U-604712, Submittal of the Snubber Program Plan for the Fourth 10-Year Interval

Submittal of the Snubber Program Plan for the Fourth 10-Year Interval

ML22174A331
Person / Time
Site:	Clinton
Issue date:	06/24/2020
From:	Chalmers T Constellation Energy Generation
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
U-604712
Download: ML22174A331 (1)

Text

Clinton Power Station Constellation 8401 Power Road Clinton, IL 61727 U-604712 10 CFR 50.55a June 23, 2022 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461

Subject:

Clinton Power Station Submittal of the Snubber Program Plan for the Fourth 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 Clinton Power Station (CPS) Snubber Program Plan for the fourth ten-year interval. The CPS fourth ten-year interval Snubber Program Plan complies with the requirements of the ASME OM Code 2012 Edition. The fourth ten-year interval for CPS Unit 1 began on July 1, 2020, and ends on June 30, 2030.

There are no regulatory commitments contained in this letter.

If you have any questions, please contact Mr. David Livingston, Regulatory Assurance Manager, at (217) 937-2800.

Respectfully,

~era Site Vice President Clinton Power Station

Attachment:

ER-CL-330-1008, Rev. 0, Snubber Program Plan, Fourth 10-Year lnservice Testing Interval cc: NRC Senior Resident Inspector - Clinton Power Station NRC Project Manager, NRR - Clinton Power Station NRC Regional Administrator, Region Ill Illinois Emergency Management Agency - Division of Nuclear Safety

7 Exelon Generation .

CLINTON POWER STATION 8401 POWER ROAD CLINTON, IL 61727 SNUBBER PROGRAM PLAN FOURTH 10-YEAR INSERVICE TESTING INTERVAL Commercial Service Date: November 24, 1987 NRC Docket Number: 50-461 Fourth 1ST lntervaJ: July l, 2020 through June 30, 2030 Document Number: ER-CL-330-1008 Revision Number: 00 PREPARED BY: Timothy Seo DATE: 6/24/2020 Snubber Program Owner REVIEWED BY: Joseph Pawasarat DATE: 06/25/2020 Engineering Programs APPROVED BY: DATE:

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Exelon Generation Company Clinton Power Station Fourth Inservice Testing Interval REVISION LOG This program plan is the initial issue of the Snubber Program Plan after transition from the ASME ISi Code,Section XI to the ASME Division 1 OM Code, Section 1ST (hereinafter referred to as the ASME OM Code). Beginning July 1, 2020, the snubber program will be under the ASME OM Code and will thereafter be aligned with the 1ST 10 Year Interval. The Fourth IST 10 Year Interval is currently scheduled to end on June 30, 2030.

Description Prepared Bv Date Reviewed Bv Date Annroved Bv Date Fourth Interval Snubber Program Plan Page 2 of6 ER-CL-330- I 008 Revision 0

Exelon Generation Company Clinton Power Station Fourth Inservice Testing Interval TABLE OF CONTENTS SECTION 1.0 GENERAL 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 EVALUATION 7.0 REPAIR, REPLACEMENT, AND MODIFICATION REQUIREMENTS 8.0 SCHEDULING 9.0 REPORTS AND RECORDS Page 3 of6 ER-CL-330-1008 Revision 0

Exelon Generation Company Clinton Power Station Fourth Inservice Testing Interval

1.0 General

1.1 The visual examination, service life monitoring and operational readiness testing of all safety related snubbers at Clinton Power Station (Clinton) will be implemented in accordance with ER-CL-330-1007, "Snubber Inservice Testing Program" to assess the required operational readiness of these snubbers during a seismic or other dynamic event.

1.2 The Snubber Program, as defined within ER-CL-330-1007, establishes visual examination, operational readiness testing and service life monitoring requirements, pertaining to all program snubbers that are required for safe shutdown of the reactor, maintaining the safe shutdown condition, mitigating the consequences of an accident, or ensuring the integrity of the reactor coolant pressure boundary.

1.3 The snubbers included in this program are identified within ER-CL-330-1007.

I .4 The Snubber Program described in ER-CL-330-1007 adheres to the requirements of the ASME OM Code, 2012 Edition, as required by IOCFR50.55a(b)(3)(v)(B).

2.0 Examination, Testing and Monitoring Requirements:

2.1 Visual examinations and operational readiness testing will be performed as specified within ER-CL-330-1007 and in accordance with Exelon fleet administrative procedures ER-AA-330-004 and ER-AA-330-0 I 0.

2.2 The examination boundaries are the snubber assembly from pin to pin inclusive.

2.3 Snubbers shall be examined, as specified in ER-CL-330-1007, prior to conducting any maintenance, stroking, or testing, and prior to removal, for any reason, from their installed location.

2.4 The Program Snubbers are grouped into Defined Test Plan Groups, (DTPG's) by design type, and in accordance with ISTD-5250, for testing purposes. The DTPG's at Clinton are specified in ER-CL-330-1007.

2.5 The service life of all snubbers in this program will be monitored and snubbers replaced or reconditioned as specified in ER-CL-330-1007 and required by Exelon fleet administrative procedure ER-AA-330-011 to ensure that the service life is not exceeded before the next scheduled system or plant outage, or during a period when the snubber is required to be operationally ready. The replacement or reconditioning of snubbers will be documented, and records retained in accordance with Clinton procedures.

3.0 Examination and Testing Methods:

3.1 Visual examinations will be performed by individuals qualified in accordance with ISTA-1500(e). Visual examinations and operational readiness testing shall be performed to verify the requirements specified within ER-CL-330-1007 in accordance with the requirements of Subsection ISTD of the ASME OM Code.

4.0 Examination and Testing Frequency:

Page 4 of6 ER-CL-330-1008 Revision 0

Exelon Generation Company Clinton Power Station Fourth Inservice Testing Interval 4.1 Inservice visual examinations and pre and inservice operational readiness testing will be performed at the frequency specified within ER-CL-330-1007.

4.2 Preservice visual examinations will be performed whenever new snubber locations are installed, or after system replacements or modifications as specified in ER-CL-330-1007 in accordance with paragraph ISTD-4100 of the ASME OM Code.

5.0 ASME OM Code Case OMN-13:

5.1 Code Case OMN-13 Rev. 2, which allows the extension of the visual examination interval, may be used during the Fourth Ten Year 1ST lnterval.6.0 Examination, Testing and Monitoring Evaluation:

6.1 Snubbers that do not appear to conform to the visual examination requirements of ER-CL-330-1007 and procedure ER-AA-330-004, will be evaluated and appropriate corrective action taken.

6.2 Snubbers that do not appear to conform to visual examination acceptance requirements and are later confirmed as functional as a result of operational readiness testing, may be declared acceptable for the purpose of establishing the next visual examination interval, providing that the unacceptable condition did not affect operational readiness of the snubber.

6.3 Snubbers that do not meet the operational readiness testing acceptance criteria in ER-CL-330-1007 and procedure ER-AA-330-010 will be evaluated to determine the cause of the failure and appropriate corrective action will be taken.

6.4 The service life of every snubber is evaluated at least once each fuel cycle using manufacturing input and engineering information gained through consideration of the snubber service conditions and inservice operational readiness test results in accordance with ER-CL-330-1007.

7.0 Repair, Replacement and Modification Requirements:

7.1 Repairs, replacements and modifications performed on snubbers under this program shall conform, as applicable, to the requirements specified within the Clinton Repair and Replacement Program.

8.0 Scheduling

8.1 The Visual examinations and operational readiness testing schedules will be established, tracked and maintained within the Central Programs Engineering Department.

8.2 The Snubber Testing Program will identify, and track expanded, or additional testing and/or examinations as specified and required by ER-CL-330-1007 in accordance with Subsection ISTD of the ASME OM Code.

9.0 Reports and Records:

9.1 Reports and records for the visual examinations and operational readiness testing will be Page 5 of6 ER-CL-330-1008 Revision 0

Exelon Generation Company Clinton Power Station Fourth Inservice Testing Interval maintained on all snubbers in the scope of the program as specified in ER-CL-330-1007.

9.2 Applicable records and reports, as required for repair and replacements, will be maintained for all snubbers as specified in ER-CL-330-1007.

9.3 Records of the service life of all program snubbers listed in this program, including the date at which the service life commences, and associated installation and maintenance records will be maintained as specified in ER-CL-330-1007.

Page 6 of6 ER-CL-330-1008 Revision 0