RS-22-126, Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

Constellation Energy Generation, LLC - Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI

ML22334A136
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	11/30/2022
From:	David Gudger Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-22-126, NMP1L3483
Download: ML22334A136 (1)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-22-126 NMP1L3483 November 30, 2022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

U.S. Nuclear Regulatory Commission Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI November 30, 2022 Page 2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

Subject:

Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI

Reference:

NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl," dated July 28, 2004 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv), and the guidance provided in the referenced document, Constellation Energy Generation, LLC (CEG) requests NRC approval to use a specific provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, incorporated in 10 CFR 50.55a(a)(1)(ii), for the units identified above. Specifically, CEG requests approval to use IWA-6220 ("Owners Repair/Replacement Certification Record"),

IWA-6230 ("Owners Activity Report"), and Mandatory Appendix II ("Owners Record and Report") of the 2019 Edition of the ASME B&PV Code,Section XI for post outage reporting requirements.

CEG requests approval of this request by April 30, 2023 to allow implementation for Spring 2023 outage summary reports. There are no regulatory commitments in this letter.

If you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

Respectfully, David T. Gudger Senior Manager - Licensing & Regulatory Affairs Constellation Energy Generation, LLC

U.S. Nuclear Regulatory Commission Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI November 30, 2022 Page 3

Attachment:

Request to Use Portions of a Later Edition of the ASME B&PV Code,Section XI cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources W. DeHaas - Pennsylvania Bureau of Radiation Protection S. Seaman - State of Maryland A. L. Peterson - NYSERDA

Attachment Request to Use Portions of a Later Edition of the ASME B&PV Code,Section XI

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 1 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv) and the guidance provided in Reference 1, Constellation Energy Generation, LLC (CEG) requests NRC approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, incorporated in 10 CFR 50.55a(a)(1)(ii), for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 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. Specifically, CEG requests approval to use IWA-6220 ("Owners Repair/Replacement Certification Record"), IWA-6230

("Owners Activity Report"), and Mandatory Appendix II ("Owners Record and Report") of the 2019 Edition of the ASME B&PV Code,Section XI for post outage reporting requirements.

1. Component(s) Affected All Class 1, 2, 3, MC, and CC items.

2. Requested Date for Approval Approval is requested by April 30, 2023 to allow implementation for Spring 2023 outage summary reports.

3. Applicable Code Edition and Addenda

PLANT INTERVAL EDITION START END Braidwood Station, Units 1 and 2 Fourth 2013 Edition August 29, July 28, 2028 2018 October 16, November 5, 2028 2018 Byron Station, Units Fourth 2007 Edition, through July 16, 2016 July 15, 2025 2008 Addenda 1 and 2 Calvert Cliffs Nuclear Power Plant, Fifth 2013 Edition July 1, 2019 June 30, 2029 Units 1 and 2 Clinton Power Station, Unit 1 Fourth 2013 Edition July 1, 2020 June 30, 2030 Dresden Nuclear Power Station, Sixth 2017 Edition January 20, January 19, Units 2 and 3 2023 2033 James A. FitzPatrick Nuclear Fifth 2007 Edition, through August 1, 2017 June 15, 2027 Power Plant 2008 Addenda LaSalle County Stations, Units 1 Fourth 2007 Edition, through October 1, September 30, and 2 2008 Addenda 2017 2027

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 2 PLANT INTERVAL EDITION START END Limerick Generating Station, Units Fourth 2007 Edition, through February 1, January 31, 1 and 2 2008 Addenda 2017 2027 Nine Mile Point Nuclear Station, Fifth 2013 Edition August 23, August 22, 2029 Unit 1 2019 Nine Mile Point Nuclear Station, Fourth 2013 Edition August 23, August 22, 2028 Unit 2 2018 Peach Bottom Atomic Power Fifth 2013 Edition January 1, December 31, Station, Units 2 and 3 2019 2028 Quad Cities Nuclear Power Sixth 2017 Edition April 2, 2023 April 1, 2033 Station, Units 1 and 2 R. E. Ginna Nuclear Power Plant Sixth 2013 Edition January 1, December 31, 2020 2029

4. Proposed Subsequent Code Edition and Addenda (or Portion)

Pursuant to 10 CFR 50.55a(g)(4)(iv), CEG requests permission to use IWA-6220 ("Owners Repair/Replacement Certification Record"), IWA-6230 ("Owners Activity Report"), and Mandatory Appendix II ("Owners Record and Report") of the 2019 Edition of the ASME B&PV Code in place of similar post outage reporting requirement in the editions of the ASME B&PV Code contained in Table 1 below. These requirements pertain to the preparation and submittal of the OAR-1 report (2019 and 2017 Edition) and the NIS-1 report (2013 and 2007 Edition/2008 Addenda). In summary, the 2019 Edition of the ASME B&PV Code incorporates the alternate repair/replacement activity documentation and Inservice Inspection summary report preparation and submission requirements of Code Case N-532-5 (2013 and 2007 Edition/2008 Addenda) and extends the submittal time of the OAR-1 outage summary report from 90 days to 120 days (2017 Edition, 2013 Edition, 2007 Edition/2008 Addenda). 10 CFR 50.55a(a)(1)(ii) incorporates by reference the 2019 Edition of ASME Section XI, Division 1 of the ASME B&PV Code as approved in Reference 2.

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 3 Table 1 Code of Record Impacted Code Sections 2017 Edition

• IWA-6220, "Owners Repair/Replacement Certification Record"

• IWA-6230, "Owners Activity Report"

• Mandatory Appendix II, "Owners Record and Report" 2013 Edition

• IWA-6220, "Preparation of Abstract of Examination Required by Form NIS-1"

• IWA-6230, "Summary Report Preparation"

• IWA-6240, "Summary Reports"

• Mandatory Appendix II, "Owners Report for Inservice Inspections" 2007 Edition, through

• IWA-6220, "Preparation of Abstract of Examination 2008 Addenda Required by Form NIS-1"

• IWA-6230, "Summary Report Preparation"

• IWA-6240, "Summary Report Submittal"

• Mandatory Appendix II, "Owners Report for Inservice Inspections"

5. Related Requirements 10 CFR 50.55a(g)(4)(iv) 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."

Section IWA-6220, IWA-6230, and Mandatory Appendix II of the 2019 Edition of ASME Section XI include all related requirements in this request.

6. Duration of Proposed Request The duration of this request will continue for each sites Inservice Inspection interval as provided in Section 3.

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 4

7. References

1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl," dated July 28, 2004.

2. Federal Register, 87 FR 65128, dated October 27, 2022

8. Precedents

None