RS-24-122, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI
| ML24312A381 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 11/07/2024 |
| From: | Steinman R Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-24-122 | |
| Download: ML24312A381 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-24-122 10 CFR 50.55a November 7, 2024 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 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
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 XI, dated July 28, 2004 (ML042090436)
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 specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Byron Station, Units 1 and 2 (Byron). Specifically, CEG requests approval to use IWA-5244, (Buried Components); IWA-6340(k), (Inservice Inspection Records); Table IWC-2500-1 (C-H), Item Number C7.20 (Buried Components); IWC-3516.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components); Table IWD-2500-1 (D-B), Item Number D2.20 (Buried Components); and IWD-3511.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components) of the 2021 Edition of the ASME B&PV Code,Section XI.
CEG requests approval of this request by July 15, 2025, to support implementation of the Byron Station Fifth ISI Interval.
November 7, 2024 U. S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained within this letter.
Should you have any questions concerning this letter, please contact Ms. Lisa M. Zurawski at (779) 231-6196.
Respectfully, Rebecca L. Steinman Sr. Manager - Licensing Constellation Energy Generation, LLC
Attachment:
Request to Use Portions of a Later Edition of the ASME B&PV Code,Section XI cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector - Byron Station
- Steinman, Rebecca Lee Digitally signed by Steinman, Rebecca Lee Date: 2024.11.07 15:22:36
-06'00'
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, for Byron Station, Units 1 and 2. Specifically, CEG requests approval to use IWA-5244, (Buried Components);
IWA-6340(k), (Inservice Inspection Records); Table IWC-2500-1 (C-H), Item Number C7.20 (Buried Components); IWC-3516.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components); Table IWD-2500-1 (D-B), Item Number D2.20 (Buried Components); and IWD-3511.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components) of the 2021 Edition of the ASME B&PV Code,Section XI.
- 1. Component(s) Affected All buried ASME Section XI Class 2 and Class 3 components.
- 2. Requested Date for Approval CEG requests approval of this request by July 15, 2025, to support implementation of the Byron Station Fifth ISI Interval.
3. Applicable Code Edition and Addenda
PLANT INTERVAL EDITION START Byron Station, Units 1 and 2 Fifth 2019 Edition July 16, 2025
- 4. Proposed Subsequent Code Edition and Addenda (or Portion)
Pursuant to 10 CFR 50.55a(g)(4)(iv), CEG requests permission to use IWA-5244, (Buried Components); IWA-6340(k), (Inservice Inspection Records); Table IWC-2500-1 (C-H),
Item Number C7.20 (Buried Components); IWC-3516.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components); Table IWD-2500-1 (D-B), Item Number D2.20 (Buried Components); and IWD-3511.2, (Examinations and Tests Conducted in Accordance with IWA-5244 for Buried Components) of the 2021 Edition of the ASME B&PV Code,Section XI, in lieu of the requirements of IWA-5244 for Buried Components in the 2019 Edition of the ASME B&PV Code. In summary, this paragraph and related subparagraphs provide greater flexibility with alternatives allowed for meeting the pressure testing requirements for buried components. Specifically, IWA-5244 of the 2021 Edition allows for performance of an unimpaired flow test as an alternative to the pressure decay test, inventory reduction test, and ground surface visual examination if certain conditions are met. Additionally, the related subparagraphs in the 2021 Edition provide clearer guidance on the acceptance standards associated with these tests.
Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)
Page 2
- 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.
10 CFR 50.55a(a)(1)(ii)(C)(57) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2021 Edition as approved in Reference 2. CEG is requesting the use of IWA-5244 of the 2021 Edition of ASME Section XI to utilize the requirements for pressure testing buried components in addition to all the related requirements which are contained within subparagraphs IWA-6340(k), IWC-3516.2, and IWD-3511.2, Table IWC-2500-1 (C-H),
Item Number C7.20 and associated notes, and Table IWD-2500-1 (D-B), Item Number D2.20 and associated notes.
- 6. Duration of Proposed Request The duration of this request will continue for the duration of Byron Stations Fifth Inservice Inspection Interval.
- 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, 89 FR 70449, dated August 30, 2024.
- 3. ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2019 Edition.
- 4. ASME Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2021 Edition.
8. Precedents
None