ML23114A252
| ML23114A252 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 04/28/2023 |
| From: | V Sreenivas Plant Licensing Branch III |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Wall, SP | |
| References | |
| EPID L-2022-LLR-0083 | |
| Download: ML23114A252 (1) | |
Text
April 28, 2023 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation 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-2022-LLR-0083)
Dear Mr. Rhoades:
By letter dated November 30, 2022 (Agencywide Documents Access and Management System Accession No. ML22334A136), Constellation Energy Generation, LLC (CEG, 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(a)(1)(ii), CEG proposed to use the post outage reporting requirements in paragraphs 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 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 CEG has adequately addressed the requirements in 10 CFR 50.55a(a)(1)(ii). Therefore, the NRC staff approves the use of paragraphs IWA-6220, IWA-6230, and Mandatory Appendix II of the 2019 Edition of the
D. Rhoades 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.
All other ASME BPV Code, section XI, requirements for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Senior Project Manager, Scott Wall, at 301-415-2855 or e-mail at Scott.Wall@nrc.gov.
Sincerely, V. Sreenivas, Acting 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 Digitally signed by Venkataiah Sreenivas Date: 2023.04.28 15:49:05 -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 CONSTELLATION ENERGY GENERATION, 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 letter dated November 30, 2022 (Agencywide Documents Access and Management System Accession No. ML22334A136), Constellation Energy Generation, LLC (CEG, 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(a)(1)(ii), CEG proposed to use the post outage reporting requirements in paragraphs 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 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 [U.S.
Nuclear Regulatory Commission (NRC or Commission)] approval. Portions of editions or addenda may be used, provided that all related requirements of the respective editions or addenda are met.
Paragraph 50.55a(b)(2)(xxxii) of 10 CFR states:
Section XI condition: Summary report submittal. When using ASME BPV Code,Section XI, 2010 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, Summary Reports and Owners Activity Reports described in IWA-6230 must be submitted to the NRC Preservice inspection reports for examinations prior to commercial service must be submitted prior to the date of placement of the unit into commercial service.
For preservice and inservice examinations performed following placement of the unit into commercial service, reports must be submitted within 120 calendar days of the completion of each refueling outage.
Regulatory Issue Summary 2004-12, Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section Xl (ML042090436), reinforces that licensees must request approval to use later Code editions and addenda via a letter to the NRC. Licensees may not simply update their inservice testing (IST) or inservice inspection (ISI) programs Code of Record without requesting approval from the Commission.
3.0 TECHNICAL EVALUATION
3.1 Licensees Request 3.1.1 Components for Which the Subsequent Code Edition is Requested All Class 1, 2, and 3, metal containment (MC), and concrete containment (CC) items.
3.1.2 Current Code Edition and Addenda of Record The application 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 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 6th 2017 Edition 1/20/2023 1/19/2033 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 6th 2017 Edition 4/2/2023 4/1/2033 Ginna 6th 2013 Edition 1/1/2020 12/31/2029 3.1.3 Proposed Subsequent Code Edition Pursuant to 10 CFR 50.55a(g)(4)(iv), CEG proposed to use the post-outage reporting requirements in paragraphs 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 BPV Code, section XI, at each of the facilities named in Table 1. These requirements would apply in place of the provisions of the ASME Code editions identified in Table 1.
The 2019 edition of the ASME BPV Code contains alternate requirements for documenting repair/replacement activities and for preparing and submitting ISI summary reports. The NIS-1 report (included in the 2013 and 2007 Edition/2008 Addenda) is discontinued. The NIS-2 report is simplified, and Owners Activity Report (OAR-1) form is added, as described in Mandatory Appendix II.
3.1.4 Duration of the Use of the Later Code Edition The duration of this request is for the remainder of the current 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 NRC staff considered the following criteria in its review of CEGs 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.
CEG requested to use specific provisions in the 2019 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.
Paragraph 50.55a(b)(2)(xxxii) of 10 CFR states, in part: Summary Reports and Owners Activity Reports described in IWA-6230 must be submitted to the NRC... For preservice and inservice examinations performed following placement of the unit into commercial service, reports must be submitted within 120 calendar days of the completion of each refueling outage. The NRC staff determined that this condition on paragraph IWA-6230 of the 2019 Edition of the ASME BPV Code,Section XI, listed in 10 CFR 50.55a(b), is consistent with the licensee proposal.
Therefore, the second criterion above has been satisfied.
The NRC staff determined that CEGs request dated November 30, 2022, 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-6000 and Mandatory Appendix II of the 2019 Edition of the ASME BPV Code,Section XI, in comparison with the prior Editions cited in the request to determine whether other relevant provisions would affect the proposed use of paragraphs IWA-6220, IWA-6230, and Mandatory Appendix II at CEGs facilities. The 2019 Edition of the ASME BPV Code incorporates the alternate repair/replacement activity documentation and ISI 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). The NRC staff determined that no other related changes were added to Section XI, Article IWA-6000, with the 2019 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(a)(1)(ii). Therefore, the NRC staff concludes that the use of paragraph paragraphs IWA-6220, IWA-6230, and Mandatory Appendix II of the 2019 Edition of the ASME BPV Code,Section XI, is acceptable. The NRC staff approves the use of paragraphs IWA-6220, IWA-6230, and Mandatory Appendix II of the 2019 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 requirements of the ASME BPV Code,Section XI, as incorporated by reference in 10 CFR 50.55a, for which relief was not specifically requested and approved remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Carol Moyer, NRR/DNRL/NVIB Michael Benson, NRR/DNRL/NVIB Date: April 28, 2023
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-2022-LLR-0083) DATED APRIL 28, 2023 DISTRIBUTION:
PUBLIC RidsNrrDorlLpl1 Resource RidsNrrDorlLpl3 Resource RidsRgn1MailCenter Resource RidsRgn3MailCenter Resource RidsNrrLASLent Resource RidsNrrLASRohrer Resource RidsNrrLAKZeleznock Resource RidsNrrLAKEntz Resource RidsAcrs_MailCTR Resource RidsNrrPMExelon Resource RidsNrrPMBraidwood Resource RidsNrrPMByron Resource RidsNrrPMCalvertCliffs Resource RidsNrrPMClinton Resource RidsNrrPMDresden Resource RidsNrrPMFitzPatrick Resource RidsNrrPMLaSalle Resource RidsNrrPMLimerick Resource RidsNrrPMNineMilePoint Resource RidsNrrPMPeachBottom Resource RidsNrrPMQuadCities Resource RidsNrrPMREGinna Resource RidsNrrDnrlNphp Resource RidsNrrDnrlNvib Resource CMoyer, NRR MBeason, NRR Accession No.: ML23114A252
- via memo OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DNRL/NVIB/BC NAME SWall SRohrer ABuford DATE 04/24/2023 04/27/2023 04/20/2023 OFFICE NRR/DORL/LPL3/BC(A)
NRR/DORL/LPL3/PM NAME VSreenivas SWall DATE 04/27/2023 04/28/2023 OFFICIAL RECORD COPY