ML25093A098
| ML25093A098 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/09/2025 |
| From: | Ilka Berrios Division of Operating Reactor Licensing |
| To: | Rhoades D Constellation Energy Generation, Constellation Nuclear |
| Wall, S | |
| References | |
| EPID L 2024 LLR 0064 | |
| Download: ML25093A098 (1) | |
Text
April 9, 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 - ISSUANCE OF RELIEF REQUEST I5R-04 REGARDING NON-DESTRUCTIVE EXAMINATION REQUIREMENTS (EPID L-2024-LLR-0064)
Dear David Rhoades:
By \
letter dated September 13, 2024 (Agencywide Documents Access and Management System Accession No. ML24257A063), Constellation Energy Generation, LLC (CEG, the licensee) submitted a request in accordance with paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to the requirements of 10 CFR 50.55a(g)(4)(ii), Applicable ISI Code: Successive code of record intervals, at Byron Station, Units 1 and 2 (Byron). Specifically, CEG requested approval to use the provisions in the 2013 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for non-destructive examination activities associated with inservice inspection (ISI) examinations at Byron. The regulation in 10 CFR 50.55a(z)(1) requires the licensee to demonstrate that the proposed alternatives provide an acceptable level of quality and safety.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(1). Therefore, the NRC staff authorizes the proposed alternative in I5R 04 for the first inspection period of the fifth ISI interval at Byron.
All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including a third-party review by the Authorized Nuclear lnservice 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, Ilka Berrios, Acting Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, and STN 50-455
Enclosure:
Safety Evaluation cc: Listserv ILKA BERRIOS Digitally signed by ILKA BERRIOS Date: 2025.04.09 13:10:59 -04'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST I5R-04 REGARDING NON-DESTRUCTIVE EXAMINATION REQUIREMENTS CONSTELLATION ENERGY GENERATION, LLC BYRON STATION, UNIT NOS. 1 AND 2 DOCKET NOS. STN 50-454 AND STN 50-455 1.0 INTRODUCTION By \
letter dated September 13, 2024 (Agencywide Documents Access and Management System Accession No. ML24257A063), Constellation Energy Generation, LLC (CEG, the licensee) submitted a request in accordance with paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to the requirements of 10 CFR 50.55a(g)(4)(ii), Applicable ISI Code: Successive code of record intervals, at Byron Station, Units 1 and 2 (Byron).
Specifically, CEG requested approval to use the provisions in the 2013 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, in lieu of the 2019 Edition of the ASME Code for non-destructive examination (NDE) activities associated with inservice inspection (ISI) examinations at Byron. Alternative I5R-04 will be for the NDE activities related to performing inservice inspections during the first period of the fifth ISI interval of the Byron ISI program.
2.0 REGULATORY EVALUATION
The regulations in 10 CFR 50.55a(g)(4) state, in part, that inservice examination of components and system pressure tests conducted during successive code of record intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section no more than 18 months before the start of the code of record interval.
The regulations in 10 CFR 50.55a(z) state, in part, that alternatives to the requirements in paragraphs (b) through (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (1) the proposed alternative provides an acceptable level of quality and safety, or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Based on the above, and subject to the following technical evaluation, the NRC staff finds that regulatory authority exists for the licensee to request and the NRC to authorize the alternative requested by the licensee.
3.0 TECHNICAL EVALUATION
The information provided by the licensee in support of the request for an alternative to ASME Code requirements, as incorporated by reference in 10 CFR 50.55a, has been evaluated and the bases for NRC staffs conclusion are documented below.
3.1 Licensees Alternative Request I5R-01 3.1.1 ASME Code Components Affected All Code Class 1, 2, 3, and MC components located within the ASME Code,Section XI, boundaries may be affected by the proposed change.
3.1.2 Applicable Code Editions and Addenda For the fifth ISI interval, the Byron ISI program will be based on ASME Code,Section XI, 2019 Edition.
3.1.3 Applicable Code Requirements In accordance with 10 CFR 50.55a(g)(4)(ii), for the fifth ISI interval, the licensee is required to update the Byron ISI program to the latest edition and addenda of the ASME Code,Section XI, as approved by the NRC in 10 CFR 50.55a(a). In accordance with 10 CFR 50.55a(a)(1)(ii)(C)(56), as of 18 months prior to the Byron fifth ISI interval start date, the 2019 Edition of ASME Code,Section XI, is the latest version approved in 10 CFR 50.55a(a).
3.1.4 Proposed Alternative and Basis for Use In lieu of the requirements specified in the 2019 Edition of the ASME Code, the licensee proposes to continue to use the provisions in the 2013 Edition of ASME Code,Section XI, for NDE activities associated with ISIs during the first period of the fifth ISI interval. These NDE activities are driven from ASME Code,Section XI, Subarticles IWA-2100, IWA-2200, and IWA-2300. The licensee would comply with all applicable conditions and limitations specified in 10 CFR 50.55a(b)(2) related to the NDE requirements of the ASME Code,Section XI, 2013 Edition.
This request does not apply to the balance of the ISI program including the selection, planning, and scheduling, of ISI examinations and tests as defined in IWB-, IWC-, IWD-, IWE-, and IWF-2500 or approved ISI alternatives. Therefore, ISI examinations and tests will be selected, planned, and scheduled, in accordance with the fifth interval code of record, which will be the 2019 Edition of ASME Code,Section XI.
For additional details on the licensees request, please refer to the documents located at the ADAMS Accession No. identified above.
3.1.5 Duration of Proposed Alternative The licensee requested the alternative to be approved for the first inspection period of the fifth ISI interval of the Byron ISI program.
3.2 Staff Evaluation The licensee's proposed alternative would allow Byron to continue to utilize the 2013 Edition of ASME Code,Section XI, for the first inspection period of the fifth ISI interval of the Byron ISI program, rather than the 2019 Edition. The fifth ISI interval of the Byron ISI program is currently scheduled to begin on July 16, 2025.
The CEG fleet of plants currently uses a common Code Edition for NDE requirements. The standardized NDE requirements and procedures are currently based on the 2013 Edition of ASME Code,Section XI. While the overall ISI program requirements are managed in site-specific documents under plant-specific code editions, the NDE program is controlled in common corporate procedures that are implemented across the entire CEG fleet.
The 2013 Edition of ASME Code,Section XI, is conditionally approved for use in 10 CFR 50.55a(a)(1)(ii)(C)(53). The NRC staff did not find it necessary to mandate that plants implement any of the changes incorporated into the 2019 Edition of ASME Code,Section XI, when the 2019 edition was incorporated by reference into 50.55a(a)(1)(ii). Therefore, the staff concludes that an ISI program following the requirements of the 2013 Edition of ASME Code,Section XI, subject to the limitations and modifications of 10 CFR 50.55a(b) will provide an acceptable level of quality and safety.
This use of a common inspection program would allow the licensee to leverage the knowledge from all units to ISI activities such as selection, planning, scheduling, performance, and assessments, and thereby, provide the licensee with a wealth of experience to draw on. The advantages also include the reduction of administrative burden of maintaining different sets of procedures and requirements and would result in a significant decrease in the likelihood of applying the wrong requirements.
Extending the use of the 2013 Edition of the ASME Code, as conditioned in 10 CFR 50.55a for the first inspection period would have a negligible effect on safety at Byron. Standardizing the NDE programs across the CEG fleet will help prevent compliance errors and optimize the use of internal operating experience.
In summary, based on the above discussion, the NRC staff concludes that the licensee's proposed alternative will provide an acceptable level of quality and safety.
4.0 CONCLUSION
As set forth above, the NRC staff finds that the proposed alternative provides an acceptable level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(z)(1).
Therefore, the NRC staff authorizes the use of I5R-04, Revision 0, for the first inspection period of the fifth ISI interval at Byron, which is currently scheduled to begin on July 16, 2025.
All other requirements of the ASME Code,Section XI for which relief has not been specifically requested, remain applicable, including a third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Karen Sida, NRR Stephen Cumblidge, NRR Date: April 9, 2025
SUBJECT:
BYRON STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF RELIEF REQUEST I5R-04 REGARDING NON-DESTRUCTIVE EXAMINATION REQUIREMENTS (EPID L-2024-LLR-0064) DATED APRIL 9, 2025 DISTRIBUTION:
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NAME SWall SRohrer MMItchell DATE 04/03/2025 04/03/2025 03/31/2025 OFFICE NRR/DORL/LPL3/BC (A)
NRR/DORL/LPL3/PM NAME IBerrios SWall DATE 04/09/2025 04/09/2025 OFFICIAL RECORD COPY