ML20095G777
| ML20095G777 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/23/1995 |
| From: | Detter G, Sly C BALTIMORE GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20095G750 | List: |
| References | |
| RM-1-103, NUDOCS 9512210278 | |
| Download: ML20095G777 (13) | |
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O Calvert Cliffs Nuclear Power Plant Administrative Procedure -
l COMMITMENT MANAGEMENT )
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. RM-1-103 Resision 0 O
Effective Date JllN 211995 ussa l CONTROUED i Tech Spec Related M210 Management Related N.
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Writer: C. D. Sly Sponsor: G. L. Detter, Director-Nuclear Regulatory Matters 7,) '/ ,
Approved T' / 5/l3/ff
$1anager Nudear En:Ineering Department Date l
C l 9512210278 951215 PDR ADOCK 05000317 P PDR
RM 1-103 Commitment Management Revision 0 Page 2 of 13 O RECORD OF REVISIONS AND CIIANGES REVISION CIIANGE
SUMMARY
OF REVISION OR CIIANGE 0 0 Initial Issue O
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RM-1-103 Commitment Management Revision 0 Page 3 of 13 e TABLE OF CONTENTS k SECTION TITLE PAGE
1.0 INTRODUCTION
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, 1.1 Purpose. . . . .. . . . . . . . . . . . .
.....................................5 1.2 Scope / Applicability .. .. .. . .. ..................................................5
2.0 REFERENCES
.. . . .. . . . . . . . . . . . . . . . . . . . . . . ..........................5 2.1 Developmental References ....... . ........... ...... .... . .. .... ....... ..............5 2.2 Performance References.. . . . . . . . . . . . . . . . . .... . ..............5 3.0 DEFINITIONS .. .. . .. .. .. . . . . . . . . . . . . . . . . . .. 5 4.0 RESPONSIBILITIES. , . .. . . . . . . .... . . . . .. .. 6 5.0 PROCESS. . .. . . . .. . . . .. ... . .. .. 7 5.1 Identification, Acceptance, and Assignment of Commitments... 7
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i 5.2 Completion and Closure of Commitments.. . . . . . . . . . . . . , . . . . . .9 )
5.3 Final Disposition of Conunitments . . .. .. .9
(.NJ 5.4 Revising and Deleting Conunitments. ... . . . . . . . .10 5.5 Generating Status Reports . . ... . . . . . . . .10 1
6.0 BASES. , . . .. . . . . . . . 11 7.0 RECORDS.... . . . . .. . , , . 11 ,
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ATTACHMENTS i Attachment 1, Nuclear Regulatory Action Item Identification Form.. .. ... .I1 Attachment 2, Current Licensing Basis Determination Guidance. . . . . .12 f
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RM-1 103 Commitment Management Revision 0 Page 4 of 13 LIST OF EFFECTIVE PAGES Page No. Change No. Page No. Change No. Page No. Change No.
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Commitment Management RM-1-lO Revision 0 Page 5 of 13
1.0 INTRODUCTION
O O 1.1 Purpose This procedure establishes the controls and requirements for identifying, implementing, closing, changing, and managing Nuclear Regulatory Commitments in docketed correspondence between Calvert Cliffs Nuclear Power Plant (CCNPP) and the Nuclear Regulatory Commission (NRC).
[B-1]
1.2 Scope / Applicability The Commitment Management process is applicable to all personnel involved in the identification, implementation, close out, changing, and general management of Commitments identified m l
docketed correspondence between CCNPP and the NRC. l 1
2.0 REFERENCES
2.1 Developmental References A. RM-1, Licensing and Regulatory Matters Program Directive. l B. PR-1-100, Preparation and Control of Calvert Cliffs Administrative Procedures.
C. Administrative Procedures Writer Manual, dated January 20,1994.
D. Letter from R. E. Denton (BGE) to T. T. Martin (NRC) dated March 11,1994,
" Completion of Regulatory Commitment Review."
d 2.2 Performance References A. QL-2-102, Action item Tracking.
B. RM-1-104, Updating the Safety Analysis Report (Updated Final Safety Analysis Report and Updated Safety Analysis Report.
C. RM-1-102, License Amendments and Technical Specifications Bases Changes.
3.0 DEFINITIONS A. Nuclear Regulatory Action Item A Standard Source action item in accordance with QL-2-102, Action Item Tracking, that targets specific actions to implement a Commitment, defines methods for meeting regulatory requirements, or corrects or precludes the recurrence of adverse conditions of interest to the NRC.
A
RM-1-103 Commitment Management Revision 0 Page 6 of 13 3.0 DEFINITIONS (Continued)
B. Commitment A docketed statement to or by the NRC which either establishes a Current Licensing Basis (CLB) requirement or promises a future action which has not yet been accomplished, or both. Commitments do not include statements of fact, descriptions of plant equipment, programs, or voluntary information not intended to constitute a Commitment.
In general, CLB level Commitments contain information regarding the specific method of implementing a regulatory requirement which wanants inclusion in a CLB document. He scope and level of detail of the,CLB, the significance of the information to public health and safety, and the extent to which it is material to an NRC decision are a guide to whether a commitment belongs in the CLB.
Calvert Cliffs Nuclear Power Plant is obligated to keep the NRC adequately informed of the status and disposition of Commitments. Calvert Cliffs Nuclear Power Plant has the latitude to revise the scope, details, and ultimate disposition of the intended actions.
C. Current Licensing Basis That body ofinformation describing the facility and the conduct ofits operations which has been evaluated by the NRC and relied upon as the basis for meeting the applicable regulations; and/or has been accepted by a Safety Evaluation Report or otherwise imposed on Baltimore Gas and Electric Company (BGE); and/or is a part of the operating license and accompanying technical specifications, including modification by order.
( 4.0 RESPONSIBILITIES 4.1 Department Managers / Superintendents / General Supervisors / Directors Department Managers / Superintendents / General Supervisors (GS)/ Directors responsibilities include:
A. Exercising the responsibilities of QL-2-102, Action Item Tracking, regarding Nuclear Regulatory Action Items assigned to their organizations.
4.2 Director-Nuclear Regulatory Matters (D-NRM)
D-NRM responsibilities include:
A. Providing resources for the management and implementation of the Commitment Management process.
B. Serving as the primary interface with the NRC conceming the management, control, and ultimate resolution and disposition of Commitments.
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Commitment Management RM-1-103 Revision 0 -
Page 7 of 13 4.3 Regulatory Task Manager (RTM)
RTM responsibilities include:
l A. Working with the Commitment Tracking Coordinator (CTC) to identify potential Commitments in incoming and outgoing docketed correspondence.
B. Advising responsible organizations on the intent of Commitments, maintaining awareness ,
of the scope and schedule of assigned Nuclear Regulatory Action items, and maintaining any necessary interface with the NRC.
C. Fulfilling the responsibilities of an Action Item Source for assigned Nuclear Regulatory .
Action Items as detailed in QL-2-102, Action Item Tracking.
l D. Monitoring resolution progress of assigned Nuclear Regulatory Action Items, including review of documentation prior to update of the Action Item Tracking E ; tem, and advising the D-NRM of any regulatory issues that arise while performing this monitoring function.
4.4 Commitment Tracking Coordinator CTC responsibilities include: '
A. Assigning all incoming and outgoing docketed correspondence to an RTM for the identification of Commitments.
B. Maintaining and updating Nuclear Regulatory Action Items on the Action Tracking System in accordance with QL-2-102, Action Item Tracking.
O 4.5 Responsible Individual (RI)
RI responsibilities include:
A. Acting as the Action Item Sponsor in accordance with QL-2-102, Action Item Tracking, for assigned Nuclear Regulatory Action Items.
B. Coordinating significant scope changes or extension requests to Nuclear Regulatory Action Items and Commitments with the RTM in accordance with QL-2-102, Action Item Tracking, and obtaining required approvals.
5.0 PROCESS 5.1 Identification, Acceptance, and Assignment of Commitments l i
A. The CTC shall:
- 1. Review incoming and outgoing docketed correspondence and determine the appropriate responsible RTM.
- 2. Forward the docketed correspondence to the responsible RTM with an Attachment 1 " Nuclear Regulatory Action Item Identification Fomi."
Commitment Management RM-1-103 Revision 0 Page 8 of 13 5.1 Identification, Acceptance, and Assignment of Conimitments (Continued)
NOTE The RTM should be alert to any new issues identified in docketed correspondence that may warrant the initiation of an Issue Report in accordance with QL-2-100, Issue Reporting System.
l B. The RTM shall: l
- 1. Review the docketed correspondence and document the following on i
Attachment 1:
- a. All Commitments in the correspondence.
- b. The Nuclear Regulatory Action item milestone descriptions required to effectively implen ent the Commitments.
- c. The Responsible Organization for implementation of each Nuclear Regulatory Action Item.
- d. If the Nuclear Regulatory Action Item is already being tracked on the ;
J Action Item Tracking System. '
- 2. The RTM shall coorainate the required Nuclear Regulatory Action Items with the Responsible Organization in accordance with QL-2-102, Action Item Tracking including contacting them to ensure they unders' -,d and agree with the wording of any new Nuclear Regulatory Action Items.
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- 3. The RTM shall perform a screen of each Conu .unent to determine whether the CLB requires revision and ensure required changs are initiated and tracked on the Action Item Tracking System. Attachment 2, Current Licensing Basis Determination Guidance, provides guidelines for this determination.
- 4. The RTM shall forward the Attachment I and docketed corresponrbee ic the CTC.
C. Upon receipt of the completed Attachment I from the RTM, the CTC shall:
- 1. Initiate and/or update the required Nuclear Regulatory Action Items in accordance with QL-2-102, Action Item Ti king.
- 2. Ensure the RTM reviews the Action Item Tracking System changes and additions to verify their completeness and accuracy.
- 3. If the Nuclear Regulatory Action Item is already being tracked, ensure it is appropriately updated and the responsible person notified of the update.
- 4. Contact the targeted Organization to ensure they understand and agree with the wording of any new Nuclear Regulatory Action Items.
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RM-1-103 Commitment Management Revision 0 Page 9 of 13 5.1 Identification, Acceptance, and Assignment of Commitments (Continued)
D. Upon receipt of the Nuclear Regulatory Action Item on the Action Item Tracking System, the responsible GS shall follow the requirements of QL-2-102, Action Item Tracking for Standard Source Action Items.
5.2 Completion and Closure of Commitments A. The RI assigned the Nuclear Regulatory Action Item shall complete the required actions by the due date specified on the Action Item Tracking System and provide appropriate updates of progress to the RTM.
B. The RI shall coordinate scope changes and extensions to Nuclear Regulatory Action Items i with the RTM in accordance with QL-2-102, Action Item Tracking, and obtain required approvals.
C. Upon completion of a Nuclear Regulatory Action Item, the RI shall update the Action Item i Tracking System in accordance with QL-2-102, Action Item Tracking, and submit l
objective evidence of the closure. Objective evidence includes the following:
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- 1. For procedure revisions, a copy of the revised procedure pages and the signed procedure cover sheet.
- 2. For Facility Change Requests (FCR), a copy of the completed FCR cover sneet.
- 3. For Maintenance Orders (MO), a copy of the completed MO cover sheet.
O Q D. Upon receipt of the Nuclear Regulatory Action Item closure document, the RTM shall review the information for overall completeness and effectiveness.
- 1. If the Nuclear Regulatory Action Item closure document is acceptable, the RTM shall submit the documentation to the CTC for closure.
- 2. If the Nuclear Regulatory Action Item closure document is unacceptable, the RTM shall follow the requirements of QL-2-102, Action Item Tracking to resolve the issue.
E. Based on the recommendation of the RTM, the CTC shall update the Action Item Tracking System in accordance with QL-2-102, Action Item Tracking.
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Commitment Management ' RM-1-103 Revision 0 1 Page 10 of 13 '
5.3 Final Disposition of Commitments lO NOTE l
It is the intention of this process that all Commitments u!:imately become historical and be maintained by a site process that is commensurate with their safety significance or captured in the CLB. l A. Upon closure of all Nuclear Regulatory Action Items associated with a Commitment, the RTM shall review the original commitment and the actions taken to ensure they meet NRC expectations for closing and make the appropriate follow-up notifications to the NRC.
B. Once the Commitment is reloc'ated into the appropriate CLB document, it may be closed i on the Commitment Maintenance Module of NUCLEIS. 1 5.4 Revising and Deleting Commitments l
NOTE This process applies only to Commitments that have not yet been completed. Historical Commitments may be changed utilizing the change process of the plant program to which they were ultimately dispositioned.
It should be understood that many Commitments mtv be changed without NRC approval as long as BGE determines the change does not reduce the degree of public health and safety gained by the original Commitment.
O A. Any organization or individual which requires an alteration or deletion of a Commitment shall:
- l. For active Nuclear Regulatory Action Items or Commitments in the Commitment i i
Maintenance Module, contact the RTM or CTC and follow the requirements of '
QL-2102, Action item Tracking.
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- 2. For Commitments which have been incorporated into the CLB, implement the appropriate process to change the CLB.
B.
Once a Commitment change is approved, the RTM shall coordinate any required follow-up activities, including:
- 1. Making the necessary communications to the NRC.
- 2. Ensuring all new Commitments resulting from the change are dispositioned in accordance with this procedure.
- 3. Ensuring the Commitment change documentation is submitted to the CTC.
5.5 Generating Status Reports A. The CTC may generate reports to status Nuclear Regulatory Action items.
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k Commitment Management RM-1-103 Revision 0 Page 11 of 13 6.0 BASES None 7.0 RECORDS None l
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RM-1-103 Commitment Management Revision 0 Page 12 of 13 ATTACHMENT 1. NUCLEAR REGULATORY ACTION ITEM IDENTIFICATION FORM
- 1. Document Name
- 2. Document Date 3. AIT Number i
- 4. Document Number
- 5. Action Item / Commitments Identified (Provide Responsible Person / Organization and Due Dates)
A.
O B.
- 6. CLB Revision Required? Yes No Type ; Initiation Date RTM Date CTC Date O
RM-1-103 l Commitment Management Revision 0 Page 13 of 13 ATTACIIMENT 2, CURRENT LICENSING BASIS DETERMINATION GUIDANCE
- 1. Does implementation of the Commitment require a change to the Current Licensing Basis?
Yes. Initiate the change utilizing the appropriate process. (UFSAR per RM-1-104; Technical Specifications per RM 1-102).
- 2. Can the Commitment be evaluated by the Probabilistic Safety Assessment?
Yes. Is the impact of the Commitment risk significant?
Yes. Capture the Commitment by initiating a change to the appropriate Current Licensing Basis document or as a bases capture in an established plant process.
Maybe. Continue with the balance of this Question.
No. Could changing the Commitment negatively impact the ability of a system, structure, or component to perform its safety function?
Yes. Capture the Commitment by initiating a change to the appropriate Current Licensing Basis document or as a bases capture in an established plant process.
- 3. Was the Commitment necessary for compliance with an Obligation (i.e., rule regulation or license condition)?
Yes. Capture the Commitment by initiating a change to the appropriate Current Licensing Basis document or as a bases capture in an established plant process.
- 4. Was the Commitment credited: (1) as the basis for a safety decision in an NRC Safety Evaluation Report,(2)in a response to an NRC Bulletin or Generic Letter, or (3) in an NRC Confirmatory Action Letter?
Yes. Capture the Commitment by initiating a change to the appropriate Current Licensing Basis document or as a bases capture in an established plant process.
- 5. Was the Commitment made to minimize recurrence of an adverse condition (i.e., a long-term corrective action stated in a Notice of Violation response?)
Yes. Ensure the Commitment is Bases captured in a controlled plant process. I O
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