ML21028A673

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Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI (EPID L-2020-LLR-011
ML21028A673
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: 02/03/2021
From: Blake Purnell, Nancy Salgado
Plant Licensing Branch III
To: Rhoades D
Exelon Generation Co, Exelon Nuclear
Purnell B
References
EPID L-2020-LLR-011
Download: ML21028A673 (8)


Text

February 3, 2021 Mr. David P. Rhoades 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-0118)

Dear Mr. Rhoades:

By application dated September 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20246G739), 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 the periodic system pressure test exemptions in paragraph IWA-5120 of the 2017 Edition of the ASME BPV Code,Section XI, 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 paragraph IWA-5120 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 as supplemented by the September 24, 2020, letter.

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: 2021.02.03 11:21:50 -05'00'

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. ML20246G739), 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 the periodic system pressure test exemptions in paragraph IWA-5120 of the 2017 Edition of the ASME BPV Code,Section XI, at each of these facilities.

2.0 REGULATORY EVALUATION

Specific editions and addenda, or portions thereof, of the ASME BPV Code,Section XI, have been incorporated by reference into 10 CFR 50.55a(a)(1)(ii). The editions and addenda of the ASME BPV Code,Section XI, are subject to the limitations in 10 CFR 50.55a(b)(2).

The regulations in 10 CFR 50.55a(g)(4) state, in part, that ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in Section XI of the applicable editions and addenda of the ASME Code to the extent practical within the limitations of design, geometry, and materials of construction of the components. Paragraph 50.55a(g)(4)(iv) of 10 CFR states:

lnservice 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 [10 CFR 50.55a], 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.

3.0 TECHNICAL EVALUATION

3.1 Exelons Request 3.1.1 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 subject to periodic system pressure tests.

3.1.2 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 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 3.1.3 Proposed Subsequent Code Edition The proposed subsequent Code edition to be used is paragraph IWA-5120 of the 2017 Edition of the ASME BPV Code,Section XI, in place of the requirements in subparagraph IWA-5110(c) in the currently applicable editions and addenda of the ASME BPV Code,Section XI, for each facility (see Table 1 above). Subparagraph IWA-5110(c) in the current code of record (Table 1) states: Piping that penetrates a containment vessel is exempt from the periodic system pressure test when the piping and isolation valves perform a containment function and the balance of the piping system is outside the scope of this Division. Subparagraph IWA-5110(c) was relocated to the new paragraph IWA-5120 in the 2017 Edition of the ASME BPV Code,Section XI. However, paragraph IWA-5120 also exempts additional systems and components from the periodic pressure test requirement.

3.1.4 Duration of the Use of the Later Code Edition 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.

3.2 Staff Evaluation Based on the requirements in 10 CFR 50.55a(g)(4)(iv), the U.S. Nuclear Regulatory Commission (NRC or Commission) staff considered the following criteria in its review of Exelons application:

1. The proposed edition or addenda of the ASME BPV Code are incorporated by reference in 10 CFR 50.55a(a).
2. The proposed edition or addenda of the ASME BPV Code are subject to the conditions listed in 10 CFR 50.55a(b).
3. The licensee requested NRC approval to use the subsequent edition or addenda of the ASME BPV Code.
4. If only portions of editions or addenda are to be used, all related requirements of the respective editions or addenda are met.

Exelon requested to use specific provisions in the 2017 Edition of the ASME BPV Code,Section XI, which has been incorporated by reference in 10 CFR 50.55a(a). Therefore, the first criterion above has been satisfied.

The NRC staff determined that there are no conditions on paragraph IWA-5120 of the 2017 Edition of the ASME BPV Code,Section XI, listed in 10 CFR 50.55a(b). Therefore, the second criterion above has been satisfied.

The NRC staff determined that Exelons 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,Section XI. Therefore, the third criterion above has been satisfied.

The NRC staff reviewed Article IWA-5000, which includes paragraph IWA-5120, of the 2017 Edition of the ASME Code,Section XI, to determine whether other relevant provisions would affect the proposed use of paragraph IWA-5120 at Exelons facilities. The pressure testing exemption provisions of paragraph IWA-5120 were added to Section XI with the 2017 Edition.

The NRC staff determined that no other related changes were added to Section XI, Article IWA-5000, with the 2017 Edition that would need to be implemented as part of Exelons request.

Therefore, the fourth criterion above has been satisfied.

The NRC staff finds that the licensee has adequately addressed all regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv) since the four criteria above have been satisfied.

4.0 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 paragraph IWA-5120 of the 2017 Edition of the ASME BPV Code,Section XI, is acceptable. The NRC staff approves the use of paragraph IWA-5120 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.

Principal Contributor: John Tsao, NRR/DNRL/NVIB Keith Hoffman, NRR/DNRL/NPHP Date: February 3, 2021

ML21028A673 OFFICE DORL/LPL3/PM DORL/LPL3/LA NRR/DNRL/NVIB/BC NAME BPurnell SRohrer HGonzalez DATE 2/1/21 2/1/21 1/13/21 OFFICE NRR/DNRL/NPHP/BC NRR/DORL/LPL3/BC NAME MMitchell (HGonzalez for) NSalgado DATE 1/13/21 2/3/21