ML20210P153
| ML20210P153 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/1999 |
| From: | William Reckley NRC |
| To: | Bell R NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-689 NUDOCS 9908120091 | |
| Download: ML20210P153 (1) | |
Text
3 ho) Na 4U Subj: Commitnent Management Paper Date: 6/1/9g 11:59:50 AM Eastem Daylight Time From: WReckley To. $ $aene9 Ru.$3 Be ( N EI Our oSce was closed today and so I thought I would email you some comments so that we could talk tomorrow or in PNiedelphia laterin the week.
There was an SRM on voluntary industry initiatiws on Friday,6/28. It basically said that the staf should make sure that all
- the changes 9t together re: the mow to more wluntary industry initiatiws (Vils), the new inspection / assessment processes, cnd the commitment management process. I how been following these aroes to make sure there were no major disagreements and I dont tNnk there is. I beliew we need to speciscelly mention Vlis in NEl 99-00.' 1here are basically two ways in which commitments could come llrom Vils. Either the staff would contact licensees and get commitments indi*fuelly 1 or the Vll document (tom whatewt group) could state which licenses were committing to the program. The policy matter for irxic:try will be whether a group such as NEl or owners groups can make commitments on behalf of the participating 4 Econsees.
)
4 Some other comments:
-Introduction,2nd paragraph: a less absolute statement regarding commitments to restore compliance would be better, j SometNng like; the method ..to restore compNance with an obligation will usually not be considered... The commitment in j most instances....
- Managing commitments (last paragraph): scratch reference to non-licensing basis commitments (this term is a canyowr tom the mark-up that was based on the licensing basis /non-licensing basis distinction). 1
- Sentence before CHANGE PROCESS: in addition to continuous / cyclical commitments, the one-time commitment may also warrant a dscussion. .
STEP 3 in change swiustion: I tNnk sometNng like the following sentence would be useful at the end of the Q3 "It may be prudent to discuss changes in methods of restoring compliance with the NRC staf to determine if a submittal other than the annual report may be warranted. In some cases, the description of the actual correctim actions taken or planned for restoring compliance may be of suscient interest to either the staff or public to warrant a submittal." in addition, I would change the "mey need" in the current last sentence to "will need."
STEP 3 in low chart: I dont beliew there should be a link between the decision boxes "date change justilled" and
' " original commitment implemented"
. STEP 4 in low chart and Figure A the questionnaire does not seem to how a path to Step 5. The "No" in step 4 should leed to step 5 and not to a Stop.
These are the more signitcant ones, I also how a few editorial.111 giw you a call on Wednesday,6/2.
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