ML073410349
| ML073410349 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 12/07/2007 |
| From: | Mudrick C Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RIS-00-017, SECY-00-045 | |
| Download: ML073410349 (10) | |
Text
SECY-00-045 RIS 2000-17 December 7, 2007 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
Annual Commitment Change Summary Report This report summarizes Limerick changes to NRC commitments that meet the threshold for reporting for the period from July 1, 2006 to June 30, 2007. 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.
There are no commitments contained in this letter.
If you have any questions or require additional information, please do not hesitate to contact us.
Sincerely, Original signed by Christopher H. Mudrick Vice President - Limerick Exelon Generation Company, LLC cc: S. J. Collins, Administrator Region I, USNRC C. A. Bickett, USNRC Acting Senior Resident Inspector, LGS
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 shall contain a summary of commitment changes that require NRC notification.
The following commitment changes were implemented between July 1, 2006 and June 30, 2007 and require NRC notification.
Commitment change tracking number:
2006-009 CT number:
T04085 Commitment source document:
Revised
Subject:
SRO attendance at the daily work review meeting.
Statement of commitment:
One of the commitments in the response to the NOV stated the following:
A currently licensed SRO is required to attend the daily work review meeting Change to commitment:
The commitment is revised to delete the portion that required a currently licensed SRO to attend the daily work review meeting.
Justification for change:
The current procedures (LS-AA-120 and WC-AA-106) allow an SRO knowledgeable individual to substitute for a currently licensed SRO at the Station Ownership Committee daily meeting.
Commitment change tracking numbers:
2006-011, 2006-012, 2006-013, and 2006-014 CT numbers:
T03877, T03645, T03831, and T03855 Commitment source documents:
MSRV / ECCS Action Plan, 10/6/95 MSRV / ECCS Action Plan Change, 10/15/97 Change:
Revised
Subject:
Monthly sampling and trending of suppression pool water fibrous content.
Statement of commitment:
A portion of the MSRV / ECCS Action Plan stated the following:
Chemistry shall sample and trend suppression pool water for fibrous content on a monthly basis.
This fiber sampling will be used for information only. Actions shall only be taken on the basis of suction strainer DP.
Change to commitment:
The commitment is being revised to delete the portion that requires suppression pool sampling for fibrous content.
Justification for change:
PECO Nuclear provided supplemental responses to NRC Bulletin 96-03 to notify the NRC that sampling of water and sludge material for the presence of fiber would be discontinued. The letter dated 6/15/98 was submitted following replacement of ECCS suction strainers on Unit 1.
The letter dated 6/1/99 was submitted following replacement of ECCS suction strainers on Unit
- 2.
Commitment change tracking number:
2006-022 CT number:
T04624 Commitment source document:
GL 89-13 response dated 1-29-90 Change:
Revised
Subject:
Test program to verify the heat transfer capabilities of safety-related heat exchangers cooled by Emergency Service Water (ESW) and Residual Heat Removal Service Water (RHRSW) systems.
Statement of commitment:
A portion of the Limerick response to Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment, addressed Recommended Action II. Limerick committed to a periodic retest program with frequencies based upon previous results. The program is based upon the program described in Enclosure 2 to GL 89-13.
Change to commitment:
The portion of the commitment is being revised to extend the final test frequency on the emergency diesel generators (EDG) heat exchangers from 5 years to 6 years.
Justification for change:
GL 89-13 Enclosure 2 states the following:
In the periodic retest program, a licensee or applicant should determine after three tests the best frequency for testing to provide assurance that the equipment will perform the intended safety functions during the intervals between tests. Therefore, in the periodic retest program, to assist that determination, tests should be performed for the heat exchangers before any corrective actions are taken. As in the initial test program, tests should be repeated after any corrective actions are taken to establish baseline data for future monitoring of heat exchanger performance.
Testing has verified that our cleaning methods were able to increase the margin to fouling limits on the heat exchanger tubes. The 6-year frequency will allow alignment of the test with the cleaning of the heat exchanger, which is 2 years.
Commitment change tracking number:
2007-002 CT number:
T04631 Commitment source document:
SER Unit1 TS Amendment 42 Change:
Revised
Subject:
Control Rod Exercise Test Frequency Statement of commitment:
Every Sunday the operators move each control rod in and out one notch.
Change to commitment:
Revised to state:
During this test the operators move each control rod in and out one notch.
Justification for change:
The change in frequency of performing this test is being evaluated and performed in accordance with the requirements of TS 6.8.4.j Surveillance Frequency Control program.
Commitment change tracking number:
2007-004 CT number:
T03661 Commitment source document:
Letter From NRC Dated 10-05-95 Change:
Deleted
Subject:
ISI Program Second Interval Relief Request RR-13 Statement of commitment:
The relief requests are granted provided the licensee performs the leak test at the peak calculated containment pressure and a test procedure that provides for detection and location of through-wall leakages in pipe segments being tested is implemented.
Change to commitment:
The above commitment is being deleted.
Justification for change:
Relief requests are only approved for a single interval. Once the interval is completed the old relief requests are no longer valid and must be re-submitted to the NRC.
Commitment change tracking number:
2007-005 CT number:
T04427 Commitment source document:
Letter From NRC Dated 02-14-02 Change:
Deleted
Subject:
ISI Program Second Interval Relief Request RR-12 Statement of commitment:
This relief request permits use of ASME Code Case N-516-1 "Underwater Welding" for Limerick Units 1 and 2 under certain conditions described in this relief request.
Change to commitment:
The above commitment is being deleted.
Justification for change:
Relief requests are only approved for a single interval. Once the interval is completed the old relief requests are no longer valid and must be re-submitted to the NRC.
Commitment change tracking number:
2007-009 CT number:
T03187 Commitment source document:
NRC Inspection Report 88-01 NOV Change:
Deleted
Subject:
10CFR50.54(t) Emergency Preparedness (EP) Program Reviews Performed by Nuclear Oversight Statement of commitment:
The Nuclear Quality Assurance organization has been assigned the responsibility for the performance of future 10CFR50.54(t) reviews and their distribution. The review will be distributed as an attachment to the QA audits.
Change to commitment:
The above commitment is being deleted.
Justification for change:
The issue no longer meets the definition of an NRC commitment per LS-AA-110 Commitment Management. The annual audit of the EP Program is required by law under 10CFR50.54(t).
Commitment change tracking number:
2007-019 CT number:
T04535 Commitment source document:
NRC Inspection Report 2003-004 Change:
Deleted
Subject:
LSRO License Reactivation Statement of commitment:
The licensee ceased their prior practice and have initiated a corrective action item to revise their Operator Requalification Program Manual to change their methods for re-certifying inactive SRO license holders to perform Fuel Handling Supervisor duties. This revision will require that all parts of the reactivation will be performed with the accompaniment of an active SRO or LSRO. In addition, the licensee will initiate further revisions to their program consistent with the following NRR guidance provided as part of this resolution.... the facility licensee can satisfy the intent of the regulation by implementing a reactivation program that specifies, in detail, the refueling tasks, activities, and procedures that an (L)SRO must satisfactorily complete or simulate (e.g., by using dummy fuel assemblies) in order to demonstrate watch-standing proficiency. Moreover, such a program shall exercise positive control to ensure that the required tasks, activities, and procedures are completed within a reasonable period of time (ideally, no more than one week) before the (L)SRO is assigned to supervise refueling shift functions.
Change to commitment:
The above commitment is being deleted.
Justification for change:
Actions for the commitment are included in current OP-AA-105-102 Rev.8 NRC Active License Maintenance which is an Exelon corporate level Operations procedure.
Commitment change tracking number:
2007-029 CT number:
T02845 Commitment source document:
NRC Bulletin 87-01 Response Change:
Deleted
Subject:
Response to NRC Bulletin 87-01 Thinning Of Pipe Walls in Nuclear Power Plants Statement of commitment:
Philadelphia Electric Company (PECO) committed to development of a program to address Erosion/Corrosion of carbon steel piping subject to wet steam environments.
Change to commitment:
The above commitment is being deleted.
Justification for change:
Exelon has an existing program for Erosion/Corrosion/FAC which is controlled by procedure ER-AA-430. There is no longer a need for this commitment since the program is well established and has existed since the early 1990's as a result of the response to Generic Letter 89-08 "Erosion/Corrosion Induced Pipe Wall Thinning".