ML123350106

Annual Commitment Change Summary Report

ML123350106
Person / Time
Site:
Issue date:	11/30/2012
From:	Dougherty T J Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RIS 2000-17, 2012-001, 2012-013, IR-88-003, SECY-00-0045
Download: ML123350106 (3)

See also: RIS 2000-17

Text

SECY-00-045 RIS 2000-17

November 30, 2012

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, 2011 to June 30, 2012. 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 new regulatory 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

Thomas J. Dougherty

Vice President - Limerick Exelon Generation Company, LLC

Attachment: List of changes to NRC commitments

cc: Administrator Region I, USNRC USNRC Senior Resident Inspector, LGS

Attachment - List of changes to NRC commitments

November 30, 2012

Page 1 of 2

LS-AA-110 Commitment Management, Section 4.7, "NRC Notification of Commitment Changes/Deletions", requires submittal of a writ

ten 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, 2011 and June 30, 2012

and require NRC notification.

Commitment change tracking number: 2012-001 CT number: T02156

Commitment source document:

NRC Inspection Report 50-352/88-03 Change: Deleted

Requestor: Maintenance

Subject:

Timely closure of maintenance work packages.

Statement of commitment:

Revise procedure A-26 to require a specific time limit of 6 months on closure by entering them

in the history file following MRF Section 6 signoff of completed work.

Licensee is to delay

Nuclear Operations QC closeout to streamline the process.

Change to commitment:

Deleted

Justification for change:

A-26 has been superseded by MA-MA-716-010-1010, whic

h states that work orders shall be in history status within 90 days of either supervisor sign-off or work group supervisor acceptance; otherwise, they shall be formally tracked administratively. The commitment has been captured as part of an administrative control that is subject to a revi

sion review process (i.e., SQR

process). Therefore, annotation of the implementing document is no longer required.

Attachment - List of changes to NRC commitments November 30, 2012

Page 2 of 2

Commitment change tracking number: 2012-013

CT number: T03282

Commitment source document: NRC

Inspection Report 87-19, Reply to NOV Change: Delete

Requestor: Engineering

Subject:

Control of design change documents.

Statement of commitment:

The Modification Coordinator or designee will review design change documents with the

affected drawings to ensure that all those docum

ents requiring red-lining are identified on the as-built drawing update form. Administrative procedure A-14, Appendix 7 will be revised to implement these items.

Change to commitment:

Deleted

Justification for change:

The original commitment was for the Modifi

cation Coordinator to ensure all documents

requiring red-lining are identified

on the "As-built Drawing Update Form". Red line drawings are those drawings maintained in an as-built condition which are required in the control room for

day-to-day shift operations and for plant troubleshooting. Th

e red-lining process has been eliminated, a time period has been establishe

d for the as-building of design changes thus eliminating the need for a red-line drawi

ng. The current procedures, CC-AA-311, "Drawing

Creation and Revision" and CC-AA-311-1001, "Controlled Docume

nt Prioritization" exceed the original commitment for updating critical control room drawings (red-

line drawings) and are now classified as A1 Drawings/documents used

for safe and reliable operation of the plant.

These drawings are required by thes

e procedures to be updated prior

to return to service for field work, or 7 days for document changes follo

wing technical approval. In addition, the Maintenance Work Order procedure, MA-MA-716-010-1005, "Work Order (W/O) Planning Process", requires an activity to

be generated for the up-dating of

A1 drawings. These activities are required to be completed before the equipment is returned to service. The commitment has been met.