The PMP hours can be anything where you lead or managed a project, and where the term 'project' is consistent with the PMI. As we know, a Program Manager may or may not manage a specific and individual project. The point here is that if you can adequately prove, and have someone verify it, that you actually lead, managed, or was part of a project and your actions are consistent with the definition of a project, those hours should be accepted.
As always, if you have deep concern, I would recommend you call the PMI and and get clarification.