ML20217B965

Discusses NRC Audit of Licensee Programs for Managing Commitments Made to Nrc.Audit Will Be Performed by NRR PM Using Encl Guidance Document & Will Take Place During Next 90 Days.Findings Will Be Reported to Commission

ML20217B965
Person / Time
Site:	River Bend
Issue date:	03/23/1998
From:	Wigginton D NRC (Affiliation Not Assigned)
To:	Mcgaha J ENTERGY OPERATIONS, INC.
References
TAC-MA0836, TAC-MA836, NUDOCS 9803260231
Download: ML20217B965 (3)

Text

r:

Mr. John R. McG;h3, Jr. -

March 23, 1998

. 3S,:_ Vice PresidInt - Oper:tions l Entergy Operations, Inc.

River Bond Station P. O. Box 220 St. Francisville, LA 70775 l

SUBJECT:

NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC (TAC NO. MA0836)

Dear Mr. McGaha:

The NRC staff has initiated a variety of activities related to the management of licensing basis

,, ' information as a result of problems encountered at the Millstone and Maine Yankee facilities. As i part of the staffs activities,' audits of commitment management programs will be performed at j- . eight representative reactor facilities. The audits will assess the licensees' implementation of -

j . commitments made to NRC and will also assess the long-term control of commitments as a j follow-up to the issuance of industry guidance for evaluating and reporting changes to )

l commitments made to the NRC. In this regard, River Bend Station has been selected as one of eight facilities at which the staff will audit commitment management programs.

'The audits will be performed by the NRR project manager and will be performed using the enclosed guidance document," Guidance for NRR Audit of Licensing Programs Managing l Commitments Made to the NRC." Audits will take place during the next 90 days and will require i

approximately one week onsite.' Specifics details regarding dates and information to be provided in advance will be coordinated with your staff. Following the completion of the audits, the staff will report the findings to the Commission and, as necessary, make recommendations for changes to NRC policy or regulations regarding the handling of commitments made to the NRC that are not otherwise controlled by specific regulations.

Thank you for your cooperation in support of this effort. You, or your staff, may direct any questions regarding the audit to either myself (301-415-1301) or William Reckley at (301) 415-1314.

Sincerely, ORIGINAL SIGNED BY:

David L Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-458 l

Enclosure:

As stated

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%[*****,$ March 23, 1998 Mr. John R. McGaha, Jr.

Vice President- Operations Entergy Operations, Inc. ,

River Bend Station  !

P. O. Box 220 St. Francisville, LA 70775 i

SUBJECT:

NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC (TAC NO. MA0836)

Dear Mr. McGaha:

g l The NRC staff has initiated a variety of activities related to the management of licensing basis l information as a result of problems encountered at the Millstone and Maine Yankee facilities. As part of the staff's activities, audits of commitment management programs will be performed at eight representative reactor facilities. The audits will assess the licensees' implementation of commitments made to NRC and will also assess the long-term control of commitments as a follow-up to the issuance of industry guidance for evaluating and reporting changes to commitments made to the NRC. In this regard, River Bend Station has been selected as one of eight facilities at which the staff will audit commitment management programs.

The audits will be performed by the NRR project manager and will be performed using the enclosed guidance document, Guidance for NRR Audit of Licensing Programs Managing Commitments Made to the NRC." Audits will take place during the next 90 days and will require approximately one week onsite. Specifics details regarding dates and information to be provided in advance will be coordinated with your staff. Following the completion of the audits, the staff will report the findings to the Commission and, as necessary, make recommendations for changes to NRC policy or regulations regarding the handling of commitments made to the NRC that are not otherwise controlled by specific regulations.

Thank you for your cooperation in support of this effort. You, or your staff, may direct any questions regarding the audit to either myself (301-415-1301) or William Reckley at (301) 415-1314.

Sincerely, 6

I David L. igginton, Senior Project Manager

. Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket No. 50-458

Enclosure:

As stated cc w/ encl: See next page

l

. Mr. John R. McGaha Entergy Operations, Inc. River Bend Station -

l cc:

I Winston & Strawn Executive Vice President and 1400 L Street, N.W. Chief Operating Officer l Washington, DC 20005-3502 Entergy Operations, Inc.

P. O. Box 31995 Manager- Licensing Jackson, MS 39286 Entergy Operations, Inc.

River Bond Station General Manager- Plant Operations P. O. Box 220 Entergy Operations, Inc. '

St. Francisville, LA 70775 River Bend Station P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 j l P. O. Box 1050 St. Francisville, LA 70775 Director- Nuclear Safety  ;

l Entergy Operations, Inc.  !

President of West Feliciana River Bend Station l Police Jury P. O. Box 220 P. O. Box 1921 St. Francisville, LA 70775 St. Francisville, LA 70775 Vice President - Operations Support  :

Regional Administrator, Region IV Entergy Operations, Inc.  !

U.S. Nuclear Regulatory Commission P. O. Box 31995 611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 Arlington, TX 76011 Attomey General ,

Ms. H. Anne Plettinger State of Louisiana l 3456 Villa Rose Drive P. O. Box 94095 Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 I Administrator Wise, Carter, Child & Caraway Louisiana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205

{ Baton Rouge, LA 70884-2135 l i

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NUCLEAR RECULATORY COMMISSION

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• • • • • January 5,199:8 MEMORANDUM TO: Roy P. Zimerman Associate Director for Projects FROM: rector Office of Nuclear Reactor Regulation l

SUBJECT:

NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC The NRC staff evaluated problems encountered with licensing basis issues at Millstone and Maine Yankee and offered lessons learned from these experiences in SECY-97-036. " Millstone Lessons Learned Report Part 2: Policy Issues."

dated February 12, 1997, and SECY-97-042. " Response to OIG Event Inquiry 96-045 Regarding Maine Yankee," dated February 18, 1997. Both reports ,

l recommended that, as part of an overall revision of its oversight of licensing l basis information the staff proceed with its plans to evaluate the industry's l implementation of comitment management systems. In related communications with the Commission, such as SECY-96-135 " Response to Event Inquiry - Maine Yankee Atomic Power Station (Case No.96-045), the NRC staff also stated that an assessment would be performed to verify that licensees had implemented commitments made to the NRC in past licensing actions. (amendments, exemptions, etc.) and licensing activities (bulletins, generic letters, etc.).

In SECY 95-300, " Nuclear Energy Institute's Guidance Document. ' Guideline for Managing NRC Commitments'." dated December 20, 1995, the staff informed the Commission that licensees

• commitment change processes, either implementation of the NEI guideline or licensee-specific programs. would be monitored at all reactor facilities to verify that commitments are being appropriately controlled. If the audit process shows that licensees have not implemented the NEI guidance, or have not adopted some equivalent level of control and documentation of changes to their commitments, the staff will reassess the need to promulgate staff guidance or initiate rulemaking. This reassessment will be initiated after the commitment control process at selected facilities has been audited using the attached guidance.

In order to address the follow-up items related to assessing licensees' commitment management systems, the divisions of reactor projects should perform audits of eight licensee programs for managing comitments in accordance with the attached, " Guidance for NRR Audit of Licensee Programs for l

Managing Commitments Made to the NRC." These audits are currently addressed in the Consolidated Operating Plan for Reactor Licensing. The audit should include licensees from each NRC region, licensees different from those CONTACT: William Reckley 415-1314 ENCLOSURE

l .'

c R. Zimmerman ".

included in previous comitment management audits, and licensees representin a variety of plant designs, plant ages, and performance assessment ratings. g The selection of plants for the audit should also consider the availability of i those project managers with the desired level of experience to most effectively perform the audit. -

I recognize that an audit of commitment management programs at a selected i sample of reactor facilities is less of a follow-u I SECY-95-300 (i.e., inspection of all facilities). pAlthough than was described in resource considerations and the need to complete other priority tasks preclude the more inclusive evaluations at this time, the audits may be sufficient to support a general assessment of comitment management programs implemented by licensees for operating reactors and support a decision regarding the possible need for additional actions by the NRC staff. The results from the audits and, if necessary, subsequent audits and inspections will also be incorporated into other staff activities ertaining to the appropriate controls for and maintenance of licensin basis information.

In order for the audits to help determine if additional regulatory actions are needed in the area of comitment management, please have your staff, working with the regional offices, select an appropriate sample of operating reactors for auditing of the licensees' programs for managing comitments made to the NRC. The lead project manager and the project managers for the selected facilities should incorporate the performance of the audits into their activity planning so that the pilot audits may be completed by May 1998 and i the results evaluated and documented by June 1998.

Attachment:

As stated I

i

l GUIDANCE FOR NRR AUDIT OF LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC i 1.0 OBJECTIVES 1

The audits will assess the adequacy of licensees

• implementation of a sample of comitments made to the NRC in past licensing actions (amendments. exemptions.

, etc.) and licensing activities (Julletins, generic letters. etc.). The NRC staff I informed the Comission that such assessments would be conducted as a follow-up to the licensing basis issues identified at facilities such as Maine Yankee and Millstone. The audits will also determine if licensees have implemented l a)propriate controls for managing current and future comitments made to the NRC i tlat are not controlled by a codified regulatory process such as 10 CFR 50.59 or 1 50.54. including notification of the NRC when changes to commitments are determined to have safety or regulatory significance. The combined results of these audits and other NRC activities will help to determine if additional regulatory actions' are needed in the area of comitmsnt management.

2.0 BACKGROUND

1 In the original Statements of Consideration for 10 CFR Part 54 " Requirements for l Renewal of Operating Licenses for Nuclear Power Plants." dated December 13,1991 1 (56 FR 64943), the Comission explained in some detail the basis for its belief that the current regulatory process provides an acceptable level of safety. ,

Among other things, the Comission described a process whereby licensee-initiated i

. changes to any particular plant's licensing basis are subject to the Commission's ,

formal regulatory controls. This process ensures that a documented basis for '

licensee-initiated changes in the licensing basis exists and that NRC staff review and approval is obtained before implementation if the changes to the licensing basis raise an unreviewed safety question or involve changes to the technical specifications.

In SECY-92 314. " Current Licensing Basis for Operating Plants." dated September

10. 1992, the staff responded to the Comission's request to 3rovide information and recomendations concerning compilation of the current 'icensing basis for operating reactors and current industry practices for updating the Final Safety Analysis Report (FSAR). In conducting the activities necessary to respond to the Comission, the staff noted that some licensee comitments are not contained in the plant's FSAR and, therefore, are not controlled by a defined regulatory process such as 10 CFR 50.59. As a result of the findings described in SECY 314. the staff proposed a series of actions to further examine the issues. The staff sumarized these actions in SECY-94-066. " Evaluation of Issues Discussed in SECY-92-314. ' Current Licensing Basis for Operating Plants'."

Revision: 11/10/97 Audit Guide AYCll.!O $ W y

On January 4.1993. the EDO established the Regulatory Review Group (RRG) to

., identify those areas in which increased flexibility in the regulatory process could be made available to licensees without adversely affecting the level of safety at operating plants. In SECY-94-003. " Plan for Implementing Regulatory Review Group Recomendations." the staff informed the Comission of its plan to I implement recommendations made by the RRG. One of the areas identified in l

SECY-94-003 that would substantially reduce unnecessary regulatory burden was the-development of guidance for use by licensees to control docketed comitments that l are not contained in the FSAR. Two options were discussed in SECY-94-003 to l complete this RRG item: (1) to develop and promulgate staff guidance on what i

constitutes a "comitment" and the types of controls to be placed on changing l commitments: or (2) to endorse a guideline developed by the industry. As I

described below, the Nuclear Energy Institute (NEI) volunteered to develop a guideline for managing comitments.

In SECY-94-066, the staff submitted to the Comission the results of itis further evaluation of the issues identified in SECY-92-314. To address the issues pertaining to comitments made to the NRC but not controlled by processes defined in regulations, the staff performed audits of licensee programs at Hope Creek.

Crystal River. Fort Calhoun. Braidwood. Davis-Besse. Beaver Valley, and McGuire, i

On the basis of the audit findings, the staff concluded that. in general, licensees had developed their own programs and processes that effectively managed commitments made to the NRC and controlled changes to these comitments. In its evaluation, the staff found that many licensees and NRC staff members did not i have a clear understanding of when comitments can be changed without NRC l interaction. This circumstance led most licensees to act conservatively. l interacting with NRC staff, and reporting changes to comitments regardless of j safety significance. This type of action resulted in an inefficient expenditure I of both licensee and NRC resources. Therefore. in SECY-94-066 the staff referred to the recomendation of the RRG in SECY-94-003 to develop guidance.

either by the staff or by the nuclear industry, on what constitutes a commitment and the types of controls to be placed on comitments.

The guidance developed by NEI on managing comitments provides a structured process, found acceptable to the staff in late 1995. that licensees can use on a voluntary basis. The NRC accepted version of the NEI document. " Guideline for Managing NRC Commitments." Revision 2. dated December 19. 1995, is provided as an attachment to this audit guidance. The NEI guidance describes a process that can be used by licensees to modify or delete comitments and defines the circumstances in which interaction with the staff is appropriate.

The NEI guidance document provides the following definitions to help clarify the regulatory significance of, and distinction between, an obligation and a regulatory comitment:

Oblication means any condition or action that is a legally binding requirement imposed on licensees through applicable rules, regulations, orders, and licenses (including technical specifications and license conditions).

Audit Guide Revision: 11/10/97 ,

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Reculatory Commitment means an explicit statement to take a specific action u

' agreed to or volunteered by a licensee that has been submitted in writing on the docket to the Commission.

In SECY-95-300. " Nuclear Energy Institute's Guidance Document. ' Guideline for Managing NRC Commitments'." dated December 20, 1995, the staff informed the Commission that the licensees

• comitment change processes, either implementation of the NEI guideline or licensee-specific programs, would be monitored to verify that comitments are being appropriately controlled. If the audit process shows that licensees have not implemented the NEI guidance, or have not adopted some

. equivalent level of control and documentation of changes to their comitments, the staff will reassess the need to promulgate staff guidance or initiate rulemaking. This reassessment will be initiated after the commitment control process at selected facilities has been audited using this guidance.

The NRC staff evaluated problems encountered with licensing basis issues at Millstone and Maine Yankee and offered lessons learned from these experiences in SECY-97-036. " Millstone Lessons Learned Report. Part 2: Policy Issues." dated February 12. 1997, and SECY-97-042. " Response to OIG Event Inquiry 96-04S Regarding Maine Yankee." dated February 18. 3997. Both reports recommended that, as part of an overall revision of its oversight of licensing basis information, the staff proceed with its plans to perform this audit to evaluate the industry's j implementation of comitment management systems. As a result of the lessons learned from these efforts, it was deemed prudent to have the staff define a sample of previous comitments made to the NRC in licensing actions and iicensing activities and to verify the licensees

• implementation of those comitments.

This and other staff efforts related to managing licensee commitments made to the i

NRC are integral to improving the staff's performance in (1) identifying important licensee comitments or other supporting design features or operating practices used by the licensee to justify a proposed change or address design or operational problems. (2) determining by what means im>ortant comitments or other supporting information should be verified, anc (3) determining the  ;

appropriate placement of. the information within the various licensing basis i documents associated with the affected facility (i.e.. the license or technical  :

specifications, the FSAR. program description documents, or docketed l correspondence without formal regulatory controls). NRR process changes are '

being made to address these concerns for future activities. The part of this audit that looks at licensee implementation of past comitments will be included. ,

along with reviews of past audit and inspection findings. in an assessment of the i l

need for additional staff actions. This assessment will include, to the extend practical a review of the findings from those inspections performed in accordance with temporary instructions associated with licensing activities such as bulletins and generic letters. Additional staff actions following the assessment may include additional NRC inspections requests for information from licensees, or proposing changes to NRC regulations.

l i

Revision: 11/10/97 Audit Guide l

4

I 3.0 C IT GUIDELINES 3.1 VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS

, The primary focus of this part of the audit is to confirm that licensees have l implemented those comitments made to the NRC as part of past licensing actions l and resolution of past licensing activities. The audit should ensure that the-l sample of past comitments were implemented in a manner that satisfied both the i

action comitted to and the overall intent of the comitment. The auditor should select a sample of approximately 15 individual and unrelated comitments that were included in licensee correspondence in order to justify a licensing action (amendment, exemption, etc.) or resolve a licensing activity (bulletin, generic letter, etc.). The sample should be selected following informal discussions with appropriate regional staff. review of licensee tracking data, review of any reports submitted by the licensee, and consideration of other information or concerns of individual auditors.

3.2 LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC The primary focus of this part of the audit is the licensee's performance related to implementing controls for modifying or deleting comitments made to the NRC.

The audit should ensure that changes to comitments (modifications or deletions) are evaluated in accordance with the licensee's programs and procedures. the licensee's technical evaluations adequately justify the change. and that the NRC is informed of commitment changes that have safety or regulatory sigr.ificance.

The auditor should, as a minimum, determine whether the licensee. using the NEI guidelines or alternative process, resolved safety issues pertinent to the associated comitment and has or will inform the NRC of the change if the applicable notification threshold is exceeded.

3.2.1 Procedures and Controls

a. Verify that the licensee has established administrative controit for modifying or deleting comitments made to the NRC. The controls for changing comitments made to the NRC may be included in a stand-alone comitment management system or may be incorporated into other licensee administrative programs.

b. Verify that the programs provide guidance regarding the evaluation of proposed changes to comitments in terms of safety and regulatory significance. The licensee's guidance should likewise include criteria for determining when it would be ap3ropriate to notify the NRC of a commitment change. The NEI guidance cocument is an acceptable guide for licensees to follow for managing and changing their comitments to the NRC. For those licensees that have not adopted the NEI methodology.

document a comparison of the licensee's process, including criteria for evaluation of changes and NRC notification. to that recommended in the NEI guideline.

l Audit Guide Revision: 11/10/97

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l i

3.2.2 Imolementation

a. Comitment Chanoes ReDorted to NRC. Select an appropriate sample of comitment changes (modifications or deletions) that were reported or will be reported to the NRC. Ten or more examples should be used if the licensee has' performed many evaluations since the last major revision of its comitment change process; otherwise, include as many examples as practical to assess the licensee's program for controlling commitment changes. Each comitment will be reviewed to determine ttle adequacy of the licensee's technical justification for the change in comitment. The sample should be selected following informal discussions with appropriate l regional staff, review of licensee tracking data, review of any reports submitted by the licensee and consideration of other information or concerns of individual auditors. Try to select comitment changes from as many of the following categories as practical:

1. Generic Letter Responses:

2. Bulletin Responses:

3. Licensing Actions (amendments, reliefs. or exemptions): or

4. Responses to Notices of Violation (NOVs):

5. Licensee Event Reports (LERs):

6. Inspection Reports:

7. Other docketed correspondence.

b. Commitment Chanaes Not ReDorted to NRC. Select examples of comitment changes (modifications or deletions) that the licensee has not and does not slan to report to the NRC. Approximately 10 commitment changes shou'd be selected using the various categories and considerations discussed above. 'Each selected comitment change will be reviewed to determine the adequacy of the licensee's technical justification for the change as well as the determination that notification of the NRC was not warranted. The sample should be selected following informal discussions with appropriate regional staff, review of licensee tracking data, and consideration of other information or concerns of individual auditors.

c. Notifications to the NRC. For those commitment changes that are determined to warrant NRC notification. confirm that the notification has or is planned to be made and that the notification accurately describes the change.

i d. Traceability of Commitments. Confirm that the licensee has implemented l a process to ensure the traceability of comitments to support the change control process. Such processes should ensure that licensee personnel are able to identify when their activity may involve changing a regulatory commitment and direct them to ' the comitment management Revision: 11/10/97 Audit Guide I

. process. Select a sample of recently implemented commitments and 6 evaluate whether the licensea's process would reasonably support identification of the commitment in case personnel subsequently propose to alter the design features or operating practices that were the subject of the commitments. The sample should be selected following informal discussions with appropriate regional staff, review of licensee tracking data, review of any reports submitted by the licensee, and consideration of other information or concerns of individual auditors. Note that the l NEI guide does not provide recomendations for performing this function.

4.0 GUIDANCE l

l Regulatory comitments are specific actions that have been agreed to or volunteered by a licensee and are documented in docketed correspondence. Unlike regulatory requirements (obligations) contained in regulations. licenses, and orders, regulatory commitments are not legally-binding. However the regulatory l process appropriately relies on comitments in many instances and the NRC expects licensees to honor. in good faith, commitments that have a safety or regulatory surpose. In large measure, regulatory commitments are not contained in the FSAR.

Jut in other docketed correspondence such as licensee event reports, responses to Notices of Violation. responses to generic letters, applications for licensing actions and responses to requests for additional information. Those commitments not contained in the FSAR may not be controlled by a defined regulatory process

! such as 10 CFR 50.59. Therefore, licensees may have the ability t':, change docketed comitments not contained in the FSAR without informing the Comission.

The NRC staff has the ability to issue an enforcement action if ine failure to l implement a comitment has the potential to adversely affect reactor safety. The staff may also use the administrative enforcement tool of a Notice of Deviation i if a licensee fails to satisfy a comitment. In addition issues regarding I completeness and accuracy of information submitted to the NRC may warrant consideration of the requirements of 10 CFR 50.9. Additional measures are being implemented to ensure that licensee comitments and other important information regarding plant design and operating practices are placed into the most appropriate licensing basis document. whether that be the license. FSAR or docketed correspondence.

Although a specific action comitted to by a licensee may not be legally-binding, the auditors should carefully consider whether the comitment or an alternative ,

action.1s.necessary to ensure compliance with an NRC regulation or otherwise l ensure safe plant operation. For example, a licensee's response to a generic '

letter may comit to perform routine surveillances or tests beyond those I

contained in a plant's technical specifications in order to ensure the operability of an important system or component. The licensee's failure to implement such a commitment or failure to adequately evaluate changes ~to that commitment may call into question the operability of the related system or component. Safety concerns or possible regulatory nonconformances that are discovered during this audit should be forwarded to the appropriate regional personnel for follow-up as part of the NRC's inspection program.

4 Audit Guide Revision: 11/10/97 l

4.1 VERIFICATION OF LICENSEE IMPLEMENTATION OF PAST COMMITMENTS 1

In defining the audit sample of approximately 15 commitments from past licensing actions and licensing activities, the auditors should consider the following in selecting comitment changes for review:

1. Choose commitments related to a variety of systems:

2. Choose comitments involving a variety of engineering disciplines, such as nuclear, mechanical, civil, and electrical:

3. Choose comitments that involve a variety of licensee actions, such as design modifications, temporary modifications. : procedure revisions, personnel training, and revised administrative controls:

4. Ensure that the sample of selected comitments includes some which were important to the NRC staff's decision-making '3rocess for licensing actions and licensing activities during the ast several 1 years.

l To the extent practical . identify commitments for verification that have not been

• l previously addressed by NRC inspections or audits. It is desirable to choose

! comitments with a preference to risk significant issues or systems. In I

addition the auditor should attempt to verify that not only the stated commitments have been satisfied but that the underlying intents of the cobitments have been fulfilled. For example, in contrast to verifying the

( installation of major pieces of equi) ment or issuance of major procedure or

program documents. the auditor shoulc assess the lower profile but essential l aspects of implementation such as the comitments regarding maintenance or

. surveillance of the subject e > ment and training or effectiveness measures for the subject process changes."he qui comitment or aspect of a comitment being verified and the information needed to perform the verification should, as much as possible, be identified and communicated to the licensee prior to the site visit in order to minimize time spent waiting for information. The auditor

, should have informal discussions with the regional staff and other NRC staff with potential insights pertaining to a licensee *s performance in the area of implementing comitments in preparation for the audit.

l To verify the implementation of specific commitments, review licensee commitment management records, work orders, revised procedures. NRC inspection reports, and -

other documentation that could demonstrate that the specific actions were completed in accordance with the stated comitment and related schedule.  !

l Discussions with licensee personnel in licensing, system engineering, and other organizations may be useful in placing the comitment and its implementation in the ap riate historical and technical context. Where ap3ropriate, utilize

, actual sical verifications of affected equipment or procecures. The auditor '

should etermine the needed level of investigation to verify the implementation l

of each selected comitment. Whereas some comitments may be verified by a simple review of a revised procedure, training record, or completed work order, verification of other comitments may require more exhaustive reviews of design Revision: 11/10/97 Audit Guide

documents and surveillance histories, comparison of corrective actions to appropriate effectiveness measures, or interviews with licensee personnel.

For each selected commitment. determine if the implementation of the commitment resulted in an update to the facility's updated final safety analysis report (UFSAR), additional docketed correspondence (e.g.. a letter confirming implementation), or other comunications with the NRC staff. The auditor should also determine if the commitment should have been captured in an update of the UFSAR. Concerns regarding a potential violation of 10 CFR 50.71(e) identified during this audit should be referred to the appropriate regional office for follow-up or otherwise pursued using other inspection and enforcement guidance.

4.2 LICENSEE PROGRAMS FOR MANAGING COMMITMENTS MADE TO THE NRC This guidance is intended to help auditors in evaluating licensee programs related to the revision of commitments made to the NRC. The audit consists of two parts: (1) procedures and controls: and (2) implementation. Reviewing the licensee's comitment management program procedures in the office will allow more l time for implementation review while onsite. Choose the initial selection of l comitment changes in the office using licensee-supplied lists of proposed and

completed commitment changes and any available independent knowledge of recent l changes to previous comitments or activities that would likely affect past l comitments. In addition. select recent commitments from docketed correspondence for performing the part of the audit dealing with traceability. At least one week before the audit, inform the licensee which commitment changes have been selected for possible review. This should minimize the time waiting for the licensee to produce the requested documentation.

NEI's guidance document is an acceptable guide for licensees to follow for I managing and chancling their comitments to the NRC. The defined process and I controls of the NE1 guidance document are the preferred method, but auditors may ;

encounter various degrees of formality and involvement of NRC staff in licensee processes for changing commitments. Various inspection and NRR activities include. or will include, verification that comitments agreed to or volunteered by the licensee have been implemented in accordance with the original licensee comitment and related schedule. This part of the audit focuses on subsequent changes to licensee comitments that may or may not involve interactions with the NRC. The audit should (1) evaluate the licensee's method for evaluating proposed changes to regulatory commitments with consideration given to the intent of the l_

original comitment and the safety and regulatory significance of the proposed change, and (2) evaluate the licensee *s method for communicating comitment changes to the NRC when such changes are deemed significant to safety or the NRC's regulatory function.

An important aspect of commitment management that is not addressed in the NEI

! guideline is the part of the process that ensures traceability of commitments. ,

The NEI guideline provides a basic framework for evaluating a change to a i comitment once licensee personnel propose such a change. However, for those j personnel to utilize the NEI guideline, they must realize when a change to a plant design feature or operating practice affects a comitment made to the NRC staff. For example, a licensee commits to perform independent verification at Audit Guide Revision: 11/10/97 l I

l.

e a specific point in the execution of a procedure as a result of problems identified in an NRC Notice of Violation. Several years later, the licensee determines that the independent verification step is no longer necessary due to improved performance of its personnel. In order for a commitment change process to work effectively the personnel likely to propose a revision to the affected procedure must be able to identify that the independent verification was added l to the procedure as 3 art of a regulatory comitment. Possible ways to provide l traceability incluce markings or notations within the procedure and administrative requirements to investigate proposed procedure changes that might l affect regulatory commitments. Similar processes would be necessary for design features or other licensee comitments not incorporated into controlled procedures.

! 4.2.1 Procedures and Controls

, a. Verify that the licensee has defined a process for managing comitments l made to the NRC. Such process descriptions may be contained in licensee

! procedures, general guidance documents, program descriptions, training

! material. administrative documents, or combinations of these documents.

The controls for changing comitments made to the NRC may be included in a stand-alone comitment management system or may be incorporated into l

other licensee corrective action, licensing, or administrative programs.

Commitment management systems may involve periodic assessments of all outstanding comitments or may evaluate changes on a case-by-case basis.

Indentify the governing procedures and guidance documents and discuss the licensee's comitment change process with the responsible licensee personnel. Document how the licensee's process is controlled as well as the how the process is used to evaluate proposed changes to commitments.

For example, the process may be governed by an administrative procedure or other document that is controlled in accordance with facility technical specifications and quality assurance programs or the process may be controlled within a licensing group as a relatively informal procedure. In either case, the effectiveness of a licensee program will consider the assessments performed for Item 3.2.2. Implementation, of l this audit.

b. Verify that licensee programs include guidance regarding the evaluation i of proposed changes to commitments in terms of safety and regulatory l

significance. The comitment change process should distinguish between the changes licensees can implement without interaction with the NRC and those governed by regulations that may require NRC review and a) proval prior to implementation. The process should include a mechantsm for determining when it would be appropriate to notify the NRC of a comitment change. The NEI guidance document is an acceptable guide for licensees to follow for managing and changing their comitments to the NRC. Ensure that the licensee has integrated the comitment management system with other line organization functions to ensure traceability of a regulatory comitment following its initial implementation. Such systems are necessary to ensure that licensee personnel are able to recognize that future changes to the affected design features or Revision: 11/10/97. Audit Guide

i ,.

operating practices require evaluation of the proposed change in

.accordance with the commitment change process as well as the normal design or procedure change process.

Although the process and review criteria in the NEI guidance document is the preferred method for controlling changes to commitments, there is no defined regulatory requirement that specifies how licensees must control-those changes. Therefore, licensees may define criteria for justification of commitment changes and NRC notif1 cation of such changes that are different than those recomended in the NEI guidance. For those licensees that have not adopted the NEI methodology, document a comparison of the licensee's process, including criteria for evaluation of changes and NRC notification, to that recommended in the NEI guide.

Although observations regarding the licensee's process or related I criteria should be included in the documentation of the audit any l concerns related to the actual effectiveness of licensee programs should be reinforced by actual examples reviewed in accordance with Item 4.2.2.

Implementation, of this audit guidance.

4.2.2 Imolementation .

l The implementation area of the audit assesses the licensee's performance

! implementing its commitment change process. Commitments and changes thereto can l involve all technical disciplines associated with a nuclear plant. Few auditors l are expert in every nuclear-related discipline. Therefore, the auditor should l recognize when technical assistance is needed to effectively review a safety evaluation or resolve a safety concern. The need for assistance can be anticipated based on the commitment changes selected for review. Also acceptable l 1s simply identifying and documenting (in the documentation of the audit) l i

technical questions for follow-up at a later date (either by the region or NRR). I Recognizing failures of the licensee to comply with the administrative control requirements of its commitment change process is important. However, recognizing failures of the licensee to adequately assess how a change will affect plant operational safety or compliance with applicable regulations is more important.

l l The focus of the implementation part of the audit should, therefore, be on safety and ensuring that revised . comitments have not' led to noncompliance with applicable regulations. For example. if you agree that a commitment change was safe and believe it would not introduce issues of compliance with any regulations, questions or concerns regarding the change process can simply be documented in the audit report. By contrast, a comitment change evaluation that failed to address an obvious safety or regulatory consideration would be more significant. Failure to recognize that a commitment change required assessment by regulations such as 10 CFR 50.59 or 50.54 may also be significant. Safety ,

concerns or possible regulatory nonconformances that are discovered during this audit should be forwarded to the appropriate regional personnel for follow-up as part of the NRC's inspection program.

Audit Guide Revision: 11/10/97 l

a. Commitment Chanaes Reoorted to the NRC. In addition to the selecision of commitment changes from various sources such as submittals pertaining to

_ licensing actions. responses to bulletins and generic letters, res>onses to NOVs. and LERs. other considerations for selecting commitment c1anges for review are:

1. Choose changes related to a variety of systems:

2. Choose changes involving a variety of engineering disciplines, such as nuclear, mechanical, civil, and electrical:

3. Choose changes that involve a variety of licensee actions such as design modifications, temporary modifications, procedure revisions. l personnel training, and revised administrative controls: l

4. The selected sample of comitments and comitment changes to be reviewed may need to give preference to recent items since the commitment management systems being evaluated vary in regard to when l l they were developed and the extent to which past commitments have ,

been captured:

5. Since changes to the FSAR and other programs are, or will be, assessed in NRC inspection procedures, this review should exclude commitments integrated into the FSAR. Quality Assurance Program, i Site Security Plan. Emergency Plan, or other document governed by a change control and 50.5 or 50.54: mechanism contained in regulations such as 10 CFR

6. Give preference to changes related to commitments which were ,

! previously considered in an NRC decision making process. Examples l

.- include commitments related to enforcement discretion, resolution of generic safety issues, and resolution of significant inspection issues.

~

Review each selected commitment change against the requirements and i guidance established in the licensee's procedures or guidance. For each change, consider:

e the relationship between the commitment being changed and regulatory requirements (obligations);

e the relationship between the commitment being changed and overall plant safety or risk profile:

e the licensee's criteria for determining the acceptability of a proposed comitment change (e.g., the NEI guidance includes the use of the questions from 10 CFR 50.92):

e systems and components affected by the change (What is the effect of the change on their capability to perform their specified or intended functions?):

Revision: 11/10/97 Audit Guide 1

o intent of the original commitment (Was commitment related to

. regulatory compliance, required safety function. or process enhancement?):

e potential effects of commitment change (Has licensee reasonably concluded that revised commitment will maintain plant safety and regulatory compliance, that original commitment was unnecessary or-ineffective, or that revised commitment will improve performance?);

e documentation of the comitment' change (Each evaluation of. a comitment change should be documented in accordance with the licensee's procedural requirements. Auditors should note that the NRC accepted NEI guidance recommends less documentation for the justification of commitment changes than that typically provided in licensee 10 CFR 50.59 safety evaluations or design documents.); and l e effective implementation of the revised comitment (Select several commitment changes for verification of implementation. Review licensee commitment management records, work orders, revised procedures. NRC inspection reports, and other documentation that could demonstrate that the specific revised actions were completed in accordance with the stated commitment revision and related schedule. Where appropriate, utilize actual physical verifications -

of equipment and processes.).

b. Commitment Chances Not Reoorted to NRC. Review each selected evaluation of a comitment change against the requirements and guidance established in the licensee's procedures or guidance. For each change, consider the technical factors listed above as well as the licensee's criteria for determining if the commitment change requires notification of the NRC.

. For those commitment changes not requiring NRC notification, ensure that the justification for the change is documented in a record that will be maintained for the life of the facility (maintenance of current licensing basis).

c. Notifications to the NRC. Verify that each commitment change determined to warrant NRC notification, has been or will be included in either a periodic or individual report to the NRC. Ensure that the description of ,

the comitment change submitted to the NRC is consistent with the action '

taken by the licensee.

d. Traceability of Comitments. Verify that each sample of a recently implemented comitment would be reasonably identifiable as a commitment to those licensee personnel most likely to be involved in a subsequent change to the affected design feature or operating practice.

Audit Guide Revision: 11/10/97

. 5.0 REPORTING REOUIREMENTS Document the results of this audit in an audit report which summarizes the licensee's comitment management process, specific reviews performed, and other pertinent information (recent changes in programs, planned changes in programs,

etc.). The report will be transmitted to the licensee in a standard letter from l the project manager.

6.0 ENFORCEMENT The failure of any licensee to adopt the approach recommended by NEI and accepted l by the NRC is not subject to enforcement action. However, an administrative action, such as a Notice of Deviation, may be warranted if poor licensee controls of commitment changes resulted in a significant failure to satisfy a commitment made to the NRC. In addition. issues regarding completeness and accuracy of information submitted to the NRC may warrant consideration of the requirements of 10 CFR 50.9. Suggested items for a Notice of Deviation and apparent violations of NRC regulations, operating 1icenses, or other regulatory requirements discovered during execution of this audit must be referred to the appropriate regional office for follow-up or otherwise pursued using other inspection and enforcement guidance. '

7.0 COMPLETION SCHEDULE This audit shall be performed and documented for the facilities selected for the pilot effort by May 31, 1998. Subsequent audits or inspections, if necessary, will be determined on the basis of the lessons learned from the first set of audits.

8.0 CONTACT If you have questions regarding this audit guidance, contact William Reckley, NRR/DRPW/PD3-3, at (301) 415-1314, e-mail WDR.

9.0 STATISTICAL DATA REPORTING TAC numbers will be opened for the reporting of time spent in the preparation for and execution of this audit.

10.0 RESOURCE ESTIMATE It is estimated that approximately 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> per facility will be expended in performing this audit. The required time will consist of an in-office review of process descriptions, procedures, and documentation related to comitments and commitment changes that has been provided by the licensee in support of the audit and an onsite portion involving interviews, review of supporting documentation for commitment changes, and verification of implementation of specific commitments. Subsequent evaluation of the audit reports and preparation of recomendations is estimated to require an additional 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The total resource estimate, assuming audits at eight facilities, is 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br />.

Revision: 11/10/97 Audit Guide

i The development of this guidance and the performance of the audits have been incorporated into NRR's Operating Plan for 1998 - 1999 as as part of the Reactor Licensing Program as well as being part of the division level operating plan for l DRPE/DRPW. i

11.0 REFERENCES

l l

Nuclear Energy Institute's. " Guideline for Managing NRC Comitments."

Revision 2. dated December 19. 1995 (copy attached).

. SECY-95-300. Nuclear Energy Institute's Guidance Document. " Guideline for Managing NRC Comitments." dated December 20. 1995.

I SECY-94-066. " Evaluation of Issues Discussed in SECY-92-314. ' Current Licensing l Basis for Operating Plants'." dated March 15. 1994.

SECY-92-314. " Current Licensing Basis for Operating Plants." dated l

September 10. 1992.

i l SECY-94-003. " Plan for Implementing Regulatory Review Group Recommendations."

dated January 7. 1994.

SECY-97-036. " Millstone Lessons Learned Report. Part 2: Policy Issues." dated

February 12, 1997.

SECY-97-042. " Response to 0IG Event Inquiry 96-045 Regarding Maine Yankee." dated February 18. 1997.

t END

Attachment:

NEI Guideline For Managing NRC Commitments. Rev. 2. 12/19/95 l

1 Audit Guide Revision: 11/10/97

1 l

1 1

t l

l

! l l

l GUIDELINE FOR MANAGING NRC COMMITMENTS r

l l

l Nuclear Energy Institute ,

{

Revision 2 December 19,1995 1

I

(

I i

i l

l I

Attachment r76 iO A!ja 2 2 3 9//-

, , distmetion betwas commitments si high uid low (or even no) saiety signihcance, and j

the lack cf a readily acceptable and practical method for eliminating or changing resulting commitments when warranted, impedes the achievement of this cbjective.

l ', Licensees have historically treated commitments seriously and only make changes after l due consideration of any safety impacts. At times, licensees have hesitated to change

commitments, even thoughjustified from a safety standpoint, due to concerns that the NRC may negatively view the commitment changes, or because the prcicess for changing commitments is perceived as burdensome. A uniform practice regarding commitments and commitment change mechanisms within the industry would assist individual utilities in focusing resources on significant issues and in changing past commitments that no longer serve their intended purpose. ,

RECOMMENDED ACTIONS Manneine Commitments l

. Any significant commitment of utility resources, whether to satisfy a l concem of an NRC inspector, to respond to a NRC generic communication,

, or to determine the appropriate manner to implement a regulatory requirement, should be the result of a reasoned management decision-making process. To ensure proper management control ofutility resources, an intemal process to control commitments should be established. For  ;

example: l

~

Commitments and their relative priority should be based upon an l evaluation'of the safety benefit that will be attained; the pertinent legal requirement, if any; the technical bases for the contemplated action ~or activity; and the resources available, in the context of other requirements and commitments. The cost (both initial costs and those that would be incurred over the life of the unit) and value added of an action being considered in response to an NRC request

. . .should be carefully evaluated, including consideration of any pertinent regulatory requirement (s).'

- Commitments should be made only by previously designated persons. Consistent with the utility's management approach, the number ofindividuals designated could be very few, or the

! responsibility could be delegated fairly broadly within each individual's area ofresponsibility.

2 Resision 2: 12/19/95 1

reouces oI violation ana Licensee Event Keports scenury actin,a s f minimize recurrence cf the adverse condition. Historically, not all such actions were necessary to minimi'c recurrence - some

', represented enhancements to ongoing practices not directly related to the cause of the event. Future correspondence should not identify these actions as commitments.

Chancing Commitments

. Changes to commitments should also be the result of a reasoned management decision making process. To ensure continued management control ofresources applied to commitments, the following commitment change practices are recommended:

- Each licensee should periodically consider evaluating its outstanding commitments and the manner in which its commitments have been implemented, to the extent that the conduct of the evaluation itselfis cost-effective (e.g., focuses on those commitments that have a major impact on the utility's costs). The licensee should determine whether the current commitment represents the most cost-effective way of satisfying the safety issue that prompted the commitment and should change those commitments as appropriate.

Each licensee should establish a practical commitment change process that distinguishes the relative safety significance and regulatory interest of commitments communicated to the NRC staff.

Attachment A to this guideline provides an example commitment change process.

- Each licensee should consider including a " sunset clause" in commitments, where appropriate, to establish a period of time to evaluate the effectiveness of the commitment.

4 Revision 2: 12/19/95

-l to correct or preclude the recurrence ef adverse conditions or to make

., improvements to the plant or plant processes. A Regulatory Ccamitment is an intentional undertaking by a licensee to complete a specific action. In the past, not all licensee correspondence has clearly distinguished the difference between Regulatory Commitments and factual statements, descriptive information, and voluntary enhancements not intended to constitute commitments. Potential confusion resulting from this lack of clarity will require dialogue between a licensee and the NRC on a case-by-case basis. Implementation of the Guidelines for Managing NRC Commitments should remedy this situation in the future.

Because Regulatory Commitments are not legally binding requirements, licensee management has the latitude to decide the scope and details of the intended actions without significant interaction or guidance from NRC management.

CHANGE PROCESS ,

l He following outlines a recommended change process intended to provide ]

. licensee management with the necessary flexibility to effectively manage the safe and 1 efficient operation of their nuclear plants, while ensuring that changes that are significant to safety an&or of high regulatory interest are communicated to the NRC. De recommended change process does not apply to confirmatory action letter commitments as described in the NRC's Enforcement Policy, NbE-1600.

Obli Fations l

No changes from current requirements are needed. The available statutory-based mechanisms include petitions for rulemaking under 10 CFR 2.802, exemption requests under 10 CFR 50.12, license amendment requests under 10 CFR 50.90, changes to certain plans under 10 CFR 50.54 and requests to modify or rescind orders issued under 10 CFR 2.202.

Reguinfory Commitments The attached flowcharts, Figures A 1 and A-2, outline a regulatory commitment ~'

management change process that (1) delineates commitments that have safety significance an&or regulatory interest; (2) establishes guidance for notifying the NRC of changes to commitments that have safety significance an&or regulatory interest; and, (3) establishes a rationale for eliminating past regulatory commitments that have negligible safety significance an&or regulatory interest.

Figure A-3 is a summary sheet that provides an adequate level of documentation for the decisions made in revising a commitment using this change process.

6 Revision 2: 12/19/95 6

- STEP 2: IS THE CHANGE SIGNIFICANT TO SAFETY 7 Commitment changes that are not captured by the codified processes identified in Step I above still need to be evaluated in tenns of their safety sign 16cance unless application of the NSAC-125 screening criteria under Step 1 determined that the change does not impact the ability of a SSC to perform its safety function. Figure A-2 outlines a determinstically-based approach for conducting safety assessments.

The process is briefly desen%I below:

The first step is to evaluate if the change could negatively impact the ability of a SSC to perform its intended safety function. NSAC-125, Section 4, contains useful criteria for performing this evaluation. Other relevant information in performing this evaluation is an understanding of the safety basis for the original commitment. A review ofpertinent documentation (e.g., NRC Bulletin or Generic Letter, LER, NOV, etc.) that prompted the original commitment is a source for basis information. A further factor to be considered in performing the evaluation is whether the change could negatively impact the ability oflicensee personnel to i ensure the SSC is capable ofperforming its intended safety function as a result of  !

changes to procedures, programs and other human performance elements. Ifthe evaluation determines that the change could not negatively impact the ability of a 1 SSC to perform its intended safety function, the change is not safety significant. i If the evaluation determines that the change could impact the ability of a SSC to perform its intended safety function, then an assessment applying the criteria of 10

, CFR 50.92 (c), (1) through (3), should be performed to determine if the change involves a significant hazards consideration. Probabilistic Safety Assessment (PSA) insights can be used to supplement deterministic-based assessments. If the ,

i assessment determines that a significant hazards consideration exists, the change is significant to safety. Otherwise, the change is not safety significant.

Changes to commitments that are evaluated as being significant to safety would either not be implemented or would require discussion with the NRC and review and approval, as appropriate, or w1itten notification. Changes evaluated as not significant to safety would proceed to Step 3 to assess if a compliance issue exiss.

. I i

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i 8 i Revision 2: 12/19/95 i I

~

information under 10 CFR 50.54(f) or 10 CFR 2.204; and, (4) commitments identified as long term corrective actions in response to a NRC Notice ef Vi:lation. Regulatory commitments may invalve both new actions as well as .

existing actions credited by licensees in responding to NRC requests. For example, responses to an item in an NRC Bulletin crediting an existing program, practice or plant feature as meeting the intent of the requested action is a regulatory commitment. Changes to regulatory commitments not captured in categories (1) through (4) would proceed to Step 5.

l 1

If the original commitment has yet to be implemented, the licensee can proceed I with the change, but the NRC abould be notified of the change as soon as practicable after the change is approved by licensee management, but before any i committed completion date. Notification should be accomplished by i supplementing the docketed correspondence containing the original commitment.  !

If the original commitment was made in response to a Notice of Violation, the l licensee can proceed with the change, but the NRC should be notified of the change as soon as practicable after the change is approved by licensee  !

management if the commitment has been in place less than two years. Notification i should be accomplished by supplementing the NOV response.

For other commitments in this category, if the commitment has been implemented, or is of a recurring nature, the licensee can make the change and provide annual or refueling outage interval notification to the NRC.

STEP 5: WAS THE ORIGINAL COMMITMENT MADE TO MINIM 1ZE RECURRENCE OF AN ADVERSE CONDITION?

Commitments to take long tenn corrective actions in Licensee Event Reports (LERs) are made to minimize recurrence of adverse conditions. A good measure of the effectiveness of these commitments is the success in avoiding recurrent adverse conditions. 'Ibe NRC, under its enforcement policy, uses a two. year time.

period from the date of the last' inspection'or the period within the last two

. inspections, whichever is longer, as an indication that the adverse condition related to a particular area has boca corrected.

Licensees may find it useful to periodically review the necessity of commitments related to minimfring recunence of adverse conditions. Licensees need the flexibility to change or eliminate commitments they determine are no longer necessary based on:

10 Revision 2: 12/19/95

~

- m m m m - ,._....,...n.y w - m _. - - u

,' revised commitment was identi5ed that minimized recurrence cf the original adverse condition could be provided as a listing in the report under a general basis description.

Documentation Figure A 3," Revised Commitment Evaluation Summary,"provides documentation of the decisions made in applying the above change process. The form would serve as proof that an evaluation was performed and should be retained by the licensee either (1) until submittal of the annual report or report Sled coincident with the FSAR updates per 10 CFR 50.71(c) for commitment changes that require NRC notification, or (2) for the life of the facility for commitment changes that do not require NRC notiScation. Where the form calls for a description of the rationale for a decision, it is expected that, in the majority ofinstances, a justi5 cation of one or two sentences would be sufficient. In some cases a more detailed explanation or reference to a backup assessment may be appropriate. It is not the intent to generate lengthy descriptions supported by detailed analyses, but rather to capture the essence of the basis for changing the commitment.

12

. Revision 2: 12/19/95

FIGURE A-2 SAFETY SIGNTFICANCE ASSESSMENT (DECISION STEP 2)

• \

i MtollDEC1810N STEP 1 .

9 P i

COULD NO C"A"CI AEI j ABERYOF 88C70 l PEAFORM EAFETY PUNCT10N l

i i YES l

i lf PERFORu AssEssutNT

! USING CRITERIA 0F 10 CFR 80.92 (C),(1)THRU (3) -

1 P i

DOES

', CHANGE RESULT IN SIGNIFICANT MAZARDS CONSIDERAtl0N

) SIGNIFIC 70 1I CONTINUEWfTN DECISION STEP 2 V

If -

DOCUMENT RAtl0NALE -

I f CotiMITNENT CHANGE E g not sArm 84NIFICANT r PROCEEDTODECSONSTEPS 14 Revision 2: 12/19/95

l < . Has the original commitment been implemented? _

!l No. EXIT PROCESS'. Provide timely noti 6 cation ofrevised commitment to NRC. _!

' ,' Yes. EXIT PROCESS". Notify NRC cfrevised commitment in next annual /RFO Di interval summary report. ,,j i N

4. Was the original commitment (1) explicitly credited as the basis for a safety decision in an t NRC SER, (2) made in response to an NRC Bulletin or Generic Letter, (3) made in 4l response to a request for infonnation under 10 CFR 50.54(f) or 10 CFR 2.204, or, (4) identified as a long term corrective action in response to a NRC Notice of Violation? ,

No. Continue with STEP 5. .

i Yes. Has the commitment been implemented? (see page 11 of the guidance if the commitment was made in response to a Notice of Violation.) 3 No. EXIT PROCESS . Provide timely notification ofievised commitment to y N NRC.

es. EXIT PROCESS *. Notify NRC ofrevised commitment in next k

..: a.4l' I annual /RFO interval summary report. -

.. 3 l

5. Was original commitment made to minimize recurrence of an adverse condition (i.e., a

.gl long term corrective action stated in a LER)?

No. Change commitment. No NRC notification required. ~'y}

Yes. Is the revised commitment necessary to minimize recurrence of the adverse ]l condition?

' OiFC # l No. Briefly describe rationale": . . . ,

g;-:4

. --g Change commitment. No NRC notification required. - - -

Yes. Notify NRC ofrevised commitment in next annual /RFO interval summary 3 report. . .-

-y

!

• EXIT PROCESS means the balance of this summary is not to be completed. .,

" Attach additional sheets providing rationale,ifnecessary.

l

. 16 Revision 2:12/19/95 4

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