ML25232A209

Re-submittal of Updated Final Safety Analysis Report (Ufsar), Revision 16 and Fire Protection Report (Fpr), Amendment 25

ML25232A209
Person / Time
Site:	Dresden   (DPR-002, DPR-019, DPR-025)
Issue date:	08/20/2025
From:	Lueshen K Constellation Energy Generation
To:	Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-25-130
Download: ML25232A209

Text

4300 Winfield Road Warenville, IL 60555 630 657 2000 Office RS-25-130 10 CFR 50.4(b)(6)

August 20, 2025 10 CFR 50.71(e) 10 CFR 54.37(b)

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20055 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License Nos. DRP-2, (Renewed) DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237, and 50-249

Subject:

Re-submittal of Dresden Updated Final Safety Analysis Report (UFSAR), Revision 16 and Fire Protection Report (FPR), Amendment 25

Reference:

Letter to NRC, Dresden Updated Final Safety Analysis Report (UFSAR), Revision 16 and Fire Protection Report (FPR), Amendment 25, dated 6/23/25 [ML25174A304, ML25174A306, ML25174A308, ML25174A309, ML25174A310]

In the reference, Constellation Energy Generation, LLC (CEG) submitted revisions to Updated Final Safety Analysis Report (UFSAR) and the Fire Protection Report (FPR), summaries of evaluations conducted pursuant to 10 CFR 50.59, "Changes, tests, and experiments," 10 CFR 54.37(b),

"Additional records and recordkeeping requirements," and NEI 99-04, "Guidelines for Managing NRC Commitment Changes for Dresden Nuclear Power Station, Units 2 and 3 (Dresden). The NRC has requested that the files be re-submitted as separate files by chapter and volume for the UFSAR and FPR, respectively. Therefore, this submittal supersedes the previous referenced submittal in its entirety.

In accordance with the requirements of 10 CFR 50.71, "Maintenance of records, making of reports,"

Paragraph (e)(4), CEG submits Revision 16 to the UFSAR for Dresden, Amendment 25 to the FPR, summaries of evaluations conducted pursuant to 10 CFR 50.59, "Changes, tests, and experiments,"

10 CFR 54.37(b), "Additional records and recordkeeping requirements," and NEI 99-04, "Guidelines for Managing NRC Commitment Changes."

The enclosed Dresden UFSAR, Revision 16 is being provided in its entirety in electronic format on the Electronic Information Exchange (EIE). Also enclosed in electronic format is the Dresden FPR, Amendment 25, Dresden Technical Requirements Manual (TRM), and Dresden Technical Specifications Bases (TSB). UFSAR pages changed as a result of this update are delineated with "Rev. 16 - June 2025" in the page header. FPR pages changed as a result of this update are delineated with "Amendment 25" in the page header.

Changes to the UFSAR, FPR, TRM and TSB have been made under the provisions of 10 CFR 50.59, Changes, tests, and experiments, 10 CFR 72.48, changes, tests, and experiments, and 10 CFR 54.37(b), Additional records and recordkeeping requirements.

RS-25-130 August 20, 2025 U. S. Nuclear Regulatory Commission Page 2 Attachment A provides a brief summary of the changes incorporated into UFSAR Revision 16.

Attachment B provides a brief summary of the changes incorporated into FPR Amendment 25.

Attachment C provides the summary report pursuant to 10 CFR 50.59(d)(2).

Attachment D provides a summary of changes to the TRM.

Attachment E provides a summary of regulatory commitment changes.

Attachment F provides the summary report pursuant to 10 CFR 54.37(b).

Attachment G contains the directory path, filename, and size of each individual file.

As required by 10 CFR 50.71(e)(2)(i), I, Director - Licensing, certify that to the best of my knowledge, the information contained in the enclosure and attachments to this letter accurately reflect information and analyses submitted to the NRC or prepared pursuant to NRC requirements, and changes made under the provisions of 10 CFR 50.59 and 10 CFR 72.48.

There are no commitments made in this document. Should you have any questions concerning this letter, please contact Amy Hambly at amy.hambly@constellation.com.

Respectfully, Kevin Lueshen Director - Licensing Constellation Energy Generation, LLC Attachments: Attachment A, "UFSAR Revision 16 Change Summary Report" Attachment B, "FPR Amendment 25 Change Summary Report" Attachment C, "10 CFR 50.59 Evaluation Summary Report" Attachment D, "Technical Requirements Manual Change Summary Report" Attachment E, "Summary of Regulatory Commitment Changes" Attachment F, "10 CFR 54.37(b) Aging Management Review Summary" Attachment G, "Electronic File Directory Structure"

Enclosures:

000 UFSAR Cover and List of Affected Pages.pdf 001 UFSAR CHAP 01 Introduction.pdf 002 UFSAR CHAP 02 Site Characteristics.pdf 003 UFSAR CHAP 03 Design of SCE.pdf 004 UFSAR CHAP 04 Reactor.pdf 005 UFSAR CHAP 05 Reactor Coolant Sys.pdf 006 UFSAR CHAP 06 Engineered Safety Features.pdf 007 UFSAR CHAP 07 Instrumentation and Controls.pdf 008 UFSAR CHAP 08 Electrical Power.pdf 009 UFSAR CHAP 09 Auxiliary Systems.pdf 010 UFSAR CHAP 10 Steam and Power Conv Sys.pdf 011 UFSAR CHAP 11 Radioactive Waste Mgmt.pdf 012 UFSAR CHAP 12 Radiation Protection.pdf 013 UFSAR CHAP 13 Conduct of Operations.pdf

Lueshen, Kevin Digitally signed by Lueshen, Kevin Date: 2025.08.20 09:01:57

-05'00'

RS-25-130 August 20, 2025 U. S. Nuclear Regulatory Commission Page 3 014 UFSAR CHAP 14 Initial Test Program.pdf 015 UFSAR CHAP 15 Accident and Trans Analysis.pdf 016 UFSAR CHAP 16 Technical Specifications.pdf 017 UFSAR CHAP 17 Quality Assurance.pdf 018 UFSAR APPENDIX A UFSAR Supplement.pdf 019 FPR List of Affected Pages 020 FPR VOL 1 Updated Fire Hazards Analysis.pdf 021 FPR VOL 2 Safe Shutdown Analysis.pdf 022 FPR VOL 3 Part 1 of 2.pdf 023 FPR VOL 3 Part 2 of 2.pdf 024 FPR VOL 4.pdf 025 FPR VOL 5.pdf 026 DRE TRM 027 DRE TSB cc:

Regional Administrator - NRC Region III NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Region III - Library

Attachment A Dresden Nuclear Power Station UFSAR Revision 16 Change Summary Report Page 1 of 2 22-006 Revision to UFSAR Section 2.2 and 6.4 Revised sections 2.2, 6.4, and table 2.2 to update Chemical Survey Analysis methodology and results of latest analysis per Engineering Change (EC) 636323.23-006 Revision to UFSAR Sections 4.1, 4.2, and 4.3 Revised sections 4.1, 4.2, 4.3, and tables 1.2 and 4.1 to support receipt, handling, and loading of new GNF3 nuclear fuel assemblies per EC 638449.23-007 Revision to UFSAR Sections 1.6, 4.2, and 9.1 Revised sections 1.6, 4.2, and 9.1 to incorporate new and spent fuel criticality safety analyses for the New Fuel Vaults (NFVs) and Spent Fuel Pools (SFPs) per EC 637901.23-008 Revision to UFSAR Sections 1.2, 3.9, 3.11, 4.1, 4.2, 4.3, 4.4, 4.6, 6.2, 6.3, 7.6, 7.8, 15.0, 15.1, 15.2, 15.3, 15.4, 15.5, 15.6, 15.7, and 15.8 Revised sections 1.2, 3.9, 3.11, 4.1, 4.2, 4.3, 4.4, 4.6, 6.2, 6.3, 7.6, 7.8, 15.0, 15.1, 15.2, 15.3, 15.4, 15.5, 15.6, 15.7, and 15.8 to support irradiation and operations of Unit 2 with new GNF3 fuel assemblies per EC 629262 and EC 638037.23-009 Revision to UFSAR Section 3.9 Revised section 3.9 to update ASME OEM Code edition to reflect sixth ten-year interval.

Reference NRC Safety Evaluation that approved the relief request associated with the sixth 10-year interval Inservice Testing Program dated October 21, 2023.22-009 and 23-010 Revision to UFSAR Section 4.6 Revised section 4.6 to change filter rating for CRD Drive Filters per EC 629262 and EC 638037.23-011 Revision to UFSAR Sections 1.2, 2.1, and 2.4 Revised section 4.6.3.3.2.1 to reflect change in filter rating of Unit 2 and Unit 3 Control Rod Drive (CRD) system filter changes per EC 635376 and EC 635409.23-012 Revision to UFSAR Section 3.2 Revised section 3.2 to identify the Station Blackout (SBO) Building as a Category I safety-related structure.23-013 Revision to UFSAR Section 4.6 Revised section 4.6 to remove Control Rod Scram Times and incorporate a reference to Technical Specification 3.1.4 to provide Control Rod Scram Time requirement.23-014 Revision to UFSAR Section 8.1 Revised section 8.1 to correct Section 8.1.2 to reflect nine 345kV transmission lines.23-015 Revision to UFSAR Section 6.2 Revised section 6.2 to incorporate Reactor Building Ventilation Radiation Monitor Standby Gas Treatment Time Delay Logic modification per EC 639868.23-016 Revision to UFSAR Section 9.2 Revised section 9.2 to restore seismic failure mode of the Ultimate Heat Sink (UHS) to the section.

Attachment A Dresden Nuclear Power Station UFSAR Revision 16 Change Summary Report Page 2 of 2 24-001 Revision to UFSAR Section 4.6 Revised section 4.6 to reflect CRD filter ratings after implementation of EC 635376 and EC 635409. This change included all content from and superseded UFSAR change 23-010.24-005 Revision to UFSAR Section 8.2 Revised Figure 8.2-1 to add COMED 345kV Bus Tie 12-13 Circuit Breaker per EC 640849.24-006 Revision to UFSAR Sections 4.2, 4.3, 4.4, 4.6, and 9.1 Revised sections 4.2, 4.3, 4.4, 4.6, and 9.1 to support introduction of GNF3 fuel in Unit 3, including removal of AREVA/Framatome methods per EC 640377 and EC 641353. Additional changes made to support TSTF-564, Safety Limit MCPR license amendments for Units 2 and 3.

Reference amendments 285/278 (Units 2/3) and NRC Safety Evaluation dated June 26, 2024.24-008 Revision to UFSAR Section 7.3 Revised section 7.3 to correct Low Pressure Coolant Injection (LPCI) Loop Select Response Discrepancy for Recirc Suction Valve Closure.24-010 Revision to UFSAR Section 3.8 Revised section 3.6 to correct typographical error In High Energy Line Break criteria.24-011 Revision to UFSAR Section 9.1 Revised section 9.1 to clarify that BORAL coupons installed in the Unit 3 SFP are used to monitor condition of both Unit 2 and Unit 3 High Density Fuel Racks.

24-0013 Revision to UFSAR Section 9.2 Revised section 9.2 to clarify function of Refuse Pumps.24-014 Revision to UFSAR Section 4.6 Revised section 4.6 to add note to allow 20 micron CRD Drive Water filters per EC 635376 revision 1 and EC 635409 revision 1.

Attachment B Dresden Nuclear Power Station FPR Amendment 25 Change Summary Report Page 1 of 1 Revision Summary:

Fire Protection Report Change Packages23-001, 23-002 and 24-001 update Amendment 25 of the Fire Protection Report. The revisions associated with this update include:

Volume 1 (Fire Hazards Analysis):

1. Change 23-001: EC 637109 - Update Sections 4.2.2, 4.5.2, 4.5.3, and 5.6.1 to remove mention of the wet-pipe system above ACAD compressors.

2. Change 23-002: EC 638773 - Update Section 6.4.3 to clarify there are minor, fixed combustibles within 20ft low fire loading area between U1 and U2.

Volume 2 (Safe Shutdown Report):

1. Change 24-001: EC 629262 - Revise section 3.1.1.2.2 Reactor Coolant Makeup to reflect calculation DRE98-0030 Revision 0D.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 1 of 9 Safety Evaluation Number 2023-05-001 Type of Safety Evaluation: UFSAR Change Evaluation Reference Number: EC 638449, Revision 0

Title:

GNF3 New Fuel Receipt for Placement in Fuel Storage Racks and Reactor Core Unirradiated

==

Description:==

This activity issues the documentation necessary to authorize the receipt, processing, and storage of the new GNF3 fuel in the Dresden New Fuel Storage Vault (NFV) and the spent fuel pool (SFP). This activity also addresses the installation of unirradiated GNF3 fuel in the reactor core.

This activity is required in conjunction with EC 637901 for implementation of the plant design basis change to the criticality safety analyses, reflected in Technical Specifications 4.3.1.1.c, required to demonstrate the GNF3 nuclear fuel can be maintained subcritical while stored on site in either the NFV storage racks or the SFP storage racks, and approved by License Amendments 279/272 (Units 2/3). The criticality analyses are implemented outside of this activity.

A 10 CFR 50.59 Screening determined many changes being made during the proposed activity screened out, except the following:

- Incorporation of GNF fuel design methodologies used in establishing design basis in UFSAR Chapter 4 are different from the current Framatome methods.

The 50.59 evaluation determined:

1. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not result in a more than minimal increase in the frequency of occurrence of an accident previously evaluated in the UFSAR.

2. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

3. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not result in more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR.

4. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

5. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not create a possibility for an accident of a different type than any previously evaluated in the UFSAR.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 2 of 9

6. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core change would not create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the UFSAR.

7. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core would not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.

8. The use of GNF2D lattice code (TGBLA06) and 3D core simulator code (PANAC11) design methods are part of GESTAR II. UFSAR Section 4.3 only included descriptions for Framatome design methods. Changes to UFSAR Section 4.3 to account for GNF design methods by way of GESTAR II was considered an adverse change to methodologies as described in the current UFSAR. GESTAR II is referenced and approved for use at Dresden through TS 5.6.5.b (reference to NEDE-24011-P-A). The use of GNF3 fuel complies with GESTAR II by means of NEDC-33879, Rev. 4. The use of GNF3 fuel product and the associated design methods involving TGBLA06 and PANAC11 are within the requirements and constraints of GESTAR II.

Therefore, the use of GESTAR II for inclusion of the GNF3 fuel product and the associated GNF design methods to UFSAR Sections 4.2 and 4.3 is not considered a departure from a method of evaluation described in the UFSAR.

9. The receipt, processing, and storage of GNF3 fuel in the NFV or SFP and loading unirradiated fuel into the reactor core does not impact the Technical Specifications or Facility Operating License.

Based upon the results of this evaluation, implementing the activity per governing procedures may be performed without prior NRC approval.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 3 of 9 Safety Evaluation Number 2023-06-001 Type of Safety Evaluation: Modification Evaluation Reference Number: EC 629262, Revision 0

Title:

Nuclear Fuels Transition to GNF3 at Dresden (AST Dose Calculations FHA and Post-CRDA)

==

Description:==

This activity updates dose consequence analysis for Control Rod Drop Accident (CRDA) and Fuel Handling Accident (FHA) design accidents at Dresden. The activity supports operation and use of the GNF3 fuel type in core reloads up to and including on a full-core scale. The scope of the evaluation was limited to the impacts of dose-related calculations. Additionally, this activity evaluates the impact on components in affected EQ zones due to increase in normal operating dose from anticipated Dresden plant life extension from 60 to 80 years.

The 50.59 Evaluation determined:

1. The revision of alternate source term (AST) dose calculations for GNF3 fuel does not introduce the possibility of a change in the frequency of an accident because the calculation of doses is not an initiator of any accident and no new failure modes are introduced. There is no change in accident frequency based on implementation of the GNF3 CRDA dose calculation.

2. The revision of AST dose calculations for GNF3 fuel does not result in any increase in the likelihood of malfunction of safety related SSCs.

3. The revision of AST dose calculations for GNF3 fuel results in less than a minimal increase in the radiological consequence for CRDA.

4. The revision of AST dose calculations for GNF3 fuel does not result in any increase in the consequences of malfunctions of safety-related SSCs.

5. The implementation of GNF3 dose consequence analyses does not introduce the possibility of a new accident because the core source term is not an initiator of any accident and no new failure modes are introduced.

6. There are no new malfunctions or possibilities of malfunctions introduced by the GNF3 dose analyses.

7. The revision of AST dose calculations for GNF3 fuel would not result in a design basis limit for a fission product barrier in the UFSAR exceeded or altered.

8. License amendments 233/229 (Units 2/3) adopted full implementation of the AST methodology and RG 1.183 (Rev. 0) Section 3.1 states that core inventories should be determined using an appropriate isotope generation and depletion computer code such as ORIGEN 2 or ORIGEN-ARP. GNF3 AST calculations take inventories generated via ORIGEN-ARP, which is allowed by RG 1.183. Therefore, the use of ORIGEN-ARP in the GNF3 qualifies as a new methods of evaluation that is approved by NRC, it does not constitute a departure from a method of evaluations described in the UFSAR.

9. Updating dose calculations for GNF3 fuel transition and EQ calculation of normal operating dose from plant life extension does not require a change to the Technical Specifications or Facility Operating License.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 4 of 9 Based upon the results of this evaluation, implementing the activity per governing procedures may be performed without prior NRC approval.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 5 of 9 Safety Evaluation Number 2023-08-001 Type of Safety Evaluation: Modification Evaluation Reference Number: EC 629262, Revision 0

Title:

Dresden GNF3 Fuel and Vendor Transition

==

Description:==

Dresden will transition from the ATRIUM 10XM fuel design to the GNF3 fuel design beginning with Unit 2 Cycle 29 reload. EC 629262 allows the GNF3 fuel design to be irradiated and for irradiated GNF3 fuel to be placed into the SFP. This evaluation addressed the GNF3 fuel assembly design and associated nuclear, thermal hydraulic, and transient analysis changes, including GNF methodologies.

The 50.59 Evaluation determined:

1. This activity does not introduce the possibility of a change in the frequency of occurrence of any accident previously evaluated in the UFSAR.

2. This activity does not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

3. This activity does not result in more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR.

4. This activity does not result in a more than minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

5. This activity does not create a possibility for an accident of a different type than any previously evaluated in the UFSAR.

6. This activity does not create a possibility for a malfunction of an SSC important to safety with a different result than any previously evaluated in the UFSAR.

7. This activity does not result in a change that would result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.

8. The implementation of the GNF3 fuel product and the associated GNF design and analysis methods under the GESTAR II into the Dresden UFSAR does not result in a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses because GESTAR II is referenced and approved for use at Dresden, as reflected by it currently being listed in the Technical Specifications and as acknowledged by the NRC with their issuance of Amendment Nos. 281 (U2) and 274 (U3). The use of GNF3 fuel product, the GEXL21 Correlation, the ODYN-based transient analyses methods, and the SAFER/PRIME ECCS-LOCA analysis method, are within the requirements and constraints of GESTAR II.

9. This activity does not affect the Technical Specifications or Facility Operating License.

Based upon the results of this evaluation, implementing the activity per governing procedures may be performed without prior NRC approval.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 6 of 9 Safety Evaluation Number 2023-08-002 Type of Safety Evaluation: Modification Evaluation Reference Number: EC 629262, Revision 0

Title:

Nuclear Fuel Transition to GNF3 at Dresden

==

Description:==

Dresden will transition from the ATRIUM 10XM fuel design to the GNF3 fuel design beginning with Unit 2 Cycle 29 reload. EC 629262 allows the GNF3 fuel design to be irradiated and for irradiated GNF3 fuel to be placed into the SFP. This evaluation addressed the mechanical scope of the GNF3 new fuel introduction.

The 50.59 Evaluation determined:

1. This activity does not result in more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the UFSAR because the GNF3 changes are not an initiator of any accident and because no new failure modes are introduced by the GNF3 changes.

2. This activity does not result in more than a minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR because the GNF3 changes are not an initiator of any new malfunctions and no new failure modes are introduced.

3. The UFSAR-described dose analyses remain valid and bounding. There is no increase in the consequences of any accident previously evaluated in the UFSAR because this portion of the GNF3 new fuel introduction does not introduce the possibility of a change in the consequences of an accident nor is this portion of the GNF3 new fuel introduction an initiator for any new accidents. Therefore, there is not more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR.

4. All existing UFSAR-described dose analyses remain valid and bounding. There is no increase in the consequences of any malfunction previously evaluated in the UFSAR because this portion of the GNF3 new fuel introduction does not introduce the possibility of a change in the consequences of a malfunction, and because this portion of the GNF3 new fuel introduction is not the initiator of any new malfunctions. Therefore, there is not more thana minimal increase in the consequences of a malfunction evaluated in the UFSAR.

5. The GNF3 new fuel introduction effects are completely described by the existing accident analyses. Therefore, there is no increase in the possibility of an accident of a different type than is already analyzed in the UFSAR.

6. This portion of the GNF3 new fuel introduction does not introduce the possibility for a malfunction of an SSC with a different result because the activity does not introduce a failure mode that is not already considered in the UFSAR.

7. The activity does not result in a change that would cause any system parameter to change and does not result in a Design Basis Limit for a Fission Product Barrier (DBLFPB) as described in the UFSAR being exceeded or altered.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 7 of 9

8. This activity does not result in a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses.

9. This activity does not result in a change to the Technical Specifications or the Facility Operating License.

Based upon the results of this evaluation, implementing the activity per governing procedures may be performed without prior NRC approval.

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 8 of 9 Safety Evaluation Number 2024-03-001 Type of Safety Evaluation: Modification Evaluation Reference Number: EC 638687, Revision 0

Title:

Upgrade U3 FWRV Control Systems to Eliminate SPV

==

Description:==

For both Unit 3 Feedwater Regulating Valves (FWRVs), this modification will replace the existing single solenoid that controls the air flow for the valve actuator with a digitally controlled dual positioner and position feedback system. Separate power and instrument air supplies will be used for each of the two positioners on each valve to create redundancy.

The 50.59 Evaluation determined:

1. There are no accidents analyzed in the UFSAR that can be caused by the components modified by this proposed activity. Thus, there is no more than a minimal increase in the frequency of occurrence of an accident previously evaluated in the UFSAR.

2.. This activity does not result in a more than minimal increase in the likelihood of occurrence of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

3. The proposed activity does not establish new design functions, interfaces or design parameters with system, structure or components that are credited for mitigation of the consequences of an accident or for barrier performance. As documented in EC638687, there is no adverse effect on main control room or turbine building heat or combustible loading. Thus, the proposed activity does not result in more than a minimal increase in the consequences of an accident previously evaluated in the UFSAR.

4. The proposed activity does not establish new design functions, interfaces or design parameters with system, structure or components that are credited for mitigation of the consequences of a malfunction of an SSC important to safety. Thus, the proposed activity does not result in more than a minimal increase in the consequences of a malfunction of an SSC important to safety previously evaluated in the UFSAR.

5. This activity modifies the control of the FWRVs, to improve the redundancy of the valve position control interface. A failure of the new position controllers or sensors would, at worst-case, result in the FWRVs failing in position as-is, irrelevant of selector switch position, which is bounded by the possible failures with the existing position control solenoid. The proposed activity does not establish new system interfaces. Based on review of the types of accidents previously evaluated in the UFSAR, there are no new accidents that can be caused by operation of the FWRVs.

6. This activity modifies the control of the FWRVs, to create a redundancy in the interface between the non-redundant FWLC system and the FWRV actuator. No new system interfaces are created. The worst-case possible failure of control of the FWRVs is for one or both valves to fail full-open or full-close specifically due to a Bailey INFI 90 failure or airline break. The results of this type of failure are bounded by the feedwater control system transients previously evaluated in the UFSAR. Thus, there is no possibility created for a malfunction of an SSC important to safety with a different result than any previously evaluated in the UFSAR.

7. This activity modifies the control of the FWRVs, to improve the redundancy of the valve position control interface between the FWLC system and the valve actuator. No new failure

Attachment C Dresden Nuclear Power Station 10 CFR 50.59 Evaluation Summary Report Page 9 of 9 results are introduced by this modification that are not bounded by the existing UFSAR accident analysis as described above. This activity does not result in a change that would cause any system parameter to change. This activity does not make any changes to fuel cladding, the reactor coolant system pressure boundary, or containment barriers. There is no breach of the reactor coolant pressure boundary, and no changes to the numerical values in the UFSAR that are used directly in the determination of the integrity fission product barriers. No changes are made to radiological release paths. Thus, the proposed activity does not result in a design basis limit for a fission product barrier as described in the UFSAR being exceeded or altered.

8. The activity does not involve a departure from a method of evaluation described in the UFSAR used in establishing the design bases or in the safety analyses.

9. This activity does not result in a change to the Technical Specifications or the Facility Operating License.

Based upon the results of this evaluation, implementing the activity per governing procedures may be performed without prior NRC approval.

Attachment D Dresden Nuclear Power Station Technical Requirements Manual Change Summary Report Page 1 of 1 23-002 Revision to TRM Section 3.7.j Revised TRM to remove systems from the list of Water Suppression Systems due to system removal. Reference Engineering Change 637109.23-003 Revision to TRM Section 5.0.b Revised TRM to remove reference to Technical Specification 5.5.6. Reference License Amendments 254/247 (Unit 2/3), NRC Safety Evaluation dated May 26, 2017.23-004 Revision to TRM Section 3.7.a Revised TRM to remove verbiage from Applicability of TRM 3.7.a. Reference License Amendments 221/212 (Units 2/3), NRC Safety Evaluation dated September 11, 2006.23-005 Revision to TRM Appendix E Updated Appendix E to include Dresden 2 COLR Revision 20 for D2C29.24-002 Revision to TRM Section 3.7.m Revised TRM Surveillance Frequency Requirement (TSR) 3.7.m.1 frequency change from 92 days to 184 days. Reference Engineering Change 641941.24-005 Revision to TRM Appendix E Updated Appendix E to include Dresden 2 COLR Revision 21 for D2C29.24-006 Revision to TRM Appendix F Updated Appendix F to include Dresden 3 COLR Revision 19 for D3C29.25-001 Revision to TS TSR 3.8.a.1 and 3.8.b.1 are revised based on Surveillance Test Interval (STI) Evaluation 20-003.

Revisions to TRM Appendix I as part of the Surveillance Frequency Control Program (SFCP) 25-001: TS SR 3.8.4.1 and 3.8.6.1 are revised based on Surveillance Test Interval (STI)

Evaluation 20-003.

Attachment E Dresden Nuclear Power Station Summary of Regulatory Commitment Changes Page 1 of 1 In accordance with the guidance provided in Nuclear Energy Institute (NEI) 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes," dated July 1999, Dresden Nuclear Power Station is submitting a summary of commitments revised that can be changed with notification to the NRC submitted along the FSAR updates as required by 10 CFR 50.71(e).

No commitment changes were processed requiring NRC notification during the period of June 1, 2023, through May 31, 2025.

There was one late performance of a regulatory commitment.

Commitment Number: NTS 249-200-78-073 Source/Original Document:

1. IE Bulletin 80-10, Contamination of Nonradioactive System and Resulting Potential for Unmonitored, Uncontrolled Release of Radioactivity to Environment Comments:

In May 2025, a Service Water sample was unable to be obtained from the Unit 2 B Low Pressure Coolant Injection (LPCI) heat exchanger due to the condition documented in Issue Report (IR) 04866384. This was a late Regulatory Commitment of performing LPCI heat exchanger sampling for isotopic analysis at least once per 30 days.

The heat exchanger sample was completed at 31 days.

1 of 1 Attachment F Dresden Nuclear Power Station 10CFR 54.37(b) Aging Management Review Summary In accordance with 10 CFR 54.37(b) and the guidance specified in Regulatory Issue Summary 2007-16, Revision 1, Implementation of the Requirements of the 10 CFR 54.37(b) for Holders of Renewed Licenses, the UFSAR update required by 10 CFR 50.71 must include any Structures, Systems or Components (SSCs) newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with 10 CFR 54.21. This UFSAR update must describe how the effects of aging will be managed such that the intended function(s) in 10 CFR 54.4(b) will be effectively maintained during the period of extended operation.

The 10 CFR 54.37(b) review of changes to the plant Current Licensing Basis covered the period of April 1, 2023 to May 19, 2025. The review included:

Engineering Changes that were installed or completed since the last UFSAR update, UFSAR pending change descriptions and revised text, and NRC Interim Staff Guidelines (ISGs) related to license renewal.

No newly identified SSCs were identified that require aging management or evaluation of Time Limiting Aging Analyses (TLAAs) in accordance with the License Renewal Rule. Therefore, there are no associated updates required to the Dresden UFSAR described Aging Management Programs.

Attachment G Dresden Nuclear Power Station Electronic File Directory Structure Page 1 of 1 Directory Path File Name Size C:\ DRE UFSAR REV 16 000 UFSAR Cover and List of Affected Pages.pdf 130 KB C:\ DRE UFSAR REV 16 001 UFSAR CHAP 01 Introduction.pdf 414 KB C:\ DRE UFSAR REV 16 002 UFSAR CHAP 02 Site Characteristics.pdf 1523 KB C:\ DRE UFSAR REV 16 003 UFSAR CHAP 03 Design of SCE.pdf 8628 KB C:\ DRE UFSAR REV 16 004 UFSAR CHAP 04 Reactor.pdf 3960 KB C:\ DRE UFSAR REV 16 005 UFSAR CHAP 05 Reactor Coolant Sys.pdf 2932 KB C:\ DRE UFSAR REV 16 006 UFSAR CHAP 06 Engineered Safety Features.pdf 12731 KB C:\ DRE UFSAR REV 16 007 UFSAR CHAP 07 Instrument and Controls.pdf 5939 KB C:\ DRE UFSAR REV 16 008 UFSAR CHAP 08 Electrical Power.pdf 4964 KB C:\ DRE UFSAR REV 16 009 UFSAR CHAP 09 Auxiliary Systems.pdf 4342 KB C:\ DRE UFSAR REV 16 010 UFSAR CHAP 10 Steam and Power Conv Sys.pdf 439 KB C:\ DRE UFSAR REV 16 011 UFSAR CHAP 11 Radioactive Waste Mgmt.pdf 6646 KB C:\ DRE UFSAR REV 16 012 UFSAR CHAP 12 Radiation Protection.pdf 41753 KB C:\ DRE UFSAR REV 16 013 UFSAR CHAP 13 Conduct of Operations.pdf 235 KB C:\ DRE UFSAR REV 16 014 UFSAR CHAP 14 Initial Test Program.pdf 534 KB C:\ DRE UFSAR REV 16 015 UFSAR CHAP 15 Accident and Trans Analysis.pdf 3893 KB C:\ DRE UFSAR REV 16 016 UFSAR CHAP 16 Technical Specifications.pdf 63 KB C:\ DRE UFSAR REV 16 017 UFSAR CHAP 17 Quality Assurance.pdf 69 KB C:\ DRE UFSAR REV 16 018 UFSAR APPENDIX A UFSAR Supplement.pdf 306 KB C:\DRE FPR AMEND 25 019 FPR List of Affected Pages 67 KB C:\DRE FPR AMEND 25 020 FPR VOL 1 Updated Fire Hazards Analysis.pdf 3610 KB C:\DRE FPR AMEND 25 021 FPR VOL 2 Safe Shutdown Analysis.pdf 4362 KB C:\DRE FPR AMEND 25 022 FPR VOL 3 Part 1 of 2.pdf 32880 KB C:\DRE FPR AMEND 25 023 FPR VOL 3 Part 2 of 2.pdf 37119 KB C:\DRE FPR AMEND 25 024 FPR VOL 4.pdf 87331 KB C:\DRE FPR AMEND 25 025 FPR VOL 5.pdf 23924 KB C:\DRE TRM 026 DRE TRM 2266 KB C:\DRE TSB 027 DRE TSB 2380 KB