ML20269A200

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Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI (EPID L2020-LLR-0117
ML20269A200
Person / Time
Site: Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  Constellation icon.png
Issue date: 09/30/2020
From: Nancy Salgado
Plant Licensing Branch III
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
Purnell B, NRR/DORL/LPLIII, 415-1380
References
EPID L2020-LLR-0117
Download: ML20269A200 (8)


Text

September 30, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; JAMES A. FITZPATRICK NUCLEAR POWER PLANT; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND R. E. GINNA NUCLEAR POWER PLANT - REQUEST TO USE A PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI (EPID L-2020-LLR-0117)

Dear Mr. Hanson:

By application dated September 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G735), as supplemented by letter dated September 24, 2020 (ADAMS Accession No. ML20268A984), Exelon Generation Company, LLC (Exelon) submitted a request to use a provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, at Braidwood Station (Braidwood), Units 1 and 2; Byron Station (Byron), Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Units 1 and 2; Clinton Power Station (Clinton), Unit No. 1; Dresden Nuclear Power Station (Dresden), Units 2 and 3; James A.

FitzPatrick Nuclear Power Plant (FitzPatrick); LaSalle County Station (LaSalle), Units 1 and 2; Limerick Generating Station (Limerick), Units 1 and 2; Nine Mile Point Nuclear Station (NMP),

Units 1 and 2; Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3; Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2; and R. E. Ginna Nuclear Power Plant (Ginna). Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv), Exelon proposed to use subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI, in place of the corresponding subparagraph from the code of record at each of these facilities.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that Exelon has adequately addressed the requirements in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff approves the use of subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI, for Braidwood Units 1 and 2, Byron Unit Nos. 1 and 2, Calvert Cliffs Units 1 and 2, Clinton Unit

No. 1, Dresden Units 2 and 3, FitzPatrick, LaSalle Units 1 and 2, Limerick Units 1 and 2, NMP Units 1 and 2, Peach Bottom Units 2 and 3, Quad Cities Units 1 and 2, and Ginna. For each facility, this approval is for the remainder of the current 10-year inservice inspection interval, as specified in the application and corrected by the September 24, 2020, letter. All other ASME BPV Code,Section XI, requirements which are not modified by the staffs approval of the licensees request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

If you have any questions, please contact Blake Purnell at 301-415-1380 or via e-mail at Blake.Purnell@nrc.gov.

Sincerely, Nancy L. Salgado, Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, and 50-244

Enclosure:

Safety Evaluation cc: Listserv Nancy L.

Salgado Digitally signed by Nancy L. Salgado Date: 2020.09.30 14:57:59 -04'00'

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE A PROVISION OF A LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE EXELON GENERATION COMPANY, LLC BRAIDWOOD STATION, UNITS 1 AND 2 BYRON STATION, UNIT NOS. 1 AND 2 CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 CLINTON POWER STATION, UNIT NO. 1 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 JAMES A. FITZPATRICK NUCLEAR POWER PLANT LASALLE COUNTY STATION, UNITS 1 AND 2 LIMERICK GENERATING STATION, UNITS 1 AND 2 NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 R. E. GINNA NUCLEAR POWER PLANT DOCKET NOS. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, AND 50-244

1.0 INTRODUCTION

By application dated September 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G735), as supplemented by letter dated September 24, 2020 (ADAMS Accession No. ML20268A984), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request to use a provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV)

Code,Section XI, at Braidwood Station (Braidwood), Units 1 and 2; Byron Station (Byron), Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant (Calvert Cliffs), Units 1 and 2; Clinton Power Station (Clinton), Unit No. 1; Dresden Nuclear Power Station (Dresden), Units 2 and 3; James A. FitzPatrick Nuclear Power Plant (FitzPatrick); LaSalle County Station (LaSalle), Units 1 and 2; Limerick Generating Station (Limerick), Units 1 and 2; Nine Mile Point Nuclear Station (NMP), Units 1 and 2; Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3; Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2; and R. E. Ginna Nuclear Power Plant (Ginna). Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv), Exelon proposed to use subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI, in place of the corresponding subparagraph from the code of record at these facilities.

2.0 PROPOSED USE OF SUBSEQUENT CODE EDITION AND ADDENDA 2.1 Components for Which the Subsequent Code Edition is Requested All Class 1, 2, and 3 items located in the ASME BPV Code,Section XI, boundaries.

2.2 Current Code Requirement Subparagraph IWA-4540(b) provides items that are exempt from pressure testing after repair/replacement activities.

2.3 Current Code Edition and Addenda of Record The application, as supplemented, identified the currently applicable editions and addenda of the ASME BPV Code,Section XI, for each plant, as shown in Table 1 below. In addition, Table 1 shows the associated 10-year inservice inspection (ISI) interval, including the start and end dates, for each plant.

Table 1: Current ASME BPV Code,Section XI, Code of Record PLANT ISI INTERVAL ASME BPV CODE, SECTION XI START END Braidwood Unit 1 4th 2013 Edition 8/29/2018 7/28/2028 Braidwood Unit 2 4th 2013 Edition 11/5/2018 10/16/2028 Byron Units 1 and 2 4th 2007 Edition, through 2008 Addenda 7/16/2016 7/15/2025 Calvert Cliffs Units 1 and 2 5th 2013 Edition 7/1/2019 6/30/2029 Clinton 4th 2013 Edition 7/1/2020 6/30/2030 Dresden Units 2 and 3 5th 2007 Edition, through 2008 Addenda 1/20/2013 1/19/2023 PLANT ISI INTERVAL ASME BPV CODE, SECTION XI START END FitzPatrick 5th 2007 Edition, through 2008 Addenda 8/1/2017 6/15/2027 LaSalle Units 1 and 2 4th 2007 Edition, through 2008 Addenda 10/1/2017 9/30/2027 Limerick Units 1 and 2 4th 2007 Edition, through 2008 Addenda 2/1/2017 1/31/2027 NMP Unit 1 5th 2013 Edition 8/23/2019 8/22/2029 NMP Unit 2 4th 2013 Edition 8/23/2018 8/22/2028 Peach Bottom Units 2 and 3 5th 2013 Edition 1/1/2019 12/31/2028 Quad Cities Units 1 and 2 5th 2007 Edition, through 2008 Addenda 4/2/2013 4/1/2023 Ginna 6th 2013 Edition 1/1/2020 12/31/2029 2.4 Proposed Subsequent Code Edition and Addenda The proposed subsequent Code edition and addenda to be used is subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI.

2.5 Duration of the Use of the Later Code Edition and Addenda The duration of this request is for the remainder of the current 10-year ISI interval for each plant, as shown in Table 1 above.

3.0 REGULATORY EVALUATION

The licensee is proposing to use a portion of a later edition and addenda of the ASME BPV Code,Section XI, in accordance with 10 CFR 50.55a(g)(4)(iv), which states:

Inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (a) of this section, subject to the conditions listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.

Given that 10 CFR 50.55(g)(4)(iv) permits the U.S. Nuclear Regulatory Commission (NRC) staff to approve the use of subsequent editions and addenda of the ASME BPV Code,Section XI, the NRC staff finds that, subject to the following technical evaluation, the licensee may propose to use a portion of a later edition and addenda of the ASME BPV Code,Section XI, and the NRC staff has the regulatory authority to approve the use of a portion of a later edition and addenda of the ASME BPV Code,Section XI.

4.0 NRC TECHNICAL EVALUATION As previously stated in Section 3.0 of this safety evaluation, prior to approving the use of a subsequent edition and addenda of the ASME BPV Code under 10 CFR 50.55a(g)(4)(iv), the NRC staff must find that: (1) the proposed subsequent edition and addenda are incorporated by reference in 10 CFR 50.55a(a); (2) the licensee will comply with the conditions listed in 10 CFR 50.55a(b) that are applicable to the proposed edition and addenda of the ASME BPV Code; (3) the licensee requested approval to use the subsequent edition and addenda; and (4) if only portions of edition or addenda are to be used, all related requirements of the respective edition or addenda are met. If these criteria are met, the NRC staff finds the use of the subsequent edition and addenda of the ASME BPV Code,Section XI, to be acceptable.

4.1 Incorporation by Reference In evaluating the first criterion, 10 CFR 50.55a(a) incorporates by reference the ASME BPV Code,Section XI, from the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition through the 2017 Edition. The licensee proposed to use the 2017 Edition of Section XI, which is included in the list of editions and addenda incorporated by reference in the current edition of 10 CFR 50.55a(a). Therefore, the NRC finds that the first criterion has been satisfied.

4.2 Subject to Conditions Listed in 10 CFR 50.55a(b)

In evaluating the second criterion, the NRC staff finds that 10 CFR 50.55a(b) contains no conditions relevant to this request. Therefore, the NRC staff finds that the second criterion has been satisfied.

4.3 Requesting Commission Approval In evaluating the third criterion, the licensees request dated September 2, 2020, constitutes a request to the Commission for approval to use a subsequent edition or addendum of the ASME BPV Code. Therefore, the NRC staff finds that the third criterion has been satisfied.

4.4 All Related Requirements In evaluating the fourth criterion, the NRC staff finds that there are no related requirements relevant to this request. Therefore, the NRC staff finds that the fourth criterion has been satisfied.

4.5 Summary Based on the review above, the NRC staff finds that the licensee has adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv).

5.0 CONCLUSION

As set forth above, the NRC staff finds that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff concludes that the use of subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI, is acceptable. The NRC staff approves the use of subparagraph IWA-4540(b) of the 2017 Edition of the ASME BPV Code,Section XI, at Braidwood Units 1 and 2, Byron Unit Nos. 1 and 2, Calvert Cliffs Units 1 and 2, Clinton Unit No. 1, Dresden Units 2 and 3, FitzPatrick, LaSalle Units 1 and 2, Limerick Units 1 and 2, NMP Units 1 and 2, Peach Bottom Units 2 and 3, Quad Cities Units 1 and 2, and Ginna. For each facility, this approval is for the remainder of the current 10-year ISI interval, as listed in Table 1 above.

All other ASME BPV Code,Section XI, requirements which are not modified by the NRC staffs approval of the licensees request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: Blake Purnell, NRR Date: September 30, 2020

ML20269A200

  • via email OFFICE DORL/LPL3/PM DORL/LPL3/LA NRR/DNRL/NPHP/BC*

NAME BPurnell SRohrer MMitchell DATE 9/29/20 9/28/20 9/25/20 OFFICE NRR/DORL/LPL3/BC*

NAME NSalgado DATE 9/30/20