ML20134D486

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Forwards Rev 6 of UFSAR for Lgs,Units 1 & 2,IAW 10CFR50.71 (e)(4) & 10CFR50.4(b)(6)
ML20134D486
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 01/31/1997
From: Fetters D
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20134D488 List:
References
NUDOCS 9702050186
Download: ML20134D486 (27)
v • d • e


Text

~

Drew D.Fettrrs Vce Presdent A StatKan Simon 10CFR50.71(:)(4)

V 10CFR50.54(a)(3)

PECO NUCLEAR ecco te- c-v 965 Chestertwook Blvd.

A UNot or PECO ENERcv Wayne. PA 190075691 610 640 6650 January 31,1997 l Docket Nos. 50-352 50-353 License Nos. NPF-39 NPF-85

U.S. Nuclear Regulatory Commission ATTN
Document Control Desk Washington, DC 20555

SUBJECT:

Limerick Generating Station, Units 1 and 2 i

Submittal of Revision 6 of the '

Updated Final Safety Analysis Report l

Dear Sirs:

1 in accordance with 10CFR50.71(e)(4) and 10CFR50.4(b)(6), this letter submits one (1) original and ten (10) copies of Revision 6 of the Updated Final Safety Analysis Report (UFSAR) for j Limerick Generating Station (LGS), Units 1 and 2. The enclosed copies of Revision 6 are being <

provided to the NRC on a replacement page basis with a 'st of effective pages identifying the latest revision date of all current pages in accordance wtn 10CFR50.71(e)(1). In each revision package, we have also provided page replacement instructions for incorporating Revision 6 page changes into the LGS UFSAR. As required by 10CFR50.71(e)(5), each replacement page includes a bold vertical line in the margin adjacent to each area changed and the date of change is included on each page. Revision 6 reflects changes made up to a maxiruum of six months prior to this submittal in accordance with the requirements of 10CFR50.71(e)(4). As a ,

result, the UFSAR Revision 6 package, has been made to reflect changes made to LGS, Units 1  !

and 2, under the provision of 10CFR50.59, at least up to July 31,1996.

l The enclosed UFSAR Revision 6 also contains the annual revision of the Quality Assurance (OA) l Program Description which is being submitted in accordance with 10CFR50.54(a)(3). The i updated QA Program Description (i.e., Section 17.2 of the UFSAR Revision 6) reflects editorial and organizational changes and those changes described in Attachment 1 as required by i 10CFR50.54(a)(3)(ii) since the previous submittal. Based on the information provided in i Attachment 1, we have conduded that the QA Program Description changes included in Revision 6 of the UFSAR do not reduce the commitments in the QA Program Description previously accepted by the NRC.

mwa.m 6 \b

' 9702050186 970131 .

PDR Al'OCK 05000352 K PDR,,

- . - - -- -.- - _ ..-. - - . . - - .. . -. . . . . .-. .-. - .=.- ..- -

4 January 31,1997 Page 2 i l

l 1 As required by 10CFR50.71(e)(2)(i), I certify that to the best of my knowledge, Revision 6 of the l UFSAR accurately reflects information and analyses submitted to the NRC, or prepared pursuant  !

to NRC requirements as described above. In addition, as required by 10CFR50.71(e)(2)(ii),

Attachment 2 to this letter identifies changes made under the provision of 10CFR50.59, and  ;

included in the enclosed Revision 6, but not previously submitted to the NRC. >

I if you have any questions or require further information, please contact us. l Very truly yours, i .-

1

. w Enclosure i Attachments 3

cc: H. J. Miller, Administrator, Region I, USNRC (w/ attachments and enclosurc) l N. S. Perry, USNRC Senior Resident inspector, LGS (w/ attachments and enclosure) k 4

l e

l l

l 1

ATTACHMENT 1 PECO Nuclear QA Program Description Changes LGS UFSAR, Revision 6 Change Paragraoh fth Descriotion d Chanae Classification

1. Table d Contents Chan0ed *PECO Energy" to "PECO Nuclear." Organizational Ust d Figures 17.2 17.2.2.2 17.2.2.3 17.2.2.8 17.2.3.8.1 17.2.4.1.a 17.2.4.1.b 17.2.4.1.d 17.2.7.6 i

17.2.9.2 17.2.9.4  ;

17.2.9.4.1 17.2.9.7 17.2.15.2 17.2.15.2.2 17.2.15.8 i 17.2.15.10 17.2.17.4 17.2.17.5 17.2.17.6 Appendix 17.2.11 Figure 17.2.4

2. List d Figures Changed Organizational 17.2 " Nuclear Generation Group" 17.2.1 to 17.2.1.1 "PECO Nuclear" 17.2.1.2 because d organizational name change.

17.2.1.3 17.2.2.7 17.2.2.8 17.2.2.8.1 17.2.9.3 Appendix 17.2.1 Figure 17.2.1 Figure 17.2.2

__m . _ _ _ - _ - . _ _ . _ _ _ . _ . _ _ _ _ _ . _ _ _ _ . _ . .

NQ I Paraoraoh No. Description of Change Classification l

3. 17.2.1.1 Changed Organizational 17.2.1.2 " Senior Vice President and 17.2.1.2.3 Chief Nuclear Officer"
17.2.1.2.3.h . to -

A 17.2.1.2.3.2.1.d " President of PECO Nuclear and -

i 17.2.1.2.3.2.3 Chief Nuclear Officer" I l 17.2.1.2.5.6 because of a change in poskion tkle and organizational '

17.2.1.2.5.11 restructuring. i j 17.2.1.2.5.12 i i 17.2.2.8 i 17.2.16.4.3

! 17.2.18.6 i i - 17.2.18.6.k  !

! Appendix 17.2.11 1

Figure 17.2.1 5 j Figure 17.2.2 l 4. 17.2 Changed "Quaiky Assurance Program" to "OA Program" and Editorial -

] 17.2.1.1 " Quality Assurance Program Description" to "QA Program  ;

i 17.2.1.2.3.1 Description" for consistent word usage throughout the QAPD. l l 17.2.1.2.5.6 .

17.2.2.1 l t

3

5. 17.2.2.3 Capitalized " Program" in "QA Program" when referring to Editorial j 17.2.2.8 PECO's OA Program.  ;

17.2.2.11  ;

j 17.2.4.2 l 1 17.2.7.1.b.3 i

6. List of Figures For Figures 17.2-3 and 17.2-5 through 17.2-10, deleted the Editorial
titles of the organization charts that are no longer provided  :

i with the OAPD. For Fig.' 17.2.7, replace the entry Organizational l l "lNTENTIONALLY LEFT BLANK" with " Deleted." l 1 For Figure 17.2.2, replaced the title of " Organization Chart, I i Nuclear Generation Group, PECO Energy Company" with )

" Organization Chart, PECO Nuclear, a Unit of PECO Energy  !

} Company." Changes made for consistency with PBAPS j QAPD.

j 7. 17.2.1.1 Changed title of PECO Energy's " Chairman of the Board and Organizational j 17.2.1.2.5.11 Chief Executive Officer" to " Chairman of the Board."

Figure 17.2.1 Changed title of PECO Energy's " President and Chief

. Figure 17.2.2 Operating Officer" to " President and Chief Executive Officer."

i Changed " Office of the Chief Executive" to Office of the Chairman / Chief Executive Officer."

j Changes made to reflect current organizational titles.

J l

1 4

A

~ - . -

Change l Paragraph No. Description of Chanoe Classification l t

8. 17.2 Added the following two sentences after the first sentence: Clarification ,

"PECO Energy is the licensee and retains full responsibility for i all LGS actMties. PECO Nuclear, a Unk of PECO Energy, is ~

assigned responsibilky for execution of LGS activkies, i including maintenance and implementation of the QA l Program." These sentences are added to clarify that PECO i Energy remains the licensee, and to introduce wkhin the QAPD l the role and authority of PECO Nuclear.  ;

in the sentence following the added two sentences discussed  !

above, changed " President" to " President and Chief Executive Officer" to match the organizational position equivalent to the position that which issued the policy statement i For fifth paragraph, clarified that reference to Section 13.5 is to 1 Section 13.5 of tne UFSAR.

For seventh paragraph of 17.2, revised end of first sentence from " described in Section 17.2" to " described in this Section 17.2" to help the reader understand that this is a self-reference.

9. 17.2.1 Deleted the sentence which provided a co Jnt of the Editorial organizations within PECO Energy and the number of Senior VPs and VPs. The referenced Organization Chart better describes the PECO Energy organizational structure than the deleted sentence. Also reworded third sentence which identifies the PECO Energy organizations that are not part of PECO Nuclear but which support PECO Nuclear (PECON).

10, 17.2.1.2 Revised first paragraph by combining the two sentences into Organizational one for readability purposes Also revised the end of the sentence from ' establishment of the QA Program goals, and Editorial objectives" to " establishment of the QA Program, goals, and objectives

  • to correct the mispunctuation. l Added a paragraph discussing the new position of Senior Vice President, Nuclear Operations, to the organizational description.

Closed this new paragraph with the sentence "The reporting relationships of PECO Nuclear are shown on the Figure 17.2-2 organization chart."

Deleted first sentence of third paragraph which stated that  !

'The organization of the Nuclear Generation Group is shown in Figure 17.2-2." since it would have been redundant with the newly added sentenco above it.

Edited last sentence of third paragraph to more broadly describe the types of support provided by contractors and  ;

non-PECON organizations. j

11. 17.2.1.2.1 Revised beginning of sentence from "The LGS organization. Editorial duties, and" to "The LGS operating organization, duties, and' to be consistent with the wording of referenced UFSAR Section 13.1.2.
12. 17.2.1.2.2 Revised the former cross reference to UFSAR "Section 13" to Editorial "Section 13.1.1" so that the precision of this cross reference is consistent with that in the preceding paragraph 17.2.1.2.1.

1 Ohange Paracraoh No. Descriotion of Chance Classification

13. 17.2.1.2.3 Removed the period at the end of each clause in each list of Editorial I 17.2.1.2.3.1 responsibilities.

17.2.1.2.3.1.1 17.2.1.2.3.1.2 17.2.1.2.5.9

14. 17.2.1.2.3 At the end of the second paragraph, deleted the words 'and Organizational l the Peach Bottom and Urnerick Independent Technical Review ]

Programs

  • because the former ISEGs are no longer separate Editorial organizational units.

At the end of the third paragraph replaced the colon with a period.

15. 17.2.1.2.3.a Revised beginning of the sentence from " establish Nuclear Editorial Quality Assurance pol!:y" to " establish Quality Assurance i policy" for consistency in term'nology. Also, for the list of functional areas, removed the capitalization on all the generic terms.
16. 17.2.1.2.3.e Changed the entry from " Require tracking and verification of Editorial )

corrective action and problem resolution for all QA-identified l Corrective Action Requests (level 2 and 3 issues)" to ' Require tracking and verification of corrective action and problem '

resolution for NOA-identified level 2 and 3 PEP issues." Also deleted the last sentence which was specific to tracking of deviations (DEVs). Changes made to be consistent with the terminology used by implementing procedures and to allow the terms CAR and DEV to be discontinued for NOA-identified, level 3 PEP issues. The processing requirements for NOA-identified PEP issues are not changed by discontinuing use of the terms CAR and DEV.

17. 17.2.1.2.3.f Enclosed the sentence following the clause in parenthesis. Editorial
18. 17.2.1.2.3.h Removed the apostrophe from "of Umerick Generation Editorial Station's operations."
19. 17.2.1.2.3.m Deleted the words 'of quality and evaluated suppliers' which Editorial did not add anything to the term " Evaluated Vendors Ust."
20. 17.2.1.2.3.n Changed the clause " Perform assessment / surveillance of Editorial vendor activities as appropriate" to " Assure assessment / surveillance of vendor activities is performed as appropriate" in order to better reflect the actual responsibility of the Director, NOA.
21. 17.2.1.2.3.1 Broke the former introductory paragraph into two paragraphs. Editorial The first paragraph discusses the organizational constituents of the dMslon. The second paragraph discusses the reporting relationship between the Manager, Umerick Quality DMslon, and the Director, NOA; the qualification requirements of the Manager; and the introductory sentence to the list of responsibilities of the Manager.

Change Paraaraoh No. Descriotion of Chanae Classification

22. 17.2.1.2.3.1.g Revised the words " adequacy of th9 nuclear facility OA Editorial Program" to " adequacy of the QA Program" for consistency in terminology and consistency with the PBAPS OAPD.
23. 17.2.1.2.3.1.h Capitalized the word " Directives" in the term "Stop Work Editorial Directives" to recognize that the Stop Work Directive is a defined form by the implementing procedures.

2

24. 17.2.1.2.3.1.1 Removed the capitalization from the words " personnel Editorial qualification records" because these words are generic.

J

25. 17.2.1.2.3.1.1 At the end of the second sentence, replaced the colon with a Editorial period.
26. 17.2.1.2.3.1.1.1 Revised the entry from " Development and approval of Editorial Surveillance Guidelines" to " Assure development of and approve Surveillance Guidelines" to better describe the

, Manager's responsibility and to make this entry agree with the structure of the other entries in this list of responsibilities.

27. 17.2.1.2.3.1.2 Changed the title " Superintendent" to " Supervisor" because the Organizational position title has changed.

, Also, at the end of the second sentence, replaced the colon Editorial with a period.

28. 17.2.1.2.3.1.2.b Revised the entry from " Oversee the verification activities in the Editorial areas of maintenance and modification activities performed on safety-related equipment" to " Oversee verification activities in the areas of maintenance and modifications performed on safety-related equipment."
29. 17.2.1.2.3.1.2.d Changed the word " Overview" to " Oversight" in order to use Editorial the correct word.
30. 17.2.1.2.3.1.2.f Changed " Quality Verification" to "OV" for consistent use of the Editorial abbreviation.

4

31. 17.2.1.2.3.2 Deleted the sentence following the header because it did not Editorial add anything to the text that follows.
32. 17.2.1.2.3.2.1 Replaced the colon at the end of the introductory clause with Editorial the words "the following." and removed semicolons at the ends of subitems a, b, and c.
33. 17.2.1.2.3.2.1.a Changed "NRC issuances, industry advisories, Licensee Event Clarification Reports, and other sources that may indicate areas for improving plant safety" to " Review of NRC issues, industry Editorial advisories, Licensee Event Reports, and other sources for the purpose of identifying potential areas for improving plant safety." Change made to more clearly identify the intended action.

Change Paraaraoh No. Descriotion of Chanae Cassification

34. 17.2.1.2.3.2.1.b Changed " Internal and extemal operating experience Carification
information that may indicate areas for improving plant safety" to " Review of intamal and extemal operating experience Editorial information for the purpose of identifying potential areas for improving plant safety." Change made to more clearty identify the intended action.
35. 17.2.1.2.3.2.1.c Added the words " Review of" before the existing entry in order Clarification to more clear 1y identify the intended action. Also made the word " surveillance" plural. Editorial
36. 17.2.1.2.3.3 Broke the former introductory paragraph into two paragraphs. Editorial The first paragraph identifies that the division consists of the Assessment Section. The second paragraph discusses the reporting relationship between the Manager, CNO, and the Director, NOA; states that the Meager is responsible for all C'@ activities; and concludes with an intmductory sentence to (he list of the Manager's responsibilities.

l

37. 17.2.1.2.3.3.a Revised the entry " Manuals and procedures" to read Clarification i

" Preparation, revision, and maintenance of NOA manuals and procedures" for clarification purposes. Editorial

38. 17.2.1.2.3.3.d Revised the entry " Oversight of the quality activities of Nuclear Organizational Support" to " Conducting internal assessments and surveillances of Station Support Department's quality-related Editorial activities" to accommodate organizational name change and l

for consistency with subitem "g." l

39. 17.2.1.2.3.3.g Revised the entry " Conducting ir temal assessments and Clarification surveillances at the corporate offices" to " Conducting internal assessments and surveillances of QA Program activities performed by PECO Energy organizations other than PECO Nuclear." Revised to better define the activities for which NOA provides oversight.
40. 17.2.1.2.3.3.] Removed the term "UFSAR" because the QA Program Editorial Description is already defined as this section of the UFSAR.
41. 17.2.1.2.3.3.1 Replaced the colon at the end of the introductory clause with Editorial the words "the following."
42. 17.2.1.2.3.3.1.c Revised entry from "Providing the engineering programs Editorial overview and modifications interface" to " Oversight of engineering programs and design of modifications" for correct word usage and clarification.
43. 17.2.1.2.5.1 In the last sentence of the paragraph, changed 'The NRB shall Editorial be established" to "The NRB is established" in order to better reflect the current status of the NRB.

._._ _ _ _ _ _ _ . _ _ _ _ . . _ . _ _ _ _ . . _ _ _ _ _ . _ _ _ _ . __.___m _ . _ _ _ . .

i CIEnge  ;

1 Paragraoh No. Descriotion of Chance Classification .

3  !

i
44. 17.2.1.2.5.5 Replaced the colon with a period. Replaced NSD (Nuclear Editorial  !

l Support Department) with SSD (Station Support Department) {

i because of organizational name change. Organizational

45. 17.2.1.2.5.6 in first sentence, removed the capitalization from the words Editorial l l " quality assurance" (generic use). In the second sentence,

! replaced the words " corporate Quality Assurance Program" ,

l with "OA Program Description contained herein." Also in the 1 i second sentence, replaced the words "have the corporate i Quality Assurance organization avalable" with "have the NOA j department avalable." These changes made to be consistent with PBAPS OAPD.

) 46. 17.2.1.2.5.7 At the end of the last sentence, replaced the word " Board" with Editorial j "NRB" in order to be consistent with the PBAPS OAPD.

j 47. 17.2.1.2.5.7.1 This clause appeared twice. Deleted second occurrence. Editorial i'

48. 17.2.1.2.5.9 Replaced "The NRB shall review;" with "The NRB, or its Clarification

, appointees, shall review the following." Also added a comma ECR 9644486 after the word " codes" in subitem "e." Editorial

' 49. 17.2.1.3 Deleted words 'and Purchasing" at the end of the first Organizational paragraph as well as the entire last paragraph to i accommodate organizational changes that relocated the Editorial

purchasing function for PBAPS from the former Purchasing j Division of the Support Services Department to the Station and Station Support organizations. Responsibilities of the Station organization and the Station Support Department are provided by UFSAR Section 13.
50. 17.2.1.4 Deleted sentence "The Claims - Security Division is the only Clarification organization in the Legal Department that is involved in nuclear plant activities." because the Legal Department assists PECON on various issues.
51. 17.2.2.1 In the first paragraph, last line, added a comma after the word Editorial "important."
52. 17.2.2.1.1 Split former second paragraph into four paragraphs to be Editorial consistent with the PBAPS CAPD.

Also revised the sentence beginning with "An overview of the OA Program" to read " Oversight of PECO Nuclear's implementation of the OA Program" to correct the word choice and to be consistent with the PBAPS OAPD.

)

Change Paraaraoh No. Descriotion of Chanae Classification

53. 17.2.2.3 in second sentence, added a comma after the word Editorial

" formalized." in the second paragraph, changed the last three sentences of this paragraph from " Training aids and individual study periods shall be utilized, as appropriate. Formal i classroom instruction shall be scheduled. Evaluation of 1 tralnees' progress shall be documented." to " Training aids and materials are utilized. Formal classroom and individual study periods are scheduled. Evaluation of trainees' progress is  ;

documented." Changes made to be consistent with the PBAPS OAPD.

In the third paragraph, second sentence, capitalized the terms General Employee Training, Emergency Plan, Fire Protection l Program, and Security Plan because these terms identify 4

specific PECON programs. Also removed the colon after the word " includes."

in the third paragraph, third sentence, replaced the words "shall be trained" to "are tralned" to be consistent with the status of the training activity and to be consistent with the PBAPS OAPD.

In the third paragraph, sixth sentence, replaced the words

" procedures shall delineate" with " procedures delineate."

54. 17.2.2.6 Broke the former first paragraph into two paragraphs. The first Editorial paragraph discusses the Maintenance organization and the reporting relationship between the Director, Maintenance, and the LGS Vice President. The new second paragraph discusses l NOA's quality verification role.

In the third paragraph, replaced the words "have had specific quality training" with "have specific quality training."

55. 17.2.2,7 in the third sentence, replaced the words "in accordance with Clarification Materials Management, Corporate, NOA, and plant procedures" with "in accordance with PECO Nuclear Editorial procedures" to be consistent with PECON's use of Common Nuclear Procedures for these procurernent activities.

l in the fourth sentence, clarified that it is plant items or services that are to be purchased through Supply Management. Non-plant items such as office supplies need not be purchased through Supply Management.

Last sentence of paragraph is reworded to clarify that a vendor organization may be authorized to purchase plant items and services in accordance with its procurement program, provided the vendor has been evaluated and accepted for this service.

56. 17.2.2.8 in the first sentence, removed the comma after the word Editorial

" objectives" and capitalized the words " Policies" and

" Directives."

In the second sentence, removed the colon after the phrase 'in the areas of." Also added "I&C' to the list of areas and placed

" surveillance inspection / testing" before " maintenance" for consistency with the PBAPS OAPD.

Change Paraoraoh No. Descriotion of Chance Classification

57. 17.2.2.8,2nd paragraph Revised the second paragraph from "A matrix of procedures or Editorial l documents is presented in Appendix 17.2.1 to demonstrate that 10CFR50, Appendix B criteria are fully implemented by documented procedures." to "A matrix of the administrative procedures versus the eighteen criteria of 10CFR50, Appendix l

B, is presented in Appendix 17.2.1 to demonstrate that i Appendix B provisions are fully implemented by documented procedures." for consistency with the PBAPS QAPD.

58. 17.2.2.8,3rd paragraph in the third paragraph, changed "OA Program sha!! require" to Clarification "OA Program requires" and ' Radioactive shipments
  • to

' Radioactive waste shipments" because 10CFR71, subpart H, Editorial I deals with radwaste shipments. l

59. 17.2.2.8,8th paragraph in first sentence, replaced " reviewed periodically" with Organizational

" reviewed on a continuing basis."

In second sentence, replaced "The nuciear organization Editorial management" to "PECO Nuclear management." In the same sentence replaced " reports at Senior Vice President and Chief Nuclear Officer staff meetings" with " reports at staff meetings held by the President of PECO Nuclear and Chief Nuclear Officer."

At the end of this sentence removed the capitalization from the words " inspections" and " audits."

Changes made for consistency with the PBAPS CAPD.

60. 17.2.2.10,4th paragraph Changed the entire paragraph from " Resolutions of differences Editorial of opinion between assessed and assessing personnel, regarding deficiencies or noncompilances identified by NOA shall be made by management. NOA management is authorized to stop work when such work is considered to be a serious quality degradation." to " Resolutions resulting from differences of opinion regarding deficiencies or noncompliances identified from assessments, surveillances, or verifications by NOA shall be made by management. NOA management is authorized to stop work when such work could result in a degradation of quality." Revised to be consistent with the PBAPS OAPD.
61. 17.2.2.11 In first sentence, added " instructions" to the list of documents Editorial that make up the QA Program.

In second paragraph, added " guidelines' to list of documents that pertain to quality-related activities. Changes made for consistency with the PBAPS CAPD.

62. 17.2.2.13 Combined subitem "a" with the introductory clause to make a Editorial complete sentence. Also added " managing quality-related activities" as an activity for which personnel must be trained.

Incorporated subitem "b," into a separate sentence as follows:

" Personnel performing or verifying quality-related actMtles shall be trained and certified." Changes made to be consistent with PBAPS OAPD.

Change Parag aoh No. Descriotion of Chance Classification

63. 17.2.2.16 Removed the comma after "The Quality DMslon Manager" and Editorial addea the word " plant" to " reviews plant operating characteristics." Also changed "NRC issuances" to *NRC l

Issues."

Provided the words that the acronym "PIMS' stands for and removed the word " database" following the parenthetical entry (PIMS). Changes made to be consistent with PBAPS OAPD.

64. 17.2.3.1 In the first sentence, changed ' Measures shall be established
  • Editorial to " Measures are established.' in the second sentence, j changed "The provisions shall identify" to "The provisions identify." Changes made to reflect the ct.rrent status of the design control program; i.e., it has been established and is

! Implemented.

65. 17.2.3.1.d Replaced the comma after " reactor physics" with a semicolon. Editorial
66. 17.2.3.3.1 Revised the sentence that previously read " Instructions for the Clarification design of modifications shall be written to require compliance to regulatory requirements as defined in 10CFR50.59, and as Editorial defined in the license application, in accordance with the design basis of the structures, systems, or components.' to

" Controls for the design of modifications to structures, systems, or components that are safety related or augmented quality shall ensure that applicable regulatory requirements and the design basis, as defined by 10CFR50.2 and as specified in the license documents, are correctly translated into specifications, drawings, procedures, and instructions."

Revision made to better reflect the requirements of the first sentence of 10CFR50, Appendix B, Criterion lit, and to make better sense.

67. 17.2.3.4 Replaced the first "shall be' with *is' and the second "shall be" Editorial with "are' to reflect the current status of the program.
68. 17.2.3.5 Replaced " Measures shall be established" with ' Measures are Editorial established' to reflect the current status of the program.
60. 17.2.3.6.1 In the first sentence, replaced " adequacy of modifications shall Editorial be determined
  • with " adequacy of modifications is determined."

In the third sentence, replaced "The reviews shall consist of" with "The reviews consist of."

Both changes made to reflect the current status of the program.

In the second paragraph, first sentence, clarified that the topic is design verification.

In the second paragraph, second sentence, removed the word

'those" from the phrase "except in those cases." In the sentence that follows, replaced "In those cases" with 'In these cases." In the last sentence removed the word 'the* from the introductory "In all cases, the design" and rephrased the end of the sentence from "the component, system, or structure to perform its function." to 'the structure, system, or component to perform its safety function." Changes made to be consistent with the PBAPS OAPD.

i Change Paragraph No. Description of Change Classification

70. 17.2.3.6.2 Revised the beginning of the introductory sentence from Edkorial "When the adequacy of desion* to "When the adequacy of a design" Revised the end of the sentence from "to ensure that:" to "to ensure the following "
71. 17.2.3.7 Added a comma after ' commercial (off-the-shelf) koms." Editorial
72. 17.2.3.8.a Replaced the closing colon with a period Editorial
73. 17.2.4.1 Removed the comma after ' assure adequate quality." Editorial in the second paragraph, replaced the colon at the end of the introductory statement wkh the words "the following" and removed the period at the end of each clause in each list of responsibHkies. Also enclosed the sentences following the clause in subitema "a" and 'b' in parentheses. For subitem "d" replaced "for inspection and audit, and source inspection" with "for source inspection and audit."
74. 17.2.4.4 Removed "the" from " including the procurement of' and "a" Editorial from " replacement parts as a part of."
75. 17.2.4.5 For each of the three first sentences, reworded from Clarification

" procedures shah require," " member shaX determine," and

' member shah also determine" to " procedures require," Edkorial member determines," and ' member also determines."

in the first sentence changed the words "a nuclear safety-related kem" to "a safety-related Rem" in order to be consistent in terminology.

In the third sentence added a comma after the words 'special controls to be applied." Changed the end of the third sortence from "and documentation requirements" to " receipt controls, and QA documentation requirements' in order to clearly require that receipt inspection requirements be established during the preparation of procurement documents.

76. 17.2.4.6 In the first sentence, deleted the word ' clearly
  • because of its Editorial subjective nature and because without the word, the sentence states the same requirement.

Combined the last two sentences into one by changing

  • Technical and quality assurance requirements are defined in procurement documents. These requirements are subjected to the design review process and are referenced in procurement documents." to "The procurement documents shall establish the technical and quality assurance requirements and they shall be verified as part of the design review process."
77. 17.2.4.8.1 Reworded sentence from " Nuclear Generation Group Supply Organizational Management shah process only approved requisitions in accordance with PECO Energy Procurement procedures and Editorial policies." to "PECO Nuclear shall process procurement requisitions in accordance with approved procedures and policies." Revision made to accommodate the the Station's Materials Managemert organizations also process procurement requisitions.

\

Change Paraaraoh No. Descriotion of Chanoe Classification

78. 17.2.4.8.2 Reworded entire paragraph from " Nuclear Generation Group Clarification Supply Management shall not alter the requisition of any nuclear safety-related item or service without prior approval of Editorial the requisitioning source, except for commercial items such as ,

price, quantities, schedule, F.O.B. terms, etc. Prior approval is  !

required from the responsible organization for cases where the requisitioning source is not the PECO Energy organization responsible for the technical and quality aspects of the item or service." to "The technical or quality assurance requirements i estabilshed by a purchase raquisition for any quality-related

] Item shall not be altered without prior approval of the requisitioning source." Revision made to establish the '

prohibition across the entire PECON organization, not just

Supply Management. Alse reworded for clarity and  !

consistency with the PBAPS CAPD. i

79. 17.2.4.9 Revised the beginning of the sentence from " Nuclear Organizational Engineering procurement documents" to "PECO Nuclear procurement documents" to broaden the requirement across the PECON organization. This revision is a result of the redistribution of engineering activities across multiple j organizations.

2 80. 17.2.5.2 Revised end of the second paragraph from " quality Editorial compilances" to " quality compliance." j l

81. 17.2.5.3 Deleted entire sentence "The NOA Department shall review Editorial
and approve NOA Procedures, including revisions." because it
is redundant to the broader statements of 17.2.5.1,17.2.5.9 (renumbered), and 17.2.6.4. As a result of the deletion, the 4

steps previously numbered as 17.2.5.4 through 17.2.5.11 are now numbered as 17.2.5.3 to 17.2.5.10.

82. 17.2.5.4 Added " work request forms" and " databases" to the list of Clarification (new number) possible recording documents. Also changed the words "to assure compliance" to "to document compliance" to better Editorial describe the purpose of using recording documents.
83. 17.2.5.3 Revised the structure of the second sentence to eliminate the Editorial
(new number) list structure. Revised the sentence to now read "The i instructions include scope of work; engineering, design,

, procurement, and insta!!ation responsibilities; and special testing requirements.

4 a

)

Change  ;

Paragraph No. Descriotion of Chanoe Classification 84.- 17.2.5.9 Revised the entire paragraph from " Administrative procedures Clwification  !

(now number) shall be written by other organizations participating in

  • quality-related activities supporting operation of LGS under the Editorial .

OA Program These procedures shall contain provisions which clearfy delineate the sequence of actions for the conduct of l safety-related activities." to " Organizations participating in LGS l quality-related activities shall prepare and issue any procedural l documents necessary to control their activities. These i procedural documents shall contain provisions which clearly delineate the sequence of actions for the conduct of safety 4 elated activities." Revised to preclude an interpretation that requires all administrative procedures be prepared by other organizations. Also broadened the scope of the statement to encompass all procedural documents, not just administrative procedures.

86. 17.2.5.10 Revised the statement to strengthen the qualification and Functional (now number) independence requirements of SORS and Quality Reviewers.

Revised from " Administrative procedures pertaining to quality.

related activities shall be reviewed by individuals within the responsible organization. This review shall be controlled by appropriate procedures.' to ' Administrative procedures pertaining to quality-related activities shall be reviewed by individuals qualified in OA Program requirements. An individual who reviews an administrative procedure shall not have prepared the procedure. These reviews shall be controlled by appropriate procedures." Revision made pursuant to NRC requirements established upon PECON request to transfer the activity of reviewing administrative procedures from NQA to the line organization. l

(

Reference:

ECR 96-02069)

86. 17.2.6.1 Changed first sentence from " Measures shall be established Editorial -

and documented to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe activities affecting quality." to

" Measures are established through administrative procedures to control the issuance of documents such as instructions, procedures, and drawings, including changes thereto." ,

Revision made to reflect the status of these measures; i.e., the measures are already in place.

87. 17.2.6.1.1 Corrected the possessive pronoun in the second sentence Editorial from *lts" to "their" to agree with the pronoun's antecedent,

" organizations."

4

88. 17.2.6.2 Revised the beginning of the first sentence from "Those Editorial participating in an activity shall be made aware of" to "Those participating in an activity are aware of" to reflect the status of this activity; i.e., indoctrination activities have already been implemented (and continue to be for new personnel).
89. 17.2.6.3 Replaced the colon at the end of the introductory clause with Editorial the words "the following." and deleted the periods at the ends of the clauses in subitems "a" through "g.'

1

- --..x- , ,,7 -, _ ----.--yr

Chainge Paranraph No. Descriotion of Change Classification  ;

90.- 17.2.6.4 Revised the sentence from "The NOA Procedures and Edkorial l revisions thereto shall be controlled per NOA Procedures  !

! under the authorky of the Director, NOA." to

] and revisions thereto are controlled and approved by the '

Director, NOA."  ;

l 91, 17.2.6.5 Revised the beginning of the first sentence from " LGS activity Editorial

instructions, procedures, and drawings, shah be procedurally . i

{ controlled and approved in accordance wkh the administrative i e

procedures" to " LGS activity instructions, procedures, and i

! drawings, are procedurally controlled and approved in

! accordance with administrative procedures" to reflect the i status of this activity; l.e., these documents are already and -

continue to be controlled.

l

! 92. 17.2.6.6 Changed the words "The control of documents shau apply" to Editorial l ' Document control applies."

4

! 93. 17.2.7.1 Changed the colon at the end of the introductory sentence to Editorial

! a period l 94. 17.2.7.1.b Changed the colon at the end of the introductory sentence to Edhorial i a period and removed the periods at the ends of the clauses j in subitems 1,2, and 3. In clause b.2, changed the word

" articles" to " items."

l

' Changed first sentence from ' Measures shall be established" to Editorial

95. 17.2.7.3
i. Measures are established" to better reflect the status of QA l l' program for control of purchased items and services. Also l l replaced the colon at the end of the second sentence with a l l period and removed the periods at the ends of the clauses for subitems "a" through "e." j

{

96. 17.2.7.7 Clarified that it is the purchase of sa'ety-related items or Clarifcation  !

services which is controlled. Removed the quotation marks enclosing

  • evaluated vendors", as well as the unnecessary Editorial i
capitalization of these words. Changed the word "altemate" to )
" designee." Revised the end of the sentence from

" requirements to ensure the quality of the product" to j " requirements necessary to assure the quality of the purchased

product." for consistency with the wording of the PBAPS i OAPD.

i Also added the following sentence: *NRC licensed nuclear j operating utilities are not maintaineu on the Evaluated Vendors

List. The utuity Quality Assurance Programs were deemed j acceptable by the NRC as a function of the fcensing process."

to clarify that PECON does not evaluate the OA Program of

{

currently licensed utilities when purchasing items from them.

4 Y

l i

i J

,. _ _ . . , m,--- - - --- -, - -

Change Paragraoh No. Descriotion d Change Classification

' )

97. 17.2.7.8 Revised the sentence from " Vendors that are on the " Evaluated Clarification j Vendors List' are audted triennially by NQA commensurate
  • with the importance, complexity, and quantty of the product Editorial i or service being purchased." to " Vendors on the Fvaluated j Vendors List are mamanaad by NQA at least once every 3
years." Revision made to preclude possible confusion over the j term
  • triennial" Also, the minimum frequency of NOA ,

assessment is not impacted by the "importance, complexity, or  ;

~

! quantity of product or services being purchased," therefore, i

these words were deleted from the end of the sentence. i 6

l' 98. 17.2.8.1 Revised the beginning of the first sentence from

  • Measures Clarification  ;

shall be established

  • to " Measures are established" to reflect j the status d this activity; i.e., the material control measures Editorial i have been established and continue to be implemented.

j in the second sentence, added a comma after the word '

3 ' repair" and deleted the words " Engineering Work Letter

  • because EWLs are no longer used. i i ,

l 99. 17.2.8.3 Changed the words "shall be established" to "are established" Editorial i to reflect the status of this activity.  ;

Changed the words "shall apply" to " apply." )
Deleted the word "and" after "(including shelf-life)."  !

Added a comma after the word " installation."

i 100. 17.2.8.4 Changed the words "shall be delineated" to 'are delineated' to Editorial reflect the status of this activity. Also changed " materials" to 3

  • material" and " items' to " characteristics."

101, 17.2.9.1 Changed the words " Measures shall be established" to Editorial i

" Measures are established

  • to reflect the status of this activity.

Also removed the comma after the term "special processes

  • a l 102. 17.2.9.4.1 Changed the beginning of the sentence from " Certification of Editorial j welders performing activities under the QA Program shall be 3

kept current" to " Certifications of welders are kept current" to 4

delete unneeded words.

i i 103. 17.2.9.6 Changed the words "shall be written" to "are written" to reflect Editorial the status of this activity; i.e., the NDE procedures have been

! prepared, approved, and issued.

104. 17.2.9.6.1 Added the words "and certified

  • after the words "be qualified" Clarification to clearly establish that NDE personnel require certification.

Also changed the words at the beginning of the sentence from Editorial

  • NDE procedures shall require" to "NDE procedures require."

105. 17.2.9.7 Deleted the second sentence invoking SNT-TC-1 A because it Editorial is redundant to 17.2.9.6.1.

106. 17.2.9.8 Removed the comma after the word " documented" in the Editorial second sentence.

I

Change Paraaraoh No. Descriotion of Chanae Classification 107. 17.2.10.1 In the first sentence changed the words "shall be established

  • Editorial to 'is established
  • to reflect the status of this activity.

108. 17.2.7.10.1 Replaced the colon at the end of the introductory clause with Editorial the words ' provide for the following." and removed the periods at the ends of the clauses in subitems 'a' through "g."

109. 17.2.10.4 Revised the beginning of the sentence from "The verification Clarification programs for modifications' to " Quality Verifications (OVs) for modifications" to clarify that verifications performed by NOA for Editorial mods and nonroutine maintenance are called " Quality Verifications" (OVs) as discussed by administrative procedure A-C-33.

110. 17.2.10.4.2 At the end of the sentence changed the words "with Nuclear Clarification Engineering Division approved requirements" to "with PECO Nuclear approved requirements" to allow for the use of both Common Nuclear Procedures and departmental procedures of other organizations participating in the mod process.

111. 17.2.10.5 ("W the beginning of the sentence from " Verification Editorial

.nel are responsible for assuring" to " Verification personnel assure."

112. 17.2.10.7 Enclosed the words "and beyond which work shall not Editorial proceed' in parentheses and deleted the commas so as to aid readability.

113. 17.2.10.8 Deleted the statement concerning stop work authority because Editorial it is redundant to paragraph 17.2.2.10. As a result of the deletion, the paragraphs that follow are renumbered.

114. 17.2.10.8 Changed the two sentences from " Personnel performing Clarihcation (new number) quality verifications shall be qualified in accordance with applicable industry standards and company training programs.

Certification of inspector qualifications shall be maintained in accordance with procedures.' to " Personnel performing verifications are qualified in accordance with applicable industry standards and company training programs.

Certifications of inspector qualifications for OV personnel are maintained in accordance with procedures." Revised first sentence to broaden the requirement to be qualified to all personnel who perform verifications (not just NOA personnel).

Revised the second sentence to clarify that it is NOA's OV personnel who require certification as inspectors.

115. 17.2.10.8.1 Revised the beginning of the sentence from "The code Editorial (new number) authorized inspector shall assure" to "The code authorized inspector assures

  • for consistency with the PBAPS OAPD.

116. 17.2.10.9 Reworded the term " systems, structures, and components

  • to Editorial (new number)
  • structures, systems, and components
  • for consistency.

e 4 Change Paragraph No. Descriotion of Change ClassNication c

117. 17.2.10.11 Revised the second paragraph from " Procedures shah be ClarWication l (now number) selectively reviewed, as appropriate, in the course of activities performed during NOA assessments, surveillances, and verNications to assure that necessary verNication points are i included and that a mechanism is provided for the .

documentation of verWication results." to " Procedures are  ;

selectively reviewed, as appropriato, by NOA to assure that  ;

necessary verWication points and inspection criteria are I included and that a mechanism is provided for the I documentation of verification results." Deleted the description of when such procedure reviews are performed to allow for reviews at any time. Added the words 'and inspection criteria" to broaden the review activity to ensuring that verification activities' acceptance criteria are also provided.

118, 17.2.11.1 Changed beginning of first sentence from "A test program shall Editorial be established to ensure that aX testing required to demonstrate that an item wHl perform" to "PECO Nuclear's test program assures that all testing required to demonstrate that a structure, system, or component wHl perform." Revision made to reflect current status of the test program and to utlize the SSC terminology consistently.

Revised the beginning of the second sentence from "The testing shall be performed" to " Testing is performed" for consistency.

119. 17.2.11.2 Changed the term ' qualifications tests" to " qualification tests" Editorial to agree with common usage.

120. 17.2.11.3 Replaced the colon at the end of the introductory clause with Editorial the words "the following." and removed the periods from the clauses in subitems "a" through "g." For subitem "c" replaced the words "such as:" with " including the following.' and removed the periods from the clauses in subitems 1 through 6.

121. 17.2.1 .4 Changed the beginning of the sentence from " Measures shall Editorial  !

be established" to " Measures are established" to reflect the l status of the program.

122. 17.2.11.5 Changed the beginning of the first sentence from " Test results Editorial shah be documented" to " Test results are documented" for  !

consistent phraseology. l Changed the beginning of the second sentence from

" Unsatisfactory test results shall be documented as required by procedures, and corrective action shall be taken" to

" Unsatisfactory test results are documented and corrective action taken" for simpilfication.

Change Paraaraoh No. Descriotion of Chanae Classification 123. 17.2.11.9 in the first sentence replaced the words "an ISI/IST Inspection Editorial Program has been developed and shall be implemented" with "an ISI/IST Inspection Program is implemented" for simplification. Changed the beginning of the second sentence from "The program shall include baseline examinations' to "The program includes baseline examinations

  • for consistent phraseology.

124. 17.2.12.1 Changed the beginning of the sentence from ' Measures shall Editorial be established

  • to ' Measures are established" for consistency.

125. 17.2.12.3 in the second paragraph, changed the words "the reference Editorial standards shall be chosen" to "the reference standards are chosen" for consistency.

In the fourth paragraph added the parenthetical "(devices used for the calibration and evaluation of plant systems and components)" after the term " measuring and test equipment" to clarify the scope of M&TE for which the calibration precision requirements apply. Also changed "has an accuracy" to 'have an accuracy" to make the subject and verb agree in number.

Also added a comma after the word tolerances to improve readability.

126. 17.2.12.4 Replaced the organizational group " Installation" with " Contract Organizational Management" to reflect the organizational name change.

127. 17.2.13.1 Changed the words "shall be established" and "shall be Editorial specified* to "are established' and "are specified" for consistency. Also changed ' existence shall be verified" to

" existence verified."

128. 17.2.13.2.1 Changed the entire paragraph from " Storage requirements Clarification shall be defined by cognizant personnel unless special instructions are provided by the vendor and approved by appropriate cognizant personnel." to " Storage requirements are established by cognizant personnel. Vendor instructions / recommendations are considered when establishing storage requirements." Change made to clarify that the responsibility for establishing storage requirements lies with PECON.

129. 17.2.13.2.2 Changed the words 'shall be inspected" to "are inspected" for Editorial consistency.

130. 17.2.13.2.3 Changed the words "shall be delineated" to "are established" Editorial and added a comma after the adverbial phrase "as necessary."

Also deleted the words " protection against" in order for the sentence to state what was intended; i.e., to avoid deleterious effects of environments, not avoid deleterious effects of protection against environments.

! Change i Paraornoh No. Descriotion of Change Classification ,

131. 17.2.13.2.4 in the first sentence, changed the words ' requirements shall be Editorial I

delineated" to " requirements are established" for consistency.  ;

1 Replaced the second sentence in ks entirety. Changed  :

' Labeling requirements are to be applied in a manner that is i clearly visible and remain legible to specify special controls or j

handling instructions." to " Labels that identify special controls or handling instructions shall be plainly visible and affixed in a i j manner that ensures they are remain secure and legible."

4 Revision made to improve clarity and readability. 9 i -

132. 17.2.14.1 In the first and second sentences, changed " Measures shall be

~

! Editorial j established" and " measures shall provide" to " Measures are ,

established" and ' measures provide" for consistency.

At the end of the first sentence changed " operation status

  • to i

" operating status" to agree with common usage.

l At the end of the second sentence, added the words "in order" i before the words "to preclude

  • to help readability.

133. 17.2.14.2 Changed the words 'shall be controlled' and "shall be subject Editorial '

to' to 'is controlled" and "are subject to" for consistency.

134. 17.2.14.4 Replaced the first sentence "A receipt inspection program shall Clarification be documented and the physical segregation of items which have not satisfactorily completed receipt inspection shall be Editorial employed to assure that the status of items can be determined " with "The receipt inspection program requires items that have not passed receipt inspection to be physically segregated and their status clearly identified." Revision made to improve clarity.

For the last sentence, replaced the words "the deficiency is" with "their deficiencies are" for agreement with the subject of the sentence, " Items.'

135. 17.2.4.7 Changed the beginning of the sentence from ' Measures shall Editorial also provide" to ' Measures are also established

  • for consistency. Also removed the words 'of the nuclear power plant" because they are unneeded, and added a comma after the word ' switches."

136. 17.2.4.9 At the end of the sentence, replaced the words "shall be Editorial controlled' with "is controlled" for consistency. Also removed the words "for these actMties" at the end of the sentence because they are unneeded.

137. 17.2.15.1 Changed the beginning of the sentence from " Measures shall Editorial be established' to " Measures are established

  • to reflect the status of the NCR program.

Edited the second sentence from "The measures established shall include, as appropriate, administrative and/or implementing procedures for the following functions for nonconforming materials, parts, or components." to "The measures address the following functions." Revised for simpillication.

i 1 Change Paragraoh No. Descriotion of Chanae Classification 138. 17.2.15.1.b Deleted this subitem altogether because it is redundant with its Editorial preceding subitem. As a result, the subitems that follow are renumbered.

139. 17.2.15.1.b Changed the wording from " Describe the nonconforming Editorial (new number) condition (s)* to " Description of the nonconforming condition (s)" for consistency in clause structure; i.e., each clause begins with a noun.

! 140. 17.2.15.1.c Replaced entirely with " Disposition which establishes the Clarification (new number) actions to be taken. The responsibility and authority for the disposition of nonconforming items shall be defined for each responsible organization. Nonconforming items may be dispositioned in any of the following methods."

141, 17.2.15.1.d.1 Deleted this entry altogether because it is now embodied in Editorial (former number) the new 17.2.15.1.c. As a result of the deletion, the subitems

{ that followed this entry are now renumbered.

142. 17.2.15.1.c.1 Broke the discussion of restoration into two topics: repair and Editorial (new number) rework. As a result, replaced the entire entry with " Rework the

ltem to conforming status. Rework is the process by which a nonconforming item is made to conform to a prior specified requirement by completion, remachining, reassembling, or

, other corrective means. Reworked items shall be reinspected in accordance with applicable procedures." Repaired items are now discussed by a new 17.2.15.1.c.1. Deleted reference to the term " restoration" so that the discussion concerning l j disposition categories better aligns with discussion of the topic by 10CFR50, Appendix B, Criterion 15.

! 143. 17.2.15.1.c.2 Replaced the former discussion on " repair" dispositions with Editorial (new . number) " Repair the item by restoring the nonconforming characteristic to a condition such that the capability of the item to function reliably and safely is unimpaired, even though the item still may not conform to original requirements. Provide engineering rationale / justification and independent review for a

" repair" disposition. Repaired items shall be reinspected in accordance with applicable procedures." Provided the additional discussion to better differentiate between " rework" and " repair."

144. 17.2.15.1.c.3 Replaced the words ' Replacement with conforming material" Editorial (new number) with

  • Replace the item with a conforming one ' to make the structure of the subitem list consistent; i.e., begin each  !

sentence with the active verb. I I

I l

Change

Paraaraoh No. Descriotion of Chanae Classification 145. 17.2.15.1.c.4 Replaced the words " Acceptance for interim use unti Clarif' cation (new number) replaced." with " Accept the item for interim use until it is replaced." for consistency in structure. Also replaced the i additional d;scussion that followed the first sentence with '

' Ensure that the item is clearly identified as nonconforming and controlled. Provide a description of the change, waiver, or I deviation that is temporarily accepted; the duration of anticipated interim use; technical justification for using the item during this period; any compensatory measures to be taken; I and independent review of the disposition." The topic of l

" repair" dispositions has been moved to the new 17.2.15.1.c.3.

l Added additional requirements to document the duration of I anticipated interim use and the compensatory measures to be i taken, if any. I l

146. 17.2.15.1.c.5 Added a new disposition "use-as-is" to allow for permanent Clarification (new number) acceptance of an item that did not meet its specified design 4

requirements but which, upon evaluation, is determined to be i

acceptable. This is a variation of the "use-as-is" for interim use

, disposition category discussed in the new 17.2.15.1.c.4.

l Added to bring the disposition category discussion into l alignment with 10CFR50, Appendix B, Criterion 15.

147. 17.2.15.1.d.7 Deleted the entry for signature approvals and date because it Editorial (former number) is part of the approval process and doesn't belong in the I discussion on the types of dispositions. Documentation of NCRs is now addressed by the new 17.2.15.1.e.

148. 17.2.15.1.f Deleted this entry as a separate item. It is now part of the new Editorial (former number) 17.2.15.1.c. l 149. 17.2.15.1.e Revised the former sentersce from " Documentation of each Editorial (new number) itern from first identification to final disposition" to

" Documentation of the nonconforming item from initial identification to completion of corrective action." Revision made to ensure that implementation of the disposition is included with the NCR documentation. Also moved the topic of including or referencing the NCR in the records package for the affected item from the former 17.2.15.1.h to this paragraph.

150. 17.2.15.3 Changed the words "shall be tagged" to "are tagged" for Editorial consistency in how on-going requirements are discussed. In the second sentence changed " Nuclear Engineering or Site Engineering is responsible" to " Engineering is responsible" for simpler presentation.

151. 17.2.15.9 Changed the second sentence from "The testing and Clarification inspection of a repair shall be as given in the approved disposition of the nonconforming item." to " Repaired items shall be tested and inspected in accordance with the approved disposition." to broaden the requirement from just providing a disposition to implementing the disposition.

Change Paranraoh No. Descriotion of Chanoe Classification 152. 17.2.16.1 in the first and third sentences, changed " Measures shall be Editorial established" and " measures established shall include" to

" Measures are established

  • and ' measures established include" for consistency.

153. 17.2.16.1.a Changed the words 'cause of the condition shall be Clarification determined and documented, and corrective action taken" to

'cause of the condition is determined and documented, resolution determined and documorded, and corrective action taken" for consistency and to clarify that the entire response to a PEP lasue is to be evaluated and documented.

154. 17.2.16.2 Changed the words ' Administrative procedures shall require" Editorial and " inspection requirements shall be included" to

' Administrative procedures require" and " inspection requirements are included

  • for consistency. Also changed the term " components, systems, or structures" to ' structures, systems, or components for consistency. Removed the 'and" before the word ' codes" and added a comma after " codes."

155. 17.2.16.3 Changed the words " Procedures shall establish" and Editorial

" procedures shall include" to ' Procedures are established" and

" procedures include

  • for consistency. Replaced the colon at the end of the second sentence with a period 156. 17.2.16.3.b Deleted former "b" entry because it was an integral part of the Editorial former "c" ertry. Former "c" and "d" are now *b" and 'c."

157. 17.2.16.3.b Change the entry from " identify and document, if possible, the Clarification (now number) root cause.' to " Identify, il possible, and document the root cause(s)." Change made to recognize that more than one root Editorial cause is sometimes identifiable.

158. 17.2.16.3.c Revised to allow individuals other staff engineers to monitor Clarification (now number) equipment history and determine performance trends.

150. 17.2.16.4.1 Changed from ' Dependent on factors, such as the significance Editorial of the deficiency, the cause, and the corrective action taken, line organization management shall review the corrective action for deficiencies identified by NOA to determine the adequacy and effectiveness of such action. Dependent upon the same factors, NOA shall also verify the effectiveness of these corrective actions through subsequent assessments or surveillances.' to "For significant NOA-identifMK! issues, line organization management shall determine and document the adequacy and effectiveness of corrective actions taken. The consequences of the issue, the causes and generic implications of the issue, and the extent of corrective actions needed are factors that determine whether a issue is significant. NOA shall also assess the effectiveness of corrective actions through subsequent assessments or surveillances." Editorial change only.

-- - - - -- . ~

! 1 Change  !

i Paragraoh No. Descriotion of Chance Classification l 5 180. 17.2.16.6 Changed "NOA periodic assessments of the NCR procedure" Clarification to "NOA periodic assessments of nonconformance reports" to 1 j clarify that this activity is not a periodic procedure review, but Editorial l j iruitead, is a regularly scheduled oversight activity in which

ccrrective actions performed for nonconformances and PEP

} ist,ues are assessed.

161. 17.2.17.1 in the second sentence, added " maintenance of records" to Clarification

the list of requirements.

I 162. 17.2.17.7 in the last sentence, added the word "in" for grammatical Editorial sense 163. 17.2.17.8 At the end of the introductory sentence, replaced the colon Editorial

with a period for consistency.

i 164. 17.2.18.6 At the end of the introductory sentence, replaced the colon Editorial  !

j with a period and removed the periods at the ends of the existing clauses.

i Removed last sentence stating "The assessment program is described in section 17.2.18." because it was self-referencing and unneeded.

166. 17.2.18.6.d Capitalized " Operational OA Program." Editorial f

166. 17.2.18.6.e Changed The emergency and implementing procedures" to Editorial l' "The Emergency Plan and implementing procedures" to properly refer to the Emergency Plan. l 4

$ 167, 17.2.18.6.g Replaced former subitems g, h, and I with "The Fire Protection Programmatic i Program and implementing procedures, including an I inspection and assessment of the Fire Protection and Loss

! Prevention Program, shall be performed utilizing an outside qualified fire protection consultant at least once every 24 a

months." As a result of effectively deleting 2 subitems, former j

through n are renumbered. Replacement done in accordance j with NRC approval of change to Fire Protection assessment frequency.

i Reference ECR-4 l 168. 17.2.18.6.k Changed the term " unit operation" to " facility operation" to Editorial (new number) accommodate the two-unit facility.

]

189. 17.2.18.6.1 Revised the sentence from "The performance of activities Editorial (new number) required by the OA Program to meet the criteria of Regulatory Guide 4.15, December,1977, at least once per 24 months." to The OA Program activities required by Regulatory Guide 4.15, December 1977, "Ouality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment," at least once per 24 months" in order to provide the title of the Reg. Guide and for simpler wording.

170. 17.2.18.6 in last paragraph, changed " semi-annually" to "at least once Editorial every 6 months" to preclude possible confusion over the term semlannually.

c - -

- = _ _ ,a .

)

Change Paragraoh No. Description of Chance Classification i

171. 17.2.18.7 Changed " procedures shall require" to " procedures require" for Edtorial ,

j consistency.

j 172. ' 17.2.18.11 Deleted this sentence altogether because reference to UFSAR Editorial j section 13.4 is no longer necessary after moving the NRB

discussion to Section 17.2.18. Paragraphs 17.2.18.12 and 17.2.18.13 are renumbered as a result.

i

-: 173. Appendix 17.2.1 Added "PECO NUCLEAR ADMINISTRATIVE PROCEDURES" as Clarification i a header above the list of procedures to clarify that all these l procedure types include administrative procedures. Also deleted "NEDP-Series' procedures from the list because they l have all been converted to other procedure types.

174. Appendix 17.2.11 Changed the first sentence from "PECO Energy follows the Clarification

ANSI Standards and USNRC Regulatory Guides, as described i below." to "PECO Energy is the licensee and retains full Editorial
responsibility for all LGS activities. PECO Nuclear, a Unit of
PECO Energy, is responsible for execution of all activities 1

! necessary to comply with the following ANSI Standards and l

) USNRC Regulatory Guides, as amended by the listed alternatives and exceptions described below." Added the l

t.

! sentence to clarify the relationship between PECO Energy and l

! PECO Nuclear i j Also replaced colons with periods at the end of introductory  ;

t sentences throughout for consistency.

! I 175. Appendix 17.2.11 Deleted this item because the description and activities of the _ Editorial ,

item c.4 NRS as discussed in section 17.2.1.2.5 comply with the requirements of ANSI N18.7-1976/ANS-3.2. No exception or j altemative needs to be stated. As a result of this deletion, i

j subitems c.5 through c.22 are renumbered.

i

) 176. Appendix 17.2.11 Included "ASME'in the reference to ANSI /ASME 45.2.23-1978 Editorial <

l Ite m e.5 to be consistent with its designation on the standard itself. l t

j 177. Appendix 17.2.ll Added 'P.ev.1" to the Reg. Guide 1.144 reference for Editorial

Ite m p completeness and consistency.

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ATTACHMENT 2 Page 1 of 2 l i

1 l 10CFR50.71(e)(2)(ii) requires that revisions to the UFSAR include changes made under the provisions of 10CFR50.59, but not previously submitted to the NRC. Accordingly, the list below identifies those plant modifications and projects included in Revision 6 of the Limerick Generating Station, Units 1 and 2. Updated Final Safety Analysis Report (UFSAR). The list.dgga not represent a complete list of UFSAR change

packages incorporated into Revision 6.

Modification Unit Number Number Descriotion 6240 1 Elimination of the RHR Steam Condensing Mode on Unit 1.

P-00100 1&2 Retirement of the Plant Process Computer and the Emergency Response Display System as a result of the installation of the new Plant Monitoring System.

P-00195 1&2 Replacement of the Control Rod Drive Pump, Gearbox and Motors with a Direct Drive Pump (Pump-Motor Only).

P-00210 1&2 Replace RCIC Simni Admission Valve HV-050-1(2)F045 to improve Speed Control j of RCIC Turbine during RCIC System Startup. j P-00227 2 Elimination of the RHR Steam Condensing Mode on Unit L P-00291 1&2 Replacement of 28 Main Control Room I Large Case Multipoint Recorders with a PC Computer Based Data Acquisition System.

P-00292 1&2 Replacement of the Unit 1 and 2 Post Accident Monitoring (PAM) Recorders with Westronics 2100C Series Recorders.

P-00333 1&2 Installation of a Water Treatment Plant Trailer Hookup to allow the use of Reverse Osmosis Water Processing.

P-00373 1&2 Removal of the Radwaste Building Decontamination Transfer Table OA-5331.

P-00411 1&2 Condensate Filter Demineralizer Upgrade through the use of Non-precoat Style Filter Elements.

P-00447 1&2 Installation of Test Taps to take Diesel Generator Fuel Oil Samples.

P-00458 1 EHC Reliability Enhancements to Reduce Spurious Turbine Trips and Resultant Reactor Scrams.

I ATTACHMENT 2 PIge 2 of 2 l l

I Modification Unit  !

Number Number Descriotion P-00565 1 Installation in the Unit 1 Drywell of 480V and 120V Power Receptacles at Strategic Points for Use During Outages.

P-00610 1&2 Design and Installation of Work Management Centers Outside Unit 1 Turbine and Reactor Buildings for Use During Outages.

94-00511 1&2 Removal of the Radwaste Hydraulic Press 005324.

94-06387 1 Modify RHR/LPCI Injection Valves HV-051-1F0178 and HV-051-1F017D and Core Spray Valves HV-052-1F005 and HV-052-1F037 to eliminate the potential for Pressure Locking through the addition of an External Piping Bypass.

94-06389 1 Replace Disc / Wedge on RCIC Injection Valve HV-049-1F013 to Reduce the Potential for Pressure Locking and Thermal Binding.

95-01110 1&2 Design Permanent Jumper Connections for RPS/UPS Panels 1 A-C248 and 18-C248 to allow the performance of Relay Trip l Testing.

95-02335 1 Modify HPCI Injection Valve HV-055-1F006 to Reduce the Potential for Pressure Locking.

95-02336 1 Modify HPCI Pump Discharge Injection Valve HV-055-1F105 wedge to Reduce the Potential for Pressure Locking.

95-05340 1&2 Reactor Enclosure and Refuel Area 95-03820 Secondary Containment automatic isolation 94-10694 logic interlock which allows HVAC Zones 1/11 and ill to be logically combined to allow normal ventilation system operation during the initial stages of a refuel outage.

96-01236 1 Modify LPCI Injection Valve HV-051-1F017D Disc and Remove External Bypass une Installed to Eliminate Pressure Locking.

96-03220 1 Create a Controllable Vent Path from 1 A Core Spray Loop to the Suppression Pool.

96-03700 1&2 Renovation of the Existing Chemistry Lab.

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