View source for A98055, Forwards List of Revised Regulatory Commitments Which Were Evaluated as Satisfactory Using NEC Commitment Change Methodology

{{Adams
| number = ML20195J801
| issue date = 11/20/1998
| title = Forwards List of Revised Regulatory Commitments Which Were Evaluated as Satisfactory Using NEC Commitment Change Methodology
| author name = Starkey R
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = ZRA98055, NUDOCS 9811250066
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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Commonwealth lawn Company
  ,     ,  Zion Generating Station
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l ZRA98055 November 20,1998 U. S. Nuclear Regulatory Commission Document Control Desk                                                                                                         )
Washington, D.C. 20555 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR 39 and DPR-48 NRC Docket Nos. 50-295 and 50-304

==Subject:==
Change to Regulatory Commitments

==Reference:==
(1)         Letter to USNRC from O. D. Kingsley (Comed) dated February 17,1998, Integration of Section 50.54(f) Commitments into the Nuclear Generation Group Strategic Reform Initiatives.
(2)        Letter to USNRC from J. J. O'Connor (Comed) dated March 28, 1997, Commonwealth Edison Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(f) Regarding Safety Performance at Comed.
(3)        Nuclear Energy Institute guidance decumeret dated December 19,1995, " Guidelines for managing NRC Commitments," Revision 2.
(4)        Letter to A. B. Beach (USNRC) from J. C. Brons (Comed) dated March 30, 1998, Applicable Regulations, Disposition of Commitments, and Systems Required Following                 ,
Permanent Shutdown and Defueling of Zion Units 1 and 2.
Reference 1 identified that ZION Station will oidy be implementing those 50.54(f) commitments of Reference 2 necessary to place it in SAFSTOR. This letter is to revise the scope of several regulatory commitments created by Reference 2 as identified in Attachment A.
Attachment A identifies:
: 1.        The relerence which created the regulatory commitment                                                          / j
: 2.         The original commitment                                                                                          /
: 3.         The revised commitment.                                                                                        ,/f These changes in conunitments were satisfactorily evaluated using the Nuclear Energy Institute commitment             2 change methodology (Reference 3) as conunitted to in Reference 4. Should you have any questions concerning this
                                                                                                                              // &c'j) letter, please contact Mr. Robert Godley at (847) 746-2084 Extension 2900.
Respectfully, NI R. Starkey l          Decommissioning Plant Manager l
Zion Nuclear Power Station 1
;          Attachrnent 9811250066 981120' PDR        ADOCK 05000295 p                               PDR; A Umcom Company

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November 20,1998 U.S. Nuclear Regulatory Commission                                                                         :
Attachment A to 2RA98055 Page 1 of 4                                                                                                1 Change to Regulatory Commitments The following table identifies actions committed to by Comed in this document. These
                  . commitment changes were evaluated as satisfactory using the Nuclear Energy Institute commitment change methodology.
Please notify Mr. Robert Godley, Zion Station Regulatory Assurance Manager, of any questions regarding this document or any associated regulatory commitments.                          ,
1 I                   l Reference Which Created The Commitment                                                                     i i
Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonweahh Edison                         ;
I Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(0 Rgarding Safety Performance at Comed.
Orginal Commitment To improve performance m planning, scheduling, and conducting routine maintenance, Zion management         i refocused efforts to more effectively i.mplement a "12 week rolling" work planning and schedulmg process.  ;
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Revised Commitment                                                                                         i Zion station will implement a limited work planning process to accommodate the reduced scope work           l effort required under a <lecommissioned plant in SAFSTOR.
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j 2                   l Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison                        ,
Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for                    j Information Pursuant to 10CFR50.54(f) Regarding Safety Performance at Comed.                               ;
Orginal Commitment                                                                                         l Performance Improvement Management This strategy addresses how station performance will be                 I assessed to assure improvement. The strategy is implemented through action plans increasing                j management oversight of field activities, implementing an effective self assessment program, improving the 4 PIF and root cause analysis processes, and improving the management of the station's formal commitment tracking system.
Revised Commitment None,this commitment has been deleted. The expectations for the imp!ementation of a self-assessment program at Zion are contained in a Station Manager document dated July 10,1998, Expectations for Self-Assessment Program.
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l November 20,1998 U.S. Nu' clear Regulatory Commission Attachment A to ZRA98055 Page 2 of 4 Change to Regulatory Commitments                                               '
3                     I                                                                                      i Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(I) Regarding Safety Performance at Comed.                                  !
Orginal Commitment Work management processes will be clarified and streamlined in this strategy and training on these processes improved. The Operation 3 Work Control Center concept will be used to improve the control           j of work activities. Action Request and Work Request backlogs will be screened, prioritized and reduced.       ,
Multi-disciplined teams will physically walkdown plant structures, systems, and components to identify        '
undocumented material deficiencies.                                                                           l Revised Commitment Zion station will implement a limited work planning process to accommodate the reduced scope of work effort required to maintain a decommissioned plant in SAFSTOR                                                 4
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j 4                     I Reference Which Created The Commitment                                                                        4 l
Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison                           i Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(f) Regarding Safety Performance n Comed.                                   ,
Orginal Commitment                                                                                            )
Management and Personnel Development - This strategy develops the capabilities and depth of the organization. This includes training, skills development, outside recntiting, and a substantially increased management involvement in the accredited training program. Required management and supervisory skills will be identified, personnel will be evaluated against these attributes, and appropriate development activities will be conducted. Instructor skills and training lesson plans will be upgraded. The System        ;
Engineer training program will be upgraded. The strategy will also address upgrading craft skills and        :
qualificationt l
Revised Commitment                                                                                            :
None,this commitment has been deleted. Additional skill developments are not needed because the               I personnel which remain in the Zion Decommissioning Organization (ZDO) were selected through a targeted selection process. This process selected the best candidate based on his/her skills and competencies to perform targeted assignments within the ZDO. Qualifications will be maintained in acco-dance with 10CFR50.120 requirements.
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r November 20,1998 U.S. Nuclear Regulatory Commission Attachment A to 2RA98055 Page 3 of 4 Change to Regulatory Commitments 5                   l Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison                                   ,
Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for                               j Information Pursuant to 10CFR50.54(0 Regarding Safety Performance at Comed.                                           J Orginal Commitment The ef fectiveness of work planning and control processes, quality of routine work activities, and equipment problems challenging operations will be addressed in the strategy entitled Getting Work Done.
Revised Commitment Zion Station will implement a limited work planning process to accommodate the reduced scope of work effort required to maintain a decommissioned plant in SAFSTOR 6                   l Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(0 Regarding Safety Performance at Comed.
Orginal Commitment Comed management has committed to keep both units shutdown until corrective actions have been taken to ensure safe operation. These corrective actions regarding personnel performance, along with the results nf the Comed investigation of the event, will be submitted to the NRC in response to the Confirmatory Action Letter. The 1997 Operational Plan will also be modified as appropriate to address the depth of issues surrounding this event.
Revised Commitment None,this commitment has been deleted. Completion of corrective actions related to improving personnel performance during critical operations of Zion Units 1 and 2 will not be pursued. In
,            accordance with 10CFR50.82(a)(1)(I), on February 13,1998, Comed submitted its written certification of permanent cessation of operations at Zion Station Units 1 and 2. In accordance with 10CFR50.82(a)(1)(iQ               ;
on March 9,1998, Comed provided the NRC written certification that all fuel has been removed from the Zion Station Units 1 and 2 reactor vessels and that the two units will remain permanently defueled.
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l l           November 20,1998 l           tl.S. Nu* clear Regulatory Commission l
Attachment A to ZRA98055 l           Page 4 of 4 l
Change to Regulatory Commitments I
7                    l Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated Alarch 28,1997, Commonwealth Edison l
Company's (Comed) Response to the U. S. Nuclear Regulatory Comminion (NRC) Request for                      j Information Pursuant to 10CFR50.54(f) Regarding Safety Performance at Comed.                                ;
Orginal Commitment The responsibilities of the action plan manager will be to develop the implementing plan and ensure that it is effective. In reviewing the action plan, the responsible manager will verify that it can be implemented and is capable of achieving its objectives.
Revised Commitment None,this commitment has been deleted. The responsibilities for station Action Plan Manager are no l
longer being implemented due to permanent plant shutdown. Action Plan Managers were assigned for 1997 Operational Plan Action Plans. Due to plant shutdown the continued monitoring and work on these specific plans to resume critical operations of the units has been stopped.
i 8                    l Reference Which Created The Commitment Letter to USNRC from J.J. O'Connor (Comed) dated March 28,1997, Commonwealth Edison Company's (Comed) Response to the U. S. Nuclear Regulatory Commission (NRC) Request for Information Pursuant to 10CFR50.54(f) Regarding Safety Performance at Comed.
Orginal Commitment The Zion management team (Site Vice President and Senior Managers), as assisted by the strategy manager, will provide a forum for review of plan effectiveness. The results of the strategies, and the removal of any barriers to successful completion of the action plans, will be discuned at weekly review meetings.
Revised Commitment None,this commitment has been deleted. Weekly review fomms of recovery plan effectiveness are no longer required because work on the recovery plan has stopped with the plant shutdown announcement.
The Station Manager and the 2DO management team meet periodically to review and discuss plant decommiuioning issues.
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