ML25057A353
| ML25057A353 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/28/2025 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Rhoades D Constellation Energy Generation |
| Wiebe J | |
| References | |
| EPID L-2024-LLR- 0073 | |
| Download: ML25057A353 (1) | |
Text
February 28, 2025 David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BYRON STATION, UNIT NOS. 1 AND 2 - CORRECTION TO SAFETY EVALUATION ISSUED FOR REQUEST TO USE PROVISIONS FROM A LATER EDITION OF ASME CODE, SECTION XI (EPID-L-2024-LLR- 0073)
Dear David Rhoades:
By letter dated February 4, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25034A065), the U.S. Nuclear Regulatory Commission (NRC) issued authorized Constellation Energy Generation, LLC (CEG, the licensee), to use certain provisions from a later edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), section XI, during the fifth Inservice Inspection (ISI) interval of the Byron Station (Byron), Unit Nos. 1 and 2, which is scheduled to commence on July 16, 2025.
The NRC inadvertently referred to the interval as the fifth 10-year ISI interval [emphasis added]. However, in the November 7, 2024, application (ML24312A381), the CEG only referred to the interval as the the fifth ISI interval. As such, referring to the interval as the fifth 10-year ISI interval was not aligned with the licensees request. Additionally, Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(ii), which approves NRC Regulatory Guide (RG) 1.147, Revision 21, Inservice Inspection Code Case Acceptability, ASME [American Society of Mechanical Engineers] Section XI, Division 1, issued March 2024 to be incorporated by reference into the regulation. RG 1.147, Revision 21, conditionally approved Code Case N-921. Code Case N-921 establishes a 12-year interval for ISI programs and can be implemented at the beginning of an ISI interval as part of a routine update of the ISI program.
The NRC staff agrees that the interval should appropriately be referred to as the fifth ISI interval. The NRC staff has determined that these were inadvertent typographical errors and are entirely editorial in nature.
Based on the information provided in the November 7, 2024, application, the NRC had concluded that use of the specified portions of subsequent editions and addenda of the ASME Code, section XI, is acceptable. The correction of referring to the interval as the fifth ISI interval does not affect the conclusion on the NRC staffs safety evaluation dated February 4, 2025. Accordingly, the NRC staffs conclusion that the licensee had adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv) remains valid and remains approved for the duration of the fifth ISI interval of Byron, Unit Nos.1 and 2, which
is scheduled to commence on July 16, 2025. The staffs revised safety evaluation pages are contained in the enclosure to this letter.
If you have any questions concerning this action, please contact me at (301) 415-2855 or by email to Scott.Wall@nrc.gov.
Sincerely,
/RA/
Scott P. Wall, Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-454 and STN 50-455
Enclosure:
Corrected Safety Evaluation cc: Listserv
Enclosure CONSTELLATION ENERGY GENERATION, LLC BYRON STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-454 AND 50-455 CORRECTED SAFETY EVALUATIN
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE PROVISIONS FROM A LATER EDITION OF ASME CODE, SECTION XI CONSTELLATION ENERGY GENERATION, LLC BYRON STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-454 AND 50-455 EPID: L-2024-LLR-0073
1.0 INTRODUCTION
By letter dated November 7, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24312A381), Constellation Energy Generation, LLC (the licensee) requested to use certain provisions from a later edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), section XI, during the fifth inservice inspection (ISI) interval of the Byron Station (Byron), Unit Nos. 1 and 2, which is scheduled to commence on July 16, 2025.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
the licensee requested to use the 2021 Edition of ASME Code, section XI, IWA-5244 subject to conditions in 50.55a(b) for pressure testing of the buried pressure-retaining components.
2.0 REGULATORY EVALUATION
Pursuant to 10 CFR 50.55a(a)(1)(ii), the ASME Code, section XI, from the 1974 Edition through the 2021 Edition have been approved for incorporation by reference, but limited to those provisions identified in paragraph (b)(2) of Section 50.55a.
Pursuant to 10 CFR 50.55a(g)(4)(iv), 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 section 50.55a, subject to the conditions listed in paragraph (b) of section 50.55a, and subject to the U.S. Nuclear Regulatory Commission (NRC or Commission) 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 Component Affected All buried ASME Code Class 2 and 3 pressure-retaining components are affected.
3.2
Applicable Code Edition and Addenda
The code of record for the fifth ISI interval of Byron, Unit Nos. 1 and 2, is the 2019 Edition of the ASME Code, section XI.
3.3 Duration of Request The request is for the duration of the fifth ISI interval of Byron, Unit Nos. 1 and 2, which is scheduled to commence on July 16, 2025.
3.4 Request and Basis for Request The licensee requested to use: IWA-5244; IWA-6340(k); table IWC-2500-1, Examination Category C-H, Item No. C7.20; IWC-3516.2; Table IWD-2500-1, Examination Category D-B, Item No. D2.20; and IWD-3511.2 of the 2021 Edition of the ASME Code, section XI.
The licensee stated that the requested paragraphs and all related subparagraphs from the 2021 Edition of the ASME Code, section XI, provide greater flexibility and clarity. Specifically, paragraph IWA-5244 of the 2021 Edition of the ASME Code, section XI, 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.
3.5
NRC Staff Evaluation
The NRC staff has evaluated this request pursuant to 10 CFR 50.55a(g)(4)(iv). The NRC staffs evaluation focuses on whether: (1) the subsequent editions and addenda of the ASME Code as requested for use is incorporated by reference in paragraph (a) of section 50.55a, (2) the Code requirements subject to the conditions listed in paragraph (b) of section 50.55a are met, (3) a request is submitted for the NRC approval, and (4) all related requirements of the respective editions and addenda are met. The NRC staff finds that if these four criteria are met, the requirements of 10 CFR 50.55a(g)(4)(iv) will also be met.
In evaluating the licensees request, the NRC staff confirms that,
- 1. The 2021 Edition of ASME Code, section XI, as requested for use, is incorporated by reference in 10 CFR 50.55a, and subject to conditions in paragraph (b)(2) of section 50.55a.
- 2. There are no applicable provisions in 10 CFR 50.55a.
- 3. This submittal serves as the licensees request for NRC approval to use portions of the 2021 Edition of ASME Code, section XI, for the pressure testing of buried pressure-retaining components.
- 4. The licensee has acknowledged that all related requirements of the respective editions and addenda will be complied.
Based on the above, the NRC staff determines that each of the four regulatory requirements for use of certain portions of later editions and addenda of the Code have been met, and that use of: IWA-5244; IWA-6340(k); table IWC-2500-1, Examination Category C-H, Item No. C7.20; IWC-3516.2; table IWD-2500-1, Examination Category D-B, Item No. D2.20; and IWD-3511.2 of the 2021 Edition of the ASME Code, section XI, for duration of the fifth ISI interval are acceptable.
4.0 CONCLUSION
As set forth above, the NRC staff determines that use of the specified portions of subsequent editions and addenda of the ASME Code, section XI, is acceptable. Accordingly, the NRC staff concludes 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 approves this request for the duration of the fifth ISI interval of Byron, Unit Nos. 1 and 2, which is scheduled to commence on July 16, 2025.
All other ASME Code, section XI requirements for which relief was not specifically requested and authorized herein by the NRC staff remain applicable, including the third party review by the Authorized Nuclear In service Inspector.
Principal Contributor: Ali Rezai, NRR Date: February 4, 2025
ML25057A353 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DNRL/NPHP/BC NAME SWall SRohrer MMitchell DATE 02/26/2025 02/26/2025 02/26/2025 OFFICE NRR/DORL/LPL3/BC (A)
NRR/DORL/LPL3/PM NAME IBerrios SWall DATE 02/27/2025 02/28/2025