ML25118A020
| ML25118A020 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 04/15/2025 |
| From: | Joseph C Constellation Energy Generation |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 25-0017 | |
| Download: ML25118A020 (1) | |
Text
{{#Wiki_filter:Constellation SVPL TR: #25-0017 April 15, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Dresden Nuclear Power Station 6500 North Dresden Road Morris, IL 60450 10 CFR 50.55a Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Dresden Nuclear Power Station Submittal of the Snubber Program Plan for the Sixth 10-Year Interval In accordance with the American Society of Mechanical Engineers (ASME) Operations and Maintenance of Nuclear Power Plants (OM Code), Subsection ISTA-3200, "Administrative Requirements", paragraph (a), attached for your information is a copy of the Dresden Nuclear Power Station (DNPS) Snubber Program Plan for the sixth inspection interval. The DNPS sixth ten-year interval Snubber Program Plan complies with the requirements of the ASME OM Code 2017 Edition. The sixth ten-year interval for both Units 2 and 3 began on November 1, 2023, and ends on October 31, 2033. There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Daniel J. Murphy, Regulatory Assurance Manager, at (779) 231-7443. Respectfully, ~r~ l-{
- Po-.µ_\\ /f?t~r\\+ M.M~9cw f.-r Carolyne Joseph Site Vice President Dresden Nuclear Power Station
Attachment:
ER-DR-330-1008, Revision 0, Dresden Generating Station Units 2 and 3 Snubber Program Plan, Sixth Inspection Interval
Constellation ER-DR-330-1008 Revision 0 Page 1 of 5 DRESDEN GENERATING STATION Units 2 & 3 SNUBBER PROGRAM PLAN SIXTH INSPECTION INTERVAL Commercial Service Dates: Unit 2 (DPR-19) - 06/09/70 Unit 3 (DPR-25) - 11/16/71 Dresden Generating Station 6500 North Dresden Road Morris, IL 60450
TABLE OF CONTENTS SECTION 1.0 GENERAL ER-DR-330-1008 Revision 0 Page 2 of 5 2.0 EXAMINATION, TESTING AND MONITORING REQUIREMENTS 3.0 EXAMINATION AND TESTING METHODS 4.0 EXAMINATION AND TESTING FREQUENCY 5.0 ASME OM CODE CASE OMN-13 6.0 EXAMINATION, TESTING AND MONITORING EV AUATION 7.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 8.0 SCHEDULING 9.0 REPORTS AND RECORDS
1.0 General
ER-DR-330-1008 Revision 0 Page 3 of 5 1.1 Examination, testing, and service life monitoring of all safety related snubbers at Dresden will be implemented and performed in accordance with ER-DR-330-1007, Snubber Program Document, to ensure required operational readiness of these snubbers during a seismic or other event(s), initiating dynamic loads. 1.2 The snubber program, as defined in ER-DR-330-1007, establishes visual examination, operational readiness testing and service life monitoring requirements, pertaining to those mechanical and hydraulic snubbers required for safe shutdown of the reactor, maintaining the safe shutdown condition, mitigating consequences of an accident, or to ensure integrity of the reactor coolant pressure boundary. 1.2.1 Examination boundaries include snubber assembly from pin-to-pin, inclusive. The ISI Program will evaluate integral and nonintegral snubber attachments outside examination boundaries, in accordance with requirements of ASME Section XI, year of record. 1.2.2 Procedure DTS-0020-02 identifies snubbers included in this program, in accordance with ER-DR-330-1007. 1.3 The Snubber Program described in ER-DR-330-1007 adheres to requirements of ASME OM Code, Section IST, 2017 Edition, as required by 10CFR50.55a(b)(3)(v). 1.4 Snubber program procedure ER-DR-330-1007 establishes visual examination, operational readiness testing, and service life monitoring programs for hydraulic and mechanical snubbers in accordance with the requirements of Subsection ISTD, paras. ISTD-4000, ISTD-5000, ISTD-6000, respectively, and the applicable paragraphs of Subsection IST A. 2.0 Examination, Testing and Monitoring Requirements: 2.1 Visual examinations and operational readiness testing will be performed to the extent specified within ER-DR-330-1007 and in accordance with Constellation procedures ER-AA-330-004 and ER-AA-330-010. 2.2 Snubbers are grouped into defined test plan groups (DTPG) by design type, in accordance with ISTD-5252 for testing purposes. DTPGs at Dresden are described in ER-DR-330-1007. 2.3 Service life of all program snubbers will be monitored, and snubbers replaced or reconditioned as specified in ER-DR-330-1007 and required by Constellation procedure, ER-AA-330-011, to ensure service life is not exceeded at or before the next scheduled system or plant outage, or during a period when the snubber is required to be operable. The replacement or reconditioning will be documented, and records retained as required by ER-DR-330-1007, in accordance with ASME, Section 1ST, Subsections ISTA and ISTD.
3.0 Examination and Testing Methods: ER-DR-330-1008 Revision 0 Page 4 of 5 3.1 Visual examinations and operational readiness tests will be performed by individuals qualified in accordance with ISTA-1500(e). Visual examinations and operational readiness testing are performed to verify requirements specified within ER-DR-330-1007 in accordance with ASME, Section IST, Subsection ISTA and Subsection ISTD. 4.0 Examination and Testing Frequency: 4.1 Visual examinations and operational readiness testing will be performed at the frequency specified within the ER-DR-330-1007. Dresden will perform 100% accessible and inaccessible snubber visual examinations every 10 years per ASME OM Code Case OMN-13 Rev 3. 4.2 Visual examinations will be performed whenever new snubber locations are installed, or after system replacements or modifications in accordance with Subsection ISTD-4100. 5.0 ASME OM Code Case, OMN-13 5.1 Dresden Units 2 and 3 have satisfied pre-requisites for use of Code Case OMN-13, allowing extension of the visual examination interval. OMN-13 was in effect during the fifth 10-year Interval at Unit 2 and Unit 3. Code Case OMN-13 Rev 3 is approved for use by the NRC in Regulatory Guide 1.192, Revision 4, published in December 2021, and will be used during the sixth 10-year Interval. 6.0 Examination, Testing and Monitoring Evaluation: 6.1 Snubbers not conforming to visual examination requirements of ER-DR-3 3 0-1007 and ER-AA-330-004 will be recorded for evaluation and appropriate corrective action. 6.2 Snubbers not conforming with visual examination acceptance requirements but later confirmed as operable via operational readiness testing may be declared operable for the purpose of establishing the next visual examination interval, provided the unacceptable condition did not affect operational readiness of snubber or supported system. 6.3 Snubbers not meeting operational readiness testing acceptance criteria in accordance with ER-DR-330-1007 and ER-AA-330-010 will be evaluated to determine cause of the failure and appropriate corrective action will be taken. 6.4 Service life of a snubber is evaluated using manufacturing input and engineering information gained through consideration of snubber inservice conditions and inservice operational readiness test results, in accordance with ER-DR-330-1007.
7.0 Repair, Replacement and Modification Requirements: ER-DR-330-1008 Revision 0 Page 5 of 5 7.1 Repairs, replacements and modifications performed on snubbers under this program shall conform, as applicable, to requirements specified within Dresden's repair and replacement program.
8.0 Scheduling
8.1 Visual examination and operational readiness testing schedules will be established, tracked, and maintained by Dresden's engineering department. 8.2 The snubber inservice testing program requires tracking of expanded or additional testing and/or examinations, as specified by ER-DR-330-1007 and, in accordance with Subsection ISTD. 9.0 Reports and Records: 9.1 Reports and records will be generated and retained in accordance with requirements of ER-DR-330-1007, in accordance with ISTA-9000 and ISTD-9000. 9.2 Reports and records for visual examinations and operational readiness testing will be maintained for all snubbers in the program. 9.3 Applicable records and reports, as required for repair and replacements, will be maintained for all snubbers. 9.4 Service life records including the date at which the service life commences, and associated installation and maintenance records, will be maintained for all snubbers in the program.}}