audit and review report for plant aging management reviews ... · audit and review report for plant...

Audit and Review Report for

Plant Aging Management Reviews and Programs

Oyster Creek Generating Station (OCGS)Docket No.: 50-219

August 18, 2006

Revision 1

Technical Support Provided and Report Compiled byBrookhaven National Laboratory

Upton, New YorkContract No. JCN J-3168, Task Order 4

Report Prepared forLicense Renewal Branch C

Division of License RenewalOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory Commission

Washington, D.C. 20555-0001

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Table of Contents

Page #

1. Introduction and General Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. Audit and Review Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

3. Aging Management Review Audit and Review Results . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.0 OCGS’s Use of the Generic Aging Lessons-Learned Report . . . . . . . . . . . . . . . 53.0.1 Format of the OCGS License Renewal Application . . . . . . . . . . . . . . . . 5

3.0.1.1 Overview of OCGS LRA Table 1 . . . . . . . . . . . . . . . . . . . 7

3.0.1.2 Overview of OCGS LRA Table 2 . . . . . . . . . . . . . . . . . . . 73.0.2 Audit and Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

3.0.2.1 Review of the OCGS AMPs . . . . . . . . . . . . . . . . . . . . . . . 9

3.0.2.2 Review of the OCGS AMR Results . . . . . . . . . . . . . . . . . 9

3.0.2.3 NRC-Approved Precedents . . . . . . . . . . . . . . . . . . . . . . 10

3.0.2.4 Updated Final Safety Analysis Review Supplement . . . 10

3.0.2.5 Documentation and Documents Reviewed . . . . . . . . . . 10

3.0.2.6 Commitments To Be Included in the Safety EvaluationReport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

3.0.2.7 Exit Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 113.0.3 OCGS Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . 11

3.0.3.1 OCGS AMPs That Are Consistent with the GALL Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

3.0.3.1.1 Thermal Aging and Neutron IrradiationEmbrittlement of Cast Austenitic Stainless Steel(OCGS AMP B.1.10) . . . . . . . . . . . . . . . . . . . . . 17

3.0.3.1.2 Flow-Accelerated Corrosion (OCGS AMP B.1.11). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

3.0.3.1.3 Compressed Air Monitoring (OCGS AMP B.1.17). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

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3.0.3.1.4 One-Time Inspection (OCGS AMP B.1.24) . . . . 24

3.0.3.1.5 Selective Leaching of Materials (OCGS AMPB.1.25) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

3.0.3.1.6 10 CFR Part 50, Appendix J (OCGS AMP B.1.29). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

3.0.3.1.7 Masonry Wall Program (OCGS AMP B.1.30) . . . 45

3.0.3.1.8 Protective Coating Monitoring and MaintenanceProgram (OCGS AMP B.1.33) . . . . . . . . . . . . . . 47

3.0.3.1.9 Electrical Cables and Connections Not Subject to10 CFR 50.49 Environmental QualificationRequirements (OCGS AMP B.1.34) . . . . . . . . . . 57

3.0.3.1.10 Inaccessible Medium-Voltage Cables Not Subjectto 10 CFR 50.49 Environmental QualificationRequirements (OCGS AMP B.1.36) . . . . . . . . . . 60

3.0.3.1.11 Environmental Qualification Program (OCGS AMPB.3.2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64

3.0.3.2 OCGS AMPs That Are Consistent with the GALL Reportwith Exceptions and/or Enhancements . . . . . . . . . . . . . 66

3.0.3.2.1 ASME Section XI Inservice Inspection, SubsectionsIWB, IWC, AND IWD (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 Studs (OCGS AMP B.1.3). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90

3.0.3.2.4 BWR Vessel ID Attachment Welds (OCGS AMPB.1.4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93

3.0.3.2.5 BWR Feedwater Nozzle (OCGS AMP B.1.5) . . . 97

3.0.3.2.6 BWR Control Rod Drive Return Line Nozzle(OCGS AMP B.1.6) . . . . . . . . . . . . . . . . . . . . . 103

3.0.3.2.7 BWR Stress Corrosion Cracking (OCGS AMPB.1.7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109

3.0.3.2.8 BWR Penetrations (OCGS AMP B.1.8) . . . . . . 115

3.0.3.2.9 BWR Vessel Internals (OCGS AMP B.1.9) . . . 119

3.0.3.2.10 Bolting Integrity (OCGS AMP B.1.12) . . . . . . . 119

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3.0.3.2.11 Open-Cycle Cooling Water System (OCGS AMPB.1.13) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 124

3.0.3.2.12 Close-Cycle Cooling Water System (OCGS AMPB.1.14) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 131

3.0.3.2.13 Boraflex Rack Management Program (OCGS AMPB.1.15) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 135

3.0.3.2.14 Inspection of Overhead Heavy Load and LightLoad (Related to Refueling) Handling Systems(OCGS AMP B.1.16) . . . . . . . . . . . . . . . . . . . . 138

3.0.3.2.15 BWR Reactor Water Cleanup System (OCGS AMPB.1.18) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144

3.0.3.2.16 Fire Protection (OCGS AMP B.1.19) . . . . . . . . 149

3.0.3.2.17 Fire Water System (OCGS AMP B.1.20) . . . . . 158

3.0.3.2.18 Aboveground Outdoor Tanks (OCGS AMP B.1.21). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 165

3.0.3.2.19 Fuel Oil Chemistry (OCGS AMP B.1.22) . . . . . 169

3.0.3.2.20 Reactor Vessel Surveillance (OCGS AMP B.1.23). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 192

3.0.3.2.21 Buried Piping Inspection (OCGS AMP B.1.26). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 192

3.0.3.2.22 ASME Section XI, Subsection IWE (OCGS AMPB.1.27) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 199

3.0.3.2.23 ASME Section XI, Subsection IWF (OCGS AMPB.1.28) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 238

3.0.3.2.24 Structure Monitoring Program (OCGS AMP B.1.31). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 244

3.0.3.2.25 RG 1.127, Inspection of Water-Control StructuresAssociated with Nuclear Power Plants (OCGS AMPB.1.32) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 260

3.0.3.2.26 Electrical Cables and Connections Not Subject to10 CFR 50.49 Environmental QualificationRequirements Used in Instrument Circuits (OCGSAMP B.1.35) . . . . . . . . . . . . . . . . . . . . . . . . . . 271

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3.0.3.2.27 Metal Fatigue of Reactor Coolant PressureBoundary (OCGS AMP B.3.1) . . . . . . . . . . . . . 276

3.0.3.3 OCGS AMPs That Are Not Consistent with the GALLReport or Not Addressed in the GALL Report . . . . . . . 282

3.0.3.3.1 Periodic Testing of Containment Spray Nozzles(OCGS AMP B.2.1) . . . . . . . . . . . . . . . . . . . . . 282

3.0.3.3.2 Lubricating Oil Monitoring Activities (OCGS AMPB.2.2) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 282

3.0.3.3.3 Generator Stator Water Chemistry Activities(OCGS AMP B.2.3) . . . . . . . . . . . . . . . . . . . . . 282

3.0.3.3.4 Periodic Inspection of Ventilation Systems (OCGSAMP B.2.4) . . . . . . . . . . . . . . . . . . . . . . . . . . . 283

3.0.3.3.5 Periodic Inspection Program (OCGS AMP B.2.5). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 283

3.0.3.3.6 Wooden Utility Pole Program (OCGS AMP B.2.6). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 283

3.0.3.3.7 Periodic Monitoring of Combustion Turbine PowerPlant (OCGS AMP B.2.7) . . . . . . . . . . . . . . . . . 283

3.1 OCGS LRA Section 3.1 – Aging Management of Reactor Vessel, Internals, andReactor Coolant Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2833.1.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 2833.1.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 284

3.1.2.1 AMR Results That Are Consistent with The GALL Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 293

3.1.2.1.1 Cracking Due to Thermal and Mechanical Loadingin Class 1 Small Bore Piping . . . . . . . . . . . . . . 293

3.1.2.1.2 Cracking Due to Stress Corrosion Cracking andIntergranular Stress Corrosion Cracking . . . . . 294

3.1.2.1.3 Cracking Due to IASCC of Top Guide . . . . . . . 296

3.1.2.1.4 Cracking Due to IASCC of Core Shroud . . . . . 297

3.1.2.1.5 Cracking Due to SCC, IGSCC, AND IASCC ofCore Spray Spargers . . . . . . . . . . . . . . . . . . . . 298

3.1.2.1.6 Cracking Due to SCC of CRD Stub Tubes . . . . 299

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3.1.2.1.7 Cracking Due to IASCC of In-Core Neutron MonitorDry Tubes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 301

3.1.2.1.8 Cracking Due to SCC, IGSCC, and Cyclic Loadingof Vessel Drain Nozzle . . . . . . . . . . . . . . . . . . . 302

3.1.2.1.9 Cracking Due to SCC, IGSCC, and Cyclic Loadingof Valve Bodies . . . . . . . . . . . . . . . . . . . . . . . . 302

3.1.2.1.10 Loss of Material Due to General Corrosion ofExternal Surface or Carbon and Low Alloy SteelComponents . . . . . . . . . . . . . . . . . . . . . . . . . . 303

3.1.2.1.11 Loss of Material Due to Pitting and CreviceCorrosion in Stainless Steel and Nickel-AlloyReactor Vessel Internals Components . . . . . . . 304

3.1.2.1.12 Reduction of Heat Transfer Due to Fouling . . . 304

3.1.2.2 AMR Results For Which Further Evaluation IsRecommended By The GALL Report . . . . . . . . . . . . . 305

3.1.2.2.1 Cumulative Fatigue Damage . . . . . . . . . . . . . . 305

3.1.2.2.2 Loss of Material Due to General, Pitting, andCrevice Corrosion . . . . . . . . . . . . . . . . . . . . . . 306

3.1.2.2.3 Loss of Fracture Toughness Due to NeutronIrradiation Embrittlement . . . . . . . . . . . . . . . . . 311

3.1.2.2.4 Cracking Due to Stress Corrosion Cracking andIntergranular Stress Corrosion Cracking . . . . . 312

3.1.2.2.5 Crack Growth Due to Cyclic Loading . . . . . . . . 315

3.1.2.2.6 Loss of Fracture Toughness Due to NeutronIrradiation Embrittlement and Void Swelling . . . 315

3.1.2.2.7 Cracking Due to Stress Corrosion Cracking . . . 315

3.1.2.2.8 Cracking Due to Cyclic Loading . . . . . . . . . . . . 316

3.1.2.2.9 Loss of Preload Due to Stress Relaxation . . . . 316

3.1.2.2.10 Loss of Material Due to Erosion . . . . . . . . . . . . 317

3.1.2.2.11 Cracking Due to Flow-Induced Vibration . . . . . 317

3.1.2.2.12 Cracking Due to Stress Corrosion Cracking andIrradiation-Assisted Stress Corrosion Cracking(IASCC) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 318

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3.1.2.2.13 Cracking Due to Primary Water Stress CorrosionCracking (PWSCC) . . . . . . . . . . . . . . . . . . . . . 318

3.1.2.2.14 Wall Thinning Due to Flow-Accelerated Corrosion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 318

3.1.2.2.15 Changes in Dimensions Due to Void Swelling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 318

3.1.2.2.16 Cracking Due to Stress Corrosion Cracking andPrimary Water Stress Corrosion Cracking . . . . 318

3.1.2.2.17 Cracking Due to Stress Corrosion Cracking,Primary Water Stress Corrosion Cracking, andIrradiation-Assisted Stress Corrosion Cracking

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 319

3.1.2.2.18 Quality Assurance for Aging Management of Non-safety-Related Components . . . . . . . . . . . . . . 319

3.1.2.3 AMR Results That Are Not Consistent With The GALLReport Or Not Addressed In The GALL Report . . . . . . 319

3.1.2.3.1 Aging Effects/mechanisms in Table 3.1.1 That AreNot Applicable for OCGS . . . . . . . . . . . . . . . . . 320

3.1.2.3.2 Reactor Vessel, Internals, and Reactor CoolantSystems AMR Line Items That Have No AgingEffect (OCGS LRA Tables 3.1.2.1.1 Through3.1.2.1.6) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 322

3.1.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 323

3.2 OCGS LRA Section 3.2 – Aging Management of Engineered Safety Features. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 323

3.2.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 3233.2.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 324


3.2.2.1.1 Loss of Material Due to General Corrosion onInternal and External Surfaces Exposed to Air andMoisture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 333

3.2.2.1.2 Loss of Material Due to General, Pitting, Crevice,and Microbiologically Influenced Corrosion SteelContainment Isolation Components ExposedInternally to Untreated Water . . . . . . . . . . . . . . 335

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3.2.2.1.3 General, Pitting, Crevice, and MicrobiologicallyInfluenced Corrosion and Fouling in Stainless SteelContainment Isolation Component Exposed to Rawor Untreated Water . . . . . . . . . . . . . . . . . . . . . 336

3.2.2.1.4 General, Pitting, Crevice, and MicrobiologicallyInfluenced Corrosion and Fouling in SteelContainment Isolation Component Exposed to RawWater . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 336

3.2.2.1.5 Loss of Material Due to General Corrosion ofExternal Surface of Carbon and Low Alloy SteelComponents . . . . . . . . . . . . . . . . . . . . . . . . . . 337

3.2.2.1.6 Loss of Material Due to General, Pitting andCrevice Corrosion . . . . . . . . . . . . . . . . . . . . . . 337



3.2.2.2.2 Loss of Material due to Cladding . . . . . . . . . . . 339

3.2.2.2.3 Loss of Material Due to Pitting and CreviceCorrosion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 339


3.2.2.2.5 Hardening and Loss of Strength Due to ElastomerDegradation . . . . . . . . . . . . . . . . . . . . . . . . . . . 345

3.2.2.2.6 Loss of Material Due to Erosion . . . . . . . . . . . . 346

3.2.2.2.7 Loss of Material Due to General, Pitting, Crevice,and Microbiologically Influenced Corrosion, andFouling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 346

3.2.2.2.8 Loss of Material Due to General, Pitting andCrevice Corrosion . . . . . . . . . . . . . . . . . . . . . . 346

3.2.2.2.9 Loss of Material Due to General, Pitting, Crevice,and Microbiologically Influenced Corrosion . . . 349

3.2.2.2.10 Quality Assurance for Aging Management of Non-Safety-Related Components . . . . . . . . . . . . . . 350


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3.2.2.3.1 Aging Effect/mechanism in Table 3.2.1 That AreNot Applicable for OCGS . . . . . . . . . . . . . . . . . 351

3.2.2.3.2 Engineered Safety Features AMR Line Items ThatHave No Aging Effect (OCGS LRA Tables3.2.2.1.1 Through 3.2.2.1.3)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3553.2.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 357

3.3 OCGS LRA Section 3.3 – Aging Management of Auxiliary Systems . . . . . . . 3573.3.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 3583.3.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 359



3.3.2.1.2 Cracking Initiation and Growth Due to Thermal andMechanical Loading . . . . . . . . . . . . . . . . . . . . . 378


3.3.2.1.4 Cracking Initiation and Growth Due to StressCorrosion Cracking . . . . . . . . . . . . . . . . . . . . . 378

3.3.2.1.5 Components Exposed to Dry Air with No AgingEffect Identified . . . . . . . . . . . . . . . . . . . . . . . . 380


3.3.2.1.7 Loss of Preload Due to Stress Relaxation . . . . 385

3.3.2.1.8 Loss of Material Due to Pitting, Crevice, andGalvanic Corrosion . . . . . . . . . . . . . . . . . . . . . 385

3.3.2.1.9 Loss of Material Due to Pitting, Crevice, andMicrobiologically Influenced Corrosion, and Fouling

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 386

3.3.2.1.10 Loss of Material Due to General Corrosion . . . 387



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3.3.2.2.4 Cracking Due to Stress Corrosion Cracking andCyclic Loading . . . . . . . . . . . . . . . . . . . . . . . . . 396


3.3.2.2.6 Reduction of Neutron-Absorbing Capacity and Lossof Material Due to General Corrosion . . . . . . . 399


3.3.2.2.8 Loss of Material Due to General, Pitting, Crevice,and Microbiologically- Influenced Corrosion (MIC)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 403

3.3.2.2.9 Loss of Material Due to General, Pitting, Crevice,Microbiologically Influenced Corrosion and Fouling

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 406


3.3.2.2.11 Loss of Material Due to Pitting, Crevice, andGalvanic Corrosion for Copper Alloy Exposed toTreated Water . . . . . . . . . . . . . . . . . . . . . . . . . 415

3.3.2.2.12 Loss of Material Due to Pitting, Crevice, andMicrobiologically Influenced Corrosion . . . . . . . 416

3.3.2.2.13 Loss of Material Due to Wear . . . . . . . . . . . . . 418

3.3.2.2.14 Loss of Material Due to Cladding Breach . . . . . 419

3.3.2.2.15 Quality Assurance for Aging Management of Non-Safey-Related Components . . . . . . . . . . . . . . . 419


3.3.2.3.1 Aging Effects/mechanisms in Table 3.3.1 That AreNot Applicable for OCGS . . . . . . . . . . . . . . . . . 420

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3.3.2.3.2 Auxiliary Systems AMR Line Items That Have NoAging Effect (OCGS LRA Tables 3.3.2.1.1 Through3.3.2.1.41) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 422

3.3.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 425

3.4 OCGS LRA Section 3.4 – Aging Management of Steam and Power ConversionSystem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4253.4.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 4263.4.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 426





3.4.2.2.3 Loss of Material Due to General, Pitting, Crevice,and Microbiologically- Influenced Corrosion andFouling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 439





3.4.2.2.8 Loss of Material Due to Pitting, Crevice, andMicrobiologically Influenced Corrosion . . . . . . . 444

3.4.2.2.9 Loss of Material Due to General, Pitting, Crevice,and Galvanic Corrosion . . . . . . . . . . . . . . . . . . 444



3.4.2.3.1 Aging Effect/Mechanism in Table 3.4.1 That AreNot Applicable for OCGS . . . . . . . . . . . . . . . . . 446

xi

3.4.2.3.2 Steam and Power Conversion System AMR LineItems That Have No Aging Effect (OCGS LRATables 3.4.2.1.1 Through 3.4.2.1.7) . . . . . . . . . 450

3.4.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 451

3.5 OCGS LRA Section 3.5 – Aging Management of Primary Containment,Structures, Component Supports, and Piping and Component Insulation . . . 4513.5.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 4523.5.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 452


3.5.2.1.1 Stress Corrosion Cracking of High Strength LowAlloy Bolting Materials (Item 3.5.1-51) . . . . . . . 465

3.5.2.1.2 Degradation of Group 6 Elastomer Seals, Gaskets,and Moisture Barriers (Item 3.5.1-44) . . . . . . . 465

3.5.2.1.3 Lock-up Due to Wear of Radial Beam Seats inBWR Drywell (Item 3.5.1-30) . . . . . . . . . . . . . . 466

3.5.2.1.4 No Aging Effect for Steel (All Types) and Aluminumin a ?Concrete” Environment . . . . . . . . . . . . . . 466

3.5.2.1.5 No Aging Effect for Stainless and Galvanized Steeland Aluminum in a ?Indoor-Air” or ?Containment-Atmosphere” Environment . . . . . . . . . . . . . . . . 466

3.5.2.1.6 Loss of Preload in Structural Bolting . . . . . . . . 467

3.5.2.1.7 AMR Result for Class MC Pressure RetainingBolting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 467

3.5.2.1.8 Loss of Mechanical Function for Stainless andGalvanized Steel and Aluminum ASME Class 1,2,3and MC Supports (Item 3.5.1-58, Item 3.5.1-59,LRA Table 3.5.2.1.18) . . . . . . . . . . . . . . . . . . . 467


3.5.2.2.1 PWR and BWR Containments . . . . . . . . . . . . . 468

3.5.2.2.2 Safety-Related and Other Structures andComponent Supports . . . . . . . . . . . . . . . . . . . . 476


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3.5.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 494

3.6 OCGS LRA Section 3.6 – Aging Management of Electrical Components . . . 4943.6.1 Summary of Technical Information in the Application . . . . . . . . . . . . . 4943.6.2 Project Team Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 495



3.6.2.2.1 Electrical Equipment Subject to EnvironmentalQualification . . . . . . . . . . . . . . . . . . . . . . . . . . . 499

3.6.2.2.2 Degradation of Insulator Quality Due to Presenceof Any Salt Deposits and Surface Contamination,and Loss of Material Due to Mechanical Wear

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 499

3.6.2.2.3 Loss of Material Due to Wind Induced Abrasionand Fatigue, Loss of Conductor Strength Due toCorrosion, an Increased Resistance of ConnectionDue to Oxidation or Loss of Pre-load . . . . . . . . 500



3.6.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 500

ATTACHMENT 1: LIST OF ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 501

ATTACHMENT 2: PROJECT TEAM AND APPLICANT PERSONNEL; PUBLIC EXIT MEETING ATTENDEES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 503

ATTACHMENT 3: AGING MANAGEMENT PROGRAM ELEMENT DESCRIPTIONS . . . . . . 506

ATTACHMENT 4: SUMMARY OF LRA AUDIT OPEN ITEMS . . . . . . . . . . . . . . . . . . . . . . . 507

ATTACHMENT 5: LIST OF DOCUMENTS REVIEWED . . . . . . . . . . . . . . . . . . . . . . . . . . . . 508

ATTACHMENT 6: LIST OF COMMITMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 528

ATTACHMENT 7 FORKED RIVER COMBUSTION TURBINES, RADIO COMMUNICATION SYSTEMS,AND METEOROLOGICAL TOWER LICENSE RENEWAL AUDIT AND REVIEW . . 550

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Tables

Page #

Table 3.0.3-1 OCGS Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Table 3.1-1 Project Team’s Evaluation for LRA Section 3.1 – Reactor Vessel, Internals, andReactor Coolant Systems Components in the GALL Report . . . . . . . . . . . . . 285

Table 3.2-1 Staff Evaluation for Engineered Safety Features Components in the GALLReport . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 325

Table 3.3-1 Staff Evaluation for Auxiliary System Components in the GALL Report . . . . . 359

Table 3.4-1 Staff Evaluation for Steam and Power Conversion System Components in theGALL Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 427

Table 3.5-1 Staff Evaluation for Containment, Structures, Component Supports, and Pipingand Component Insulation in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . 453

Table 3.6-1 Staff Evaluation for Electrical Components in the GALL Report . . . . . . . . . . . 495

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Audit and Review Report for Plant Aging Management Reviews and ProgramsFor Oyster Creek Generating Station

1. Introduction and General Information

1.1 Introduction

By letter dated July 22, 2005 (Agencywide Documents Access and Management System[ADAMS] ADAMS Accession Number ML0520800480), AmerGen Energy Company, LLC,(AmerGen, the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) itsapplication for renewal of Facility Operating License No. DPR-16 for Oyster Creek GeneratingStation (ADAMS Accession Number ML052080185). The applicant requested renewal of itsoperating license for an additional 20 years beyond the 40-year current license term.

In support of the staff’s safety review of the license renewal application (LRA) for Oyster CreekGenerating Station (OCGS), the License Renewal Branch C (RLRC) led a project team thataudited and reviewed selected aging management reviews (AMRs) and associated agingmanagement programs (AMPs) developed by the applicant to support the LRA for OCGS. Theproject team included both NRC staff and contractor personnel provided by BrookhavenNational Laboratory (BNL), the RLRC technical contractor. Attachment 2 lists the project teammembers, as well as other NRC staff and BNL personnel who supported the project team’saudit and review.

The project team performed its work in accordance with the requirements of Title 10 of theCode of Federal Regulations (CFR), Part 54 (10 CFR Part 54), Requirements for Renewal ofOperating Licenses for Nuclear Power Plants; the guidance provided in Revision 1 ofNUREG-1800, Standard Review Plan for Review of License Renewal Applications for NuclearPower Plants (SRP-LR); and the guidance provided in Revision 1 of NUREG-1801, GenericAging Lessons Learned (GALL) Report, (GALL Report).

Details of how the project team implemented these requirements and guidance are found in “Audit and Review Plan for Plant Aging Management Reviews and Programs - Oyster CreekGenerating Station,” Revision 1, Docket No. 50-219, (ADAMS Accession NumberML060200084) (OCGS audit and review plan).

This audit and review report documents the results of the project team’s audit and review work.The project team performed its work at NRC Headquarters, Rockville, Maryland; at BrookhavenNational Laboratory offices in Upton, New York; and at the applicant’s offices (OCGS site) inForked River, New Jersey. The project team conducted on-site visits during the weeks ofOctober 3, 2005, January 23, 2006, February 13, 2006, and April 19, 2006. The project teamconducted a public exit meeting at the Lacey Township Municipal Building in Forked River, NewJersey, on April 20, 2006. Attachment 2 lists the applicant personnel and other individualscontacted by the project team in support of the work documented in this audit and reviewreport. It also lists those attending the public exit meeting.

1.2 Background

In 10 CFR 54.4, the scope of license renewal is defined as those systems, structures, andcomponents (SSCs) (1) that are safety-related, (2) whose failure could affect safety-relatedfunctions, or (3) that are relied on to demonstrate compliance with NRC regulations for fireprotection, environmental qualification, pressurized thermal shock, anticipated transientswithout scram, and station blackout. An applicant for a renewed license must review all SSCs

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within the scope of license renewal to identify those structures and components (SCs) subjectto an AMR. SCs subject to an AMR are those that perform an intended function without movingparts or without a change in configuration or properties, and that are not subject to replacementbased on qualified life or specified time period. Pursuant to 10 CFR 54.21(a)(3), an applicantfor a renewed license must demonstrate that the effects of aging will be managed in such a waythat the intended function or functions of those SCs will be maintained for the period ofextended operation.

In addition, 10 CFR 54.21(d) requires that the applicant submit a supplement to the Final SafetyAnalysis Report (FSAR) that contains a summary description of the programs and activities formanaging the effects of aging.

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALLReport is a technical bases document. It summarizes staff-approved AMPs for the aging of alarge number of SCs that are subject to an AMR. It summarizes the aging managementevaluations, programs, and activities credited for managing aging for most of the SCs used bycommercial nuclear power plants, and serves as a reference for both the applicant and staffreviewers to quickly identify those AMPs and activities that the staff have determined willprovide adequate aging management during the period of extended operation. If an applicantcommits to implementing these staff-approved AMPs, the time, effort, and resources used toreview an applicant’s LRA will be greatly reduced, thereby improving the efficiency andeffectiveness of the license renewal review process. The GALL Report identifies (1) SSCs, (2)component materials, (3) environments to which the components are exposed, (4) agingeffects/aging mechanisms associated with the materials and environments, (5) AMPs that arecredited with managing the aging effects, and (6) recommendations for further applicantevaluations of aging effects and their management for certain component types.

The GALL Report is treated in the same manner as an NRC-approved topical report that isgenerically applicable. An applicant may reference the GALL Report in its LRA to demonstratethat its programs correspond to those that the staff reviewed and approved in the GALL Report. If the material presented in the LRA is consistent with the GALL Report and is applicable to theapplicant’s facility, the staff will accept the applicant’s reference to the GALL Report. In makingthis determination, the staff considers whether the applicant has identified specific programsdescribed and evaluated in the GALL Report but does not conduct a review of the substance ofthe matters described in the GALL Report. Rather, the staff determines that the applicantestablished that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL Report program, it is incumbent on the applicant toensure that its plant program addresses all ten program elements of the referenced GALLReport program. These elements are described in the SRP-LR, Appendix A.1, “AgingManagement Review - Generic (Branch Technical Position RLSB-1).” In addition, theconditions at the plant must be bounded by the conditions for which the GALL Report programwas evaluated. The applicant must certify in its LRA that it completed the appropriateverifications and that those verifications are documented and retained by the applicant in anauditable form.

2. Audit and Review Scope

The AMRs and associated AMPs that the project team reviewed are identified in the OCGSaudit and review plan. The project team examined 49 of the OCGS AMPs, including 11 AMPsfor the Forked River Combustion Turbine (FRCT), and associated AMRs. The FRCT AMPs

1Table 2 provides detailed results of the AMRs for those components identified in the LRA Section 2 as

being subject to an AMR.

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and AMRs are addressed in Attachment 7 to this audit and review report. The project teamreviewed AMPs and AMRs that the applicant claimed were consistent with the GALL Report,and AMRs for which further evaluation is recommended by the GALL Report. The project teamalso reviewed certain plant-specific AMPs.

The applicant noted that some of its AMPs, although described as consistent with the GALLReport, contain some deviations from the GALL Report. These deviations are of two types:

• exceptions to the GALL Report - exceptions are specified to GALL Report recommendations that the applicant does not intend to implement.

• enhancements - enhancements include those actions/activities necessary to (1) ensureconsistency with GALL Report AMP recommendations, or (2) provide additional featuresto the program or program activities that the applicant will implement prior to the periodof extended operation. Enhancements may expand, but not reduce, the scope of anAMP.

The project team’s audit and review activities for the OCGS AMPs, and its conclusionsregarding these reviews, are documented in Sections 3.0.3 of this audit and review report.

The project team reviewed all OCGS LRA Table 21 AMR line-items in Chapter 3, except thosethat were assigned to the Office of Nuclear Reactor Regulation (NRR), Division of Engineering(DE) staff. Those the project team reviewed were either consistent with the GALL Report, asidentified by Notes A through E in OCGS LRA Table 3.X.2-Y (from Column 9 of the Table 2sdiscussed in Section 3.0.1 of this audit and review report), or reviewed and accepted by theproject team on the basis of an NRC-approved precedent (see Section 3.0.2.3 of this audit andreview report).

The project team determined that the AMR results, reported by the applicant to be consistentwith the GALL Report, are consistent with the GALL Report. The project team also determinedthat the plant-specific AMR results reported by the applicant are technically acceptable andapplicable. For AMR results for which the GALL Report recommends further evaluation, theproject team reviewed the applicant's evaluation and determined that it adequately addressesthe issues for which the GALL Report recommends further evaluation.

The AMR results that are within the scope of the project team’s audit are identified inAppendix D of the OCGS audit and review plan. The AMR result line-items reviewed by theproject team in Chapter 3 of the OCGS LRA Tables 3.X.2-Y were either consistent with theGALL Report or justified by the applicant on the basis of an NRC-approved precedent.

In the OCGS LRA, Tables 3.X.2-Y, in addition to the notes, the applicant provided a summaryof AMR results for the applicable systems, which included the SCs, associated materials,environment, any aging effects requiring management, and an AMP for each line-item. Thenotes describe how the information in the tables aligns with the information in the GALL Report. Those that are aligned with the GALL Report are assigned letters and are described below. Those defined by the applicant are assigned numbers and are defined in the OCGS LRA.

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Note A indicates that the OCGS AMR line-item is consistent with the GALLReport for component, material, environment, and aging effect. In addition, theOCGS AMP is consistent with the AMP identified in the GALL Report.

Note B indicates that the OCGS AMR line-item is consistent with the GALLReport for component, material, environment, and aging effect. In addition, theOCGS AMP takes some exceptions to the AMP identified in the GALL Report. The project team determined that the identified exceptions to the GALL ReportAMPs are acceptable.

Note C indicates that the component for the OCGS AMR line-item is different,but consistent with the GALL Report for material, environment, and aging effect.This note indicates that the applicant was unable to find a listing of some systemcomponents in the GALL Report. However, the applicant identified a differentcomponent in the GALL Report that had the same material, environment, agingeffect, and AMP as the component that was under review. The project teamdetermined that the OCGS AMR line-item of the different component wasapplicable to the component under review.

Note D indicates that the component for the OCGS AMR line-item is different,but consistent with the GALL Report for material, environment, and aging effect. In addition, the OCGS AMP takes some exceptions to the AMP identified in theGALL Report. The project team reviewed these line-items to confirmconsistency with the GALL Report. The project team determined that the OCGSAMR line-item for the different component was applicable to the componentunder review. The project team determined that the identified exceptions to theGALL Report AMPs are acceptable.

Note E indicates that the OCGS AMR line-item is consistent with the GALLReport for material, environment, and aging effect, but a different AMP iscredited. The project team evaluated these line-items to determine that the AMPcredited by the applicant is applicable.

Note F indicates that the material is not in the GALL Report for the identifiedcomponent.

Note G indicates that the environment is not in the GALL Report for the identifiedcomponent and material.

Note H indicates that the aging effect is not in the GALL Report for component,material, and environment combination.

Note I indicates that the aging effect in the GALL Report for the identifiedcomponent, material, and environment combination is not applicable.

Note J indicates that neither the identified component nor the material andenvironment combination is evaluated in the GALL Report.

Discrepancies or issues discovered by the project team during the audit and review thatrequired a response are documented in this audit and review report. If resolution of an issuewas not resolved prior to issuing this audit and review report, a request for additional

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information (RAI) was prepared by the project team to solicit the information needed todisposition the issue. The RAI will be included and dispositioned in the safety evaluation report(SER) related to the OCGS LRA. The list of RAIs associated with the audit and review report isprovided in Attachment 4 to this audit and review report.

The project team conducted an audit and review of the information provided in the OCGS LRAand program bases documents, which are available at the applicant’s office, and throughinterviews with OCGS technical staff. The project team determined that the applicable agingeffects were identified, the appropriate combination of materials and environments were listed,and acceptable AMPs were specified.

The AMR results review of OCGS LRA Sections 3.1 through 3.6 reviewed by the project teamare provided in Sections 3.1 through 3.6 of this audit and review report.

3. Aging Management Review Audit and Review Results

This section of the audit and review report contains the project team’s evaluation of the OCGSAMPs and AMRs. In OCGS LRA Appendix B, the applicant described the AMPs that it relies onto manage or monitor the aging of long-lived, passive components and structures.

In OCGS LRA Section 3, the applicant provided the results of the AMRs for those structuresand components that it identifies in OCGS LRA Section 2 as being within the scope of licenserenewal and subject to an AMR.

3.0 OCGS’s Use of the Generic Aging Lessons-Learned Report

In preparing its OCGS LRA, AmerGen credited the GALL Report. The GALL Report containsthe staff’s generic evaluation of the existing plant programs, and it documents the technicalbasis for determining where existing programs are adequate without modification, and whereexisting programs should be augmented for the extended period of operation. The evaluationresults documented in the GALL Report indicate that many of the existing programs areadequate to manage the aging effects for particular structures or components for licenserenewal without change. The GALL Report also contains recommendations on specific areasfor which existing programs should be augmented for license renewal. OCGS references theGALL Report in its LRA to demonstrate that the programs at its facility correspond to thoserecommended in the GALL Report.

3.0.1 Format of the OCGS License Renewal Application

The OCGS LRA closely follows the standard LRA format presented in Nuclear Energy Institute(NEI) guidance, NEI 95-10, Industry Guideline for Implementing the Requirements of10 CFR Part 54 – The License Renewal Rule, Revision 5.

The organization of Section 3 of the OCGS LRA parallels Chapter 3 of the SRP-LR. Section 3of the OCGS LRA provides the results of the AMRs for SCs that the applicant identified assubject to an AMR. Organization of this section is based on Tables 1 through 6 of Volume 1 ofNUREG-1801, draft dated January 2005, and Chapter 3, “Aging Management Review Results,”of NUREG-1800, draft dated January 2005. The use of the draft January 2005 GALL Report isin accordance with the January 13, 2005 meeting between the NRC and NEI on updatinglicense renewal guidance documents, as summarized and documented in a meeting summarydated February 17, 2005 (ADAMS Accession Number ML050490142).

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In AmerGen letter 2130-06-20293 dated March 30, 2006 (ML060950408), the applicantsummarized the results of its reconciliation of the Oyster Creek license renewal application withthe guidance contained in the September 2005 Revision 1 NUREG-1800 and NUREG-1801documents. The applicant provided details of this reconciliation in its reconciliation document,“Reconciliation of Program and Line Item Differences Between January 2005 DraftNUREG-1801 and September 2005 Revision 1 NUREG-1801,” Revision 1, (ML060870123). Inits reconciliation document, the applicant identified and reconciled differences between the draftJanuary 2005 GALL AMP and AMR line items used in the Oyster Creek LRA, with those in theSeptember 2005 Revision 1 GALL Report. This reconciliation document was reviewed as partof this audit, and was treated as an extension of the Oyster Creek license renewal applicationfor purposes of this audit.

OCGS LRA Tables 3.0-1 and 3.0-2, provide descriptions of the internal and external serviceenvironments that were used in the aging management reviews to determine aging effectsrequiring management. OCGS LRA Table 3.0-3 provides descriptions of the passivecomponent materials, and Table 3.0-4 provides descriptions of aging effects. This table alsoprovides the equivalent GALL Report aging effects.

The results of the AMRs are presented in two table types. The first table type is Table 3.X.1(Table 1), where the “3" indicates the table pertaining to the Chapter 3 AMR; the ?X” indicatesthe table number from Volume 1 of the GALL Report (see the definition table below), and the 1indicates that this is the first table type (Table 1) in Section 3.X. For example, in the reactorvessel, internals, and reactor coolant systems subsection, this is Table 3.1.1, and in theengineered safety features subsection, this is Table 3.2.1.

Definition Table

X Definition

1 Reactor Vessel, Internals, and Reactor Coolant Systems

2 Engineered Safety Features

3 Auxiliary Systems

4 Steam and Power Conversion System

5 Containment, Structures, Component Supports, and Piping andComponent Insulation

6 Electrical Components

The second table type is Table 3.X.2-Y, (Table 2) where “3" again indicates the OCGS LRAsection number; “X” again indicates the table number from Volume 1 of the GALL Report; the“2" indicates that this is the second table type (Table 2) in Section 3.X; and “Y” indicates thesystem table number. For example, within the reactor vessel, internals, and reactor coolantsystems subsection, the AMR results for the Isolation Condenser System are presented inTable 3.1.2.1.1, and the results for the Nuclear Boiler Instrumentation System are inTable 3.1.2.1.2. In the engineered safety features subsection, the containment spray system results are presented in Table 3.2.2.1.1, and the Core Spray System results are inTable 3.2.2.1.2.

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The applicant compared the OCGS AMR results with information in the tables of the GALLReport and provided the results of its comparisons in two table types that correspond to the twotable types described above.

3.0.1.1 Overview of OCGS LRA Table 1

OCGS LRA Table 1 provides a summary comparison of how the OCGS AMR results align withthe corresponding tables of the GALL Report. OCGS LRA Table 1 consists of the followingcolumns: “Item Number,” “Component,” “Aging Effect/Mechanism,” “AMPs,” “FurtherEvaluation Recommended” and “Discussion.” These OCGS LRA tables have the same formatand are essentially the same as Tables 1 through 6 of the GALL Report, Volume 1, except thatthe “ID” and “Type” columns of the GALL Report tables were replaced by an “Item Number”column and the ?Related Generic Item” and “Unique Item” columns of the GALL Report tableswere replaced by a “Discussion” column. The “Discussion” column includes furtherclarifying/amplifying information. The following are examples of information that are containedwithin the “Discussion” column:

(1) information on further evaluation required or reference to the location ofthat information

(2) the name of a plant-specific program being used

(3) exceptions to the GALL Report assumptions

(4) a discussion of how the line-item is consistent with the correspondingline-item in the GALL Report

(5) a discussion of how the line-item differs from the corresponding line-itemin the GALL Report, when it may appear to be consistent

3.0.1.2 Overview of OCGS LRA Table 2

The OCGS LRA Table 3.X.2-Y (Table 2) provides the detailed results of the AMRs for thosecomponents identified in OCGS LRA Section 2 as being subject to an AMR. There is a Table 2for each of the components or systems within a system grouping (e.g., Reactor Vessel,Internals, and Reactor Coolant Systems, Engineered Safety Features, Auxiliary Systems, etc.).For example, the Engineered Safety Features system group contains tables specific toContainment Spray System, Core Spray System, and Standby Gas Treatment System. Table 2consists of the following nine columns:

(1) Component Type – The first column identifies the componenttypes that are subject to an AMR. The component types are listedin alphabetical order. In the structural tables, component typesare sub-grouped by material.

(2) Intended Function – The second column identifies the licenserenewal intended functions for the listed component types. Definitions and abbreviations of intended functions are listed inTable 2.1-1 in Section 2 of the OCGS LRA.

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(3) Material – The third column lists the particular materials ofconstruction for the component type being evaluated.

(4) Environment – The fourth column lists the environment to whichthe component types are exposed. Internal and external serviceenvironments are indicated. A description of these environmentsis provided in Table 3.0-1 and Table 3.0-2, for mechanical,structural, and electrical components, respectively.

(5) Aging Effect Requiring Management – The fifth column lists theaging effects identified as requiring management for the materialand environment combinations of each component type.

(6) Aging Management Programs – The sixth column lists theprograms used to manage the aging effects requiringmanagement.

(7) NUREG-1801 Volume 2 Item – The seventh column documentsidentified consistencies of factors listed in Table 2 of the OCGSLRA with the GALL Report by noting the appropriate GALL ReportAMR line-item. Each combination of the following factors listed inTable 2 is compared to the GALL Report to identify thoseconsistencies: component type, material, environment, agingeffect requiring management, and AMP. If there is nocorresponding AMR line-item in the GALL Report for a particularcombination of factors, Column 7 is left blank.

(8) Table 1 Item – The eighth column is a cross reference ofline-items from Table 2 to Table 1. Each combination of thefollowing that has an identified GALL Report AMR line-item alsohas a Table 1 line-item reference number: component type,material, environment, aging effect requiring management, andAMP. Column 8 lists the corresponding line-item from Table 1. Ifthere is no corresponding item in the GALL Report Volume 1,Column 8 is left blank.

(9) Notes – The ninth column contains notes that are used todescribe the degree of consistency with the AMR line-items in theGALL Report. Notes that use letter designations are standardnotes based on the letter from A. Nelson, NEI, to P.T. Kuo, NRC,"U.S. Nuclear Industry's Proposed Standard License RenewalApplication Format Package, Request NRC Concurrence," datedJanuary 24, 2003 (ML030290201). (Note that the staff concurredin the format of the standardized format for LRAs by letter datedApril 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI[ML030990052].) Notes that use numeric designators are specificto OCGS. The letter notes are described in detail in Section 2 ofthis audit and review report.

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3.0.2 Audit and Review Process

The project team performed the audit and review in accordance with the criteria defined inRevision 1 of NUREG-1800, “Standard Review Plan for Review of License RenewalApplications for Nuclear Power Plants (SRP-LR).” Additional details on how the SRP-LRcriteria were addressed are provided in the OCGS audit and review plan. This review processis summarized in this section.

3.0.2.1 Review of the OCGS AMPs

For the OCGS AMPs for which the applicant claimed consistency with the AMPs in the GALLReport, the project team determined consistency. The project team determined reviewed theOCGS AMP descriptions and compared the ten program elements for those AMPs to thecorresponding program elements for the GALL Report AMPs (Attachment 3 shows the tenaging management program elements from the SRP-LR). The Division of Engineering (DE)reviewed and determined the adequacy of the applicant's 10 CFR Part 50, Appendix B Programand the results documented in Section 3 of the safety evaluation report (SER) related to theOCGS LRA.

For the OCGS AMPs that have one or more exceptions and/or enhancements, the project teamreviewed each exception and/or enhancement to determine whether the exception and/orenhancement is acceptable, and whether the OCGS AMP, as modified by the exception and/orenhancement, would adequately manage the aging effects for which it is credited. In somecases, the project team identified differences that the applicant did not identify between theOCGS AMPs credited by the applicant and the GALL Report AMPs. In these cases, the projectteam reviewed the difference to determine whether or not it is acceptable, and whether or notthe AMP, as modified by the difference, would adequately manage the aging effects.

For those OCGS AMPs that are not included in the GALL Report, the project team reviewed theOCGS AMP against the program elements specified in Appendix A.1 of the SRP-LR. Theproject team determined whether these OCGS AMPs would manage the aging effects for whichthey are credited.

3.0.2.2 Review of the OCGS AMR Results

The AMRs in the GALL Report fall into two broad categories:

• those the GALL Report concludes are adequate to manage aging of the componentsreferenced in the GALL Report, and

• those for which the GALL Report concludes that further evaluation is recommended forcertain aspects of the aging management process.

The project team determined that the OCGS AMR results, reported by the applicant to beconsistent with the GALL Report, are consistent with the GALL Report. The project team alsodetermined that the plant-specific AMR results reported by the applicant are technicallyacceptable and applicable. For AMR results for which the GALL Report recommends furtherevaluation, the project team reviewed the applicant's evaluation to determine whether itadequately addresses the issues for which the GALL Report recommended further evaluation.

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3.0.2.3 NRC-Approved Precedents

To help facilitate the staff’s review of its LRA, an applicant may reference NRC-approvedprecedents to demonstrate that its non-GALL programs correspond to reviews that the NRChas approved for other plants during its review of previous applications for license renewal. When an applicant elected to provide precedent information, the project team determinedwhether the material presented in the precedent was applicable to the applicant’s facility,determined whether the plant program was bounded by the conditions for which the precedentwas evaluated and approved, and determined that the plant program contained the programelements of the referenced precedent. In general, if the project team determined that theseconditions were satisfied, it used the information in the precedent to frame and focus its reviewof the applicant’s program.

It is important to note that precedent information is not a part of the LRA; it is supplementaryinformation voluntarily provided by the applicant as a reviewer’s aid. The existence of aprecedent, in and of itself, is not a sufficient basis to accept the applicant’s program. Rather,the precedent facilitates the review of the substance of the matters described in the applicant’sprogram. As such, in the applicant’s documentation of its programs that are based onprecedents, the precedent information is typically implicit in the evaluation rather than explicit. If the project team determined that a precedent identified by the applicant is not applicable tothe particular plant program for which it is credited, it may have referred the program toNRR/DE for review in the traditional manner, i.e., as described in the SRP-LR, withoutconsideration of the precedent information.

AmerGen chose not to use precedent information to support its selection of OCGS agingmanagement programs.

3.0.2.4 Updated Final Safety Analysis Review Supplement

Consistent with the SRP-LR, for the AMR results and associated AMPs that it reviewed, theproject team also reviewed the Updated Final Safety Analysis Review (UFSAR) supplement thatsummarizes the applicant’s programs and activities for managing the effects of aging for theperiod of extended operation, as required by 10 CFR 54.21(d).

3.0.2.5 Documentation and Documents Reviewed

In performing its work, the project team relied heavily on the OCGS LRA, the SRP-LR, and theGALL Report. The project team also reviewed the applicant’s AMP bases documents (acatalog of the documentation used by the applicant to develop or justify its AMPs), and otheron-site documents, including selected implementing documents, to determine whether theapplicant’s activities and programs will adequately manage the effects of aging on SCs.

Any discrepancies or issues discovered during the audit and review that required a formalresponse on the docket are documented in this audit and review report. If an issue was notdocketed or was not resolved prior to issuing this audit and review report, an RAI was preparedby the project team describing the issue and the information needed to disposition the issue. The RAI, if needed, is included and dispositioned in the SER related to the OCGS LRA. The listof RAIs associated with the audit and review is provided in Attachment 4 to this audit andreview report.

11

Attachment 5 characterizes the nature and extent of the project team’s reviews of theapplicant’s documents, and lists the documents reviewed by the project team. During its auditand review, the project team also conducted detailed discussions and interviews with theapplicant’s license renewal project personnel and other personnel with technical expertiserelevant to aging management.

3.0.2.6 Commitments To Be Included in the Safety Evaluation Report

During the audit and review, the project team requested additional information to resolve issuesrelated to the content of the LRA. In responding to these requests for additional information,the applicant, in some cases, committed to supplement its LRA to correct entries or implementadditional activities, as needed, to appropriately manage aging of the various SSCs within thescope of license renewal. A list of these commitments is included in Attachment 6 of this auditand review report.

3.0.2.7 Exit Meeting

The project team held a public exit meeting with the applicant on April 20, 2006, to discuss theresults of its audit and review of the AMPs and AMR results assigned to the project team. These discussions reflected the project team’s work and its results, as documented in this auditand review report.

3.0.3 OCGS Aging Management Programs

The project team’s audit and review activities for the OCGS AMPs and its conclusionsregarding these programs are documented below. The audit and review was performed inaccordance with the guidance contained in the OCGS audit and review plan, as summarized inSection 3.0.2 of this audit and review report.

Table 3.0.3-1, OCGS Aging Management Programs, presents the AMPs credited by theapplicant and described in Appendix B of the LRA. The table also indicates the SSCs thatcredit the AMPs and the GALL AMP from which the applicant claimed consistency. The sectionof the audit and review report in which the project team’s evaluation of the program isdocumented also is provided.

Table 3.0.3-1 OCGS Aging Management Programs (1)

OCGS AMP (LRA

Section)

GALL Report

Comparison

GALL Report AMP(s) OCGS LRA Systems or

Structures that Credit

the AMP

Project

Team’s

Evaluation

Section

ASME Section XI

Inservice Inspection,

Subsections IW B,

IWC, and IW D (B.1.1)

Consistent with

exception and

enhancement

XI.M1, ASME Section

XI Inservice

Inspection,

Subsections IW B,

IW C, and IW D

Reactor Vessel, Internals,

and Reactor Coolant Sys.

Engineered Safety

Features

Auxiliary Systems

Steam and Power

Conversion System

3.0.3.2.1

OCGS AMP (LRA

Section)

GALL Report

Comparison



the AMP

Project

Team’s

Evaluation

Section

12

W ater Chem istry

(B.1.2)

Consistent with

exceptions

XI.M2, Water

Chemistry


and Reactor Coolant

Systems

Engineered Safety

Features

Auxiliary Systems

3.0.3.2.2

Reactor Head

Closure Studs (B.1.3)

Consistent with

exception

XI.M3, Reactor Head

Closure Studs


and Reactor Coolant

Systems

3.0.3.2.3

BW R Vessel ID

Attachment W elds

(B.1.4)

Consistent with

exceptions

XI.M4, BW R Vessel ID

Attachment W elds


and Reactor Coolant

Systems

3.0.3.2.4

BW R Feedwater

Nozzle (B.1.5)

Consistent with

exception and

enhancement

XI.M5, BWR

Feedwater Nozzle


and Reactor Coolant

Systems

3.0.3.2.5

BW R Control Rod

Drive Return Line

Nozzle (B.1.6)

Consistent with

exceptions

XI.M6, BWR Control

Rod Drive Return Line

Nozzle


and Reactor Coolant

Systems

3.0.3.2.6

BW R Stress

Corrosion Cracking

(B.1.7)

Consistent with

exceptions (3)

and

enhancement(2)

XI.M7, BWR Stress

Corrosion Cracking


and Reactor Coolant

Systems

3.0.3.2.7

BW R Penetrations

(B.1.8)

Consistent with

exception

XI.M8, BWR

Penetrations


and Reactor Coolant

Systems

3.0.3.2.8

BW R Vessel Internals

(B.1.9)

Consistent with

exceptions and

enhancements

XI.M9, BWR Vessel

Internals


and Reactor Coolant

Systems

3.0.3.2.9

Thermal Aging and

Neutron Irradiation

Embrittlement of Cast

Austenitic Stainless

Steel (CASS) (B.1.10)

Consistent XI.M13, Thermal Aging

and Neutron Irradiation

Embrittlement of Cast

Austenitic Stainless

Steel (CASS)


and Reactor Coolant

Systems

3.0.3.1.1

Flow- Accelerated

Corrosion (B.1.11)

Consistent XI.M17, Flow-

Accelerated Corrosion


and Reactor Coolant

Systems

Engineered Safety

Features

Steam and Power

Conversion System

3.0.3.1.2

OCGS AMP (LRA

Section)

GALL Report

Comparison



the AMP

Project

Team’s

Evaluation

Section

13

Bolting Integrity

(B.1.12)

Consistent with

exceptions

XI.M18, Bolting

Integrity


and Reactor Coolant

Systems

Engineered Safety

Feature Systems

Auxiliary Systems

Steam and Power

Conversion System

3.0.3.2.10

Open-Cycle Cooling

W ater System

(B.1.13)

Consistent with

enhancements

XI.M20, Open-Cycle

Cooling W ater System

Auxiliary Systems 3.0.3.2.11

Closed-Cycle Cooling

W ater System

(B.1.14)

Consistent with

exception

XI.M21, Closed-Cycle

Cooling W ater System

Auxiliary Systems

Steam and Power

Conversion System

3.0.3.2.12

Boraflex Rack

Management

Program (B.1.15)

Consistent with

exception

XI.M22, Boraflex

Monitoring


Inspection of

Overhead Heavy

Load and Light

Load (Related to

Refueling) Handling

Systems (B.1.16)

Consistent with

exceptions(3)

and

enhancements

XI.M23, Inspection of

Overhead Heavy Load

and Light

Load (Related to

Refueling) Handling

Systems


Com pressed Air

Monitoring (B.1.17)

Consistent XI.M24, Compressed

Air Monitoring


BW R Reactor Water

Cleanup System

(B.1.18)

Consistent with

exception

XI.M25, BW R Reactor

W ater Cleanup

System


and Reactor Coolant

Systems

3.0.3.2.15

Fire Protection

(B.1.19)

Consistent with

exception and

enhancements

XI.M26, Fire Protection Auxiliary Systems 3.0.3.2.16

Fire W ater System

(B.1.20)

Consistent with

enhancements

XI.M27, Fire W ater

System


Aboveground

Outdoor Tanks

(B.1.21)

Consistent with

exception

XI.M29, Aboveground

Carbon Steel Tanks


Fuel Oil Chem istry

(B.1.22)

Consistent with

exceptions (2)

and

enhancements

XI.M30, Fuel O il

Chem istry


OCGS AMP (LRA

Section)

GALL Report

Comparison



the AMP

Project

Team’s

Evaluation

Section

14

Reactor Vessel

Surveillance (B.1.23)

Consistent with

enhancement

XI.M31, Reactor

Vessel Surveillance


and Reactor Coolant

Systems

3.0.3.2.20

One-Time Inspection

(B.1.24)

Consistent with

exceptions (2)XI.M32, One-Time

Inspection


and Reactor Coolant

Systems

Engineered Safety

Feature Systems

Auxiliary Systems

Steam and Power

Conversion Systems

Containment, Structures

and Component Supports

3.0.3.1.4

Selective Leaching of

Materials (B.1.25)

Consistent XI.M33, Selective

Leaching of Materials


and Reactor Coolant

Systems

Engineered Safety

Feature Systems

Auxiliary Systems

3.0.3.1.5

Buried Piping

Inspection (B.1.26)

Consistent with

exceptions and

enhancements

XI.M34, Buried Piping

and Tanks Inspection


ASME Section XI,

Subsection IW E

(B.1.27)

Consistent with

exception

XI.S1, ASME Section

XI, Subsection IW E


and Reactor Coolant Sys.

Engineered Safety

Features

Auxiliary Systems

Steam and Power

Conversion System

3.0.3.2.22

ASME Section XI,

Subsection IW F

(B.1.28)

Consistent with

exception and

enhancements

XI.S3, ASME Section

XI, Subsection IW F

Containment Structures


3.0.3.2.23

10 CFR Part 50,

Appendix J (B.1.29)

Consistent XI.S4, 10 CFR Part 50,

Appendix J



3.0.3.1.6

Masonry W all

Program (B.1.30)

Consistent XI.S5, Masonry W all

Program



3.0.3.1.7

OCGS AMP (LRA

Section)

GALL Report

Comparison



the AMP

Project

Team’s

Evaluation

Section

15

Structures Monitoring

Program (B.1.31)

Consistent with

exceptions (2)

and

enhancement(2)

XI.S6, Structures

Monitoring Program


and Reactor Coolant

Systems

Engineered Safety

Features

Auxiliary Systems

Steam and Power

Conversion System



3.0.3.2.24

RG 1.127, Inspection

of Water-Control

Structures Associated

W ith Nuclear Power

Plants (B.1.32)

Consistent with

enhancements

XI.S7, RG 1.127,

Inspection of

W ater-Control

Structures Associated

with Nuclear Power

Plants



3.0.3.2.25

Protective Coating

Monitoring and

Maintenance

Program (B.1.33)

Consistent XI.S8, Protective

Coating Monitoring

and

Maintenance Program



3.0.3.1.8

Electrical Cables and

Connections Not

Subject to 10 CFR

50.49 Environmental

Qualification

Requirements

(B.1.34)

Consistent XI.E1, Electrical

Cables and

Connections Not

Subject to 10 CFR

50.49 Environmental

Qualification

Requirements

Electrical Components

and Systems

3.0.3.1.9

Electrical Cables and

Connections Not

Subject to 10 CFR

50.49 Environmental

Qualification

Requirements Used

in Instrumentation

Circuits (B.1.35)

Consistent with

enhancements

XI.E2, Electrical

Cables and

Connections Not

Subject to 10 CFR

50.49 Environmental

Qualification

Requirem ents Used in

Instrumentation

Circuits


and Systems

3.0.3.2.26

Inaccessible Medium

Voltage Cables Not

Subject to 10 CFR

50.49 Environmental

Qualification

Requirements

(B.1.36)

Consistent with

enhancement(2)XI.E3, Inaccessible

Medium Voltage

Cables Not Subject to

10 CFR 50.49

Environmental

Qualification

Requirements


and Systems

3.0.3.1.10

OCGS AMP (LRA

Section)

GALL Report

Comparison



the AMP

Project

Team’s

Evaluation

Section

16

Periodic Testing of

Containment Spray

Nozzles (B.2.1)

N/A Oyster Creek

plant-specific program

Engineered Safety

Features Systems

3.0.3.3.1

Lubricating Oil

Monitoring Activities

(B.2.2)

N/A Oyster Creek



Generator Stator

W ater Chem istry

Activities (B.2.3)

N/A Oyster Creek



Periodic Inspection of

Ventilation Systems

(B.2.4)

N/A Oyster Creek


Engineered Safety

Features Systems

Auxiliary Systems

3.0.3.3.4

Periodic Inspection

Program (B.2.5)

N/A Oyster Creek


Steam and Power

Conversion System

3.0.3.3.5

W ooden Utility Poles

Program (B.2.6)

N/A Oyster Creek



and Systems

3.0.3.3.6

Periodic Monitoring of

Combustion Turbine

Power Plant (B.2.7)

N/A NA None – this AMP was

deleted by the applicant.

3.0.3.3.7

Metal Fatigue of

Reactor Coolant

Pressure Boundary

(B.3.1)

Consistent with

enhancements

X.M1, Metal Fatigue of

Reactor Coolant

Pressure

Boundary


and Reactor Coolant

Systems

3.0.3.2.27

Environmental

Qualif ication (EQ)

Program (B.3.2)

Consistent X.E1, Environmental

Qualification (EQ) of



and Systems

3.0.3.1.11

Notes: (1) Aging management programs for the Oyster Creek station blackout system Forked River

combustion turbine power plant, radio comm unications systems, and meteorological

tower are addressed in Attachment 7 to this audit and review report.

(2) Exception(s) and/or enhancement(s) were added based on the applicant’s reconciliation

of the aging managem ent programs in the draft January 2005 GALL Report with the

approved Septem ber 2005 GALL Report.

(3) Exception(s) and/or enhancement(s) were deleted based on the applicant’s reconciliation

of the aging managem ent programs in the draft January 2005 GALL Report with the

approved Septem ber 2005 GALL Report.

17

3.0.3.1 OCGS AMPs That Are Consistent with the GALL Report

3.0.3.1.1 Thermal Aging and Neutron Irradiation Embrittlement of Cast AusteniticStainless Steel (OCGS AMP B.1.10)

In the OCGS LRA, Appendix B, Section B.1.10, the applicant stated that OCGS AMP B.1.10,"Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel(CASS)," is a new plant program that will be consistent with GALL AMP XI.M13, "Thermal Agingand Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)."

3.0.3.1.1.1 Program Description

The applicant stated, in the OCGS LRA, that this program will provide for aging management ofCASS reactor internal components within the scope of license renewal. The program will beimplemented prior to the period of extended operation.

The applicant also stated that the program will include a component specific evaluation of theloss of fracture toughness. A supplemental inspection will be performed for those componentswhere loss of fracture toughness may affect the function of the component, using the criteriaprovided in GALL AMP XI.M13. This inspection will ensure the integrity of the CASScomponents exposed to the high temperature and neutron fluence present in the reactorenvironment.

3.0.3.1.1.2 Consistency with the GALL Report

In OCGS LRA, the applicant stated that OCGS AMP B.1.10 is consistent with GALLAMP XI.M13.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part,the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.10,including PBD-AMP-B.1.10, "Thermal Aging and Neutron Irradiation Embrittlement of CastAustenitic Stainless Steel,” Rev. 0, which provides an assessment of the AMP elements'consistency with GALL AMP XI.M13. Specifically, the project team reviewed the programelements (see Section 3.0.2.1 of this audit and review report) contained in OCGS AMP B.1.10and associated bases documents to determine their consistency with GALL AMP XI.M13.

The project team reviewed those portions of the applicant’s Thermal Aging and NeutronIrradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) for which the applicantclaims consistency with GALL AMP XI.M13 and found that they are consistent with this GALLReport AMP. The project team found that the applicant’s Thermal Aging and NeutronIrradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) program conforms to therecommended GALL AMP XI.M13.

3.0.3.1.1.3 Exceptions to the GALL Report

None

3.0.3.1.1.4 Enhancements

None

18

3.0.3.1.1.5 Operating Experience

The applicant stated, in the OCGS LRA, that the aging management program for ThermalAging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) is a newprogram, and therefore, no programmatic operating experience exists.

In PBD B.1.10, the applicant stated that research data on both laboratory-aged andservice-aged materials has confirmed that loss of fracture toughness could occur in somereactor vessel CASS internal components. Oyster Creek internal reactor vessel CASScomponents are periodically examined, but no degradation has been identified to date. Sincethe thermal aging and neutron irradiation embrittlement of CASS aging management program isa new program, a review of plant operating experience cannot confirm at this time that loss offracture toughness of cast austenitic stainless steel is a factor.

The Oyster Creek thermal aging and neutron irradiation embrittlement of CASS agingmanagement program will include a component specific evaluation to assess the susceptibilityfor the loss of fracture toughness. This evaluation will be performed prior to the period ofextended operation. A supplemental inspection will be performed for those components whereloss of fracture toughness may affect function of the component, using the criteria provided inNUREG-1801 Aging Management Program, XI.M13. This inspection will ensure the integrity ofthe CASS components exposed to the high temperature and neutron fluence present in thereactor environment.

The project team also reviewed the operating experience provided in the basis document, andinterviewed the applicant's technical staff to conclude that no industry operating experience withthermal aging and embrittlement of CASS has emerged.

The staff believes that the corrective action process will capture internal and external plantoperating issues to ensure that aging effects are adequately managed.

3.0.3.1.1.6 UFSAR Supplement

The applicant provided its UFSAR Supplement for the thermal aging and neutron irradiationembrittlement of cast austenitic stainless steel (CASS) program in OCGS LRA, Appendix A,Section A.1.10, which states that the thermal aging and neutron irradiation embrittlement ofcast austenitic stainless steel (CASS) program is a new program that will provide for agingmanagement of CASS reactor internal components within the scope of license renewal.

The applicant also stated that the program will be implemented prior to the period of extendedoperation. The program will include a component specific evaluation of the loss of fracturetoughness in accordance with the criteria specified in GALL AMP XI.M13. For thosecomponents where loss of fracture toughness may affect function of the component, asupplemental inspection will be performed. This inspection will ensure the integrity of the CASScomponents exposed to the high temperature and neutron fluence present in the reactorenvironment.

The project team also reviewed the applicant’s license renewal commitment list in Appendix Aof the OCGS LRA, and confirmed that this program is identified as a new program that will beimplemented prior to the period of extended operation as item 10 of the commitments.

19

The project team reviewed the UFSAR Supplement for OCGS AMP B.1.10, found that it wasconsistent with the GALL Report, and determined that it provided an adequate summarydescription of the program, as identified in the SRP-LR FSAR Supplement table and asrequired by 10 CFR 54.21(d).

3.0.3.1.1.7 Conclusion

On the basis of its audit and review of the applicant's program, the project team determined thatall the program elements are consistent with the GALL Report. On the basis of its review of theUFSAR Supplement for this program, the project team found that it provided an adequatesummary description of the program, as required by 10 CFR 54.21(d).

3.0.3.1.2 Flow-Accelerated Corrosion (OCGS AMP B.1.11)

In OCGS LRA, Appendix B, Section B.1.11, the applicant stated that OCGS AMP B.1.11,"Flow-Accelerated Corrosion," is an existing plant program that is consistent with GALLAMP XI.M17, “Flow-Accelerated Corrosion."

3.0.3.1.2.1 Program Description

The applicant stated, in the OCGS LRA, that this program is based on EPRI guidelines inNSAC-202L-R2, “Recommendations for an Effective Flow Accelerated Corrosion Program,”April 1999. The program predicts, detects, and monitors wall thinning in piping, fittings, valvebodies, and feedwater heaters due to Flow-Accelerated Corrosion (FAC).

The applicant also stated that analytical evaluations and periodic examinations of locations thatare most susceptible to wall thinning due to FAC are used to predict the amount of wall thinningin pipes, fittings, and feedwater heater shells. Program activities include analyses to determinecritical locations, baseline inspections to determine the extent of thinning at these criticallocations, and follow-up inspections to confirm the predictions. Inspections are performed usingultrasonic, radiographic, visual or other approved testing techniques capable of detecting wallthinning. Repairs and replacements are performed as necessary.

3.0.3.1.2.2 Consistency with the GALL Report

In OCGS LRA, the applicant stated that OCGS AMP B.1.11 is consistent with GALLAMP XI.M17.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part,the documents listed in Attachment 5 of this audit and review report for OCGS AMP B.1.11,including program basis document PBD-AMP-B.1.11,"Flow-Accelerated Corrosion,” Rev. 0,which provides an assessment of the AMP elements' consistency with GALL AMP XI.M17. Specifically, the project team reviewed the program elements (see Section 3.0.2.1 of this auditand review report) contained in OCGS AMP B.1.11 and associated bases documents todetermine consistency with GALL AMP XI.M17.

Also, the project team reviewed OCGS document Number ER-AA-430, “Conduct of FACActivities,” Revision 1, which is a procedure for establishing, controlling, updating, anddocumenting FAC programs.

20

The project team reviewed those portions of the applicant’s Flow-Accelerated Corrosionprogram for which the applicant claims consistency with GALL AMP XI.M17 and found that theyare consistent with this GALL Report AMP. The project team found that the applicant’sFlow-Accelerated Corrosion program conforms to the recommended GALL AMP XI.M17.

3.0.3.1.2.3 Exceptions to the GALL Report

None

3.0.3.1.2.4 Enhancements

None

3.0.3.1.2.5 Operating Experience

The applicant stated, in the OCGS LRA, that operating experience of Flow-AcceleratedCorrosion aging management program activities has shown that the program can determinesusceptible locations for flow accelerated corrosion, can predict the component degradation,and can detect the wall thinning in piping, valves, and other components (such as the feedwaterheater shells) due to flow-accelerated corrosion. In addition, the program provides forreevaluation, repair or replacement for locations where calculations indicate an area will reachminimum allowable thickness before the next inspection. Periodic self assessments of theprogram have been performed which have identified opportunities for program improvements. In 2000, inspections of the “C” feedpump minimum recirculation line showed that several90-degree elbows experienced significant wear. Similar wear was found on several 45-degreeelbows. As a result of these inspections, approximately 25 feet of 4” pipe, one 90-degreeelbow, and three 45-degree elbows were replaced with chrome-moly material.

The applicant stated in the basis document that during Cycle 17, UT Inspections wereperformed on the high-pressure (HP) feedwater heater (FWH) shells. These inspections weredriven by the Point Beach FWH shell rupture event and other industry experience as describedin SEN 199, “Feedwater Heater Shell Rupture,” and NRC Information Notice (IN) 99-19,“Rupture of the Shell Side of a Feedwater Heater at the Point Beach Nuclear Plant.” Results ofthe inspections showed wall thinning on all three HP FWH shells. Two areas on the “A” HPFWH required immediate repair. Other identified degradation was evaluated and determine tobe acceptable through the remainder of the operating cycle at which time further inspectionsand repairs were performed. There have been a number of steam leaks associated with flashtank and drain tank piping and attached piping. However, there have been some cases whereleaks did occur that were not predicted. As a result of these pipe failures, the FAC programwas modified to more accurately predict that wall thinning was occurring. The experience atOyster Creek with the FAC program shows that the FAC program is effective in managing FACin high-energy carbon steel piping and components. Two deficiencies in the program wereidentified: 1) The System Susceptibility Evaluation did not meet EPRI or proceduralrecommendations and 2) plant model input to the FAC Program software tool, CHECWORKS,contained a number of errors and omissions. These deficiencies were identified as the primaryreasons the FAC program has missed identifying components that developed leaks as a resultof Flow Accelerated Corrosion. A FAC program improvement project was implemented tocorrect the deficiencies. The project was completed during August 2003. As a result of theimprovement project, the risk of a FAC failure in unidentified susceptible lines has beenreduced.

21

The project team recognized that the corrective action program, which captures internal andexternal plant operating experience issues, will ensure that operating experience is reviewedand incorporated in the future to provide objective evidence to support the conclusion that theeffects of aging are adequately managed.

The project team also reviewed the operating experience provided in the OCGS LRA, andinterviewed the applicant's technical staff to confirm that the plant-specific operating experiencedid not reveal any degradation not bounded by industry experience.

On the basis of its review of the above plant-specific operating experience and discussions withthe applicant's technical staff, the project team determined that the applicant’sFlow-Accelerated Corrosion program will adequately manage the aging effects that areidentified in the OCGS LRA for which this AMP is credited.

3.0.3.1.2.6 UFSAR Supplement

The applicant provided its UFSAR Supplement for the Flow-Accelerated Corrosion program inOCGS LRA, Appendix A, Section A.1.11, which states