CY-00-045, Annual Commitment Change Summary Report
| ML25318A263 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/13/2020 |
| From: | Gillin M Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| SECY-00-045, RIS 2000-17, LG-25-144 | |
| Download: ML25318A263 (1) | |
Text
Constellation LG-25-144 November 13, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Annual Commitment Change Summary Report SECY-00-045 RIS 2000-17 This report summarizes Limerick Generating Station (LGS) changes to NRC commitments that meet the threshold for reporting for the period from July 1, 2024 to June 30, 2025. Changes to these commitments are performed using procedure LS-AA-110, Commitment Management, which employs the guidance provided in NEI 99-04, Guidelines for Managing NRC Commitment Changes. NEI 99-04 was approved by the NRC for licensee use by SECY-00-045, Acceptance of NEI 99-04, "Guidelines for Managing NRC Commitments." Licensees were informed that NEI 99-04 was an acceptable process for control of regulatory commitments by the issuance of RIS 2000-17, Managing Regulatory Commitments made by Power Reactor Licensees to the NRC Staff, on September 21, 2000.
LS-AA-110, Commitment Management, Section 4.7, "NRC Notification of Commitment Changes/Deletions," requires submittal of a written report once per calendar year. This report includes one commitment change summary with the details provided in the attachment.
There are no new regulatory commitments contained in this letter.
If you have any questions, please contact Jordan Rajan at (610) 718-3400.
Respectfully, Digitally signed by Gillin, Michael Gillin Michael F. F.
1 Date: 2025.11.14 10:35:18-05'00' Michael F. Gillin Vice President - Limerick Generating Station Constellation Energy Generation, LLC
Attachment:
List of Changed NRC Commitments cc: Administrator Region I, USNRC USNRC Senior Resident Inspector, LGS
Attachment - List of Changed N RC Commitments November 13, 2025 Page 1 of 2 The following commitment change was implemented between July 1, 2024, and June 30, 2025, and requires NRC notification.
Commitment change tracking number:
CT number:
Commitment source document:
Change:
Subject:
2024-001 T04676 NRC Bulletin 83-03 Revised Check Valve Failures in Raw Water Cooling Systems of Diesel Generators Statement of commitment:
For Limerick, the bulletins require that Check Valves in two cooling water systems be addressed: (1) the plant Emergency Service Water (ESW) and (2) the Diesel Generator skid-mounted Jacket Coolant system.
The ESW system valves will be addressed in the lnservice Inspection program.
The Jacket Coolant system valves will be addressed in the plant Maintenance procedures and will be inspected during the Diesel inspections performed each refueling outage.
Commitment revised as follows:
For Limerick, the bulletins require that Check Valves in two cooling water systems be addressed: (1) the plant Emergency Service Water (ESW) and (2) the Diesel Generator skid-mounted Jacket Coolant system.
The ESW system valves will be addressed in the lnservice Inspection program.
The Jacket Coolant system valves will be addressed in the plant Maintenance procedures developed in accordance with the Technical Requirements Manual.
Justification for change:
The Emergency Diesel Generator (EOG) jacket coolant system check valve inspection performance frequency can meet the NRG BULLETIN 83-03 commitment as driven by procedures developed in accordance with the Technical Requirements Manual (TRM). See TRM Unit 1 and Unit 2 section 4.8.1.1.2, 3/4 8-1. In accordance with LS-AA-107, the TRM is considered "Incorporated by Reference" into the UFSAR. TRM changes are in accordance with NEI 98-03, Revision 1, and can be treated in a manner consistent with procedures fully or partially described in the UFSAR, and therefore, are controlled as procedures in accordance with the applicable established procedure process. In addition, 1 O CFR 50.65 Maintenance Rule (M-Rule) monitors the effectiveness of the EDG's maintenance, including these check valves.
Any degradation in performance that impacts the ability of the EDGs to perform their safety function is evaluated for accelerated maintenance. Therefore, the M-Rule process and TRM provide adequate means to ensure no adverse Structure, System, or Component (SSC) changes are implemented and that this commitment will continue to be met.
Attachment - List of Changed NRC Commitments November 13, 2025 Page 2 of 2 No issue reports for equipment issues were generated in the past 1 O years for any of the 092-1 (2)516A(B,C,O), Jacket Water Heat Exchanger Check Valve. There is no degraded performance history from 2005 until the present time on any EOG. There is no degrading trend or equipment history of as-found inspections that indicate performance issues such that the EOGs safety function may be prevented. This change will allow for the evaluation and implementation of appropriate maintenance intervals ensuring the EOG system will be able to reliably perform its design basis function.