3.4.1-34 , the appli cant stated that s teel and stai nless steel pipi ng, pip ing com ponen ts, and pipi ng ele ments i n conc rete i s not a ppli cable at OCGS. There are no in-sco pe steel or s tainless ste el pipin g, piping componen ts, and pipi ng elements in a conc rete env iron ment in t he s team and pow er co nve rsio n sy stem s at Oys ter C reek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no steel or stai nless steel piping, pip ing components, or piping eleme nts in concre te. Therefore, the project team conc urred with the applicant's conclusion that this aging effect is not applicable to Oy ster Cre ek.
450 On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Table 3.4.1, It em 3.4.1-35, the applicant st ated that steel, stainless steel, aluminum, and copper alloy piping, piping component s, and piping elements exposed to gas is not applica ble at OCGS. The re are no in-scope steel, s tainless ste el, aluminu m, or copper al loy piping, pipi ng components, and piping eleme nts exposed to a gas env ironment in th e steam and pow er co nve rsio n sy stem s at Oys ter C reek.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-scope steel , stainless steel, alumi num, or copper al loy pip ing, piping comp onents, or pip ing elements ex posed to a gas environment.
Therefore, the project tea m concurred w ith the appl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
In OCGS LRA Tabl e 3.4.1, Item 3.4.1-36 , the appli cant stated that s teel, stainl ess steel an d copper allo y pipin g, piping componen ts, and pipi ng elements ex posed to lub ricating oil (no water pooling) is not applica ble at OCGS. L ubricating oi l (no wa ter pooling) i s not credited at Oyster Creek. Compon ents a re ev aluat ed as part of t he lu brica ting oi l env ironme nt.The pro ject tea m revi ewed the AM R lin e items in Tab les 3.4.2.1.1 throu gh 3.4.2.1.7 i n the OC GS LRA for the steam a nd power conversion systems, and determined that Oyster Creek has no in-sco pe ste el, st ainl ess ste el or coppe r all oy pi ping, p ipin g compon ents, o r pipi ng ele ments exposed to a lubricati ng oil (no w ater poolin g) environment.
Therefore, the project team conc urre d w ith the a ppl ica nt's con clu sio n tha t thi s agi ng effe ct i s no t app lic abl e to Oys ter C reek.On the basis th at none of the co mponent groups add ressed in thi s AMR a re in the sco pe of license ren ewal, the project team found tha t, for this component group, this aging effect is n ot applicable to OCGS.
3.4.2.3.2 Steam and Pow er Conversi on System A MR Lin e Items That Hav e No Aging Effect (OCGS LRA Tables 3.4.2.1.1 Through 3.4.2.1.7
)In OCGS LRA Tabl es 3.4.2.1.1 through 3.4.2.1.7, the app licant id entified lin e-items whe re no aging effects were ide ntified as a re sult of its aging rev iew proce ss.In OCGS LRA Ta bles 3.4.2.1.1 thro ugh 3.4.2.1.7, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabricated from glass w ere exposed to an air, l ubricating oi l, raw w ater, and treated water envi ronmen t.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review 451 report for the steam and power con version sy stems, and determin ed that no si gnificant aging effects were identi fied for components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team found that glass exposed to an air, lub ricating oil , raw w ater, or treated w ater enviro nment will not result in aging that wi ll be of conc ern during the p eriod of exten ded operation. Therefore, the project team de termined that there are no appl icable agin g effects requiring management for this material
/environment combination.
In OCGS LRA Ta bles 3.4.2.1.1 thro ugh 3.4.2.1.7, the ap plic ant id entifi ed AM R lin e-item s whe re no aging eff ects were identified as a result of its ag ing review process. Specifically, instances in whi ch the appl icant stated that n o agin g effects w ere id entifi ed occ urred w hen co mponen ts fabrica ted from s tainl ess ste el w ere ex posed to an air-i ndoor uncon troll ed env ironme nt.The project team reviewed the recommendations in the GALL Report f or this materi al/en viro nment c ombina tion, and de termin ed tha t the a ppli cant's eva luati ons ar e consistent w ith the recommend ations in the GALL Repo rt. In additio n, the project team review ed the applica nt's AMR technical basis documen ts listed i n Attachment 5 o f this audit an d review report for the steam and power con version sy stems, and determin ed that no si gnificant aging effects were identi fied for components w ith this materi al/enviro nment combinati on.On the basis o f its review of current industry research and operating exp erience, the p roject team found that st ainless steel exposed to an air-indoor uncontrolled environment will not result in aging that w ill be o f concern during the period of ex tended operati on. Therefore, the projec t team determined that there are no applicable aging eff ects requiring ma nagement f or this material/env ironment combin ation.Conclusio n On th e bas is of its re view, t he pr ojec t tea m fo und t hat t he app lican t app ropr iate ly iden tif ied AMR resu lts in volving mate rial, envir onme nt, agin g ef fec ts re quir ing m anag emen t, an d AMP combinations that are not app licable to OCGS, and AM R results i nvolvi ng material and environment combinations that do not have aging effect s requiring manag ement at OCGS.
3.4.3 Conclusion On the basis o f its review , the project team d etermined that the applican t has demonstrated that the aging effects associate d with th e steam and po wer conv ersion sys tem components w ill be adequately man aged.The project team als o review ed the appl icable UF SAR suppl ement program summaries a nd concludes th at they ade quately desc ribe the AM Ps credited for man aging aging of the steam and po wer c onve rsion compon ents, a s requi red by 10 CF R 54.2 1(d).3.5 OCGS LRA Section 3.5 -
Ag ing Management o f Primary C ontainment, Structu res, Component Sup ports, and Pipin g and Compon ent Insulation This section o f the audit and review report document th e project team's review and eval uation of OCGS agi ng manage ment re view (AMR) resul ts for the aging ma nagemen t of the primar y containment, structu res, component su pports, and pi ping and compon ent insulati on component and component grou ps associated with the followin g systems: (1) prima ry containme nt, (2) 452 reactor build ing, (3) chlori nation facili ty, (4) conden sate transfer buil ding, (5) dilu tion structure, (6) eme rgency dies el gen erator buil ding, (7) ex haust tunnel , (8) fir e pond dam, (9) fire pumpho uses, (10) he ating b oile r hous e, (11) intake structu re and canal , (12) m iscel laneo us ya rd structures, (13) new radwaste b uilding, (14) office building, (15) oyster creek su bstation, (16) turbine bui lding, (17) v entilation stack, (18) componen t supports commodi ty group and, (1 9)piping and c omponent insul ation commodity group.3.5.1 Summary o f Technical Information in the A pplication In the OCGS LRA Section 3.5 , the appli cant provid ed the results of its AMR s for structures.
In OCGS LRA Ta ble 3.5.2, ?Summary of Aging M anagement Primary Containment, S tructures, Compon ent Su pports , and P ipin g and C ompone nt Insu latio n," the appl icant prov ided a summa ry comparison of its AMR li ne-items wi th the AMR line-items evaluated in the GALL Report for the primary conta inment, structures, c omponent supports , and pipi ng and component insulation components and component groups. The applicant also identif ied for each component type in the OCGS LRA Tabl e 3.5.1 those c omponents that are consistent w ith the GALL R eport, those for which the GALL Report re commends further eva luation, an d those compone nts that are not addressed in the GALL Rep ort, together wi th the basis for their excl usion.In the OCGS LRA Tables 3.5.2.1
.1 through 3.5.2.1.19, the applica nt provide d a summary of the AM R re sul ts for comp onen t ty pes asso cia ted w ith (1) p rima ry c onta inme nt, (2) re acto r bui ldi ng, (3) chlorinati on facility , (4) condensate transfer buildi ng, (5) dilutio n structure, (6) emergenc y diesel genera tor buildi ng, (7) exhaust tunnel, (8) fire p ond dam, (9) fire pu mphouses, (10) heating boil er house, (11) i ntake structure and canal, (12) mi scellaneou s yard structu res, (13)new radw aste bui ldi ng, (1 4) offi ce b uil din g, (15) oy ster cree k sub stat ion , (16) tur bin e bu ild ing, (17) ventil ation stack, (18) co mponent supports commodity group a nd, (19) pipi ng and component insu lation commodi ty group. Spe cifically , the information for ea ch component ty pe included intended functio n, material, en vironment, agin g effect requiring management, AM Ps, the GALL Repo rt Volume 2 i tem, cross reference to th e OCGS LRA Tabl e 3.5.1 (Table 1
), and generi c and plant-speci fic note s rela ted to consi stency wit h the GA LL Rep ort.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of aging effect requiring managements (AE RMs). These review s included evaluati on of plant-spe cif ic and indus try op erat ing e xperi ence. The plant-spe cif ic eval uati on inc luded revie ws of condition re ports and dis cussions w ith appropri ate site perso nnel to id entify AERM
: s. The applicant' s review of industry o perating expe rience incl uded a rev iew of the GA LL Report and operat ing ex perie nce i ssues ident ified since the i ssuanc e of the GALL R eport.3.5.2 Project T eam Evaluatio n The project team rev iewed OC GS LRA Secti on 3.5 to determi ne if the appl icant provi ded sufficie nt info rmatio n to de monstra te that the effec ts of agi ng for the prima ry co ntain ment, structu res, co mponen t supp orts, a nd pi ping a nd comp onent insul ation compon ents th at are within the scope of li cense renew al and sub ject to an AM R wil l be adequatel y managed so th at the intended function(s) wi ll be main tained consi stent with the CLB for the p eriod of exten ded operat ion, a s requi red by 10 CF R 54.2 1(a)(3).The project team rev iewed c ertain iden tified AMR line-items to confirm the appl icant's cl aim that these AMR line-items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t
453 the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line-items. The project team's audit evaluation is documente d in Section 3.5.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line-items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in SRP-LR. The projec t team's audit eval uatio n is d ocumen ted in Secti on 3.5.2.2 of t his a udit a nd rev iew report.The project team did not revie w the remai ning AMR line-items that were no t consistent w ith or not addressed in the GALL R eport. These w ere review ed by the NRR/DE staff and do cumented in the SER fo r the Oy ster Cr eek pla nt.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the p rimary contai nment, structures, compo nent supports, an d piping and component insu lation compo nents.Table 3.5-1 bel ow prov ides a summary of the project team's evaluati on of components, agi ng effects/aging mechanisms, and AMPs l isted in L RA Section 3.5 that are ad dressed in th e GALL Report. It also includes the section of the audit and review report in which the project team's evaluati on is documen ted. It should be noted tha t the line items in thi s table corres pond to the line items in Table 3.5-1 of the Septem ber 2005 Revision 1 SRP-LR document; theref ore, in many cases, th ey do not match the lin e items in Tabl e 3.5.1 of the OCGS L RA. The SRP-L R line item n umber i s deno ted pa renthe tical ly i n the c olumn 1 entry. Als o, li ne ite ms that are applicabl e only to PWR plants are not incl uded in thi s table; therefore, c ertain SRP-L R line i tem numbers do not appear in th is table.Table 3.5-1 Staff Evalua tion for Containme nt, Structures, C omponent Supp orts, and Piping and C omponent Insulatio n in the GA LL Report Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on BW R C oncre te and S teel (Ma rk I, I I, and III) Containm ents Concrete el ements: wall s, dome, basemat, ri ng gir der, butt resses, contai nment (as applicable).(It em 3.5.1-1)
Ag ing of a cc es sib le an d in ac ce ss ible concret e areas due to aggressive chemi cal at ta ck, and corro sion of embedded steel ISI (I W L) and f or ina cc es sib le concret e, an examinati on of representative samples of below-grade concret e, and peri odic monit ori ng of gro un dw ate r if en viro nm en t is non-agg res sive. A pla nt s pe cif ic program is t o be ev alu ate d if en viro nm en t is aggressi ve.N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 454 Concrete el ements;All (I tem 3.5.1-2)Cracks and distor tion du e to incr eased str ess lev els f rom sett lement Struct ures Monitor ing Program. If a de-wate ri ng syst em is rel ied upon for contr ol of sett lement, then li cense e to ensure proper f uncti oning of t he de-wat eri ng syst em through th e peri od of ext ended operat ion.N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.2)Concrete el ements: foundat ion, sub-founda ti on (It em 3.5.1-3)
R ed uc tion in foundat ion st rengt h, cracking , dif ferent ial settlem ent d ue to erosi on of por ous con cre te subfoundat ion Struct ures Monitor ing Pr ogram If a de-wat eri ng syst em is rel ied upon to co ntro l erosi on of cement from porous con cre te subfoundat ions, then licens ee to ensure pr oper functi oning of t he de-wate ri ng syst em thro ugh the p eri od of ext ended operat ion.N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.2)Concrete el ements: do m e, w all, basemat, ri ng gir der, butt resses, con tainm ent, co nc re te f ill-in annulus (as appl icabl e)(It em 3.5.1-4)
Reducti on of stren gth and modulus of con cre te du e to elev ated tem perature A p lan t-s pe cif ic AMP is to be eval uated N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.3)Steel elements:
Drywel l; tor us;dry well head;em be dd ed sh ell and sand pocket re gio ns; dr ywe ll support skirt; t orus ring girder; downcomers; li ner pl at e, ECCS suction heade r, support skirt , r egion shiel ded by diaphragm floor, Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on ISI (I W E) and 10 CFR Part 50, Appendix J ISI (I W E) (B.1.27)and 10 CFR Part 50, Appendix J (B.1.29);Protect ive Coati ngs (B.1.33)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.1.4)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 455 suppressi on chamber (as appl icabl e)(It em 3.5.1-5)
Steel elements:
steel li ner, li ner anchors, int egral attac hm ents (It em 3.5.1-6)
Loss of materi al du e to ge ne ra l, pit ti ng and crev ice corrosi on ISI (I W E) and 10 CFR Part 50, Appendix J ISI (I W E) (B.1.27)and 10 C FR Part 50 , Appendi x J (B.1.29)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.1.4)Prestr essed contai nment tendons (It em 3.5.1-7)
Loss of pr estre ss due to r elaxat ion, shri nkage, cre ep, and el evated tem perature T LA A, e va lua ted in acc orda nce with 10 CFR 54.21(c)
N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.5)Steel and stai nless steel elements:
vent li ne, vent header, vent l ine be ll ows;downcomers;(It em 3.5.1-8)
Cum ulat ive fat igue damage (CLB fa tigu e a na lysis exist s)T LA A, e va lua ted in acc orda nce with 10 CFR 54.21(c)
TLAA Eva l uat ed b y DE (See Au dit Report Secti on 3.5.2.2.1.6)Steel , st ainl ess steel elements, dissi milar metal welds: penetr ati on sleev es, penetr ati on bel lows;suppressi on pool shell , unbr aced downc om ers (It em 3.5.1-9)
Cum ulat ive fat igue damage (CLB fa tigu e a na lysis exist s)T LA A, e va lua ted in acc orda nce with 10 CFR 54.21(c)
TLAA Eva l uat ed b y DE (See Au dit Report Secti on 3.5.2.2.1.6)Stai nless st eel penetr ati on sleev es, penetr ati on bel lows, dissi milar metal welds (It em 3.5.1-10)
Cra ck ing du e to stress corrosi on cracking ISI (I W E) and 10 CFR Part 50, Appendix J, and addit ional app ropr iate examinati ons/eval uati ons for bell ows assemblies and di ssimil ar metal welds.ISI (I W E) (B.1.27)and 10 CFR Part 50, Appendix J (B.1.29)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.1.7)Stai nless st eel v ent li ne bel lows, (It em 3.5.1-11)
Cra ck ing du e to stress corrosi on cracking ISI (I W E) and 10 CFR Part 50, Appendix J, and addit ional app ropr iate examinati on/eval uati on for bell ows assemblies and di ssimil ar metal ISI (I W E) (B.1.27)and 10 CFR Part 50, Appendix J (B.1.29)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.1.7)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 456 welds.Steel , st ainl ess steel elements, dissi milar metal welds: penetr ati on sleev es, penetr ati on bel lows;suppressi on pool shell , unbr aced downc om ers (It em 3.5.1-12)
Cra ck ing du e to cycl ic l oading ISI (I W E) and 10 CFR Part 50, Appendix J, and sup plem ente d to det ect fi ne cr acks TLAA (CLB fati gue analysis exists);
covered by Item 3.5.1-9 Eva l uat ed b y DE (See Au dit Report Secti on 3.5.2.2.1.8)Steel , st ainl ess steel elements, dissi milar metal welds: tor us; ven t li ne; vent header; vent l ine be ll ows;downc om ers (It em 3.5.1-13)
Cra ck ing du e to cycl ic l oading ISI (I W E) and 10 CFR Part 50, Appendix J, and sup plem ente d to det ect fi ne cr acks TLAA (CLB fati gue analysis exists);
covered by Item 3.5.1-8 Eva l uat ed b y DE (See Au dit Report Secti on 3.5.2.2.1.8)Concrete el ements: do m e, w all, basem at ring girder, butt resses, contai nment (as appl icabl e)(It em 3.5.1-14)
Loss of materi al (Scal ing, cracki ng, and spa lling) due to freez e-th aw ISI (IW L).Ev alu atio n is nee ded for pla nts tha t ar e lo ca ted in m oderate to severe weather ing condit ions (weathe ri ng index > 100 day-inch/yr
)(NU REG-1557).N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.9)Concrete el ements: wall s, dome, basemat, ri ng gir der, butt resses, con tainm ent, co nc re te f ill-in annulus (as applicable).(It em 3.5.1-15)
Cra ck ing du e to expansion and reac tion with aggregat e; i ncrease in p or os ity, perm eab ility due to leachi ng of cal cium hydr oxide ISI (I W L) for accessibl e areas.None for inaccessi ble ar eas if concret e was co ns tru cte d in accordance wi th t he recomm endati ons i n ACI 201.2 R.N ot A pp lica ble Not Appl icabl e;Steel contai nment (See Au dit Report Secti on 3.5.2.2.1.10)Seals, gaskets, and m oisture barriers (It em 3.5.1-16)
Loss of seal ing an d leakage t hrough con tainm ent d ue to deter ior ati on of j oint seals, gaskets, and m oisture barriers (caul king, fl ashing, and other sealan ts)ISI (I W E) and 10 CFR Part 50, Appendix J ISI (I W E) (B.1.27)and 10 CFR Part 50, Appendix J (B.1.29)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Per sonn el ai rl ock, equipment hat ch and CRD hatch Loss of l eak ti ghtness i n closed pos ition du e to 10 CFR Part 50, Appendix J and Plant Technical 10 CFR Part 50, Appendix J (B.1.29)and Plant Technical Co nsis tent w ith G AL L (S ee Au dit Report Sect ion Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 457 locks, hinge s, and closure me c h a n i s ms (It em 3.5.1-17) mechanical wear of locks, hinge s and closure me c h a n i s ms Specif icat ions Specif icat ions 3.5.2.1)Steel penetr ati on sleev es and dissi milar metal welds; personnel air lock, equip ment hat ch a nd CRD hatch (It em 3.5.1-18)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on ISI (I W E) and 10 CFR Part 50, Appendix J ISI (I W E) (B.1.27)and 10 CFR Part 50, Appendix J (B.1.29)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Steel elements:
stai nless st eel suppressi on ch am be r s he ll (i nner surf ace)(It em 3.5.1-19)
Cra ck ing du e to stress corrosi on cracking ISI (I W E) and 10 CFR Part 50, Appendix J N ot a pp lica ble Not appl icabl e;carbon st eel suppressi on chamber Steel elements:
suppressi on chamber li ner (i nter ior surface)(It em 3.5.1-20)
Loss of materi al du e to ge ne ra l, pit ti ng, and cr evi ce corrosi on ISI (I W E) and 10 CFR Part 50, Appendix J N ot a pp lica ble Not appl icabl e;carbon st eel suppressi on chamber; no l iner Steel elements:
dry well head and downcomer pipes (It em 3.5.1-21)
Frett ing or lock up due to mechanical wear ISI (I W E)ISI (I W E) (B.1.27)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Prestr essed con tainm ent: tendons and anchorage com pon ents (It em 3.5.1-22)
Loss of materi al due to cor rosi on ISI (I W L)N ot A pp lica ble Not Appl icabl e;Steel contai nment Safety-Re lated and Othe r Structures; an d Co mp onen t Supp orts All Groups except Group 6: i nter ior and above gr ade exte rior co ncr ete (It em 3.5.1-23)
Cracking, loss o f bond, and loss of material (spal li ng, sca ling) du e to corrosi on of embedded steel Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.2.2.1)All Groups except Group 6: i nter ior and above gr ade exte rior co ncr ete (It em 3.5.1-24)
Incre ase in poro sity an d p er m ea bility, cracking , l oss of material (spal li ng, sca ling) du e to aggress ive chemical at tack Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.2.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 458 All Groups except Group 6: st eel co m po ne nts: all struct ural steel (It em 3.5.1-25)
Loss of materi al due to cor rosi on Struct ures Monitor ing Pro gram. If prot ecti ve coat ings are r elied u pon to m ana ge th e eff ects of agi ng, t he struct ures monitori ng progr am is t o incl ude prov isions to address protective coati ng monitor ing and maintenance.
Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.2.2.1)All Groups except G ro up 6: a cc es sib le an d in ac ce ss ible concret e: foundat ion (It em 3.5.1-26)
Loss of materi al (spal li ng, scal ing)and crac king due to freez e-th aw Struct ures Monitor ing Program.Ev alu atio n is nee ded for pla nts tha t ar e lo ca ted in m oderate to severe weather ing condit ions (weathe ri ng ind ex> 100 day-inch/yr)(NU REG-1557).Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.2.1)All Groups except G ro up 6: a cc es sib le an d in ac ce ss ible int eri or/e xteri or con cre te (It em 3.5.1-27)
Cra ck ing du e to exp ans ion du e to reac tion with aggregat es Struct ures Monitor ing Program. None for inaccessi ble ar eas if concret e was co ns tru cte d in accordance wi th t he recomm endati ons in ACI 201.2R-77.
Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.2.2)G ro up s 1-3 , 5-9: A ll (It em 3.5.1-28)
Cracks and distor tion du e to incr eased str ess lev els f rom sett lement Struct ures Monitor ing Program. If a de-wate ri ng syst em is r eli ed upon for contr ol of sett lement, then t he licens ee is to ensure pr oper functi oning of t he de-wate ri ng syst em thro ugh the p eri od of ext ended operat ion.Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.2.3)Groups 1-3, 5-9: foundat ion R ed uc tion in foundat ion st rengt h, Struct ures Monitor ing N ot a pp lica ble Not appl icabl e; no poro us c onc rete Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 459 (It em 3.5.1-29) cracking , dif ferent ial settlem ent d ue to erosi on of por ous con cre te subfoundat ion Program. If a de-wate ri ng syst em is r eli ed upon for contr ol of sett lement, then t he licens ee is to ensure pr oper functi oning of t he de-wate ri ng syst em thro ugh the p eri od of ext ended operat ion.subfoun dation or de-wate ri ng syst em (See Au dit Report Secti on 3.5.2.2.2.2.3)Group 4: Radi al beam seats in BW R dry wel l; RPV support shoes for PW R with no zzle support s; St eam gen erato r sup ports (It em 3.5.1-30)
Loc k-u p du e to wear ISI (I W F) or Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL.(See Au dit Report Secti on 3.5.2.1.3)Groups 1-3, 5, 7-9: below-grade con cre te components, such as ex ter ior wa lls below gr ade and foundat ion (It em 3.5.1-31)
Incre ase in poro sity an d p er m ea bility, cracking , l oss of material (spal li ng, scaling)/aggressive chemi cal at ta ck;Cracking, loss o f bond, and loss of material (spal li ng, scali ng)/corrosi on of embedded steel Struct ures monitori ng Program;Exam inat ion of representative samples of below-grade concret e, and peri odic monit ori ng of gro un dw ate r, if the en viro nm en t is non-agg res sive. A pla nt s pe cif ic program is t o be ev alu ate d if en viro nm en t is aggressi ve.Struct ures Monitor ing Pr ogram (B.1.31);Exam inat ion of representative samples of below-grade concret e, and peri odic monit ori ng of groun dwater (non-aggre ssive environm ent).Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.2.4)Groups 1-3, 5, 7-9: exter ior above and below gr ade reinfo rce d co ncr ete foundat ions (It em 3.5.1-32)
Incre ase in poro sity an d p er m ea bility, and loss of stre ngth due to l eaching of calci um hydroxi de Struct ures Monitor ing Pr ogram fo r ac ce ss ible areas. None for inaccessi ble ar eas if concret e was co ns tru cte d in accordance wi th t he recomm endati ons in ACI 201.2R-77.
Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.2.5)Groups 1-5:
con cre te (It em 3.5.1-33)
Reducti on of stren gth and m odu lus du e to elev ated A p lan t-s pe cif ic AMP is to be eval uated Struct ures Monitor ing Pr ogram (B.1.31) wi th a 2-y ear i nspecti on Co nsis tent w ith GALL, which recomm ends furt her eval uati on Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 460 tem perature frequency and a quantitati ve cri teri on for cr ack width (See Au dit Report Secti on 3.5.2.2.2.3)Group 6: Concret e;all (I tem 3.5.1-34)Incre ase in poro sity an d p er m ea bility, cracking , l oss of m ateria l due to aggress ive chemi cal at ta ck;cracking , l oss of bond, l oss of m ateria l due to corrosi on of embedded steel Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and maintenance programs and for ina cc es sib le concret e, an examinati on of representative samples of below-grade concret e, and peri odic monit ori ng of gro un dw ate r, if the en viro nm en t is non-agg res sive. A pla nt s pe cif ic program is t o be ev alu ate d if en viro nm en t is aggressi ve.Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.4.1)Group 6: ext eri or above and bel ow grad e co ncr ete foundat ion (It em 3.5.1-35)
Loss of materi al (spal li ng, scal ing)and crac king due to freez e-th aw Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and maintenance programs.Ev alu atio n is nee ded for pla nts tha t ar e lo ca ted in m oderate to severe weather ing condit ions (weathe ri ng ind ex> 100 day-inch/yr)(NU REG-1557).Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.4.2)G ro up 6: a ll accessibl e/ina cc es sib le reinfo rce d co ncr ete (It em 3.5.1-36)
Cra ck ing du e to expansion/rea cti on wit h aggregat es Accessibl e areas: Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.4.3)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 461 and maintenance programs. None for inaccessi ble ar eas if concret e was co ns tru cte d in accordance wi th recomm endati ons in ACI 201.2R-77.
Group 6: ext eri or above and bel ow grade re inf orced concret e foundat ion int eri or sl ab (It em 3.5.1-37)
Incre ase in poro sity an d p er m ea bility, loss of str ength due to l eaching of calci um hydroxi de Fo r ac ce ss ible areas, Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and maintenance programs. None for inaccessi ble ar eas if concret e was co ns tru cte d in acc orda nce with recomm endati ons in ACI 201.2R-77.
Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See Au dit Report Secti on 3.5.2.2.2.4.3)Groups 7, 8:
Tank li ners (It em 3.5.1-38)
Cra ck ing du e to stress corrosi on cracking; l oss of m ateria l due to pit ti ng and crev ice corrosi on A p lan t-s pe cif ic AMP is to be eval uated N ot A pp lica ble Not appl icabl e; The only stai nless st eel li ned concret e tank at O yste r C re ek is the spent fuel pool skimm er surge tank. Aging effe cts of t he stai nless steel tank liner are eval uated wi th t he mechanical auxil iar y sy stems.(See Au dit Report Secti on 3.5.2.2.2.5)Support mem bers;welds; bolt ed connecti ons;support anchorage to buildi ng structure (It em 3.5.1-39)
Loss of materi al due to ge neral and pit ti ng corrosi on Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL (See Au dit Report Secti on 3.5.2.2.2.6)Buil ding co ncret e at locat ions of expansion and grout ed anchors; grout pads for support base pl ates (It em 3.5.1-40)
R ed uc tion in concret e anchor cap acity du e to loca l conc rete degradat ion/servi ce-i nduced cracking or ot her concret e agin g Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL (See Au dit Report Secti on 3.5.2.2.2.6)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 462 me c h a n i s ms Vibr ati on isol ati on elem ents (It em 3.5.1-41)
Reducti on or l oss of isol ati on functi on/r adiat ion hardeni ng, temperatur e, humidit y, sustai ned vib rato ry loadi ng Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith GALL (See Au dit Report Secti on 3.5.2.2.2.6)Groups B1.1, B1.2, and B1.3: support mem bers: anchor bolt s, wel ds (It em 3.5.1-42)
Cum ulat ive fat igue damage (CLB fa tigu e a na lysis exist s)T LA A, e va lua ted in acc orda nce with 10 CFR 54.21(c)
Not appl icabl e; no CLB fati gue analy ses)Not appl icabl e; no CLB fati gue analy ses (See Au dit Report Secti on 3.5.2.2.2.7)G ro up s 1-3 , 5, 6: all masonry bl ock wa lls (It em 3.5.1-43)
Cra ck ing du e to restr aint shri nkage, creep, and aggress ive envi ronment M as on ry W all Program M as on ry W all Program (B.1.
30)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Group 6 el astomer seals, gaskets, and m oisture barriers (It em 3.5.1-44)
Loss of seal ing du e to det eri orat ion of seals, gaskets, and m oisture barriers (caul king, fl ashing, and other sealan ts)Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.12)Group 6: ext eri or above and bel ow grad e co ncr ete foundat ion; int eri or slab (It em 3.5.1-45)
Loss of materi al due to ab rasi on, cavi tat ion Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and maintenance Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Group 5: Fuel pool li ners (It em 3.5.1-46)
Cra ck ing du e to stress corrosi on cracking; l oss of m ateria l due to pit ti ng and crev ice corrosi on W ater Chem istry and monitor ing of spent f uel po ol wa ter lev el in acc orda nce with techni cal specif icat ions an d leakage f rom the leak chase channels.W ater Chem istry (B.1.2) and monitori ng of spent fuel pool water lev el in acc orda nce with techni cal specif icat ions Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Group 6: al l metal structural mem bers (It em 3.5.1-47)
Loss of materi al due to ge neral (stee l onl y), pi tt ing and crevi ce corrosi on Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and m ainten anc e. If prot ecti ve coat ings are r elied u pon to Inspect ion of W ater-Contr ol Struct ures (B.1.32)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 463 manage aging, prot ecti ve coat ing monitori ng and maintenance pr ov isio ns sh ou ld be incl uded.Group 6: ear then water contr ol struct ures - dams, embank ments, reserv oir s, channels, canals, and ponds (It em 3.5.1-48)
Lo ss of m ate ria l, loss of fo rm due to eros ion, se ttlem ent, sedimentat ion, frost acti on, waves, current s, sur face runoff , Seepage Inspect ion of W ater-Contr ol Struct ures or FE RC/US A r my Corps of Engineers dam inspecti ons and maintenance programs Inspect ion of W ater-Contr ol Struct ures (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Support mem bers;welds; bolt ed connecti ons;support anchorage to buildi ng structure (It em 3.5.1-49)
Lo ss of m ate ria l/general , pi tt ing, and crevi ce corrosi on W ater Chem istry and I SI (I W F)W ater Chem istry and ISI (I W F) for Treated W ater Envir onment Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Groups B2, and B4:
ga lva nize d s tee l, aluminum, sta inl ess steel support mem bers; welds;bolt ed connecti ons;support anchorage to buildi ng structure (It em 3.5.1-50)
Loss of materi al due to pi tt ing an d crevi ce corrosi on Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Group B1.1:
high stren gth l ow-al loy bolts (It em 3.5.1-51)
Cra ck ing du e to stress corrosi on cracking; l oss of m ateria l due to general corrosi on Bo lting Integ rity N ot a pp lica ble Not appl icabl e; no high stren gth low-all oy bol ts used in G roup B1.1 sup ports Groups B2, and B4:
slidi ng supp ort beari ngs and sl idi ng support surfaces (It em 3.5.1-52)
Loss of mechanical fun ction d ue to corrosi on, distor tion, dirt, overl oad, f ati gue due to v ibr ator y and cycl ic t hermal l oads Struct ures Monitor ing Pr ogram Struct ures Monitor ing Pr ogram (B.1.31)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Groups B1.1, B1.2, and B1.3: support mem bers: welds;bolt ed connecti ons;support anchorage to buildi ng structure (It em 3.5.1-53)
Loss of materi al due to ge neral and pit ti ng corrosi on ISI (I W F)ISI (I W F) (B.1.28)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Groups B1.1, B1.2, and B1.3: Constant Loss of mechanical fun ction d ue to ISI (I W F)ISI (I W F) (B.1.28)Co nsis tent w ith G AL L (S ee Au dit Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 464 and vari able l oad spri ng hangers; guides; stops;(It em 3.5.1-54) corrosi on, distor tion, dirt, overl oad, f ati gue due to v ibr ator y and cycl ic t hermal l oads Report Sect ion 3.5.2.1)Groups B1.1, B1.2, and B1.3: Sli ding surfaces (It em 3.5.1-56)
Loss of mechanical fun ction d ue to corrosi on, distor tion, dirt, overl oad, f ati gue due to v ibr ator y and cycl ic t hermal l oads ISI (I W F)ISI (I W F) (B.1.28)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Groups B1.1, B1.2, and B1.3: Vibr ati on isolation elem ents (It em 3.5.1-57)
Reducti on or l oss of isol ati on funct ion/radi ati on hardeni ng, temperatur e, humidit y, sustai ned vib rato ry loadi ng ISI (I W F)ISI (I W F) (B.1.28)Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Galvani zed st eel and al uminum support mem bers;welds; bolt ed connecti ons;support anchorage to buildi ng structure expos ed to air -
indoor uncontr oll ed (It em 3.5.1-58)
None None None Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)Stai nless st eel support mem bers;welds; bolt ed connecti ons;support anchorage to buildi ng structure (It em 3.5.1-59)
None None None Co nsis tent w ith G AL L (S ee Au dit Report Sect ion 3.5.2.1)3.5.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant states are c onsistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA is a cceptable.
In OCGS LRA Se ction 3.5.1.2.1, the applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging eff ects re lated to the prim ary conta inment , react or buildin g, chlo rinatio n facili ty, condensate trans fer building, di lution structu re, emergency di esel generator b uilding, ex haust tunnel, fire pond dam, f ire pumphouses, heating boiler house , intake structur e and canal, 465 miscellaneo us yard struc tures, new ra dwaste bui lding, office buil ding, oyster cre ek substation, turbine bui lding, venti lation stack, co mponent supports commodity group, p iping and co mponent insulation commodity group components and component groups:
*Water Chemistry Program (B.1.2)
*ASME S ection XI, Subse ction IWE Program (B.1.27)
*ASME S ection XI, Subse ction IWF Program (B.1.28)
*10 CFR Part 50, Appendi x J Program (B.1.2 9)*Masonry Wall Program (B.1.30)
*Structures Mo nitoring Program (B.1.3 1)*RG 1.12 7 Insp ectio n of Water-Con trol S tructur es Ass ociat ed w ith Nu clear Pow er Pla nts Program (B.1.32)
*Protective Coating Mo nitoring and M aintenance P rogram (B.1.33)
Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line-items to determine tha t the applicant (1) provides a brief descri ption of the sy stem, components, materi als, and environment; (2) states that the applicabl e aging effects have b een revie wed and are evalu ated in the GALL R eport; and (3) i dentifies those aging effects for the primary c ontainment, reacto r building, ch lorination facility, c ondensate transfer b uilding, di lution structu re, emergency di esel gene rato r bui ldi ng, e xha ust t unne l, fi re po nd d am, fi re pu mpho uses , hea ting boi ler hous e, i ntake structure and can al, miscell aneous ya rd structures, new radwaste b uilding, office bu ilding, oy ster creek substation, tu rbine buil ding, ventil ation stack, compon ent supports commod ity group, piping and component insulation comm odity group components that are subject to an AMR.
Based on i ts review of the AMR results for whi ch the appli cant claimed consistency with the GALL Report, the project team asked the applicant for se veral cl arifications, an d also for additional supporting in formation.
3.5.2.1.1 Stress Corrosion Crack ing of High Streng th Low Alloy Bolting Materials (Item 3.5.1-51)
The project team asked th e applica nt to provi de additio nal information to ensure that th is aging effect is not applicable to OCGS. The applicant provided data on the mater ial types used in structural appl ications, an d their as-rece ived y ield strengths.
One recent use o f A-490 bolts w as identified for a c rane support. H owever, since the bo lt is not p re-loaded i n this appl ication, an import ant pre-condi tion fo r SCC does n ot ex ist.Based on a review of this data, the project team determin ed that no hi gh strength low alloy bolting material s susceptibl e to SCC are used in stru ctural appli cations at OCGS, and found the applicant' s AMR re sult to be ac ceptable.3.5.2.1.2 Degrada tion o f Group 6 Elas tomer S eals, Gaskets, and M oistu re Barr iers (Item 3.5.1-44)
The project team asked the applicant to clarify its AMR result. The applicant sta ted that this aging effect was referenced to Table 1 Item 3.3
.1-46, because Item 3.5.1-44 did not exist in the January 200 5 draft GALL update.
It was add ed in the S eptember 2005 GAL LRev. 1. The appli cant cr edits the st ructure s moni toring program, whi ch is consi stent w ith th e GALL Repor t.
466 The proj ect t eam r eviewe d the corr espo nding Tabl e 2 ent ries , and fou nd th e appl ican t's AMR resul t for thi s aging effect to b e cons isten t wi th the GALL R eport.3.5.2.1.3 Lock-up Due to Wear of Radial Beam Seats in BWR Drywell (Item 3
.5.1-30)The app lica nt ide ntifie d this as no t appl icabl e to OC GS in the LR A, bec ause L ubrite plate s are not used. The p roject team asked the applicant to provide more information abo ut the design o f the radial beam seats and how free mov ement is achi eved. In re sponse, the ap plicant des cribed the two sets of radial bea ms at El. 44'-3" and 23'-6", and identified tha t Lubrite pl ates are used on sup port br ackets a t the 2 3'-6" e leva tion. The ap plic ant furth er stat ed tha t the ra dial beams and su pport b rackets are in specte d for lo ss of mat erial under the st ructure s moni toring program, but based on industry op erating history , Lubrite does not require agin g management for lock-up due to we ar. Howev er, the support b rackets which incorporate th e use of Lubrite are monitored under the str ucture s moni toring program.The project team determi ned that the ex isting commitment to monitor the radi al beams and suppor t brack ets unde r the st ructur es monit oring p rogr am is suf ficien t to ident ify any degradation of th e Lubrite plates' intended funct ion to allow free movement. The applicant's AMR result for this aging ef fect is consistent with the intent of the GALL Report, and is acceptable.
3.5.2.1.4 No Aging Effect for Steel (A ll Types) a nd Aluminu m in a ?Concrete" Env ironment The applican t referenced a Table 1 item under auxili ary systems in the Table 2s for structures, and claimed consistency with GALL. The project team as ked the appli cant to describ e the plant-specific operat ing experience for struct ural applications of steel (all types) and aluminum in a concrete env ironment. The app licant in dicated that th ere was no history o f degradation for structural appl ications of stee l (all ty pes) and alu minum embedded in concrete, a s long as no concrete degradati on occurred tha t allow ed exposu re to air and water. The a pplicant further stated that it w ill ev aluate ina ccessible areas (embedments) i f there are indi cations in an accessible area that may be indica tive of degradati on in the i naccessible area.The project team determined that the applicant's AMR result for steel (all types) and aluminum in a concrete env ironment is co nsistent w ith the recommend ations in the GALL Repo rt, and found it to be acce ptable.3.5.2.1.5 No Aging Effect for Stainl ess and Galv anized S teel and Al uminum in a
?Indoor-Air" or ?Containment-Atmosp here" Envi ronment The applican t referenced Table 1 items under a uxilia ry systems i n the Table 2s for structures, and claimed consistency with GALL. The project team asked the applica nt to describe the plant-specific operating exp erience for structural applicati ons of stainles s and galva nized ste el and aluminu m in a indo or-air or contai nment-atmosphere env ironment. The app licant in dicated that there wa s no history of degradation for structura l applic ations of stainl ess and galv anized steel and a lumin um in a indo or-air or con tainme nt-atmo sphere envi ronmen t.The project team determi ned that the ap plicant's AMR resu lt for stainless and galva nized ste el and aluminu m in an ind oor-air or conta inment-atmosphere e nvironment i s consistent w ith the recommendations i n the GALL Re port, and found i t to be accepta ble.
467 3.5.2.1.6 Loss of Preload in Structural Bolting The applican t referenced Table 1 items under a uxilia ry systems i n the Table 2s for structures, credited the s tructures monitori ng program, and clai med consistency with GALL. The project team asked the appl icant to desc ribe how loss of prelo ad is managed b y the structure s monitoring program for structura l bolting. The applican t indicated that structural bo lting applicatio ns at OCGS do n ot require speci fic predetermined bolting prelo ad to assure th e intended functio
: n. Typical methods, such a s turn-of-the-nut, are use d to ensure ad equate joint tightness. Loss of preload in this contex t refers to loss of joi nt integrity d ue to loose or missing bolts and nu ts. This aging effect is man aged by v isual in spection for loo se or missing n uts and bolts.The project team determi ned that the ap plicant's AMR resu lt for loss of prel oad in structu ral bolting is c onsistent w ith the recommend ations in the GALL Repo rt, and found it to be acceptable.
3.5.2.1.7 AMR Re sult for Class MC Pressu re Retainin g Bolting The applicant refere nced a Table 1 item under Engineered Saf ety Features in LRA Table 3.5.2.1.1, credited the IWE and Appendix J programs, and cl aimed consis tency w ith GALL. The project team noted that there is n o comparable Table 1 item u nder structures. The project team asked th e appl icant to pro vide addi tiona l info rmatio n abou t its A MR r esult for Cla ss MC pressu re retaining bol ting. The appli cant indica ted that IWE is credited for managin g loss of material and Appen diix J lea k rate te sting i s credi ted for ma naging l eak-tigh tness o f the con tainme nt, inc lud ing l oss of pre loa d in the Cla ss M C pr essu re re tain ing b olti ng.The project team determi ned that the ap plicant's AMR resu lt for Class M C pressure retai ning bolting is c onsistent w ith the recommend ations in the GALL Repo rt, and found it to be acceptable.
3.5.2.1.8 Loss of Mecha nical Fun ction for Stainl ess and Galv anized S teel and Al uminum ASME Class 1,2,3 and MC Supports (Item 3.5.1-58, It em 3.5.1-59, LRA Table 3.5.2.1.18)
The pro ject tea m noted that ?loss of mechanical funct ion" was not identified in LRA Table 3.5.2.18 as an applicabl e aging effect, in need of aging management, for stainle ss and galvaniz ed steel and aluminum AS ME Cla ss 1,2,3 and M C supports. The project team also noted that SR P-LR Ta ble 1 items 3.5.1-5 8 and 3.5.1-5 9 do n ot li st the speci fic agin g effects addressed, for w hich aging management is not required. The project team as ked the appli cant to explai n why loss of mechanic al function i s not an appl icable agin g effect for these materials.
The applican t stated that al l special OCGS ASME Class 1,2,3 and MC supports, for whi ch loss of mechanical functi on is an a pplicabl e aging effect (e.g., constant and variabl e load spri ng hangers), are f abricated from carbon and low-alloy steel.
The project team determi ned that the ap plicant's AMR resu lt for stainless and galva nized ste el and al uminum ASM E Cla ss 1,2, 3 and MC s upport s is c onsis tent w ith th e GALL Repor t.Conclusio n The project team has evaluated the appli cant's claim o f consistency with the GALL Report. The project team al so has revi ewed informa tion p ertain ing to the ap plic ant's c onsid eratio n of rece nt 468 and proposal s for managing associa ted aging effects. On the bas is of its rev iew, the project team found that the A MR resul ts, which the applica nt claimed to be consiste nt with th e GALL Report , are c onsis tent w ith th e AM Rs in the GA LL Rep ort.3.5.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In OCGS LRA S ectio n 3.5.2.2, the appl icant prov ided further e valu ation of aging manageme nt, as reco mmended by th e GALL Repor t, for the aging e ffects rel ated to the pr imary conta inment , reactor build ing, chlorina tion facility , condensate tran sfer building, di lution structu re, emergency diesel genera tor buildi ng, exhaust tun nel, fire pond dam, fire pumphouses , heating boil er house, inta ke st ruct ure a nd c anal , mis cel lan eous yar d str uctu res, new radw aste bui ldi ng, o ffice bui ldi ng, oyste r creek s ubstat ion, t urbin e bui ldin g, ven tilat ion s tack, co mponen t supp orts co mmodity group, p ipin g and co mponen t insu latio n commo dity group c ompone nts an d compo nent gro ups. The applican t also prov ided information concerning how it wil l manage the rel ated aging effects.
Project Team Eval uation For some AM R line-ite ms assigned to the project team in the OCGS LRA Tabl es 3.5.1, the GALL Report reco mmends further eval uation. When further evalua tion is reco mmended, the project team revi ewed these further evalua tions provi ded in OCGS L RA Section 3.5.2.2 against the criteria p rovided i n the SRP-LR Section 3.5
.2.2. The project tea m's assessments o f these evaluati ons are documen ted in this section. These assessments are a pplicabl e to each Tabl e 2 AMR li ne-item in Se ction 3.5 ci ting the item in Table 1.3.5.2.2.1 PWR and BWR Conta inment s 3.5.2.2.1.1 Aging of Inaccessibl e Concrete Are as In Section 3
.5.2.2.1.1 of the OCGS LR A, the appli cant stated that a ging of inaccessib le areas of concrete contai nments is not a pplicabl e since Oy ster Creek has a Mark I steel containment. The project team concur red with the applicant's evaluation that this aging eff ect is not applicable since Oyste r Cree k has a Mark I steel conta inment.3.5.2.2.1.2 Cracks and Dis tortion Due to Increased Stres s Levels from Settlement; Reducti on of Foundation S trength, Cracking and D ifferential Settleme nt Due to Eros ion of Porous Concre te Subfoundation s, If Not Covered by Structure s Monito ring Program In Section 3
.5.2.2.1.2 of the OCGS LR A, the appli cant stated that c racks and distorti on of concre te sub foundat ions are no t appl icabl e sin ce Oys ter Cre ek has a Mark I steel conta inment. The project team concurred with the applicant's evaluation that this aging ef fect is not applicable since Oyste r Cree k has a Mark I steel conta inment.3.5.2.2.1.3 Reduction o f Strength and Mo dulus of Concre te Structures Due to Eleva ted Temperat ure The project team rev iewed OC GS LRA Secti on 3.5.2.2.1.3 agai nst the criteri a in SRP-L R Section 3.5.2.2
.1.3.
469 SRP-L R Sect ion 3.5.2.2.1.3 sta ted tha t reduc tion o f strength and mo dulus of conc rete du e to elevated temperatures coul d occur in P WR and BW R concrete and steel contai nments. The imple mentati on of 10 CFR 5 0.55a and AS ME S ectio n XI, Su bsecti on IWL woul d not b e abl e to identify the reduction of strength a nd modulus o f concrete due to e levated te mperature.
Subse ction CC-34 00 of AS ME S ectio n III, D ivi sion 2, spe cifies the co ncrete temper ature l imits for normal operatio n or any o ther long-term perio
: d. The GALL Rep ort recommends further eval uatio n of a p lant-s pecifi c aging manageme nt progr am if an y por tion o f the con crete contai nment c ompone nts ex ceeds speci fied te mperatu re li mits, i.e., gen eral a rea tem peratu re greater than 66
/C (150/F) and loca l area temperatu re greater than 93
/C (200/F).In the OCGS LRA Section 3.5
.2.2.1.3, the appl icant addresse d reduction o f strength and modulus of concrete due to ele vated temperatu res. The OCGS LRA stated that the normal operating temperature inside th e Oyster Creek pri mary contain ment drywe ll vari es from 139
/F (at elev. 5 5') to 256
/F (at elev. 95'). The con tainment structure is a BWR Mark I steel containment, w hich is no t affected by general area temperature of 15 0/F and loca l area temperature of 200
/F. Con crete for the re actor p edesta l, and the dr ywe ll flo or sla b (fill slab) are located below elev. 55' and are not exposed to the elevated temperature. The biological shield wall e xtends from elev. 37'-3" to el ev. 82'-2" and is ex posed to a tempe rature range of 139
/F -184/F. The wall is a composite steel-concrete cylinder surrounding the reactor vessel. It is framed with 27 in. deep w ide flange colu mns covered with steel plate on b oth sides. The area between the plates is filled wi th high densi ty concrete to satisfy the sh ielding requi rements. The steel colu mns pro vide the i ntende d struc tural suppo rt functi on and the en cased high d ensit y concrete prov ides shiel ding requirements. The encased con crete is not a ccessible for inspection.
The elevated drywel l temperature con cern was e valuated as a part of the Inte grated Plant Assessment Sy stematic Eva luation Pro gram (SEP Topic III-7.B).
The evalu ation concl uded that the temperature would not adversely aff ect the structural and shielding f unctions of the wall.
The elevated drywel l temperature w as also id entified as a concern for the reac tor buildi ng dryw ell s hiel d wa ll. F urther eval uatio n for thi s wal l is discu ssed i n subs ectio n 3.5.2.2.2, i tem (8).The project team conc urs with th e applica nt's further eva luation be cause the ex isting elev ated temperature condi tion in the drywel l wil l not impai r the intended functions of the stee l containment shell or the shielding concret e of the biological shield wall.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.1.3 for further ev aluation.3.5.2.2.1.4 Loss of Materi al Due to Ge neral, Pitti ng and Crevi ce Corrosion The project team rev iewed OC GS LRA Secti on 3.5.2.2.1.4 agai nst the criteri a in SRP-L R Section 3.5.2.2
.1.4.SRP-LR Secti on 3.5.2.2.1.4 state d that loss o f material due to general, pittin g and crevic e corrosion cou ld occur in steel ele ments of accessibl e and inac cessible a reas for all ty pes of PWR and BW R containments.
The existi ng program relies o n ASME Section XI, Sub section IWE, and 10 C FR Pa rt 50, A ppend ix J , to man age thi s aging effect. The GALL R eport recommends further ev aluation o f plant-specific pro grams to manage this agi ng effect for inacc essib le are as if co rrosio n is s ignific ant.
470 In the OCGS LR A Sect ion 3.5.2.2.1.4, th e appl icant addre ssed l oss of ma terial of steel eleme nts due to general, pitting and cre vice corros ion. The OCGS L RA stated that at Oyster Creek, the potential for loss of m aterial, due to corrosion, in inaccessible areas of the containment drywell shell w as first recogniz ed in 1980 when w ater was di scovered co ming from the sand bed region drains. Corro sion wa s later confirmed by ultrason ic thickness (U T) measurements taken duri ng the 1986 refueli ng outage. As a re sult, severa l correctiv e actions w ere initia ted to determine the extent of corrosi on, evalu ate the integrity of the dryw ell, mitigate a ccelerated corro sion, and monitor the condition of cont ainment surfaces. The corrective actions include extensive UT measurements of the dry well s hell thic kness, removal of the sand in the sand bed region, cleaning and coating exte rior surfaces in areas where sand wa s removed, an d an engineeri ng evaluati on to confirm the d rywell structural in tegrity. A corro sion monitori ng program was established , in 1987, for the drywel l shell above the sand bed regio n to ensure tha t the containment v essel is c apable of performing i ts intended functi ons. Elements of the program have been incor porate d into the AS ME S ectio n XI, Su bsecti on IWE (B.1.2
: 7) and prov ide for:*Periodic U T inspections of the shell th ickness at criti cal locati ons,*Calculati ons whi ch establis h conservati ve corrosio n rates,*Projections of the shell thi ckness based on the conserva tive corrosi on rates, and
*Demo nstr atio n tha t the minim um re quir ed sh ell th ick ness is in ac cord ance with AS ME code.Additional ly, the NR C was no tified of this pote ntial generic issue that l ater became the s ubject of NRC IN 86-99 and GL 87-05.
The applican t provided the follow ing summary of the o perating expe rience, monitori ng activiti es, and correctiv e actions taken to ensure that th e primary co ntainment w ill perform its intended functions:
Drywel l Shell in the Sand Bed Region
: The drywel l shell is fabricated from AS TM A-212-61T Gr. B steel pla te. The shell was coate d on the inside surface with a n inorganic z inc (Carbol ine carboz inc 11) and on the outsid e surface with ?Red Le ad" pri mer id entifi ed as TT-P-86C Type I. The r ed le ad coa ting co vered the en tire exterior of the vessel from elevation 8' 11.25" (Fill slab level) to elevation 94' (below drywell flange).The sand bed re gion was fil led wi th dry sand as specified b y ASTM 633. Leakage of w ater from the sand bed drains wa s observed during the 1980 and 1983 re fueling outages. A series of inve stigati ons w ere pe rformed to iden tify th e sour ce of the wate r and i ts lea k path. The res ults concluded th at the source o f water was from the refueling cav ity, wh ich is flood ed during refueling outages.
As a result of the presence of w ater in the sa nd bed region, extensiv e UT thickness measurements (about 1000) of the dry well s hell w ere taken to determi ne if degradation was occurring. These m easurements corre sponded to known water leaks and indicated that wall thinning had occurred in th is region.
Becau se of red uced t hickne ss read ings, a dditi onal thickne ss meas uremen ts we re obta ined to determine the v ertical profil e of the thinni ng. A trench w as excav ated inside the dryw ell, in th e concre te floo r, in t he are a wh ere thi nning at the floor l evel was most se vere. Mea suremen ts taken from the ex cava ted tre nch i ndica ted tha t thin ning o f the emb edded shel l in concre te we re 471 no more seve re than those ta ken at the floor le vel and became less s evere at the lower p ortions of the sand bed region. Conv ersely, measu rements taken in a reas where thinning w as not ident ified at the floor l evel show ed no indi catio n of sign ifican t thin ning i n the e mbedde d shel l. Aside from UT thicknes s measurements performed b y plant s taff, independent ana lysis w as performed by th e EPR I NDE Center and th e GE Ul tra Image III ?C" scan topograph ical mappi ng syste m. The i ndepe ndent tests c onfirmed the UT resul ts. The GE Ult ra Image resul ts we re used as base line profile to track continue d corrosion.
To val idate UT meas uremen ts and chara cteriz e the fo rm of dama ge and its ca use (i.e., du e to the presence of contam inants, microbiological species, or bot h) core samples of the drywell shell were obtai ned at sev en location
: s. The core sampl es vali dated the UT measu rements and confirmed that the co rrosion of the dry well i s due to the p resence of oxy genated wet s and and exac erbate d by the pre sence of chlo ride a nd sul fate in the sa nd bed region. A co ntamin ate concentrating mecha nism due to a lternate we tting and dryi ng of the sand may have al so contributed to the corrosion phenomenon. It was therefore co ncluded that the optimum method for mitigating the corrosi on is by (1) removal of the sand to brea k up the galva nic cell, (2)remo val of th e co rros ion prod uct fr om th e sh ell and (3) appl ica tion of a p rote ctiv e co atin g.Removal o f sand was i nitiated du ring 1988 by removing shee t metal from around the vent headers to prov ide access to the sand be d from the Torus room. Du ring operating cy cle 13 some sand was removed and access holes were cut into the sand bed region throu gh the shield wall. The work was finished in December 1992 . After sand remov al, the concre te surface below the sa nd w as found to be unfini shed w ith i mprope r prov isio ns for w ater dr ainage. Corrective actions taken i n this region during 1992 i ncluded; (1) c leaning of loo se rust from the drywel l shell, followed b y appli cation of epox y coating an d (2) removin g the loose de bris from the concrete floor foll owed by rebuildi ng and reshapi ng the floor wi th epoxy to allow drainage of any water that may leak into the region. UT measure ments taken from the outsid e after cleanin g verified lo ss of material pro jections that ha d been made b ased on measure ments taken from the inside of the drywel l. There we re, howev er, some areas thi nner than projec ted; but in a ll cases engineering anal ysis determi ned that the dry well s hell thic kness satisfied AS ME code require ments. The Pro tectiv e Coat ing M onito ring an d Ma inten ance P rogram w as rev ised to include mon itoring of the coati ngs of exterior su rfaces of the dryw ell in th e sand bed region.The coated surfaces o f the former sand bed regi on were su bsequently i nspected duri ng refueling outages of 199 4, 1996, 2000, and 2004. The inspections showed no coating failu re or signs of deteriorati on. It is there fore concluded th at corrosion i n the sand be d region has b een arrested and no further loss of materia l is ex pected. M onitoring of the co ating in acco rdance with the Protective Coating Mo nitoring and M aintenance P rogram, will continue to e nsure that the containment drywel l shell maintains i ts intended functi on during the p eriod of exten ded operation.
Drywel l Shell Above Sa nd Bed Regio n: The UT i nves tigati on pha se (19 86 thro ugh 199 1) als o ide ntifie d los s of mate rial, due to corrosion, in the upper regio ns of the dryw ell shel l. These regions were han dled separate ly from the sand bed region because of the significant di fference in corrosion rate and phy sical difference in desi gn. Corrective action for these regions inv olved pro viding a corrosion allowa nce by de monstrating, through ana lysis, tha t the original drywel l design pres sure was conservative. Amendment 165 to the Oyster Creek Technical Specificat ions reduced the drywell design pressu re from 62 psig to 44 ps ig. The new design pressu re cou pled with measur es to 472 prevent w ater intrusion into the gap b etween the drywel l shell and the concre te will allow the upper portion of the drywe ll to meet A SME cod e requirements.
Originally , the knowle dge of the extent o f corrosion wa s based on U T measurements going completely around the i nside of the dry well a t several elevatio ns. At each e levation , a belt-li ne sweep w as used w ith readings ta ken on as li ttle as 1" cen ters wherev er thickness chan ged between su ccessive nominal 6" c enters. Six-by-six grids that exh ibited the worst metal loss around each elevation were established using this approach and included in the Drywell Corros ion In specti on Pro gram.As ex per ie nce in cre ase d w ith ea ch d ata col le cti on cam pai gn, on ly gri ds s how in g ev id enc e o f a change were retained in the inspecti on program. Addi tional assu rance regarding the adequacy of this inspecti on plan w as obtained by a compl etely rand omized in spection, in volvi ng 49 grids that showed that all inspection locations satisfied ASME code requirem ents. Evaluation of UT measurements taken throu gh 2000 concl uded that corros ion is no longer occurrin g at two (2) elevatio ns, the 3rd el evation i s undergoing a co rrosion rate of 0.6 mils/year, w hile the 4 th elevatio n is subject to 1.2 mils/y ear. The recent U T measurements (2004) confirmed that the corrosion rate continues to decline. T he two elevations that previously exhibited no increase in corrosion con tinue the no corrosion i ncrease trend.
The rate of corrosion for the 3 rd elevati on decreased from 0.6 mi ls/year to 0
.4 mils/yea
: r. The rate of corrosi on for the 4 th elevati on decreased from 1.2 mi ls/year to 0
.75 mils/ye ar. After each UT ex amination ca mpaign, an engi neer ing a nal ysi s is perfo rmed to e nsur e the requ ired min imum thi ckne ss i s pro vid ed th rough the period of extended operation. T hus, corrosion of the dr ywell shell is considered a TLAA further described i n Section 4
.7.2.The a ppl ica nt co ncl uded that the cont inu ed mo nito ring of th e dry wel l for los s mat eria l th rough ASME S ection XI, Subse ction IWE, the Protective Coating Mo nitoring and M aintenance Program, and 10 CFR Part 50, Appendix J provide reasonable assurance that loss of mater ial in inacc essib le are as of the dryw ell w ill be det ected prior to a l oss of a n inte nded fu nctio n. Observed cond itions that h ave the po tential for impac ting an intend ed function are evaluated or corrected in a ccordance w ith the correcti ve action process. The A SME Sec tion XI, Subsecti on IW E, the pr otecti ve coating monitor ing and m aintena nce, and 10 CFR Part 50 Appendix J programs are desc ribed in Appendix B.
The project team noted that the appl icant did not address agin g management of the portion of the dryw ell shel l embedded i n the dryw ell concrete floor. This area is inacces sible for ins pection, but is potenti ally su bject to wetti ng on both the i nside and outside surfaces.
The project team asked the applicant to submit its AMR for t his inaccessible portion of the drywell shell.
In its response , the appli cant stated that th e embedded po rtion of the dry well s hell is exempt from visual ex amination i n accordance with IWE-1232. Pressure testing in acco rdance wi th 10 CFR Part 50, Appendix J, Type A test, is credited for managing aging effects of inaccessible portions of the dry well s hell consi stent with NUREG-1801.
The applican t pointed ou t that NUREG-180 1 Vol. 2 Item N umber II.B1.1-2, Aging M anagement Program (AMPs) c olumn states tha t loss of material due to corrosi on is not si gnificant if the following co nditions are satisfied:
*Concrete meetin g the specificatio ns of ACI 318 o r 349 and the guidance of 201.2 R was used for conta inment shel l or l iner, 473*The concrete is monitored to en sure that it i s free of cracks that prov ide path for w ater seepa ge to th e surfac e of the conta inment shel l or l iner,*The moisture barrier , at the junction where the shell or liner becomes embedded , is subject to aging managemen t activiti es in accord ance wi th ASME Section XI, Sub section IW E requirements, and
*Water ponding on the contain ment concrete floor a re not common and when de tected are cl eaned up in a time ly ma nner.If any of the abov e condition s cannot be s atisfied, then a plant-specific aging management program fo r corro sion is ne cessar y." The app licant ind icated t hat its AMR r esults c oncluded that Oys ter Cre ek sat isfies the above requirements and a plant-speci fic aging management program is not required for corro sion of the embedded d rywell shell. The Oyster Creek concre te meets the recommend ations of ACI 318 and the guidance o f ACI 201.2R-77.
The drywel l concrete floor will be monitored for cracks under the stru ctures monitorin g aging management program (B.1.31).
Oyster Creek design does n ot include a moisture barri er. Howev er the design p rovides a 9" high curb (mi n)around the enti re drywe ll floor (ex cept at the tw o trenches di scussed belo w) to prev ent any w ater accumulated on the floor from being i n contact w ith the dry well s hell. The cu rb is consi dered part of the dryw ell concrete floor and ins pected for cracking unde r the structures moni toring program (B.1.31). The dry well floo r is designed to slope a way from the drywel l shell towards the drywell sump for proper drainage.
The sump level is monitored in the main control room in accordance w ith Technical Specificatio ns, and actio ns are taken to en sure Technical Specification s limits are not viol ated. Shoul d the sump fill and overflow leak rate canno t be monitored, a pl ant shutdow n will be required to regain leak rate mon itoring capabi lity and dete rmin e the sou rce o f the lea k.The applican t further stated that du ring the inv estigative p eriod to determi ne the exte nt of corrosion in the exteri or surfaces of the sand bed region, tw o trenches w ere excav ated in the drywell concrete floor. The purpose of the trenches was to expose the embedded drywell shell so tha t UT thi ckness measure ments c an be taken from insi de the dryw ell i n the s and be d regio n. Visual i nspection an d UT measurements di d not identi fy corrosion a s a concern o n the expo sed embedd ed dry wel l she ll i nside the dr ywe ll w ithin the ex cava ted tre nches. The tw o trenc hes w ere sealed w ith an ela stomer to preven t water in trusion into the embedded sh ell. Prior to entering the period of extended operation a one-t ime visual inspection of the embedded drywell shell, within the two trenc hes, wil l be performed by removing the sealant and exposing the embedded shell. Insp ection and a cceptance crite ria wil l be in a ccordance w ith IWE. If visual inspe ction reveals corrosion that could impact drywell integrity, correc tive actions will be initiated in accordance w ith the correcti ve action process to en sure that the dry well re mains capabl e of performi ng its i ntende d functi on. Fo llow ing the se in specti ons, th e trenc hes w ill be res ealed to continue prote cting the embedde d shell.
In addition , one-time UT measu rements wil l be taken and co rrecti ve ac tions wil l be i nitia ted in accord ance w ith th e corre ctiv e acti on pro cess to ensur e that the dryw ell is c apable of performing i ts intended functi on.In its letter d ated April 4, 2006, the ap plicant commi tted to the follo wing: A v isual ex amination of the dryw ell shel l in the d rywell floor inspecti on access trenc hes wil l be performed to a ssure that the dryw ell steel remains inta ct. If degradation i s identified, the dryw ell shel l conditi on wil l be evaluated and correctiv e actions taken, as necessary. These surfaces w ill eith er be inspec ted as part of the scop e of the ASM E Section XI, S ubsection IWE inspection program, or they w ill be restored to the o riginal desi gn configuration usi ng concrete or othe r suitable ma terial to pre vent moisture coll ection in these areas.
This is Aud it Commitment 3.5.2.2.1-1.
474 In its lette r dated May 1, 200 6 (Amer Gen Let ter No. 2130-06-203 28), th e appl icant commit ted to the followi ng: In addition to AmerGen's pre vious commi tment to perform one-time v isual examinatio ns of the dryw ell shel l in the a reas expose d by the tre nches in the bottom of the dry wel l (r efere nce Amer Gen 4/4/0 6 le tter to N RC), one-tim e Ul tras oni c Tes ting (UT)measurements wi ll be taken to confirm the adequacy of the shell thickness in th ese areas, provi ding furt her co nfiden ce tha t the d ryw ell r emains capab le of p erformin g its i ntende d functi on. This co mmitment wil l be p erformed prior to ente ring th e peri od of ex tended opera tion. This is Aud it Commitment 3.5.2.2.1-2.
The app lica nt als o note d that the in access ible dryw ell s hell in th e sand bed re gion b ecame accessible (from th e outside surface) af ter removal of sand in 1992. The interf ace of the shell and the sand bed floor was cleaned, coated, and sealed with silicon sealant. The periodic coating inspec tion has not identified an y coating de gradation at the shell/concrete interface that would indicate that corrosion is occurring in the embedde d portion of the shell.
On the basis of the infor mation provided, the project te am determined that the applicant will determine the condition of the inaccessible portion of the drywell shell embedded in the drywell concrete floor pri or to entering the extended period of operati on, based on the results of the inspection of the two trenches, and t hat corrective actions will be taken as necessary if degradation is found.The project team ev aluated the degradation hi story of the OCGS c ontainment and the appli cant's aging manageme nt commi tments fo r the e xtend ed per iod o f operat ion i n its eval uatio n of the appl icant's IWE aging m anageme nt progr am (B.1.27). Th ree  au dit op en ite ms have been ident ified. See 3.0.3.2.22 of th is au dit re port.3.5.2.2.1.5 Loss of Prestress D ue to Relax ation, Shrin kage, Creep, and El evated Temperat ure In Sec tion 3.5.2.2.1.5 of th e OCGS LRA, t he app lica nt stat ed tha t loss of prest ress of c oncret e containments i s not appli cable sinc e Oyster Creek ha s a Mark I ste el containme nt. The project team concurred w ith the appl icant's ev aluation th at this aging effect is n ot applicab le since Oyster Creek h as a M ark I ste el co ntain ment.3.5.2.2.1.6 Cumu lati ve F atig ue D amage In OCGS LRA Section 3.5.2.2.1
.6, the applicant stated that fatigue is a TLAA, as def ined in 10 CFR 54.3. Applica nts must eval uate TLAAs in accordance w ith 10 CFR 54.21(c)(1). The NRR/DE staff eval uated this TLAA , and its ev aluation i s documented se parately i n Section 4 of the SER related to the OCGS LRA.
3.5.2.2.1.7 Cracking Due to S tress Corrosion Cracking The project team rev iewed OC GS LRA Secti on 3.5.2.2.1.7 agai nst the criteri a in SRP-L R Section 3.5.2.2
.1.7.SRP-LR Secti on 3.5.2.2.1.7 state d that cracking due to stress corrosi on cracking of stainl ess steel penetrati on sleev es, penetration bellow s, and dissi milar metal w elds could occur in al l types of PWR and BW R containments.
Cracking due to S CC could also occur i n stainless steel ve nt line bell ows fo r BWR contai nments. The ex istin g program relie s on A SME Secti on XI, Subse ction IWE and10 C FR Pa rt 50, A ppend ix J to mana ge this aging e ffect. The GALL R eport 475 recommends further ev aluation o f additional appropriate ex aminations/ev aluations i mplemented to detect these aging effects for stainless ste el penetratio n sleeve s, penetration bellow s and dissimila r metal wel ds, and stain less steel vent lin e bellow s.In the OCGS LRA Section 3.5
.2.2.1.7, the appl icant addresse d cracking of stainl ess steel penetr ation slee ves, penetr ation bell ows, and di ssimi lar me tal w elds due to stress corrosion cracking. The OCGS LRA stated that at Oy ster Creek, cracking of contai nment penetration s (including penetration sleeves, penetr ation bellows, and dissimilar metal welds) due to cyclic loading is considered meta l fatigue and i s addressed a s a TLAA in Section 4.6.
Str ess cor ros io n cr ack in g is an agi ng m ech ani sm t hat req ui res the si mul tan eou s ac tio n o f a corrosive e nvironment, s ustained tens ile stress, a nd a suscepti ble material. Elimina tion of any one of t hese e lement s wi ll el imina te susc eptib ilit y to S CC. S tainl ess ste el el ements of prima ry contai nment a nd the conta inment vacu um brea kers sy stem, i nclud ing di ssimi lar w elds, are susceptible to SCC. H owever these elements are located i nside the co ntainment dry well o r outside the d rywell , in the reacto r buildin g, and are not su bject to corrosiv e environ ment as disc usse d belo w.The dry wel l is made i nert w ith ni trogen t o rend er the primar y con tainme nt atmos phere non-fla mmable by ma intai ning th e oxy gen con tent be low 4% by vol ume dur ing no rmal o perati on. The normal operati ng average temperature inside th e drywe ll is l ess than 139
/F and the r elative humidity ra nge is 20-40%.
The reactor buil ding normal op erating temperature ra nge is 65/F -92/F; except i n the trunion room where th e temperature can reach 140/F. The relati ve hu midity is 10 0% max imum. B oth the conta inment atmosp here a nd in door a ir env ironme nts are non-co rrosiv e (chl oride s <150 ppb, s ulfates <100 p pb, an d fluor ides <150 p pb).Thus, SCC is not expected to occur in the containment penetration be llows, penetration sl eeves, and containmen t vacuum brea kers expansio n joints, pip ing and pipi ng components, and dissimila r metal wel ds. A revi ew of plant operating exp erience did not identi fy cracking of the components and primary conta inment leakage has not been i dentified as a concern. Therefore, the ex istin g 10 CF R Part 50 Ap pendi x J l eak test ing an d ASM E Sect ion XI, Subse ction IWE, are adequate to detect cracking. Observed conditions that have th e potential for impacting an inten ded fun ction are ev aluat ed or c orrecte d in a ccorda nce w ith th e corre ctiv e acti on pro cess. The ASME Section XI, Sub section IWE and 10 CFR Part 50 Appen dix J pro grams are described in Appendix B.
The project team asked th e applica nt to address w hether the probl ems encountered at Dresden/Quad Ci ties wi th cracking of expan sion bell ows is a pplicabl e to OCGS. The ap plicant stated that th e prob lems w ere un ique to Dresd en/Quad Citi es and do no t appl y to OC GS. On the basis tha t the envi ronment conduci ve to SCC does not ex ist at OCGS, the p roject team found the appli cant's further ev aluation for cra cking due to SCC to be accepta ble.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.1.7 for further ev aluation.3.5.2.2.1.8 Cracking Due to C yclic L oading In Section 3
.5.2.2.1.7 of the OCGS LR A, the appli cant stated that c racking of containment penetrations (i ncluding pen etration slee ves, penetrati on bellow s, and dissi milar metal w elds) due to cy clic loadi ng is c onsid ered me tal fati gue, an d is a ddress ed as a TLAA in LR A Sect ion 4.6.
476 The project team concurred with the applicant's further evaluation, that this aging ef fect is addressed as a TLAA in LR A Section 4
.6.3.5.2.2.1.9 Loss of Materi al (Scali ng, Cracking, and Spa lling) Due to Freeze-Thaw In Sec tion 3.5.2.2.1.8 of th e OCGS LRA, t he app lica nt stat ed tha t loss of materi al du e to freeze-thaw o f concrete contain ments is not ap plicable since Oyste r Creek has a M ark I steel containment. The proj ect team concurred with the applicant's evaluation that this ag ing effect is not ap plic able since Oyste r Cree k has a Mark I steel conta inment.3.5.2.2.1.10 Cracking Due to Expansion and Reaction with Aggreg ate, and Increase in Porosity a nd Permeabil ity Due to Leaching of Ca lcium Hy droxide In Section 3
.5.2.2.1.8 of the OCGS LR A, the appli cant stated that c racking due to ex pansion and reaction w ith aggregates of concrete co ntainments is not applica ble since Oyster Creek has a Mark I steel containment. Th e project team concur red with the applicant's evaluation that this aging effec t is n ot app lica ble s ince Oyster Creek h as a M ark I ste el co ntain ment.3.5.2.2.2 Safety-Rela ted an d Other Structu res an d Comp onent Suppo rts 3.5.2.2.2.1 Aging of Structures Not Covered by Structures M onitoring Program In the OCGS LRA, Section 3.5.2.
2.2.1, the applicant addressed further evaluations in accord ance w ith th e Janu ary 2 005 Dr aft Rev isio n of the SRP-L R. The appli cant p rovi ded i ts reconcilia tion to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR in Attachment 3 , Items T-04, T-06, and T-11 o f its reconcili ation document.
The project team reviewed the reconciliation document against the crit eria in Section 3.5.2.2.2.1 of SRP-LR, Rev. 1, for items (1), (2), and (3). B ased on its review of LRA Sectio n 3.5.2.2.2.1, the project team determined that the applicant's reconciliation also applies to items (4), (5), and (6) in SRP-LR Secti on 3.5.2.2.2.1; i.e., the structures mon itoring program is credited. Item (7) is not appl ica ble to Oy ster Cre ek.SRP-LR Secti on 3.5.2.2.2.1 state s that the GALL Report recommends further evaluati on of certain structure/a ging effect combinations i f they are not c overed by the structures moni toring program. This i nclud es (1) crackin g, loss of bond , and l oss of ma terial (spal ling, scali ng) due to corrosion of embedd ed steel for Groups 1-5, 7, 9 structures (T-04); (2) increase in porosi ty and permeability , cracking, loss of materi al (spall ing, scaling) du e to aggressive chemical attac k for Groups 1-5, 7, 9 stru ctures (T-06); (3) los s of mate rial due to corros ion for Groups 1-5, 7 , 8 structures (T-11); (4) lo ss of material (spa lling, scal ing) and cracking du e to freeze-thaw for Groups 1-3, 5, 7-9 structures; (5) cracking d ue to expa nsion and reaction w ith aggregates for Groups 1-5, 7-9 stru ctures; (6) cracks and distortion d ue to increas ed stress lev els from sett leme nt for Grou ps 1-3, 5-9 st ruct ures; and (7) redu ctio n in foun dati on s tren gth, c racki ng, different ial s ettleme nt due to ero sion of porou s conc rete su bfounda tion fo r Group s 1-3, 5-9 structures. The GALL Report recommends further evaluati on only for structure/aging effect combin ation s that are no t wi thin t he stru ctures monito ring pr ogram.The SR P-LR fu rther s tated t hat lo ck up du e to w ear co uld o ccur for Lubri te rad ial b eam sea ts in BWR drywell , RPV suppo rt shoes for PWR with noz zle supp orts, steam generator su pports, and other sli ding support be arings and sl iding support surfaces. The exi sting program relies on the structures moni toring program or ASM E Section XI, S ubsection IWF to manage this a ging effect. The GALL Report rec ommends further eval uation onl y for structure/aging effect 477 combinations that are not w ithin the IS I (IWF) or structures monitoring program.  (NOTE: S ee 3.5.2.1 of this aud it report for the pro ject team's asses sment of the appli cant's aging manageme nt resu lts for l ock up d ue to w ear of L ubrite radi al be am seat s in B WR drywel l.)In Attachment 3, Item T-04 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, to re quired if not w ithin the sc ope of the appl icant's structu res monitoring program. This i tem is with in the scope of Oyst er Cre ek's st ructure s moni toring program, therefore further eval uation is not required.
In Attachment 3, Item T-06 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to t he Oyster Creek LRA due to this item chang
: e. The environment for t his item, c oncret e: int erior and ab ove gr ade ex terior , chan ged from ?aggressive env ironment" to
?air- indoor un controlled o r air - outdo or". The wordi ng for further evaluati on was ch anged from not required if wi thin the scop e of the appli cant's structures monitoring program, to re quired if not within the scope of the applicant's structur es monitoring prog ram. Each instance of use of this item is w ithin the sc ope of Oyster Cree k's structures monito ring program, therefore further evaluati on is not requi red.In Attachment 3, Item T-11 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, to re quired if not w ithin the sc ope of the appl icant's structu res monitoring program. This i tem is with in the scope of Oyst er Cre ek's st ructure s moni toring program, therefore further eval uation is not required.
The project team concurred with the applicant's determination that no further evaluation is require d, on t he bas is tha t the s tructur es moni toring program i s credi ted for a ging man agement.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.1 for further ev aluation.3.5.2.2.2.2 Aging Management of Inaccessible Areas 3.5.2.2.2.2.1 Aging Management of Inaccessible Areas [Item 1]
In the OCGS LRA, Section 3.5.2.
2.2.2, the applicant addressed further evaluations in accord ance w ith th e Janu ary 2 005 Dr aft Rev isio n of the SRP-L R. The appli cant p rovi ded i ts reconcilia tion to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR in Attachment 3 , Item T-01 of its reconci liation d ocument. The project team review ed the reconcilia tion document a gainst the criteri a in Secti on 3.5.2.2.2.2.1 o f SRP-LR, Rev. 1.SRP-L R Sect ion 3.5.2.2.2.2.1 s tated t hat lo ss of mat erial (spal ling, scali ng) and cracki ng due to freeze-thaw coul d occu r in b elow-grade i nacces sibl e conc rete ar eas of Gr oups 1-3, 5 a nd 7-9 structures (T-01). The GAL L Report recommend s further evalu ation of this a ging effect for inacc essib le are as of the se Grou ps of str ucture s for pl ants l ocated in mod erate t o sev ere weathering c onditions.
In Attachment 3, Item T-01 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
For inacces sible areas , as 478 descri bed i n the U FSAR Secti on 3.8.4.6, ?Material s, Quality Control and Special C onstruction Techniques", concrete is designed consistent w ith ACI 318 recommendations to provide workabl e concre te of ho mogen eous str ucture which, when har dened, will have durabil ity, impermeabili ty and the specified strength.
Testing of concrete w as performed in ac cordance with ASTM Stand ards sp ecifie d in A CI 318 to ens ure the desi red qua lity of conc rete i s furnis hed. The strength quality of the concrete w as establis hed by tes ts made in ad vance of the b eginning of operations using a maximum slump of four inches.
Specimens were tested and cured in accordance w ith ASTM C39.The rev iew of desi gn and constru ction docume nts in dicat ed tha t the s pecifi ed ai r conte nt is 4 to 6 percent. Water-to-cement ratio w as based on the strength required by the des ign consideri ng the maximum sl ump of four inches. C urves represe nting the relati on betwee n the wate r content and the av erage 28-day c ompressive strength were es tablished for a range of value s includi ng the compressiv e strengths specifie
: d. The curves were estab lished by at least three points, each point represented average values f rom at least four tes t specimens. The maximum allowable water conten t for each class of concrete was determined from the c urves and corresponded to a compres sive strength of 15 p ercent greater than t hat sp ecifie d for tha t clas s of con crete. A review of documentation for a sample of clas s 4LA (4000 psi) concrete cylinde r tests shows that the 28-day strength meets or ex ceeds the spe cified 4000 p si compressiv e strength.
Inspections co nducted in a ccordance w ith the structures monitoring program ha ve identi fied minor loss of material (spalling , scaling) and cracking which could be attributed to freeze-thaw in accessible areas. Enginee ring evalua tion of the ide ntified loss of material and c racking concluded i t is not signi ficant to impact the intended functi on of the affected structure.
Based on the abov e eva luati on, the appl icant concl uded t hat lo ss of mat erial and c racking due to freeze-thaw i s not significan t for inaccessib le areas. Thus , a plant-spec ific aging management program is not require d.The project team asked th e applica nt for more information a bout aging management of inaccessibl e concrete area s, specificall y to confirm that the OCGS structures mo nitoring program credited for li cense renew al wil l inspect a ll inacce ssible area s that may be exposed by excavati on for any reas on, whether the enviro nment is consi dered aggressive or not, and a lso wil l ins pect a ny i nacces sibl e area whe re obs erved condi tions in ac cessi ble a reas, w hich are exp osed to th e sa me en vir onme nt, s how that sign ific ant c oncr ete d egrad atio n is occ urri ng.In its response , the appli cant stated that Oy ster Creek wi ll inspe ct inaccessi ble areas of structures in the scope of lice nse renewa l that are ex posed by excavati on for any reas on, whether the environment is conside red aggressive o r not. Inaccessi ble areas of struc tures in the scope of lice nse re newa l wi ll be insp ected if obse rved condi tions in ac cessi ble a reas, w hich are exp osed to th e sa me en vir onme nt, s how that sign ific ant c oncr ete d egrad atio n is occ urri ng.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.2.1 for further e valuatio n The project team found that  the app licant has demonstrated that the effects of aging wi ll be ade quately managed so that the in tended functions wi ll be main tained duri ng the period o f extended ope ration, as requi red by 10 CFR 54.21(a)(3).
479 3.5.2.2.2.2.2 Aging Management of Inaccessible Areas [Item 2]
In the OCGS LRA , Section the applicant a ddressed further ev aluations i n accordance with the January 200 5 Draft Revis ion of the SRP-LR. The appl icant provi ded its recon ciliatio n to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Item T-03 of its reconcil iation docu ment. The project team review ed the reconci liation d ocument against the crite ria in Sec tion 3.5.2.2.2.2.2 of SRP-LR, Rev. 1.SRP-L R Sect ion 3.5.2.2.2.2.2 s tated t hat cra cking du e to ex pansi on and reacti on w ith aggregates coul d occu r in b elow-grade i nacces sibl e conc rete ar eas for G roups 1-5 an d 7-9 structures (T-03). The GAL L Report recommend s further evalu ation of inacce ssible area s of these Groups of structure s if concrete w as not constructe d in accorda nce with the recommendations i n ACI 201.2R
-77.In Attachment 3, Item T-03 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, and stated condi tions are sati sfied for inaccessi ble areas, to required if not within the scope of the a pplicant's structures monitori ng program, or concrete w as not constructed as stated for inaccessible areas. This item is within the scope of Oyster Creek's structu res mon itori ng progra m, there fore furth er ev aluat ion i s not r equire d. The staff agree s wi th the ap plic ant's asses sment.The project team determi ned that the rec ommendations of SR P-LR Section 3.5.2.2.2.2.2 can be achieved by the applicant's commitments to (1) oppor tunistic inspection of norm ally inaccessible areas if they are exposed for any reason , and (2) insp ection of inacc essible are as of structures if observed c onditions i n accessibl e areas, wh ich are ex posed to the s ame environ ment, show that si gnifica nt con crete d egradat ion i s occu rring. S ee 3.5.2.2.2.2.1 of th is au dit re port.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.2.2 for further e valuatio n.3.5.2.2.2.2.3 Aging Management of Inaccessible Areas [Item 3]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The appl icant provi ded its recon ciliatio n to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Item T-08 of its reconcil iation docu ment. The project team review ed the reconci liation d ocument against the criteria i n Section 3
.5.2.2.2.2.3 of SRP-LR , Rev. 1.SRP-LR Section 3.5.2.2.2.2.
3 stated that crack s and distortion due to increased stress levels from settl ement a nd red uctio n of found ation strength , cracki ng, and differen tial settle ment du e to erosi on of po rous co ncrete subfoun datio ns cou ld oc cur in belo w-grad e ina ccessi ble c oncret e areas of Groups 1-3, 5 and 7-9 structu res (T-08). The exi sting program relies on structures monitoring program to man age these aging effects. Some plants may rely on a de-wateri ng system to low er the site groun d water l evel. If the p lant's CLB credits a de-watering sy stem, the GALL Report reco mmends verificati on of the contin ued functional ity of the de-w atering system during the period of extended oper ation. The GALL Report recom mends no further evaluation if this a ctiv ity i s incl uded i n the s cope o f the ap plic ant's structu res mon itori ng progra m.
480 In Attachment 3, Item T-08 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to t he Oyster Creek LRA due to this item chang
: e. Oyster Creek does not rely on a de-w atering system for co ntrol of settlement.
The wording for further e valuatio n was changed from not require d if w ithin the sc ope of t he app lica nt's s tructur es moni toring program, to required if not within the scope of the applicant's structures mon itoring program. This item is within the scope of Oyster Creek's str uctures monitoring program, ther efore fur ther evaluation is not requ ired. The sta ff agrees w ith th e appl icant's ass essmen t.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.2.3 for further e valuatio n.3.5.2.2.2.2.4 Aging Management of Inaccessible Areas [Item 4]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant addre ssed aging management o f inaccessible areas in OCGS LRA Section 3.5.2.2.
2.2. The project tea m reviewed OCGS LRA Section 3.5.2.2
.2.2 against the c riteria in Section 3.5.2.2
.2.2.4 of the Septembe r 2005 Rev ision 1 of the SRP-LR.
SRP-LR Secti on 3.5.2.2.2.2.4 sta ted that increa se in porosi ty and permea bility, cracking, loss of material (spal ling, scali ng) due to aggressiv e chemical attack; and cracking, lo ss of bond, and loss of material (spalling, scaling) due to corrosion of em bedded steel could occur in below-grade i nacces sibl e conc rete ar eas of Gr oups 1-3, 5 a nd 7-9 structu res. Th e GALL Repor t recommends f urther evaluation of plant-spec ific programs to manage these aging effects in inaccessibl e areas of these Grou ps of structures if the environment is aggressive.
In Section 3
.2.2.2.2 of the OCGS LR A, the appli cant addressed cracking, spalli ng, and inc reas es i n po rosi ty a nd p erme abi lit y du e to aggre ssi ve c hemi cal atta ck; a nd c racki ng, s pal lin g, loss of bond, an d loss of materia l due to co rrosion of embedde d steel in below-grade inaccessibl e concrete area
: s. The appli cant stated that re cent Oyster Cre ek groundwater analy sis r esul ts (p H: 5.6 - 6.4 , chl orid es: 3 - 138 p pm, and su lfa tes: 7 - 73 pp m) ha ve sho wn that th e groun dwat er at Oy ster Cr eek is not aggre ssiv e for Grou ps 2-3 , 8-9 s tructur es. Therefore , further eval uatio n of bel ow-gra de in access ible concre te area s for Grou ps 2, a nd 8-9 structu res is not re quired. Simi larly inac cessi ble a reas o f Group 3 structu res are not ex posed to aggressi ve en viro nment e xcep t for fire wate r pumph ouses (fresh w ater pu mphous e onl y). Further eval uation of group 3 s tructures, other than fresh water pu mphouse is no t required.
The fresh water pu mphouse reinforced concrete is su bject to slightl y aggressive water from the Fire Pond D am (pH: 4.8, chl orides = 12 p pm, and sulfates = 6 ppm). Inaccessi ble areas w ill be inspe cted i f excav ated for any reason , or if o bserv ed con ditio ns in acces sibl e area s, wh ich a re exp osed to th e sa me en vir onme nt, s how that sign ific ant c oncr ete d egrad atio n is occ urri ng.The structures monito ring program wil l be enhan ced to incl ude periodi c groundwater monitoring in order to d emonstrate that the below grade environmen t remains non-aggressi ve. Observ ed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected in accordance with the corrective action process. Th e structures monitor ing program is described in Appendix B.
The project team asked th e applica nt for more information a bout the w ater-flowing and aggressive env ironments for the freshw ater pump house and the serv ice water seal we ll, and the operating exp erience for these structures, incl uding wheth er degradation h as been obse
: rved, 481 monito red, an d/or re paire d, and whe ther th ere are any speci al co nside ration s (e.g., m ore frequent inspections , more detaile d inspectio ns) over an d above th e normal structure s monitoring program in spection proce dures.In response, the applicant s tated that the freshw ater pump house is located at the fire pond dam south west of the reactor buil ding outside the protected are
: a. The pump hou se supplie s water for the fire protection system. As d iscussed i n the LRA, pa ragraph 3.5.2.2.2.2, the pump house is subject to
?Raw Water - Fresh Water" envi ronmen t descr ibed in LR A Tabl e 3.0-2. Chemi stry analy sis of t he w ater i ndica tes tha t it i s sli ghtly aggressi ve be cause pH=4.8 and i s less than 5.5 specified in NUREG-1801.
The chloride and sulfate con tents are belo w the aggressiv e limits (12 ppm and 6 ppm respectivel y) specified in NURE G-1801. The wa ter is generall y standin g; except for low natura l stream vel ocity, and low v elocity due to fire pump o peration, thus the label"water-flowi ng". The freshwater pu mp house is monitored on a frequency of 4 ye ars under the Struct ures Monit oring Pr ogram B.1.31). Inspec tion of accessib le areas o f the s truct ure above the water level was conducted in 2002. The inspection results indicate that the struc ture is structurally sound. Operati ng experienc e (OE) revie w did n ot identify o bjective ev idence that inacc essib le an d unde r wat er area s of the structu re hav e been insp ected previ ously. The OE review noted that the pump bays w ere desilted in late 2 003. There we re no reports of struc tural concerns by the desilting team. The OE review also did not indicate that repairs were made in the pa st. The freshw ater pu mp hous e is n ot sub ject to speci al co nside ration s, such as more frequent or detailed inspection s above th e normal structure monitoring program. There are no special co nsiderations for inspecting i naccessible and underw ater portion of the structure under the current term. How ever the struc ture wil l be subject to special consideratio ns during the peri od of exten ded op erat ion as discu ssed below.The service water system (SW S) Seal We ll is a reinforced concrete 2-cell junct ion box, partly abov e gro und, that is i n the flow path of th e se rvi ce w ater sys tem r etur n li ne to the dis char ge canal. The 2 cells are s eparated by a 4-foot high conc rete wall that acts as a weir ov er which water disc harged from SWS line overflow s and drains out through a 30" diameter drai n at the bottom o f the sec ond ce ll. Th e drai n lin e is c onnec ted to the roo f drain s and overb oard discharge system (Section 2.
3.3.33) which conveys water to the discharge canal. The weir overflow w as considere d a "water-flow ing" environ ment. The internal surfaces of the junctio n box are su bject to "raw water-salt w ater" enviro nment, as descri bed in LRA Table 3.0-2. The envi ronmen t is a ggressiv e (pH = 7.9, c hlori des = 1 4,659 ppm, an d sul fates = 1 ,419 p pm)because the c hloride l imit specified in NURE G-1801 ( < 500 p pm) is exce eded.The SWS Seal Well is no t curre ntly monito red un der the structu res mon itori ng progra m (B.1.3 1). There is documented evidence that the SWS Seal W ell has been inspected previously in October 1999. A s a result of thi s inspectio n, there are reco rds indicati ng interior surfaces of the stru ctur e w ere c oate d w ith an e las tome r to p rote ct ag ain st co ncre te de grada tion. The coa ting , howeve r, is not moni tored on a regul ar basis such that it coul d be credited for managing aging of concrete. Observ ed exterio r surfaces of the abov e ground structure th at are expo sed to the water-flowi ng and aggressive raw wa ter-salt wate r environmen t described a bove on i nternal surfaces, shows rust stains and cracking. How ever the struc ture appears ac ceptable. A n Issue Report (IR), w as issued i n accordance with the corrective a ction process to determine w hy the structu re is not in the sc ope of t he mai ntenan ce rul e struc tures mo nitori ng progra m, and t o evaluate its conditi on for the current term.
In the LRA, A merGen has committed to includi ng the SWS seal well i n the scope o f the structures monito ring program. The structure will be subject to special consideratio n if the initi al inspecti on, discussed below, shows that it is required
.
482 The applican t stated that, as i ndicated in LRA Tables 3.5.2.1.9 and 3.5
.2.1.12, the freshw ater pump house an d the SWS seal wel l wil l be monitore d under the stru ctures monitorin g program on a frequency of 4 years duri ng period of ex tended operati on. The initi al inspecti on wil l be completed prior to entering the period of extended operation. The results of this inspection will be evalu ated to determin e if any corre ctive acti ons are required or if more frequent insp ections are warranted to ensure that the intend ed function of the st ructures is maintained. Inac cessible areas of the structures will be inspecte d as per the s tructures monitori ng program if exposed by exca vati on for a ny re ason, and i f observ ed con ditio ns in acces sibl e area s, wh ich a re ex posed to the s ame e nvi ronm ent, sho w th at si gnifi cant con cret e de grada tion is o ccur ring.The project team determi ned that the ap plicant's approach to agi ng management for the freshwater pump h ouse and the service w ater seal w ell is a ppropriate. The need to insp ect more frequently than every 4 years w ill be d etermined prio r to entering the period of exte nded operation.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.2.4 for further e valuatio n.3.5.2.2.2.2.5 Aging Management of Inaccessible Areas [Item 5]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant prov ided its rec onciliati on to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Item T-02 of its reconcil iation docu ment. The project team review ed the reconci liation d ocument against the criteria i n Section 3
.5.2.2.2.2.5 of SRP-LR , Rev. 1.SRP-LR Secti on 3.5.2.2.2.2.5 sta ted that increa se in porosi ty and permea bility, and loss of strength due to leac hing o f calci um hyd roxi de cou ld oc cur in belo w-grad e ina ccessi ble c oncret e areas of Groups 1-3, 5 and 7-9 structu res. The GALL Re port recommends further ev aluation o f this aging effect for inacces sible areas of these groups of structure s if concrete w as not constructed in accordance w ith the recommend ations in ACI 201.2R-77
.In Attachment 3, Item T-02 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to t he Oyster Creek LRA due to this item chang
: e. Further evaluation is only required for inacce ssible area s if concrete w as not constructe d as stated (i n accordance with the recommendations i n ACI 201.2R
-77). In the Oy ster Creek LRA, the use of this l ine item is not for inaccessibl e areas. Acce ssible area s inspectio ns are performed in accordance w ith the structures monitori ng program, per September 2005 GALL.
The project team determi ned that the ap plicant has eliminated increase i n porosity and permeability , and loss o f strength due to lea ching of calciu m hydroxi de as an ap plicable aging effect/mechanism for inaccessi ble concrete areas at Oyster Creek, based on the quality of below-grade concrete.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.2.5 for further e valuatio n.
483 3.5.2.2.2.3 Reduction o f Strength and Mo dulus of Concre te Structures Due to Eleva ted Temperat ure In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant addre ssed aging management for el evated tempera ture i n conc rete i n OCGS LRA S ectio n 3.5.2.2.2.1(8). The projec t team r evie wed OCGS LRA Sectio n 3.5.2.2.2.1(8) agai nst the criteri a in Secti on 3.5.2.2.2.2.3 o f the September 2005 Revision 1 of the SRP-LR.
SRP-L R Sect ion 3.5.2.2.2.3 sta ted tha t reduc tion o f strength and mo dulus of conc rete du e to elevated temperatures coul d occur in P WR and BW R Group 1-5 con crete structures. F or any concre te ele ments th at ex ceed s pecifi ed temp erature limi ts, furthe r eva luati ons ar e recommended. App endix A of ACI 349-85 spe cifies the conc rete temperature li mits for normal operation or any other l ong-term period. The temperatures shal l not exc eed 150/F except for local areas , which are allow ed to have increased te mperatures not to e xceed 200/F. The GALL Report recommends further evaluati on of a plant-sp ecific program if any portion of the safety-related an d other concrete structures ex ceeds specifie d temperature li mits, i.e., general area temperature greater than 66/C (150/F) and loca l area temperatu re greater than 93
/C (200/F). The acceptance crit eria are described in Branch Technical Position RLSB-1 (Appendix A.1 of th is SR P-LR).In the OCGS LRA Section 3.5
.2.2.2.1(8), the app licant addre ssed reduction of strength and modulu s of con crete d ue to e leva ted temp erature s. The a ppli cant st ated th at for l oss of s trength and modulus of concrete structures due to elev ated temperatures for Group s 2-5, GALL recommends a Pl ant Specific A MP and further evaluati on if the general temperature is greater than 150 o F or if the loc al temperature i s greater than 200
/F. For Oyster Creek, the structures monitoring program is used to manage c racking of concrete structure s exposed to elevate d temperatures.
The app lica nt ind icate d that concre te tempe rature limit s spec ified in the GALL R eport a re exceeded only in a section o f the reactor buil ding (Group 2) dry well s hield w all that en closes the containment dry well h ead. Thermocoupl es mounted on the head, in the general are a of the shield w all, indi cated a maxi mum temperature of 285
/F. Engineeri ng analysi s predicted th at the average temperature through the 5' thick concrete w all coul d be in the range of 180
/F-215/F;considering a worst case thermal envi ronment insid e the contain ment of 340
/F. As a resul t, an investigati on was i nitiated to evaluate the impact of the e levated te mperature on the structural integrity of the shield wall. The initial inspection of the shield wall identified concrete cr acking in the area that i s subject to hi gh temperature. A map of the cracked area th at includes crack len gth a nd w idth wa s de vel oped for fu ture moni tori ng.Subsequently , an engineeri ng evaluati on was co nducted to asse ss the impact o f the elevated temperature on the drywel l shield wall. For this pu rpose, a finite element model was created considering the geometry of the shi eld wal l and structura l elements co nnected to it.
The analysi s was bas ed on a tempera ture of 285
/F and a redu ced co ncrete compre ssiv e stren gth that accounts for tempe rature-induced reduction. The results concl uded that conc rete and rebar str ess li mit s ar e i n a cco rda nce wi th A CI 3 49 cri ter ia wi th a n a deq uat e sa fety mar gin. N RC sta ff revi ew fou nd the anal ysis accep table and c onclu ded th at the wal l is capab le of p erformin g its inten ded fun ction. The st aff also recomme nded c ondit ion mo nitori ng of the dryw ell s hiel d wa ll to ensure its co ntinued function. The wall has been i ncluded i n the scope o f the structures monitoring program and inspected p eriodicall y to ensure its continue d function. Observ ed conditions that have th e potential for impacting an i ntended function are evalu ated or corrected 484 in accordance with the corrective action process. Th e structures monitor ing program is described in Appendix B.
In order to facil itate its ev aluation, the project team asked th e applica nt to provi de the follow ing additional information rela ted to the el evated tempera ture conditio n in the rea ctor buildi ng drywell shield wall:
*When was th e cond ition first di scove red, *What was the extent of the elevated temperature region,*What was the extent of the cracked region (dis tribution, le ngth, width o f cracks) when first discovere d,*When did NRC conclud e that this co ndition i s acceptable , and did th is conclus ion consider the remaining operati ng life of OC at that ti me,*Describe the monitoring program, in cluding the d ates and quanti tative resul ts obtained, since NRC acceptance o f the condition
,*Currently, w hat is the ex tent of the elev ated temperature regi on and w hat is the ex tent of the cra cked regi on (di stribu tion, length , wi dth of cr acks),*Has there bee n a need to conduct re-anal ysis or make a ny repairs
,*Is the licen se renewal commitment under th e OCGS SMP greater than, equal to, or less than the condition monitoring act ivities currently being conducted to satisf y the NRC staff's recommendation In resp onse, the ap plic ant sta ted tha t the d ryw ell s hiel d wa ll el evate d tempe rature concer n surfaced in ea rly t o mid-1980's. The i ssue w as ev aluat ed as part of N UREG-0 822, ?Integrated Plant Safety Assessment, Sy stematic Eva luation Pro gram, Oyster Creek Nucl ear Generating Station," January 1983, Topic II I-7.B.The applican t further stated that a review of the current li censing basis information did not identify doc uments that prov ide detail s on the ex tent of the cracked region when i t was first discovered in mid-1980
's. The appli cant was a ble to concl ude that the co ndition of the wall w as monitored after it w as discov ered. How ever, speci fic criteria suc h as distrib ution, wi dth, and length of cracks were not identi fied. The earli est document that provides this information is an inspe ction report prepa red in 1994. This r eport h as bee n used since 1994 as a b enchma rk against whi ch subsequent ob served shi eld wal l conditi on is ev aluated. Observ ed cracks on the outsi de of dr ywe ll sh ield wal l, as docume nted i n the 1 994 i nspect ion re port, s how that th e enti re shield w all abov e elevati on 95'-3" may be affected by the elevated temperature. Dis tribution of the cracks is genera lly rand om. Crack wid ths are generall y hairli ne; with no cracks wi der than 1/32".The applican t also stated that the NRC staff evaluation of information submitted by GPU, the previ ous ow ner of Oy ster Cr eek, on the dry wel l shi eld w all e leva ted temp erature began in 19 86. In its Safety Evaluation dated October 24, 1986 (Letter, J. Zwolinsky, NRC, to P. Fiedler, GPUN, with a S afety Eval uation 4.12, S EP Topic III-7.B, N RC Information Reque st Form of NURE G-0822, Desi gn Code s, Des ign Cri teria and Lo ad Com binat ions, dated Octobe r 29, 1 986), the staff required further inv estigation to co mplete its ev aluation.
GPU transmitted the requested informat ion, i n sev eral c orresp onden ces be twee n 1990 through 1993. The sta ff comple ted it s review of the submitted i nformation and con cluded in a Safety Ev aluation d ated May 11, 1994 that the dryw ell shie ld wal l is capab le of performing its i ntended function (Letter from Alexan der W. Dromerick, Jr., NRC , to J. Barton, GPU , "Oyster Creek Nuc lear Generatin g station -
Evaluation of Effect s of High Temper ature on drywell Shield Wall and Biological Shield W all, SEP To pic II I-7.B " Design Codes , Desi gn Crit eria, Load C ombina tions , and R eactor Cavi ty 485 Criteria" (TAC N
: o. M76879) dated Ma y 11, 1994
). The May 11, 1994 Sa fety Evalu ation did not speci fy that the co nclus ion i s base d on th e remai ning o perati ng life of Oyste r Cree k. As recommended b y the NRC staff in their M ay 11, 199 4 Safety Ev aluation, Oy ster Creek implemented a periodic cra ck monitoring program. The p rogram consists of vi sual inspe ction of dryw ell s hiel d wa ll ab ove e leva tion 9 5'-3" every refuel ing ou tage (Le tter from R.W. Keaten to U.S. NRC, "Oyster Creek Nuclear Generating Station (O CNGS) Docket 50-219 SEP Topic III-7B, dryw ell Shie ld Wall Integrity", dated A pril 19, 19 94). The benchmark i nspection w as conducted in April 199 4 to record the surface conditio n of the dryw ell shie ld wal l, includ ing the crack patterns, crack le ngth, and wi dth. In October 19 96, during the re fueling outage, the applicant performe d a second inspection was performed to asses s the condition of the drywell shield w all wh ile the rea ctor cavity is flooded w ith water.
The followi ng conditions were observ ed by th e appl icant: 1.The crack pattern remain ed unchanged 2.Some observa ble hair l ine cracks may be newl y devel oped or may be un-recorded from the l ast inspecti on 3.No cracks wi der than 1/32" w ere observed 4.No spalli ng or new sc aling/peeli ng was obse rved 5.There is evi dence of growin g water stain s from the pipe pe netration and cracks.The applican t further stated that en gineering eva luation con cluded that th is conditi on is loca l and has no impact on structural i ntegrity of the w all. The app licant conc luded from the 199 8 inspe ction that: 1.The crack pattern remain ed unchanged from prev ious inspe ction.2.The bottom 8' of the w all wa s repainted s ince the l ast inspecti on and new fine cracks were ob served. Ho wever, n o new si gnificant cracks we re observed.
3.Inspec tion o f the w all a fter pla nt shu tdow n show ed tha t the s urface c racking were mostly clo sed and no excessiv e cracking 4.No concrete sp alling w as observed 5.New w ater stains w ere observed. Howev er no significan t leaching or staining w as observed.The applicant's structura l engineer who performed the inspect ion concluded that the drywell shield w alls w ere structurall y adequate to perform their intend ed functions.
The applican t's 2002 i nspection rep ort noted that the structural cond ition of the sh ield w alls w as the sa me as th at obs erved in 19 98. Cr acks ob serve d we re min or and that th e wa lls w ere adequate to perform thei r intended functi ons.The applican t's 2005 i nspection rep ort noted that the shield w alls w ere in good/sou nd conditio n and capable of performing their inte nded function.
The minor hairl ine cracks and rust stains were the sa me as noted i n previou s inspectio ns.The applican t further stated that, as evidence d by opera ting experie nce discusse d above, th e extent of the el evated tempera ture region and the extent o f the cracked region ha ve not significantly changed since the benchmark report of 1994. Additi onal minor c racks and stains have been observ ed si nce th at time. How ever they were not co nside red si gnifica nt eno ugh to impact the in tended function o f the drywel l shield wall. A re-analy sis was performed for GPU by ABB Impell Corporation (R eport #0037-001 96-0) and transmi tted to NRC i n November 19, 1993 486 (Letter , R. Ke aton, GP UN, to NRC, ?Response to Request f or Additional Informat ion on Drywell Temperature (SEP Topi c III-7.B)," dated No vember 19, 19 93). There has b een no need for repairs. The l icense renew al commitment und er the Oyster C reek structures monitori ng aging manageme nt is equal to the condi tion mo nitori ng acti viti es con ducted under the cu rrent te rm to satisfy NRC staff recommendations.
As a follow-up to the appl icant's resp onse, the project team review ed the Ma y 11, 1994 letter from A. Dromerick and the November 1 9, 1993 letter from R. Keaton referenced above, al ong with ABB I mpell Corpo ration Repor t # 03-0370-1 341, ?Oyster Creek Nucl ear Generating Stati on Structural Ev aluation o f the Spent Fuel Pool," Rev. 0, June 29, 1 992. Based on its rev iew, the project team had a concern that se veral pote ntial aging i ssues may no t have not been adequa tely addre ssed, i n cons idera tion o f an add ition al 20 year s of ope ration. These relat e to known degradati on of the dryw ell shie ld wal l (DSW), the biological shield w all (BSW), and the spent fuel pool supporting structu ral elements.
The project team asked the applica nt to revie w the letter from A. Dro merick, Jr. (NRC) to J. Barton (GPU), "Oy ster Creek Nucle ar Generating station - Evaluation of Eff ects of High Tem perature on drywell Shield Wall and Biological Shield Wall, SEP Topic I II-7.B " Design Codes , Desi gn Crit eria, Load C ombina tions , and R eactor Cavi ty Criteria" (TAC N
: o. M76879) dated Ma y 11, 1994 , and describ e how the applican t has implemented the following element s of the staff
's SER: (1) The staff
's crack width acceptance criterion (0.
02 inch), above which repairs should be made to prevent water intrusion and potential corros ion of rebar in the drywell shield wall.(2) The OCGS stat ement in the cited April 19, 1994 letter fr om R.W. Keaten to U.S. NRC that it is de velopin g procedures for monito ring the condi tion of the DSW during each refueling outage.
(3) The OCGS stat ement cited April 19, 1994 letter f rom R.W. Keaten to U.S. NRC that it has assigned a structural-sys tem engineer to the OCGS site w ho is respon sible for ensuring that the str uctures at the site are monitor ed and evaluated. (NRC letter to GPU states: The staf f believes that this blanket comm itment by the licensee, if properly imple mented, wou ld en sure th e cont inued functio n of the BSW.)The applican t was al so asked to addre ss the follow ing questions:
(4) Re gardin g the co nclus ion i n the c ited I MPE LL Rep ort, Se ction 5.4 Co nclus ion (4), related to the effects of consolidated fuel loads, ha s OCGS implemente d a fuel rack change that increases the total fuel load in the spent fuel pool?
(5) Regarding the cra cking in the spe nt fuel area that the cited ana lysis p redicted and compared to actua l observa tions of cracking, w hat is the ap plicant's aging management commitment for these cracks?.
In re spon se to the proj ect t eam's fol low-up q uest ion , the app lic ant s tate d the foll owi ng: (1) Cracking of the dry well s hield w all is mon itored under the structures moni toring program. The program requires v isual in spection of the s hield w all for new cracks, crack growth and staining of the concrete as described in refer ence 4. An engineer with a B.S.
degree, or a professio nal engineer, who has a minimum of five years ex perience w orking on nuc lear s tructur es, con ducts i nspect ions. Acce ptance crite ria ar e in a ccorda nce w ith 487 ACI 349, w hich states tha t passive cracks less than 0.015 inches are acceptabl e withou t further evaluati on. This crite ria envel opes the staff recommended 0.02 inches crack width crit eria fo r the drywell shield wall. T he curr ent proc edure do es not sp ecify a numerical v alue for crack w idth, rather the procedure reli es on qualita tive asses sment by the qualified e ngineer to establ ish if observ ed cracks meet the gui dance in A CI 349 and whether they could impa ct structural in tegrity of the w all. Prev ious inspe ction results, descri bed pr evio usly indi cate th at the cracks a re gene rally hairl ine th at requi re no r epair , and that the cra cks have ex hibited no significant cha nge over the y ears. The structures mon ito rin g pr ogr am (B.1.31) i mpl eme nti ng p roc edu re w il l b e e nha nce d to ad d th e st aff recomme nded c riteri a for the dryw ell s hiel d wa ll cr ack wi dth (0.02-in ch).(2) The stateme nt in the ci ted Ap ril 1 9, 199 4 lett er from R.W. Keaten to U.S. N RC, ?GPU Nuclear is develop ing a program to ensu re monitoring of conc rete conditio ns during refueling outage and a formal guideli ne for performing the monito ring (e.g. visual inspections for crack growth and/or staining of the co ncrete)." is rel ated to action s planned by GPU to imple ment a formal monitori ng program. This plan ned formal program has been incorpor ated into the structures monitoring progr am as discussed in item (1) abov
: e. The normal i nspection frequency of the structures moni toring program of 4 yea rs wa s redu ced to ever y refue ling o utage for the dry wel l shi eld w all c onsis tent w ith the sta tement i n cite d lett er.(3) Oyster Creek ha s assigned a s tructural sys tem engineer to moni tor the conditi on of the dryw ell shie ld wal l as we ll as othe r structures. The en gineer is a l icensed professional en gineer with a minimum of 5 y ears experi ence wi th nuclear stru ctures.Inspection and acceptance crite ria are as discussed above. Inspection freq uency is every refuel ing ou tage as stated in th e cite d Apri l 19, 1994 l etter fro m R.W. Keaten to U.S. NRC. The enhanced proc edure wi ll incorp orate the NRC staff recommended 0.02 inch cra ck width acc eptance criteri on to be used for future inspection s.(4) The conclusi on cited i n ABB IM PELL Report
#03-0370-1341, Section 5.4, conclusion 4, related to the effects of consolida ted fuel loads is not impl emented at Oyster Creek. The term consolidate d fuel refers to remov ing the hardw are from fuel bundles, suc h as channel s and end p lates, to all ow for storage of greater quan tity of spent fuel in the high densi ty racks. The cons olidated fuel loads are therefore greater than loads th at are a resul t of the fuel rack change.
The ABB IM PELL anal ysis in cluded the consoli dated fuel loa d in one o f the load combi nations to de termine if the spe nt fuel pool structure will support it. H owever, as stated abov e, Oyster Creek do es not store fuel in the spent fuel st orage p ool i n a co nsoli dated form.(5) With respect to the cracking in the spent fuel pool area ci ted in ABB IMPELL analysi s, Oyster Creek has observed cra cks on the concrete girder along Co lumn Line R E, and the bottom of the floor slab beneath the spent f uel pool north wall and, the drywell shield wall cracking. The observed crack s were attributed to temperat ure conditions and little crackin g, if any , takes p lace under sustai ned l oads. As ci ted in the AB B IMP ELL R eport, cracking predicted by the ana lysis i s closely correlated w ith observe d cracking. The analysi s showed that the spent fuel pool structure is in full compliance with AC I 349-80 for all loads for which th e plant w as license
: d. The analy sis also c oncluded tha t the spent fuel pool structu re is capabl e of supporting the consolidate d fuel load; b ut the stress margin in certai n components i s zero. The z ero margin in thi s case is a cademic sinc e Oyster Creek does not store fuel i n a consoli dated form. Subsequentl y, four additi onal fuel racks were installed in the ye ar 2000. A fin ite element a nalysis of the fuel pool 488 structu re wa s perfor med by Holte c Inter natio nal a nd is docume nted i n Hol tec Re port HI-981983, "Li censing Report for Storage Capacity Expansi on of Oyster Creek S pent Fuel Pool", Revisi on 4, dated Ju ne 15, 1999.
Monitori ng of the cracks identi fied in the spent fuel pool area is i ncluded i n the exi sting Oyster Cree k structures monitori ng program (B.1.31). The pro gram is credited for aging management of the cracks du ring the period o f extended ope ration.The project team reviewed the applicant's responses, and concluded that the applicant's program to man age concrete crack ing in the drywell shield wall (DSW), the biological shield wall (BSW), and the spent fuel pool supporting structu ral elements is adequate, ba sed on the 2-y ear inspection frequency, the inc lusion of a quan titative a cceptance crite rion for crack wi dth, consistent w ith NRC sta ff recommendations, and th e apparent stab ility o f the existin g crack patterns and cra ck widths.
The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.3 for further ev aluation.3.5.2.2.2.4 Aging Management of Inaccessible Areas for Group 6 S tructures 3.5.2.2.2.4.1 Aging Management of Inaccessible Areas for Group 6 S tructures [Item 1]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant prov ided its rec onciliati on to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Items T-18 and T-19 of its reco nciliati on document. The project team revi ewed the reconcilia tion document against the crite ria in Sec tion 3.5.2.2.2.4.1 of SRP-LR, Rev. 1.SRP-LR Secti on 3.5.2.2.2.4.1 sta tes that increa se in porosi ty and permea bility, cracking, loss of material (spal ling, scali ng)/ aggressive chemi cal attack; and c racking, loss of bond, and loss of material (spalling, scaling)
/ corrosion of embedde d steel could occur in below-grade inaccessible concrete areas o f Group 6 structures (T-18, T-19).
The GALL Report recommends further evaluati on of plant-speci fic programs to manage these aging effects in inacc essible are as if the environment is aggressive.
The acceptance criteria are d escribed in Branch Techni cal Positi on RLSB-1 (App endix A.1 of t his S RP-LR).In Attachment 3, Item T-18 , of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The applica nt stated that Oyster Creek has committed to insp ecting inacces sible areas of structures in th e scope of license ren ewal tha t are expose d by ex cavation for any reason, and to sample and test groundwater pe riodicall y during the period of exte nded operatio
: n. This lin e item has be en invoked for w ater control struc tures. Oyster C reek has committed to performing a baseli ne inspection of submerged water c ontrol structures prior to enteri ng the period o f extended operat ion. A seco nd in specti on w ill be per formed 6 years after th e base line insp ectio n. A th ird inspection will be performed 8 ye ars after the second inspection. Follow ing each ins pection, the identified de gradations w ill be e valuated to determine i f more frequent inspection s are warran ted or there is a need for correct ive actions to ensure that age related deg radations are adequately managed. Inspectio ns wil l be condu cted in acco rdance wi th the RG 1.127, inspection of wate r-contr ol str ucture s asso ciate d wi th nuc lear p ower plan ts progr am.The applican t further stated that the review of design and co nstruction docu ments indicate d that the sp ecifie d air conten t is 4 to 6 p ercent. Water-to-ce ment ra tio w as bas ed on the str ength 489 required by th e design consi dering the max imum slump of four inc hes. Curve s representing the relati on bet ween the w ater co ntent a nd the aver age 28-day c ompress ive strength were established for a range of valu es includi ng the compressiv e strengths specifie
: d. The curves were establ ished by at least three points, each point represe nted average v alues from at lea st four test specimens.
The maximum al lowabl e water con tent for each clas s of concrete w as determined from the cu rves and co rresponded to a compressive strength of 15 percent greater than that speci fied for that class o f concrete. A rev iew of docu mentation for a sampl e of class 4LA (4000 ps i) concrete cy linder tests shows that the 28-day strength meets or ex ceeds the specified 4000 psi compressi ve strength.
The applican t stated that in spections con ducted in ac cordance w ith RG 1.127, In spection of water-control structu res associated with nuclear power plants have identified cracking , change in material prope rties, and lo ss of material (spa lling, scal ing), which could be attributed to co rrosion of emb edde d ste el i n ac cess ibl e are as. Engi neer ing e val uati on o f the ide ntifi ed c racki ng, change in materi al propertie s, and loss of material concl uded it is not significant to impact the intended functio n of the affected structure.
Based on ab ove eva luation, the applicant c oncluded tha t cracking, change in material properties, and loss of material due to corrosi on of embedded ste el is not significant for accessible and inacces sible areas , and RG 1.127, inspection of water-control structures associ ated w ith nu clear pow er pla nts w ill adequa tely manage the agi ng effect.
Thus, a plant-specific aging management program is not required.
The project team conc urred with the appli cant's assess ment that the RG 1.1 27, inspecti on of wat er-c ontr ol s truc ture s as soci ated wi th nu cle ar po wer pla nts p rogra m wi ll a dequ atel y ma nage the aging eff ects that may be caused by corrosion of em bedded steel, and that a plant-specif ic progr am is not necessa ry.In Attachment 3, Item T-19 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The applica nt stated that Oyster Creek has committed to insp ecting inacces sible areas of structures in th e scope of license ren ewal tha t are expose d by ex cavation for any reason, and to sample and test groundwater pe riodicall y during the period of exte nded operatio
: n. This lin e item has be en invoked for w ater control struc tures. Oyster C reek has committed to performing a baseli ne inspection of submerged water c ontrol structures prior to enteri ng the period o f extended operat ion. A seco nd in specti on w ill be per formed 6 years after th e base line insp ectio n. A th ird inspection will be performed 8 ye ars after the second inspection. Follow ing each ins pection, the identified de gradations w ill be e valuated to determine i f more frequent inspection s are warran ted or there is a need for correct ive actions to ensure that age related deg radations are adequately managed. Inspectio ns wil l be condu cted in acco rdance wi th RG 1.127, in spection of water-control structures associ ated with nuclear pow er plants.
The applican t further stated that i nspections co nducted in a ccordance w ith RG 1.127, i nspection of wate r-contr ol str ucture s asso ciate d wi th nuc lear p ower plan ts hav e ide ntifie d conc rete degrada tion, whi ch cou ld be attrib uted to aggressi ve ch emical attack i n acce ssibl e area s. Engineering ev aluation o f the identified i ncrease in p orosity and permeabili ty, cracking, and l oss of material concl uded it is not significant to impact the i ntended function of the affected structure.
Based on ab ove eva luation, the applicant c oncluded tha t change in materi al propertie s, cracking, and loss of material (spal ling, scali ng) due to aggressiv e chemical attack is not significant for access ible and inaccessibl e areas, and R G 1.127, inspec tion of water-co ntrol 490 structures associ ated with nuclear pow er plants w ill adequate ly manage the aging effect. Thus, a plant-speci fic aging management program is not required.
The project team conc urred with the appli cant's assess ment that the RG 1.1 27 inspecti on of wat er-c ontr ol s truc ture s as soci ated wi th nu cle ar po wer pla nts p rogra m wi ll a dequ atel y ma nage the aging eff ects that may be caused by aggress ive chemical attack, and that a plant-s pecific progr am is not necessa ry.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.4.1 for further e valuatio n.3.5.2.2.2.4.2 Aging Management of Inaccessible Areas for Group 6 S tructures [Item 2]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant prov ided its rec onciliati on to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Item T-15 of its reconcil iation docu ment. The project team review ed the reconci liation d ocument against the criteria i n Section 3
.5.2.2.2.4.2 of SRP-LR , Rev. 1.SRP-L R Sect ion 3.5.2.2.2.4.2 s tates t hat lo ss of mat erial (spal ling, scali ng) and cracki ng due to freeze-thaw c ould occur i n below-grade inaccessi ble concrete areas of Group 6 struc tures (T-15). The G ALL Report recommends f urther evaluation of this aging effect f or inaccessible areas for plants l ocated in mod erate to seve re weatheri ng conditions.
In Attachment 3, Item T-15 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The applica nt stated that for inacc essib le are as, as descri bed i n the U FSAR Secti on 3.8.4.6, ?Material s, Quality Control and Speci al Co nstruct ion Te chniqu es", co ncrete is de signed consi stent w ith AC I 318 r equire ments to provide work able conc rete of homog eneous s truct ure which, when harden ed, will have dur ability, impermeabili ty and the specified strength.
Testing of concrete w as performed in ac cordance with ASTM Stand ards sp ecifie d in A CI 318 to ens ure the desi red qua lity of conc rete i s furnis hed. The strength quality of the concrete w as establis hed by tes ts made in ad vance of the b eginning of operations using a maximum slump of four inches.
Specimens were tested and cured in accordance w ith ASTM C39.The app lica nt furthe r state d that inspe ction s cond ucted in ac cordan ce wi th the Oyster Creek R G.1.127, inspec tion of water-co ntrol structures a ssociated w ith nuclear power pl ants have identified loss of material (spalling, scaling) and cracking which could be attributed to freeze-thaw in accessible areas. Enginee ring evalua tion of the ide ntified loss of material and c racking concluded i t is not signi ficant to impact the intended functi on of the affected structure.
The applican t concluded that loss of materia l and cracking d ue to freeze-thaw is not signi ficant for inaccessibl e concrete area s of Group 6 structures, and that a pl ant-specific aging management program is no t required.
The project team noted that the appl icant's RG. 1
.127, inspecti on of water-contro l structures associated with nuclear power plants program is credite d for managing loss of material, cracking, and change i n material pro perties in b oth accessibl e and inac cessible (su bmerged)concrete areas o f Group 6 structures, regardl ess of the aging mechan ism. Any degradation that may be caused by freeze-thaw will be identified. The project team conc urred with the applicant's conclusion that a plan t-specific program is not needed.
491 The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.4.2 for further e valuatio n.3.5.2.2.2.4.3 Aging Management of Inaccessible Areas for Group 6 S tructures [Item 3]
In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 Draft Rev ision of the S RP-LR. The app licant prov ided its rec onciliati on to the further evaluati ons listed in the Septe mber 2005 Rev ision 1 o f the SRP-LR i n Attachment 3, Items T-16 and T-17 of its reco nciliati on document. The project team revi ewed the reconcilia tion document against the crite ria in Sec tion 3.5.2.2.2.4.3 of SRP-LR, Rev. 1.SRP-L R Sect ion 3.5.2.2.2.4.3 s tates t hat cra cking du e to ex pansi on and reacti on w ith aggregates and increas e in porosi ty and permea bility, and loss of stren gth due to leac hing of calcium hy droxide c ould occur i n below-grade inaccessi ble reinforced concrete areas o f Group 6 structures (T-16, T-17). The GAL L Report recommend s further evalu ation of inacce ssible area s if concrete wa s not constructed in accordan ce with the recommendation s in ACI 20 1.2R-77.In Attachment 3, Items T-16 and T-17 of its re conciliati on document, the applicant s tated that there is no c hange required to th e Oyster Creek LR A due to thi s item change. The applicant stated that the Oyster Creek LRA commitment to perform inspect ions in accordance with RG 1.127 does no t change. The appl icant further stated that as describ ed in the U FSAR Secti on 3.8.4.6 , ?Material s, Quality Control and Special C onstruction Techn iques", the cement u sed for Oyster Creek w as an approv ed brand of Portl and Cement con forming to ASTM Sp ecification C-150; Type II, low alkali. Alkali content is limited to 0.6 percent total alkali. The low alkali requirement for the cement was w aived, pro vided pe trographic tests con ducted in ac cordance with AS TM C295 an d C227 demons trated no potenti al alkali reactivity for all aggregates proposed for use.
This provid es assurance th at aggregates do not reac t with rei nforced concrete.The applican t further stated that the aggregate used on the project was from ap proved sourc es and co nsiste d of cle an, ha rd, dur able partic les co nforming to the require ments o f concre te speci ficatio ns. Tes ts we re perfo rmed as neces sary to dete rmine that th e prop osed a ggregate would p roduce concrete of acceptable qual ity and d urability , meeting ACI reco mmendations.
The project team conc urred with the appli cant's assess ment of cracking due to e xpansion and reaction w ith aggregates. The project team also noted that the appl icant's RG. 1
.127 inspecti on of water-control structures associ ated with nuclear pow er plants program i s credited for managing loss of materi al, cracking, and c hange in materia l properties in both acce ssible and inaccessibl e (submerged) concrete areas of Group 6 s tructures, regardless of the aging mechanism. Any degradation tha t may be cau sed by the se aging mechanis ms will be identi fied.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.4.3 for further e valuatio n.3.5.2.2.2.5 Cracking Due to S tress Corrosion Cracking and Los s of Material Due to Pi tting and Crevi ce Corrosion In the OCGS LRA Table3.5.1, Item Nu mber 3.5.1-30, the a pplicant i ndicated that cracking due to stress corrosi on cracking or lo ss of material du e to pitting an d crevice corrosion for Group 7 and 8 stainl ess steel tan k liners is not applica ble. The appl icant stated th at the only stainless 492 steel lin ed concrete tan k at Oyster Creek is the spent fuel pool surge tank. A ging effects of the stainless ste el tank line r are eval uated wi th the mechanic al auxi liary sy stems.SRP-LR Secti on 3.5.2.2.2.5 state s that the GALL Report recommends further evaluati on of plant-specific programs to manage cracking du e to SCC an d loss of materia l due to pi tting and crevi ce co rro sion for stai nles s ste el tan k lin ers e xpose d to s tand ing wa ter. The revie wer re views the applica nt's proposed aging management program on a case-by-ca se basis to ensure that the intended functions wi ll be main tained duri ng the period o f the extended operation.
The project team rev iewed Tabl es 3.5.2.1.1 through 3.5.2.1.19 in th e OCGS LRA, an d noted that the only stainless steel tank liner listed is the fuel pool sk immer surge tank liner, in Table 3.5.2.1.2. The AMR for thi s tank re ferences GALL Ta ble 2 item V II.A4-1 1 and Table 1 item 3.3.1-2 2, in auxi liary syste ms. The wate r chemi stry a nd one-time i nspect ion p rograms a re credited for aging mana gement. The project team d etermined that the applican t's aging management program for the stai nless steel tank liner i s acceptable
.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.6 for further ev aluation.3.5.2.2.2.6 Aging of Supports No t Covered b y Structures M onitoring Program In the OCGS LR A, the appli cant a ddress ed furth er ev aluat ions in ac cordan ce wi th the Janua ry 2005 D raft Rev isio n of the SRP-L R. No further eval uatio n wa s requi red be cause all s upport s (other than ASM E Class su pports) are cov ered by the structures monitori ng program. The applicant p rovided i ts reconcili ation to the further evaluati ons listed in the Septe mber 2005 Revisio n 1 of the SRP-L R in Attachmen t 3, Items T-29, T-30, and T-31 of its reconcil iation document. The projec t team review ed the reconci liation d ocument against the criteria i n Section 3.5.2.2.2.6 of SRP-LR , Rev. 1.SRP-LR Secti on 3.5.2.2.2.6 state s that the GALL Report recommends further evaluati on of certain compone nt support/aging effect combin ations if they are not cov ered by the structures monitoring program. This includes (1) loss of materia l due to genera l and pitti ng corrosion, for Groups B2-B5 su pports (T-30); (2) reduc tion in co ncrete anchor ca pacity du e to degradation of the surroundin g concrete, for Groups B1-B5 supports (T-29); a nd (3) reductio n/loss of isol ation functio n due to degra datio n of vi bratio n iso latio n ele ments, fo r Group B4 su pports (T-31). Further eval uation is necessary o nly for structure/a ging effect combinations n ot covered b y the structu res mon itori ng progra m.In Attachment 3, Item T-29 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, to re quired if not w ithin the sc ope of the appl icant's structu res monitoring program. This i tem is with in the scope of Oyst er Cre ek's st ructure s moni toring program, therefore further eval uation is not required.
The pro ject tea m concu rred w ith th e appl icant's ass essmen t.In Attachment 3, Item T-30 of its reconcil iation docu ment, the appli cant stated that th ere is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, to re quired if not w ithin the sc ope of the appl icant's structu res monitoring 493 program. This i tem is with in the scope of Oyst er Cre ek's st ructure s moni toring program, therefore further eval uation is not required.
The pro ject tea m concu rred w ith th e appl icant's ass essmen t.Attachment 3, Item T-31 o f its reconcili ation document, the applica nt stated that the re is no change required to the Oyster Cree k LRA due to th is item change.
The wordin g for further evaluati on was ch anged from not required i f within the scope of the app licant's s tructures monitoring program, to re quired if not w ithin the sc ope of the appl icant's structu res monitoring program. This i tem is with in the scope of Oyst er Cre ek's St ructure s Mo nitori ng Progra m, therefore further eval uation is not required.
The pro ject tea m concu rred w ith th e appl icant's ass essmen t.The project team found tha t, based on the above di scussion, the applicant h as met the criteri a of SRP-LR Secti on 3.5.2.2.2.6 for further ev aluation.3.5.2.2.2.7 Cumulativ e Fatigue Damage D ue to Cycl ic Loadin g In LRA Secti on 3.5.2.2.3 (2), th e applica nt stated that fatigue o f support members, ancho r bolts, and wel ds for Groups B1.1, B 1.2, and B1.3 component suppo rts is a TLAA as defined in 10 CFR 54.3 only if a CLB fatigue a nalysis exists. TLAA s are required to be eval uated in acc ordance with 10 CFR 54.21(c).
At Oyster Creek, the re are no fatigue an alyses ap plicable to Groups B1.1, and B1.2 component supp orts in the C LB. Therefore, cumulati ve fatigue damage for Groups B1.1 and B1.2 componen t supports is not a TLAA as defined in 10 CFR 54.3.
The Oyster Creek CLB includes fatigue analysi s for certain Group B 1.3, ASME Class M C component supports. For th ese supports (toru s support col umns and sw ay braces), c umulative fatigue damage is a TLAA , and is ev aluated in accordance w ith 10 CFR 54.21(c), in L RA Section 4.6.1.The NRR/DE sta ff reviewed thi s TLAA, and i ts evalua tion is do cumented separate ly in S ection 4 of the SER related to the OCGS LRA.
3.5.2.2.3 Quali ty As suranc e for Agi ng Ma nagemen t of Non-Safety-Rela ted Co mponen ts OCGS LRA Section 3.5.2.2.3 is reviewed by NRR staff and will be addressed separately in Section 3 of the SER related to the OCG S LRA.Conclusio n The project team ev aluated the degradation hi story of the OCGS c ontainment and the adequacy of the a ppli cant's aging manageme nt commi tments fo r the e xtend ed per iod o f operat ion i n its evaluation of the applicant's IW E aging managem ent program (B.
1.27). Three  signif icant audit open i tems ha ve be en id entifi ed. Se e 3.0.3.2.22 o f this a udit r eport.3.5.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Summary of Information i n the Appli cation In OCGS LRA Ta ble 3.5.1, S ummary of Agin g Man agement Eval uatio ns for th e Prim ary Containment, Stru ctures, Component Supports, and P iping and C omponent Insula tion, the 494 applicant p rovided i nformation regarding compo nents or material
/environment combination in the GALL R eport t hat it eval uated and i denti fied as not ap plic able to its plan t.In OCGS LRA Tabl es 3.5.2.1.1 through 3.5.2.1.19, the ap plicant prov ided addi tional deta ils of the r esul ts of the AMR s fo r mat eria l, env iron ment , ag ing e ff ect r equ iring mana gem ent, and AMP combinations that are not con sistent wi th the GALL Re port. Specifica lly, the applicant i ndicated, via Notes F through J, that neither the i dentified compon ent nor the materi al/enviro nment combination is eval uated in the GALL Report a nd provid ed information co ncerning how the aging effect requiring management wi ll be managed
.Project Team Eval uation The project team did not revie w the resul ts of the AMR s for material, env ironment, aging effect requiring management, and AMP co mbinations tha t are not consi stent with the GALL Repo rt or are no t ad dre sse d i n th e GA LL Rep ort. Th ese AM R l in e i tem s w ere rev ie we d b y N RR/DE sta ff, and are discussed in the SER related to the OCGS LRA.
3.5.3 Conclusio n Three  s ignific ant au dit op en ite ms hav e been iden tified. See 3.0.3.2.22 of th is au dit re port.The project team als o review ed the appl icable UF SAR suppl ement program summaries a nd concluded that the applicant needs to update th e UFSAR based on commitments specif ied in appli cant's lett ers da ted Ap ril 4 , 2006 , Apri l 17, 2006, May 1, 200 6, and resol ution s to op en ite ms discu ssed i n Sect ion 3.0.3.2.22 of th is rep ort.3.6 OCGS LR A Sectio n 3.6 - A ging Ma nageme nt of E lectric al Comp onents This section o f the audit and review report documents the project team's review and eval uation of OCGS AMR re sults for the aging mana gement of the electric al component and component groups associated with (1) insulated c ables and connections, (2) electrical penetrations, (3)high-voltage i nsulators, (4) tran smission con ductors and con nections, (5) fuse holders, (6) wooden u tility p oles, (7) cabl e connection s (metallic parts), and (8) un insulated grou nd conductors.
3.6.1 Summary o f Technical Information in the A pplication In the OCGS LRA Section 3.6 , the appli cant provid ed the results of its AMR s for the electric al components and component groups.
In Table 3.6.1 o f the OCGS LRA, the applicant p rovided a summary compari son of its AM R line items with the AMR line ite ms evaluate d in the GALL Report for the el ectrical compo nents and component groups. F or each compone nt type in the table, the applican t identified th ose compon ents th at are consi stent w ith th e GALL Repor t, thos e for w hich the GAL L Repo rt recommends further ev aluation, a nd those compon ents that are no t addressed i n the GALL Report, together w ith the basi s for their exc lusion.In Tables 3.6.2.1.1 and 3.6.2.1.2 o f the OCGS LRA, the applicant p rovided a summary of the AMR resu lts for component ty pes associate d with (1) insulated cables and connections, (2
)electrical penetrations, (3) high-voltage insulators, (4) transmission conductors and connections, (5) fuse holders, (6) wooden utility poles, (7) cab le connecti ons (metalli c parts), and (8) 495 uninsulated ground conductors. Specifical ly, the i nformation for each compo nent type i ncluded the in tended functio n, mater ial, envi ronmen t, agin g effect requ iring manageme nt (AE RM), AMPs, the GALL Report Volume 2 item, cross-reference to T able 3.6.1 of the OCGS LRA (T able 1), and generi c and plant-speci fic note s rela ted to consi stency wit h the GA LL Rep ort.The applican t's AMR s incorporated applicab le operatin g experience in the dete rmination of AERM s. Thes e rev iew s incl uded e valu ation of pla nt-spe cific a nd in dustry opera ting ex perie nce. The pl ant-sp ecific eval uatio n inc luded revi ews o f condi tion r eports and d iscus sions wit h appropriate si te personnel to identify A ERMs. The applicant' s review of industry o perating experience included a review of the GALL Repo rt and operatin g experience issues id entified since the i ssuanc e of the GALL R eport.3.6.2 Project T eam Evaluatio n The project team rev iewed S ection 3.6 of the OCGS LRA to de termine if the app licant prov ided sufficient information to demonstrate that th e effects of aging for the electri cal components that are withi n the scope o f license renew al and sub ject to an AM R wil l be adequatel y managed so that the intend ed function(s) w ill be mai ntained cons istent wi th the CLB for the period of exten ded op eratio n, as r equire d by 10 CFR 54.21 (a)(3).The project team rev iewed c ertain iden tified AMR line ite ms to confirm the app licant's c laim that these AMR line items were consi stent w ith th e GALL Repor t. The p roject t eam di d not r epeat its review of the matters descri bed in the GALL Report. H owever, the project team di d verify tha t the material p resented in th e OCGS LRA w as applica ble and tha t the appli cant had ide ntified the appropriate GALL Report AMR line items. The proj ect team's audit evaluation is documented in Section 3.6.2.1 of this audit and revie w report. In addition, the project team's e valuatio ns of the AMP s are d ocumen ted in Secti on 3.0.3 of thi s audi t and r evie w rep ort.The project team reviewed those selected AMR line items for which further evaluation is recommended by the GALL Rep ort. The project team c onfirmed that the ap plicant's further evaluations were in accordance with the acceptance criteria in the SRP-LR. The proj ect team's audit eval uatio n is d ocumen ted in Secti on 3.6.2.2 of t his a udit a nd rev iew report.The project team als o review ed of the remaini ng AMR l ine items tha t were not consistent w ith or not addressed in the GALL R eport based on NRC-approv ed precedents.
The audit in cluded evaluati ng whether al l plausi ble aging effects we re identified and wheth er the aging effects liste d were appro priate for the combi nation of material s and env ironments speci fied. The project team's eval uatio n is d ocumen ted in Secti on 3.6.2.3 of t his a udit a nd rev iew report.Final ly, t he pro ject tea m revi ewed the AM P summa ry de script ions in the UFSA R Sup plemen t to ensure that they provided an adequate de scription of the programs credited w ith managing or monitoring aging for the e lectrical c omponents.
Table 3.6-1 bel ow prov ides a summary of the project team's evaluati on of components, agi ng effects/aging mechanisms, and AMPs l isted in S ection 3.6 of the OCGS LRA that a re addressed in the GALL R eport. It also includes th e section of the audit and re view report in w hich the project team's ev aluation i s documented.
Table 3.6-1 Staff Evalua tion for Electrical Components in the GA LL Report 496 Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on Elect ri cal equipment subj ect to 10 CFR 50.49 envi ronmental qu al i fi ca t i on (EQ)requ irem ents (It em 3.6.1-1)
De grad ation d ue to vari ous agi ng me c h a n i s ms Envir onmental Quali fi cati on of Ele ctr ic Co m pon ents TLAA Co nsis tent w ith GALL, which recomm ends furt her eval uati on (See SER Secti on 4.4)Elect ri cal cabl es, connecti ons and fuse holders (i nsulat ion) not sub ject to 10 CFR 50.49 EQ requ irem ents (It em 3.6.1-2)
Reduced insul ati on resi stance and elect ri cal f ail ure due to v ar iou s p hys ica l, ther mal, radi oly ti c, photol yt ic, and chemical me c h a n i s ms Elect ri cal Cabl es and Connecti ons No t Sub ject to 10 CFR 50.49 EQ Re quire m ents Elect ri cal Cabl es and Connecti ons Not Subject to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents program, B.
1.34.Co nsis tent w ith GALL (Se e Au dit Re port Secti on 3.6.2.1)Conductor insul ati on for elect ri cal cabl es and connecti ons us ed in inst rumentati on cir cuit s not subj ect to 10 CFR 50.49 EQ requ irem ents that a re se nsitive to re du ctio n in conductor insul ati on re si st anc e (IR)(It em 3.6.1-3)
Reduced insul ati on resi stance and elect ri cal f ail ure due to v ar iou s p hys ica l, ther mal, radi oly ti c, photol yt ic, and chemical me c h a n i s ms Elect ri cal Cabl es And Connecti ons Us ed In Inst rumentati on Circui ts Not Subject To 10 CFR 50.49 EQ Re quire m ents Elect ri cal Cabl es and Connecti ons Not Subject to 10 CFR 50.49 Envir onmental Quali fi cati on Requirements Used In I nstru mentati on Circui ts pr ogram, B.1.35 Co nsis tent w ith GALL (Se e Au dit Re port Secti on 3.6.2.1)Conductor insul ati on for ina cc es sib le medium vol tage (2 kV t o 35 kV)cab les (e.g., ins talle d in co nd uit or di rect buri ed) not sub ject to 10 CFR 50.49 EQ requ irem ents (It em 3.6.1-4)
Locali zed damage and breakdown of insu lation lea ding to elect ri cal f ail ure due to mo isture int rusi on, wat er tree s Ina cc es sib le Medium Voltage Cables Not Subject to 10 CFR 50.49 EQ Re quire m ents Ina cc es sib le Medium Voltage Cables Not Subject To 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents program, B.
1.36 Co nsis tent w ith GALL (Se e Au dit Re port Secti on 3.6.2.1)Fuse Holders (Not Part of a Larger As sem bly): Fuse holder s -metall ic cl amp (It em 3.6.1-6)
Fa tigue d ue to ohmic heati ng, ther mal cycl ing, elect ri cal t ransi ents, frequent manipulat ion, vib rati on, chemical contaminat ion, corrosi on, and oxidat ion Fuse Holders None NURE G-1801 agin g effect is no t appli cable t o Oyster Cree k.(See eval uati on by DE )
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 497 Metal enclosed bus - Bus/
Connecti ons (It em 3.6.1-7)
Loosenin g of bol ted con nec tions d ue to ther mal cycl ing an d ohmic heati ng Metal Enclosed Bus None Not Appl icabl e.Oyster Creek has no phase bus i n the scope of l icense renewal. (See eval uat io n by DE )Metal enclosed bus - I nsulat ion/Insulators (It em 3.6.1-8)
Reduced insul ati on resi stance and elect ri cal f ail ure due to v ar iou s p hys ica l, ther mal, radi oly ti c, photol yt ic, and chemical me c h a n i s ms Metal Enclosed Bus None Not Appl icabl e.Oyster Creek has no phase bus i n the scope of l icense renewal. (See eval uat io n by DE )Metal enclosed bus - Enc losure assemblies (It em 3.6.1-9)
Loss of materi al due to ge neral corrosi on Struct ures Monitor ing Pr ogram N/A Not Appl icabl e.Oyster Creek has no phase bus i n the scope of l icense renewal. (See eval uat io n by DE )Metal enclosed bus - Enc losure assemblies (It em 3.6.1-10)
Hardenin g and l oss of str eng th du e to elastom ers degradat ion Struct ures Monitor ing Pr ogram N/A Not Appl icabl e.Oyster Creek has no phase bus i n the scope of l icense renewal. (See eval uat io n by DE )High vol tage insulators (It em 3.6.1-11)
Degradati on of insu lation q uality due to pr esence of any s alt dep osits and surfa ce contaminat ion; Loss of materi al cause d by mechanical wear due to wi nd blo wing on tr ansmission condu ctors A p lan t-s pe cif ic aging managem ent program is t o be eval uated None Co nsis tent w ith GALL, which recomm ends furt her eval uati on (Eva lu ati on by DE)Transmission conductor s and connecti ons;swit chyar d bus and connecti ons (It em 3.6.1-12)
Loss of materi al due to wi nd ind uced abrasi on and fati gue; l oss of con duc tor stre ngth due to cor rosi on;incr eased resi stance of con nec tion du e to oxidat ion or loss o f prel oad A p lan t-s pe cif ic aging managem ent program is t o be eval uated None Co nsis tent w ith GALL, which recomm ends furth er ev alua tion. NURE G-1801 agin g effect is no t appli cable t o Oyster Creek. (Ev aluat ion by DE)
Component Gr oup Aging Effec t/Mech anism AMP in GALL Rep ort AMP i n LRA Sta ff Eval uati on 498 C ab le Connecti ons -Me tallic parts (It em 3.6.1-13)
Loosenin g of bol ted con nec tions d ue to ther mal cycl ing, ohmic heati ng, elect ri cal t ransi ents, vib rati on, chemical contaminat ion, corrosi on, and oxidat ion Ele ctr ica l Ca ble Connecti ons Not Sub je ct To 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents None NURE G-1801 agin g effect is no t appli cable t o Oyster Creek. (Ev aluat ion by DE).Fuse Holders (Not Part of a La rg er As se m bly)Insul ati on materia l (It em 3.6.1-14)
None None None N ot A pp lica ble 3.6.2.1 AMR Results Th at Are Consis tent with The GALL Report Summary of Information i n the Appli cation For aging management ev aluations th at the appli cant stated are consistent w ith the GALL Report, the projec t team conducted its audit an d review to determine i f the applican t's reference to the GALL Re port in the OCGS LRA is a cceptable.
In OCGS LRA Se ction 3.6.2.1, th e applica nt identified the materials, e nvironments, and aging effects requiring management. The ap plicant i dentified the foll owing programs tha t manage the aging effects related to the insulated cables and connections:
* Elect rical Cabl es and Conne ction s Not S ubject to 10 C FR 50.49 EQ R equire ments (B.1.34)
* Electrical Cables and Connection s Not Subject to 10 CFR 50
.49 EQ Requirements Used in Instrument Ci rcuits (B.1.35)
* Inacce ssibl e Me dium V oltage Cabl es Not Subje ct to 1 0 CFR 50.49 EQ Requ iremen ts (B.1.36)Project Team Eval uation The project team rev iewed i ts assigned OCGS L RA AMR line ite ms to determine th at the applicant (1) provided a brief descri ption of the sy stem, components, materi als, and environment, (2) stated that the applicab le aging effects have been revi ewed and are eval uated in the GALL R eport, and (3) i dentified those aging effects for the insulate d cables an d connections that are subjec t to an AMR.
On the basis o f its review , the project team found that the appl icant appropri ately add ressed the aging effec t/mecha nisms, as rec ommende d by the GAL L Repo rt.
499 Conclusio n The project team has evaluated the appli cant's clai m of consistency with the GALL Report.
The project team also review ed information pe rtaining to the applicant' s considerati on of recent operat ing ex perie nce an d prop osals for mana ging ass ociat ed agi ng effects.
On the basi s of its review , the project team found that the AM R results that the applica nt claimed to be consiste nt with the GA LL Rep ort are consi stent w ith th e AM Rs in the GA LL Rep ort.3.6.2.2 AMR Results Fo r Which Further E valuation Is Re commended By The GALL Report Summary of Information i n the Appli cation In Section 3
.6.2.2 of the OCGS LRA , the appli cant provid ed further eval uation of aging management as recommende d by the GA LL Report for the i nsulated cab les and con nections, electrical penetrations, h igh-voltage i nsulators, transmi ssion condu ctors and conne ctions, fuse holders, w ooden util ity pole s, cable con nections (metal lic parts), an d uninsul ated ground conductor compon ents and compon ent groups. The app licant al so provid ed information concerning how it wil l manage the rel ated aging effects.
Project Team Eval uation For some AM R line i tems assigned to th e project team in OCGS LRA Tabl e 3.6.1, the GALL Report recommends further evaluati on. When further evaluation is recommended , the project team reviewed the evaluations provided in Section 3.6.2.2 of the OCGS LRA ag ainst the criteria provided in Section 3.6.2.2 of the SRP-LR. The project tea m's assessments o f these evaluati ons is docu mented in thi s section. Thes e assessments are applicab le to each Table 2 AMR li ne item in S ection 3.6 ci ting the item in Table 1.3.6.2.2.1 Electrical Equipment Subject to Environ mental Qualifica tion The project team rev iewed OC GS LRA Secti on 3.6.2.2.1 agai nst the criteri a in SRP-L R Section 3.6.2.2
.1.SRP-LR Section 3.6.2.2.1 stat ed that environmental qualificat ion (EQ) is a TLAA as defined in 10 CFR 54.3. TLAAs are requ ired t o be e valu ated i n acco rdance wit h 10 C FR 54.21(c).OCNGS LRA Se ction 3.6.2.2.1 stated that EQ i s a time-limi ted aging analy sis (TLAA) as d efined in 10 CFR 54.3. TLAAs a re required to be evaluate d in accorda nce with 10 CFR 54.2 1(c). The evaluati on of this TLAA w ill be a ddressed separa tely in Section 4 o f the SER relate d to the OCGS LRA.3.6.2.2.2 Degradation of Insul ator Quality Due to Prese nce of Any S alt Deposi ts and Surface Contaminati on, and Loss of Material Due to M echanical Wear Sec tio n 3.6.2.2.2 i s re vi ew ed by NR R/D E s taff.
500 3.6.2.2.3 Loss of Materi al Due to Wind Induced Abrasion an d Fatigue, Loss of Conductor Strength Due to Corro sion, an Inc reased Resi stance of Conn ectio n Due to Oxidation or Loss of Pre-lo ad Sec tio n 3.6.2.2.3 i s re vi ew ed by NR R/D E s taff.3.6.2.2.4 Quali ty As suranc e for Agi ng Ma nagemen t of Non-Safety-Rela ted Co mponen ts Sec tio n 3.6.2.2.4 i s re vi ew ed by NR R/D E s taff.Conclusio n On the basis o f its review , for component groups e valuated in the GALL R eport for whic h the GALL Report reco mmends further eval uation, the pro ject team determined that these further eval uatio ns wi ll be revi ewed by th e NRR/DE sta ff, and w ill be doc umented in th e SER relat ed to the OCGS LRA.
3.6.2.3 AMR Results Th at Are Not C onsistent With The GALL Report Or Not Addressed In The GALL Rep ort Sec tio n 3.6.2.3 is rev ie we d b y N RR/DE sta ff.3.6.3 Conclusion On the basis o f its review , the project team d etermined that the applican t has demonstrated that the aging effects associate d with th e electrical components w ill be a dequately mana ged.The project team als o review ed the appl icable UF SAR suppl ement program summaries a nd concludes th at they ade quately desc ribe the AM Ps credited for man aging aging of electrica l compon ents, a s requi red by 10 CF R 54.2 1(d).
501 ATT ACHMENT 1: LIST OF ABBREVIA TIONS ACI Americ an Con crete I nstitu te ADAMS Agencywi de Documents A ccess and M anagement System AMP aging management program AMR aging management revi ew ASME Americ an Soc iety of Me chani cal E nginee rs ASTM American Society for Test ing Materials BNL Brookha ven N ation al La borato ry BTP Branch Technica l positio n B WR boiling w ater reactor BWRVIP Boiling Water Reactor Vess el Improvement Program C Celsius CASS cast austeniti c stainless steel CFR Code of Federal Regulations CLB current licensing basis DE Divisi on of Engineerin g DIPM Divisi on of Inspection Program Management DSSA Division of Systems Safety and Analysis EDG emergency dies el generator EPRI Elect ric Po wer R esearc h Insti tute ESF engineered safety features EQ environmenta l qualificatio n F Fahrenheit FAC flow-accelera ted corrosion FSAR Final Safety Anal ysis Repor t GALL Generic Aging Les sons Learned GL Generic Letter GSI Generic Safety Is sue I&C instrumentation and control IASCC irradiation assisted stres s corrosion cra cking IGSCC intergranular stres s corrosion cra cking IN Information Notice INPO Institute of Nucle ar Power Ope rations ISG Interim Staff Guidance ISI inservice inspection LER lice nsee e vent report LRA license ren ewal ap plication MIC microbiologic ally i nfluenced corrosi on n/cm 2 neutrons per square centimeter NDE nondestructiv e examinati on NEI Nucle ar Ene rgy Ins titute NPS nominal p ipe size NRC U.S. Nuclear Regulatory C ommission NRR Office of Nuclear Reacto r Regulation NUMARC Nuclear Management and Resources Council NUREG Nucle ar Regu latory Commis sion techni cal re port OCGS Oyster Creek Generati ng Station ppm parts per mill ion P WR pressurized water reacto r RAI request for addition al information 502 RCPB reacto r cool ant pre ssure b ounda ry RCS reactor coolan t system RG Regulatory Gui de RLEP-B License Re newal a nd Enviro nmental Impacts P rogram, Section B RLSB License Re newal a nd Standardi zation Bra nch SBO station blac kout SCC stress corrosion cracking SC structu res an d compo nents SER Safety Eval uatio n Repo rt SLC standby l iquid control SRP-LR Standard Rev iew Pl an-License R enewal SSC structure, system, a nd component SW service w ater TLAA time-limited aging analysis UFSAR Update d Fin al Sa fety An alys is Re port 503 AT TA CHMEN T 2:  PROJE CT T EA M A ND A PPLIC AN T PE RSONN EL; PUBLIC EXIT MEETING ATT ENDEES Project T eam G. Cranston/Roy Mathew , NRC, Team Lead er J. Davis, NRC, Rev iewer - Mechani cal R. Mathew , NRC, Rev iewer - Electrical D. Hoang, NRC, Review er - Structural R. Morante, BNL, Lead R eview er - Mech anical, M aterials, Struc tural M. Subudh i, BNL, Rev iewer - Material s, Mechani cal R. Lofaro, BNL, Re viewe r - Systems, M echanical K. Sulli van, BNL, Review er - AMP s, Systems, Fi re Protection M. Vil laran, BNL, R eview er - Systems, Fire Protecti on, Mecha nical B. Joh anson , Aerot ek, Admi nistra tive Suppo rt Project T eam Support K. Chang, NRC, Chief, RLEP S ection C D. Ashley , NRC, OCGS Li cense Renew al Project M anager App licant Personne l R. Artz , Subje ct Ma tter Ex pert, F uel Oi l Che mistry L. Corsi, Li cense Renew al Team Engineer M. Gallaghe r, Exelon Vice Presi dent, License Renewal S. Getz, Lice nse Renew al Team Engineer G. Harttraf t, Subject Matter Expert, Mechanical Systems ISI D. Honan, Li cense Renew al Team Engineer J. Hufnagel, NRC Interface/Licensing L ead M. Ma y, License Renewal Team Engineer C. Micklo, License Re newal Team Engineer M. Mi ller, Licen se Renew al Team Engineer K. Muggleston, License Re newal Team Engineer A. Ouaou, Lice nse Renew al Team Engineer F. Polaski, Li cense Renew al Mana ger T. Quintenz, Si te Lead Lice nse Renew al Engineer S. Raffertya, Licen se Renew al Team Engineer R. Skelsky, Sub ject Matter Ex pert, EDG Sys tem D. Warfel, Oyster Creek License R enewal Technical Le ad 504 Atten dees at the P ublic Exit Meeting on A pril 20, 2006 Name Organization Donnie J. A shley NRC Louise Lund NRC Ann Hodgdon NRC Ken Chang NRC Roy M athew NRC James Davis NRC Hans Ashar NRC Ron B ella my NRC Diane Scren ci NRC Marvin Sykes NRC Rich Mora nte Brookha ven N ation al La borato ry Jennifer Sneed Office of S enator Frank R. Laute nberg Joan Richa rds Office of Congressman Jim Sax ton Richard Pi nney New Jersey DEP Ron Zak New Jersey DEP David M ost Lacey Township Joseph Scarpelli Mayor-Brick Township Bud Swe nson Exelon/A merGen/Oyster Creek Tim Rausch Exelon/A merGen/Oyster Creek Mike Galagher Exelon/A merGen/Oyster Creek Don Warfel Exelon/A merGen/Oyster Creek John G. Hufnagel Exelon/A merGen/Oyster Creek Cindy Connelly Exelon/A merGen/Oyster Creek Wayne Romb erg Exelon/A merGen/Oyster Creek Jim La ird Exelon/A merGen/Oyster Creek Pete Resler Exelon/A merGen/Oyster Creek Rachelle Benson Exelon/A merGen/Oyster Creek Vinod Aggarwa l Exelon/A merGen/Oyster Creek Howie R ay Exelon/A merGen/Oyster Creek
***Exelon/A merGen/Oyster Creek George Rossi IBEW LU 400 Guy Peterson IBEW LU 400 Ed Stroup IBEW LU 1289 Paula Gotsch GRAMMES Jef fer y Brown GRAMMES Janet Tavro GRAMMES Jane R. De Marzo GRAMMES Gail Ma rsh Saxer League of Women Voter s Sandra Potasl es L WV Joan Rubin L WV Barbara Bail ine L WV Donald Warren Jersey Sho re Nuclear Watch 505 Name Organization
***JSNW***JSNW Kelly McNicho las Sierra Clu b Suza nne Le ta NJPIRG Steve Hea ley OCSD-OEM Paul Gunter NIRS Peggi Sturmf els NJE Federati on Tony DeMarzo MBC Mic hele Donato Mayor Scarpelli Ed Frydend ahl Manchester Resident Regina Di scenza Resident William Stockles Resident Sand ra Br own Resident Howa rd Sch wartz Resident Monty Williamson Local Joan ie M. Pa rks Waretown Resident George Chowern a Taxpayer***Times - Beaco n New spape rs Nicholas Clunn Asbury Park P ress Tom Mongelli Millennium Radio Bill M urray none listed Eugene Creamer none listed
*** Name not legible 506 ATT ACHMENT 3: A GING MANAGEMENT PROGRA M ELEMENT DESCRIPTIONS Ele ment Descr ipt ion 1. Scope of the Program Th e sc ope of the prog ram sho uld inc lude the s pec ific struc tures and com pon ents subj ect to a n agi ng management r evi ew.2. Preventive Acti ons Pre ven tive ac tions s hou ld m itigate or prev ent th e ap plicab le agin g eff ects. 3. Param eters Monitor ed or Inspect ed Parameters monitor ed or i nspected shou ld be li nked to t he effect s of agi ng on the intend ed fu nction s of th e pa rticular s tructu re an d co m pon ent. 4. Det ecti on of Ag ing E ffec ts Detecti on of agi ng effect s should occur bef ore t here i s loss o f any str uctur e and component int ended funct ion. This i ncludes aspects such a s method or t echnique (i.e., vi sual, vol umetric, surface i nspecti on), frequen cy, sample siz e, dat a coll ecti on and ti ming of new/
one-t ime inspect ions t o ensure t imely detect ion of aging effect s.5. Moni tori ng and Trendi ng Monitor ing an d tr ending should provi de predi cti on of t he extent of t he effect s of aging and ti mely cor recti ve or mit igat ive acti ons.6. Accept ance C rite ria Acceptance cr it eri a, agai nst whi ch the nee d for cor recti ve acti on wil l be eval uated, should ens ure that the particular str ucture and c om ponent intended fun ctions are maintai ned under al l cur rent li censing basis de sign con dit ions du ri ng the pe ri od of extended op erat ion.7. Corrective Acti ons Correct ive acti ons, i ncludi ng root cause dete rminati on and prev enti on of re currence, sh ou ld b e tim ely.8. Confi rmation Process The confir mation pro cess shoul d ensure t hat pr eventi ve acti ons are adequa te and appropri ate cor recti ve acti ons have been complet ed and are ef fecti ve.9. Adm inistr ative C on tro ls Adm ini strat ive contr ols shou ld pr ovi de a for mal revi ew and approv al pr ocess.10. Operat ing Experi ence Operati ng experi ence in vol vin g the agi ng managem ent pr ogram, incl uding past correct ive acti ons resul ti ng in program enhancements or addi ti onal p rograms, should provi de object ive evi dence to su pport a deter minati on that the ef fects of aging wil l be adequatel y managed so tha t t he str uctur e and component i ntended functi ons wil l be maintai ned duri ng the pe ri od of ext ended operat ion.
507 AT TA CHMEN T 4: S UMMA RY OF L RA A UDIT OPEN ITEMS During the audi t and revi ew, the proje ct team identifie d the follow ing open items.
These open items represent i ssues identi fied during the au dit and rev iew of the Oy ster Creek lice nse renewa l app li cat io n th at c oul d n ot b e re sol ve d a s pa rt o f th e a udi t, a nd we re f orw ard ed to t he NRC sta ff for resolution.
Open I tem No.Descr ipt ion 3.0.3.2.22-1 The project team found t hat t he absence of a leakage monit ori ng progr am to m eet t he cu rre nt lic en se ter m co m m itm en t ra ise s a qu es tion ab ou t the ba sis for the ap plic an t's clai m that wate r i s no l onger l eaking i nto t he annul ar gap bet ween the dr ywel l shel l and the concr ete shi eld wal l. The project team ident if ied t he revi ew of appl icant inf ormation tha t co nf irm s th e a bs en ce of w ate r lea ka ge into the an nu lar ga p b etw ee n th e d ryw ell shell and the concret e shiel d wall as Open It em  3.0.3.
2.22-1.3.0.3.2.22-2 However, b ecause ther e has been no UT inspe cti on conducted since 1996 and t he remaini ng corrosi on margin i n 1996 was l ess than 0.
1" at several locat ions, the pr oject team ini ti ated f urth er eval uati on of t he appl icant's agi ng managem ent comm it ment for UT inspecti on of t he former sand bed r egion. The project team ident if ied t he revi ew of appli cant i nformati on that confi rms the dry well shell in t he former sand bed r egion has the mini mum requi red t hickness t o ensure no l oss of i ntended f uncti on duri ng the extended pe ri od of oper ati on as Open It em 3.0.3.2.22-2.3.0.3.2.22-3 Because of t he minimal cor rosi on margin remaini ng in the f ormer sand bed regi on, and the appl icant's r eli ance on th e coati ng to mit igat e addi ti onal co rrosi on, t he proj ect t eam ini ti ated f urth er rev iew of the appl icant's i nspecti on progr am to ensure t hat t he coati ng wil l cont inue t o perfor m its i ntended f uncti on for t he extended peri od of oper ati on. The pr oje ct te am ide ntif ied the rev iew of a pp lica nt in fo rm atio n th at c on firm s th e d ryw ell s he ll in t he former sand bed r egion has the mini mum requi red t hickness and t hat coat ing and in specti ons are adequa te t o ensure no l oss of i ntended f uncti on duri ng the extended pe ri od of oper ati on as Open Item 3.0.
3.2.22-3.
508 ATT ACHMENT 5: LIST OF DOCUMENTS REVIEWED The followi ng is a lis t of documents rev iewed b y the project team as part of the a udit and rev iew of the OCGS LRA. In clusion of a document on thi s list does not imply that the project te am revi ewed the en tire d ocumen t; rathe r, sel ected sectio ns or p ortion s of the docume nts w ere review ed as part of the overall effort documented in thi s audit and review report. In addi tion, incl usion of a do cument in thi s lis t does not i mply NRC a ccepta nce of th e docu ment.Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed Oyster Creek Gene rat in g Sta ti on (OCGS) AMPs ASME Se ct i on XI Inser vice Inspect ion, Subsect io ns I W B, IW C, a nd IW D (B.1.1)XI.M1, AS ME Secti on XI I nservi ce Inspect ion, Subsect io ns I W B, IW C, a nd IW D Fo cus ed A rea S elf-A sse ssm ent (F AS A) R epo rt, ?Oyster Creek ISI Program," Apr il 26-29, 2004.Oys ter C reek OC-1 P rogr am Plan , ?OCG S ISI Program Plan Fourth Ten-Year I nspecti on Int erval ," Rev. 1, 09/30/2004 OC GS Im plem enting Pro ced ure T Q-AA-122 , ?Quali fi cati on and Certi fi cati on of Nondest ructi ve (NDE) Personnel
," Rev. 1, undated OC GS Im plem enting Pro ced ure E R-A A-3 35-0 25, ?Oversight of Vendor NDE Acti vit ies," Rev. 1, undat ed OCG S NIS-1 I nservi ce Inspect ion Dat a Report f rom 1R19 Refueli ng Outage, January 22, 2003 OCG S NIS-1 I nservi ce Inspect ion Dat a Report f rom 1R20 Refueli ng Outage, February 16, 2005 PB D-A MP-B.1.01, ?OCGS Pr og ra m Bas i s Do cu ment AS ME Secti on XI I nservi ce Inspect ion, Subsecti ons IW B, I W C, and IW D," Rev. 0, 11/28/2005 Ex elon Nu clea r Pro ced ure E R-A A-3 30, ?Conduct of I nservi ce Inspect ion Act ivi ti es," Rev. 4, undated W ater Chem istry (B.1.2)XI.M2, Water C he m istr y plan t-spe cific A MP BW RV IP-1 30, ?BW R Ve ss el a nd Inte rn als Pro ject:  B W R W ater C hem istry Gu idelines - 20 04 R evisio n,"EPRI TR-1008192, Fi nal Repor t, October 2004 BW RV IP-7 9, ?BW R Vessel and I nter nals Pr oject:  BW R W ater Chem ist ry Guidel ines - 2000 Revisi on," EPRI TR-103515-R2, Final Report, March 2000 BW RV IP-2 9, ?BW R Vessel and I nter nals Pr oject:  BW R W ater Chem ist ry Guidel ines - 1996 Revisi on," EPRI TR-103515-R1, Final Report, Decem ber 1996 NE I 03-0 8, ?G uid elin e fo r th e M an ag em en t of M ate ria ls Issues," May 2003 OC GS Im plem enting Pro ced ure C Y-A B-1 20-1 000 , ?BW R Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 509 Ch em istry Op tim ization," R ev.2 OC GS Im plem enting Pro ced ure C Y-A B-1 20-1 100 , ?Reactor W ate r H ydr og en W ate r C he m istr y, N ob le C he m an d Z inc Injec tion," R ev.2 OC GS Im plem enting Pro ced ure C Y-A B-1 20-1 00, ?Reactor W ater Chem istry ," Rev.7 OCG S Implementing Procedure CY-AB-120-110,?Co nde nsa te an d Fe edw ater C hem istry," Re v.7 OC GS Re port, ?Focus Area Sel f-Assessment Report
," 4/13 -4/16, 2004 PB D-A MP-B.1.02, ?W ater Chem istry ," Rev. 0, dated 11-22-200 5.Reactor Head Closure Studs (B.1.3)XI.M3, React or Head Closure St uds PB D-A MP-B.1.03, ?Reactor Head Cl osure St uds Oyster Creek Generati ng Stat ion," Rev. 0, 12/08/2005 OC-1, ?ISI Pr ogra m Plan Fou rth T en-ye ar ins pec tion Inte rval,"Rev. 1, 9/30/04 Dra wing CE 232-573 , "Stud , Nu t, W ash er, & B ush ing D etail,"Rev. 10 Certi fi ed Materi al Test Report (CMT R), Cruci ble St eel Com pany, Piece Number 573-01, Code Num ber G-385, 8/7/65 BW R V ess el ID Att achment W elds (B.1.4)XI.M4, BWR Vessel ID Att achment W elds PB D-A MP-B.1.04, ?BW R V ess el ID A ttach m ent W elds ,"Rev. 0, 12/07/2005 BW R Vessel I d Att achment welds Oyster Cree k G enerating Station (implem entation procedure), OC-5, ?Program Plan, Reactor I nter val s Program," Rev.
0, 09/30/2005 BW R Feedwater Nozzl e (B.1.5)XI.M5, BW R Feedwater Noz zl e NURE G-0619, " BW R Feedwater Nozz le and Control Rod Driv e Return L ine Noz zl e Cracking," November 1980 G E N E-52 3-A7 1-05 94-A ,"A lter na te B W R Fe ed wa ter No zzle Inspect ion Requi rement," Revisi on 1, August 1999 OC-1, ?OCG S ISI Program Plan f or Fourt h Ten-Year Inspect ion I nter val ," Rev.1, 09/01/2004 Lett er P. F. McKee (NRC) to J.
J. Bar ton (GPU), "Eval uati on of the Request for Rel ief From NU REG-0619 for Oyst er Creek Nuclear Generati ng Stat ion (TAC N o. M85751)" dated Octo ber 4, 1994 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 510 Let ter A. M. Dromeri ck (NRC) t o J. J. Ba rt on (GPU), "GPU Nuclear Corporat ion Pr oposal to Revi se NUREG-0619 Rega rding the Feedw ater Nozzles and C ontrol Rod Drive Return Li ne Nozzl e (TAC No. M83157)," dated Jul y 8, 1992 Drawing MP 1083-8 7-01, Sheets 1 and 2, " Feedwater Spar ger Assem bly & Detai ls" DRF 88021, R3, (MDD-OC-422A, R3), "Modif icat ion Desi gn De scr iption fo r M ain F eed wate r Line Bloc k V alve A ddition ," November 29, 1989 Lett er J. C. Devi ne to NRC, " Revisi on to NUREG 0619 Routi ne Inspect ion Cri teri a for Feedwat er and Cont rol Rod Driv e Return L ine Noz zl es," September 1, 19 92.PBD-AMP-B.1.05," BW R Feedwater Nozz le," Rev. 0, 12/09/2005 BW R Control Rod Driv e Return L ine N ozz le (B.1.6)XI.M6, BW R Control Rod Drive R etu rn Lin e N ozz le NURE G-0619, " BW R Feedwater Nozz le and Control Rod Driv e Return L ine Noz zl e Cracking," November 1980 OC-1, ?OCG S ISI Program Plan f or Fourt h Ten-Year Inspect ion I nter val ," Rev. 1, 09/01/2004 Lett er P. F. McKee (NRC) to J.
J. Bar ton (GPU), "Eval uati on of the Request for Rel ief From NU REG-0619 for Oyst er Creek Nuclear Generati ng Stat ion (TAC N o. M85751)" dated Octo ber 4, 1994 Let ter A. M. Dromeri ck (NRC) t o J. J. Ba rt on (GPU), "GPU Nuclear Corporat ion Pr oposal to Revi se NUREG-0619 Rega rding the Feedw ater Nozzles and C ontrol Rod Drive Return Li ne Nozzl e (TAC No. M83157)" dat ed July 8, 1992 D ra win g G E 9 21 D 25 7, "C on tro l Ro d D rive (C R D) H ydr au lic Syste m Re turn N ozzle S afe End Re plac em ent" OC NG SR 14-A CR D, "C RD RL No zzle Insp ection (RF O 1 4)," Decem ber 1992 Lett er J. C. Devi ne to NRC, " Revisi on to NUREG 0619 Routi ne Inspect ion Cri teri a for Feedwat er and Cont rol Rod Driv e ret urn Li ne Nozzl es," September 1, 19 92 R ep or t 99 0-17 43 , "D es ign Re po rt o f C R D Re tur n N ozz le Thermal Sleeve Modifi cati on," September 1977 OC GS OC-5 P rogr am Plan , ?Re acto r Intern als P rogr am ,"Rev. 0, 09/30/2005 PB D-A MP-B.1.6, ?BW R C RD Re turn L ine N ozzle," R ev. 0 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 511 BW R Stress Corrosi on Cracking (B.1.7)XI.M7, BWR Stress Corrosi on Cracking OC-1, ?OCG S ISI Program Plan f or Fourt h Ten-Year Inspect ion I nter val ," Rev.1, 09/01/2004 N R C G L 8 8-01 , "N R C Po sitio n o n IG SC C in B W R Au ste nitic Stai nless St eel Pi ping," U.S. Nuclear Regulat ory Com mission, January 25, 1988; Suppl ement 1, Februar y 4, 1992 NURE G-0313," Technical Report on Materi al Sel ecti on and Proces sing Guidelines for BW R C oolant Pressure Bound ary Pipi ng," W. S. Hazel ton and W. H. Koo, U.S.
Nuclear Regulat ory Com mission, Rev. 2, 1988 OCGS IGS CC I nsp ect i on P ro gr am Pl an OC-2, "I GSCC Inspect ion Pr ogram (GL 88-01 and BW RVIP-75)," Rev. 0, 07/31/2003 BW RVIP-75, "BW R Vessel and I nter nals Pr oject: Techni cal Ba sis fo r Re vision s to G L 88-01 In spe ction S che dule ," October 1999 Bateman, W.H., NRC Final SER of t he BW RVIP-75, May 14, 2002 ASME C ode, Sect ion XI , " Rules for In-servi ce Inspect ion of Nuclear Plant Com ponents," 1995 Edi ti on thr ough 1996 Addendum OCG S Implementing Procedure ER-AA-3 30-002, "I n-serv ice Insp ection of S ection XI W elds and Co m pon ents ," Re v. 4 OCGS I mpl emen t i ng Pr oc ed ur e E R-AA-33 0-00 9, " ASM E Se ction X I Re pair/R epla cem ent P rogr am ," Re v. 3 PBD-AMP-B.1.07, "BW R Stress Corr osion Cr acking," Rev. 0, 12/19/2005 TR-050, "GPUN Response to GL 88-01 and NUREG 0313, Rev. 2," Rev. 3, 12/17/1990 BW R Penetrat ions (B.1.8)XI.M8, BW R Penetrat ions BW RVIP-1 30, "BW R Vessel and I nte rnal s Proj ect: BW R W at er Chemi st ry Gui del i nes - 20 04 Re vi si on," E PRI TR-1008192, Fi nal Repor t, October 2004 BW RVIP-2 7-A, "BW R Stand by Liquid Control System/Co re Pl at e DP I nsp ect i on a nd F l aw E va l uat i on Gu i del i nes , EPRI TR-107286, Jul y 2003 BW RVIP-49-A, "I nstru ment Penetrat ion I nspecti on and Fl aw Evalua ti on Guidel ines," EPRI TR-108695, March 2002 OCG S Reactor I nter nals Pr ogram Plan OC-5, " Reactor Int ernal s Program" Rev.
0, 09/30/2005 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 512 OCGS Impl ement i ng P ro ced ur e ER-AB-331-1 001 , "B W R RX Intern als," R ev.1 OCGS Impl ement i ng P ro ced ur e ERR-AB-331 , "B W R RX Intern als M ana gem ent P rogr am Activities
," Re v. 3 OCGS I mpl emen t i ng Pr oc ed ur e E R-AA-33 0-00 9, " ASM E Se ction X I Re pair/R epla cem ent P rogr am ," Re v.3 PBD-AMP-B.1.08, "BW R Penetrat ions," Rev. 0, 11/22/2005 BW R Vessel Int ernal s (B.1.9)XI.M9, BWR Vessel Inte rn als PB D-A MP- B.1.9 , ?BW R V ess el Intern als," R ev. 0 Thermal Aging and Neutron I rradi ati on Em bri tt lement of C as t Au ste nitic Stai nless St eel (B.1.10)XI.M13, Thermal Aging and Neutron Irr adiat ion Em bri tt lement of C as t Au ste nitic Stai nless St eel PB D-A MP- B.1.1 0, ?Thermal Aging and Neutron I rradi ati on Em bri tt lement of Cast Austeni ti c Stai nless St eel," Rev. 0, 12/15/2005 Flow-Accel erat ed Corrosi on (B.1.11)XI.M17, Fl ow-Acceler ated Corrosi on PB D-A MP- B.1.1 1, ?Flow-Ac cele rated Co rros ion," R ev. 0 Bo lting Integ rity (B.1.12)XI.M18, Bolt ing Integ rity PB D-A MP- B.1.1 2, ?Bo lting Integ rity," Rev. 0 Open-Cycl e Cooli ng W ater Syst em (B.1.13)X I.M 20 , O pe n-C ycle Cooli ng W ater Syst em PB D-A MP-B.1.13, ?Oyster Creek Program Basis Document Open Cycle Cool ing Water Syst em," Rev. 0, 12/7/2005 TR 140 , ?Em ergency Servi ce W ater and Servi ce W ater Syst em Piping Pl an," Rev. 2, May 4, 2005 ER-AA-340 , ?GL 89-1 3 Pr ogra m Im plem enting Pro ced ure,"Rev.2, undated SP-130 2-12-261 , ?Safety-rel ated Speci fi cati on for Pi pe Int egri ty Inspect ion Pr ogram," Rev.
7, 12/15/2004 & Rev.
8a, undated TD R-8 29, ?Insp ection Histo ry of the OC NG S P ipe Inte grity Program (Pipe Int egri ty Inspect ion Pr ogram)," Rev.
4, 12/15/2004 600 7.4.0 07, ?Contai nment Spray a nd Emergency Servi ce W ater Syst em 1 Pum p Operabil it y Test ," Rev. 18, undated C los ed-C ycle Cooli ng W ater Syst em (B.1.14)
XI.M21, C los ed-C ycle Cooli ng W ater Syst em PB D-A MP-B.1.14, ?Oys ter C reek Pro gram Bas is Do cum ent: Closed Cy cle Cool ing Water Syst ems," Rev. 0 12/
19/05 W TC Pro ject N o. 10 49, ?Closed Cy cli ng Cooli ng W ater Chem ist ry Assessment Oyster Creek Nuclear Genera ti ng Stat ion," 09/06/2001 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 513 EP RI 1 007 820 , ?Closed C ycle Cooling W ater Chem istry Guidel ines," Revi sion 1, Final Report Apr il 2004 CY-AA-120-400 , ?C los ed Co olin g W ate r C he m istr y Str ate gic Plan ," Re v. 8 309.1.1, ?Turbine Bui ldi ng Closed Cool ing Water Routi ne Evolut ions"CY-AA 120-110 , ?Ch em istry Lim its and Fre que ncie s," R ev. 0 642.4.00 1, ?RBCC W In-servi ce Test," Rev. 25 636.4.00 3, ?Diesel Generator
#1 Load Tests," Rev. 73 CA P 02 000 , ?140 8 U T M eas urem ents of R BC CW Piping ,"10/10/2000 Borafl ex Rack Managem ent Program (B.1.
15)XI.M22, Borafl ex Monitor ing PB D-A MP-B.1.15, ?OCG S Program Basis Document: Bor afl ex Ra ck Ma nag em ent P rogr am ," Re v. 0 Inspect ion of Overh ead H eavy Load and Li ght Loa d (R elated to Refueli ng) Handl ing Syst ems (B.1.16)
XI.M23, Inspect ion of Overh ead H eavy Load and Li ght Loa d (R elated to Refueli ng) Handl ing Syst ems PB D-A MP-B.1.16, ?OC GS Pro gram Bas is Do cum ent: Inspect ion of Overhead heavy Load and Li ght Load (Relat ed to Refuel ing) handl ing Sy stems," Rev.
0, undat ed OCG S CAP Report O2000-1446, 10/15/2000 OCG S CAP Report O2004-0601, 02/24/2004 OCG S CAP Report O2004-2877, 10/03/2004 C om pr es se d A ir Monitor ing (B.1.17)XI.M24, C om pr es se d A ir Monitor ing PB D-A MP-B.1.17, ?Oys ter C reek Pro gram Bas is Do cum ent: Com pressed Ai r Monit ori ng," Rev. 0, 11/28/2005 CA P-0 200 4-06 47, ?Fa ilure of B oth Se ts o f In str um en t Air Dryer s," 03/17/2004 ISA-S7.0.01-199 6, ?Qu ality Stand ard f or Ins trum ent A ir,"11/12/1996 SD BD-O C-8 52, ?Pla nt C om pr es se d A ir S yste m De sig n B as is Do cum ent," R ev. 3 R0 800 446/PM 008 11, ?Inst rument Air Syst em D ew Point and Parti culat e Stat us," 06/25/2001 R0 800 738 , ?Instru m ent A ir Lea k T est, M SIV V 1-7 Statu s,"03/25/2001 Co rres pon den ce file n o 88 156 , ?OCNGS Re sp on se t o GL 88-14," 02/21/1992 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 514 Co rres pon den ce N o. C 321-92-207 2, ?OCN GS Status of Acti ons in Response to GL 88-14," March 9, 1992 Les son Plan 261 1, ?PBGD Servi ce Inst rument and Breat hing Air, Course 828.
0.0043," Rev. 8, 8/30/2004 BW R Reactor W ater Cleanup Syst em (B.1.18)XI.M25, BWR Reactor W ater Cleanup Sy stem OC GS Do cum ent O C-2 , ?I GSCC I ns pe ct i on Pr og ra m (GL 88-01 and BW RVIP-75)," Rev. 0, 07/31/2003 GP U L etter to NR C 1 940-00-200 96, ?Oys ter C reek Re que st to Eli minate I nspecti ons," Apri l 13, 2000 PB D-A MP-B.1.18, ?OCGS Program Basis Document:
BW R Reactor W ater Cleanup Sy stem," Rev.
0, 11/17/2005 Fire Protect ion (B.1.19)XI.M26 , Fire Protect ion PB D-A MP-B.1.19, ?Oys ter C reek Pro gram Bas is Do cum ent: Fire Protect ion Rev. 0," 11/23/2005 CC-AA-211 , ?Fire P rotec tion P rogr am ," Re v. 1 645.6.01 7, ?Fire Barri er Penet rati on Survei ll ance," Rev. 10, 06/2004 101.2, ?Oyster Creek Sit e Fir e Prote cti on Program," Rev.
54 645.6.01 3, ?Fire S upp res sion Syste m Ha lon F unc tional T est,"Rev. 19, 06/2005 645.6.01 6, ?Fire Suppressi on Low Pressure CO2 System Functi onal Test ," Rev. 8, 02/2003 645-6.02 8, ?The rm o-Lag and Mec atiss Envelope System Fire Barri ers," Rev. 7, 11/17/2000 020 00-3 90, ?W all Penetr ati on Seal Shri nkage," 0 3/20/2000 020 00-1 356 , ?Da m age d Blo ck W all in Elec tric T ray R oom ,"09/17/2002 020 01-0 601 , ?D isc re pa nc ies Du rin g F ire Do or Se lf Assessm ent W alkdown," 04/12/2001 020 01-0 247 , ?Fire Dam per Failures During SE B Fire Alarm and Halon Ci rcui try Survei ll ance Test (645
.6.030)," 02/16/2001 LIB R 080 211 4, ?Fire Door Eval uati on Stat us," June 25, 2 001 LIB R 080 212 9, ?Fire Door Eval uati on Stat us," June 25, 2 001 LIB R 080 216 6, ?Fire Door Eval uati on Stat us," June 25, 2 001 Fire W ater Syst em (B.1.20)XI.M27, Fire W ater Syst em PB D-A MP-B.1.20, ?Oys ter C reek Pro gram Bas is Do cum ent: Fire W ater Syst em," Rev 0, 12/
01/2005 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 515 NF PA 25, ?Standard for t he Inspect ion, Testi ng and Mainten ance of W ater-Based Fi re Prot ecti on Syst ems," 1998 Edit ion CA P 02 002-091 6, ?Leakage Noted Duri ng Fir e Prote cti on Syst em Flush (645.
6.007)CA P 02 002-101 9, ?Incre ased Cleani ng Frequency of Micr on Fil ters at Di lut ion Pl ant," Event date 07/12/2002 Pro gram He alth R epo rt, ?Oyster Cree k Fire Protection/Fire Safe Shutdo wn Program 4th Quart er," 2003 SP-130 2-52-108 , ?Sp ecifica tion fo r Insp ection of T ank s,"Rev. 3, 05/13/1992 101.2, ?Oyster Creek Sit e Fir e Prote cti on Program," Rev.
54 645.6.00 7, ?Fire Protect ion Sy stem Flush Rev.
15 645.6.00 3, ?Fire Hose Stati on, Hose House and Fi re Hydr ant Inspect ion," Rev. 18 R0 804 258 PM 811 01M , ?MIC Testing o f Fi re Prot ecti on W ater Stat us," 29 June 2001 645.6.01 2, ?Fire Pum p Functi onal Test ," Rev. 29 645.6.01 1, ?Deluge and Spr inkl er Sy stem Inspect ion," Rev. 11 CC-AA-211 , ?Fire P rotec tion P rogr am ," Re v.1 Aboveground Outd oor Tanks (B.1.21)XI.M29, Aboveground Carb on St eel Tanks PB D-A MP-B.1.21, ?OC GS Pro gram Bas is Do cum ent: Aboveground Out door Tanks,"
Rev. 0, 11/21/2005 Fuel Oil Chem istry (B.1.22)X I.M 30 , Fu el O il Chem istry NU RE G-143 3, ?Standard Technical Specif icat ions General Elect ri c Plant s, BW R/4," Vol. 1, Rev. 3.0, June 2004 NR C R egu latory G uide 1.13 7, ?Fuel Oi l Sy stems for Sta ndby Diesel Generator s," Rev. 1, October 1979 AS TM Stan dard D 2 276-00, ?Standard Test Method f or partic ulate C onta m ination in Aviatio n fue l by Line S am pling,"2000 AS TM Stan dard D 2 709-96, ?Standard Test method for W ater and Sediment i n Middl e dist il lat e Fuels by Centri fuge," 1996 AS TM Stan dard D 4 057-95, ?Standard Practi ce for Manual Sam pli ng of Pet rol eum and Petrol eum Products,"
2000 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 516 PB D-A MP-B.1.22, ?O C G S P ro gr am Ba sis Do cu m en t: F ue l O il Chem ist ry ," Rev. 0, 11/21/2005 OC GS Im plem enting Pro ced ure C Y-O C-1 20-1 107 , ?Fu el O il Sam ple an d Analy sis Schedul e," Rev. 0, undated OC GS Im plem enting Pro ced ure C Y-O C-1 30-7 001 , ?W ater and Sediment," Rev. 0, undat ed OC GS Im plem enting Pro ced ure 3 27.1 , ?Fuel Oi l Recei pt and handli ng Procedure
," Rev. 30, undated OC GS Im plem enting Pro ced ure 8 28.7 , ?Secondary Syst ems Analy sis: Plant Oil ," Rev. 22, undated OC GS Spe cificatio n SP-130 2-38-010 , ?OCG S Specif icat ion for O yster C reek Ge nera ting S tation D iese l Fue l Oil No. 2,"Rev. 8, 06/23/2004 Reactor Vessel Survei ll ance (B.1.23)XI.M31, Reactor Vessel Sur vei ll ance PB D-A MP-B.1.23, ?OCG S Program Basis Document: React or Ve sse l Surv eillance ," Re v. 0 On e-Ti me Inspect ion (B.1.24)X I.M 32 , O ne-T im e Inspect ion OC GS Re port, ?Inspect ion Sample Basi s, Oyst er Creek License Renewal Proj ect," August 16, 2005 PB D-A MP-B.1.24, ?OC GS Pro gram Bas is Do cum ent: One-Time Inspecti on," Rev. 0, undated EP RI R epo rt 100 070 1, ?Int eri m T hermal Fati gue Management Guidel ine (MRP-24)," Janu ary 2001 Select ive Leachi ng of Materi als (B.1.25)XI.M33 , Selective Leaching of M ate ria ls PB D-A MP- B.1.2 5, ?Select ive Leachi ng of Mater ial s," Rev. 0, 12/04/2005 Buri ed Pipi ng Inspect ion (B.1.26)XI.M34, Buri ed Pi pi ng an d Tanks Inspect ion PB D-A MP- B.1.2 6, ?Buri ed Pipi ng Inspect ion," Rev. 0, 12/04/2005 AS ME Sec tion X I, Su bse ction IW E (B.1.27)XI.S1 , AS ME Se ction X I, Su bse ction IW E PB D-A MP- B.1.2 7, ?AS ME Sec tion X I, Sub sec tion IW E,"Rev. 0, 12/04/2005 AS ME Sec tion X I, Su bse ction IW F (B.1.28)XI.S3 , AS ME Se ction X I, Su bse ction IW F PB D-A MP- B.1.2 8, ?AS ME Sec tion X I Sub sec tion IW F,"Rev. 0, 12/04/2005 OCG S Focus Area Sel f Assessment Report Apr il 26-29, 2004 CAP 02004-736 CAP 02001-1187 AS ME Sec tion X I, 199 5 Ed ition, Su bse ction IW F Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 517 240 0-G MM-390 0.52 , ?Ins pe ctio n a nd T or qu ing of B olt Co nne ctions ," Re v. 3 ER-AA-330 , ?Co ndu ct of In Ser vice In spe ction A ctivate d,"Re v. 4 ER-AA-330-003 , ?In-s er vi ce I nsp ect i on o f S ect i on XI Co m pon ent S upp orts," R ev. 3 ER-AA-335-016 , ?VT-3 Visual Examinati on of Component Su ppo rts an d Atta chm ents ," Re v. 2 OC-1, ?OC ASM E Secti on XI Progr am Plan Fourth Ten Year Inspect ion I nter val ," Rev. 1 09/
30/04 10 CFR Part 50, Appendix J (B.1.29)XI.S4, 10 CF R Pa rt 50, Appendi x J PB D-A MP-B.1.29, ?10 CFR Part 50, Appendix J, Rev. 0, 12/01/2005 020 00-1 355;020 02-1 564 , ?Plant Operati ng Experi ence"02004-3442.
;02005-1350 ?Plant Operati ng Experi ence"Oyster Creek FSAR (excerpt)
Table 6.2-12, "Contai nment Isol ati on Valv e/Mechani cal I ntegr it y," 28 pages ER-AA-380 , ?Primary Contai nment Leakage Rak Testing Pro gram ," Re v. 3 ER-O C-3 80, ?Oyster Creek Pri mary Contai nment Leakage Ra te T esting Pro gram ," Re v. 0 M as on ry W all Program (B.1.
30)XI.S5, Ma sonry W all Program PB D-A MP- B.1.3 0, ?Masonry W all Program," Revi sion 0, 12/18/05 CA P-0 200 3-00 38, ?Issue Report-Vari ous Defici encies Id ent i fi ed b y NRC"CA P-0 200 2-00 65, ?Iss ue Re po rt- C ra ck in b etw ee n P ou r W all and Co ncr et e Bl ock"AC I-201-1R-92, ?Guide for Making Condit ion Sur vey of Concrete i n Servi ce"AC I-530-92-AS CE 5-92 , ?Buil ding Code Requi rements for Masonry St ructu re"TD R 8 30, ?Ma son ry Bloc kw all W alk D own Per IEB-8-1 1,"Rev. 1, 09/18/88 Struct ures Monitor ing Pr ogram (B.1.31)XI.S6, Struct ures Monitor ing Pr ogram PB D-A MP-B.1.31, ?OC GS Pro gram Bas is Do cum ent: Stru cture s M onitor ing P rogr am ," Re v. 0 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 518 125.6, ?Bu ilding Str uctu re M onitor ing P rogr am ," Re v. 4 240 0-G MM-390 0.52 , ?Inspect ion an d Torquin g of Bol tek Co nne ctions ," Re v. 3 NU RE G-180 1 & A CI 3 49.3 8.02 , ?Evalua ti on of Exi sti ng Nuclear Safety-rel ated Concret e Struct ure," Rev. 1, June 17
, 2002 10 C FR 50.6 5, ?Mainten ance Rule" SP-130 2-53-051 , ?Specif icat ion f or Peri odic Moni tori ng of t he Concrete Cracks i n the React or Bui ldi ng Stru cture"RG 1.127, Inspect ion of W ater-Contr ol Struct ures As soc iated W ith Nuclear Power Plant (B.1.32)XI.S7, RG 1.127, Inspect ion of W ater-Contr ol Struct ures As soc iated w ith Nuclear Power Plan ts PB D-A MP-B.1.32, ?OCGS Pr ogr am Basi s Doc ument: RG 1.12 7, Ins pec tion of W ater-Co ntrol S tructu res Ass ocia ted W ith Nu clea r Po wer Plan ts," R ev. 0 Protect ive Coati ng Monitor ing an d Mainten ance Program (B.1.
33)XI.S8, Protective Coati ng Monit ori ng and Maint enance Program PB D-A MP-B.1.33, ?OC GS Pro gram Bas is Do cum ent: Pro tective Co ating M onitor ing an d M ainten anc e Pr ogra m ,"Re v. 0 Elect ri cal Cabl es and Connecti ons Not Subject to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents (B.1.34)XI.E1, Elect ri cal Cables and Connecti ons Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents PB D-A MP-B.1.34, ?Elect ri cal Cabl es and Connecti ons Not Subject to 10 CFR 50.49 Envir onmental Qual if icat ions Requirements" NU ER G/C R-5 643 , ?Insigh ts G aine d Fr om Agin g R ese arc h,"U.S. Nucl ear Regul ator y Comm issi on, March 1992 EP RI T R-1 096 19, ?Guidel ine f or t he Managem ent of Adverse Locali zed Equi pment Envir onments," El ectri c Power Research Inst it ute, Palo Al to, CA, June 1999 IEE E S td. P1 205-200 0, ?IEEE Guide f or Assessi ng, Moni tori ng an d M itiga ting Ag ing Ef fe cts on Cla ss 1E Eq uip m en t U se d in Nuclear Power Generati ng Stat ions"SA ND 96-0 344 , ?Aging Management Guidel ine f or Comm erci al Nuclear Power Pla nts- Elect ri cal Cabl e and Terminati ons,"prepared by Sandi a Nati onal L aborat ori es for the US Depart ment of Energy , Sept ember 1996 Oys ter C reek Eng inee ring S tand ard E S-0 27, ?Envir onmental Parameters- Oy ster Creek NGS," Rev. 4, 06/13/2000 Oys ter C reek Spe cificatio n, SP-900 0-41-005 , ?Inst all ati on Sp ecifica tion fo r Ca bles and Ra cew ays a t Oys ter C reek ,"Revisi on 5, 08/16/86 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 519 Elect ri cal Cabl es and Connecti ons Not Subject to 10 CFR 50.49 Envir onmental Quali fi cati on Requirements Used in I nstru mentati on Circui ts (B.1.35)XI.E2, Elect ri cal Cables and Connecti ons Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on Requirements Used in I nstru mentati on Circ uits PB D-A MP-B.1.35, ?Elect ri cal Cabl es and Connecti ons Not subject to 10 CFR 50.49 Envir onmental Qual if icat ion Requirements Used i n Inst rumentati on Circu it s"Oys ter C reek Pro ced ure 2 400-SM I-362 3.03 , ?I RM, SRM, LPRM C haract eri zat ion Trend ing an d Diagnost ics"Oys ter C reek Pro ced ure 2 400-SM I-362 3.08 , ?IRM Detector Current-Vol tage (I.V.) Test ing"Oyster Creek Routi ng W ork Order R0802887 f or implementi ng 2400-SMI-3623.03 Oys ter C reek Sur veillanc e T est 6 21.3.005 , ?High Radi ati on Monitor- Reactor Buil ding I solat ion-Cali brat ion"Oyster Creek Routi ng W ork Order R0803575 f or implementi ng ST 621.3.
002 LS-AA-125 , ?Co rrec tive Ac tion P rogr am (CA P) P roc edu re,"Revisi on 9 OC Pro ced ure 2 400-SM I-362 3.08 , ?IRM Detector Current-Vol tage (I.V.) Test ing"OC Pro ced ure 2 400-SM I-362 3.09 , ?Cali brat ion an d Operati on of t he LPRM Diagnosti c Syst em," Revisi on 11 OC Pro ced ure 6 21.3.002 , ?Air Eject or Off Gas Radiat ion Monitor Check Source Functi onal Test ," Revisi on 25 OC Pro ced ure 6 21.3.005 , ?High Radi ati on Monit or (React or Buil ding I solat ion) Cali brat ion," Revi sion 46 330 592.35.0 2, 24 00-S MI-362 3.08 , ?Proced ure Rev isi on (I.V.tes ting for IR M s) for O C Lic en se Re ne wa l"330 592.35.0 9, ST 213 02A W ork Or der r evisio n req ues t to implement 621.
3.002 f or OC License Renewal Oys ter C reek Te chn ical Sp ecifica tions, T able 4.1.1 Ina cc es sib le Medium Voltage Cables Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents (B.1.36)XI.E3, Ina cc es sib le Medium Voltage Cables Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents PB D-A MP-B.1.36, ?Inaccessi ble Medi um-Voltage Cabl es Not Subject to 10 CFR 50.49 Envir onmental Qual if icat ion Requirements" EP RI T R-1 096 19, ?Guidel ine f or t he Managem ent of Adverse Locali zed Equi pment Envir onments," June 1999 IEE E S td 40 0-20 01, ?IEEE Guide f or Fi eld Test ing an d Ev alu atio n o f th e In su latio n o f S hie lde d P ow er Ca ble Syst ems," January 2002 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 520 En gine ering Eva luation 016 4-97 , ?Oyster Creek Medium Volt age Cable Test Program," May 15, 1997 O yste r C re ek 2.4 kV an d 4.16 kV ca ble tes t m atr ix p re pa re d in su pp or t of O cto be r 20 04. N R C AM P a ud it; S ub se qu en tly rev ise d and su bmitt ed i n th e AmerGen resp onse t o RAI 2.5.1.19-1 for t he Forked Riv er Combustion Turbi ne, October 12, 2005; Subsequentl y r evi sed to r econcil e dif ferences between t he draft revi sion of NURE G 1801, January 2005 and the i ssued Revisi on 1 to NURE G 1801, Septe mber 2005.
LS-AA-125 , ?Co rrec tive Ac tion P rogr am (CA P) P roc edu re,"Revisi on 9 OC Pro ced ure 2 400-SM E-3 78.0 5, ?Power Factor Testi ng of 5kV Cables,"
Revisi on 2 (Used as par t of current cable test ing prog ram.)OC Pro ced ure 2 400-SM E-3 780.06, ?Diele ctric T esting for 2.3 kV an d 5kV Cables an d Equipm ent," Revision 8 (Used a s part of curr ent cabl e test ing pr ogram)Exam ple of completed W O for DTE Testing, C2008036 EP RI T R-1 003 057 , ?Lice nse Re new al Elec trical H and boo k,"Decem ber 2001 EP RI T R-1 003 664 , ?Medium-Volt age Cables i n Nuclear Plant Ap plication s- S tate o f Indu stry an d C ond itioning M onitor ing,"October 2003 Am erGen response t o RAI 2.5.1.19-1, October 12, 2005 Oys ter C reek Eng inee ring E valua tion 01 64-9 7, ?Oyster Creek Medium Voltage Cable Test Pr ogram," May 15, 1997"W hit e Paper" Appendix E, on Assessment of Under ground Cable Fai lur es, submit ted t o the st ate of New Jersey, Bureau of Nuclea r Engi neeri ng, 7/25/05 Peri odic Moni tori ng of Combustion Turbine Power Plant Elect ri cal (B.1.37)NA Infor m ation N otice 8 9-64 , ?Elect ri cal Bus Bal Fail ures"Inform ation Notice 2000-14, "No n-Vital Bus Fault Leads to Fire and Los s of Off-S ite Power" LS-AA-125 , ?Co rrec tive Ac tion P rogr am (CA P) P roc edu re,"Revisi on 9 IEE E S td 12 05-2 000 , ?IEEE Guide f or Assessi ng, Moni tori ng an d M itiga ting Ag ing Af fe cts on Cla ss 1E Eq uip m en t U se d in Nuclear Power Generati ng Stat ions," 03/30/2000 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 521 RAI Response to NRCRAI 2.5.
1.19-1, 10/12/05 AR A2078783, corr ecti ve maintenan ce EP RI T R-1 096 19, ?Guidel ines f or t he Managem ent of Adverse Locali zed Equi pment Envir onments," June 1999 Peri odic Test ing of Contai nment Spray Nozzl es (B.2.1)Oyster Creek pla nt-sp ec ific program Assi gne d t o DE Lu br ica ting O il Monitor ing Act ivi ti es (B.2.2)Oyster Creek pla nt-sp ec ific program Assi gne d t o DE Generator Stat or W ater Chem istry Acti vit ies (B.2.3)Oyster Creek pla nt-sp ec ific program Assi gne d t o DE Peri odic I nspecti on of Vent il ati on Syst ems  (B.2.4)
Oyster Creek pla nt-sp ec ific program Assi gne d t o DE Peri odic I nspecti on Program  (B.2.5)
Oyster Creek pla nt-sp ec ific program Assi gne d t o DE Peri odic Moni tori ng of Combustion Turbine Power Plant (B.2.7)Oyster Creek pla nt-sp ec ific program AM P de leted b y applica nt.Metal Fati gue of Reactor Cool ant Pressu re Bound ary (B.3.1)X.M1, Metal Fati gue of Reactor Coolant Pressu re Bound ary PB D-A MP-B.3.01, ?Metal Fatigue of R eactor Co olant Pressure Boundary ," Rev. 0, 12/07/2005 Ref. 3.1 4.1 , " Cycl e based Fati gue dev el opment f or RPV, Torus & Isol ati on Condenser Locat ions" Ref. 314.14, " Cycl e counti ng & cycl e based fat igue r eport for the t ransi ent & f ati gue monitor ing sy stem for t he Oyster Creek Generati ng Stat ion" Re f. 314.15, ?Transfer Funct ion & Sy stem Logic r eport for Transient & Fati gue Monit ori ng Syst em for the OC Feedwater Nozzl es" Re f. 314.16, ?Report on Syst em R evi ew & Recom mendations for Transi ent & Fat igue Moni tori ng Syst em at the Oyst er Creek Generati ng Stat ion" Ref. 314.17, " Oyster Creek Stat ion-Unit 1 Operati onal R ec or ds Re vie w f or Lic en se Re ne wa l"Ca lculation Pac ka ge, ?Cycl e Based Fati gue Develo pment for Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 522 RP V, T orus , and Isolation Co nde nse r Loc ations ," Re v. 0 Am er G en AR No. A2 11 47 40 Ev al 5 , "T ra ns ien t C ycle Counti ng Long Table for OCNGS through 7/1
/2005," SI f il e #OC-0512-212 3.14.2 "Fat igue Ev aluat ion f or Feedwate r Pi ping" 3.14.7 "40-Year & 60 year C ycle Projections & Fatigue Pro Histo ri cal Base L ini ng" 3.1 4.8 "Env ir onmental Fati gue Cal cul ati ons fo r RPV Locati ons" 3.14.18 "Fat igue Pr o Hist ori cal Basel ini ng" Envir onmental Qua l i fi ca t i on (EQ)Program (B.3.
2)X.E1, Envir onmental Qua l i fi ca t i on (EQ)of El ectri cal Co m pon ents PB D-A MP-B.3.02, ?Envir onmental Qual if icat ion Pr ogram"Oyster Creek St ati on Bl ackout Syst em Forked River Combusti on Tur bi ne AMPs Bo lting Inte gr ity -FRCT (B.1.
12A)XI.M18 Bol ti ng Integ rity PB D-A MP-B.1.12A , ?FRCT Program Basis Document: Bol ti ng Integ rity - FR CT ," Re v. 0 C los ed Cyc le Cooli ng W ater Sy st em - FRCT (B.1.1 4A)XI.M21 C los ed-C ycle Cooli ng W ater Syst em PB D-A MP-B.1.14A , ?FR CT Pro gram Bas is Do cum ent: Clos ed-C ycle C ooling W ater S ystem - FR CT ," Re v. 0 Aboveground Outdoor Tanks -
FRCT (B.1.
21A)XI.M29, Aboveground Outd oor Tanks PB D-A MP-B.1.21A , ?FR CT Pro gram Bas is Do cum ent: Ab ove grou nd O utdo or T ank s - F RC T," R ev. 0 Fuel Oil Chem istry- FRCT (B.1.
22A)X I.M 30 , Fu el O il chem istry PB D-A MP-B.1.22A , ?FRCT Program Basis Document: Fuel Oil Chem ist ry - FRCT," Rev. 0, 11/04/2005 TAQ Engineer ing I nc., Tank Certi fi cati on Report, unnumbered, October 30, 2000 On e-Ti me In spe ct i on - FRCT (B.1.2 4A)X I.M 32 , O ne-T im e Inspect ion PB D-A MP-B.1.24A , ?OC GS Pro gram Bas is Do cum ent: One-Time Inspecti on - FRCT," Rev. 0, 11/04/2006 OC GS Lette r to N RC 213 0-05-202 28, ?Supplemental Response t o NRC Request for Addi ti onal Inf ormati on (RAI 2.5.1.19-1), dated Sept ember 28, 2005, Relat ed to Oy ster Creek Gener ati ng St ati on Li cense Rene wal Appl ica ti on (TAC No. MC7624),"
November 11, 2005 Select ive Leachi ng of Mat er i al s - F RCT (B.1.2 5A)XI.M33 , Selective Leaching of M ate ria ls PB D-A MP-B.1.25A , ?FR CT Pro gram Bas is Do cum ent: Se lective L eac hing of M ateria ls - F RC T," R ev. 0 Appl ic ant's A ging Management Program GAL L R epo rt Agi ng Management Program LRA-AM P Ba sis Doc um ent and Othe r Docu me nts Reviewed 523 Buri ed Pipi ng In spe ct i on - FRCT (B.1.2 6A)XI.M34, Buri ed Pipi ng Inspect ion PB D-A MP-B.1.26A , ?FRCT Program Basis Document: Bur ied Piping Insp ection - FR CT ," Re v. 0 Buri ed Pipi ng Inspect ion-Met Tower (B.1.26B)XI.M34, Buri ed Pipi ng Inspect ion PB D-A MP-B.1.26B , ?Me t To wer Pro gram Bas is Do cum ent: Bu ried P iping In spe ction-Me t To wer ," Re v. 0 Peri odic Moni tori ng of Combustion Turbine Power Plant-Ele ctri cal (B.1.37)NA PB D-A MP-B.1.37, ?FR C T Pr og ra m Ba sis Do cu m en t: P er iod ic Mo nitoring of C om bus tion T urbin e Po wer Plan t-Elec trical,"Re v. 0 Inspect ion of Inte rn al S ur fa ce s in Miscel laneous Pipi ng and duct ing Com ponents -FRCT (B.1.38)XI.M38, Inspect ion of I nter nal Sur faces in Mi scell aneous Pipi ng and duct ing Co m pon ents PB D-A MP-B.1.38, ?FR CT Pro gram Bas is Do cum ent: Inspect ion of Int ernal Surfaces i n Miscel laneous Pipi ng and duc ting C om pon ents - FR CT ," Re v. 0 Lu br ica ting O il Ana l y si s - F RCT (B.1.39)XI.M39, Lubri cati ng Oil Analy sis PB D-A MP-B.1.39, ?FR CT Pro gram Bas is Do cum ent: Lub ricating Oil An alysis - F RC T," R ev. 0 Peri odic I nspecti on- FRCT (B.2.
5A)NA PB D-A MP-B.2.5A, ?FR C T Pr og ra m Ba sis Do cu m en t: P er iod ic Insp ection - FR CT ," Re v. 0 A pp l i ca nt's A MR Se ct i on s a nd Sy st ems fo r OCGS OC GS LRA-AM R B asis Do cum ent and Othe r Docu me nts Reviewed 3.1 Reactor Vessel , I nter nals, and Reactor Cool ant Sy stems OC-AM R-2.3.1.5 , ?Reactor Head Cool ing Sy stem," Rev.
0, 12/13/05 OC-AM R-2.3.1.6 , ?Reactor I nter nals," Rev. 0, 12/713/05 BW R-V IP -13 9, ?Steam Dryer and Inspect ion & Fl aw Evalua ti on Guidel ines," 2/2005 OC-AM R-2.3.1.7 , ?Reactor Pr essure Vessel
," Rev. 0, 12/7/05 OC-AM R-2.3.1.8 , ?Reactor Reci rcul ati on Syst em," Rev. 0, 12/16/05 3.2 Engineer ed Safet y Feat ures Syst ems OC-AM R-2.3.1.3 , ?Isol ati on Condenser Sy stem," Rev.
0, 12/13/05 OC-AM R-2.3.1.4 , ?Nuclear Boil er I nstru mentati on," Rev. 0, 12/13/05 OC-AM R-2.3.2.2 , ?Contai nment Spray Sy stem," Rev.
1, 12/13/05 A pp l i ca nt's A MR Se ct i on s a nd Sy st ems fo r OCGS OC GS LRA-AM R B asis Do cum ent and Othe r Docu me nts Reviewed 524 OC-AM R-2.3.2.3 , ?Core Spray Syst em," Rev. 0, 12/28/05 OC-AM R-2.3.2.4 , ?Standby Gas Treatment Syst em," Rev. 0, 12/12/05 3.3 Auxil iar y Sy stems OC-AM R-2.3.3.1 , ?C B attery R oom He ating & Ven tilation,"
Rev. 0, 12/12/05 OC-AM R-2.3.3.2 , ?416 0 Sw itchge ar R oom Ven tilation,"
Rev. O, 12/
16/05 OC-AM R-2.3.3.3 , ?480 Swit cgear Room Ventil ati on," Rev. 0, 12/28/05 OC-AM R-2.3.3.4 , ?Ba ttery and Mg Set R oom Ven tilation,"
Rev. 0 1/17/06 OC-AM R-2.3.3.5 , ?Chlori nati on Syst em," Rev. 0, 12/5/05 OC-AM R-2.3.3.6 , ?Circul ati on W ater Syst em," Rev. 0, 1/9/06 OC-AM R-2.3.3.7 , ?Contai nment Inert ing Sy stem," Rev.
0, 12/9/05 OC-AM R-2.3.3.8 , ?Co ntainm ent V acu um Bre ak ers ," Re v. 0 12/27/05 OC-AM R-2.3.3.9 , ?Control Rod Drive Syst em," Rev. 0, 12/14/05 OC-AM R-2.3.3.1 0, ?Control Room HVAC," Rev. 0 1 2/13/05 OC-AM R-2.3.3.1 1, ?Cranes and Hoist s," Rev. 0, 12/28/05 OC-AM R-2.3.3.1 2, ?Dryw ell Floo r and Equ ipm ent D rains ,"Rev. 0, 1/19/06 OC-AM R-2.3.3.1 3, ?Em ergency Diesel Generator and Auxil iar y Sy stem," Rev.
0, 12/19/05 OC-AM R-2.3.3.1 4, ?Em erge ncy S ervic e W ater S ystem ,"Rev. 0, 12/21/05 OC-AM R-2.3.3.1 5, ?Fire Protect ion Sy stem," Rev.
0, 1/25/06 OC-AM R-2.3.3.1 6, ?Fu el Sto rage and Ha ndling Equ ipm ent,"Rev. 0, 12/23/05 OC-AM R-2.3.3.1 7, ?Hardened Vent Syst em," Rev. 0, 12/16/05 OC-AM R-2.3.3.1 8, ?Heati ng & Process St eam," Rev. 0, 1/13/06 A pp l i ca nt's A MR Se ct i on s a nd Sy st ems fo r OCGS OC GS LRA-AM R B asis Do cum ent and Othe r Docu me nts Reviewed 525 OC-AM R-2.3.3.1 9, ?Hydrogen & Monitor ing Sy stem," Rev.
0, 12/19/05 OC-AM R-2.3.3.2 0, ?Inst rument (Contr ol) Air Syst em," Rev.0, 12/7/05 OC-AM R-2.3.3.2 1, ?Main Fuel Oil Storag e & Transfer Syst em," Rev. 0, 12/5/05 OC-AM R-2.3.3.2 2, ?Miscel laneous Floor and Equi pment Drain Sy stem," Rev.
0, 1/6/06 OC-AM R-2.3.3.2 3, ?Nitr ogen Suppl y Sy stem," Rev.
0, 12/5/05 OC-AM R-2.3.3.2 4, ?Noble Moni tori ng Syst em," Rev. 0, 12/21/05 OC-AM R-2.3.3.2 5, ?Post-acci dent Sampli ng Syst em," Rev. 0, 12/21/05 OC-AM R-2.3.3.2 6, ?Process Sampling Syst em," Rev. 0, 12/21/05 OC-AM R-2.3.3.2 7, ?Radiat ion Moni tori ng Syst em," Rev. 0, 12/14/05 OC-AM R-2.3.3.2 8, ?Radwaste Area Heat ing an d Venti lat ion Syst em," Rev. 0, 12/16/05 OC-AM R-2.3.3.2 9, ?Reactor Bui ldi ng Closed Cool ing Water Syst em," Rev. 1, 2/10/06 OC-AM R-0 M-2.3.3.30, ?Reactor Bui ldi ng Floor and Equipment Drai ns," Rev. 0, 1/11/06 OC-AM R-2.3.3.3 1, ?Re acto r Bu ilding Ve ntilation S ystem ,"Rev. 0, 1/3/06 OC-AM R-2.3.3.3 2, ?Reactor W ater Cleanup Sy stem," Rev.
0, 12/7/05 OC-AM R-2.3.3.3 2, ?Ro of D rains and Ov erbo ard D isch arge ,"Rev. 0, 1/4/06 OC-AM R-2.3.3.3 4, ?Sanit ary W aste Sy stem," Rev.
0, 1/4/06 OC-AM R-2.3.3.3 5, ?Servi ce W ater Syst em," Rev. 0, 1/13/06 OC-AM R-2.3.3.3 6, ?Shutdown Cool ing Sy stem," Rev.
0, 1/3/06 OC-AM R-2.3.3.3 7, ?Sp ent F uel P ool C ooling Syste m ,"Rev. 0, 1/6/06 A pp l i ca nt's A MR Se ct i on s a nd Sy st ems fo r OCGS OC GS LRA-AM R B asis Do cum ent and Othe r Docu me nts Reviewed 526 OC-AM R-2.3.3.3.38, ?Stan dby Liq uid C ontro l System ,"Rev. 0, 1/13/06 OC-AM R-2.3.3.3 9, ?Travel ing I n-core Pr obe Syst em," Rev. 0, 1/4/06 OC-AM R-2.3.3.4 0, ?Turbine Bui ldi ng Closed Cool ing Water Syst em," Rev. 0, 12/14/05 OC-AM R-2.3.3.4 1, ?W ate r T re atm en t & D istr. Sys tem ,"Rev. 0, 1/5/06 Ho ltec R epo rt HI-2 043 279 , Proje ct N o. 14 05, ?Sum m ary Report of the Examinat ion of Oyster Creek Nuclear Stat ion Bo ral Su rveillanc e."Ho ltec R epo rt HI-2 033 000 , Proje ct N o. 12 56, ?Exam inat ion of Oys ter C reek Nu clea r Statio n Bo ral Su rveillanc e."3.4 Steam and Power Conversi on Syst ems OC-AM R 2.3.4.1 , ?Condensate Sy stem," REV. 0 1/
12/06 OC-AM R-2.3.4.2 , ?Condensate Transf er Sy stem," Rev.
0, 1/12/06 OC-AM R-2.3.4.3 , ?Feedwater Sy stem," Rev.
0, 12/16/05 OC-AM R-2.3.4.4 , ?Main Condenser," Rev. 0, 12/21/05 OC-AM R-2.3.4.5 , ?Ma in G ene rator and Aux iliary System
,"Rev. 0, 12/19/05 OC-AM R-2.3.4.6 , ?Main Steam Syst em," Rev. 0, 1/18/06 OC-AM R-2.3.4.7 , ?Ma in Tu rbine and Aux iliary System
,"Rev. 0, 12/5/05 3.5 Primary Contai nment, Str uctur es, Com ponent Suppor ts, and Pip ing and Com ponent I nsulat ion OC-AM R-2.5.1, ?Stat ion Bl ackout Sy stem," Rev.
0, 1/4/06 OC-AM R-2.5.1.1 5, ?Ra dio C om m unic ations Syste m s,"Rev. 0, 12/28/05 OC-AM R-S-2.4.2 , ?Primary Contai nment," Rev.
0 1/13/06 OC-AM R-S-2.4.2 , ?Stru cture s O ther th an C onta inm ent,"Rev. 1, 2/10/06 OC-AM R-S-2.4.3 , ?Co m pon ent S upp orts C om m odity G roup ,"Rev. 1, 2/10/06 NU RE G-082 2, "Integ rated Plan t Saf ety As ses sm ent, Syst ematic Eval uati on Program", Oyster Creek Nuclear Generati ng Stat ion Fi nal Repor t Dated January 1983.Lette r, J. Zw olinsk y (NR C) to P. Fie dler (G PU N) w ith a Sa fety Evalua ti on 4.12 (SEP Topic II I-7.B) NRC Informati on Request Form of NUR EG-0822, Desi gn Codes, Desi gn Crit eri a and A pp l i ca nt's A MR Se ct i on s a nd Sy st ems fo r OCGS OC GS LRA-AM R B asis Do cum ent and Othe r Docu me nts Reviewed 527 Load Combinati ons, Dat ed Oct. 29, 1986.Lett er fr om Alexander W. Dromerick, Jr. (NRC) to J.
Barton (GPU), "Oy ster Creek Nuclear Genera ti ng stat ion -Ev alu atio n o f E ffe cts of H igh T em pe ra tur e o n d ryw ell S hie ld W all and Bio logi cal Shi eld Wall, SEP Topic II I-7.B "Desig n Codes, Design Crit eri a, Load Combinat ions, and Reactor Cavit y Cri teri a" (TAC No. M76879) dat ed May 11, 1994.Lett er fr om R.W. Keat en to U.S. NRC, "Oyst er Creek Nuclea r G en er atin g S tatio n (O C N G S) Do ck et 5 0-21 9 S EP T op ic II I-7B, dry well Shiel d W all Int egri ty", dated Apr il 19, 1994 Lett er, R. Keaton (GPUN) to NRC, Response to Request for Ad ditio na l Inf or m atio n o n D ryw ell T em pe ra tur e (S EP T op ic II I-7.B), Dat ed November 19, 1993.
Holt ec Report HI
-981983, "Li censing Report f or Stor age Ca pac ity Expa nsio n of O yster C reek Spe nt Fu el Po ol", Revisi on 4, dat ed June 15, 1999 MPR-953, "GPU Nuclear Corp orat ion, Oyster Creek Nuclear Generat in g Sta ti on Torus Shel l Thi ckness Marg in", MPR Associat es INC, October 1986.Calcul ati on No. C-1302-187-E310-038 , " Oyster Creek Torus Corrosi on All owable Pi t Depth", October 2002 3.6 Elect ri cal Components OC-AM R-2.5.1, ?Elect ri cal Comm odit ies," Rev. 0, 1/3/06 PLI-02, Oyster Creek License Renewal Proj ect Lev el Inst ructi on 2 "Scopi ng of Sy stems, Str uctur es, and Com moditi es," Rev. 4, 9/8/05 PLI-03, Oyster Creek License Renewal Proj ect Lev el Inst ructi on 3 "Scopi ng of Sy stems and Struct ures," Rev. 2, 9/8/05 PLI-08, Oyster Creek License Renewal Proj ect Lev el Inst ructi on 8 "Pr ogram Basis Documents," Rev. 7, 1/24/06 PP-15 "St andard Mater ial s, Envi ronments, and Aging Ef fects,"Oyst er Creek Li cense Renewal Pr oject , Rev. 5, 1/31/06 EP RI 1 003 057 , ?Lice nse Re new al Elec trical H and boo k,"Final , December 2001 EP RI-T R-1 096 19, ?Guidel ine f or t he Managem ent of Adverse Locali zed Equi pment Envir onments," Fi nal, June 1999 528 ATTA CHMENT 6: LI ST OF COMM ITMENTS The followi ng table lis ts all commitmen ts identified by the app licant in Appendix A, Table A.5 of the OCGS LRA th at were rev iewed b y the project team. This lis t reflects revis ions to the commitment list i n Table A.5 o f the OCGS LRA prov ided by the applica nt in the foll owing li cense renewal submittals:
*AmerGen Letter 2130-05-202 14, ?Response to N RC Request for Add itional In formation (RAI 2.5.1.19-1), d ated September 2 8, 2005, Rel ated to Oyster C reek Generating Statio n License Re newal A pplication (TAC No. M C7624)," dated October 12, 2005.
*AmerGen Letter 2130-05-202 28, ?Supplemental Response to NRC Request for Additional Information (RAI 2.5
.1.19-1), dated Se ptember 28, 2005 , Related to Oyster Creek Generating Stati on License Renewal Applicati on (TAC No. M C7624), dated November 11 , 2005.*AmerGen Letter 2130-05-202 39, ?Response to N RC Request for Add itional In formation dated Nove mber 9, 2005, Re lated to Oys ter Creek Generating S tation Licen se Renew al Applicati on (TAC No. M C7624)," dated December 9, 200 5.This list al so reflects new audit commitments made by the applican t during this a udit, and documented in the followi ng license re newal s ubmittals:
*AmerGen Letter 2130-06-202 93, ?Reconcili ation of Oyster C reek Generating Statio n License Re newal A pplication with Se ptember 2005 Re vision 1, NUREG-1800 and NUREG-1801 (TAC No. MC7 624)," dated M arch 30, 2006.
*AmerGen Letter 2130-06-202 84, ?Commitments Associat ed with Containment (Drywell and Torus) Condi tion Mon itoring Rela ted to AmerGen Ap plication for Renewed Op erating License - Oy ster Creek Generatin g Station (TAC No. MC762 4)," dated Apri l 4, 2006.
*AmerGen Letter 2130 20316,"Respo nses to Actio n Items Associa ted with Oyster Creek Generating Stati on License Renewal Audits (TAC N
: o. MC76 24)," dated Apri l 17, 2006.*AmerGen Letter 2130-06-203 28, ?Supplemental Commitments Assoc iated wi th AmerGen Appli catio n for Re newe d Opera ting Li cense - Oyst er Cre ek Gener ating S tation (TAC N o. MC7624)," D ated May 1, 2006.The commitment numbers in the table are those assigned by the applicant in the OCG S LRA, with the exception of new audi t commitments made by the appli cant as a resu lt of this audi t and revi ew, w hich are nu mbered based on the secti on numb er of the audi t repor t in w hich they are discussed.
529 Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 1) ASME S ect i on XI Inser vice Inspect ion, Sub sec ti ons I W B, I W C, and IW D 3.0.3.2.1 Ex istin g p ro gr am is c re dite d. F or the iso latio n c on de ns er s th is pr og ra m als o in clu de s e nh an ce m en t ac tivitie s id en tifie d in NURE G-1801, l ines I V.C1-5 and I V.C1-6. These enhancement activit ies consist of:
: 1. Temperature a nd radi oacti vit y monit ori ng of t he shel l-side (cool ing) water , whi ch wil l be implemented pri or t o the per iod of extended op erat ion.2. Edd y cu rr en t t es t i ng of t he t ub es , wi t h i ns pe ct i on (V T or UT)of t he tubeshee t and chan nel he ad, whi ch wil l be perfor med duri ng the f ir st t en year s of t he extended peri od of oper ati on.2) W ater Chem istry 3.0.3.2.2 Exist ing pr ogram is credi ted.3) Reac tor Head C losure Studs 3.0.3.2.3 Exist ing pr ogram is credi ted.4) B W R V ess el ID Att achment W elds 3.0.3.2.4 Exist ing pr ogram is credi ted.5) BW R Feedwater N ozz le 3.0.3.2.5 Exist ing pr ogram is credi ted. The Oyster Creek Feedwater No zzle agin g m ana gem ent p rogr am will be en han ced to implement th e recomm endati ons of t he BW R Owners Group Li censi ng Topi cal Report General Ele ctr ic (GE)NE-523-A71-0594.
: 6) BW R Control Rod D rive Re tur n L ine No zzle 3.0.3.2.6 Exist ing pr ogram is credi ted.7) BW R Stress Corrosi on Cracking 3.0.3.2.7 Exist ing pr ogram is credi ted.3.0.3.2.7-1 3.0.3.2.7 The a ppl i can t commit te d t o r ev i se A MP B.1.7 i n t he OCGS L RA to in clu de the en ha nc em en t ide ntif ied in th e p ro gr am ba sis document, PBD-AMP-B.1.0 7, whi ch stat ed that for t hose components wit hin t he scope of t he BW R stress cor rosi on cracking aging managem ent pr ogram, all new and repl acement SS m ater ial s wil l be low-carbon gr ades of SS wi th car bon content li mited t o 0.035 wt. % maxim um and ferri te cont ent li mited t o 7.5% minimum
.8) BW R Penetrat ions 3.0.3.2.8 Exist ing pr ogram is credi ted.9) BW R Ve ss el In ter na ls 3.0.3.2.9 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. Ins pec tion of the s team dryer in a cco rdan ce w ith BW RVIP-139.2. In sp ec tion of t he top gu ide as rec om m en de d in NURE G-1801.3. Rol li ng of t he CRD stub tubes as a permanent repai r, once the NRC approves t he ASME code case. I f th e ASME code Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 530 case is not appr oved, the pr ogram wil l be changed to use a per manen t re pai r a cce pt abl e t o t he NRC.10) Thermal Agi ng and Neutron I rradi ati on Em bri tt lement of Cast Austeni ti c Stai nless St eel (CASS)3.0.3.1.1 Program is new.
The program wil l i nclude a component sp ec ific ev alu atio n o f th e lo ss of f ra ctu re tou gh ne ss in acc orda nce with the criteria s pec ified in N UR EG-180 1, X I.M1 3. For those components where l oss of fr actur e toughness may affect the i ntended f uncti on of t he component, a suppl emental inspect ion wi ll be perf ormed. This i nspecti on wil l ensur e the int egri ty of t he CASS com ponents expo sed to t he hig h temperatur e and neut ron fl uence present in t he react or env ironm ent.11) Fl ow- Accel erat ed Corrosi on 3.0.3.1.2 Exist ing pr ogram is credi ted.12) B olting Inte grity 3.0.3.2.10 Exist ing pr ogram is credi ted.3.0.3.2.10-1.3.0.3.2.10 The appli cant comm it ted t o revi se the  b olt ing i ntegr it y pr ogram (B.1.12) i n the OCGS LRA to incl ude the e nhancement ident if ied i n the pr ogram basis document, which st ated t hat t he si te pr oce dur e wi l l be e nha nce d t o i ncl ude re fe re nce t o EPR I TR-104 213 , ?Bo lted Jo int Ma intena nce & A pplica tion G uide ,"Decem ber 1995.13) Open-Cycl e Cooli ng W ater Syst em 3.0.3.2.11 Exist ing pr ogram is credi ted. The program wil l be enhanced as fol lows. Volumetri c inspect ions, for pi ping t hat has be en repl aced, wi ll be i ncluded at a mini mum of 4 abov eground loc atio ns ev er y 4 ye ar s. In sp ec tion of h ea t ex ch an ge rs will specif y examinat ion f or l oss of materi al due to gener al, pit ti ng, crevi ce, gal vani c and MIC in the RBCCW , TBCCW and Contai nment Spray p revent ati ve maintenan ce tasks.14) C los ed-C ycle Cooli ng W ater Syst em 3.0.3.2.12 Exist ing pr ogram is credi ted.15) Boraf lex Moni tori ng 3.0.3.2.13 Exist ing pr ogram is credi ted.16) I nspecti on of Overhead Heavy Load and Li ght Load (Relat ed to Refuel ing) Handli ng Syst ems 3.0.3.2.14 Exist ing pr ogram is credi ted. The scope of t he progr am will be incr eased to i nclude addit ional hoist s that have been i denti fi ed as a poten ti al Sei smic II/I concern and ar e in scope for 10C FR 54.4 (a)(2). Th e pro gram will also be enh anc ed to includ e insp ection s for rail wea r, and loss of m ateria l due to corrosi on, of cranes and hoi sts st ructu ral components, incl uding the br idge, the t rol ley , bol ti ng, l if ti ng devi ces, and t he rai l sy stem.17) C om pr es se d A ir Monitor ing 3.0.3.1.3 Exist ing pr ogram is credi ted.18) BW R Reactor W ater Cleanup Sy stem 3.0.3.2.15 Exist ing pr ogram is credi ted. Based on GL 89-10 cont ainment isol ati on val ve upgrade s/ enhancements, an effe cti ve Hydr ogen W ate r C he m istr y Pr og ra m , an d th e c om ple te la ck of c ra ck ing found dur ing an y of the RW CU pipi ng weld inspect ions perfor med under GL 88-01, al l i nspecti on requi rements for t he port ion of the RW CU System outboard of t he second Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 531 contai nment isol ati on val ves have been eli minated.19) Fi re Prot ecti on 3.0.3.2.16 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. Speci fi c fuel supply inspect ion cr it eri a for f ir e pumps during test s.2. I nspecti on of ext ernal surfaces o f th e halo n and carbon dioxi de fi re suppre ssion sy stems.3. Addi ti onal i nspecti on cri teri a for de gradat ion of fi re barr ier wall s, cei li ngs, and f loor s.3.0.3.2.16-1 3.0.3.2.16 The a ppl i can t commit te d t o r ev i se A MP B.1.19 i n t he OCGS LRA to add t he enhancement to t he OCG S fi re prot ecti on program, rel ated t o peri odic v isual inspect ions of fi re door surface i ntegr it y and clear ance checks, as descr ibed i n the progr am basis d ocument, PBD-AMP-B.
1.1 9, t o th e OCGS LRA.
: 20) Fi re W ater Syst em 3.0.3.2.17 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. Spri nkler head test ing i n accordance wi th NFPA 25,?Inspection, Testing and M aintenance of W ater-Based Fire Protect ion Sy stems."  Samples wi ll be submitt ed to a test ing labor ator y pr ior to bei ng in servi ce 50 y ears. This t esti ng wil l be repeat ed at i nter val s not exceed ing 10 year s.2. W ater s am pling fo r the p res enc e of M IC a t an inte rval no t to exceed 5 y ears.3. Peri odic no n-i ntru sive wall thi ckness m easurements of sele cted portion s of th e fire w ater s ystem at an interva l not to exceed every 10 ye ars.4. Vi sual i nspecti on of t he redundant fi re wat er st orage t ank heater duri ng tank i nter nal i nspecti ons.21) Abovegr ound Outd oor Tanks 3.0.3.2.18 Program is new.
The program wil l manage the cor rosi on of outdoor carbon st eel an d aluminum tanks.
The program credi ts t he appl icat ion of paint , seal ant, and coati ngs as a corrosi on prevent ive measure and perfor ms periodi c vi sual inspect ions t o monitor degradat ion of the pai nt, sealan t, and coati ngs and any resul ti ng metal degr adati on.3.0.3.2.18-1 3.0.3.2.18 The appli cant comm it ted t o revi se the  a boveground outdoor tanks prog ram (B.1.21) i n the OCGS LRA to incl ude the excepti on ide nti fi ed in the pr ogram basis document, which stat ed that the speci fi ed frequ ency by the Oy ster Creek program is ev ery 5 yea rs i n place of sy stem walkdowns each outage.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 532 22) Fuel O il Chem istry 3.0.3.2.19 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. Rout ine an aly sis f or part icul ate cont aminati on usin g modifi ed ASTM D 2276-00 Method A on fuel oil samples from the Em ergency Diesel Generator Fuel St orage Tank, t he Fir e Pond Die sel Fuel Tanks, and th e Mai n Fue l Oil Tank.2. Ana l y si s f or pa rt i cu l at e c on t ami na t i on us i ng modi fi ed ASTM D 22 76-0 0 M eth od A o n n ew fue l oil.3. Anal ysi s for wat er and sedi ment using ASTM D 2709-96 for Fire Pond Diesel Fuel Tank bot tom sam ples.4. Anal ysi s for bact eri a to v eri fy the ef fecti veness of bi ocide addi ti on i n t he Emerg ency Die sel Gener at or F uel St ora ge Tan k, th e Fi re P ond Di esel Fuel Tanks, and th e Mai n Fue l Oil Tank.5. Peri odic dr aini ng, cl eaning, and i nspecti on of t he Fir e Pond Diesel Fuel Tanks and t he Main Fuel Oil Tank. Inspect ion acti vit ies wi ll incl ude the u se of ul traso nic t echnique s for deter mining t ank bott om thicknesses shoul d ther e be any evi dence of cor rosi on or pi tt ing.3.0.3.2.19-1 3.0.3.2.19 T he ap plic an t co m m itted to r ev ise O C G S A M P B.1.2 2, f ue l oil chemistry , i n the OCGS LRA to incl ude a one-t ime int ernal inspect ion of the EDG day t anks to conf ir m the absence of aging effect s. Vi sual i nspecti on wil l be perfor med and further inspect ions wi ll be perf ormed to quant if y t he degradat ion, should ther e be any evi dence of cor rosi on or pi tt ing ob served duri ng the v isual inspect ion.3.0.3.2.19-2 3.0.3.2.19 The a ppl i can t commit te d t o r ev i se A MP B.1.22 i n t he OCGS LRA to i nclude the except ion i denti fi ed in the r econcil iat ion document, whi ch stat ed that Oyster Creek has not a dopted t he Standard Technical Specif icat ions, however, the Oy ster Creek fuel oil specif icat ions an d procedur es inv oke simil ar requi rements for f uel oi l pur it y and fuel oil test ing.23) Reactor Vessel Survei ll ance As sign ed to NRR/DE Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to implement BW RVIP-116 ?Int egrat ed Survei ll ance Program (ISP) Implementati on for L icense Renewal
," if approved by t he NRC. If BW RVIP-116 i s not appr oved, Exelon wi ll provi de a pla nt-sp ec ific su rve illan ce pla n fo r th e lic en se ren ew al p er iod in acc orda nce with 10 CF R P art 50 , App end ices G a nd H prior to enter ing t he peri od of ext ended operat ion.24) One-Time Inspect ion 3.0.3.1.4 Program is new.
The One-Time Inspecti on progr am will provi de reasonabl e assurance t hat an ag ing ef fect is not occurri ng, or that the agi ng effect is occu rri ng slowl y enoug h to not affect the component or st ructu re i ntended f uncti on duri ng the pe ri od of extended op erat ion, and ther efore wi ll not r equir e addi ti onal aging managem ent. This pr ogram wil l be used for the Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 533 fol lowi ng: 1. To co nf i rm cr ack i ni ti at i on a nd g ro wt h du e t o SCC, I GSCC, or t hermal and mechanical loadi ng is not occur ri ng in Class 1 piping less than four-inch nom inal pipe size (N PS) exp ose d to reac tor co olan t.2. To con firm the effectiveness of the W ater Chem istry Program to manage the l oss of materi al and crack i nit iat ion an d growth aging effect s.3. To confi rm the effect ive ness of t he Closed Cy cle Cool ing W ater Syst em program to m anage the loss of material aging effe ct.4. To con firm the effectiveness of the Fuel Oil Chem istry prog ram and Lub ricating Oil M onitor ing A ctivities pr ogra m to m ana ge th e loss of m ateria l aging effe ct.5. To confi rm loss of materi al i n stai nless st eel pi ping, pipi ng components, and pi ping e lements i s insi gnif icant in a n interm ittent co nde nsa tion (inte rnal) e nviron m ent.6. To confi rm loss of materi al i n steel pipi ng, pi ping components, and pi ping e lements i s insi gnif icant in a n indo or air (intern al) en vironm ent.7. To confi rm loss of materi al i s insi gnif icant for non-safet y-rel ated (NSR) pipi ng, pi ping co mponents, and pi ping elements of vents and drai ns, f loor and equi pment drai ns, and other syst ems and com ponents t hat coul d contai n a fl uid, and, are i n scope for 10CFR54.4(a)(2) for spati al i nter acti on. The scope of t he progr am consists of only those sy stems not covered by other aging managem ent act ivi ti es.3.0.3.1.4-1 3.0.3.1.4 The one-ti me inspecti on agi ng managem ent pr ogram does not ve rify th e e ffe ctiv en es s o f th e s ele ctiv e le ac hin g o f m ate ria ls agin g m ana gem ent p rogr am. Th e ap plican t com m itted to correct li ne it em 43 in Table 3.
3.1 t o dele te r eference to usi ng the one-ti me inspecti on to v eri fy the ef fecti veness of t he select ive leachi ng of materi als pr ogram.3.0.3.1.4-2 3.0.3.1.4 The a ppl i can t commit te d t o r ev i se A MP B.1.24 i n t he OCGS LRA to i nclude the except ion i denti fi ed in the r econcil iat ion do cu m en t, w hic h s tate s th at th e n ew O yste r C re ek on e-tim e inspect ion ag ing management program wil l i nclude the one-t ime i nspect io n of Cl ass 1 pi pi ng l ess t han or equal to NPS 4.3.0.3.1.4-3 3.0.3.1.4 The one-ti me inspecti on progr am will also incl ude destr ucti ve or non-dest ructi ve examinati on of one socket welded connecti on using t echnique s proven b y past indust ry experi ence to be effect ive for t he ide nti fi cati on of cra cking i n small bor e socket Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 534 welds. Should an i nspecti on opport unit y not occur (e.g., socket we ld fa ilure or s oc ke t we ld re pla ce m en t), a su sc ep tible small-bo re socket wel d wil l be examined eit her dest ructi vel y or non-dest ructi vel y pr ior to ent eri ng the pe ri od of ext ended operat ion.3.0.3.1.4-4 3.0.3.1.4 The a ppl i can t commit te d t o r ev i se A MP B.1.24 i n t he OCGS LRA to i nclude the except ion i denti fi ed in the r econcil iat ion document, whi ch st ate s th at t he 1995 ASME Secti on XI B&PV Code, i ncludi ng 1996 addenda, is cur rent ly used at Oyster Cree k.3.0.3.1.4-5 3.0.3.1.4 The a ppl i can t commit te d t o r ev i se A MP B.1.24 i n t he OCGS LRA to i nclude the except ion i denti fi ed in the r econcil iat ion document, whi ch stat es that EPRI Report 1000701 i s not appl ic abl e at Oys te r Cr eek.25) Sel ecti ve Leachi ng of M ate ria ls 3.0.3.1.5 Program is new.
The Select ive Leachi ng of Mater ial s program wil l consi st of inspect ions of a repr esentat ive select ion of components of th e dif ferent suscepti ble materi als t o deter mine if loss o f materi al due to sel ecti ve l eaching is occur ri ng. Vi sual inspect ions wi ll be consi stent wit h ASME Section XI VT-1 vi sual insp ection requ irem ents and sup plem ente d by ha rdne ss te sts and othe r exa m ination s of th e se lected set o f com pon ents. If sele ctive lea chin g is fo und , the c ond ition will be e valua ted to deter mine the need t o expand i nspecti ons.26) Buri ed Pipi ng Inspect ion 3.0.3.2.21 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. I nspecti on of bur ied pi ping wi thi n ten y ears of e nter ing t he pe rio d o f ex ten de d o pe ra tion , un les s a n o pp or tun istic inspect ion occu rs wi thi n thi s ten-year peri od.2. The buri ed port ions of the f ir e prot ecti on syst em and the piping locate d insid e the vau lt.3.0.3.2.21-1 3.0.3.2.21 The appli cant comm it ted t o repl ace the pr evi ously un-repl aced buri ed safet y-rel ated ESW pipi ng pri or t o the per iod of extended op erat ion.27) A SM E S ection XI, Su bse ction IW E 3.0.3.2.22 Exist ing pr ogram is credi ted.3.0.3.2.22-1 3.0.3.2.22 Consist ent wi th cur rent pract ice, a str ippabl e coati ng wil l be app lied to the reac tor ca vity liner to pre ven t wate r intrus ion into the ga p b etw ee n th e d ryw ell s hie ld w all a nd the dryw ell s he ll du rin g p er iod s w he n th e re ac tor ca vity is floo de d. T his comm it ment appli es to r efuel ing ou tages pr ior to and duri ng the peri od of ext ended operat ion.3.0.3.2.22-2 3.0.3.2.22 T he rea cto r c av ity se al le ak ag e tr ou gh dra ins an d th e d ryw ell sand bed regi on drai ns wil l be monitored for wat er l eakage pe rio dic ally.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 535 3.0.3.2.22-3 3.0.3.2.22 Am erGen wil l condu ct UT thi ckness m easurements i n the upper re gions o f th e dry well shell every other refuel ing ou tage at t he same locati ons as are cur rent ly measured. This wi ll be perfor med every ot her ref ueli ng outage pri or t o and duri ng the peri od of ext ended operat ion.3.0.3.2.22-4 3.0.3.2.22 Prior to the period of extended ope ration, AmerG en will perform addit ional vi sual i nspecti ons of t he epoxy coati ng that was appli ed to t he exter ior surface o f th e dry well shell in t he sand be d re gio n, s uc h th at th e c oa ted su rfa ce s in all 1 0 d ryw ell b ays wil l hav e been i nspected at least once. I n addi ti on, t he inservice inspection (ISI) program w il l be enhance d to require inspect ion of 100% of the epoxy coati ng every 10 ye ars duri ng the per iod of extended operat ion. These inspect ions wi ll be perfor med in accordance wi th ASME Secti on XI, Subsecti on IW E. Perf ormance of the i nspecti ons wil l be stagger ed such that at l east t hree bay s wil l be examined every other refuel ing outage. This comm it ment appli es pri or t o the per iod of extended op erat ion, and ever y t en year s duri ng the pe ri od of extended op erat ion.3.0.3.2.22-5 3.0.3.2.22 U ltra so nic T es ting (U T) th ick ne ss m ea su re m en ts o f th e d ryw ell shell in t he sand bed re gion wi ll be perf ormed on a frequency of every 10 ye ars. The ini ti al i nspecti on wil l occur pri or t o the peri od of ext ended operat ion. The UT m easurements wil l be taken from the inside of the drywell at the sam e locations where UT m easurements were per formed in 1996. The i nspecti on re su lts w ill be co m pa re d to pre vio us res ults. Sta tistic ally sign ificant d eviation s fro m the 1 992 , 199 4, an d 19 96 U T re sults wil l r esult in co rrect ive acti ons that incl ude the f oll owing: a)perfor m additi onal UT measurem ents t o confi rm the readi ngs;b) not if y NRC wit hin 48 hours of confi rmation of the i denti fi ed co nd ition; c) co nd uc t vis ua l ins pe ctio n o f th e e xte rn al s ur fa ce in the sand b ed regi on in areas where any une xpected cor rosi on may be detect ed; d) perfor m engineeri ng eval uati on to assess the ext ent of condit ion an d to det ermine i f addi ti onal i nspecti ons are required to assure drywell integrit y; and e) perform operabi li ty deter minati on and just if icat ion f or opera ti on unti l next inspection. These actions will be com pleted prior to restart from the associ ated out age.3.0.3.2.22-6 3.0.3.2.22 D ur ing the ne xt U T ins pe ctio ns to b e p er fo rm ed on the dryw ell sand bed regi on (ref erence AmerGen 4/4/06 let ter to NRC), an att empt wil l be made to locat e and eval uated some of t he local ly thi nned areas i denti fi ed in the 1992 inspect ion f rom the exter ior of t he dry well. Thi s test ing wi ll be perf ormed using t he lat est UT methodology wit h exist ing she ll paint in p lace. The UT thickness measurements for t hese lo call y t hinned areas may be taken fr om either insi de the dr ywel l or outsi de the dry well (sand bed r egion) to l imit radi ati on dose to as lo w as reasona bly achievable (ALARA
).
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 536 3.0.3.2.22-7 3.0.3.2.22 As no ted in A m er G en's 4/4/0 6 le tter to N R C , Am er G en will perf orm tor us coat in g i nspect io ns i n accor dance wi th ASME Secti on XI, Subsecti on IW E every other refuel ing ou tage pr ior to and du ri ng the pe ri od of ext ended operat ion. This new comm it ment clari fi es that the scope of each of these insp ection s will includ e the wette d are a of a ll 20 toru s ba ys. Should t he curren t t orus coat ing sy stem be repl aced, t he insp ection freq uen cy an d sc ope will be re-eva luated. Inspect ion scop e wil l, as a minimum, m eet t he requi rements of ASME Secti on XI, Subsect io n IWE.3.0.3.2.22-8 3.0.3.2.22 Am erGen wil l dev elop r efi ned acceptan ce cri teri a and thr es ho lds for en ter ing tor us co atin g d ef ec ts a nd un ac ce pta ble pit depths i nto t he correct ive acti on process f or fur ther eval uati on. These i mprovem ents wi ll be i ncorporat ed int o the inspect ion i mplem enti ng documents pri or t o the next perfor mance of these i nspecti ons, whi ch is a lso pr ior to t he peri od of ext ended operat ion.28) A SM E S ection XI, Su bse ction IW F 3.0.3.2.23 Exist ing pr ogram is credi ted. The scope of t he progr am will be enhanc ed to include additional MC sup ports, and require inspect ion of the unde rwater support s for l oss of materi al due to cor rosi on and l oss of mechanical funct ion an d loss of prel oad on bol ti ng by inspect ing f or missi ng, det ached, or loosened bolt s.29) 10 CFR Part 50
, Appendix J 3.0.3.1.6 Exist ing pr ogram is credi ted.30) M as on ry W all Program 3.0.3.1.7 Ex istin g p ro gr am is c re dite d. T he M as on ry W all P ro gr am is part of t he Stru cture s Monit ori ng Program.
: 31) Str uctur es Monit ori ng Program 3.0.3.2.24 Ex isting p rogr am is cre dited. T he p rogr am includ es e lem ents of t he Masonry Wall Pr ogram and the RG 1.127, Inspect ion of W ater-Contr ol St ructu res Associ ated W it h Nuclear Power Plant s aging managem ent pr ogram. The Struct ures Monit ori ng Program wil l be enhanced to incl ude: 1. Buildi ngs, structural com ponents an d com m odities that are not in s cop e of m ainten anc e rule but h ave bee n de term ined to be in the scope o f l icense r enewal. These incl ude miscell aneous pl atfor ms, flood a nd secondary contai nment doors, penetr ati on seal s, sump li ners, str uctur al seal s, and anc hors and em bed m ent.2. C om pon ent s upp orts, o ther th an th ose in sco pe o f AS ME XI, Subse ct io n I W F.3. I nspecti on of Oyst er Creek ext ernal surfaces o f mechanical components tha t ar e not cover ed by oth er pr ograms, HVAC duct, damper housings, and HVAC closure bol ti ng. I nspecti on and acceptan ce cri teri a of t he exter nal sur faces wi ll be the same as those specif ied f or st ructu ral steel components and struct ural bolt ing.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 537 4. The vi sual i nspecti on of i nsulat ed surface s wil l r equir e the removal of insul ati on. Removal of insul ati on wil l be on a sampling basi s that bounds i nsulat ion materi al t ype, sus cep tibility of ins ulated piping or co m pon ent m ateria l to potent ial degradat ions t hat coul d resul t fr om being in contact wit h insul ati on, and sy stem operati ng temperatur e.5. I nspecti on of el ectri cal pan els and racks, j uncti on boxes, inst rument racks and panel s, cabl e tr ays, offsi te power struct ural components and thei r founda ti ons, and a nchorage.6. Pe riodic s am pling, tes ting, an d an alysis of grou nd w ater to confi rm that t he envi ronment remains non-aggressi ve for buri ed rei nforced co ncret e.7. Peri odic i nspecti on of components submerged i n salt water (Int ake Struct ure and Canal , Di lut ion st ructu re) and in t he water of t he f ir e pon d dam, i ncl udi ng t ras h ra cks at th e I nt ake Str uc tur e a nd Ca na l.8. I nspecti on of penet rati on seal s, st ructu ral seals, and othe r elast omers for change i n material propert ies.9. I nspecti on of vi brat ion i solat ors, associat ed wit h component support s other than t hose covered by ASME XI, Subsecti on IW F, for reduct ion or loss o f i solat ion f uncti on.10. The curr ent i nspecti on cri teri a wil l be revi sed to add loss o f m ate ria l, du e to co rro sio n fo r s tee l co m po ne nts , an d c ha ng e in material propert ies, due to leachi ng of cal cium hydr oxide a nd aggressi ve chemical att ack for r einf orced concr ete. W ooden pil es and sheet ing wi ll be i nspected f or l oss of materi al and change i n material propert ies. 11. Per iodi c inspect ion of the Fi re Pond Dam for l oss of m aterial and l oss of form
.12. I nspecti on of St ati on Blackout Syst em Structure s, st ructu ral components, and phase bus encl osure assembli es.13. I nspecti on of Forked Ri ver Combustion Turbine p ower pl ant exter nal sur face of mechanical components that are not covered by other programs, HVAC duct, damper housings, and HVAC closure bol ti ng. I nspecti on and accept ance cri teri a of the ext ernal surfaces wi ll be the same as those specif ied f or struct ural steel components and str uctur al bol ti ng.14. The prog ram will be enhanced t o Incl ude Inspect ion of Meteorol ogical Tower Struct ures. Inspect ion an d acceptance cri teri a wil l be the same as those speci fi ed for o ther str uctur es In t he scope of t he progr am.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 538 15. The prog ram will be enhanced t o incl ude Inspect ion of exter ior surfaces o f pi ping a nd pip ing components asso ciat ed wit h the Radi o Com municati ons syst em, locat ed at t he meteorologi cal t ower si te, for l oss of materi al due to cor rosi on.inspect ion an d acceptance cri teri a wil l be the same as those specif ied f or ot her ext ernal surfaces o f mechanical components.
3.0.3.2.24-1 3.0.3.2.24 Th e ap plican t com m itted to a dd th e ex cep tion ide ntified in its reconci li ati on document for t he str uctur es monitori ng progr am, which st ates t hat t he progr am takes excepti on to t he insp ecti on fre qu en cy o f at lea st o nc e p er ref ue ling cyc le s pe cif ied in NURE G-1801, XI.
M36.3.0.3.2.24-2 3.0.3.2.24 The September 2005 Revisi on 1 GALL program specif ies monitori ng for l eakage. The Oyst er Creek st ructu res monitori ng progr am will be enhanced t o requi re vi sual insp ection of ex terna l surfa ces of m ech anic al stee l com pon ents that are not covered b y ot her prog rams for l eakage from or onto ext ernal surfaces, worn, fl aking, or oxi de-coat ed surface s, corrosi on stai ns on ther mal insul ati on, and p rote cti ve coat ing degradat ion (cracking and fl aking). Thi s is a new enhancement based on t he reconci li ati on of t his agi ng managem ent pr ogram from the Januar y 2005 draft GALL to the approved Sept ember 2005 Revisi on 1 GALL.
3.0.3.2.24-3 3.0.3.2.24 The appli cant comm it ted t o revi se the st ructu res monitor ing program (AMP B.1.31) in t he OCG S LRA to i nclude an inspect ion f requency for submerged por ti ons of wat er cont rol struct ures t hat i s consist ent wi th t he new comm it ment ident if ied in PBD-AMP-B.1.
32 for t he submerged water co ntro l st ructu res program 32) RG 1.127, Inspect ion of W ater-Contr ol Struct ures Associ ated wit h Nuclear Power Plan ts 3.0.3.2.25 Exist ing pr ogram is credi ted. The program is par t of the Struct ures Monit ori ng Program. The RG 1.127, Inspect ion of W ater-Contr ol St ructu res Associ ated wi th Nucl ear Power Plant s aging managem ent pr ogram wil l be enhanced to incl ude: 1. Moni tori ng of submerged str uctur al components and tr ash racks.2. Peri odic i nspecti on of components submerged i n salt water (Int ake Struct ure and Canal , Di lut ion st ructu re) and in t he water of t he fi re pond dam.
: 3. Peri odic i nspecti on of t he Fir e Pond Dam for loss of material and loss of form
.4. Ins pec tion of stee l com pon ents for los s of m ateria l, due to corrosi on.5. I nspecti on of wooden pi les and sheeti ng for l oss of materi al and change i n material propert ies.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 539 6. P ar am ete rs m on itor ed will b e e nh an ce d to inc lud e c ha ng e in material propert ies, due to leachi ng of cal cium hydr oxide, and aggr essi ve c hemic al at ta ck.3.0.3.2.25-1 3.0.3.2.25 The appli cant comm it ted t o revi se the LRA AMP B.1.
32 to add the ex ce ptio n to the ins pe ctio n fr eq ue nc y sp ec ified in NURE G-1801 XI.S7 st ated i n progra m basis document PBD-AMP-B.1.32.
The appli cant has committed to a ba seli ne inspect ion pr ior to ent eri ng the pe ri od of ext ended peri od of operat ion, a second i nspecti on 6 y ears aft er t he basel ine inspect ion, and a t hir d inspe cti on 8 y ears aft er t he second inspect ion, and has comm it ted t o eval uate t he ide nti fi ed degrada tions to determine if m ore frequent inspec tions are warrant ed.33) Prot ecti ve Coati ng Monitor ing an d Mainten ance Program 3.0.3.1.8 Existing program is credited. The Oyster Cree k Protective Coati ng Monit ori ng and Maint enance Progr am provides f or aging managem ent of Servi ce Level I coat ings i nside t he pri mary contai nment and Servi ce Level II coati ngs for t he exter nal dr ywel l shel l i n the ar ea of t he sand bed re gion.3.0.3.1.8-1 3.0.3.1.8 Th e ap plican t com m itted rev ise LR A T able s 3.5.2.1.1 and 3.5.1 to del ete t he prot ecti ve coat ing monit ori ng and maintena nce program (B.1.
: 33) fr om line i tems to manage loss of material for access hatch co vers, dry well penetr ati on slee ves, an d personnel air lock/equipment hat ch exposed t o a contai nment atmosphere (i nter nal) envi ronment, and li ne it ems to m anage corrosi on for t he vent li ne, and v ent header exposed to an indo or air (e xtern al) en vironm ent.3.0.3.1.8-2 3.0.3.1.8 T he co atin g in sid e th e to ru s w ill be vis ua lly ins pe cte d in accordance wi th ASME Secti on XI, Subsecti on IW E, per the prot ecti ve coat ings pr ogram. This comm it ment wil l be perfor med every ot her ref ueli ng outage pri or t o and duri ng the peri od of ext ended operat ion.34) El ectri cal Cabl es and Connecti ons Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents 3.0.3.1.9 Program is new.
The program wil l be used to manage agi ng of non-EQ cables an d connecti ons duri ng the pe ri od of ext ended operat ion. A represe ntat ive sample of accessi ble cab les and connecti ons loca ted i n adverse local iz ed envi ronments wil l be visu all y i nspected at least once ever y 10 y ears for indi cati ons of acceler ated i nsulat ion ag ing.35) El ectri cal Cabl es and Connecti ons Not Subj ect to 10 CFR 50.49 Envir onmental Quali fi cati on R eq uir em en ts U se d in Instru m enta tion C ircuits 3.0.3.2.26 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to incl ude: 1. A r evi ew of t he Reactor Buil ding Hi gh Radiat ion Moni tori ng and Air Eject or Offgas Radi ati on Monit ori ng syst em calibr ati on resul ts fo r cabl e agin g degradat ion be fore t he peri od of extended operation and every 10 years thereafter.
: 2. A r evi ew of t he LPRM/APRM and IRM syst em cable test ing resul ts fo r cabl e agin g degradat ion be fore t he peri od of extended operation and every 10 years thereafter.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 540 36) I naccessibl e Medium Volt age Cables Not Subject to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents 3.0.3.1.10 Program is new.
The program m anages the aging of inaccessi ble medium-vol tage cabl es that feed equi pment perfor ming li cense renewal int ended funct ions. These cables m ay at tim es b e ex pos ed to m oistur e an d are sub jecte d to syst em voltage for more tha n 25% of the t ime. Manhol es, conduit s and sumps associate d wit h these cab les wi ll be inspect ed for wat er col lect ion ev ery 2 yea rs and dr ained as requi red. In add it ion, the cabl e cir cuit s wil l be test ed usin g a proven t est f or det ecti ng deter ior ati on of t he insu lat ion sy stem due to wet ti ng, such as power fact or, part ial dischar ge, or polar iz ati on ind ex, as descr ibed i n EPRI TR-103834-P1-2, or oth er tes ting tha t is s tate-o f-th e-ar t at th e tim e th e te st is perfor med. The cables wi ll be test ed at l east once e very 10 year s. I nclusi on of t he 13.8kV sy stem circui ts i n thi s program refl ects t he scope expansi on of t he Stat ion Bl ackout Sy stem elect ri cal commoditi es.3.0.3.1.10-1 3.0.3.10 The a ppl i can t commit te d t o r ev i se A MP B.1.36 i n t he OCGS LRA to cl ari fy that the appl icant does not use pol ari zat ion i ndex test ing as the l one condi ti on monitor ing t est f or medium-volt age cable ci rcui ts.3.0.3.1.10-2 3.0.3.10 The ap pl ic ant committ ed t o i ncl ude b ot h 13.8 and 34.5kV ca ble s in its e xis ting ca ble tes t pr og ra m tha t cu rre ntly o nly incl udes 2.4 a nd 4.16kV cabl es. Thi s is a new enhancement based on t he reconci li ati on of t his agi ng managem ent pr ogram from the Januar y 2005 draft GALL to the approved Sept ember 2005 Revisi on 1 GALL.
3.0.3.1.10-3 3.0.3.10 The appli cant comm it ted t o revi se Appendi x A Table A.
05 comm it ment #36, and OCGS LRA A ppendice s A.1.36 and B.1.36, t o stat e that cable test/monit ori ng frequ ency wi ll be at least once ever y 10 y ears, that it wil l be adjust ed based on test/monit ori ng resul ts, and that the t est r esult s wil l be tren ded.37) Peri odic Test ing of Contai nment Spray Nozzl es As sign ed to NRR/DE Exist ing pl ant speci fi c program is cr edit ed. Carbo n steel pipi ng ups tream of the drywe ll and tor us s pray n ozzles is sub ject to po ss ible ge ne ra l co rro sio n. T he pe rio dic flow tes ts o f dr ywe ll and tor us spray nozz les add ress a concer n that rust from the possibl e general corrosi on may plug the spr ay noz zl es. These periodic tests verify that the drywell and torus spra y nozzl es are free f rom pluggi ng that could resul t fr om corrosion pr oduct buil dup from upstr eam sources.
: 38) Lu br ica ting O il Monitor ing Act ivi ti es 3.0.3.3.2 Exist ing pl ant speci fi c program is cr edit ed. The pr ogram m an ag es los s o f m ate ria l, cr ac kin g, a nd fou ling in lu br ica ting oil heat exchang ers, syst ems, and components in t he scope of li cense renewal by monit ori ng physi cal and chemical pr opert ies in lubri cating oil.
Sam pling, t esting, and m onitoring veri fy lubr icat ing oi l pr opert ies. Oil analy sis per mits i denti fi cati on of specif ic wear mechanisms, contaminati on, and o il degradat ion with in o pe ra ting m ac hin er y, an d c om po ne nts of s yste m s in sco pe fo r licens e ren ewa l. The prog ram will be en han ced to add surve il lance for verificati on of flow through the Fire Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 541 Pr ote ctio n S yste m die se l driv en pu m p g ea rb ox lub ric atin g o il cooler.39) Generat or Stat or W ater Chem istry Acti vit ies As sign ed to NRR/DE Exist ing pl ant speci fi c program is cr edit ed. The pr ogram manages loss of materi al agi ng effect s by monit ori ng and controlli ng water che m istry. Generator stator water che m istry contr ol maint ains hi gh puri ty water in a ccordance wi th General Elect ri c and EPRI gui deli nes for st ator cooli ng water syst ems.40) Peri odic I nspecti on of Venti lat ion Sy stems As sign ed to NRR/DE Exist ing pl ant speci fi c program is cr edit ed. The pr ogram incl udes in tern al and exter nal sur face i nspecti ons of vent il ati on syst em com ponents f or i ndicat ions of loss o f materi al, such as rust, corrosion and pitting.
Heat transfer surfac es are inspect ed for f ouli ng. Fl exibl e connecti on and door se al ela sto m er m ate ria ls a re ins pe cte d fo r de trim en tal c ha ng es in m ate ria l pro pe rtie s, a s e vid en ce d b y cr ac kin g, p er fo ra tion s in the m ateria l or leak age. Th e pro gram will be en han ced to incl ude duct e xposed to so il , i nstru ment pipi ng and val ves, restr ict ing or if ices and fl ow elements, and ther mow ell s. The acti vit ies wi ll also be enhanced t o incl ude in specti on gui dance for det ecti on of t he appl icabl e agin g effect s.41) Peri odic I nspecti on Program 3.0.3.3.5 Plant specif ic pr ogram is new.
The program incl udes syst ems in t he scope of l icense r enewal t hat r equir e peri odic monit ori ng of ag ing eff ec ts, an d a re no t co ve re d b y oth er ex istin g p er iod ic monitori ng progr ams. Acti vit ies consi st of a peri odic i nspecti on of sel ected sy stems and components to ver if y i ntegr it y and confi rm the absence of i denti fi ed agi ng effect s. The insp ection s are con dition m onitor ing ex am ination s inten ded to assure t hat exi sti ng envi ronmental condit ions ar e not causi ng material degradat ion t hat coul d resul t i n a l oss of sy stem int ended funct ions.42) W oo de n U tility Po le Program As sign ed to NRR/DE Plant specif ic pr ogram is new.
The program is used to manage loss of material and change of material propert ies f or wooden uti li ty poles in or near t he Oyster Creek Substat ion t hat pr ovi de struc tural s upp ort for the c ond ucto rs c onn ecting the O ffsite Power Syst em and the 480/208/
120V Uti li ty (JCP&L) Non-Vi tal Power Syst em to the Oyst er Creek pl ant. The program consist s of i nspecti on on a 10-y ear i nter val by a quali fi ed inspect or. The wooden pole s are i nspected f or l oss of materi al du e to an t, ins ec t, an d m ois tur e d am ag e a nd for ch an ge in material propert ies due to moist ure damage.
: 43) Peri odic Moni tori ng of Combustion Turbi ne Power Pla nt A7.3.0.3.3.1 A new plant specif ic pr ogram is credi ted. The program wil l be used in conjunct ion wi th t he exist ing St ructu res Monit ori ng Program and the new I naccessibl e Medium Voltag e Cables Not Subject to 10 CFR 50.49 Envir onmental Qual if icat ion Requirements pr ogram to manage aging ef fects for t he elect ri cal commoditi es that support FRCT operat ion. The program consist s of vi sual i nspecti ons of accessi ble el ectri cal cables a nd connecti ons exposed i n enclo sures, pit s, manholes an d p ipe tre nc h; v isu al in sp ec tion for wa ter co llec tion in manholes, pi ts and t renches, locat ed on the FRCT sit e, f or Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 542 inaccessi ble medium vol tage cabl es; and v isual inspect ion of accessibl e phase bus and conne cti ons and phase bus insul ator s/suppor ts. The new program wil l be perfor med on a 2-y ear i nter val for manhole, pit and tr ench in specti ons, on a 5-y ear i nter val for pha se bus i nspecti ons, and o n a 10-y ear int erval for cabl e and connect ion i nspecti ons.44) Metal Fati gue of Reactor Cool ant Pressu re Bound ary 3.0.3.2.27 Ex isting p rogr am is cre dited. T he p rogr am will be en han ced to use the EPRI-li censed Fati guePro cy cle coun ti ng and fat igue usage fact or t racking computer progr am. The com puter program provi des for ca lcul ati on of st ress cy cles and fat igue usage fact ors fr om operati ng cycl es, aut omated counti ng of fati gue str ess cycl es and aut omated calcul ati on and tr acking of fati gue cumulati ve usage fa ctors. The program wil l al so be enhanced to provi de for ca lcul ati ng and tr acking of the cumulati ve usage fa ctors for boun ding l ocati ons for t he react or pressure v essel, Class I pipi ng, t he tor us, t orus vent s, t orus attached piping and pen etrations, and the isolati on cond enser.3.0.3.2.27-1 3.0.3.2.27 The appli cant comm it ted t o cert if icat ion by a Professi onal Engineer of t he react or vessel design specif icat ion an d desig n report s prepare d for t he fat igue a cti vit ies associ ated wi th t he LRA. This wi ll be perf ormed by Jul y 31, 2006.45) Envi ronmental Qua l i fi ca t i on (EQ)Program 3.0.3.1.11 Exist ing pr ogram is credi ted. EQ com ponents t hat cannot be qu alifie d fo r 60-ye ar s w ill be rep lac ed be fo re the en d o f th eir quali fi ed li fe.46) New P-T Curves As sign ed to NRR/DE Revised pr essure-t emperature (P-T) l imit s for a 60-y ear li censed operat ing l if e have been pr epared and wi ll be su bm itted to th e N R C for ap pr ov al.47) C irc um fe re ntia l W eld Exam Reli ef As sign ed to NRR/DE Ap ply fo r ex ten sio n R ea cto r V es se l Cir cu m fe re ntia l W eld Exam inat ion Rel ief for 60-year operat ion 48) Axi al wel d Exam Reli ef As sign ed to NRR/DE Apply for ext ension Reactor Vessel Axial W eld Examinat ion Reli ef for 60-y ear oper ati on 49) M ea su re Dr ywe ll wa ll thi ckness As sign ed to NRR/DE Drywel l wal l t hickness wi ll be monitor ed to ensu re mini mum wall thick nes s is m aintain ed. T he A SM E S ection XI, Subsecti on IW E aging managem ent pr ogram, wil l manage the aging effect s.50) Fl uence Methodol ogy As sign ed to NRR/DE The NRC has i ssued a SER for RAMA approvi ng RAMA for re ac tor ve ss el flu en ce ca lcu latio ns. O yste r C re ek will c om ply wi th t he a ppl i cab l e r equ i re ment s of t he S ER.51) B oltin g In teg rity -FRCT A7.3.0.3.2.1 The Bolt ing I ntegr it y - FRCT aging management program is a new program that provi des for co ndit ion monit ori ng of bol ts and bolt ed joi nts wi thi n the scope of l icense r enewal at the For ked River Com busti on Turbin e power pl ant. This pr ogram is based on the General Elect ri c recomm endati ons for p roper bo lt ing material select ion, lubr icat ion, prel oad appl icat ion, inst all ati on and m ainten anc e as soc iated w ith the c om bus tion turb ine un its an d a ux iliary s yste m s. T he pro gr am als o in clu de s p er iod ic Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 543 walkdown i nspecti ons for b olt ing de gradat ion or bolt ed joi nt leakage at a frequ ency of at l east once e very four y ears. The program manages the loss of materi al and loss o f prel oad agin g eff ects. Th is new prog ram will be im plem ente d prio r to enter ing t he peri od of ext ended operat ion.52) C los ed-C ycle Cooli ng W ater Syst em -FRCT A7.3.0.3.2.2 The Closed-Cy cle Cool ing Water Syst em - FR CT aging managem ent pr ogram is a new pr ogram that manages agi ng of pipi ng, pi ping co mponents, pi ping e lements and heat exchangers t hat ar e incl uded i n the scope of l icense r enewal for l oss of materi al and cracki ng, and a re exposed t o a cl osed cooli ng water envi ronment at t he Forked Riv er Combustion Turbine p ower pl ant. The Closed-Cy cle Cool ing Water Syst em- FR CT aging m anagem ent program reli es on preve ntive m easures to minim ize corrosion by maintaining water chem istry contr ol par ameters and by perfor ming syst em m onit ori ng and maintenance i nspecti on acti vit ies t o confi rm that t he agi ng ef fe cts are ad eq ua tely m an ag ed. C he m istr y co ntr ol, perfor mance m onit ori ng and i nspecti on acti vit ies ar e based on indust ry-recogni zed gui deli nes of EPRI TR-107396, "Cl osed Cooli ng W ater Chem ist ry Guidel ines," for closed-cycl e cooli ng water syst ems. Chem ical contr ol par ameters wil l be monitored by annu al wat er chemistr y sampli ng. Sy stem operati onal monitori ng acti vit ies wi ll be perf ormed at a fr equency of at least once every six months.
This new pr ogram wil l be implemented pri or t o enter ing t he peri od of ext ended operat ion.53) Abovegr ound Steel Tanks - FRCT A7.3.0.3.2.3 The Aboveground St eel Tanks - FRCT aging managem ent program is a n ew program that wil l manage corro sion of aboveground outdoor steel tanks. Paint coati ng is a corrosi on prevent ive measure, and peri odic v isual inspect ions wi ll monitor degradat ion of the pai nt coat ing an d any resul ti ng metal degr adat io n of ta nk ext ern al sur fac es. The ab ove gro und t anks exter nal sur faces wi ll be vi suall y i nspected f or coat ing degradat ion by walkdown at least once ever y t wo year s. The M ain Fu el O il tan k b otto m is in co nta ct w ith c on cr ete an d s oil, and is inaccessi ble f or vi sual i nspecti on. Theref ore, the program incl udes peri odic Nondest ructi ve wal l-thi ckness examinati ons of t he Main Fuel Oil tank bot tom to ver if y t hat signi fi cant cor rosi on is not occur ri ng. Thi s program, i ncludi ng the i nit ial tank ext ernal paint inspect ions, wil l be implemented pri or t o the per iod of extended operat ion. The recomm ended UT inspecti on of t he Main Fuel Oil tank bot tom was performed in O cto be r 20 00 , so it is n ot n ec es sa ry to pe rfo rm this inspect ion ag ain pr ior to ent eri ng the pe ri od of ext ended operat ion. Based on t he resul ts of the Octobe r 2000 inspect ions, and subsequent repai rs t o the t ank fl oor, the t ank wa s c er tifie d to be su itab le fo r th e s tor ag e o f nu m be r 2 f ue l oil for a pe ri od of t ime not t o exceed 20 y ears fr om O ctober 2000, be fo re the ne xt in ter na l ins pe ctio n w ou ld b e n ec es sa ry.Th eref ore, a ddition al UT inspe ctions will be pe rform ed p rior to October 2020.
Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 544 54) F ue l O il Ch em istr y -FRCT A7.3.0.3.2.4 T he Fu el O il Ch em istr y - F R C T ag ing m an ag em en t pr og ra m is a new pro gram that provides assuranc e that contam inants are maintai ned at acce ptabl e lev els i n new and st ored fue l oi l f or syst ems and com ponents wi thi n the scope of Li censing Renewal. The Fuel Oil Storag e Tank wil l be maintai ned by monitori ng and cont rol li ng fuel oil contaminant s in a ccordance wit h the gui deli nes of t he American Soci ety for Test ing M ate ria ls (A ST M). F ue l oil s am plin g a ctiv ities will b e in accordance wi th ASTM D 4057 for multi lev el and tank bot tom sampling. Fuel oi l wi ll be peri odical ly sampled and anal yz ed for pa rt i cu l at e c on t ami na t i on i n a cco rd an ce wi t h mod i fi ed ASTM Standard D 2276 Method A or ASTM Standard D 6217, and, for t he pr es en ce of wa t er an d s ed i ment i n a cco rd an ce wi t h AS TM Sta nd ar d D 27 09 or A ST M Sta nd ar d D 17 96. T he Fu el O il Storage Tank will be peri odical ly drai ned of accumulat ed water and sedi ment and wil l be peri odical ly drai ned, cl eaned, and int ernal ly inspect ed. These act ivi ti es effect ive ly manage the effect s of agi ng by provi ding r easonabl e assurance t hat potent ial ly harmful cont aminants ar e maintai ned at l ow con cen trations. Th is new prog ram will be im plem ente d prio r to enter ing t he peri od of ext ended operat ion. The int ernal inspect ion of the Mai n Fuel Oi l t ank was perfor med in October 20 00 , so it is n ot n ec es sa ry to pe rfo rm this ins pe ctio n a ga in pri or t o enter ing t he peri od of ext ended operat ion. Based on the r esult s of t he October 2000 inspect ions an d repai rs, the tank was certifi ed to be suitable for the storage of num ber 2 fuel oil for a peri od of t ime not t o exceed 20 y ears fr om O ctober 200 0, be fore the n ext inte rnal ins pec tion wo uld be nec ess ary. The refore, additional i nternal inspections of the tank floor are not necessar y pr ior to ent eri ng the pe ri od of ext ended operat ion and wil l be perfor med prior t o October 2020.
: 55) One Time Inspecti on- FRCT A7.3.0.3.2.5 The One-Time Inspecti on - FRCT program will provi de measures to ver if y t hat an ag ing management program is not needed, con fi rms the effect ive ness of exi sti ng acti vit ies, or determ ines that degradation is occurring which will require eval uati on and corr ecti ve acti on. The pr ogram wil l be implemented pri or t o the per iod of extended operat ion.Inspect ion methods wi ll incl ude vi sual exa minati on or vol umetric examinat ions. Should aging effect s be detect ed, t he program wil l i nit iat e acti ons to char acter iz e the nat ure and extent of t he agi ng effect and dete rmines what su bsequent m onitoring i s neede d to ensure intended functions are maintai ned duri ng the pe ri od of ext ended operat ion.56) Sel ecti ve Leachi ng of Mat er i al s - F RCT A7.3.0.3.2.6 The Select ive Leachi ng of Mater ial s - FRCT aging managem ent pr ogram is a new pr ogram that wi ll consist of ins pe ctio ns of c om po ne nts co ns tru cte d o f s us ce ptib le m ate ria ls to d ete rm ine if los s o f m ate ria l du e to se lec tive lea ch ing is occ urring. For th e FR CT pow er pla nt, thes e are limited to copper al loy material s exposed to a clo sed cool ing wat er envi ronment. One-t ime inspect ions wi ll be consi st of vi sual inspections supp leme nted by hardness tests. If selective Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 545 leachi ng is found, the condi ti on wil l be eval uated t o deter mine the abi li ty of t he component to per form it s int ended funct ion unti l t he end of t he peri od of ext ended operat ion an d for t he need to e xpand i nspecti ons. Thi s new progr am will be im plem ente d in the tim e pe riod a fter J anu ary 20 18 a nd p rior to January 2028.57) Buri ed Pipi ng In spe ct i on - FRCT A7.3.0.3.2.7 The Buried Pipi ng Inspect ion - FRCT aging managem ent program is a n ew program that manages the exter nal sur face aging effect s of l oss of materi al f or carbon steel pipi ng and pipi ng syst em com ponents i n a soi l (exter nal) envi ronment. The program acti vit ies consi st of prevent ive and condit ion-monitori ng measures to manage the l oss of materi al due to ext ernal corrosi on for p ipi ng and pi ping sy stem co m po ne nts in th e s co pe of lic en se ren ew al th at a re in a so il (exte rnal) envi ronment. The pr ogram scope incl udes buri ed port ions of gly col cool ing wat er pi ping l ocated at the For ked River Com busti on Turbin e stat ion. Exter nal i nspecti ons of buried com ponents w il l occur opportunistically when they are exc ava ted d uring m ainten anc e. W ithin 10 years prior to enter ing t he peri od of ext ended operat ion, inspect ion of buri ed pipi ng wil l be perfor med unless an opport unist ic i nspecti on occurs wi thi n thi s ten-year peri od. Upon ent eri ng the pe ri od of extended op erat ion, inspect ion of buri ed pip ing wi ll again be pe rfo rm ed with in th e n ex t ten yea rs , un les s a n o pp or tun istic ins pe ctio n o cc ur s d ur ing this ten-ye ar pe rio d. T his pro gr am will be implemented pr ior to ent eri ng the pe ri od of ext ended operat ion.58) I nspecti on of I nter nal Su rfa ce s in Miscel laneous Pipi ng and Ducti ng Compon ent s - F RCT A7.3.0.3.2.10 The Inspect ion of Int ernal Surfaces i n Miscel laneous Pipi ng and Ducti ng Com ponents -
FRCT aging managem ent pr ogram is a new program that consist s of vi sual i nspecti ons of t he int ernal surfaces of steel pipi ng, va lve bodie s, duct work, f il ter housings, fan housi ngs, damper housi ngs, muffl ers and heat exchanger shell s in t he scope of l icense r enewal at the For ked River Com busti on Turbin e power pl ant t hat ar e not cov ered by other aging managem ent pr ograms. Int ernal inspect ions wi ll be perfor med during schedul ed maintenance a cti vit ies when the surfaces ar e made accessibl e for v isual inspect ion. The program incl udes vi sual i nspecti ons to assur e that exist ing envi ronmental condit ions ar e not causi ng materia l degr adati on that c ould resu lt in a loss of co m pon ent inte nde d fun ctions. These inspect ions wi ll be perf ormed during the major combustion t urbi ne insp ecti on outages and wil l be perfor med on a fre quency o f at least once ever y 10 y ears. The ini ti al inspect ions asso ciat ed wit h thi s program wil l be perfor med at the next major insp ecti on outage for each unit. Based on an i nsp ect i on f re que ncy of 10 y ear s, t he n ext i nsp ect i on f or CT Unit 1 wil l be perfor med by May 2014, and the next i nspecti on for CT Unit 2 wil l be perfor med by November 2015.
: 59) Lu br ica ting O il Analy sis Pr ogram -A7.3.0.3.2.11 The Lubri cati ng Oil Analy sis Pr ogram - FRC T is a new pr og ra m tha t inc lud es m ea su re s to ve rify th e o il en viro nm en t in Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 546 FRCT m ec ha nic al e qu ipm en t is m ain tain ed to th e re qu ire d q ua lity.T he Lu br ica ting O il An alys is P ro gr am - F R C T m ain tain s o il sys tem s c on tam ina nts (pr im ar ily wa ter an d p ar ticu late s) with in acceptabl e li mits, ther eby pr eservi ng an envi ronment that is no t conduciv e to l oss of materi al, cracki ng, or reduct ion i n heat tran sfer. Lubri cati ng oil test ing act ivi ti es incl ude sampling and analy sis of lubr icat ing oi l f or det ri mental cont aminants. The presence of water or par ti culat es may also b e indi cati ve of inle ak ag e a nd co rro sio n p ro du ct b uild up. T his pro gr am is augmented by the One Time Ins pect io n - FRCT (B.
1.2 4A)pr og ra m , to v er ify th e e ffe ctiv en es s o f th e L ub ric atin g O il Analy sis Pr ogram - FRC T. The new progr am will be implemented pri or t o the per iod of extended operat ion. The new program wil l be implemented pri or t o the per iod of extended op erat ion.60) Peri odic I nspecti on Pro gr am - FRCT A7.3.0.3.3.2 The Periodi c Inspect ion Pr ogram - FRC T is a new pr ogram that w ill consis t of pe riodic ins pec tions o f sele cted com pon ents to ver if y t he int egri ty of t he syst em and confirm the absence of iden tified ag ing ef fec ts. Insp ection s will be s che dule d to coinci de wit h major combustion t urbi ne maintenance inspect ions, when the su bject components are made accessibl e. These i nspecti ons wil l be perfor med on a frequency not t o exceed once ever y 10 y ears. The purpose of the ins pe ctio n is to d ete rm ine if a s pe cif ied ag ing eff ec t is occurri ng. I f th e agin g effect is occu rri ng, an ev aluat ion wi ll be perfor med to determine t he effect it wil l hav e on the abil it y of affect ed components to per form thei r i ntended f uncti ons for t he peri od of ext ended operat ion, and appropr iat e correct ive acti on is t aken. I nspecti on methods may incl ude vi sual exa minati on, sur fac e or v olum etric e xam ination s. W hen inspe ction r esu lts fa il to m ee t es tab lish ed ac ce pta nc e c rite ria , an ev alu atio n w ill be c ond ucte d to ide ntify action s or m eas ures nec ess ary to provi de reasonabl e assurance t hat t he component int ended fun ction is m aintain ed d uring the p eriod of ex tend ed o pera tion. The ini ti al i nspecti ons associ ated wi th t his pr ogram wil l be perf orm ed a t the ne xt m ajor in spe ction o utag e for eac h un it. Based on an i nspecti on frequ ency of 10 ye ars, the next inspect ion f or CT Unit 1 wil l be perfor med by May 2014, and the next i nspecti on for CT Unit 2 wil l be perfor med by November 2015.61) Buri ed Pipi ng and Tank Inspecti on - Met Tower Repeater Engi ne Fu el S up ply A7.3.0.3.2.12 The Buried Pipi ng and Tank Inspect ion - Met Tower Repeater Engine Fuel Supply aging managem ent pr ogram Is a new program that manages the exter nal sur face agi ng effect s of loss of material for copp er and car bon steel pipi ng, and ca rbon steel tanks i n a soi l (exter nal) envi ronment. The pr ogram acti vit ies consi st of prevent ive and condi ti on-monitor ing measures to manage the l oss of materi al due to ext ernal corrosi on for p ipi ng and pi ping sy stem com ponents i n the sc op e o f lice ns e re ne wa l tha t ar e in a s oil (e xte rn al)envi ronment. The pr ogram scope incl udes buri ed port ions of the Met Tower based radi o comm unicat ions sy stem repeater Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 547 backup engine generat or fuel (propan e) suppl y pi ping a nd the associat ed buri ed fuel supply tank, locat ed at t he Forked Riv er Meteoro logical Tower.
External inspect ions of buri ed components wil l occur opp ortun istically whe n the y are e xca vate d du ring m ainten anc e. W it hin 10 year s pri or t o enter ing t he peri od of ext ended operat ion, inspect ion of buri ed pip ing wi ll be perf ormed unless an o ppo rtunis tic insp ection occ urs within this ten-ye ar pe riod. Upon enteri ng the pe ri od of ext ended operat ion, inspect ion of buri ed pip ing wi ll again be perf ormed withi n the next ten y ears, unless a n opport unist ic i nspecti on occurs dur ing t his t en-y ear peri od. Thi s program wil l be Implemented pri or t o enter ing t he peri od of ext ended operat ion.3.1.2.1.6-1 3.1.2.1.6 Th e ap plican t com m itted to re vise L RA AM P B.1.9 to c larify its posit ion r elat ed to t he use of r oll/expansi on techni ques for the repai r of l eaking CRD stub t ubes which wil l r esult in n o leakage of t he CRD of the st ub tubes d uri ng the ext ended peri od of operat ion.3.1.2.1.12-1 3.1.2.1.12 The appli cant comm it ted t o revi sing t he OCG S LRA, Secti on 3.1, to addr ess loss of materi al due to pi tt ing an d crevi ce corrosi on in stai nless st eel an d nickel all oy r eactor vessel int ernal components. The BW R vessel i nter nals AMP wil l be use d to m ana ge th is agin g eff ect.3.1.2.2.1-1 3.1.2.2.1 The a ppl i can t commit te d t o r ev i se t he A MR l i ne i te ms in LRA Table 3.1.2.1.4 f or t he react or i nter nals, and Table 3.
1.2.1.5 f or the r eactor pressure vessel to del ete t he refer ence to TLAA for components where a TLAA does not exist. Furt her, the app ropr iate ag ing m ana gem ent p rogr am will be iden tified with an "E" indust ry standar d note an d a pl ant speci fi c note st ati ng: "There i s no fat igue a naly sis f or t his component.
The aging effect of cumulat ive fat igue i s managed by the BW R Vessel Int ernal s aging managem ent pr ogram."  Si milarl y f or t he feedwate r noz zl e and CRD return l ine no zzl e ther mal sleev es, the no te w ill rea d: "T he re is n o fa tigu e a na lysis for this component. The agi ng effect of cumulat ive fat igue i s managed by t he BW R Feedwater Nozz le (or BW R CRD Return Li ne No zzle, as a pplica ble) a ging m ana gem ent p rogr am." 3.1.2.2.2-1 3.1.2.2.2 The a ppl i can t commit te d t o pe rf or ming a on e-ti me UT inspect ion of the " B" I solat ion Condenser shell for pi tt ing corrosi on, pr ior to t he peri od of ext ended operat ion 3.1.2.2.2-2 3.1.2.2.2 Th e ap plican t com m itted to re vise th e O CG S LR A S ection 3.1 to addr ess loss of materi al due to pi tt ing an d crevi ce corrosi on for st ainl ess steel , ni ckel al loy , and st eel wi th st ainl ess steel or nickel alloy cladding flanges, nozzles, penetrations, pressure housings, safe ends, and vessel shell s, heads an d welds exposed to react or cool ant. The aging e ffect wil l be managed thro ugh the u se of t he water chemistry and one-t ime inspect ion pr og ra m s. T he se lec tion of s us ce ptib le lo ca tion s f or on e-tim e Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 548 inspect ions wi ll be based on sev eri ty of condi ti ons, t ime of servi ce, and l owest desi gn margin.
3.2.2.1.6-1 3.2.2.1.6 T he ap plic an t co m m itted to r ev ise the fur the r ev alu atio n in Secti on 3.2.2.2.8.2 of the OCGS LRA to stat e that Oyster Creek enginee red safet y f eatur es syst ems have no steel pipi ng, pipi ng components, or pipi ng ele ments (int ernal surfaces) exposed to condensati on, t reat ed water (i n the f orm of condensati on wett ing t he int ernal surface), or air-i ndoor uncontr oll ed envi ronments.3.2.2.2.3-1 3.2.2.2.3 The appli cant comm it ted t o revi se OCG S LRA Table 3.2.
1, l ine it em 3.2.1-34 r elat ed to st ainl ess steel pipi ng, pi ping co m po ne nts , an d p ipin g e lem en ts e xp os ed to lu br ica ting oil in the en gin ee re d s af ety f ea tur es sys tem s to sta te th at th is material/envi ronment combinati on is not appl icabl e to Oy ster Cree k.3.2.2.2.4-1 3.2.2.2.4 Th e ap plican t com m itted to re vise O CG S LR A T able 3.1.2.1.1 for t he isol ati on condenser sy stem to i nclude two new l ine i tems inv oking one-ti me inspecti on to supp lement t he W ater Chem ist ry Program for r educti on of heat tr ansfer du e to f ouli ng for t he int ernal and exter nal sur faces of t he isol ati on condenser heat exchang er t ubes. These ar e new addi ti ons based on t he reconciliati on of the O yster Creek LR A betwee n the Janua ry 2005 draf t GALL and th e approved September 2005 Revi sion 1 GALL.3.3.2.1.1-1 3.3.2.1.1 The appli cant comm it ted t o revi se Table 3.
3.2.1.18 i n the OCG S LRA to i nclude the wat er chemistr y agi ng managem ent program to addr ess loss of materi al due to pi tt ing an d crevi ce corrosi on for co mponents construct ed of copper and copper alloy in the heating and process steam system that are expos ed to auxiliary steam and boiler treated water.
3.3.2.1.1-2.3.3.2.1.1 The appli cant comm it ted t o revi se Table 3.
3.2.1.41 i n the OCG S LRA to address a ging management of l oss of materi al due to pi tt ing an d crevi ce corrosi on for v alv e bodi es constr ucted of brass and br onze exposed to t reat ed water on the i nter nal sur face by addin g the f oll owing AMR li ne it ems:*  Val ve Body - le akage boundary
- brass - t reat ed water (internal)
- loss of m aterial - water chem istry (B.1.2) - VII.E4-8 (AP-64) 3.3.1-38*  Val ve Body - le akage boundary
- brass - t reat ed water (internal)
- loss of m aterial - one-ti m e inspection (B.1.24) -
VII.E4-8 (AP-64) 3.3.1-38*  Val ve Body - le akage boundary
- bronz e - tr eated wat er (internal)
- loss of m aterial - water chem istry (B.1.2) - VII.E4-8 (AP-64) 3.3.1-38*  Val ve Body - le akage boundary
- bronz e - tr eated wat er Commitment No.Audi t an d Review Rep ort Sect ion Descr ipt ion 549 (internal)
- loss of m aterial - one-ti m e inspection (B.1.24) -
VII.E4-8 (AP-64) 3.3.1-38 3.3.2.1.12-1 3.3.2.1.12 The appli cant comm it ted t o revi se Table 3.
3.2.1.13 i n the OC GS LRA for the em ergency diesel generator and auxili ary syst em to address t he agi ng effect for r educti on of heat tr ansfer due to f ouli ng for t he brass l ube oi l cool er and r adiat or t ubes exposed to a closed cooli ng water envi ronment by credi ti ng the OC GS closed-cycle cooling water program (AMP B.1.14).3.5.2.2.1-1 3.5.2.2.1 A visu al examinat ion of the dr ywel l shel l i n the dr ywel l f loor inspect ion acce ss tr enches wil l be perfor med to assure t hat t he dry well steel remains i ntact. I f degrad ati on is ident if ied, the dry well shell condit ion wi ll be eval uated and correct ive acti ons taken, as necessary. These surf aces wil l ei ther be i nspected as p art of th e sc ope of the AS ME Sec tion X I, Sub sec tion IW E inspect ion pr ogram, or t hey wi ll be rest ored t o the or igi nal des ign co nfigu ration using con cre te or o ther s uitable m ateria l to prevent moisture coll ecti on in these ar eas. The appli cant commit te d t o pe rf or m a one-t i me vi sua l i nsp ect i on a nd UT measurem ents of the embedded dry well shell pri or t o enter ing the per iod of extended operat ion.3.5.2.2.1-2 3.5.2.2.1 In addition t o Am erGe n's previous com m itment to perform one-t ime visua l examinat ions of the dr ywel l shel l i n the ar eas exposed by the t renches i n the bot tom of the dr ywel l (refer ence Am erG en 4/4/06 letter to N RC), one-tim e U T m eas urem ents will b e ta ke n to co nf irm the ad eq ua cy o f th e s he ll thic kn es s in the se are as , pr ov idin g fu rth er co nf ide nc e th at th e d ryw ell re m ain s c ap ab le o f pe rfo rm ing its in ten de d fu nc tion. T his comm it ment wil l be perfor med prior t o enter ing t he peri od of extended op erat ion.A7.3.0.3.2.11-1 A7.3.0.3.2.11 T he ap plic an t co m m itted to r ev ise the lub ric atin g o il an alys is program - FRCT in L RA B.1.39 t o incl ude measurem ent of flash point.
550 ATTA CHMENT 7  FORKED RIVER COMBUSTION TURBINES, RADIO COMMUNICATION SYSTEMS, A ND METEOROLOGICAL TOWER LICENSE RENEWAL A UDIT AND REVIEW In resp onse t o NRC Reques t for Add ition al Info rmatio n (RAI) 2.5.1.19-1 a nd RA I 2.5.1.15-1 related to the Oyster Creek Generati ng Station (OCGS) l icense renew al appli cation, the applicant p rovided s ubmittals on October 12, 2005, November 11 , 2005, and D ecember 9, 2005, that address agin g management of components a nd systems i n the scope o f license renew al for the OCGS stati on bl ackout s ystem (SBO) s ystem Forked Rive r combu stion turbi nes (F RCTs), Radio Communi cation sys tems, and Me teorological Tower. In the RAIs, the NRC expressed the need for additi onal information to evalu ate the long-li ved passi ve componen ts of the FRCTs, and any a ging man agement programs (AMP s) and aging ma nagemen t revi ews (AMR s) rel ated to those components.
As a resul t, the appli cant revise d its approac h to aging management for the OCGS SBO combusti on turbine p ower pla nt Radio C ommunication S ystems, and M eteorological Tow er. S peci fica lly , the app lic ant h as ta ken a more deta ile d ap proa ch to sco pin g, sc reen ing, aging management revi ews and aging management programs. The F RCTs are ow ned, operat ed, an d main taine d by First Energy and p rovi de pea k loadi ng to th e grid. Cons isten t wi th OCGS commitments, and as review ed and appro ved by the NRC, the FRCTs provi de a standby source of alte rnate a c pow er for th e OCGS statio n in t he ev ent of a n SBO.As a result of the applicant's new approach to aging management of the FRCTs, 11 new AMPs have been added to the OCGS L RA, an d two exi sting OC GS AM Ps hav e been revi sed to inco rpor ate t he re sult s of the m ore d etai led AMR s. In addit ion, the pr eviou sly sub mitt ed AMP B.2.7, ?Periodic M onitoring of the C ombustion Turbin e Power P lant," identi fied in the LR A has been d elete d. The appli cant h as rev ised AMP B.1.31 , ?Structures Mo nitoring Program," for OCGS str ucture s to i nclud e struc tures, structu ral co mponen ts and phase bus e nclos ure assemb lies at the FRCT. The ap plic ant ha s rev ised AMP B.1.36 , ?Inac cess ibl e M edi um-V olta ge Cables Not Subject to 10 CFR 50.49 Environmental Qualif ications," to include inaccessible medium-voltage cables assoc iated wi th the SBO sy stem. The project team' s audit and review activiti es of AMPs B.1.31 and B.1
.36 are prov ided in S ection 3.03 o f this OCGS audit and revie w report.The app lica nt add ed AM P B.1.37, ?Perio dic M onito ring of C ombusti on Turb ine P ower Plan t -Electrical,"
to address the remaining SBO sy stem electrical commodities for w hich aging management is require
: d. In additi on, 10 new AMPs h ave been added to manage th e effects of aging of mechanical components at th e FRCT pow er plant. These new AM Ps are as foll ows:*B.1.12A:  Bolting Integ rity - FRCT
*B.1.14A:  Closed-Cycle Cooling W ater System - FRCT
*B.1.21A:  Aboveground Steel Tank s - FRCT*B.1.22A:  Fuel Oil Chemistry - FRCT
*B.1.24A:  One-Tim e Inspection - FRCT
*B.1.25A:  Selective Leaching of Materials - FRCT
*B.1.26A:  Buried Piping Inspection - FRCT 551*B.1.26B: Buried Piping and Tank Inspection - Met Tower Repeater Engine Fuel Supply
*B.1.38:  Insp ectio n of Inte rnal S urfaces in M iscel laneo us Pi ping a nd Duc ting Co mponen ts- FRCT*B.1.39:  Lubricating Oil Analysis Progra m - FRCT*B.2.5A:  Periodic Inspection Prog ram - FRCT This Attachment to t he OCGS audit and review report provides the results of the pr oject team's audit and re view activ ities relat ed to t he AM Rs and AMP s for the OCGS F RCT po wer p lant.
552 Attach ment 7 Ta ble o f Conten ts Page #A7.1 Introduction an d General Information
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......557 A7.1.1 Introduction
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......557 A7.1.2 Background
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......558 A7.2 Audit and R eview Scope..........
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......558 A7.3.Aging M anageme nt Rev iew Audi t and R evie w Re sults..........
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...559 A7.3.0 Use of t he Gene ric Agi ng Less ons-Le arned Report..........
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.....559 A7.3.0.1 Format of the FRCT Li cense Renew al Information
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559 A7.3.0.2 Audit and R eview Process..........
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.........559 A7.3.0.3 OCGS Agi ng Ma nagemen t Progra ms..........
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560 A7.3.0.3.1 AMPs That A re Con sisten t with t he GAL L Repo rt..........
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.562 A7.3.0.3.2 AMPs That A re Consistent with the GALL R eport with Excep tions and/or Enhan cements..........
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........562 A7.3.0.3.2.1 Bolting Integrity - FRCT (B.
1.12A)..........
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...562 A7.3.0.3.2.2 Closed-Cycle Cooling W ater System - FRCT (B.1.14A)
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......568 A7.3.0.3.2.3 Above Ground Steel Tanks - FRCT (B.
1.21A)..........
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....575 A7.3.0.3.2.4 Fuel Oil Chemistry - FRCT (AMP B.1.22A)
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......579 A7.3.0.3.2.5 One-Time Inspec tion - FRCT (B.1.24A)
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........587 A7.3.0.3.2.6 Selective Leaching of Materials - FRCT (B.1.25A)
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593 A7.3.0.3.2.7 Buried Piping Inspection - FRCT (B.1.26 A)..........
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......596 A7.3.0.3.2.8 Structures Mo nitoring Program (B.1.3 1)..........
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.........599 A7.3.0.3.2.9 Inaccessible Medium Voltage Cabl es Not Subject to 10 CFR 5 0.49 Envi ronmental Qualification Requirements (B.1.36
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.599 A7.3.0.3.2.10 Inspec tion o f Interna l Surfa ces in Mis cell aneou s Pip ing an d Duct ing Co mponen ts- FRCT (B.1.38)
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......599 A7.3.0.3.2.11 Lubricating Oil Analysi s - FRCT (B.1.39
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........604 553 A7.3.0.3.2.12 Buried Piping and Tank Inspect ion-Met Tower Repeater Engine Fuel Supply (OCGS AMP B.1.26B)
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..608 A7.3.0.3.3 AMPs That A re Not Consi stent with the GALL Report or No t Addressed i n the GALL R eport..........
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.........612 A7.3.0.3.3.1 Periodic M onitoring of Combus tion Turbine P ower Pla nt - Electri cal (B.1.37)
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.........612 A7.3.0.3.3.2 Periodic Inspection Program
- FRCT (B.2.5A)
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....615 A7.3.1 Aging M anageme nt of El ectric al Sy stems..........
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.......624 A7.3.1.1 Summary of Technica l Information in the Applic ation..........
.........624 A7.3.1.2 Project Team Eval uation..........
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625 A7.3.1.2.1 AMR R esult s That Are C onsis tent wi th The GALL R eport..........
.....628 A7.3.1.2.2 AMR Resul ts For Which Furthe r Evaluatio n Is Recommended By The GALL Report..........
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....628 A7.3.1.2.3 AMR Resul ts That Are No t Consistent With The GALL Rep ort Or Not Address ed In The GALL R eport..........
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....629 A7.3.2 Aging M anageme nt of M echan ical Syst ems..........
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.....629 A7.3.2.1 Summary of Technica l Information in the Applic ation..........
.........629 A7.3.2.2 Project Team Eval uation..........
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629 A7.3.2.2.1 AMR R esult s That Are C onsis tent wi th The GALL R eport..........
.....636 A7.3.2.2.2 AMR Resul ts For Which Furthe r Evaluatio n Is Recommended By The GALL Report..........
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....638 A7.3.2.2.2.1 Loss of Materi al Due to P itting and Crev ice Corrosi on..........
........639 A7.3.2.2.2.2 Reduction o f Heat Transfer Due to Fo uling..........
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......640 A7.3.2.2.2.3 Cracking Due to S tress Corrosion Cracking..........
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......640 A7.3.2.2.2.4 Hardening and Loss of Strength Due to Elastomer De gradation..........
641 A7.3.2.2.2.5 Loss of Materi al Due to Ge neral, Pitti ng, and Crevi ce Corrosion
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642 A7.3.2.2.2.6 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, a nd Micro biological ly Influence d Corrosion (MIC)
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.......644 A7.3.2.2.2.7 Loss of Materi al Due to Ge neral, Pitti ng, Crevice, M icrobiologi cally In fluenced Corrosion an d Fouling..........
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..646 554 A7.3.2.2.2.8 Loss of Materi al Due to P itting and Crev ice Corrosi on..........
........648 A7.3.2.2.2.9 Loss of Materi al Due to P itting, Crevi ce, and M icrobiologi cally In fluenced Corrosion..........
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..648 A7.3.2.2.3 AMR Resul ts That Are No t Consistent With The GALL Rep ort Or Not Address ed In The GALL R eport..........
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....650 A7.3.2.2.3.1 Mechanical System AMR Line Items That Have No Aging Effec t (Table 3.6.2.1.2B)
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.651 A7.3.2.2.3.2 Loss of Preload for Car bon and Low Allow Steel Exposed to Outdoor Air (External) (FRCT Table 3.6.
2.1.2B)..........
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..651 A7.3.2.2.3.3 Loss of Preload for Sta inless Steel Exposed to Indoor or Outdoor Air (External)(FRCT Table 3.6.2.1.
2B)..........
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652 A7.3.2.2.3.4 Cracki ng Init iatio n and Growth for Carb on and Low Allo w Ste el Ex posed to Combustion Turbine Exhaust Gases (Internal) (FRCT T able 3.6.2.1.2B)
....652 A7.3.2.2.3.5 Reduction of Heat Trans fer for Carb on and Low Allow Steel Ex posed to Fuel Oil (Internal) (FRCT T able 3.6.2.1.2B)
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..652 A7.3.2.2.3.6 Change in Material Properties for Elastom er Exposed to Fuel Oil or Outdoor Air (External) (FRCT Table 3.6.
2.1.2B)..........
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..653 A7.3.2.2.3.7 Reduction o f Heat Transfer and Loss of Material for Copper Exp osed to Indoor or Outdoor Air (External) (FRCT Table 3.6.2.1.2B)
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..653 A7.3.2.2.3.8 Loss of Material for Bronze Exposed to Outdoor Air (External) (FRCT Table 3.6.2.1.2B)
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.653 A7.3.2.2.3.9 Loss o f Mate rial for Copp er Ex posed to Soi l (Rad io Co mmunic ation s Sys tems Table 3.6.2.1.3)
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.......654 A7.3.2.2.3.10 Loss of Materi al for Copper E xposed to Outdoor Air (Ra dio Communic ations Systems Table 3.6.2.1.3)
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654 A7.3.2.2.3.11 Loss of Materi al for Brass Ex posed to Outdoor Air (Radio Communication s Systems Table 3.6.2.1.3)
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654 A7.3.2.3 Concl usion..........
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.....655 A7.3.3 Aging Management of Structural Compon ents for FRCT and M eteorological Tower..........
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.....655 A7.3.3.1 Summary of Technica l Information in the Applic ation..........
.........655 A7.3.3.2 Project Team Eval uation..........
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655 555 A7.3.3.2.1 AMR Resul ts That A re Con sisten t wi th The GA LL Rep ort..........
.....659 A7.3.3.2.2 AMR Re sults For Which Further Ev aluation Is Recommended By The GALL Report..........
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....660 A7.3.3.2.3 AMR Re sults That Are N ot Consistent With The GALL Report Or Not Addre ssed In The GA LL Rep ort..........
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....660 A7.3.3.2.3.1 Structural AM R Line Items Tha t Have No Aging Effect
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.......660 A7.3.3.2.3.2 Change in Material Properties and Loss of Material for W ood Exposed to Soil (FRCT Table 3.6.2.1.
2C)..........
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661 A7.3.3.2.3.3 Loss of Preload for G alvanized Steel Bolts Exposed to Outdoor Air (FRCT Table 3.6.2.1.2C)
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.661 A7.3.3.2.3.4 Loss of Materi al for Carbon a nd Low A lloy S teel Expo sed to Clos ed Coolin g W ater (FRCT Table 3.6.2
.1.2C)..........
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.....661 A7.3.3.2.3.5 Change in M aterial Prop erties for Poly vinyl Chloride Exposed to Outdoor Air (M et Tower Table 3
.5.2.1.20)
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.662 A7.3.3.2.3.6 No Aging Eff ect for Polyvinyl Chloride Exposed to Soil (Met Tower Table 3.5.2.1.20)
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.662 A7.3.3.2.3.7 Loss of Material for Galvanized Steel Exposed to Soil (Met Tower Table 3.5.2.1.20)
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.663 A7.3.3.2.3.8 Loss of Preload for Car bon and Low Alloy Steel Bolts Exposed to Outdoor Air (Met Tower Table 3.5.2.1.20)
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.......663 A7.3.3.3 Concl usion..........
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.....663 556 Attachment 7 Table s Page #Table A7-1 FRCT, Radio Communications System, and Met Towe r Aging Managemen t Programs..........
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..560 Table A7.3.1-1 Eval uatio n for FR CT Ele ctrica l Sy stem Co mponen ts in the GAL L Repo rt..........
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....625 Table A7.3.2-1 Evaluati on for FRCT and R adio Communi cations Sy stems Mechan ical Syste m Compo nents in the GALL R eport..........
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..630 Table A7.3.3-1 Evaluati on for FRCT, Radi o Communicatio ns Systems, an d Met Tow er Structu ral Sy stem Co mponen ts in the GAL L Repo rt..........
....656 557 A7.1 Introduction and General Information A7.1.1 Introduction By letter d ated July 22, 2005 (Agenc ywide Documents Acce ss and M anagement System
[ADAMS] ADAMS Accession Number ML0520800480), AmerGen Energy Company, LLC, (AmerGen , the a ppli cant) s ubmitte d to th e U.S. Nucl ear Re gulato ry Co mmissi on (NR C) its applicatio n for renewal of Facility Operating Licen se No. DPR-1 6 for Oyster Creek Gene rating Statio n (ADA MS A ccessi on Num ber M L0520 80185). The a ppli cant re quested renew al of i ts operat ing li cense for an a dditi onal 20 ye ars be yond the 40-year curren t lic ense t erm.Included in the appli cant's LRA was the Oy ster Creek Station Blackout Sy stem Combustion Turbine, locate d in Forked R iver, New Jersey. S ubsequent to submi tting the LRA, the applican t revi sed i ts app roach to agin g manageme nt for th e Forke d Riv er Comb ustio n Turbi ne (FR CT), the radio commun ications sy stem, and the meteoro logical tow er (Met tow er). Specifical ly, the applicant h as taken a more de tailed app roach to scopi ng, screening, aging mana gement review s, and aging management programs for the components within these systems.
The more detaile d approach for the Forked Rive r combustion turb ine is de scribed in the following tw o AmerGen submittal s, which supplement the Oyster Creek li cense renew al applicatio n:*AmerGen Letter 2130-05-202 14, ?Response to N RC Request for Add itional In formation (RAI 2.5.1.19-1), d ated September 2 8, 2005, Rel ated to Oyster C reek Generating Statio n License Re newal A pplication (TAC No. M C7624)," dated October 12, 2005, and*AmerGen Letter 2130-05-202 28, ?Supplemental Response to NRC Request for Additional Information (RAI 2.5
.1.19-1), dated Se ptember 28, 2005 , Related to Oyster Creek Generating Stati on License Renewal Applicati on (TAC No. M C7624), dated November 11 , 2005.The more detailed approach f or the radio communications system and the Met tower is described i n the follow ing AmerGen submitta l, whic h supplements the Oyster Cree k license renewal applicatio n:*AmerGen Letter 2130-05-202 39, ?Response to N RC Request for Add itional In formation (RAI-2.5.1.15-1) date d November 9, 2005, Rel ated to Oyster C reek Generating Statio n License Re newal A pplication (TAC No. M C7624)," dated December 9, 200 5.In support of the sta ff's safety review of the licens e renewal applicati on (LRA) for Oyste r Creek Generating Station (OCGS), the Licen se Renew al Branch C (RLRC) led a project team tha t audit ed and revi ewed sele cted A MRs and as socia ted AM Ps dev elope d by the ap plic ant to support the LRA for OCGS. The project tea m included both NRC sta ff and contractor personn el provi ded by Brookh aven Natio nal L aborat ory (B NL), th e RLR C tech nical contra ctor. Attachment 2 of this audit and review report lists the project team members , as wel l as other NRC st aff and BN L per sonn el who s uppo rte d the proj ect t eam's aud it and revie w.The aging manag ement reviews and aging managem ent programs cr edited for the FRCT, r adio communications system, and M et tower w ere review ed as part of the OCGS LRA audi
: t. The project team pe rformed i ts wo rk in ac cordan ce wi th the same re quireme nts use d for the OCGS audit , as de scribe d in S ectio n 1 of th is au dit an d rev iew report.
558 This Attachment to t he audit and review report documents the results of the project team's audit and revie w work for the FRCT, radio co mmunications sy stem, and Me t tower. Atta chment 2 of this audit a nd review report lists the applica nt personnel and other in dividua ls contacted by the project team i n supp ort of th e wo rk docum ented in thi s Attac hment.A7.1.2 Background The background information presented in Section 1.2 of this audit and revie w report for the OCGS LRA audi t and revi ew also applies to the FRCT, radi o communicatio ns system, and Met tower audit and re view.A7.2 Aud it and Rev iew Scope The AMRs and associated AMPs that the project team re viewed are identified in the OCGS audit and review plan. The project team examined 12 AMPs that specifically address FRCT, r adio communications system, and M et tower compo nents and sy stems in the sc ope of licens e renewal, along with revisio ns to two OC GS AMPs th at are used for thes e systems, as well a s associ ated A MRs. The pr oject te am rev iew ed AM Ps and AMR s that the ap plic ant cl aimed were consistent w ith the GALL R eport, and AM Rs for which further evalua tion is reco mmended by the GALL Report. The project team also review ed certain pl ant-specific AM Ps.The applican t noted that some of its AMPs , although descri bed as consi stent with the GALL Report, contain some devi ations from the GALL Report. These de viations are the same a s those discussed in Section 2 of this audit and review report for the OCGS LRA.
The project team's a udit and rev iew acti vities for the FRCT, radio c ommunications system, and Met tow er AMPs, and its conc lusions regardi ng these revi ews, are do cumented in S ections A7.3.0.3 of thi s Attac hment to the au dit an d rev iew report.The project team als o review ed all FR CT, radio communi cations sy stem, and Me t tower Table 2 AMR li ne-items. The projec t team review ed the AM R results, repo rted by the applicant to be consistent w ith the GALL R eport, to determine whether the y are consi stent with the GALL Report. For AM R results for w hich the GALL Report recommends further evalua tion, the project team review ed the appl icant's eva luation to determine w hether it adequa tely addre sses the issues for wh ich the GALL Report recommends further evaluati on.In Tables 3.6.2.1.2 A (FRCT electri cal) and 3.6.2
.1.2C (FRCT structura l) of AmerGen Letter 2130-05-20214, Table 3.6.2.1.2B (FRCT mechanica l) of AmerGen Letter 2 130-05-20228, a nd Tables 3.5.2.1.20 (Met tow er structural) an d 3.6.2.1.3 (radi o communicatio ns system) of AmerGen Letter 2130 20239, in addition to the notes, the applicant p rovided a summary of AMR resu lts for the appl icable sy stems, which included the SCs, asso ciated material s, environment, any aging effects requiri ng management, and an AMP for each line-item.
The notes descri be how the i nformati on in the ta bles align s wi th the informat ion i n the GA LL Rep ort. Those that are al igned with the GALL Rep ort are assigned letters and are described i n Section 2 of this audit and re view report. Those define d by the ap plic ant are assign ed numb ers an d are defined in the FRCT licen se renewal submittals.
Discrepanci es or issues discovered by the pro ject team during the audit and re view that required a response are documented i n this Attachmen t to the audi t and revi ew report.
If an issue w as not resolve d prior to i ssuing this au dit and rev iew repo rt, a request for additi onal information (RAI) w as pre pared by th e proje ct team to sol icit the in formatio n need ed to r esolv e the i ssue.
559 The RAI wi ll be in cluded and dispositio ned in the safety eval uation report (S ER) related to the OCGS LRA. A l ist of RAIs assoc iated wi th the audit is provi ded in Attac hment 4 to this audit and revi ew re port.The project team's a udit and rev iew acti vities for the FRCT, radio c ommunications system, and Met tow er AMRs, and its conc lusions res ulting from these acti vities, a re documented i n Sections A7.3.1 through A7.3.3 of this Attach ment to the au dit an d rev iew report.A7.3.Ag ing Man agemen t Rev iew Au dit and Rev iew Result s This section of the Atta chment to the audit and review report contains the proj ect team's evaluati on of the FRCT, radi o communicatio ns system, and Met tow er AMPs and AMR s. In the FRCT, radio co mmunications sy stem, and Me t tower li cense renew al submittal s, the appli cant describ ed the AMPs t hat it re lies on to m anage o r monit or the ag ing of long-live d, passi ve components and structures. The app licant al so provid ed the results of the AMRs for those structures and co mponents that it identifies as being with in the scope of license re newal a nd subject to an AMR.
A7.3.0 Use of the Gen eric A ging Lessons-Learned Rep ort In pr epar ing i ts FR CT, radio comm unic atio ns sys tem , and Met to wer ag ing m anag emen t revi ews and aging management pro grams, AmerGen credited the GALL Repo rt in the same manner as described in Section 3.0 of this audit and review report for the OCGS LRA.
A7.3.0.1 Format of the FR CT Licens e Renewal Information The FRCT, radio communications system, and M et tower l icense renew al information fol lows the same format used for the OCGS LRA, whi ch is descri bed in Sec tion 3.0.1 of thi s audit and revi ew re port.A7.3.0.1.1 Overview of FRCT Table 1 FRCT Table 1s (Tables 3.6.1A, 3
.6.1B, and 3.6.1C
), as well as the radio communication s sys tem a nd M et to wer Tabl e 1 (Tabl e 3.6.1D), pro vid e a s umma ry c ompa riso n of h ow the F RCT, radio communic ations sys tem, and Met tower AM R results al ign with th e correspondi ng tables of the GALL Report. They follow the same f ormat used for t he OCGS LRA, as described in Secti on 3.0.1.1 i n this audi t and r evie w rep ort.A7.3.0.1.2 Overview of OCGS LRA Table 2 FRCT Table 2s (Tables 3.6.2.1.2A, 3.6.2.1.2B, and 3
.6.2.1.2C), as w ell as rad io communicati ons system and M et tower Tabl e 2s (Tables 3
.5.2.1.20 and 3.6
.2.1.3) provid e the detail ed results of the AMRs for those components identified a s being subject to an AM R. There is a Table 2 for each of the compone nts or systems within a system groupi ng. The Table 2s c onsists of the same informat ion contained in the OCGS LRA Table 2s, as described in Section 3.0.1.
2 of this audit and re view report.A7.3.0.2 Aud it and Rev iew Process The project team performed the audit and r eview in accordance with the criteria defined in Revi sion 1 of NU REG-18 00, ?Standard Rev iew Pl an for Revie w of Licens e Renewa l Applic ations 560 for Nucl ear Po wer P lants ," (SRP-LR). Addit ional detai ls on how the SR P-LR c riteri a we re addressed are provided in the OCGS au dit and rev iew pl an. This rev iew proce ss is summariz ed in Se ction 3.0.2 of this audit and re view report.A7.3.0.3 OCGS A ging Ma nageme nt Pro grams The project team's a udit and rev iew acti vities for the FRCT, radio c ommunications system, and Met to wer AMPs and it s con clus ions reg ardi ng t hese prog ram s are docu ment ed bel ow.Table A7-1, FR CT, Radio Co mmunications S ystem, and M et Tower Aging M anagement Programs, presents the AMPs cred ited by th e applica nt and descri bed in the following documents:
*Structural and Electrical AMPs
: Appendix D of the Encl osure to AmerGen l etter?Response to N RC Request for Add itional In formation (RAI 2.5.1.19
-1), dated Septemb er 28, 2005, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC76 24)," dated October 12, 2005, and
*Mechanical AMPs
: Appe ndix D of the Encl osure to Amer Gen le tter ?Supplemental Response to N RC Request for Add itional In formation (RAI 2.5.1.19
-1), dated Septemb er 28, 2005, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC76 24), dated Nov ember 11, 2005.
Table A7-1 al so indicate s the GALL Rep ort program to whi ch the appli cant claimed its AMP was consistent (if ap plicable), and the SSC s for which the AMP is credited for managing or monitoring aging. The section of this Attachment to the a udit and rev iew repo rt in whi ch the project team's ev aluation o f the program is documen ted is also provided.Table A 7-1 FRCT, Ra dio Communications System, and Met Tower A ging Management Progra ms FR CT/RC/MT A MP (ID N o.)GAL L R epo rt Compari son GAL L R epo rt AMP(s)FR CT/RC/MT Syst ems or Structur es that Cred it the AM P Pro ject T eam's Eval uati on Sect ion Bo lting Inte gr ity -FRCT (B.1.
12A)Co nsis tent w ith excepti ons XI.M18, Bolt ing Integ rity FRCT Mechanical Syst ems A7.3.0.3.2.1 Closed-Cy cle Cool ing W ater Syst em - FR CT (B.1.1 4A)Co nsis tent w ith excepti on XI.M21, Closed-Cycl e Cooli ng W ater Syst em FRCT Mechanical Syst ems A7.3.0.3.2.2 Aboveground Out door Tanks - FRCT (B.1.2 1A)Co nsis tent w ith excepti on XI.M29 , Above Ground Carbon Steel Tanks FRCT Mechanical Syst ems A7.3.0.3.2.3 Fu el O il Ch em istr y -FRCT (B.1.
22A)Co nsis tent w ith excepti ons X I.M 30 , Fu el O il Chem istry FRCT Mechanical Syst ems A7.3.0.3.2.4 One-Time Inspecti on -FRCT (B.1.
24A)Co nsis tent w ith excepti ons X I.M 32 , O ne-T im e Inspect ion FRCT Mechanical Syst ems A7.3.0.3.2.1 Select ive Leachi ng of Mat er i al s - F RCT Co nsis tent w ith excepti ons XI.M33 , Selective Le ac hin g o f M ate ria ls FRCT Mechanical Syst ems A7.3.0.3.2.6 FR CT/RC/MT A MP (ID N o.)GAL L R epo rt Compari son GAL L R epo rt AMP(s)FR CT/RC/MT Syst ems or Structur es that Cred it the AM P Pro ject T eam's Eval uati on Sect ion 561 (B.1.2 5A)Buri ed Pipi ng In spe ct i on - FRCT (B.1.2 6A)Co nsis tent w ith excepti ons XI.M34, Buri ed Pipi ng and Tanks Inspect ion FRCT Mechanical Syst ems Radio Comm. Sy s.A7.3.0.3.2.7 Struct ures Monit ori ng Program (B.1.
31)Co nsis tent w ith enh anc em ents XI.S6, Struct ures Monitor ing Pr ogram FRCT Mechanical Syst ems FRCT Elect ri cal Syst ems FRCT Struct ural Syst ems Met Tower Struct ural Sys.Radio Com. Sys.
A7.3.0.3.2.8 Inaccessi ble Medi um Volt age Cables Not Sub je ct t o 10 CFR 50.49 Env ir onmental Quali fi cati on Requirements (B.1.36)Co nsis tent w ith excepti ons X I.E 3, In ac ce ss ible Medium Voltage Ca bles No t Sub ject to 10 CFR 50.49 Envir onmental Quali fi cati on Re quire m ents FRCT Elect ri cal Syst ems A7.3.0.3.2.9 Inspect ion of Int ernal Su rfa ce s in Miscel laneous Pipi ng and Ducti ng Compo ne nt s - FRCT (B.1.38)Co nsis tent w ith excepti ons XI.M38 I nspecti on of Inte rn al S ur fa ce s in Miscel laneous Pipi ng and Ducti ng Co m pon ents FRCT Mechanical Syst ems A7.3.0.3.2.10 Lu br ica ting O il An alys is- FRCT (B.1.39)Co nsis tent w ith excepti ons X I.M 39 Lu br ica ting O il Analy sis Pr ogram FRCT Mechanical Syst ems A7.3.0.3.2.11 Peri odic Moni tori ng of Com busti on Turbin e Po we r P lan t Ele ctr ica l (B.1.37)N/A Oyster Creek plant-speci fi c program FRCT Elect ri cal Syst ems A7.3.0.3.3.1 Peri odic I nspecti on Pro gr am - FRCT (B.2.5 A)N/A Oyster Creek plant-speci fi c program FRCT Mechanical Syst ems A7.3.0.3.3.2 Buri ed Pipi ng Inspect ion-Met Tower (B.1.2 6B)Co nsis tent w ith excepti ons XI.M34, Buri ed Pipi ng and Tanks Inspect ion Met Tower Mechanical Syst ems A7.3.0.3.2.12 562 A7.3.0.3.1 AMPs That Are Consistent with th e GALL Report None.A7.3.0.3.2 AMPs That Are Consistent with th e GALL Report with Exceptions a nd/or Enhan cement s A7.3.0.3.2.1 Bolting Integrity - FRCT (B.
1.12A)In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 20 05, Ap pendi x D, S ectio n B.1.1 2A, the appl icant stated that OC GS AM P B.1.12A, ?Bolting Integrity - FR CT," aging management program is a new pro gram that is consi stent with GALL AMP XI.M1 8, ?Bolting Integrity
," with ex ceptions.A7.3.0.3.2.1.1 Program Descriptio n In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at this program w ill be u sed for condition mo nitoring of bolts and bolted joints wi thin the scop e of license renewal at the Forked River Co mbustion Turbine station. The F orked River Combustion Turbi ne power plant wa s originally designed and supplied by General Electric C ompany. This program is based on the General Elec tric recommendatio ns for proper bol ting material se lection, lu brication, pre load applicatio n, installa tion and mai ntenance assoc iated wi th the combustio n turbine un its and auxili ary systems.
The program also i ncludes peri odic wa lkdown in spections for bol ting degradation or b olted joint l eakage. The program manages the loss of bolti ng function, incl uding loss of material and loss o f preload aging effects. Bol ted joint ins pections rel y on detec tion of visibl e leakage during ro utine observ ations and e quipment maintenan ce activi ties.A7.3.0.3.2.1.2 Consi stency wit h the GA LL Rep ort In their response to RAI 2.5.1.
19-1, the applicant stated that the OCGS AMP B.1.12A is consistent w ith the GALL XI.M
.18, with exceptions
.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.12A, incl uding the pro gram bas es doc ument P BD-AM P-B.1.12A, ?Bolti ng Integri ty - F RCT,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M18. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.12 A and associ ated bases do cuments to determine con sistency w ith GALL AM P XI.M18.The project team rev iewed th ose portions of the Bolting Integri ty program for whi ch the appli cant claims consi stency w ith GALL AM P XI.M18 and found that they are consiste nt with th e GALL Report AM P. The project team found the appli cant's Bolti ng Integrity - FR CT conforms to the reco mme nded GALL AMP XI.M18, with exc epti ons a s des crib ed bel ow.A7.3.0.3.2.1.3 Exce ption s to th e GALL Repor t In their respon se to RAI 2.5.1
.19-1, the appl icant stated th e followi ng exception s to the GALL Report program ele ments:
563 Exception 1 Elements :
: 1. Scope of Program
: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: The Bolting Integ rity - FRCT program does not specif ically incorporate NRC and industry recommen dations delineated in NUREG-1339, "R esolution o f Generic Safety Issu e 29: Bolti ng Degradation or F ailure in Nuclear Po wer Plan ts."  The program also does n ot specificall y address E lectric Pow er Research Institute (EPRI) NP-5769 f or safety-related bolting , or EPRI TR-104213. These documents we re develo ped specifical ly for the nuclear pow er industry.
The Forked Riv er Combustion Turbine statio n is a non-n uclea r fossil-fueled stati on. The Bolti ng Integri ty- FRCT program w as evalu ated against the ten elements of agin g management pr ogram XL.M18, "Bolting Integrity," specif ied in NUREG-1801.
Each element is eval uated, and the associated portions of the el ement that are ap plicable to the Forked Ri ver Combustion Turbine power plant have been incorporated into t his program. This program appl ies good ind ustry bolti ng practices based on Gene ral Electri c (the original FRCT designer a nd supp lier) reco mme ndat ions , sup plem ente d with p erio dic wal kdo wn inspections to confirm bolti ng integrity. The requirements for safety-related bo lting, and bol ting for nuclear ste am supply system component suppo rts, do not appl y to the Fo rked River C ombustion Turbin e pow er pla nt.The GALL Report i dentified the foll owing recommend ations for the program e lements ?scope of program," ?preve ntiv e acti ons," ?parame ters mon itored or in specte d," ?detection of aging effects,"
?monitoring and tre nding" and
?acceptance cri teria" associ ated with the excep tion taken:
: 1. Scope of Prog ram:  This program cov ers bolting w ithin the sc ope of licens e renewal, including: 1) safety-relat ed bolting, 2) bolting f or nuclear steam supply system (NSSS) component supp orts, 3) boltin g for other pressure retai ning components, inc luding non-sa fety-related bol ting, and 4) structu ral boltin g (actual measured yi eld strength &#xb3; 15 0 ksi). The aging managemen t of Reactor Head Closure Stud s is addresse d by XI.M3 , and is no t included in this program.
The staff's re commend ation s and guidel ines for compr ehens ive bolti ng inte grity programs that encompass all safety-related bolting are delineated in NUR EG-1 339, wh ich inc lud e the cri teri a es tabl ish ed i n the 199 5 ed iti on th rough the 1996 add enda of ASM E Code Sec tion XI. The ind ustry's tech nical basi s for the program for safety-relate d bolting and guidelines for material sel ection and testing, bolting p reload control , ISI, plant op eration, and ma intenance, an d evaluati on of the structural integrity of bo lted joints, a re outlined in EPRI N P-5769, with the exceptions noted in NUREG-1339. For other bolting, t his information is set forth in EPR I TR-104213.
564 2. Preventive A ctions:  Selectio n of bolting materi al and the use of lubrican ts and sealants is in accordan ce with the guidelin es of EPRI NP-5 769, and the additional recomme ndati ons of N UREG-1 339, to prev ent or mitigat e degra datio n and failur e of safety-r elated bolting. NUREG-1339 tak es exception to certain items in EPRI NP-5769, and recommends additi onal measures with regard to them. Boltin g replacement acti vities i nclude prope r torquing of the bolts and checking for uniformity of the gasket co mpression after asse mbly. M aintenance p ractices require the appl ication of an appropriate pre load, based on EPRI doc uments.3. Parameters Moni tored or Inspected
: This program monitors the effects of aging on the inten ded function of bol ting. Specifical ly, bolti ng for safety-related pressure retaining com ponents is inspected for leak age, loss of mate rial, crackin g, and l oss of p reloa d/los s of pres tress. B oltin g for othe r press ure retain ing com ponen ts is i nspect ed for si gns of le akage. H igh stre ngth bo lts (actual yi eld strength >150 ksi) used in N SSS componen t supports are mon itored for cracking. Structural b olts and fasteners are inspecte d for indicati on of potent ial proble ms includ ing loss of mat erial, cr acking , loss of coating integr ity, and obvi ous signs of corrosi on, rust, etc.
: 4. Detect ion o f Agin g Effec ts:  Inspection requirements are i n accordance with the ASME  Section XI, Table s IWB 2500-1, IW C 2500-1 and IWD 2500-1 editions endorsed in 10 CFR 50.5 5a(b)(2) and the recommendations o f EPRI NP-5769.
For Class 1 components, Tabl e IWB 2500-1, Examinatio n Category B-G-1, for bolts greater than 2-inches in diameter, speci fies volumetri c examinati on of studs and bolts an d visual VT-1 examina tion of surfaces of nuts, w ashers, bushin gs, and flanges. Ex amination Ca tegory B-G-2, for bolts 2-inches or s maller, requires only v isual VT-1 ex amination of surfaces of bolts, studs, an d nuts. For C lass 2 components, Table IW C 2500-1, Ex amination Ca tegory C-D, for bol ts greater than 2-inch es in diame ter, requ ires v olumet ric ex aminat ion o f studs a nd bol ts. Examinati on Categories B-P, C-H, and D-B require vi sual exa mination (IW A-5240) durin g system leakage testi ng of all pressure-retaining Cl ass 1, 2 and 3 components, ac cording to Tables IWB 2500-1, IW C 2500-1, and IWD 2500-1, respectivel
: y. In addi tion, degradatio n of the closure bolting due to crack initiati on, loss of prestress, or loss of material due to corrosion of the closure bolting would resul t in l eakage. The ex tent an d sche dule of insp ectio ns, in accord ance w ith Tables IW B 2500-1, IW C 2500-1, and IW D 2500-1, combined with periodic system wal kdowns, assure detection of le akage before the leakage be comes excessiv e. For other p ressure retaini ng bolting, perio dic system w alkdowns assu re de tect ion of le akage befo re th e le akage bec omes exc essi ve. Hi gh strength str uctural bolts and fastener s (actual yield strength 150 ksi) f or NSSS component supports, may be subject to stress corros ion cracking (SCC). For this type of high streng th structural bolts that are potentially subjected to SCC, in sizes greater than 1-inch nominal diamet er, volumetric examination comparable to that of Exami nation Category B-G-1 is required in additi on to vis ual examination. This requireme nt may be waived with adequate plant-specific justifi catio n. Stru ctural bolts and fas teners (actua l yi eld s trength < 150 ks i) bot h insi de and outsi de con tainme nt are inspe cted b y vi sual inspe ction (e.g., Structures Monitoring Prog ram or equivalent). In addition to visual and volumetric examinatio n, degradation o f these bolts and fasteners may be detected and measured by removing the bolt/f astener, a proof t est by tension or torquing, in situ ultrason ic tests, or a hammer test. If these bol ts and fasteners are found 565 cracked and/or corrod ed, a closer inspection is performed to asse ss the exten t of corrosion. An appropriate technique is selected on the basis of the bolting applicatio n and the ap plicable code.5. Monitoring and Trendin g:  The i nspect ion s chedu les o f ASME Secti on XI ar e effective and ens ure timely detection of appl icable agin g effects. If bolting conne ction s for pre ssure r etain ing com ponen ts (not cove red by ASM E Sect ion XI)is reported to be leaking, then it may be i nspected dai ly. If the le ak rate does not increas e, the ins pection freq uency may be decreas ed to biweek ly or weekly.
: 6. Acceptance Criteria
:  Any indi catio ns of agi ng effects in AS ME p ressur e retain ing bo lting are ev aluat ed in accord ance w ith Se ction XI of the ASM E Cod e. For other pressu re retaining bo lting, NSSS component suppo rt bolting and structu ral bo lting, indi catio ns of agi ng shou ld be disp ositi oned i n acco rdance wit h the correctiv e action proc ess.The applican t stated, in the ir response to RAI 2.5.1.19-1 and in the basis documen t PBD-AM P-B.1.12 A, th e fol low ing: The scope of the pro gram covers bol ting withi n the scope o f license renew al at the Fo rked River Combustion Turbi ne power plant. There i s no safety-rela ted bolting or bolting for nucle ar steam supply sy stem (NSSS) compo nent supports a t the Forked Riv er Combustion Turbine pow er plant. The program sc ope inclu des pressure-retai ning component b olting and stru ctural bolti ng used on the F orked River combustion turbi ne units and auxili ary systems and structures i n the scope of license renewal. The Forked River Combust ion Turbine power plant was originally designed and supplied by General Electric Co mpany, and th is program is ba sed on the Gen eral Electric reco mmendations for prope r bolting appl ication and maintenance associated w ith the combustion turbi ne units and auxili ary systems.
For preventive actions, selection of bolting material and the use of lubricants and sealant s is in accordance w ith the recommend ations prov ided by General Elec tric. The GE Inspe ction and Maintena nce manual for the units prescri be the speci fic sealants an d lubricants to be used, a nd how and where they are appli ed. Boltin g replacement acti vities i nclude prope r torquing of the bolts, proper a lignment of flanges, and checking for proper matin g surface contact after assembly b ased on the s pecific joint c lassification. Mainte nance practice s require the applicatio n of an appropri ate preload, a s specified i n the General Electric Insp ection and Maintenance Instructions for the combustion turbine units. Preload of gasketed joints is contro lled by to rque w rench or by measur ement o f bolt o r stud elonga tion. Prelo ad of joi nts w ith metal-to-metal conta ct is control led by to rque wrench, b y measurement o f bolt or stud elongation, or by head ro tation.For parameters moni tored or inspe cted, this program mon itors the effects of aging on th e inten ded fun ction of bol ting as socia ted w ith th e Forke d Riv er Comb ustio n Turbi ne pow er pla nt. There are no safety-related pressu re retaining co mponents or NSS S component su pports at the Forked Rive r Combustion Turbi ne power plant. Pressu re retaining bo lting at the Fo rked River Combustion Turbi ne power plant wi ll be peri odically inspected for si gns of leakage. Other bolting wi ll be in spected for signs of si gnificant degradation includi ng loss of material , loss of coating integrity , and obvi ous signs of corrosi on, rust, or loo se or missing b olts.For detection of aging effects, degradation of the p ressure retaini ng closure bol ting due to crack initiation, loss of prestress , or loss of material due to corr osion of the closure bolting would result 566 in l eaka ge. P erio dic pla nt w alkd own s w ill ass ure d etec tion of le akage befo re th e le akage becomes exce ssive suc h that the in tended function o f the Forked Riv er Combustion Turbine power pl ant woul d be impacted. In additi on to leakage dete ction, plant walkdow ns wil l includ e inspection of bolting for signs of si gnificant degradation includi ng loss of material , loss of coatin g integrity, and obvious signs of corrosion , rust, or loose or missing bol ts.For monitoring an d trending, w alkdown i nspections for l eakage and inspe ctions for bolti ng degradation w ill be p erformed at least on ce every four years. Ide ntified leakage w ill be monitored dai ly until repaired. M uch of the equipment at the Forked Ri ver Combusti on Turbine power pl ant is loca ted outdoors, so even small leaks must be i mmediately isolated or repaired because of potenti al envi ronmental conce rns. If continued leakage is accep table under the applicabl e permits and regulations, and if the leak rate d oes not incre ase, the insp ection freq uency may be decreas ed to biweek ly or weekly.
For acceptance criteria, any indicati ons of leaking press ure retainin g bolting, or bol ting degradation that could potenti ally l ead to loss of system or compon ent intended functions, wi ll be evalu ated and di spos ition ed in a ccor danc e with t he co rre ctive acti on pr oces s des crib ed bel ow.The project team noted that there are no saf ety-related components or nuc lear steam supply system support components that su pport the operati on of Forked Riv er Combustion Turbine station and h ence the guida nce for the ASM E Section XI i nspection requi rements, selecti on of bolting material and the use of lubricants and sealants contained in NUREG-1339, EPRI TR-104213, and E PRI NP-5769 does not appl y to the FR CT power pl ant. On this b asis, the project team found thi s exceptio n acceptable
.Exception 2 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
The sit e corre ctiv e acti ons pr ogram, qua lity assura nce (QA) proce dures, site review and approval process, and administrative controls are implement ed in accordance w ith 10 CFR Part 50, Appe ndix B. The staff finds the requirements o f 10 CFR Part 50, Appendi x B, accep table to add ress the correcti ve action s, confirmation proces s, and admini strative con trols.The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Branch Technica l Positio n ?Quality A ssurance for Aging Management Pro grams."  On this basi s, the project team foun d this ex ception acce ptable.
567 A7.3.0.3.2.1.14 Enhan cements None.A7.3.0.3.2.1.15 Operating Expe rience The app lica nt stat ed in their respo nse to NRC R AI 2.5.1.19-1 that i n Ma rch 20 04 (Un it 1 F RCT), GE Energy Services perform ed major inspection and maintenanc e activities and documented all work performed in a n inspectio n reports dated June 7, 2004.
The equipment in spections included the turbine and its internals and support eq uipment. All work was carried out closely following th e instruction s and guidanc e found in the original equi pment manufacturer's desi gn, maintenance an d inspectio n manuals. A cceptance crite ria and correc tive acti ons for these activiti es ensure that equipment is mai ntained w ithin desi gn specifications
.The Unit 1 i nspection w as a major mainten ance inspec tion. This w as the first major in spection that was pe rformed on the unit since ini tial instal lation in 1988. Duri ng final alignment of the load gear followi ng the major inspe ction, three l oad gear anchor bolt studs fail ed. The cause of the failure was determined to be improper i nitial i nstallation. All anc hor bolt studs were repa ired by weldin g new studs in place.
The anchor bol ts had not fail ed during the s ixteen y ears of operation pri or to the major outa ge.There is no hi story of bolted joint failures resulting in loss of intende d function of the co mbustion turbin e uni ts. Da maged an d miss ing bo lts ha ve be en id entifi ed in the ho t exh aust gas plen um, but the exh aust system struc tural integrity was not compromised and the unit ope rability and reliability was not affected. Critical bolting associat ed with the combustion turbine assembly is inspected du ring maintenance inspection s and replac ed if required.
Numerous bolts and bolted joints we re visual ly observ ed during w alkdowns co nducted durin g the combustion turbi ne Unit 2 ma jor inspection outage that began i n October 2005.
Bolted join ts, including pipe flanges, ventilation joints , pump casings and valve bonnets, were observed in indoor and outdoor env ironments, and w ere found to be i n good conditi on with no signs of signifi cant d egradat ion o r missi ng or l oose b olts. Min or surfa ce rust was observ ed on some outdoor bolti ng. The coating of pai nted boltin g was observ ed to be in good conditi on. Boltin g was observ ed on Unit 1, Unit 2, an d common auxi liary sy stems.The operating ex perience w ith the Forked R iver combus tion turbines includes a significant number of past ins pection acti vities th at included observatio ns of bolting and bolted join ts. The documented ins pection resul ts provide objective e vidence that existi ng environmen tal conditi ons are not resulti ng in significan t bolting degradati on that could result in a loss of the b olting intended functio ns. Past ins pections hav e been performed at a various frequencies, as lo ng as 16 years for so me components, w ith the uni ts performing reliabl y betwe en inspecti ons.Impleme ntatio n of thi s new program wil l assu re that prope r bolt ing mai ntenan ce pra ctices are continued, an d that wal kdown insp ections for leakage a nd inspecti ons for bolting de gradation will be performed at least once every four years, providing assur ance that the aging ef fects will be adequately managed for the peri od of extended operation.
The project team rev iewed th e operating ex perience prov ided in th e basis doc ument, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.
568 On the b asis o f its rev iew of the a bove  plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applic ant's t echnica l staf f, th e proje ct team determ ined that the applic ant's Bolt ing Int egrit y -FRCT program wi ll adequatel y manage the a ging effects that are identi fied in the OCGS LRA for which thi s AMP i s credited.
A7.3.0.3.2.1.16 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he Bol ting In tegrity - FRC T program in the ir response to NR C RAI 2.5.1.19-1 , which stated that the B olting Integrity
- FRCT program is a new program that provides for condition mon itoring of bolts a nd bolted joi nts withi n the scope o f license ren ewal at the Forked Riv er Combustion Turbine pow er plant. The F orked River Combustion Turbine power plant was originally designed and supplied by General Electric Company. Thi s program is based on the General Electric rec ommendations for prop er bolting materi al se lecti on, lu brica tion, prelo ad app lica tion, insta llati on and mainte nance assoc iated wit h the combustion turbine units and auxiliary systems. The prog ram also includes periodic walkdow n inspectio ns for bolting degrada tion or bol ted joint lea kage at a frequency of at l east once every four years. The p rogram manages the loss of material and loss of preload aging effects. This new p rogram will be implemen ted prior to e ntering the peri od of extended operation.
The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the Nov ember 11, 2006 supplemental response to RA I 2.5.1.19-1, and confirmed that this program i s identified as a new program that wi ll be impl emented prior to the period of extended o peration as i tem 51 of the commitments.
On the b asis o f its rev iew of the a bove  plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applic ant's t echnica l staf f, th e proje ct team determ ined that the applic ant's Bolt ing Int egrit y -FRCT program wi ll adequatel y manage the a ging effects that are identi fied in the OCGS LRA for which thi s AMP i s credited.
The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.12 A found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.1.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.2 Closed-Cycle Cooling W ater System - FRCT (B.1.14A)
In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , Appendix D, Section B.1.14 A, the appli cant st ated th at OCGS AMP B.1.14 A, "Cl osed-C ycle Cool ing Water Sy stem -FRCT," is a ne w program that i s consistent w ith GALL AM P XI.M21, "Cl osed-Cycl e Cooling Water Syste m," wi th tw o exc eptio ns and an en hance ment.
569 A7.3.0.3.2.2.1 Program Descriptio n In the Nov ember 11, 2005, supplemental response to NR C RAI 2.5.1.19-1 , the appli cant stated that th is pro gram mana ges agin g of pumps , tanks, pipi ng, pip ing com ponen ts, pi ping e lement s and heat ex changers that are i ncluded i n the scope o f license renew al and are exposed to a closed cooling water environment at the Fork ed River combustion turbine power plant. This program incorporates experience with ex isting activ ities associ ated with the closed cooling w ater system, performed at the Forked Riv er combustion tu rbine pow er plant. The c losed cool ing water env ironment at the Forked Rive r combustion turb ine pow er plant is a blended water-glyco l based env ironment. This p rogram includes preventiv e measures to mi nimize co rrosion and SCC, a nd per formance monito ring an d main tenanc e ins pecti on act ivi ties t o moni tor the effects of corrosion and SCC on the intended functio n of the components.
Preve ntiv e acti viti es rel y on mainte nance of appr opria te wa ter che mistry contro l para meters with in the speci fied l imits of Elec tric P ower Resea rch Ins titute (EPRI) TR-100 7820, ?Closed Cooling W ater Che mistr y Guideline
," Revisio n 1, for blended g lycol for mulatio ns, to m inimize corros ion a nd SC C. Thes e cont rol pa rameter s incl ude pe rcent gl ycol or freez e poi nt, and pH. EPRI TR-100782 0 does not requi re monitoring of sy stem corrosion i nhibitor con centrations for blend ed gly col form ulati ons, u nless corros ion i nhibi tors ha ve be en add ed. If co rrosio n inh ibito rs are added, then EPRI TR-10078 20 Section 5.9 recommends that the corrosion inhibitor concentrations be monitored to within the range recommende d by the c orrosion inh ibitor manufacturer. The FRCT cl osed-cycle cooling w ater system uti lizes a proprietary inhibite d glycol prod uct and does not add suppl emental corrosi on inhibi tors.The applicant also stated that perf ormance monitoring provides indications of degradation in closed-cycl e cooling w ater systems, w ith plant o perating condi tions provi ding indica tions of degradation in frequently operate d systems. In addition, sta tion maintena nce inspecti ons provide c ondition mon itoring of heat ex changers expos ed to closed-cycle coo ling water environments. These measures w ill ensu re that the inte nded functions o f the systems and comp onen ts se rvi ced by t he c los ed c ool ing w ater sys tem a re no t com prom ise d by agin g.A7.3.0.3.2.2.2 Consi stency wit h the GA LL Rep ort In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that the close d-cycle co oling wate r - FRCT AM P-B.1.14A is consistent w ith GALL AM P XI.M21, with two exce ption s and an enh anceme nt.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for the closed-cy cle cooli ng wate r - FR CT AM P-B.1.14A, i nclud ing pro gram bas is do cument PBD-A MP-B.1.14A , ?Closed Cycle C ooling Water - FRCT," Rev.
0, which provides an assessment of the AMP el ements'consistency with GALL AMP XI.M 21. Specifica lly, the project team revi ewed the program elements (see Section 3.0.2.
1 of this audit and review report) contained in the closed-cycle cooling w ater - FRCT program b asis document PBD-AMP-B.1.14A and a ssociated ba ses documents to dete rmine their co nsistency with GALL AMP XI.M 21.The project team rev iewed th ose portions of the closed-cy cle cooli ng water - FR CT aging management program for whi ch the appli cant claims c onsistency with GALL AMP XI.M 21 and found that they are consistent with the GALL Report AM P. The project team found that the applicant' s closed-cy cle cooli ng water - FR CT aging management program con forms to the reco mme nded GALL AMP XI.M21, with th e exce ptio ns an d enha ncem ent d escr ibed b elow.
570 A7.3.0.3.2.2.3 Exce ption s to th e GALL Repor t In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated the followi ng exception s to the GALL R eport program elements
: Exception 1 Elements: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 5. Monito ring and Trendin g 6. Acceptance Criteria Exception: NUREG 1801 refers to EPRI TR-1073 96 ?Closed Coo ling Water Chemi stry Gu idel ines" 1997 Revi sion. Oyste r Cree k imple ments the guidance p rovided i n EPRI 1007 820 "Closed Cooling Water Chemi stry Gu idel ine," Revi sion 1, wh ich i s the 2 004 Re visi on to TR-1073 96. EP RI peri odica lly updat es in dustry wate r chemi stry guidelines, as new i nformation becomes a vailabl e. Oyster Cree k has revie wed EPR I 1007820 an d has determin ed that the most signifi cant d ifference is th at the new revi sion provi des mor e prescriptiv e guidance an d has a more c onservativ e monitoring approach. EP RI 1007820 mee ts the same recommend ations of EPRI TR-107396 for maintaining c onditions to minimize corrosion and microbio logical grow th in close d cooling w ater systems for effectively mi tigating many agin g effects.
The GALL Report i dentified the foll owing recommend ations for the
?preve ntiv e acti ons,"?parame ters mon itored or in specte d," ?monitoring and tre nding," and
?acceptance cri teria"program elements asso ciated wi th the excep tion taken:
: 2. Preventive A ctions:  The program relie s on the use of appropriate materi als, lining, or co ating to protect the underlyi ng metal surfaces and maintain sy stem corros ion i nhibi tor con centra tions wit hin th e spec ified limit s of EPR I TR-107 396 to minimize corrosion and SCC.
: 3. Parameters Moni tored or Inspected
:  The aging management pro gram monitors the eff ects of corrosion and SCC by testing and inspect ion in accordance w ith guidance in EPRI TR-10 7396 to ev aluate sy stem and componen t condition.
: 5. Monitoring and Trendin g:  In accordance with EP RI TR-107396, i nternal vi sual inspe ction s and performan ce/funct ional tests a re to b e perfor med per iodi call y to demons trate s ystem operab ilit y and confirm the effec tive ness o f the pro gram.6. Acceptance Criteria
:  Corrosion inhibitor concentrations are maintained within the limits specified in the EPRI water chemistry guidelines f or CCCW.  (NUREG 1801 r efers to EPRI TR-10739 6 for con trol o f water chemi stry).In reviewing this exception, the project team not ed that in Section 2.2 of the prog ram basis docume nt, PB D-AM P-B.1.14A, ?Closed-Cy cle Cooli ng Water," Rev. 0, the paragraph ti tled?Sum mar y o f Ex cep tio ns t o N URE G-1 801" de scr ib ed the ab ov e e xc ept io n re la ted to the use of 571 EPRI TR-10739 6, ?Closed Cooling W ater Chemistry Guidelines" (1997 revision). However, this exce ption was not id entifi ed or d iscus sed i n the S ectio n 3.0 o f the pro gram bas is do cument, whi ch con tains the ev aluat ion o f the in divi dual GALL a ging man agement program e lement s. The applican t stated that PB D-AMP-B.1.1 4A wil l be revi sed to incl ude this ex ception in the program basis docu ment Section 3
.0 evalua tion of the ind ividual GALL aging management program elements.
The applicant stated that th e program basis documen t, PBD-AMP-B.1.14A, for t he closed-cycle cooli ng wat er - FR CT agin g manageme nt progr am wi ll be revi sed to addre ss the exce ption to the us e of EPR I TR-107 396, ?Closed Coo ling Water Chemistry Guidel ines," in the evaluati on of the in divi dual program e lement s in S ectio n 3.0 o f the pro gram bas is do cument.As part of the aud it, the project tea m interview ed the appl icant's tech nical staff to disc uss technical i ssues related to this ex ception. Duri ng the intervi ew, the ap plicant des cribed its re view and ev aluat ion o f the di fferences betw een EP RI TR-1 07396 , ?Close d Cool ing Water Che mistry Guidelines," the 1997 revision of the guidelines ref erred to in NUREG-1801, and EPRI TR-1007 820, ?Closed Coo ling Water Chemistry Guidel ine," Revi sion 1, w hich is the 2004 revision implemented b y Oyster Cre ek. The applica nt stated that the most significant d ifference from the orig inal version of the closed cooling water chemistry guidelines docum ent is that EPRI TR-1007820 prov ides more presc riptive gui dance and ha s a more conserv ative moni toring approa ch. The appl icant further stated that E PRI TR-10078 20 meet s the s ame recommendations o f EPRI TR-107396 for mai ntaining cond itions to mi nimize co rrosion and microbiologic al growth i n closed co oling wate r systems for effectivel y mitigating many aging effects.In addition , the appli cant stated that a s part of its compara tive rev iew of the gui delines documents it had contacted Ant hony Selby, the author of EPRI TR-107396 and EPRI TR-1007820, to co nfirm that the new guidance that was prov ided in TR-1 007820 w as not contrary to the guidance in TR-107396.
The pro ject tea m revi ewed EPRI TR-1007 820, ?Close d Cool ing Water Che mistry Guide line ," Revisio n 1, and EP RI TR-107396 (Re vision 0) and confirmed th e applica nt's assessment that the new re vision provides more prescriptiv e guidance, ha s a more conserv ative moni toring approach, and meets the same requi rements for maintaini ng conditions to minimiz e corrosion and microbio logical grow th in close d cooling w ater systems for effective ly mitigati ng many aging effects. On this basis , the project team found this exce ption accepta ble.Exception 2 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
572 The sit e corre ctiv e acti ons pr ogram, qua lity assura nce (QA) proce dures, site review and approval process, and administrative controls are implement ed in accordance w ith 10 CFR Part 50, Appe ndix B. The staff finds the requirements o f 10 CFR Part 50, Appendi x B, accep table to add ress the correcti ve action s, confirmation proces s, and admini strative con trols.The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.2.4 Enhan cements In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated identified the followin g enhancement in order to meet meeti ng the GALL Repo rt program elements: Eleme nt: 1. Scope of Program Enhan cement: The closed-cy cle cooli ng water - FR CT aging management program i s a ne w pro gram to b e impl emented for the compon ents in the scope of license renewal and subject to a closed cycle cooling w ater enviro nment located a t the Forked Riv er combustion Turbin e pow er pla nt.The GALL Report i dentified the foll owing recommend ation for the
?scope of program" elemen t associ ated w ith th e enha ncemen t: 1. Scope of Prog ram: A CCCW system is define d as part of the se rvice w ater system that is not subject to s ignificant sources of contamination , in whi ch water chem istr y i s co ntro lle d, an d in wh ich hea t is not dire ctly reje cted to a hea t si nk.In reviewing this enhancement, the proj ect team noted that in Section 2.2 of the program basis document PBD-AMP-B.1.14A,?Closed-Cy cle Cooli ng Water," Rev. 0, the paragraph ti tled?Summary of Enha ncemen ts to N UREG-1 801" s tated t hat the close d-cyc le co olin g wate r -FRCT aging manag ement program is a new program to be implemented for the components in the scope of li cense renew al and sub ject to a close d cycle cooling w ater enviro nment located a t the Forked Riv er combustion Turb ine pow er plant. Ho wever, th is enhancemen t was not identified or discussed i n the Sectio n 3.0 eval uation of the i ndividu al GALL aging man agement program element
: s. The applicant stated that PBD-AMP-B.1.
14A will be revised to include this enhancement in the program basis document Secti on 3.0 eva luation of the indivi dual GALL aging management program ele ments.The applicant stated that th e program basis documen t, PBD-AMP-B.1.14A, for t he closed-cycle cooling w ater - FRCT agin g management program wi ll be rev ised to addre ss the enhanc ement to develo p the new closed-cy cle cooli ng water - FR CT aging management program in the eval uatio n of the indi vidu al pro gram ele ments, i n Sect ion 3.0 of the program basis docume nt.In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that th is pro gram mana ges agin g of pumps , tanks, pipi ng, pip ing com ponen ts, pi ping e lement s 573 and heat ex changers that are i ncluded i n the scope o f license renew al and are exposed to a closed cooling water environment at the Fork ed River combustion turbine power plant. This program incorporates experience with ex isting activ ities associ ated with the closed cooling w ater system, performed at the Forked Riv er combustion tu rbine pow er plant. The c losed cool ing water env ironment at the Forked Rive r combustion turb ine pow er plant is a blended water-glyco l based env ironment. This p rogram includes preventiv e measures to mi nimize co rrosion and SCC, a nd per formance monito ring an d main tenanc e ins pecti on act ivi ties t o moni tor the effects of corrosion and SCC on the intended functio n of the components; therefore, the project tea m determined that this new program is acceptab le.On this basis , the project team found this enhanc ement acceptabl e since w hen the enhancement is implemented, OCGS AMP-B.1.14A, "Closed-Cycle Cooling W ater - FRCT," will be consisten t with GALL AMP XI.M 21 and w ill prov ide additi onal assuran ce that the effects of aging will be adequately managed.A7.3.0.3.2.2.5 Operating Expe rience In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that the Forked Ri ver combustio n turbine po wer plan t has not ex perienced a loss of intende d function failure o f components due to corrosion prod uct buildup , through-wall loss of material , or SCC for components within the scope of license renewal that are subject to a closed-cycle cooli ng wat er env ironme nt.The Forked River combustion tu rbine units undergo periodic majo r inspection outages in accord ance w ith man ufacture r's re commend ation s. In M arch 2 004 (U nit 1 combus tion t urbin e), GE Energy Services perform ed major inspection and maintenanc e activities and documented all work performed in a n inspectio n report dated J une 7, 2004.
In October 2005 GE began a major inspection and maintenan ce outage on the Unit 2 combu stion turbine. The scope of equip ment inspections included the turbine and its internals and support equipment. Acceptance cr iteria and corr ecti ve a ctio ns fo r the se a ctiv iti es e nsur e tha t equ ipme nt i s mai ntai ned wi thin des ign specifications
.The combustion tu rbine lube oil heat exchangers w ere removed, d isassembled and inspecte d during the major i nspection ou tages performed on each combustion turb ine unit.
GE did not ident ify an y si gnifica nt degra datio n of the se hea t exc hangers in th e Uni t 1 out age fina l repo rt. The Unit 2 l ube oil h eat exchangers were vi sually inspected du ring the current (Octob er 2005)outage and w ere found to be i n good conditi on with only mino r pitting of carbon steel compon ents, w ith no signi ficant s igns of c orrosi on or w all t hinni ng in t he cop per al loy tubes. Pump casings, pi ping, and va lve inte rnal surfaces ex posed to clo sed coolin g water we re also visuall y inspecte d during this outage with no significant c orrosion or w all thinn ing observed
.Forked Rive r combustion turb ine pow er plant compo nents in the scope of licen se renewal and exposed to closed cool ing water, i ncluding hea d tanks, the wa ter-to-air heat ex changer located at the mechanic al draft cooli ng tower, and the variou s heat exch angers cooled b y the clo sed cooling w ater system, hav e not expe rienced los s of intended functi on failures du e to age-related degradation.
The combustion tu rbine operati ng experienc e provide s objective evidenc e that the Forked River combustion turbi ne components s ubject to close d cooling w ater are not ex periencing si gnificant age-related degr adation, and that the closed-cycle cooling water chem istry has been adequately mainta ined to effecti vely manage the effect s of agin g. This new close d cyc le co olin g wate r -
574 FRCT a ging man agement program w ill incl ude ad ditio nal c hemist ry co ntrols and c ompone nts condition monitoring activities, providing f urther assurance that a non-corrosive environment is maintained s uch that aging-rela ted degradation will continue to b e minimiz ed.The project team rev iewed th e operating ex perience prov ided in th e November 11, 2005, suppl emental respo nse to NRC R AI 2.5.1.19-1 , and i nterv iew ed the appl icant's tech nical staff to confirm that the pl ant-specific ope rating experi ence did n ot reveal any degradati on not bound ed by indus try experi ence.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staf f, the project team determined that th e applicant's  closed-cycle cooling w ater - FRCT program w ill adequate ly manage the aging effects that are ide ntified in the applicant' s FRCT AM Rs for which this AM P is credi ted.A7.3.0.3.2.2.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he Cl osed-C ycle Cool ing Water Sy stem -FRCT program inthe November 11 , 2005, suppl emental respons e to NRC R AI 2.5.1.19-1, Appendix A, Section A.1.14A, wh ich stated tha t the closed-cy cle cooli ng water sy stem aging management program is a new program that manages aging of pipin g, piping componen ts, piping eleme nts and heat e xchangers that a re included in the scop e of license renewal for loss of material and c racking and are ex posed to a cl osed cooli ng water env ironment at the Forked River com bustion turbine power plant. The pr ogram relies on pr eventive me asures to minim ize corrosion by maintainin g by maintai ning water c hemistry contro l parameters and by performing system monitoring and inspect ion activities to confirm that the ag ing effect s are adequately managed. Chemistry control, performance monitoring, and i nspection ac tivities are based on indus try-re cogniz ed gui deli nes of E PRI TR-10739 6, ?Close d Cool ing Water Che mistry Guidelines
," for closed-cyc le cooli ng water sy stems.In the supple mental response to NRC RA I 2.5.1.19-1, the a pplicant al so stated that ch emical control parameters will be monitored by annual water chemi stry sampli ng. System ope rational monitoring activities will be performed at a f requency of at least once every six months. This new program w ill be i mplemented prio r to entering the period of exte nded operatio n.The project team als o review ed the appl icant's li cense renew al commitment li st in Appen dix A o f the supplemental response to RAI 2.5.
1.19-1, and confirm ed that the enhancements to this program are identi fied and wi ll be impl emented prior to the period of extended op eration as i tem 52 of the commitments.
The project team reviewed the UFSAR Supplement for OCGS AMP B.1.14A and found that it was c onsis tent w ith th e GALL Repor t. The p roject t eam det ermine d that it pro vide s an a dequate summary descrip tion of the program, as identified i n the SRP-LR FSAR Sup plement table and as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.2.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to manage the aging effects for whi ch it is cre dited. Als o, the project team has revie wed the 575 enhancement and determined tha t the implementa tion of the enha ncement prior to the period o f exten ded op erat ion wou ld res ult in the ex isti ng AMP being cons iste nt wit h the GALL Repor t AMP to whic h it was comp ared. The proj ect t eam a lso re viewed the UF SAR Su pplem ent f or th is AMP and found that i t provides an adequate summary description of the program, as required by 10 CFR 54.21 (d).A7.3.0.3.2.3 Above Ground Steel Tanks - FRCT (B.
1.21A)In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 2005, Appendix D, Section B.1.12A, the applicant stat ed that OCGS AMP B.1.21A,"Abo vegr ound Stee l Tan ks - FRCT ," is a new pla nt pr ogr am th at is cons iste nt wit h GAL L AMP XI.M29 , ?Aboveground Carbon Steel Tanks," with an exceptio n.A7.3.0.3.2.3.1 Program Descriptio n In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at this program w ill prov ide for mana gemen t of l oss of mat eria l agi ng effe cts fo r out door carb on s teel stor age t anks. The tank s included in this program a re the main fuel oil storage tan k, the closed co oling wate r system head tanks located at the closed c ooling wa ter mechanical draft cooling tow ers, and the di esel starter jacket water (clo sed coolin g water) head tanks located on the roof of the combusti on turbine auxili ary enclo sure. The program credi ts the appli cation of pain t coating as a corrosion preventiv e measure and includes p eriodic v isual in spections to monitor degradatio n of the paint coating and an y resulti ng metal degradatio n for the steel tan ks.Periodic i nternal UT in spections w ill be p erformed on the bottom o f the outdoor steel Main F uel Oil tank supported by earthen
/concrete foundatio
: n. Other outdoor carbon steel tanks in the scope of this pro gram are not directl y supported by earthen or concrete foundati ons and therefore under go external visual inspections without the necessity of bottom surface UT inspections
.The mai n fuel oil t ank is the on ly i n-scop e outd oor tan k suppo rted by an ea rthen/c oncret e foundat ion. This ta nk does not ha ve ca ulking or sea ling a round the tan k-foundat ion i nterface. Raised ta nks not directly su pporte d by earthe n or concr ete fo undatio ns also do no t have caulking or seal ing. Therefore, inspec tion of sealan t or caulking at th e tank-foundation i nterface does not apply.The Aboveground Steel Tanks - F RCT aging management program i s a new program. External tank inspection s will be at a frequency of every tw o years. B ottom surface UT inspe ctions wi ll be at a frequency of once every 2 0 years, bas ed on plan t specific opera ting experie nce with the Forked Rive r Combu stion Turbin e pow er pla nt main fuel o il st orage ta nk. This program, includin g the initial tank external paint ins pections, w ill be i mplemented prio r to the perio d of extended o peration. The re commended UT ins pection of the mai n fuel oil tank bottom was performed in Oct ober 2 000, s o it i s not n ecessa ry to perform th is in itial insp ectio n agai n prio r to entering the peri od of extended operation.
Based on the results of the Octob er 2000 inspections , and subsequent repairs to the tank floor, the tank w as certified to b e suitable for the storage of number 2 fuel oil for a peri od of time not to e xceed 20 years before the next inte rnal inspe ction wou ld be neces sary. Therefo re, UT i nspect ions of the ta nk floor are no t nece ssary prior to enteri ng the period o f extended ope ration, and w ill be p erformed again prior to October 2020.
576 A7.3.0.3.2.3.2 Consi stency wit h the GA LL Rep ort In their response to RAI 2.5.1.
19-1, the applicant stated that the OCGS AMP B.1.21A is consistent w ith the GALL XI.M
.29, with an excepti on.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.21A, incl uding the pro gram bas es doc ument P BD-AM P-B.1.21A, ?Abov eground Steel Tanks - FRCT,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s con sist ency wit h GAL L AMP XI.M.29. Speci fically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.21 A and associ ated bases do cuments to determine con sistency w ith GALL AM P XI.M29.The project team rev iewed th ose portions of the Abovegroun d Steel Tanks -
FRCT program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 29 and found t hat the y are consistent w ith the GALL R eport AMP. The project team found that the appl icant's Abo veground Steel Tanks - FR CT program conforms to the reco mmended GALL AM P XI.M29, w ith the excep tion as des crib ed bel ow.A7.3.0.3.2.3.3 Exce ption s to th e GALL Repor t The applican t stated, in the OCGS LRA, that the excepti on to the GALL Report program elements are a s follows:
Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken.
The sit e corre ctiv e acti ons pr ogram, qua lity assura nce (QA) proce dures, site review and approval process, and administrative controls are implement ed in accordance w ith 10 CFR Part 50, Appe ndix B. The staff finds the requirements o f 10 CFR Part 50, Appendi x B, accep table to add ress the correcti ve action s, confirmation proces s, and admini strative con trols.The applican t stated that in their respons e to RAI 2.5.1.1 9-1 that the Forked River Co mbustion Turbines and s upporting syste ms are non-safety-rel ated and are not subject to 10 CFR Part 50 Appen dix B requi rements in th e curre nt li censi ng basi s (CLB). Amer Gen has elec ted no t to include thi s program under Oys ter Creek 10 CFR Part 50 Appe ndix B Program. Instead, proces ses an d proc edures wil l be e stabl ished to ass ure tha t cond ition s adv erse to quali ty are promptly identified and correct ed. Identified conditions that do not satisfy acceptance criter ia will be documented, e valuated, and corrected a s required to mai ntain the i ntended function of combustion turbi nes during the period of exte nded operatio
: n. In the case of significant conditions adverse to qua lity, the procedures w ill require that the cause of the conditio n be 577 determined, acti ons to preclu de repetition be taken, and th e condition be reported to the approp riate leve l of man agement.The confirmation proc ess for the Forked Ri ver Combusti on Turbine w ill focus on follow-up actions that mus t be taken to v erify effective i mplementation o f corrective acti ons and precl ude repetition of si gnificant conditi ons adverse to quality.
The establis hed process a nd procedures will include the requirements that mea sures be taken to preclude repe tition of significa nt conditio ns advers e to qua lity. The se meas ures will inclu de action s to verif y effe ctive implementation of the proposed corrective a ctions, determin ation of root caus e, tracking open corrective a ctions to compl etion, and rev iews of correc tive acti on effectiveness.
In addition , the applican t state d that t he Fork ed River Com bustion Turbin e proced ures will inclu de admini strat ive controls that p rovide for formal re view and approv al of aging management activiti es.The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.3.4 Enhan cements None.A7.3.0.3.2.3.5 Operating Expe rience The applican t stated in the ir response to NRC RAI 2
.5.1.19-1 that pai nting has prov ided adequate protectio n to the ex ternal surfaces of outd oor steel tanks, su ch that loss of material due to exte rnal corrosio n has not bee n a concern.
Some coating degrad ation has be en observed, an d the resulti ng exposed s teel surfaces hav e experie nced minor surface rusting that does not impa ct the tank intend ed function. Impl ementation of this new program, pri or to the period of exte nded operatio n, will result in specific eva luations of an y identi fied coating degrada tion, incl uding an ass essmen t on th e pote ntial impac t on th e tank i ntende d functi on. These periodi c inspectio ns of tank coatings prov ide assuranc e that the in tended functions will be maintained.
A certified tank i nspection co mpany insp ected the main fuel oil tank on October 30, 2000. The ins pect ion inc lud ed u ltra soni c tes ting (UT) of th e flo or, s hel l an d roo f, Ma gneti c Fl ux L eaka ge (MFL) testi ng of the floor wi th UT prove-up , level surveyi ng of the foundation se ttlement and a thorough visu al inspecti on of the entire tank structure.
The res ults o f the M FL/UT i nspect ion to detec t floor unders ide c orrosi on in dicat e that some isolated un derside corrosi on is occurri ng. A total of ei ght MFL in dications w ere found and eval uated, wit h the d eepes t unde rside corros ion p it meas uring 0.185" r emaini ng floor thickne ss. An analy sis of corrosion rates since initial tank installati on determined that a minimum 0
.230"remain ing fl oor thic kness was requir ed in order to cert ify the t ank as ac ceptab le until th e next 20-year in ternal inspe ction. Four l ocations w ere identified below the required 0.23 0" thickness, and these lo cations w ere subsequently repaired w ith seal w elded patch plates.Visual i nspection of the floor internal surface reveale d 15 pits, w ith the deep est pit measuri ng 0.060" deep mea sured with a pit gauge. These pits we re subsequently weld re paired.
578 Ultras onic inspe ction s at a number of loca tions on the shel l and roof, co upled wit h a co mplete visual inspection of these areas, sho wed no s igns of significant co rrosion probl ems or structural deficiencies.
There were n o signs of servi ce induced weld fail ures or leakage.
Early si gns of paint failure were noted on the tank roof ex terior surface.
The le vel surve y in dicat ed tha t the ta nk founda tion i s lev el w ithin 1/4".The main fuel oi l tank was found to be general ly in goo d condition. With the repair of the identified floor corr osion, it was the professional opinion of the inspection f irm that the tank is suita ble for the st orage o f number 2 fuel oil fo r a per iod o f time no t to ex ceed 2 0 yea rs befor e the next in ternal in spectio n will be necess ary.Unit 2 began a major outage ins pection in October 2005. D uring the outage, w ith many components dis assembled, compo nents were visuall y inspecte d for signs of age relate d degradation. The e xternal surfaces of the closed cooling w ater system hea d tanks located at the closed c ooling wa ter mechanical draft cooling tow ers, and the di esel starter jacket w ater (close d cool ing w ater) h ead ta nks loc ated o n the r oof of the combus tion t urbin e aux ilia ry enclosure, w ere visua lly in spected and d id not show signs of significant paint degradati on or metal corrosion. The main fuel o il storage tanks w ere walked down, in cluding ascen ding the tank stairs up the side of the tan k to the tank roof. The tank w alls did not show signs of significant pai nt degradation o r metal corrosio
: n. The tank roof wa s observed to have ea rly signs of coating failure, as was noted in the tank i nspection rep ort discussed above. The u nderlyin g metal show ed minor surface ru st. This condi tion does no t threaten the stru ctural integrity of the roof and continue s to be monito red by routi ne site in spection.The operating ex perience w ith the abov eground steel tan ks at the Forked Ri ver Combusti on Turbine pow er plant prov ides objecti ve evi dence that ex isting envi ronmental condi tions are not causing significa nt material de gradation that cou ld result i n a loss of comp onent intende d functions. Recen t external inspections confirm that the ex terior paint has prevente d significant material degradati on. Internal i nspections o f the main fuel oi l storage tank confirms tha t corrosion of the ta nk bottom is occurri ng at a rate that ca n be managed by the recommended future periodic inspections. Implementation of this new program wil l assure that the painted external ta nk surfaces are insp ected at leas t once eve ry two y ears, and that i nternal insp ection of the main fuel oi l storage tank w ill be p erformed at least on ce every 20 years, providin g reasonable a ssurance that the aging effects will be adequately managed for the peri od of extended o peration.The project team rev iewed th e operating ex perience prov ided in th e basis doc ument, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Aboveground Steel Tanks pr ogram w ill adequa tely manage the agi ng effects that ar e ide ntifie d in t he OCGS LRA for whi ch this AM P is credi ted.A7.3.0.3.2.3.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Aboveground Steel Tanks - FRCT in their response to NR C RAI 2.5.1.19-1 , which stated that the A boveground S teel Tanks - FRC T aging 579 management program is a new program that will manage corrosion of aboveground ou tdoor steel tanks. Paint coating is a corrosion preventive measure, and periodic visual inspections will monitor degradatio n of the paint c oating and any resulting metal degradation of tank ex ternal surfaces. The abov eground tanks exte rnal surfaces w ill be v isually inspected for co ating degradation by walkdown at least once every two years. The main fuel oil storage tank is supported on a concrete foundati on. This tank doe s not have caulking or sea ling around th e tank foun datio n inte rface. A ll ot her in-scope outdo or tanks are su pporte d by structu ral st eel. Therefore , insp ectio n of sea lant o r caul king at t he tan k-foundat ion i nterface does not ap ply to the Ab ovegro und St eel Ta nks - FR CT agin g manageme nt progr am.The main fuel oi l tank bottom is in contact w ith concrete a nd soil, a nd is ina ccessible for visual inspection.
Therefore, the program incl udes periodi c non-destructiv e wall thickness exami natio ns of the main fu el oi l tank b ottom to veri fy that signi ficant c orrosi on is not oc currin g. This program, inclu ding the ini tial tank ex ternal pain t inspection s, will be implemen ted prior to the period of exte nded operatio
: n. The recommended UT inspection of the main fuel o il tank bottom was p erformed in Octo ber 20 00, so it is not ne cessar y to p erform thi s insp ectio n agai n prio r to entering the peri od of extended operation.
Based on the results of the Octob er 2000 inspections , and subsequent repairs to the tank floor, the tank w as certified to b e suitable for the storage of number 2 fuel oil for a peri od of time not to e xceed 20 years from October 20 00, before the next internal i nspection w ould be ne cessary. Therefore, a dditional UT inspectio ns of the tank floor are no t necessary prior to enteri ng the period o f extended ope ration and w ill be performed prior to Octob er 2020.The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 53 of the commi tments.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Aboveground Steel Tanks - FR CT program wil l adequately manage the aging effects that a re identified in the OCGS LRA for wh ich this A MP is credited.The project team rev iewed th e UFSAR S upplement, found th at it was consistent w ith the GALL Report, and de termined that i t provides an adequate summary description of the program, as ident ified in the SRP-L R UFS AR Su ppleme nt tabl e and as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.3.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exception and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio n, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.4 Fuel Oil Chemistry - FRCT (AMP B.1.22A)
In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , Appendix D of the Enclosur e, Secti on B.1.2 2A, the a pplicant stated that FRCT AMP B.1.22A , "Fuel O il Chemist ry -
580 FRCT," is a n ew p lant p rogram th at is consi stent w ith GA LL AM P XI.M 30, "Fu el Oil Chemi stry," with ex ceptions.A7.3.0.3.2.4.1 Program Descriptio n In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that the fuel oi l chemistry-FRCT aging management pro gram is a new program that provi des assurance that c ontaminants are maintained a t acceptable levels in new and stored fuel oil for systems and c omponents wi thin the scop e of license renewal. The fuel oil s torage tank wil l be maintained b y monitorin g and controll ing fuel oil contaminants i n accordance with the guidelines of the American Society for Testing Materials (ASTM). Fuel oil sampling activities will be in accordance w ith ASTM D 4057 for multi level a nd tank bottom sampl ing. Fuel oi l wil l be periodical ly sample d and anal yzed for parti culate contami nation in accordance w ith modified ASTM Stand ard D 2276 M ethod A, or AS TM Standard D 6217, and for the presence of w ater and sediment in accordanc e with A STM Standard D 2709 or A STM Standard D 1796. The fuel oil storage tan k will b e periodica lly drai ned of accumulated water and sediment, and will be periodical ly drain ed, cleaned, and internal ly insp ected. These acti vities e ffectively mana ge the effects of a ging by prov idin g reason able assura nce th at pote ntial ly h armful c ontami nants are maintained a t low co ncentrations.
A7.3.0.3.2.4.2 Consi stency wit h the GA LL Rep ort In the supplemental response to NRC RAI 2.5.
1.19-1, the applicant stated that FRCT AMP B.1.2 2A is consi stent with GALL AMP XI.M30, w ith excep tions.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for FRCT AMP B.1.22A, incl uding the pro gram bas is do cument, PBD-A MP-B.1.22A , ?Fuel Oil C hemist ry - F RCT,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M30. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in FRC T AMP B.1.2 2A to determine their consi stency with GALL AMP XI.M 30.In review ing this AM P, the project tea m noted that the
?detection of aging effects" program element descri ption for AM P B.1.22A state d that based o n the results of the October 2000 inspections and repairs, the Forked Riv er fuel oil s torage tank was ce rtified to be su itable for the storage of number 2 fuel oil for a peri od of time not to e xceed 20 years from October 20 00, before t he nex t inte rnal i nspect ion w ould be nec essary. The p roject t eam aske d the a ppli cant to provide the technical basis for establishing t he 20-year inspection interval.
In its response , the appli cant stated that th e Forked Riv er fuel oil ta nk was insp ected, repaired with a mater ial a llow ance for corros ion, a nd cer tified for an a dditi onal 20 ye ars of se rvic e before requiring internal re-inspectio
: n. The out-of-servi ce inspecti on was co nsistent w ith the requirements of API-653 and NJAC 7:1E-2.2(a)4. The c ertification requi res inservi ce inspe ction s cond ucted at 5 y ear in terva ls, al ong wi th ope ration and ma inten ance c onsis tent w ith industry sta ndards.The project team rev iewed th e applica nt's response, as well as TAQ Inc. Tank certificati on dated October 30, 2000 for the FRCT fuel oi l storage tank. The ce rtification in cluded an out-of-service inspection report, whic h showed that the FRCT fuel oil storage tan k was in gene rally good 581 conditio n. To ma intain th e certif ication f or 20 years , inservic e inspect ions are r equire d every 5 yea rs, w hic h in clu de th e fol low ing:*Visual i nspection of roof and supports,*External v isual in spection for pai nt failures, pi tting, and corrosi on,*Visual i nspection of the floating roof for grooving, corro sion, pittin g, and coating fail ures,*Inspection of man-w ays and n ozzles , and*Insp ecti on o f pip ing m ani fold s for lea ks or dama ge The certification also noted th at the tank wa s constructed i n 1989. The pro ject team determined that the inserv ice inspec tions, together w ith the peri odic draini ng of water and s ediment from the tank would provide a n acceptable means of controll ing corrosion of the tank. In addi tion, the certification was in accordance with accepted industr y standards, including API-653 and NJAC 7:1E-2.2(a)4. On th is basis, th e project team dete rmined that the 20 year i nterval for in ternal inspections was acce ptable.The project team rev iewed th ose portions of the FRCT fuel oi l chemistry program for which the appli cant cl aimed consi stency wit h GALL AMP XI.M3 0 and found th at they are co nsiste nt wi th the GAL L Repo rt AM P. The project team fou nd tha t the a ppli cant's FRC T fuel oi l che mistry program conforms to the recommen ded GALL AM P XI.M30,"Fuel Oil Chemis try," with the excep tion s des crib ed bel ow.A7.3.0.3.2.4.3 Exce ption s to th e GALL Repor t In the supple mental response to NRC RA I 2.5.1.19-1, the a pplicant sta ted the follow ing exceptions to the GALL R eport program elements
: Exception 1: Elements: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects Exception: Preventiv e Actions (E lement 2), Paramete rs Monito red or Inspected (Ele ment 3), and Dete ction of Aging Effects (Ele ment 4)require that fuel oi l tanks be peri odically sampled, drai ned of accumulated water and sediment, cleaned, and internally inspected. M ultilev el samplin g and tank bottom sampl ing of the die sel star ter e ngin es fu el o il t anks is n ot pe rforme d. Th ese tanks are supplie d directly from the Fuel Oil Storage Tank, whi ch wil l be periodical ly sample d and anal yzed. The diesel sta rter engines fuel oil tanks are small in s ize and experience a high turnov er rate of the fuel stored wit hin a s a res ult of r outin e engi ne ope ration s. Stratification o f fuel is not li kely to occur due to the hi gh turnover rate. Additionally, the diesel starter engines f uel oil tanks are skid mounted and en closed w ithin the co mbustion turbin e accessories compart ment, w hich is mai ntain ed at a consta nt tempe rature durin g cold perio ds thro ugh ope ration of encl osure heater s. Maintai ning temperature du ring cold peri ods minimiz es thermal cycling and reduces the potential for condensation format ion within the tanks. The peri odic draini ng of water and s ediment from the 582 bottom of the diese l starter engine s fuel oil ta nks is therefore not required and the cleaning an d internal inspection of the diesel starter engines fuel oil tanks is not necessary to verify degradation is no t occur ring du e to th e accu mulati on of pa rticul ate contamination and water and sediment The GALL Report i dentifies the foll owing recommend ations for the
?preve ntiv e acti ons,"?parameters monitored or inspected
," and ?detect ion o f aging effec ts" pro gram ele ments associated w ith the ex ception taken:
: 2. Preventive A ctions: The qual ity o f fuel oi l is mainta ined by ad ditio ns of bi ocide s to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibito rs to mitigate corros ion. Perio dic cleani ng of a tank allow s removal of sediments, and p eriodic drai ning of water co llected at th e bottom of a tank mini mizes the amo unt of w ater an d the l ength o f contac t time. Accor dingl y, the se meas ures a re effective in miti gating corrosion i nside die sel fuel oil tanks. Coatings, i f used, prevent or mitigate corrosion by protecti ng the internal surfaces of the tank from contact with w ater and microbio logical organi sms.3. Parameters Moni tored or Inspected
: The AMP monitors fuel oil quality and the levels of water and mi crobiological organisms in th e fuel oil, w hich cause the loss of materi al of the tank internal surf aces. The ASTM Standard D 4057 is used for gu idance on oil sampling. The AS TM Standards D 1796 and D 2709 are u sed for determinati on of water and sediment contamination in diesel fuel. For determi nation of particu lates, modified ASTM D 227 6, Me thod A , is u sed. Th e modi ficatio n cons ists o f using a filter wit h a po re size of 3.0 mm, i nstead of 0.8 mm. These are the princi pal parameters re levant to tank struc tural int egrit y.4. Detection of Aging Effects:
Degradation of the diesel fuel oil tank can not occur w ithout exposure of the tank internal surfaces to contamin ants in the fuel oil, such as water an d microbiologic al organisms. C ompliance w ith diesel fuel oil sta ndards in i tem 3, above, and periodi c multilev el samplin g provide as surance that fuel oil contami nants are bel ow unacceptable levels. Internal surfac es of tanks that are drained for cleaning are visually inspected to detect potential deg radation. However, corrosion may occur at locations in which co ntaminants may accumulate, su ch as a tank botto m, and an ultra sonic thickness measurement of the tank bo ttom surface ensures tha t significant degrada tion is no t occu rrin g.As part of the justi fication for this e xception, th e project team note d that the FRC T license renewal document stated th at the diesel starter engines' fuel oil tan ks are small i n size a nd experience a high turnov er rate of the fuel sto red withi n as a resul t of routine engine operations, and that stratifica tion of the fuel i s not likely to occur due to this high tu rnover rate.
The applicant w as asked to prov ide additi onal information as to a) w hether the tanks ha ve the capabili ty to be i nspected, b) w hat the day tank fuel turnove r rate is, and the basis for con cluding that stratification would not occur, and c) the operatin g experience with w ater and sedi ment bui ldu p in the FRC T fuel stor age t ank.In i ts re spon se, t he a ppl ica nt st ated that the die sel star ter e ngin es' fuel oil tank s are smal l ta nks built into each of the combu stion turbine accessory skids. These tanks do not have the capab ilit y for mu ltil evel or tan k bottom sampli ng wi thout d isass embli ng tank p ipin g conne ction s. In addition , the FRCT uni ts are commercial ly operate d units that a re used to sup ply peak po wer 583 to the grid. As such, they a re frequently started and stopped, requiring frequent starting an d running of the starti ng diesel en gine. The diese l engine runs for approximatel y 20 minute s each time the associ ated turbine i s started. The tank l evel is checked regularl y during ope rator roun ds, a nd th e tan ks ar e fil led manu all y fro m the turb ine oil hea der, wh en re quir ed. The t anks requi re fi lli ng ap prox imat ely onc e ev ery mont h on ave rage; more frequ entl y du ring high usa ge months and le ss frequently duri ng low usa ge months dependi ng on seasonal grid load. S ince the diesel engines are rou tinely o perated, the fuel tanks are regularly drawn do wn and periodically refilled precluding fuel strat ification. The enclosure where the tank is located is maintained a t a constant tempe rature during col d periods by operation o f enclosure heate rs.The applican t also stated that the fuel oi l storage tank that su pplies the diesel en gine starter fuel tanks was drai ned and an internal i nspection w as performed in Octob er 2000. No evidence of water accumul ation wa s found in the tank. The tank floor incl udes a sump pi t designed to co llect any wa ter. The sump pit was found to be in good co ndition, w ith no vi sible corros ion, indi cating that the tank has n ot experie nced significan t water accu mulation or s ediment buil dup. Over the entire surface of the flo or, 15 corrosio n pits w ere found, wi th the deepest pit measuring 0.0 60" deep, as measure d with a pit gauge. These p its were s ubsequently weld rep aired. In ad dition, the tank design includes a f loating roof that precludes atmospheric moistu re intrusion into the oil.
Water was never drain ed from the tank bottom pri or to the tank in spection. Si nce the intern al inspection did not rev eal significan t water accu mulation, there is no nee d to periodi cally d rain the tank bot tom.The applican t also stated in its respo nse that one-ti me inspection s will be performed on a number of compone nts in the fuel oil supply system, to confirm the effectiveness of the Fuel Oil Chemistry - FRCT aging manag ement program. An effective fuel oil chemistr y program will preclude aging degr adation of the diesel engine supply tanks without the need t o disassemble and i nspect the ta nks. If th e resu lts of o ne-tim e ins pecti ons i ndica te that fuel o il ch emistry controls hav e been ine ffective, correctiv e actions w ill be i mplemented, inc luding ev aluation and/or inspec tion of additi onal syste m components poten tially affected, including th e diesel fuel tanks.The project team rev iewed th e applica nt's response and determined that the turnov er rate for the FRCT diesel starter engine tank s is reasonable, and will prevent stratification of the fuel stored in these tanks. Furthe r, the enclose d location of the FRCT diese l starter engine tanks together with the use of the enclo sure heaters to minimize thermal cycl ing of these tanks w ill reduc e the potential for con densation forming i nside the tan ks. Based on the operating ex perience w ith the FRCT fue l oil storage tank, mo isture intru sion has no t been a prob lem. If c orrosi on due to moistu re int rusio n we re to o ccur, th e one-time i nspect ions of the F RCT sy stem co mponen ts would p rovide ad equate detection in a timely manner. On this basis, the p roject team determined that this excep tion is acc eptable.Exception 2 Elements: 1. Scope of Program
: 5. Monito ring and Trendin g Exception: The Program Descripti on, Scope of Program (E lement 1), and Monitori ng and Trending (El ement 5) refer to pla nt technical specifications related to fuel oil quali ty. There are no plant technical s pecifications at the Forked Ri ver Combusti on Turbine powe r plan t.
584 The GALL Report i dentifies the foll owing recommend ations for the
?scope of program," and
?monitoring and tre nding" program elemen ts associated with the exception taken: 1. Scope of Pro gram: The program is focused on managing the con ditions that cause general, pittin g, and microbiol ogically influenced (M IC) of the diesel fuel tank internal surfaces in accord ance wi th the plant' s technical specification s ( i.e., NUR EG- 1430, NUREG-1431, N UREG-1432, NU REG-1433) on fuel oil puri ty and the guidelines of ASTM Stand ards D 1796, D2276 , D270 9, D62 17, an d D405 7. The program s erves to reduce the po tentia l of ex posure of the t ank int ernal surface to fuel oil contami nated with water and microbiologic al organisms.
: 5. Monitoring and Trendin g: Water and biological ac tivity or particulate contamination concentrations are monitored a nd trended i n accordance with the plant's tech nical specifications or at least q uarterly. Based on industry operating experience, q uarterly sampli ng and analy sis of fu el oi l prov ides for timel y det ectio n of con ditio ns con duciv e to corros ion o f the in ternal surface of the d iesel fuel o il ta nk before the po tentia l los s of its intended functio n.As discussed above, the project team asked th e applica nt to provi de additio nal information on the specificati ons that wo uld be use d to determine if the fuel oil sampling resul ts are acceptabl e.In its response, the applicant stat ed that water and sediment concentrat ions are tested in accordance w ith ASTM Standards D 1 796 or D 270
: 9. Particul ate contaminati on is determi ned by th e use of modifi ed AS TM Sta ndard D 2276 , method A, or A STM S tandar d D 62 17. Acceptance cri teria are per ASTM D 97 5. Use of ASTM D 975 is consistent w ith General Ele ctri c sp eci fica tion GEI-4104 7H fo r the FRC T.The project team rev iewed th e applica nts response an d determined th at the specifica tions to be used to establ ish acceptan ce criteria for the fuel oil sa mples are base d on ASTM Standard D 975, with is consis tent with General Elec tric specificati on GEI-41047H for the FRCT, as w ell as the specificati ons referenced in Regulatory Guide 1.137.
On this basis , the project team determined that this excep tion is acc eptable.Exception 3 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
585 The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.4.4 Enhan cements None.A7.3.0.3.2.4.5 Operating Expe rience In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , Section B.1
.22A, the applicant s tated that fuel oi l chemistry activiti es have b een proven to be effective i n managing the agi ng effects associ ated w ith fue l oil syste ms so th at the inten ded fun ction s of comp onents with in the scope of lic ense r enew al w ill be mai ntain ed dur ing the perio d of ex tended opera tion. On October 30, 2000, t o satisfy the recommend ations of the American Petr oleum Institute's (API's) Standa rd No. 653 en titled ?Tank Insp ectio n, Rep air, A lterat ion, a nd Rec onstru ction ,"TAQ, Inc. performed an
?out-of-service" i nspection of the Forked Rive r Combustion Turbi ne fuel oil storage tan
: k. The inspectio n include d ultrasonic testing (UT) and v isual (VT) i nspection of the flo or. The insp ectio n wa s perfor med by an AP I-653 C ertifie d Tank In specto r after 1 0 yea rs of service (da te of original tan k's construction was 1989).
The followi ng summary is pro vided concerning tank floor inspections
: VT inspectio n of the floor rev ealed 15 ?produc t side" pits wit h the de epest pit mea surin g 0.060" deep (measu red by pit ga uge). Th e pitt ing w as we ld rep aired. The floor is equip ped with a 24" sump se rviced by a 4" wate r draw-off line. The re was no topside corrosion note d on the sumps floor and wa lls and U T inspection to detect undersi de corrosion revealed no appreciab le corrosion
.Based on the above findi ngs, it was the professional opinion of the qualified i nspector that the Forked Rive r fuel oil sto rage tank will be suitabl e for the storage of No. 2 fuel oil for a period of time not to ex ceed 20 y ears befo re th e ne xt i nter nal ins pect ion. In Octo ber 2 001 (Uni t 2 F RCT)and March 2004 (Unit 1 FRCT), GE Energy Services performed major inspe ction and mainte nance activ ities , and d ocumen ted al l wo rk performe d in i nspect ion re ports d ated J anuary 4, 200 2, and June 7, 200 4, resp ectiv ely. The equ ipment insp ectio ns in clude d the t urbin e and its internals an d support equip ment. All w ork was carrie d out closel y follow ing the instructi ons and guidance found i n the original equipment manufacturer' s design, mainte nance and i nspection manuals. Acceptance criteria and cor rective actions for these act ivities ensure that equipment is maintained w ithin desi gn specifications
.The project team rev iewed th e operating ex perience prov ided for the FR CT fuel oil sy stem, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e, and discu ssion s wi th the ap plic ant's t echni cal st aff, the pr oject te am dete rmined that th e appl icant's fuel oil chemis try program - FRCT will adequately manage t he aging eff ects that are identified in the FRCT AMRs for which thi s AMP i s credited.
586 A7.3.0.3.2.4.6 UFSAR Sup plement The applican t provided its UFSAR Supplement for the Fuel Oil Chemistry -
FRCT aging management pr ogram in the November 11, 2005, supp lemental response to NRC RAI 2.5.1.19-1, Appen dix D, S ection A.1.22A , which states that the fuel oil chemi stry-FRCT aging manageme nt progr am is a new program that pr ovid es ass urance that c ontami nants are maintained at acceptable levels in new and stored fuel oil for systems and com ponents within the scope of Lic ense Renew al. The fuel oi l storage tank w ill be mai ntained by monitoring and controlling fuel oil conta minants in a ccordance w ith the guidel ines of the Ameri can Society for Testing Materia ls (ASTM).
Fuel oil sampling acti vities w ill be i n accordance with AS TM D 4057 for multileve l and tank botto m sampling. Fue l oil w ill be p eriodicall y sampled and analy zed for particulate c ontamination in accordanc e with mod ified ASTM Standard D 22 76, method A, or ASTM Sta ndar d D 6 217, and for th e pre senc e of w ater and sed imen t in acc orda nce wi th A STM Standard D 2709 or ASTM Standard D 1796. The fuel oil storag e tank will be periodically drained of accumu lated wa ter and sedime nt, and wi ll be peri odically drained, cl eaned, and internally inspected.
These activi ties effectively manage the effects of aging by providi ng reasonable a ssurance that po tentially harmful contaminan ts are maintai ned at low concentrations.
This new program will be implemen ted prior to e ntering the peri od of extended operation.
The applican t further stated in i ts UFSAR su pplement for AM P B.1.22A that the internal inspe ction of the ma in fuel oil tank w as per formed i n Octob er 200 0, so i t is n ot nec essary to perform this inspec tion again pri or to entering the period of ex tended operati on. Based o n the results of the Octobe r 2000 inspe ctions and re pairs, the tank w as certified to b e suitable for the storage of number 2 fuel oil for a peri od of time not to e xceed 20 years from October 20 00, before the next internal i nspection w ould be ne cessary. Therefore, a dditional internal inspections of the tank floor are no t necessary prior to enteri ng the period o f extended ope ration and wil l be performed pri or to October 2020
.The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 54 of the commi tments.The project team rev iewed th e UFSAR S upplement for FRC T AMP B.1.2 2A, found that it was consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.4.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eptions and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).
587 A7.3.0.3.2.5 One-Time Inspec tion - FRCT (B.1.24A)
In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , Appendix D, Section B.1.24A, the ap plicant state d that FRCT AM P B.1.24A, "One-Time Inspection -
FRCT," is a ne w plant program that w ill be con sisten t wi th GALL AMP XI.M3 2, "One-Time Ins pecti on." A7.3.0.3.2.5.1 Program Descriptio n In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that the one-time inspection-FRCT aging manag ement program is a new program that will provi de rea sonab le as suranc e that the lo ss of mat erial and l oss of h eat tra nsfer agi ng effects are not occurring, or that the aging ef fects are occurr ing slowly enough to not affect t he fuel oil and lubrica ting oil sy stem components i ntended functions during the peri od of extended operation, and therefore wil l not require a dditional aging management. The pro gram is credited for components in fuel oil and lubricatin g oil env ironments w here either (a) an aging effect is not expected to occur but there is insuff icient data to completely rule it out, (b) an aging effect is expected to progress very slowl y in the specified env ironment, but the local env ironment may b e more adverse than that general ly exp ected, or (c) the characteristics of the aging effect includ e a long incubati on period.
The applican t further stated that the One-Time Inspectio n - FRCT w ill be u sed only to provid e assurance that loss of m aterial and loss of heat transf er for component s subject to FRCT fue l oil and l ubric ating o il en viro nments are no t occur ring, o r that t he agi ng effects are in signifi cant. It will not be used to confirm that aging is not occur ring or insignificant in other FRCT environments
.The applican t further stated that the One-Time Inspectio n - FRCT w ill be u sed to veri fy that the fuel oil and lubricatin g oil syste ms activiti es are effective i n preventi ng or minimiz ing aging to the exten t that i t wi ll no t cause the l oss of i ntende d functi on dur ing the perio d of ex tended opera tion. The pro gram wi ll re quire i nspect ion a t loca tions of low or sta gnant flo w, w hich are su scepti ble to water pool ing and gradual accumulation or concentrati on of agents that promote loss of material and loss of he at transfer. The program w ill prov ide inspe ctions that ei ther verify th at unacceptable loss of material or loss of hea t transfer are not occu rring, or initi ate additio nal actions that w ill assure the intende d function of affected compone nts wil l be maintai ned during the period o f extended ope ration. The new program elements i nclude (a) de termination of the sample siz e based on an assessment of materi als of fabrication , environmen t, plausibl e aging effects, and operating ex perience; (b) i dentification of the inspectio n locations in the sy stem or component based on the aging effect; (c) dete rmination of the e xamination technique, in cluding acceptance cri teria that w ould be effectiv e in managing the aging effect for which th e component is examin ed; and (d) ev aluation o f the need for follow-up examina tions to moni tor the progression of aging i f age related degradati on is found tha t could jeopa rdize an intended function before the e nd of the period of extended o peration. When eviden ce of an aging effect is rev ealed by a one-ti me ins pecti on, an eval uatio n of the insp ectio n resu lts w ill be per form to identify app ropriate correcti ve action s.The applican t further stated that the inspection sample inc ludes ?worse case" one-ti me inspe ction of more s uscept ible materi als i n the fu el oi l and the l ubric ating o il en viro nments (e.g., low or s tagnant flow area s) to manage the effects of aging. E xamination methods wi ll incl ude vis ual exa mina tion and/or v olu metri c ex amin atio ns. Acce ptan ce c rite ria are b ased on t he d esi gn codes and standards for the Forked River combustion turbines and m anufacturer
's 588 recommendations.
The one-time ins pection-FRCT a ging management program wi ll be implemented pri or to the peri od of extended operation.
A7.3.0.3.2.5.2 Consi stency wit h the GA LL Rep ort In th e sup plem enta l resp onse to NRC RAI 2.5.1.19-1 , the appli cant stat ed th at FR CT AMP B.1.24A is c onsistent w ith GALL AM P XI.M32, w ith excep tions.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for FRCT AMP B.1.24A, incl uding the pro gram bas is do cument, PBD-A MP-B.1.24A , ?One-Time Inspe ction - FRC T", Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M32. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this a udit a nd rev iew report) conta ined in FR CT AM P B.1.24A an d asso ciate d base s docu ments to determine the ir consisten cy wi th GALL AM P XI.M32.In review ing this AM P, the project tea m noted in the FRCT licen se renewal document program description for AMP B.1.24 A that the desc ription of the
?parameters monitored or inspected "AMP el ement stated that i nspection metho ds consist of no ndestructive examinati on, includi ng visual, volumetric, and surface techni ques. Since F RCT AMP B.1.24A is n ot based on th e requirements of the AS ME Code , as stated in the first excep tion for this AM P, the appli cant was to describe th e rational to be used i n selecting the inspection method for the va rious types of components in the scope of t his AMP.In its respo nse, th e appl icant stated that th is agi ng manage ment pr ogram pe rforms on e-time inspections to confirm the effectiveness of the Fuel Oil Chemistry - FRCT and Lubricating Oil Analysi s - FRCT programs. The inspection methods selec ted wil l depend o n the component type, inten ded function, materi al and aging e ffect. Heat transfer surfaces of compone nts with a heat transfer intend ed function w ill be i nspected usi ng visual inspection to identify foul ing or other surface degradati on that could impair the h eat transfer function. Thi s same visu al inspection also assures that the pressure boundary i ntended function is maintain ed. The stainless ste el filter ele ment with a filter intende d function w ill als o be inspe cted using v isual techniques to i dentify accumul ations of dirt o r sediment, or de gradation of the filter element that could impai r or reduce the effectiveness of the fil ter intended functi on. Simil arly, restric ting orifices will be inspected using visual techniques to identify degr adation of the orifice t hat could impair or redu ce the effectivene ss of the throttle i ntended function.
This same vi sual inspe ction also assures that the pressure boundary i ntended function is maintain ed.The applican t further stated that remai ning mechanica l components i n the scope o f this program have a pres sure b ounda ry in tended functio n and are su bject to loss of materi al agi ng effect.
Mech anica l comp onents wil l be i nspect ed usi ng vi sual or ult rasoni c techn iques i n orde r to determine the e xtent of loss of material by evaluati ng the extent o f loss of wall thickness. The technique sele cted wil l depend o n the component type, and w hether the ins pection inv olves disassembly or is performed w ithout disas sembly. Fo r combustion turb ine componen ts, the most appropriate technique w ill be d etermined based on manufacturer's e xperience and recommendations for the component. Pi ping can be i nspected for wa ll thickness using ultrasonic te chniques. Vi sual inspe ction techni ques are appropri ate for pump casin gs, strainer bodies, filter housings, and v alve bod ies whe n disassembl ed during main tenance activ ities. The abov e desc ribed compon ent in specti ons w ill confirm the effect iven ess of th e Fuel Oil C hemist ry- FRCT and Lu bricating Oil Analysi s - FRCT aging mana gement programs.
589 The project team reviewed the applicant's response, which provides the rational to be used in selecting the a ppropriate i nspection tech nique. Heat tran sfer surfaces of components w ith a heat transfer intend ed function w ill be i nspected usi ng visual inspection to identify foul ing or other surface degradati on that could impair the h eat transfer function. V isual in spection w ill als o be used to as sure that the pre ssure boundary intended functi on is mainta ined. The stai nless steel filter eleme nt wi th a fil ter in tended functio n wi ll al so be inspe cted u sing v isual techn iques t o identify acc umulations o f dirt or sediment, or degradation o f the filter element that could i mpair or reduce the effective ness of the filter i ntended function.
Similarl y, restrictin g orifices wi ll be inspected us ing visual techniques to i dentify degradati on of the orifice th at could i mpair or reduce the effective ness of the throttle intended functi on. The remaini ng mechanical compon ents i n the s cope o f this p rogram ha ve a pressu re bou ndary inten ded fun ction and a re subject to loss of material aging effect. M echanical components w ill be i nspected usi ng visual or ultrasonic te chniques in order to determin e the exten t of loss of material by eva luating the ex tent of loss of wall thickness. Thes e inspection techniques are reasonab le for inspecting the f uel oil system and the lubricatin g oil syste m for the Forked Riv er combustion tu rbines and w ill prov ide reason able assura nce th at the aging effec ts for w hich this p rogram i s credi ted w ill be mana ged. On this basis , the project team d etermined that the applican t's rational for selecting in spection techniques w as acceptabl e.Upon further revi ew of this A MP, the pro ject team noted i n the FRCT li cense renew al document description for AMP B.1.24 A that the
?detection of aging effects" AMP element discusses sample selection; h owever, the rational for selecting the sa mple popula tion was not provid ed. The applicant w as asked to prov ide additi onal information on how the sample po pulation for the one-time insp ection wi ll be dete rmined.In its response , the appli cant stated that th e component sampl e inspectio n requirements for the Forked Rive r combustion turb ine componen ts will be determined based on a n evalua tion of operating exp erience w ith these uni ts and simil ar General El ectric combustio n turbine un its that have been in s ervice f or many year
: s. The m anufa cturer and power ind ustry use rs have develope d maintenance and inspecti on plans d esigned to attai n high operati onal reli ability over time. The most appro priate sample size an d inspectio n locations will be determined based on this expe rience and ma nufacturer's recommenda tions. Sin ce a consid erable amount of operating exp erience is availab le for combustion turbines, the project team determin ed that the use of operating experience is an accept able means of assuring t hat an appropriate sample population will be obtained. On this basis, the project team deter mined that the applicant's response w as acceptabl e.The pro ject tea m revi ewed those porti ons of th e appl icant's One-Time In specti on Pro gram -FRCT for which the appli cant claims c onsistency with GALL AMP XI.M 32 and found tha t they are consistent with this GALL Report AMP. The project team found that the applicant
's One-Time Inspection
- FRCT program con forms to the recommended GALL AMP XI.M32,?One-Tim e Ins pect ion," with the ex cept ions desc ribe d belo w.A7.3.0.3.2.5.3 Exce ption s to th e GALL Repor t In the supple mental response to NRC RA I 2.5.1.19-1, the a pplicant sta ted the follow ing exce ption s to th e GALL Repor t progra m:
590 Exception 1 Elements: 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects Exception: Parameters Mo nitored or Insp ected (Element
: 3) and Detecti on of Aging Effects (Element 4) re quire that insp ections be p erformed by qualified person nel follow ing procedures c onsistent w ith the require ments o f ASME Code and 10 CFR P art 50, Appen dix B. The Forked River Combustion T urbine fuel oil and lubricating oil systems are no t designed to A SME require ments and are n ot safety-related. Thu s, ASME requirements are no t applicabl e and AmerGen has ele cted not to in clude the One-Time Inspection
-FRCT under 10 CFR Part 50 Appendix B requirements. P ersonnel qualified to i ndustry stand ards using appro ved procedu res consistent with the combustion turbine m anufacturer
's recomme ndati ons w ill perform th e ins pecti ons. Th e One-Ti me Inspec tion - FRCT w ill be con ducted under a sep arate qu ality assurance acti vity sp ecifically develop ed for Forked Riv er Combustion Turbi nes as disc ussed in the Corrective Actions, Confirmation Proc ess, and Admi nistrative Controls el ements.The GALL Report i dentifies the foll owing recommend ations for the
?parameters monitored
/inspected" an d ?detection of aging effects program e lements associ ated with the excep tion taken: 3. Parameters Moni tored or Inspected
: The program monitors p arameters directl y related to the degradatio n of a component. In spection is to be performed by qualified perso nnel following p rocedures consi stent with the requirements of the ASME C ode and 10 CFR Part 50, Appen dix B, us ing a vari ety of NDE meth ods, includ ing visual , volumetric , and surface techniques.
: 4. Detect ion o f Agin g Effec ts: The inspectio n include s a representati ve sample of the syste m popul ation , and, wher e prac tical , focuse s on th e boun ding o r lead compon ents most susceptibl e to aging due to time in serv ice, severi ty of operating co nditions, an d lowest de sign margin. The program w ill rely on establi shed NDE te chniques, incl uding visual, ultrasonic, a nd surface techni ques that are performed b y qualified personnel following procedures consistent with the ASME Code and 10 CFR Part 50, Appendix B.
The inspection and test techniq ues will have a demonstrated history of eff ectiveness in detecting the agin g effect of concern.
The project team rev iewed th is excepti on and noted that the appl icant wi ll use pe rsonnel qualified to i ndustry stand ards using appro ved procedu res consistent with the combustion turbine manufacturer' s recommendations to perform the insp ections. The pro ject team determined that the use of personn el qualified to industry standards usin g approved pro cedures consi stent w ith th e combu stion turbi ne manu facturer's rec ommenda tions wil l prov ide a dequate assurance that th e inspectio ns wil l be performed by qualified perso nnel. On thi s basis, the project team determin ed that this e xception is acceptabl
: e.
591 Exception 2 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.5.4 Enhan cements None A7.3.0.3.2.5.5 Operating Expe rience In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that in October 2 001 (Unit 2 FRCT) and M arch 2004 (Un it 1 FRCT), GE E nergy Servi ces performed m ajor inspection and maintenance act ivities, and documented all work perform ed in inspection reports dated Ja nuary 4, 20 02, and June 7, 2004, respec tively. The equipment inspections included the turbine and its in ternals, and s upport equipment.
All wo rk was carried out closely followin g the instruction s and guidanc e found in the original equi pment manufacturer's desi gn, maintenance a nd inspecti on manuals.
Acceptance cri teria and corr ecti ve a ctio ns fo r the se a ctiv iti es e nsur e tha t equ ipme nt i s mai ntai ned wi thin des ign specifications
.The applicant furth er stated that the Unit 1 inspection was a major m aintenance inspection. This was t he first major i nspect ion th at wa s perfor med on the un it si nce i nitia l ins talla tion i n 1988. Durin g the Un it 1 i nspect ion, t he fuel forwar ding p umps an d emerge ncy D C lub e oil pumps were removed and sent to the Genera l Electric service s hop for cleani ng, inspection and repairs.
The GE report does n ot indicate any issue s associated with degrada tion of these pu mp casings. The combus tion t urbin e lub e oil syste m was drain ed, cl eaned and i nspect ed. Va rious pumps were inspected, an d the lube oil cool ers were cl eaned. No d egradation of these components w as ident ified. The mai n lub e oil pump w as di sassem bled and i nspect ed, an d no d efects w ere observed.
592 The applican t further stated that the Unit 2 i nspection w as a fuel noz zle and combustion secti on inspection.
The lube oi l filters w ere replaced.
The inspecti on includ ed a borescop e and combustion in spection, remov al of exhaus t frame cooling pi ping, and dis connection o f the fuel lines for ins pection, and fuel nozz le inspecti on, repair, and testing. The GE rep ort does not identify any issues w ith the disa ssembled fuel o il pipi ng. Unit 2 be gan a major outage in spection in Octo ber 20 05. Du ring th e outa ge, wi th many compon ents d isass embled , compo nents were visuall y inspecte d for signs of age relate d degradation.
The internal s urfaces of disassembl ed stainless ste el pipin g and flexibl e hoses w ere observed , and there w ere no signs o f corrosion or wall th inning. The comb ustion turbin e lube oi l heat ex changers were dissembled, c leaned and inspe cted. The car bon st eel a nd cop per al loy heat e xcha nger com ponen ts norma lly expo sed to lubricating o il were found to be in excell ent conditio
: n. The standby heat exch anger that is no t normally i n service was found to have some mi nor accumulati on of sediment tha t was cle aned off. Carb on ste el pu mp casi ngs that are no rmall y sub merged i n the l ubric ating o il re servo ir w ere visuall y observ ed to be in excell ent conditio n, with n o signs of corrosio
: n. The carbon s teel internal surfaces of the lubrica ting oil rese rvoir w ere also obs erved to be in exce llent condi tion, with no signs of corrosion.
The project team rev iewed th e operating ex perience prov ided for the FR CT to confirm that the plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e, and discu ssion s wi th the ap plic ant's t echni cal st aff, the pr oject te am dete rmined that th e appl icant's One-Time Inspection -
FRCT program wi ll adequatel y manage the a ging effects that are identi fied in the FRCT AMR s for which this AMP is credited
.A7.3.0.3.2.5.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e One-Time Inspect ion - FRCT program in the November 11, 2005, supp lemental resp onse to NRC RAI 2.5.1.19-1, Appendix D, Section A.1.24A, wh ich stated tha t the One-Time Inspec tion - FRC T aging management program is a new program that will provide a means of confirming the aging effects of loss of material and loss of heat trans fer are either not occurring or are p rogressing so slow ly as to not have a n effect on the intende d function of the co mbustion turbin e fuel oil and lubrica ting oil sy stem components w ithin the p eriod of exten ded operation. Addition ally, thi s program wil l address potentiall y long in cubation peri ods for loss of materi al and lo ss of heat transfer aging effects.
The applican t's UFSAR further stated that the One-Time Inspection
- FRCT program w ill prov ide measures to ve rify that an agi ng management program is no t needed, confirm th e effectiveness of existing acti vities, o r determine that degradation is occurring w hich wi ll require ev aluation a nd corrective a ction. The program w ill be i mplemented prio r to the perio d of extended operation.
The applican t's UFSAR further stated that in spection method s will include visual examinatio n or volumetric examinatio ns. Inspection s will be performed by qualified person nel using pro cedures deve loped consi stent w ith th e qual ity c lassi ficatio n of the Forked Riv er comb ustio n turbi nes. Acceptance cri teria wi ll be in accordance w ith design stan dards for the combusti on turbines a nd manufacturer's recommenda tions. The One-Time Inspection -
FRCT program provi des for the evaluation of the need for f ollow-up examinations to monitor the progres sion of aging if age-related degradati on is found tha t could jeopa rdize an intended functio n before the end of the period of exte nded operatio
: n. Should aging effects be detected, the program wil l initia te actions to characteriz e the nature an d extent of the aging effect and determine what subse quent 593 monitoring is n eeded to ensu re intended functions are mai ntained duri ng the period o f extended operation.
The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 55 of the commi tments.The project team rev iewed th e UFSAR S upplement for FRC T AMP B.1.2 4A, found that it was consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.5.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eptions and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption s, is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.6 Selective Leaching of Materials - FRCT (B.1.25A)
In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 20 05, Ap pendi x D, S ectio n B.1.2 5A, the appl icant stated that OC GS AM P B.1.25A,"Selective Leaching of Materials - FRCT," aging management prog ram is a new program that is consi stent w ith GA LL AM P XI.M 33, ?Selectiv e Leaching of M aterials," w ith excep tions.A7.3.0.3.2.6.1 Program Descriptio n In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at this program w ill ensu re the integrity of the c omponents that may be suscepti ble to sel ective l eaching at the Forked Rive r Combustion Turbi ne power plant. The AM P include s a one-time v isual in spection and hardness measur ement of selec ted com ponent s to dete rmine whet her loss o f mat erials du e to selec tive leach ing is occurr ing, an d wh ether t he pro cess w ill affect the abil ity o f the com ponen ts to perform their intend ed function for the p eriod of exten ded operation. The One-Time Inspecti on Program includes visual inspection s, hardness tests and other appro priate exa mination method s as may be re quired to confirm or ru le out sel ective l eaching, and to evaluate the remainin g component wall thickness when leaching is identified. Comp onents of the suscept ible materials at the FRCT si te are comprised of copper all oy material s exposed to a treated w ater (closed cooling w ater (CCW)) environment. The pu rpose of the program is to determine i f loss of material due to selective leaching of the zinc component of the alloy (dezincification) is occurring. If selective leaching is found, the progr am provides for evaluation as to the eff ect it will have on th e ability of the affected components a bility to perform their inte nded function for the period o f extended ope ration.The Sel ectiv e Leac hing o f Mate rials - FRC T aging ma nagemen t progra m is a new program.This new p rogram will be implemen ted in the fina l 10 yea rs of the period of extended op eration.
594 A7.3.0.3.2.6.2 Consi stency wit h the GA LL Rep ort In their response to RAI 2.5.1.
19-1, the applicant stated that the OCGS AMP B.1.25A is consistent w ith the GALL XI.M
.33, with an excepti on.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.25A, incl uding the pro gram bas es doc ument P BD-AM P-B.1.25A, ?Selectiv e Leaching of M aterials -
FRCT," Revi sion 0, w hich prov ides an ass essment of the AM P elements' co nsistency with GALL AMP XI.M3 3. Spe cifica lly , the p roject t eam rev iew ed the program elemen ts (see Secti on 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.25 A and associ ated bases documents  to de termine consis tency w ith GALL AM P XI.M33.The project team reviewed those portions of the Selective Leaching of Materials - FRCT program for which th e applica nt claims con sistency w ith GALL AM P XI.M18 and found that they are cons istent with the GAL L Report AMP. The pro ject t eam fo und that the applic ant's Sele ctive Leach ing of M ateria ls - F RCT pro gram con forms to t he rec ommende d GALL AMP XI.M3 3, wi th the e xcept ion as desc ribe d belo w.A7.3.0.3.2.6.3 Exce ption s to th e GALL Repor t The applican t stated in the ir response to RAI 2.5.1.19-1 the followi ng exception to the GALL Report program ele ments: Exception Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken.
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.
595 A7.3.0.3.2.6.4 Enhan cements None.A7.3.0.3.2.6.5 Operating Expe rience The applican t stated in the ir  response to NRC RAI 2.5.1.19-1 that sel ective l eaching 'one-ti me'inspection process is co nsistent w ith staff guidance in the inspecti on techniques u tilized and the selection o f components inspe cted.Selec tive leac hing h as not been ident ified at the Forked Rive r Combu stion Turbin e pow er pla nt. In March 2 004 (Unit 1 FRCT), GE Energy Services performed major inspecti on and maintenance ac tivities and documented all w ork performed in an i nspection rep ort dated June 7, 2004. All work was carried out c losely following th e instruction s and guidanc e found in the original equi pment manufacturer's desi gn, maintenance a nd inspecti on manuals.
Acceptance criteria and corrective actions f or these activities ensure that equipm ent is maintained within design specifica tions.The Unit 1 i nspection w as a major mainten ance inspec tion. This w as the first major in spection that was pe rformed on the unit since ini tial instal lation in 1988. Duri ng the Unit 1 inspection the combustion turbi ne lubricati ng oil sys tem was drai ned, cleaned and inspe cted. The equipment inspections included the lube o il coole rs subject to the closed cool ing water en vironment. The coolers w ere removed from the sump, cleaned and inspecte
: d. No degradati on of these components w as identified. Unit 2 be gan a major outage in spection in October 2005. The combustion turbi ne lubricati ng oil heat e xchangers w ere dissemble d, cleaned a nd inspected
.Based on v isual obser vati ons, th e copp er all oy he at ex changer compon ents n ormall y ex posed to closed cooling water appeared to be in excellent condition. The tube ends at the tube sheet did not show s igns of significant w all thinn ing. The operati ng experienc e with th e combustion turbine system heat exchangers subject to a closed cooling water environment and potent ially subject to sele ctive le aching, demonstrates that selecti ve leach ing has not be en an iden tified concern. This o perating expe rience demonstra tes that either the FRCT clos ed coolin g water environment is less conducive to selective leaching, or that selective leaching is occurr ing slowly enough as to no t yet become evident.
Because sel ective l eaching is a slow a cting corrosion process, this p rogram will include inspections for selectiv e leachin g within th e final 10 y ears of the period o f extended ope ration.The project team rev iewed th e operating ex perience prov ided in th e basis doc ument, and interview ed the appl icant's techni cal staff to confirm that the plant-specific operating exp erience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applic ant's t echnica l staf f, th e proje ct team determ ined that the applic ant's Sele ctive Leaching of M aterials - F RCT program wil l adequately manage the aging effects/mechani sm that are identi fied in the OCGS LRA for whi ch this AM P is credi ted.A7.3.0.3.2.6.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e selective leaching materials - FRCT program in their response to NR C RAI 2.5.1.19-1 which stated that the a ging management program is a new program that wi ll consis t of inspections of components cons tructed of susceptible materials to determine if los s of material due to selectiv e leachin g is occurring. F or 596 the FRCT pow er plant, these are limited to copper al loy materia ls expose d to a close d cooling water env ironment. One-time inspections will consist of vi sual inspe ctions suppl emented by hardness tests. If sel ective l eaching is found , the conditi on wil l be eva luated to de termine the ability of the component to perform its intend ed function unti l the end o f the period of ex tended operation and for the need to e xpand in spections. Thi s new program w ill be i mplemented in the time period a fter January 201 8 and prior to January 2 028.The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 56 of the commi tments.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applic ant's t echnica l staf f, th e proje ct team determ ined that the applic ant's Sele ctive Leaching M aterials - F RCT program wil l adequately manage the aging effects that a re identified in the OCGS LR A for which this AMP is credited
.The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.25 A found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.6.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed the exceptions and the as socia ted jus tificat ions and de termin ed tha t the A MP, w ith th e exc eptio ns, is adequa te to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.7 Buried Piping Inspection - FRCT (B.1.26 A)In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 2005, App endix D , Section B.1
.26A, the appl icant stated th at AMP B.1.26A, "Buried Pipe Inspec tion - FRCT," is co nsiste nt wi th GALL AMP XI.M3 4, ?Buried Pi ping and Tanks," w ith an exception.
A7.3.0.3.2.7.1 Program Descriptio n In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at the Buried Piping Inspe ction -FRCT aging management pro gram is a new aging management program and includes preventiv e measures to mi tigate corrosion and periodi c inspectio n of external surfaces for loss of material to mana ge the effects of corrosion on the pressure-retai ning capacity of carbon steel pipi ng in a soil (exte rnal) envi ronmen t. Prev entiv e measu res are in ac cordan ce wi th stan dard industry pra ctices for maintai ning external coatings and wrappings.
External i nspections o f burie d pip ing w ill occur o pportu nisti call y w hen ex cava ted du ring mai ntenan ce. Within1 0 yea rs prior to enteri ng the period o f extended ope ration, inspe ction of buried piping w ill be p erformed unless an opportunistic inspection occurs wi thin this ten-year perio
: d. Upon ente ring the period 597 of extended op eration, insp ection of burie d piping w ill again be performed wi thin the nex t ten years, unle ss an opportun istic insp ection occurs during this ten-year perio d.A7.3.0.3.2.7.2 Consi stency wit h the GA LL Rep ort In their response to RAI 2.5.1.
19-1, the applicant stated that the OCGS AMP B.1.26A is consistent w ith the GALL A MP XI.M3 4, with a n excepti on.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.26A, incl uding the pro gram bas es doc ument P BD-AM P-B.1.26A, "B uried Pipi ng Inspe ction - FRC T,"Revis ion 0, which p rovid es an asse ssm ent o f th e AMP ele ment s' co nsis tenc y with G ALL AMP XI.M34. Spec ifically, the project team rev iewed th e program elements (s ee Section 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.26 A and associ ated bases do cuments to determine con sistency w ith GALL AM P XI.M34.The project team rev iewed th ose portions of the Buried P iping Inspecti on - FRCT program for whi ch the appl icant clai ms cons isten cy w ith GA LL AM P XI.M 34 and found t hat the y are consistent w ith the GALL R eport AMP. Furthermore, the p roject team determine d that the applicant' s program provid es assurance th at aging effects are adequatel y managed so th at the inten ded fun ction s of buri ed pi pe w ithin the sc ope of l icens e rene wal at the OCGS a re mainta ined consi stent w ith th e curre nt li censi ng basi s duri ng the p eriod of ext ended opera tion. The pro ject tea m found t hat the appl icant's bu ried p ipe i nspect ion - FRCT p rogram co nforms to the r ecom mend ed GA LL AMP X I.M34 , with an exce ptio n as de scri bed be low.A7.3.0.3.2.7.3 Exce ption s to th e GALL Repor t The applican t stated, in the ir response to RAI 2.5.1.19-1, the followi ng exception to the GALL Report program ele ments: Exception Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken.
The sit e corre ctiv e acti ons pr ogram, qua lity assura nce (QA) proce dures, site review and approval process, and administrative controls are implement ed in accordance w ith 10 CFR Part 50, Appe ndix B. The staff finds the requirements o f 10 CFR Part 50, Appendi x B, accep table to add ress the correcti ve action s, confirmation proces s, and admini strative con trols.The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS 598 LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.7.4 Enhan cements None.A7.3.0.3.2.7.5 Operating Expe rience The applican t stated, in Ap pendix D of the response to RAI 2.5.1.19-1, for the "operating experience" program elem ent, the Buried Piping Inspection Prog ram is a new program that will be effective in managing aging degradatio n for the period of extended op eration by providi ng timely detec tion o f aging effec ts and imple mentati on of ap propri ate co rrecti ve ac tions prior to los s of s yst em or comp onen t in tend ed fu ncti ons. To d ate, ther e ha ve b een no b urie d pi pe l eaks due to exte rnal degradatio n at the Forked R iver Combu stion Turbine power pl ant. The buried piping at the Forked Rive r Combustion Turbi ne power plant that i s included in the scop e of license ren ewal i s the glycol filled cool ing water pi ping that is ro uted below grade betwee n the combustion turbi nes and the me chanical d raft cooling tow ers. A head tank normally pressurizes the system, and the head tan k includes l evel moni toring instrumentati on. There is n o history of burie d pip e lea ks in th is sy stem.Based on pl ant op eratin g expe rienc e, coa tings a nd w rappi ngs hav e prov ided adequa te protection to th e external surfaces of buried p iping such th at loss of materia l due to ex ternal corrosion has not been a concern. Thus i nspection of buri ed piping w hen excav ated for mainte nance prov ides reason able assura nce th at the inten ded fun ction s wi ll be mainta ined. Inspections w ill be p erformed within ten tears of enteri ng the period o f extended ope ration, and again within ten years after entering the period of extended operation, unless oppor tunistic inspections occur wi thin each of the se ten-year p eriods.A7.3.0.3.2.7.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he bur ied p ipe p rogram i n Appe ndix D of it s response to RA I 2.5.1.19-1, Secti on A.1.26A, w hich stated th at the buried piping insp ection -FRCT aging management pro gram is a new program that manages the external su rface aging effect s of loss of mater ial for carbon steel piping and piping system com ponents in a soil (external) e nvironment.
The program activi ties consist of preventiv e and condi tion-monitorin g measures to manage th e loss of materia l due to ex ternal corrosi on for piping an d piping sy stem components in the scope of li cense renew al that are i n a soil (external) e nvironment.
The program scope incl udes buried portions of glyc ol cooli ng water pip ing located a t the Forked River Co mbustion Turbine station.External i nspections o f buried componen ts will occur opportun istically when the y are ex cavated during maintenan ce. Within 10 years p rior to enterin g the period of ex tended operati on, inspection of buried piping will be performed unless an oppor tunistic inspection occurs within this ten-year period. Upon entering the per iod of extended operation, inspection of buried piping will again be performed w ithin the n ext ten y ears, unless an opportunis tic inspecti on occurs duri ng this ten-yea r period. This program wil l be imple mented prior to entering the peri od of extended operation.
599 The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the respons e to RAI 2.5.1.1 9-1, and confirmed that this program i s identified as a new program that will be implemented prior to the period of exte nded operatio n as item 57 of the commitments.
On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's buried pip ing inspection
- FRCT aging management program will adequately manage the aging effects that are identified in the OCGS L RA for whic h this AM P is credi ted.The project team rev iewed th e UFSAR S upplement, found th at it was consistent w ith the GALL Report, and de termined that i t provides an adequate summary description of the program, as ident ified in the SRP-L R UFS AR Su ppleme nt tabl e and as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.7.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team found that the applicant h as demonstrated th at the effects of aging wi ll be ade quately managed.
The buried pipe insp ection program has been effective i n monitoring the OCGS buried pi pe and, is expected to be equally effective for the FRC T buried pipe
: s. To date, there have been no leaks id entified for the FRCT buried pipes. On th e basis of its review of the UFSAR Supplement for this program, the project team a lso found that i t provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.8 Structures Mo nitoring Program (B.1.3 1)The OCGS struct ures monitoring prog ram (AMP B.1.31) has been enhanced to include FRCT and Met Tow er components tha t were id entified as be ing in the sc ope of licens e renewal. The project team's audi t and r evie w res ults for the OC GS stru ctures monito ring pr ogram are provi ded i n Sect ion 3.0.3.2.24 of th e OCGS audit and re view report.A7.3.0.3.2.9 Inaccessible Medium Voltage Cabl es Not Subject to 10 CFR 5 0.49 Envi ronmental Qualification Requirements (B.1.36
)The OCGS Inaccessi ble Med ium-Voltage Cab les Not Sub ject to 10 CFR 50.49 Env ironmental Qualification Requirem ents Program (AMP B.1.36) has been enhanced to include FRCT components that were identif ied as being in the scope of license renewal. The project t eam's audit and re view resul ts for the OCGS In access ible Med ium-Vo ltage C ables Not S ubject to 10 CFR 50.4 9 Environ mental Qualifica tion Requiremen ts Program are prov ided in S ection 3.0.3.1.10 of th e OCGS audit and re view report.A7.3.0.3.2.10 Inspec tion o f Interna l Surfa ces in Mis cell aneou s Pip ing an d Duct ing Co mponen ts- FRCT (B.1.38)
In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , Appendix D, Section B.1.28, the applicant stated t hat FRCT AMP B.1.38, "Inspection of Internal Surfaces in Miscel laneous Pi ping and Ducti ng Components - F RCT," is a new plant program that will be consistent w ith GALL AM P XI.M38, "Inspe ction of Internal Surfaces in M iscellane ous Pipin g and Ducti ng Comp onents."
600 A7.3.0.3.2.10.1 Program Descriptio n In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that the program as implemented for the For ked River combustion turbine power plant will consist of vi sual inspe ctions of the in ternal surfaces of stee l piping, v alve bod ies, ductw ork, filter housings, fan housi ngs, damper housi ngs, mufflers and heat ex changer shells that are not covered by other aging management p rograms. These componen ts are subject to an internal environment of indoor air th at is assumed to include sufficient moisture co ntent to result in loss of material aging effects. In a ddition, thi s program includ es piping an d mufflers with di esel engine exha ust gas as an i nternal env ironment. Internal inspection s will be performed durin g schedu led ma inten ance a ctiv ities whe n the s urfaces are mad e acce ssibl e for v isual insp ectio n. The program includ es visual inspection s to assure that existing en vironmental conditions are not causing material degradation tha t could resul t in a los s of component in tended functions.
A7.3.0.3.2.10.2 Consi stency wit h the GA LL Rep ort In th e sup plem enta l resp onse to NRC RAI 2.5.1.19-1 , the appli cant stat ed th at FR CT AMP B.1.38 is con sistent wi th GALL AM P XI.M38, w ith excep tions.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for FRCT AMP B.1.38, incl uding the program basis docum ent, PBD-AMP-B.1.38, "Inspect ion of Internal Surf aces in Miscel laneous Pi ping and Ducti ng Components - F RCT," Revisi on 0, whi ch provid es an assessment of the AM P elements' co nsistency with GALL AMP XI.M 38. Specifica lly, the project team re view ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report)contained i n FRCT AM P B.1.38 and associated b ases documents to determine thei r consistency with GALL AMP XI.M 38.In review ing this AM P, the project tea m noted that the description in the FRC T license ren ewal docume nt did not di scuss the in specti on of el astomer ic com ponen ts as p art of th is pro gram. The applican t was asked w hether any elastomeric materi als, such as flexible ducting and sea ls, are included in the scope of license renewal, and whether they are inspected as part of this program.In its response , the appli cant stated that th ere are two elastomeric c omponents used in the Forked Rive r combu stion turbi ne mech anica l sy stems s ubject to agin g manageme nt. The y are expa nsion joint s and flexi ble c onnec tions expo sed to fuel o il, o utdoor air, a nd in door a ir. NUREG-1801 l ine item VII.F4
-6 (A-17) for elasto mer seals and components ex posed to an indoor air environment was used for the duct exp ansion join
: t. It calls for a plant speci fic aging management program. The pl ant specific agi ng management program used for i nspection of these compon ents i s the F orked R iver Perio dic In specti on Pro gram.The project team reviewed the applicant's response and determined that elastom eric compon ents re quirin g aging ma nagemen t in th e Forke d Riv er comb ustio n turbi ne sy stems a re not included in the scope of FRCT AMP B.1.38; however, they will be managed by the FRCT periodic i nspection agin g management program, whi ch is accep table.The project team reviewed those portions of the applicant's Inspection of Internal Surfaces in Mis cell aneou s Pip ing an d Duct ing Co mponen ts - FR CT progra m for wh ich th e appl icant clai ms consi stency wit h GALL AMP XI.M3 8 and found th at they are co nsiste nt wi th the GALL R eport AMP. Fu rthermore, the project te am determined tha t the appli cant's program prov ides 601 assura nce th at the aging effec ts for w hich this p rogram i s credi ted w ill be ade quatel y mana ged. The project team found tha t the appli cant's Inspecti on of Internal Su rfaces in Mi scellaneou s Pipin g and Duct ing C ompo nent s - FRC T pr ogr am co nfo rms to th e rec omm ende d GAL L AMP XI.M38, wit h the excep tion desc ribe d belo w.A7.3.0.3.2.10.3 Exce ption s to th e GALL Repor t In the supple mental response to NRC RA I 2.5.1.19-1, the a pplicant sta ted the follow ing exce ption to the GALL R eport p rogram: Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken:
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.10.4 Enhan cements None A7.3.0.3.2.10.5 Operating Expe rience In the Nove mber 11, 2005, su pplemental re sponse to NR C RAI 2.5.1.19-1 , the appli cant stated that in October 2 001 (Unit 2 FRCT) and M arch 2004 (Un it 1 FRCT), GE E nergy Servi ces performed m ajor inspection and maintenance act ivities, and documented all work perform ed in inspection reports dated Ja nuary 4, 20 02, and June 7, 2004, respec tively. The equipment inspections included the turbine and its in ternals and s upport equipment.
All wo rk was carried out closely followin g the instruction s and guidanc e found in the original equi pment manufacturer's desi gn, maintenance a nd inspecti on manuals.
Acceptance cri teria and corr ecti ve a ctio ns fo r the se a ctiv iti es e nsur e tha t equ ipme nt i s mai ntai ned wi thin des ign specifications
.The applican t further stated that the Unit 1 i nspection w as a major mainten ance inspec tion. The major inspectio n is the most c omprehensiv e inspectio n that is performed on the combusti on 602 turbin e uni ts. The interv al be twee n major inspe ction s is b ased o n oper ating e xperi ence w ith these and si milar combusti on turbine i nstallation s, and factors that affect part l ife such as fuel ty pe and sta rti ng fr equ enc y. The pu rpo se o f th is ty pe of ma in ten anc e i nsp ect io n i s to id ent ify equipment degradatio n, and if degradati on is ide ntified the affected compo nent is repl aced or refurbi shed i n acco rdance wit h manufa cturers speci ficatio ns suc h that the un it w ill perform reliably through the nex t operating inte rval. This was the first ma jor inspection that was performed on the uni t since ini tial instal lation in 1988.The applican t further stated that du ring the Unit 1 inspectio n, bare pain t spots wi th surface rust were ide ntified in the filter housin g, and were c leaned and touched up w ith new paint to prev ent further rusting. The ex haust frame fan housin gs were cle aned and i nspected, and no degradation w as identified. Corrosion was ide ntified in the compressor ble ed valv es that impacted smooth v alve ope ration, but the valve body pressu re boundary was not affected, and the v alve s wer e refurb ished and re used. Venti latio n fans w ere refu rbish ed, an d no i ssues with fan housing integrity were id entified.The applican t further stated that the Unit 2 i nspection w as a fuel noz zle and combustion secti on inspection.
The Unit 2 i nspection found the inlet fil ter housing to b e in good con dition, w ith no visual defects. The inspec tion incl uded a boresc ope and combu stion inspe ction, remova l of exhaust frame cooling piping and disconnection of the fuel lines f or inspection, and fuel nozzle inspection, repair, and tes ting. Unit 2 began a major outage i nspection i n October 2005.
During the outage, wi th many compon ents disassembl ed, components w ere visua lly in spected for signs of age related degrada tion. The inte rnal surfaces of dis assembled duc twork, fan housings and several d amper housings w ere observed and did n ot show si gns of significant corrosi on. The turbine inl et air filters w ere replaced during the outage, a nd the coated internal surfaces of the filter housi ng wer e ins pected and fou nd to b e in go od con ditio n. Inte rnal s urfaces of frame cooling pip ing were al so observed to be in good condition, with mino r surface rust and n o significant pitti ng or loss of w all thickness. The internal surfaces of the dies el starter engin e exhaust pi ping and muffler we re also obse rved to be in good condi tion, wi th surface rust and no sign s of s igni fica nt pi ttin g or w all-thi nni ng.The applican t further stated that the operating ex perience w ith the Forked R iver combus tion turbines inc ludes a si gnificant number of past inspection activiti es of steel compon ents in the indoor air and diesel e xhaust en vironmen t. The d ocumen ted inspe ction re sults pr ovide obje ctive evidence that existing environmental conditions are not causing material degradation that could resul t in a loss of compo nent i ntende d functi ons. P ast in specti ons ha ve be en per formed at a frequency as lo ng at 16 year s, wi th the units performi ng reli ably betw een i nspect ions. Impleme ntatio n of thi s new program wil l assu re that these insp ectio ns are conti nued o n a mor e conservative frequency of 10 years, providing reasonable assurance that the aging eff ects will be adequately managed for the peri od of extended operation.
The project team rev iewed th e operating ex perience prov ided for the FR CT to confirm that the plant-speci fic ope rating expe rienc e did not re veal any degrada tion n ot bou nded b y in dustry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e, and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components - FRCT progra m will adequately manage the ag ing effect s that are identified in the FRCT AMRs for which this AMP is credited.
603 A7.3.0.3.2.10.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Inspection of Inter nal Surfaces in Miscel laneous Pi ping and Ducti ng Components - F RCT program in the November 11 , 2005, supplemental response to NR C RAI 2.5.1.19-1 , Appendix D, Section A.1.38, whi ch states that the Inspection of Int ernal Surfaces in Miscellaneous Piping and Ducting Component s - FRCT program is a new program that wi ll provi de a means of con firming the aging effects of loss of material and loss of heat trans fer are either not occurring or are p rogressing so slow ly as to not have an effect on the intended f unction of the combust ion turbine fuel oil and lubricating oil system components within the period of extended oper ation. Additionally, this program will address potenti ally l ong incubatio n periods for l oss of material a nd loss of hea t transfer aging effects.The applican t's UFSAR further stated that the One-Time Inspection
- FRCT program w ill prov ide measures to ve rify that an agi ng management program is no t needed, confirm th e effectiveness of existing acti vities, o r determine that degradation is occurring w hich wi ll require ev aluation a nd corrective a ction. The program w ill be i mplemented prio r to the perio d of extended operation.
The applican t's UFSAR further stated that in spection method s will include visual examinatio n or volumetric examinatio ns. Inspection s will be performed by qualified person nel using pro cedures deve loped consi stent w ith th e qual ity c lassi ficatio n of the Forked Riv er comb ustio n turbi nes. Acceptance cri teria wi ll be in accordance w ith design stan dards for the combusti on turbines a nd manufacturer's recommenda tions. The Inspe ction of Internal Surfaces in M iscellane ous Pipin g and Ducting C omponents - FR CT program provide s for the eval uation of the ne ed for follow-up examinations to monitor the prog ression of aging if age-related degr adation is found that could jeopardize an intended function bef ore the end of the period of extended operation. Should aging effects be detected, the program wil l initia te actions to characterize the nature and extent of the aging effect and determin e what sub sequent monitorin g is needed to ensure inten ded functions are mai ntained duri ng the period o f extended ope ration.The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 58 of the commi tments.The project team rev iewed th e UFSAR S upplement for FRC T AMP B.1.3 8, found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi ded an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.10.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort are consistent w ith the GALL R eport. In addi tion, the project team review ed the exc eption and the associ ated ju stifica tions and d etermi ned th at the AMP , wi th the exce ption , is a dequate to manage the aging effects f or which it is credited. The project team also reviewed the UFSAR Supplement for thi s AMP a nd found that it provides an adequate summary description of the program, as requi red by 10 CF R 54.2 1(d).
604 A7.3.0.3.2.11 Lubricating Oil Analysi s - FRCT (B.1.39
)In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 20 05, Ap pendi x D, S ectio n B.1.3 9, the appli cant st ated th at OCGS AMP B.1.39 , ?Lubricating Oil Analy sis Program - FR CT," aging management program is a new pro gram that is consi stent with GALL A MP XI.M39, ?Lubricating Oil Analysi s Program," with exceptions
.A7.3.0.3.2.11.1 Program Descriptio n In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at this program w ill inc lude measures to verify the oil env ironment in mec hanical e quipment is mai ntained to the required quali ty. The Lubricating Oil Analysi s Program - FRCT mai ntains oil systems conta minants (primari ly wa ter and particul ates) withi n acceptable limits, there by preserv ing an env ironment that i s not conducive to loss of materi al, cracking, or redu ction in h eat transfer. Lubric ating oil tes ting activiti es include sampling and analysi s of lubricatin g oil for detrimenta l contaminan ts. The presence of wa ter or particul ates may al so be indi cative of in leakage and corro sion product buildup.A7.3.0.3.2.11.2 Consi stency wit h the GA LL Rep ort In their respon se to RAI 2.5.1
.19-1, the appl icant stated th at the OCGS AM P B.1.39 is consistent with the GALL XI.M.39, w ith excep tions.The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents lis ted in Attachme nt 5 of this aud it and rev iew repo rt for OCGS AMP B.1.39, incl uding the pro gram bas es doc ument P BD-AM P-B.1.39, ?Lubri catin g Oil A naly sis P rogram -FRCT," Revi sion 0, w hich prov ides an ass essment of the AM P elements' co nsistency with GALL AMP XI.M3 9. Spe cifica lly , the p roject t eam rev iew ed the program elemen ts (see Secti on 3.0.2.1 of this audit a nd review report) contain ed in OCGS A MP B.1.39 and associ ated bases documents  to de termine consis tency w ith GALL AM P XI.M39.The project team reviewed those portions of the Lubricating O il Analysis Program - FRCT program for which th e applica nt claims con sistency w ith GALL AM P XI.M39 and found that they are consistent with the GALL Report AM P. Furthermore, the project team determi ned that the appli cant's progra m ensur es tha t combu stion turbi ne oi l sy stems w ill be effecti vely managed to provide a n acceptable oil env ironment, so that the intended functions of components within the scope of licen se renewal at the FRCT sta tion are main tained consi stent with the current licensing b asis during the period of ex tended operati on. The project tea m found that the applicant' s Lubricatin g Oil Analy sis Program - FR CT program conforms to the reco mmended GALL AMP XI.M39, with th e exce ptio ns as desc ribe d belo w.A7.3.0.3.2.11.3 Exce ption s to th e GALL Repor t The app lica nt stat ed in their respo nse to RAI 2.5.1.19-1 that the ex cepti on to t he GAL L Repo rt program elements is as follow s: Exception 1 Eleme nt: 3. Parameters M onitored or Ins pected 605 Exception: Parameters Mo nitored or Insp ected requires the flash point b e measured for the lu bricating oil
: s. Flash P oint is no t measured for lubricating o ils in s ervice, si nce this is a quality control measure ment w hen pu rchasi ng new oil. It is not a primar y measurement to determi ne the presenc e of water or c ontaminants, which a re the concerns for controlling the environmen t of concern.
The GALL Report i dentified the foll owing recommend ation for the para meters  monitored or inspected pro gram element associ ated with the excep tion taken:
: 3. Parameters Moni tored or Inspected
: For components with periodic oil changes in accordance w ith manufacturer's re commendations, a particle cou nt and check for w ater are performed to detect evidence of abnormal w ear rates, contami nation by moisture, or excessive co rrosio n. For com ponent s that do not have re gular o il chang es, viscos ity, neutraliz ation number, a nd flash poin t are also de termined to v erify the oil is suitabl e for continued us
: e. In additi on, analy tical ferrography and elemental analysi s are performed to identify w ear particles
.The applicant stated that in their re sponse to RAI 2.5.1.19-1 tha t no components with periodic oil changes were identified to have inte nded functions.
Components w ith intende d functions that d o not have re gular oil ch anges are suppl ied oil from the lubricati ng oil sys tem. A particl e count and check for water w ill be p erformed on the lub ricating oil in the lu bricating oil system to dete ct evidence of abnormal w ear rates, contami nation by moisture, or ex cessive c orrosion. In ad dition, viscosity , and neutrali zation nu mber will be determined to verify the oil i s suitable for continued use. Wear pa rticl es wi ll be iden tified through anal ytic al ferro graphy , and e lement al an alys is. The applican t takes excepti on to the Fl ash Point mon itoring recommendati on specified in the GALL si nce th is is a qual ity c ontrol measur ement w hen pu rchasi ng new oil and i s not a prima ry measurement to determi ne presence o f contaminants.
The project team does not agree wi th the appli cant's posi tion. The project team determined th at basis prov ided for exce ptions is n ot valid since the fla sh point of an industrial lubricant i s an important test to d etermine if li ght-end hydroca rbons are getting i nto the oil through seal l eaks or other means. It i s an effective w ay to monito r seal performance in light end hydro-carbon compressors. Low flash points pose a safety hazard in the event of component failure that can generate heat abo ve the flash point of the oi l, such as b earing failure.
The applican t was asked to justify the reason f or not monitoring the f lash point of lubricating oil at the FRCT and why this exception is acceptabl e to manage the effects of aging for w hich it i s credited. In its letter da ted April 17, 2006 (ML061150320), the applicant commit ted to revise the Lubricating Oil Analysis Program - FRC T in LR A B.1.39 to i nclud e measu rement of flash point. This is A udit Commitment A 7.3.0.3.2.11-1.
Exception 2 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
606 The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken.
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.11.4 Enhan cements None.A7.3.0.3.2.11.5 Operating Expe rience The applicant stated in their  response to NRC RAI 2.5.
1.19-1 that the Lubricating Oil Analysis Program - FRCT is a new pro gram that will be effective in managing aging degradati on for the perio d of ex tended opera tion b y pro vidi ng peri odic sampli ng and analy sis of l ubric ating o il to provi de time ly d etecti on of de gradati on in lubri catin g oil proper ties a nd take approp riate corrective a ctions prior to loss of sys tem or component i ntended functions. In October 2001 (Unit 2 FRC T) and March 2004 (Unit 1 FRCT), GE Energy Services performed major inspe ction and maintenan ce activi ties and doc umented all work performed in i nspection rep orts dated January 4, 2 002, and June 7, 2004, respe ctively. The equipment i nspections i ncluded the turbine and its internal s and support equipment. All work was carried out c losely following th e instructions a nd guidance found in the ori ginal equipment manufacturer's design, mai ntenance and i nspect ion ma nuals. Acce ptance crite ria an d corre ctiv e acti ons for t hese a ctiv ities ensur e that equipment is maintained within design specifica tions.The Unit 1 i nspection w as a major mainten ance inspec tion. This w as the first major in spection that was pe rformed on the unit since ini tial instal lation in 1988. Duri ng the Unit 1 inspection, the emergency DC l ubricating oi l pump wa s removed an d sent to the Gen eral Electri c service shop for clea ning, i nspect ion a nd rep airs. The GE report does n ot ind icate any issue s asso ciate d wi th degradation of this pump casing. The combustion turbi ne lubricati ng oil sys tem was drai ned, clean ed and insp ected. Vario us pump s wer e ins pected , and t he lu brica ting oi l coo lers w ere clean ed. No degrad ation of these compon ents w as id entifi ed. The main l ubric ating o il pu mp was disa ssembled and inspected, an d no defects w ere observed
.The Unit 2 inspection was a fuel nozzle and combustion section inspection. The lubricating oil filters were replaced. The GE report does n ot identify a ny issues with the lubricatin g oil syste m or components. U nit 2 began a major outage inspec tion in Octob er 2005. Duri ng the outage, wi th ma ny c ompo nent s di sass embl ed, c ompo nent s w ere v isu all y i nspe cted for s igns of age related degradation.
The internal surfaces of disassembled stainless steel piping and flexible hoses show ed no signs o f corrosion or w all thinn ing. The combustio n turbine l ubricating oi l heat exchangers w ere disassembl ed, cleaned and inspecte
: d. The carbon s teel and cop per alloy heat 607 exchanger compo nents normall y expos ed to lubri cating oil w ere found to be i n excell ent condition.
The standby h eat exchanger that is not no rmally i n service was found to have some mi nor accumulati on of sediment tha t was cle aned off. Carbon stee l pump casings that are normally submerged in the lubricatin g oil reserv oir were visuall y observ ed to be in ex cellent con dition, w ith no signs of corrosion. The ca rbon steel i nternal surfaces o f the lubricating o il reserv oir were also observ ed to be in excell ent conditio n, with n o signs of corrosion.
The operating ex perience w ith the combusti on turbine sy stem components su bject to a lubricat ing oil envir onment demonst rates t hat the combus tion tur bine lubri cating oil system s have not experi enced significa nt intrusion of water and c ontaminants that would re sult in agin g degradation. This new program w ill prov ide additi onal assuran ce that wate r and contamin ant concentrations are minimiz ed, such that a ge related degradati on wil l continue to be minimi zed.The Lubricatin g Oil Analy sis Program - FR CT will monitor for adve rse trends in performance.
Problems ide ntified wi ll not cau se impact to the intended functi ons of the Forked Ri ver Combustion Turbi ne power plant, and a dequate correctiv e actions w ill be ta ken to prevent recurrence. Ther e is sufficient conf idence that the implementation of the Lubricating Oil Analysis Program - FRCT w ill effectivel y maintain oil sy stems contaminants (primarily water and particulates) within acceptable l imits.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staf f, the project team determined that th e applicant's Lubricating Oil Analysi s Program - FRCT pro gram will adequately man age the aging effects/mechanism th at are identified in the OCGS L RA for whic h this AM P is credi ted.A7.3.0.3.2.11.6 UFSAR Sup plement The applicant provided its UFSAR Supplement for th e Lubricating Oil Analysis Program - FRCT program in their response to NR C RAI 2.5.1.19-1 which stated that the a ging management program is a new program that incl udes measures to verify the oil env ironment in mec hanical equipment is maintained to the re quired quality. The Lubricating Oil Analysis Program - FRCT maintains oi l systems co ntaminants (prima rily w ater and partic ulates) wi thin acceptab le limits, thereby prese rving an env ironment that i s not conduci ve to los s of material, crackin g, or reduction in heat transfer. Lubri cating oil te sting activi ties inclu de sampling an d analys is of lubricating o il for detrimental contaminants.
The presence of w ater or particul ates may al so be indicativ e of inleakage and corrosion pro duct buildu
: p. This program is augmented by the one time inspection - FRCT (B.1.24A) pr ogram, to verif y the effectiveness of the Lubricating Oil Analysi s Program - FRCT. Thi s program wil l be imple mented prior to the period o f extended operation.
The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the supplemental response to RAI 2.5.
1.19-1, and confirm ed that this program is identified as a new p rogram that wil l be imple mented prior to the period o f extended ope ration as item 59 of the commi tments. The appli cant committed to re vise thi s item to reflect the commitment specified in A7.3.0.3.2
.11-1.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staf f, the project team determined that th e applicant's Lubricating Oil Analysi s Program - FRCT pro gram will adequately man age the aging effects that are i dentified in the OCGS LR A for which this AMP is credited
.
608 The project team rev iewed th e UFSAR S upplement for OCGS A MP B.1.39 found that it w as consi stent w ith th e GALL Repor t, and determi ned th at it p rovi des an adequa te summa ry description of the program, as iden tified in the SRP-LR FSA R Supplemen t table and as required by 10 CFR 5 4.21(d).A7.3.0.3.2.11.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th ose program e lement s for w hich the ap plic ant cl aims c onsis tency wit h the GA LL Rep ort, are consistent w ith the GALL R eport. In addi tion, the project team has revi ewed commitmen t A7.3.0.3.2.11-1, the exceptions and the associated justif ications and determined that the AMP, with the exceptions , is adequate to manage the aging effects for wh ich it is credited. The p roject team al so rev iew ed the UFSA R Sup plemen t for thi s AM P and found th at it p rovi des an adequa te summary descri ption of the p rogram, a s requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.12 Buried Piping and Tank Inspect ion-Met Tower Repeater Engine Fuel Supply (OCGS AMP B.1.26B)
In the appli cant's respons e to NRC R AI 2.5.1.15-1 rel ated to the OCGS LRA, dated D ecember 9, 2005, Appe ndix D, Section B.1.2 6B, the appl icant stated th at OCGS AMP B.1.26B, "Buri ed Pipi ng and Tank  Ins pecti on - M et Tow er Rep eater E ngine Fuel Suppl y," w hich is con sisten t wi th GALL A MP XI.M34, ?Buried Pi ping and Tanks Inspe ction," wi th exceptio ns.A7.3.0.3.2.12.1 Program Descriptio n In their respon se to RAI 2.5.1
.15-1, the appl icant stated th at the Buried Piping and Tank Inspection -
Met Towe r Repeater Engi ne Fuel Su pply agin g management program is a n ew aging management program that re lies on co ating, wrappi ng and periodi c inspectio n as a preventiv e measure, and to mitigate and ma nage the effects of corrosion on the pres sure-ret ain ing c apac ity of ca rbon stee l an d co pper pip ing a nd fi ttin gs, a nd c arbo n ste el t ank, in a soil (external) environment.
External coatings and w rappings are mai ntained in accordance with stand ard industry practices. E xternal i nspections o f buried pipi ng components w ill occur opportunistic ally w hen excav ated during main tenance. Within 10 ye ars prior to en tering the period of exte nded operatio n, inspectio n of buried pi ping components will be performed unles s an opportunis tic inspecti on occurs w ithin this ten-year peri od. Upon en tering the perio d of extended o peration, ins pection of buri ed piping co mponents wi ll again b e performed with in the next ten y ears, unless an opportunis tic inspecti on occurs duri ng this ten-ye ar period. The aging manageme nt progr am acti viti es wi ll be coord inate d wi th Fir st Ene rgy, as neces sary, pursu ant to an Eas ement, L icens e, and Restri ctiv e Cov enant Agreeme nt.A7.3.0.3.2.12.2 Consi stency wit h the GA LL Rep ort In their response to RAI 2.5.1.
15-1, the applicant stated that the OCGS AMP B.1.26B is consistent w ith the GALL A MP XI.M3 4, with e xceptions.
The project team inte rviewe d the appli cant's technica l staff and revie wed, in whole o r in part, the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.26B, includin g the program bases do cument PBD-AM P-B.1.26B, "Buri ed Piping a nd Tank Inspection
- Met Tow er Repeater En gine Fuel S upply," Re vision 0, which provides an assessment of the AMP el ements' consisten cy wi th GALL AM P XI.M34. S pecifically , the project team re viewe d the 609 prog ram elem ents (see Sect ion 3.0.2.1 of this audit and re view re port) con tain ed in O CGS A MP B.1.26B and a ssociated ba ses documents to determine con sistency w ith GALL AM P XI.M34.The project team rev iewed th ose portions of the Buried P iping and Tank Insp ection - M et Tower Repeater Engin e Fuel Sup ply Program for w hich the app licant cla ims consisten cy wi th GALL AMP XI.M 34 and found tha t they are co nsistent w ith the GALL R eport AMP. Furthermore, the project team de termin ed tha t the a ppli cant's this program provi des as suranc e that aging effec ts are adequately managed so that th e intended functions of buried pipe wi thin the scop e of license renewal at the OCGS are mai ntained cons istent wi th the current l icensing basi s during the period of exte nded operatio
: n. The project team foun d that the appl icant's buri ed pipe i nspection- Met t ower r epea ter engi ne f uel su pply pr ogr am co nfo rms to th e rec omm ende d GAL L AMP XI.M34, wit h the excep tion s as de scri bed be low.A7.3.0.3.2.12.3 Exce ption s to th e GALL Repor t The applican t stated in the ir response to RAI 2.5.1.15-1 the followi ng exception to the GALL Report program ele ments: Exception 1 Elements: 2. Preventi ve Action s 3. Parameters M onitored or Ins pected 4. Dete ction of Agin g Effects Exception: NURE G-1801, Secti on X1.M.34, ?Buri ed P ipi ng an d Tan ks Insp ecti on," AM P re lie s on prev enti ve m easu res s uch as c oati ngs and wrapp ings, howev er portions of thi s piping may not be coated or wrapped. Inspections of buried piping that is not wrapped will inspect for loss of material due to general, pitti ng, crevice, an d MIC.The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts?Preventiv e Actions," P arameters Mon itored or Inspe cted," and
?Detect ion o f Aging E ffects."associated w ith the ex ception taken:
: 2. Preventive A ction: In accordance with in dustry practi ce, underground pi ping and tanks are coa ted during ins tallation with a p rotective co ating system, suc h as coal tar enamel with a fiberglass wrap and a kraf t paper outer wrap, a polyolifin tape coating, or a fusion bonded epoxy coating to protect the piping from contac ting th e aggress ive soil envi ronmen t.3. Parameters Moni tored or Inspected
: The program monitors p arameters such as coating and wrapping i ntegrity that are directly related to co rrosion damage of the ex ternal surface of buri ed ste el pi ping a nd tan ks. Coa tings a nd w rappi ngs are inspected by visual techniques. A ny evi dence of damaged w rapping or coati ng defects, such as co ating perforation, ho lidays, or other damage, is an indic ator of possible c orrosion damage to the externa l surface of pipi ng and tanks.
: 4. Detect ion o f Agin g Effec ts: Inspections p erformed to confirm that coa ting and wrapping are intact are an effective method to ensure that corros ion of externa l surfaces has not oc curred and the intended functio n is maintai ned. Buried piping 610 and tanks are opp ortunistical ly insp ected when ever they are excav ated during mainte nance. When oppo rtunis tic, th e ins pecti ons ar e perfor med in areas wit h the highest li kelihood of corrosi on problems, a nd in areas with a h istory of corrosion prob lems, with in the areas made accessib le to support the maintenance activity.The app lica nt's p rogram i s to be eval uated for the e xtend ed per iod o f operat ion. It is antici pated that one or more opportuni stic inspecti ons may occu r within a ten-year peri od. Prior to entering the peri od of extended operation, the applican t is to verify that there is at least one opportunistic or focused inspection is performed withi n the past ten years. Upo n entering the p eriod of exten ded operation, the applicant i s to perform a focused i nspection w ithin ten y ears, unless an o pportunistic inspection occurred wi thin this ten-year perio
: d. Any credited ins pection shou ld be performed i n areas wi th the highest l ikelihood o f corrosion prob lems, and in areas wi th a history of corrosion prob lems.The applican t stated that in their respons e to RAI 2.5.1.1 5-1 and in the program basis document PBD-AMP-B.1.26B, Rev ision 0, tha t in accordan ce with industry pra ctice, portion s of the undergr ound p ipin g and ta nk at the Forked Riv er mete orolo gical towe r wer e eith er proc ured w ith coating or coated during instal lation w ith a protecti ve coatin g system to protect the piping an d tank from c ontact ing the poten tiall y aggres sive soil envi ronmen t. Port ions of the p ipin g that a re not coated or w rapped wi ll be in spected for loss of material due to general, pitti ng, crevice, an d MIC. Inspe ction s wi ll be performe d to co nfirm tha t coati ng and wrap ping a re int act, an d to determine the e xtent of potenti al corrosion of buried pip ing components tha t are not coated or wrapped.
These inspecti ons are an effectiv e method to ensu re that corrosio n of external surfaces has not oc curred and the intended functio n is maintai ned. The burie d piping and tank will be opportunis tically inspected w henever ex cavated for main tenance. The i nspections w ill be perf ormed on all of t he areas made acc essible t o suppor t the ma intenan ce activit y.The project team noted that the appl icant follow s the recommendati ons specified in the GALL Report for inspec tions of underground piping coati ngs and wrap pings and the underground piping that are not coated or wrapped will be inspected for loss of material due to general, pitting, crevi ce, and M IC. On this ba sis, the project team found this ex ception acce ptable.Exception 2 Elements: 7. Correctiv e Actions 8. Confirmation P rocess 9. Administrative Controls Exception: These elements a re not accompli shed in acc ordance wi th the AmerGen quality assurance (Q A) program and are not in accordance with the requirement s of 10 CFR Part 50, Appendix B.
The GAL L Repo rt ide ntifie d the fo llow ing rec ommenda tions for the abov e progra m eleme nts associated w ith the ex ception taken.
The site correcti ve action s program, quality assurance (QA) pro cedures, site re view and approv al pro cess, a nd admi nistra tive contro ls are imple mented in ac cordan ce wi th 10 CFR Part 50, Appendi x B. The sta ff finds the requirements of 10 C FR Part 50, 611 Appendix B, acceptabl e to address th e corrective actions, con firmation process, a nd administrativ e controls.
The adequacy of the applican t's Quality Assurance Pro gram associated w ith this program elemen t is re view ed by DE sta ff and add ressed in Se ction 3.0 of t he SE R rela ted to the OCGS LRA. In their response to RAI 2.5.1.1 9-1, the applicant stated that it will meet the guidance in Branch Techni cal P ositi on IQM B-1, ?Quali ty As suranc e for Agi ng Ma nagemen t Progra ms."  On this basis, the project team found this excep tion acceptab le.A7.3.0.3.2.12.4 Enhan cements None.A7.3.0.3.2.12.5 Operating Expe rience The applican t stated, in Ap pendix D of the response to RAI 2.5.1.15-1, for the "operating experience" program element, the buried pip e inspectio n - Met to wer repeater engine fuel supply sy stem aging management program i s a new program that wil l be effective i n managing aging degradation for the period of ex tended operati on by prov iding timely detection of agin g effects and implementati on of appropriate corrective actions prio r to loss of sy stem or component intended fu nctions. The buried piping and tank at the Forked River Met Tower that is incl uded i n the s cope o f licen se ren ewal is th e bel ow gra de pro pane fi lled pipi ng and tank nex t to the Forked River meteorolog ical tower. There is no history of buried pipe or tank leak s in this syste m.Based on Fo rked River mete orological to wer repeater engine fuel supp ly burie d piping and tank operat ing ex perie nce, l oss of ma terial due to exte rnal c orrosi on has not be en a c oncern. Inspection of the buried pip ing and tank w hen excav ated for maintenanc e therefore provi des reasonable a ssurance that the intended functi ons wil l be maintai ned. Inspecti ons wil l be performed withi n 10 years of entering the peri od of extended operation, an d again wi thin ten years after enteri ng the period o f extended ope ration, crediti ng opportunistic inspection s that may occur w ithin each of these ten-year periods.A7.3.0.3.2.12.6 UFSAR Sup plement The app lica nt prov ided its UF SAR S upple ment for t he bur ied p ipe p rogram i n Appe ndix D of it s response to RA I 2.5.1.15-1, Secti on A.1.26B, w hich stated th at the buried piping and ta nk inspection
- Met tow er repeater engin e fuel supply aging management program is a new program that manages the e xternal surface aging effects of loss of material for carbon steel and copper pipi ng and fittings, and c arbon steel ta nk, in a soil (external) environment.
The program activiti es consist of pre ventive and condi tion-monitorin g measures to manage the loss of material due to external corrosion for the piping, fittings, and tank in the sco pe of license renewal that are in a soil (ex ternal) env ironment. The program s cope inclu des buried p ortions of the meteorological tower repeate r engine fuel sup ply (propa ne) piping an d tank located a t the Forked Rive r meteo rologi cal to wer.External i nspections o f buried componen ts will occur opportun istically when the y are ex cavated during maintenan ce. Within 10 years pri or to entering the period of ex tended operati on, inspection of buried pipi ng components w ill be p erformed unless an opportunistic inspection occurs wi thin this ten-year perio
: d. Upon enteri ng the period o f extended ope ration, inspe ction of buried pip ing components w ill again be performed wi thin the nex t ten years, u nless an 612 opportunistic inspection occurs durin g this ten-yea r period. This program will be implemen ted prior to enteri ng the period o f extended ope ration.The project team also reviewed the applicant's updated license renewal commitment list in Appendix A of the respons e to RAI 2.5.1.1 5-1, and confirmed that this program i s identified as a new program that will be implemented prior to the period of exte nded operatio n as item 61 of the commitments.
On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applica nt's technical staff, the project team determi ned that the ap plicant's buried pip ing and tank inspection - Met tower repeater engine f uel supply aging management program will adequately manage the ag ing effect s that are identified in the OCGS LRA f or which this AMP is credited.The project team rev iewed th e UFSAR S upplement, found th at it was consistent w ith the GALL Report, and de termined that i t provides an adequate summary description of the program, as ident ified in the SRP-L R UFS AR Su ppleme nt tabl e and as requi red by 10 CF R 54.2 1(d).A7.3.0.3.2.12.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the project team found that the applicant h as demonstrated th at the effects of aging wi ll be ade quately managed.
The buried pipe insp ection program has been effective i n monitoring the OCGS buried pi pe and, is expected to be equa lly effec tiv e for the m et. t owe r rep eate r eng ine fuel sup ply buri ed p ipe and tank s. To date, there hav e been no l eaks identified for the met. tower re peater engine fuel supply buried pipe and ta nks. On the basis of its revie w of the UFS AR Supple ment for this program, the project team also found that it pro vides an adequate summary description of the program, as require d by 10 CFR 54.21 (d).A7.3.0.3.3 AMPs T hat Ar e Not Consi stent w ith the GALL R eport or Not Addre ssed i n the GALL Repo rt A7.3.0.3.3.1 Periodic M onitoring of Combus tion Turbine P ower Pla nt - Electri cal (B.1.37)
In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to Sectio n B.1.37 of Appe ndix D to the OCGS LR A, date d Octob er 12, 2005, the ap plic ant sta ted tha t OCGS A MP B.1.37, ?Periodic Monitori ng of Combustion Turbi ne Power Plant - El ectrical" is a new p lant program that will incl ude el ements of GALL A MPs XI.E1, ?Electrical Cables and Connection s Not Subjec t to 10 CFR 5 0.49 E nvir onmenta l Qual ificati on Requ iremen ts," XI.E 3, ?Inaccessible Medium V oltage Cable s Not Subject to 10 CFR 50
.49 Enviro nmental Quali fication Requir ements," and XI.E4, ?Meta l Enc losed Buses."A7.3.0.3.3.1.1 Program Descriptio n In i ts re spon se to RAI 2.5.1.19-1, t he a ppl ica nt st ated that thi s pro gram w ill be u sed to ma nage aging effects for the electrica l commodities that support FR CT operation.
The new AmerGen Periodic M onitoring of Combus tion Turbine P ower Pla nt - Electri cal program, the ex isting structu res mon itori ng progra m, and t he new Inacce ssibl e Me dium-V oltage Cabl es Not Subje ct to 10 CFR 50.4 9 Environ mental Qualifica tion Requiremen ts Program wil l be used to manage aging effect s for the electrical comm odities that support FRCT operat ion. This AmerGen prog ram will include e lements of GALL AM P XI.E1 for accessib le electric al cables and connecti ons; XI.E3 for 613 manholes, pi ts, and cable trenches; and XI.E4 for the phase bu s, connections , and phase b us insulators.
This AmerGen program w ill ins pect accessib le electric al cables and connecti ons before the period of extended o peration, w ith an ins pection frequency of at least once every 1 0 years.This AmerGen prog ram will inspect manholes, pits, and cable trenches containing inaccessible medium-voltage cables loc ated on the F RCT site for wa ter collecti on so that drai ning or other corrective a ctions can b e taken. Inspecti ons for water co llection will be performed at lea st once every 2 ye ars, an d the fre quency of insp ectio n wi ll be adjust ed bas ed on the res ults o btain ed. The first inspectio ns wil l be comple ted before the peri od of extended operation.
This A merGen p rogram w ill also inspe ct the access ible phase bus, c onnec tions , and i nsula tors befor e the per iod of ext ended ope ration, with an inspec tion fr equenc y of at lea st once e very 5 years. Inspe ction of the pha se bus encl osure externa l surfaces wi ll be performed u nder the existing struc tures monitoring p rogram (AMP-B.1.31
). The first inspecti on wil l be performed befor e the per iod of ext ended ope ration, with an inspec tion fr equenc y of at lea st once e very 4 years.The followi ng represents the A MP B.1.36 scope for 13.8 kV c ables that di stribute the ou tput of the FRCT to both the OCGS SBO tr ansformer and t he 230 kV switchyard. Inaccessible medium-voltage cable circu its supportin g the FRCT and th e associated manholes, pi ts, and trenches located on the OCGS site will be tested or inspected by the new Inaccessible Medi um-Vol tage Ca bles Not Su bject to 10 CF R 50.4 9 Env ironme ntal Qu alifi catio n Requi rements Program (AMP-B.1
.36). The first tests an d inspectio ns wil l be performed before the period o f extended o perations, w ith a cabl e test frequency of at l east once ev ery 10 y ears, and a manhole, pit, and trench in spection frequency of at least once every 2 years. These aging management activi ties ensure th e continued availab ility o f the FRCTs as the alternate ac s ource in the event of an SBO at OCGS.
A7.3.0.3.3.1.2 Consi stency wit h the GA LL Rep ort In FRC T program basis docume nt PBD-AMP-B.1.37 , ?Periodic M onitoring of Combus tion Turbine Pow er Plant - E lectrical," R evision 0, the appl icant stated th at FRCT AM P B.1.37,"Periodic M onitoring of Combus tion Turbine P ower Pla nt - Electri cal" is con sistent wi th GALL AMPs XI.E1, XI.E3 , and XI.E4.
The project team interviewed the applicant's technical staff and reviewed the documents listed in  of t his audit and review report, in whole or in part, including program basis docume nt PBD-AMP-B.1.37 , ?Perio dic M onito ring of C ombusti on Turb ine P ower Plan t -Electrical," Revision 0. The project team reviewed the applicant's comparison of the FRCT program with the elements of the c orresponding NU REG-1801 Chap ter XI aging management programs XI.E1, XI.E3, and XI.E4.
Specificall y, the project team review ed the program elemen ts (see Secti on 3.0.2.1 of t his a udit a nd rev iew report) conta ined in FR CT AM P B.1.37 to determine thei r consistency with GALL AMPs XI.E1 , X1.E3, and X1.E4.
The project team rev iewed th ose portions of the applica nt's program for whi ch the appli cant claims consi stency w ith GALL AM Ps XI.E1, X1.E3, and X1.E4 and found tha t they are co nsistent with these GALL Report A MPs. The p roject team's rev iew of cabl e testing portion s of NURE G-1801 Secti on XI.E3 program elemen ts and the st ructure s moni toring associ ated w ith elect rical commod ities , as sc oped b y NU REG-18 01 Sec tion XI.S6 pro gram ele ments a re discussed i n Section 3
.0.3 of this OCGS au dit and rev iew repo rt. The project team as ked the 614 applicant w hether the GALL X1.E4 program elements included phase bus en closure inte rnal surfaces inspecti ons. The appl icant stated th at this program al so include s inspectio n of the internal po rtion of the metal enclosed bu ses to identi fy age related d egradation of insu lating and metallic components, excessive dust buildup and for eign debris, and evidence of moistur e debris intrusion. On the basis of its review, the project team determined that th e applicant's Periodic Monitori ng of Combustion Turbi ne Power Plant - El ectrical program w ill effectivel y manage the aging of accessibl e cables an d connection s; inaccessi ble medium-v oltage cables; and phase bus and conn ections, phase bus insul ators, and phas e bus enclo sure internal surfaces such that there is reaso nable assura nce that the i ntended functions of the electrica l commodities supporting the F RCTs wil l be maintai ned consiste nt with th e current lic ensing basis during the period of exte nded operatio
: n. The project team foun d that the appl icant's Peri odic Mo nitoring of Combustion Turbine Power Plant - Electrical Progr am conforms to the recommendations in GALL AMP s XI.E1, X1.E3, and X1.E 4.A7.3.0.3.3.1.3 Exce ption s to th e GALL Repor t None A7.3.0.3.3.1.4 Enhan cements None A7.3.0.3.3.1.5 Operating Expe rience In its response to RAI 2.5.1.19-1, the applicant stated that while this is a new program, FRCT has not ex perienced a cable- or bus-related failure during its pe riod of operatio
: n. The appli cant also stated th at a 2004 i nspection i nvolve d major rework an d repair of the e xhaust pl enum after and forward w alls, incl uding a comple te rebuild and rewi ring of the load compartment and junction box es, as wel l as exte nsive al ignment activi ties. These major e fforts ensured that the FRCT cables and connecti ons were i n optimal co ndition w hen returned to service. L essons learned from routin e inspectio ns are incorp orated into the future outage scope.
A review of the applicant' s corrective action docu ments did not indicate the occurrence of aging d egradation with el ectrical commodi ties at the FR CT power pl ant or a combusti on turbine re liabili ty below the 95 per cent re quireme nt.The project team rev iewed th e operating ex perience prov ided in OC GS PBD-AM P-B.1.37 and interview ed the appl icant's tech nical staff to confirm tha t the plant-spe cific operating e xperience did not rev eal any degradation not bounded by industry experience
.On the b asis o f its rev iew of the a bove plan t-speci fic ope rating expe rienc e and discu ssion s wi th the applicant's technical staff , the project team det ermined that the applicant's periodic monitoring of combusti on turbine p ower pla nt-electrical program wil l adequately manage the aging effects that are iden tified in the LRA for whi ch this AM P is credi ted.A7.3.0.3.3.1.6 UFSAR Sup plement The applican t provided its UFSAR Supplements for the Periodic Monitori ng of Combustion Turbine Power Plant - Electrical program in its resp onse to RAI 2.5.1.19-1. T he new Periodic Monitori ng of Combustion Turbi ne Power Plant - El ectrical program w ill be u sed in conju nction wi th th e ex isti ng st ruct ures moni tori ng pr ogram and the new Inac cess ibl e M edi um-V olta ge Cable s Not S ubject to 10 C FR 50.49 Env ironme ntal Qu alifi catio n Requi rements Program to 615 manage aging effects for the electri cal commoditi es that support FRCT operation. The program consists of visual inspections of access ible electrical cables and connections exposed in enclosures, pi ts, manholes, an d pipe trench es for embrittlement, d iscoloratio n, cracking, or surface contaminati on; visua l inspecti ons of manholes, pits, and cab le trenches (l ocated on the FRCT site) for ina ccessible medium-voltage cables, for wa ter collecti on; and vi sual inspe ctions of accessible phase bus, co nnections, an d insulators for melting or other signs of heat effects on the tap e cov ering b us con necti ons, cr acking o f thermop lasti c, or d egradat ion o f insul ators. Phase bus en closure ex ternal surfaces w ill be i nspected by the exis ting structures moni toring program for signs of corrosion. The inaccess ible mediu m-voltage cabl e circuits su pporting the FRCT and the a ssociated manh oles, pits, a nd trenches l ocated on the OCGS site w ill be te sted or inspected by the new Inaccessibl e Mediu m-Voltage Cable s Not Subject to 10 CFR 50
.49 Environmenta l Qualificati on Requirements P rogram for signs of insula tion degradatio n and for prevention of wetted env ironments.
The new combu stion turbine power pl ant - electri cal program wi ll be impl emented before the period of extended operation. Inspec tions of manholes, pits, and trenches located on the FRCT site wi ll be performed a t least once every 2 years for the acc umulation of w ater, and the frequency will be adjusted based on the results obt ained. Cable and connection inspections will be imp lement ed befo re the perio d of ex tended opera tion w ith a frequency of at l east o nce ev ery 10 years.
Accessible phase bus, c onnections, a nd insula tor inspectio ns wil l be performed at least once e very 5 y ears. Phase b us enclosure external surface inspectio ns wil l be performed at the fr eque ncy spe cifi ed i n the stru ctur es mo nito ring prog ram. Inac cess ibl e med ium-vol tage cable circu its and the a ssociated manh ole, pit, an d trench tests an d inspectio ns wil l be performed at the frequenc y spe cified in th e Inac cessi ble M edium-Volta ge Cabl es Not Subje ct to 10 CFR 50.49 Envi ronmen tal Qua lifica tion R equire ments P rogram.The pro ject tea m also revi ewed the l icens e rene wal commit ment li st in Secti on A.5 of the OC GS LRA to confirm tha t this new program wil l be imple mented before the pe riod of extend ed operation, and noted that i t is Item 43 on the list o f commitments.
The project team rev iewed th e UFSAR S upplement, found th at it was consistent w ith the GALL Report, and de termined that i t provides an adequate summary description of the program as ident ified in the SRP-L R UFS AR Su ppleme nt tabl e and as requi red by 10 CF R 54.2 1(d).A7.3.0.3.3.1.7 Conclusio n On the basis o f its audit and review of the applic ant's program, the p roject team found that th e applicant h as demonstrated th at the effects of aging wi ll be ade quately managed.
On the basis o f its review of the UFSAR Supplement for thi s program, the project te am also found that it prov ides an ad equate summary des cription of the program as required by 10 CFR 54.21 (d).A7.3.0.3.3.2 Periodic Inspection Program
- FRCT (B.2.5A)
In the appli cant's respons e to NRC R AI 2.5.1.19-1 rel ated to the OCGS LRA, dated N ovember 11, 2005, Appendix D, Section B.2.05A, the applicant descr ibed OCGS AMP B.2.05A," Periodic Inspec tion P rogram - FRCT."The applican t stated that OCGS A MP B.2.05 is a new program. The Period ic Inspectio n Program - FRCT aging mana gement program wil l address Fo rked River C ombustion Turbin e
616 power pl ant components i n the scope o f license renew al that require periodic mon itoring of aging effe cts , an d a re n ot c ov ere d b y o the r ag in g ma nag eme nt p rog ram s. A cti vi tie s w il l c ons ist of a periodic i nspection of sel ected components to verify i ntegrity and c onfirm the absence of ident ified aging effec ts. The inspe ction s wi ll be condi tion mo nitori ng exa minati ons, i ntende d to assure that existing environmental conditions are not causing material degr adation that could resu lt i n a l oss of in tend ed fu ncti ons. Thi s pro gram i s us ed fo r the foll owi ng:*To confirm change in material prope rties due to a ging is not occu rring in elas tomer expansion joints and flexible connections exposed to fuel oil, indoor air or outdoor air environments
.*To confi rm redu ction of heat transfer due to aging i s not o ccurri ng in h eat ex changer s exposed to indoor air or outdoor ai r environmen ts.*To confirm loss of materia l in va rious steel and stainle ss steel compo nents subject to an intermittent comb ustion turbine exhaust gas environment is monit ored such that there is no loss of compon ent intended functions.
*To confirm loss of material in copper heat exchanger compo nents subject to an indoor air or outdoor ai r environmen t is monitored such that there is no lo ss of component in tended functions.
*To confirm cracking in sta inless stee l components s ubject to intermi ttent combustion turbine ex haust gas env ironment is mon itored such th at there is no loss of componen t intended functio ns.The program elements w ill inc lude (a) dete rmination of appro priate inspe ction sample size, (b)identificatio n of inspection locations, (c) selection of examinati on technique, w ith acceptance criteria, and (d) evalua tion of results to determine the need for additi onal insp ections or oth er correc tive actio ns. The sampl e siz e wi ll be based on as pects s uch as the sp ecific aging e ffect, location, ex isting technic al information, mate rials of construc tion, servi ce enviro nment, or previ ous fai lure h istory. The i nspect ion s amples wil l inc lude locat ions wher e the mo st sev ere aging effec t(s) w ould be ex pected to occ ur. The insp ectio n loc ation s wi ll be based on as pects such as simi larity of materi als of constructio n, fabrication, op erating envi ronment, or aging effect s. Inspection methods may include visual examination, surf ace or volumetric examinatio ns, or other esta blished N on-Destructiv e Examina tion (NDE) te chniques.This program wi ll assess change in materi al propertie s, loss of material , cracking and reduc tion of heat transf er of FRCT mechanical comp onents. For components in the scope of this program, an inspecti on wil l be condu cted to confirm chan ge in material properties, l oss of material, cracking, an d reduction o f heat transfer is not o ccurring, or the agi ng effect is occurring at a rate so as not to affect the compone nt intended function. The program w ill prov ide inspection criteria, require evaluati on of the results of the inspectio ns, and prov ide recomme ndati ons for a dditi onal inspe ction s, as n ecessa ry. In specti ons w ill be sch edule d to coinc ide w ith maj or comb ustio n turbi ne mai ntenan ce in specti ons, w hen th e subje ct comp onents are made access ible. These inspections will be performed on a frequency not to ex ceed once every 10 year
: s. The ini tial inspe ctions a ssociat ed with this progr am will be perf ormed at the next major inspectio n outage for each un it. Based o n the establi shed inspec tion frequency of 10 years, the ne xt inspecti on for CT Unit 1 will be performed by M ay 2014, a nd the nex t inspection for CT Unit 2 w ill be p erformed by Nov ember 2015.
617 The project team reviewed, in whole or in part, the documents listed in Attachment 5 of this audit and revie w report for OCGS A MP B.2.05 A, includi ng the program bases d ocument PBD-A MP-B.05A, ?Perio dic In specti on - F RCT," R evis ion 0 , and i nterv iew ed the appl icant's tec hni cal sta ff.A7.3.0.3.3.2.1 Revi ew o f the OCGS AMP B.2.05 A Agai nst the Program Eleme nts The project team reviewed OCGS AMP B.2.05A against the AMP elements found in SRP-LR, Appendix A.1, Section A.1.2.3 and S RP-LR Table A.1-1. The project te am followed the review ed process as described i n the OCGS audi t and revi ew plan.A7.3.0.3.3.2.1.1 Scope of Program The ?scope of program" program ele ment in Appen dix A.1.2.3
.1 of the SRP-LR recommends that the program scope include the specific structur es and components addressed with this program.The applican t stated in OCGS AMP B.2.0 5A, for the "scope o f program" program element, that the scope of this prog ram includes systems in the scope of license renewal that req uire periodic monito ring of a ging effect s, and are no t cov ered b y oth er ex istin g perio dic mo nitori ng progra ms. Inspec tions wil l be p erformed at susc eptib le lo catio ns in the sy stem.The project team determi ned that the sp ecific components for which th e program manages aging eff ects are identified by the applicant, which satisfies th e criterion as defined in Appendix A.1.2.3.1 of the SRP-LR. On t his basis, the project team f ound that the applicant's proposed program sco pe acceptabl e.A7.3.0.3.3.2.1.2 Preventi}}

Latest revision as of 07:22, 15 January 2025

License Renewal Audit and Review Report for Plant Aging Management Reviews and Programs, Revision 1
ML062280051
Person / Time
Site: Oyster Creek
Issue date: 08/18/2006
From:
Brookhaven National Lab (BNL)
To:
NRC/NRR/ADRO/DLR/RLRC
Matthew Roy, 415-2965, PM, RLRC
Shared Package
ML062300100 List:
References
%dam200612, Job Code J3168
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