ML060760429

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2005/09/20-License Renewal Audit and Inspection Handbook, September 20, 2005
ML060760429
Person / Time
Site: Oyster Creek
Issue date: 09/20/2005
From:
AmerGen Energy Co
To:
Office of Nuclear Reactor Regulation
References
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Download: ML060760429 (28)
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Oyster Creek Generating Station Ailan Ea D R1 mm An Exelon Company License Renewal Audit and Inspection Handbook September 20, 2005 10/3 /by l 'OYSTER CREEK LICENSE RENEWALl _ Purpose of Audit and Inspection Handbook This Audit and Inspection Handbook contains background information and expectations for the Oyster Creek License Renewal Project team, including contractors and plant support staff, during the NRC Audits and Inspections.

The handbook will be reviewed in an initial pre-job brief of the Oyster Creek License Renewal Project team members. A copy of this handbook will be provided to the NRC Audit and Inspection Team Leads.OYSTER CREEK LICENSE RENEWAL NRC: AUDIT and INSPECTION SCHEDULE During the review of the Oyster Creek License Renewal Application (LRA), NRC will perform a variety of tasks on the Oyster Creek site. Following is a list of their major on-site activities with an approximate schedule (Note that final on-site preparations/training will typically occur the week prior to an Audit): Date Activity August 24, 2005 September 20-23,2005 October 20, 2005, 6 PM October 3-7, 2005 October 11-12, 2005 November 1, 2005 November 7-10, 2005 December 12, 2005 (Tentative)

March 13-17, 2006 March 27-31, 2006 TBD Public Information Meeting -License Renewal Process & Safety Review Overview.

NRC Lead: Donnie Ashley Scoping and Screening Audit -NRC Team Lead; Steve Tingen Public Exit -Scoping and Screening Methodology Aging Management Programs Audit -NRC Team Lead: Greg Cranston Environmental Audit -NRC Team Lead: Michael Masnik Public NRC Meeting -Environmental Scoping AMR Audit -NRC Team Lead; Greg Cranston Public Exit Meeting -AMP / AMR Audits Region Inspections

-Scoping & Screening and AMP NRC Team Lead: Mike Modes Public Exit Meeting -Scoping & Screening

/ AMP Regional Inspections 2

_fORGANIZATION 1 NRC Audit/ Inspection Teams As of 9/9/05 Project Managers Donnie Ashley Johnny Eads Michael Masnik NRR LR Safety Project Manager NRR Communications Project Manager NRR Environmental Project Manager Scoping and Screening Methodology Audit Steve Tingen NRR Team Lead Technical AMP and AMR Audits Greg Cranston NRR Team Lead Regional Inspections Mike Modes Region I Team Lead Team Members NRC AudiVInspection team members and reviewers will be assigned from NRC and contractor resources.

The NRC team for the Scoping and Screening Methodology audit is expected to consist of four members; their team for the AMP and AMR Audits is expected to be 8 members.I.. .3 11 OYSTER CREEK License Renewal Project Team Organization 11 0 FOLLOWS ON NEXT PAGE 3

  • F---__I-I I I nental Communicatlona

& Public d Affairs her Corporate Tom Armstrong Pete Resler co Jim Laird er Site I _Gina Scala Rachelle Benson!nerface Owner Ow Site SMEs t I I Legal I I I Brad Fewell i Kathryn Sutton Tetra-Te I (ML&B)I I j EeExl~NRC Organ I ~ I Prepa ixelncensing Oyster Creek License Renewal Project Organization nn L.ch / NUS I I eion I zations -I ling ER aration Direct reporting relationship

- ----Coordination, support &oversight function Revised 9/07/05 4 IOyster Creek LR Team Roles & Responsibilities Oyster Creek License Renewal Manager (Fred Polaski)* Provides Senior Management interface inside and outside of Company* Assists LR team set strategy for dealing with issues as needed* Participates/monitors team interactions with NRC Auditors/Inspectors OYSTER CREEK LR Proiect Technical Lead (Don Warfel)* Acts as Oyster Creek counterpart to the NRC Audit / Inspection Team Leader (Audits: or;Inspections:

  • Manages and directs the activities of the License Renewal Project Team* Facilitates multi-disciplinary discussions among LR Project Team to resolve issues* Conducts daily LR Project Team meetings* Identifies issues for which commitments and Senior Management reviews are required and, as appropriate, ensure issues are entered into the Corrective Action Program* Keeps Senior Management informed of all aspects of audit / inspection activities
  • Assigns counterparts for individual auditors / inspectors and LR team individuals to respond to questions and perform peer reviews* Obtains site concurrence on changed commitments or changes to the LRA LR Team Manager/Mentor (Al Fulvio)* Provides oversight for the Regulatory interface* Reviews responses to NRC questions from an overall project technical and regulatory perspective.
  • Supports Project Technical Lead as required.LR Prolect Team Engineers* Support pre-audit

/ inspection information request needs.* Provide timely, clear, concise, accurate and relevant communications with NRC team members in area of responsibility.

  • Document and coordinate actions to address inspection issues.* As assigned by the LR Project Technical Lead, develop responses to questions asked by auditors/inspectors.
  • Solicit additional technical support, as needed, to respond to issues and questions that are raised during the audit / inspection.
  • As assigned by the LR Project Technical Lead, perform technical reviews of draft responses to questions.
  • Participate in NRC communications and interviews with plant SMEs.* Ensure problems or issues identified during the inspection are promptly addressed.
  • Escalate issues/communications/concerns including response inadequacies, safety significant findings and personnel-related issues to License Renewal Manager.5
  • Keep the LR Technical Lead and Licensing Lead informed of subjects and outcomes of NRC team information requests and interviews.
  • Communicate the potential need for new Regulatory Commitments to Technical Lead, Site Lead and Licensing Lead.Site Lead LR Engineer (Tom Quintenz)* Provides initial site point of contact for any site resource/personnel requirements
  • Ensures site-specific information is made available to Audit/Inspection teams* Ensures site revievi of responses, when appropriate
  • Gains site approval for changes to or additions of Regulatory Commitments, as appropriate NRC Interface

/ Licensing Lead (John Hufnagel)* Coordinates inspection preparation activities, entrances and exit meetings* Provides logistical support for plant access, tours, meeting rooms, work-space, and other activities of the NRC Audit / Inspection Team* Coordinates communications with NRC License Renewal Project Manager and Audit /Inspection Team Leaders* Coordinate review of inspection issues for potential regulatory impact or safety significance

  • Escalates issues/communications/concerris including timeliness, response inadequacies, ownership for issues, safety significant findings, unclear actions* Maintains information request, document request, and other databases to support communications.
  • Provides daily reports on status of information requests LR Environmental Lead* Provide clear, concise and relevant communications with NRC team members in area of responsibility.
  • Provide responses to questions asked by auditors/inspectors.
  • Perform technical reviews of draft responses to questions.
  • Solicit additional technical support, as needed, to respond to issues and questions that are raised during the audit / inspection.
  • Escalate issues/communications/concerns including response inadequacies, safety significant findings and personnel-related issues to Project Management.

6 Plant Sublect Matter Experts (SME)* Provide clear, concise and relevant communications with NRC team members in area of responsibility.

  • Support communications with NRC auditors/inspectors and others as requested by the Technical or Licensing Lead.* Provide responses to questions asked by auditors/inspectors in a timely manner.* Perform technical reviews of draft responses to questions, as requested.
  • Solicit additional technical support, as needed, to respond to issues and questions that are raised during the audit / inspection.
  • Escalate issues/communications/concerns including response inadequacies, safety significant findings and personnel-related issues to Technical Lead or designee.* Debrief LR counterpart, LR site lead, Technical Lead and / or Licensing Lead following communications with NRC.Administrative Assistant* Provide logistics support to NRC and License Renewal Team as requested* Assist LR Licensing Lead and Team members to maintain the Information Request database* Assist all Team members to obtain copies of requested information and documents.

7 1: ense Renewal Team Expectations

  • Be familiar with "DO's and DON'Ts" for communicating with NRC Auditor/ Inspectors.
  • Review the NRC audit / inspection plan(s) associated with the audit / inspection.
  • Assist in preparations for the audit / inspection.
  • Develop, review and provide information requested by the NRC team.* Manage site audit / inspection response activities and interface with NRC counterparts
  • Ensure copies of License Renewal information provided to the NRC are kept by Project.* Identify and obtain support of appropriate Subject Matter Experts (SME) as needed to interact with the NRC.* Track issues, concerns and NRC information requests for assigned areas and prepare appropriate responses.
  • Identify additional resources needed to support the audit / inspection.
  • Communicate issues to the Licensing Lead, Technical Lead and SME's as appropriate.
  • Initiate IRs for issues that arise, as appropriate.
  • Coordinate SME interactions with the NRC and development of position papers.* Meet daily to discuss issues, open NRC questions and actions assigned.* Participate in daily briefing meetings with the NRC to discuss issues, the number of open questions and the quality of the interface (as requested).
  • Communicate with the SME's to ascertain that issues have been reviewed and researched prior to an interaction with the NRC.* Follow normal plant procedures if questions arise during the audit / inspection concerning operability of plant equipment or reportability of an event or condition.
  • All potential safety issues along with resolution or basis for continued operation should be identified to Oyster Creek plant management.
  • Communicate with Oyster Creek management as to status of issues and resource needs, as appropriate.

Do", for Communication with the NRC I Note: These reminders are intended to supplement formal plant guidance contained in LS-AA-1002, "External Organization Request Process Control," and LS-AA-1003, "NRC Inspection Preparation and Response." Please refer to those procedures.

If you have additional questions, please contact your License renewal Licensing Lead.* Be courteous, professional and business-like during communications with auditors and inspectors.

  • Be proud of our plant and don't be afraid to say so. Be positive about your interactions with the NRC.* Treat the auditors and inspectors in the same way you expect others to treat you.Be prepared for your interviews.

Bring any drawings and reports you suspect may be useful to address the subject area.LISTEN carefully to the auditor or inspector's request.UNDERSTAND each question.

Ask clarifying questions, if necessary.

Don't be distracted by terminology that is different from what you are used to.* ANSWER each question to best of your knowledge and ability, if you know the answer.Know what you are going to say before you start talking, and keep your answer focused on the question.* Resist the urge to answer if you are unsure. It's ok to say, "I don't know." When you say "I don't know," offer to find out.* If you know who the correct person is to answer the question, contact that person.* If you do not know who the correct person is to answer the question, immediately inform the Technical or Licensing Lead.* Offer to take the inspector on a tour to see an item first hand if it would be helpful.* Keep good notes of your discussions, and provide a debrief to the Licensing Lead.* If you are assigned to respond to a written question, prepare your written response as soon as practical.

If you cannot fully respond to the question within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, or if your preliminary evaluation of the question leads you to believe the issue cannot be resolved within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, escalate the issue to the appropriate License Renewal Team member and the Licensing Lead.* If you discover that you have provided incomplete or incorrect information, immediately notify the LR Licensing Lead.* If the issue meets the threshold for an IR, initiate one. If the IR has a potential impact on current plant operations, discuss the issue with the Site Lead Engineer and Licensing Lead to determine the appropriate course of action and to communicate to site management.

If 9 you initiate an IR, provide a copy of it to the Licensing Lead for capture in the appropriate file or database.* If you have any questions concerning communications with NRC, ask the LR Licensing Lead or Technical Lead.* Avoid surprises for the License Renewal project team, NRC and plant staffs. This means we must communicate in a coordinated way between ourselves and with the NRC.* For plant staff SMEs, if you are being asked questions by an auditor/inspector while performing essential work activities in support of plant operations, it's okay to ask the inspector to save his/her questions until the work activity is complete.* Reminder -it is the right of each employee to communicate concerns and issues to the NRC at all times.10 l Don'ts for Communication with the NRC* Don't be confrontational or defensive.

  • Don't be passive.* Don't speculate, theorize or hypothesize.
  • Don't solicit NRC opinion what answer they want to hear. The NRC inspectors are not our consultants.
  • Don't fail to adequately document NRC question(s) or document request(s).
  • Don't treat NRC team members as adversaries.

Both of you are professionals who are attempting to do the right thing, and both of you have the same goal of protecting the health and safety of the public.* Don't fail to provide complete information to a question or issue (e.g., provide all relevant, accurate information that you know to be a fact.)Don't fail to keep the NRC informed about your progress in obtaining answers to their questions.

  • Don't communicate with the NRC via e-mail. This is not an appropriate form of communication during an inspection.

Any License Renewal e-mails to the NRC should be from the License Renewal Licensing Lead.* Don't grant access to safeguards, proprietary or confidential information without appropriate management approvals.

Contact the LR Licensing Lead or Technical Lead if you are unsure.* Don't make a verbal or written commitment to the NRC. Only designated senior management can make commitments, in accordance with LS-AA-1 10"Commitment Management." 11 1NCONDUCT of AUDITS / INSPECTIONS l Proposed Daily Meeting Schedule Ia The following activities will be proposed to the NRC team lead. Exact schedules will be as agreed with the NRC leader.Time Description 8:00 am First day of Audit or Inspection conduct entrance meeting with introductions and explanation of logistics.

4:00 pm Daily Audit / inspection Feedback Meeting (NRC Team and designated License Renewal Team members)4:30 pm Daily Oyster Creek LICENSE RENEWAL Team meeting OYSTER CREEK LR Project Team Facilities During NRC Visits Both the NRC and the Exelon/AmerGen LR teams will be housed in the Training Building (Building 12). The NRC Team will work in the Team room in the Northwest corner of the building.

They will also utilize the adjacent "Exam Prep" room.The Oyster Creek LR Team will occupy the Education Center ("Ed Center") and conference room just south of the Ed Center, also in the Training Building.The Team room and Ed Center may be used for LR Project team and NRC team meetings.12 I Subject Matter Experts And Program Owners i The following individuals are considered subject matter experts and will respond as requested during the inspections:

Project/Plant Program[Owners Project/Plant Program Owners LRA GALL OytrCekAigMtIrga R Team Site program program Oldster Creek Aging Mgt. Program Owner Owner B.1.01 Xl.M1 ASME Section Xi Inservice Inspection, Getz Harttraft Subsections IWB, IWC, and IWD B.1.02 XL.M2 Water Chemistry Rafferty Michelle Mura (Was Michael Ford)B.1.03 XL.M3 Reactor Head Closure Studs May Harttraft B.1.04 XL.M4 BWR Vessel ID Attachment Welds May Harttraft B.1.05 XL.M5 BWR Feedwater Nozzle May Harttraft B.1.06 XL.M6 BWR Control Rod Drive Return Line Nozzle Miller Harttraft B.1.07 XL.M7 BWR Stress Corrosion Cracking Rafferty Harttraft B.1.08 XL.M8 BWR Penetrations May Harttraft B.1.09 XL.M9 BWR Vessel Internals May Harttraft B.1.10 XL.M13 Thermal Aging and Neutron Irradiation May Harttraft Embrittlement of Cast Austenitic Stainless Steel (CASS)B.1.11 XI.M17 Flow-Accelerated Corrosion Miller Gayley B.1.12 XI.M18 Bolting Integrity Corsi Schilling B.1.13 XL.M20 Open-Cycle Cooling Water System Rafferty Gayley B.1.14 XL.M21 Closed-Cycle Cooling Water System Rafferty Camire B.1.15 XL.M22 Boraflex Rack Management Program Ouaou H.S. Sharma B.1.16 XL.M23 Inspection of Overhead Heavy Load and Ouaou Gonzalez Light Load (Related to Fuel Handling)Handling Systems B.1.17 XL.M24 Compressed Air Monitoring Micklo Trettel (Was Bill Mussel)B.1.18 XL.M25 BWR Reactor Water Cleanup System Miller Harttraft B.1.19 XL.M26 Fire Protection Getz Trettel B.1.20 XL.M27 Fire Water System Muggleston Trettel 13 Project/Plant Program Owners program program Oyster Creek Aging Mgt. Program L Team OSitne B.1.21 XI.M29 Aboveground Outdoor Tanks Micklo Olzsewski (Was Michelle Kichline)B.1.22 XI.M30 Fuel Oil Chemistry Miller Artz B.1.23 XI.M31 Reactor Vessel Surveillance May Harttraft B.1.24 XI.M32 One-Time Inspection Miller Quintenz 8.1.25 XI.M33 Selective Leaching of Materials Micklo Camire B.1.26 XI.M34 Buried Piping Inspection Rafferty Tamburro B.1.27 XI.S1 ASME Section Xi, Subsection IWE Ouaou Harttraft B.1.28 XI.S3 ASME Section XI, Subsection IWVF Corsi Harttraft B.1.29 XI.S4 10 CFR Part 50, Appendix J Getz Francis B.1.30 XI.S5 Masonry Wall Program Ouaou Niogi B.1.31 Xl.S6 Structures Monitoring Program Ouaou Niogi B.1.32 XI.S7 RG 1.127, Inspection of Water-Control Ouaou Niogi Structures Associated With Nuclear Power Plants B.1.33 XI.S8 Protective Coating Monitoring and Miller Martinez Maintenance Program (Was John Clark B.1.34 Xl.E1 Electrical Cables and Connections Not Spamer Pruthi Subject to Environmental Qualification Requirements B.1.35 XI.E2 Electrical Cables Not Subject to Spamer Johnson 10CFR50.49 Environmental Qualification Requirements Used in Instrumentation Circuits B.1.36 Xl.E3 Inaccessible Medium Voltage Cables Not Spamer Pruthi Subject to 10CFR50.49 Environmental Qualification Requirements B.1.39 XI.E6 Electrical Connections (new per 2005 GALL) Spamer Pruthi B.2 Plant Specific Programs B.2.1 Periodic Testing of Containment Spray Getz Schwartz Nozzles Lubricating Oil Monitoring Activities Miller Browstow (Was B.2.2 Rick Conley)B.2.3 Generator Stator Water Chemistry Activities Corsi Michelle Mura (Was Michael Ford)B.2.4 Periodic Inspection of Ventilation Systems Micklo Yuen B.2.5 Periodic Inspection Program Corsi Quintenz B.2.6 Wooden Poles Spamer Skelskey B.2.7 Periodic Monitoring of Combustion Turbine Muggleston Skelskey Power Plant .B.3 TLAA Evaluation of Aging Management Programs Under 10 CFR 54.21 (C) (1) (iii) I I 14 Project/Plant Program Owners LRA GALL OytrCekAigMtIrga R Team Site program program Oldster Creek Aging Mgt. Program Owner Owner B.3.1 X.M1 Metal Fatigue of Reactor Coolant Pressure May Harttraft Boundary B.3.2 X.E1 Environmental Qualification (EQ) Program May Hertz 15

~- --Plant System / Component 1-R Leads & Reviewers Plant System / Component LR Leads & Reviewers System / Structure LR Team Original New Lead Site Site Reviewer Reviewer 120 VAC Vital Power System Kevin Char Desai Muggleston 120/208 Volt Non-Essential Distribution Kevin Char Desai System Muggleston 125V Station DC System Kevin ike Heck Muggleston 24/48V Instrument Power DC System Kevin Mike Heck Muggleston 4160V AC System Kevin Mike Filippone Joe Booty Muggleston 4160V Switchgear Room Ventilation Kevin John Yuen Muggleston 480/208/120V Util. (JCP&L) Non-Vital Power Charlie Char Desai Micklo 480V AC System Kevin Mike Filippone Muggleston 480V Switchgear Room Ventilation Charlie John Yuen Micklo Alternate Rod Injection System (ARI) Dave Honan im Frank Ambulance Building Ahmed Sujit Niogi Ouaou Augmented Off-Gas Closed Cooling Water Lou Corsi Joe Booty System -544 Augmented Offgas System -231 Lou Corsi oe Booty riadna Gutierrez Automatic Depressurization System Stu Getz Sylvain_ __ Schwartz Battery and MG Set Room Ventilation Kevin John Yuen Jannette Gonzalez Muggleston Breathing Air Compressor Building Ahmed ujit Niogi Ouaou Breathing Air System Charlie William Mussel Tim Trettel Micklo C Battery Room Heating & Ventilation Kevin Mike Heck Muggleston Canal Water Temperature Monitoring System Kevin Everett Muggleston Johnson Cathodic Protection System Kevin Hari P. Sharma Muggleston 16 Chemical Laboratory Auxiliary Gasses -858 Lou Corsi Ariadna Gutierrez Chlorination Facility Ahmed Sujit Niogi Ouaou Chlorination Systems -561 Lou Corsi Michelle annette Gonzalez__ __ Kichline Circulating Water System Kevin John Camire Muggleston Combustion Turbine Building Ahmed Sujit Niogi Ouaou Component Supports Commodity Group Ahmed ujit Niogi Ouaou Condensate System -421, 423 Lou Corsi Cliff Elliott Condensate Transfer building Ahmed Sujit Niogi Ouaou _ _ _ _ _ _System / Structure LR Team Original New Lead Site Site Reviewer Reviewer Condensate Transfer System -reassigned to Charlie Jannette Charlie Micklo Micklo Gonzalez Containment Inerting System Mark Miller Bob Barbieri Containment Spray System Shannon Sylvain Rafferty chwartz Containment Vacuum Breakers -243 Lou Corsi Bob Barbieri Control Rod Drive System Dave Honan Jim Frank Control Rods Stu Getz Rick Thompson Control Room HVAC Charlie John Yuen Micklo Core Spray System Stu Getz Sylvain Schwartz Cranes and Hoists Ahmed Jannette Ouaou Gonzalez Dilution Structure Ahmed Sujit Niogi Ouaou Dilution System Charlie Jannette Micklo Gonzalez Discharge Structure and Canal Ahmed Sujit Niogi Ouaou Drywell Cooling System Mark Miller Bob Barbieri ._ _Drywell Floor and Equipment Drains Stu Getz Bob Barbieri Electrical Heat Trace System Kevin oe Booty Muggleston Elevators

& Manlifts Ahmed annette Ouaou Gonzalez Emergency Diesel Generator and Auxiliary Charlie Rick Skelskey Systems Micklo Emergency Diesel Generator Building Ahmed Sujit Niogi Ouaou Emergency Service Water System Shannon Sylvain.Rafferty chwartz Exhaust Tunnel Ahmed ujit Niogi I Ouaou _17 Feedwater System -422, 625 Lou Corsi lCliff Elliott Fire Pond Dam Ahmed Sujit Niogi Ouaou Fire Protection System (Assigned to LJC 9/10) Kevin Tim Trettel Muggleston Fire Pumphouses Ahmed Sujit Niogi Ouaou Fish Sample Pool Building Ahmed Sujit Niogi Ouaou Fuel Assemblies Stu Getz Rick Thompson Fuel Storage and Handling Equipment Ahmed Rick Thompson Hari S. Sharma (Includes Fuel racks, Cask Drop Protection Ouaou Fuel Racks);Sys) Jannette Gonzalez.F uel Handling)Grounding and Lightning Protection System Kevin Hari P. Sharma Muggleston Hardened Vent System Mark Miller Bob Barbieri Heat Exchanger Building Ahmed Sujit Niogi Ouaou _Heating & Process Steam System Stu Getz Michelle Giselle Martinez Kichline Heating Boiler House Ahmed Sujit Niogi Ouaou _Hydrogen & Oxygen Monitoring System Mark Miller Bob Barbieri Hydrogen Water Chemistry System Mark Miller Michelle Giselle Martinez Kichline Independent Spent Fuel Storage Installation Ahmed Hari S. Sharma im Frank Ouaou System / Structure LR Team Original New Lead Site Site Reviewer Reviewer Instrument (Control)

Air System Charlie William Mussel im Trettel Micklo Intake Structure

& Intake Canal Ahmed Sujit Niogi Ouaou Intermediate Range Monitoring System Stu Getz Everett ohnson solation Condenser System Stu Getz ylvain__ Schwartz Lighting System Shannon Everett Rafferty Johnson Low Level Radwaste Facility Ahmed Sujit Niogi Ouaou LPRM System/APRM System Stu Getz Everett J_ ohnson Main Condenser

-302 Lou Corsi John Camire Main Condenser Air Extraction System -331, Lou Corsi William Mussel ohn Wolfrom 332 Main Fuel Oil Storage & Transfer System Dave Honan Michelle iselle Martinez Kichline 18 Main Generator and Auxiliary Systems -711, 712, 713,714,715, 716,717 Lou Corsi oEldon Bearden Main Office Building HVAC Charlie John Yuen Micklo .-Main Steam System Tom William Mussel John Wolfrom Quintenz_Main Turbine and Auxiliary Systems -301, Lou Corsi EIdon Bearden 303, 304, 311,312, 313, 314, 315,412, 413, 324, 431 Maintenance Building Ahmed ujit Niogi Ouaou Materials Storage Buildings Ahmed ujit Niogi Ouaou Meteorological Monitoring System -662 Lou Corsi Everett Johnson Miscellaneous Floor and Equipment Drain Stu Getz Chris Lefler Systems Miscellaneous HVAC Systems Kevin John Yuen Muggleston Miscellaneous Yard Structures Ahmed ujit Niogi Ouaou _Monitoring and Change Facility Ahmed Sujit Niogi Ouaou New Radwaste Building Ahmed ujit Niogi Ouaou _New Radwaste Closed Cooling Water System Charlie hris Lefler Micklo New Radwaste Service Water System Kevin Chris Lefler Muggleston New Sample Pumphouse Ahmed ujit Niogi Ouaou Nitrogen Supply System Charlie ob Barbieri Micklo Noble Metals Monitoring System Mark Miller Ariadna G utierrez Nuclear Boiler Instrumentation Stu Getz Everett Joe Booty Johnson Offgas Building Ahmed ujit Niogi Ouaou Office Building Ahmed Sujit Niogi Ouaou Offsite Power Systems Charlie Rick Skelskey Micklo Old Radwaste Building Ahmed Sujit Niogi Ouaou Other Office Buildings Ahmed ujit Niogi Ouaou System / Structure LR Team Original New Lead Site Site Reviewer Reviewer Penetration Pressurization System Ahmed 3ob Barbieri Ouaou I I 19 Pipe Tunnel Ahmed Ouaou Sujit Niogi Plant Annunciator System Kevin riadna Muggleston utierrez Plant Communications Systems Shannon riadna Rafferty utierrez Plant Computer Systems Kevin shok Syngal Muggleston

.Post-Accident Monitoring System Charlie riadna Micklo Gutierrez Post-Accident Sampling System Stu Getz Joe Booty Pretreatment building Ahmed Sujit Niogi Ouaou Primary Containment Ahmed Bob Barbieri Ouaou Process Sampling System Shannon Michelle Eldon Bearden Rafferty ichline Radiation Monitoring System Kevin Everett Muggleston Johnson Radio Communication System Dave Honan Ariadna Gutierrez Radwaste Area Heating & Ventilation Charlie Chris Lefler Micklo, Radwaste Systems Charlie Chris Lefler Micklo RAGEMS Building Ahmed Sujit Niogi Ouaou Reactor Building Ahmed Sujit Niogi Ouaou Reactor Building Closed Cooling Water Mark Miller Bob Barbieri System Reactor Building Floor and Equipment Drains Stu Getz hris Lefler Reactor Building Ventilation System Charlie John Yuen Micklo Reactor Head Cooling System Dave Honan im Frank Reactor Internals Mike May Greg Harttraft Reactor Manual Control System Dave Honan Jim Frank Reactor Overfill Protection System Stu Getz Joe Booty Reactor Pressure Vessel Mike May Greg Harttraft Reactor Protection System Kevin oe Booty Muggleston Reactor Recirculation System Stu Getz Bob Barbieri Reactor Water Cleanup System Mark Miller Ariadna Gutierrez Remote Shutdown System (electrical:

no Kevin Rick Skelskey (a)(2) or screening)

Muggleston Respirator Facility Ahmed Sujit Niogi Ouaou Rod Worth Minimizer Dave Honan Jim Frank Roof Drains and Overboard Discharge Mark Miller Chris Lefler Sanitary Waste System -581/872 Lou Corsi Chris Lefler Screen Wash System Charlie ohn Camire Micklo 20 Security Structures Ahmed Ouaou Sujit Niogi Service Air System Charlie William Mussel Tim Trettel Micklo Service Water System Mark Miller John Camire, Shutdown Cooling System Stu Getz Sylvain Schwartz Site Emergency Building Ahmed Sujit Niogi Ouaou System / Structure LR Team Original New Lead Site Site Reviewer Reviewer Source Range Monitoring System Mike May Everett._J ohnson Spent Fuel Pool Cooling Systems -251, 255 Lou Corsi Bob Barbieri Standby Gas Treatment System Charlie John Yuen Micklo Standby Liquid Control System (Liquid Poison Mark Miller Ariadna System) Gutierrez Station Blackout System Charlie Rick Skelskey Micklo Torus Water Storage & Transfer System -243 Lou Corsi ob Barbieri Traveling In-Core Probe System Stu Getz Everett Johnson Turbine Building Ahmed Sujit Niogi Ouaou Turbine Building Closed Cooling Water Mark Miller John Camire System Turbine Building Ventilation System Charlie John Yuen Micklo Ventilation Stack Ahmed ujit Niogi Ouaou .-Water Treatment

& Distr. Systems Shannon William Mussel John Wolfrom Rafferty Zinc Injection System Mark Miller Michelle Giselle Martinez Kichline 21 EINFORMATION MANAGEMENT The LR Project Team will maintain a database of NRC Information Requests and their responses.

Specific familiarization on the system will be provided to the License Renewal team. Requests may be entered directly, or they may be hand written and provided to the Administrative Assistant or Licensing Lead.A copy of an Information Request form that can be used by an NRC inspector or License Renewal team member is provided on the next page. Each completed form should be given promptly to the Administrative assistant or Licensing Lead for data entry.The database itself should be used in lieu of this form when questions are provided electronically or if time permits. Any member of the License Renewal team may enter questions and responses.

Before a response is give to the NRC requestor, the response shall be independently reviewed by an assigned peer and approved by the LR Technical Lead. The actual response provided to the requestor should normally be printed out of the database using the report capability provided.22 I NRC INFORMATION REQUEST FORM Item Number: Date Initiated:

Date Initiated:

Topic: Document

References:

NRC Representative:

AmerGen Representative:

Request: Assigned to: Response: LRCR: Additional Action (e.g., IR#): Approvals:

Prepared by/Date: Reviewed by/Date: Approved by/Date: NRC Acceptance (Date): 23 I Inspection Communications Channels The following is a communications hierarchy for the License Renewal audit / inspections.

By following this hierarchy we will ensure consistent communications and that the appropriate levels of NRC and License Renewal management are informed of responses to questions raised by the audit / inspection teams. This hierarchy will also enhance our ability to escalate and resolve issues with the NRC.NRC Contact AmerGen/OC Counterpart Frequency of Contact NRR Director License Renewal Fred Polaski As needed for issue resolution

-PT Kuo NRR License Renewal Safety PM l Fred Polaski and John Hufnagel l Daily or weekly to ensure adequate progress and resolution of issues-Donnie Ashley NRR License Renewal Bill Maher Daily or weekly to ensure adequate Environmental PM (Michael Masnik) progress and resolution of issues Audit and/or Inspection Team Lead Don Warfel and John Hufnagel Frequent daily contact during Audits Scoping/Screening Methodology to ensure progress and resolution of-Steve Tingen issues AMP/AMR-Greg Cranston Regional Inspections

-Michael Modes NRC inspection

/ Audit team LR Team members, as assigned As needed during course of audit /member by LR Technical Lead and inspection System Mgrs and Program Owners NRR Part 50 PM Dave Helker and Jhansi As Needed-Peter Tam Kandasamy 24 I Oyster Creek Audit / Inspection Information Request Flow Chart I Assign responder, peer reviewer and log into Info Request 1-database Updated 9/14/05 25 Routine External Communications

-License Renewal Project (Based on LS-AA-1030)

Updated 9/21/05 Executive/Manager Agency Personnel Frequency Licensing/Regulatory Communications Meeting Arranger Assurance Support Objective Senior Vice President, Director, NRR Quarterly Vice President, Discuss overall project Joan Bruning Mid-Atlantic Operations (Jim Dyer) (Timing -soon Licensing

& Regulatory status; any major issues after monthly Affairs or Mid Atlantic project update) Licensing Director, if needed Corporate Vice President, Director, Division of Quarterly Mid Atlantic Licensing Review any Regulatory or Helen Tiberghien Licensing

& Regulatory License Renewal Director Political Issues, Concerns Affairs (Frank Gillespie)

Site Vice President, Oyster Deputy Director, Monthly MA Licensing Director or Demonstrate engagement Marita Zaremba Creek Generating Station Division of License Exclon License Renewal with License Renewal Renewal Licensing Lead, as needed process (P.T. Kuo)Director, Mid-Atlantic Branch Chief, Monthly Exelon License Renewal Review project progress Karen Simpson Licensing, Exelon Manager, License Renewal Licensing Lead and effectiveness of License Renewal and (Sam Lee/Louise Licensee -NRC Exelon LR Licensing Lead, Lund) communications as needed Exelon License Renewal License Renewal Daily (Phone); N/A Routine project business; Karen Simpson Licensing Lead Project Manager Monthly identify, anticipate and (Donnie Ashley) (Face-to-Face) resolve project issues Exelon LR Manager and NJDEP/BNE Monthly N/A Identify/address issues of John Hufnagel Licensing Lead; Exelon Jill Lipoti concern with the State Environmental Lead; Oyster Kent Tosch Creek Reg. Assurance Manager Note: Exelon/AmerGen has established a lead individual who is responsible to be involved with and to manage all External communications (the LR project Licensing Lead, John Hufnagel).

He must be kept informed of all regulatory interactions associated with License Renewal.26 License Renewal -Issues Management Flowchart (9/29/05)Ma nageert Guideinnae

.2ntic Licensing Directorproc s NDO i aimmediated communndatihn.

Alse insed Renewale H SRntlf oSr RenAtr s ormAd Questns .f em VA Manager on Issue. notificaton Is reqluired.

Corporate Communications upatso an significant

~Determine Th addLcs n (630) 657-2 Leads & Government Aftaers eh ea tn he b communications are per rd.i -m aeelt my( t t of NRC AOI with) sueImsaeb/ / 7 /Notes: 1. This process is consistent with Exelon Procedure LS-AA- 1004, NRC Case Management Guideline.

2. Separate processes as defined in the License Renewal Handbook; are used for RAIs or Audit Questions.
3. "The License Renewal licensing lead is responsible to see that the above actions are performed.

27 Glossary of Terms l License Renewal Inspection

/ Audit Terms Audit -License Renewal: A review of documentation and underlying references to determine the accuracy of submitted material in order to reach a reasonable assurance that identified aging will be adequately managed during the period of extended operation.

NRC headquarters personnel or their contractors normally conduct this effort.Inspection

-License Renewal: A review of documentation and underlying references to determine the accuracy of submitted material in order to reach a reasonable assurance that identified aging will be adequately managed during the period of extended operation.

Inspections are normally focused on the in-plant implementation of LR processes and programs to identify affected passive equipment and manage aging. NRC regional personnel or their contractors normally conduct this effort.Information Request: A question asked of the Oyster Creek organization to clarify information provided in the License Renewal Application.

These can be received in verbal, draft or final written form. Responses are provided directly to the NRC team member in verbal or written form. Information requests and responses will be tracked by the License Renewal staff in a database.Request For Additional Information (RAI): Written question provided by NRC in a formal, docketed letter. An RAI requires a formal written response in a docketed letter. AmerGen letters responding to RAls will be submitted to NRC under oath or affirmation.

These letters actually modify the License Renewal Application.

License Renewal Process Terms Scoping and ScreeninM:

A License Renewal process for selecting those systems, structures and components that meet 10 CFR 54 for being in-scope and subject to and Aging Management Review.Aging Management Fleview (AMR): A system, structure of component specific technical evaluation of materials, and environments that identifies potential aging effects and an appropriate aging management program for managing the identified aging effect.Aging Management Program (AMP): A program designed to manage identified aging effects in in-scope systems, structures and components Aging Management Program Document:

A detailed formal description of an aging program structured to detail how the program meets 10 generic or program specific elements described in NRC License Renewal guidance documents.

Integrated Plant Assessment (IPA): A process that incorporates the Scoping and Screening and AMR process for Oyster Creek 28

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