ML25258A149
| ML25258A149 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/15/2025 |
| From: | Moore D Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CCEC-25-005 | |
| Download: ML25258A149 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.55a CCEC-25-005 September 15, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Christopher M. Crane Clean Energy Center Renewed Facility License No. DPR-50 NRC Docket No. 50-289
Subject:
Response to Request for Additional Information by the Office of Nuclear Reactor Regulation to support Review of Request to Use Subsequent Edition of the ASME BPV Code,Section XI
References:
1.
Letter from Dennis Moore (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI dated March 31, 2025 (ML25090A036) 2.
E-Mail from Brent Ballard (U.S. Nuclear Regulatory Commission) to Christian Willams and Dennis Moore (Constellation Energy Generation, LLC) Crane Clean Energy Center - Final RAI for Request to Use Subsequent Edition of the ASME BPV Code dated August 15, 2025 (ML25227A244)
By letter dated March 31, 2025, (Reference 1) Constellation Energy Generation, LLC (CEG) requested NRC approval to use a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, for the inservice inspection (ISI) program in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv) for the planned restart of the Christopher M.
Crane Clean Energy Center (CCEC) following permanent cessation of power operations. Specifically, CEG requested to update the CCEC ISI program for the 4th interval to the 2013 Edition of the ASME BPV Code,Section XI for performing Non-Destructive Examination (NDE) and Repair and Replacement (R&R) for ASME BPV Section XI related activities.
Conste lation
U.S. Nuclear Regulatory Commission Page 2 RAI Response - Request to use Subsequent Edition of ASME BPV Code,Section XI Docket No. 50-289 September 15, 2025 By E-Mail dated August 15, 2025, (Reference 2) the NRC identified areas where additional information was necessary to complete the review.
The attachment to this letter contains the NRC's request for additional information immediately followed by CEG's response.
There are no new or revised regulatory commitments contained in this letter.
If you have any questions, please contact Mr. Christian Williams, at 732-281-9104.
Respectfully, Dennis M. Moore Senior Manager Licensing Constellation Energy Generation, LLC
Attachment:
Response to Request for Additional Information cc:
w/ Attachment NRC Regional Administrator, Region I NRC Director, NRR - DORL NRC Deputy Director, NRR - DORL NRC Project Manager, NRR - DORL - Christopher M. Crane Clean Energy Center NRC Project Manager, NMSS - Christopher M. Crane Clean Energy Center Director, Bureau of Radiation Protection - PA Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township
- Moore, Dennis M Digitally signed by Moore, Dennis M Date: 2025.09.11 10:43:04 -04'00' Response to Request for Additional Information Page 1 of 3 1
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST TO USE 2013 EDITION OF ASME BPV CODE, SECTION XI FOR NDE AND R&R ACTIVITIES CONSTELLATION ENERGY GENERATION, LLC CHRISTOPHER M. CRANE CLEAN ENERGY CENTER DOCKET NO. 05000289 ISSUE DATE: AUGUST 15, 2025
Background
By letter dated March 31, 2025, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25090A036) Constellation Energy Generation, LLC (CEG, the licensee) requested NRC approval to use a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, for the inservice inspection (ISI) program in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv) for the planned restart of the Christopher M. Crane Clean Energy Center (CCEC) following permanent cessation of power operations. Specifically, the licensee requests to update the CCEC ISI program for the 4th interval to the 2013 Edition of the ASME Code for performing Non-Destructive Examination (NDE) and Repair and Replacement (R&R) for ASME BPV Section XI related activities. The licensees letter also stated:
In the regulatory path letter (Reference 2 [ML24310A104]), CEG stated that it will ensure that all necessary codes and standards, including 10 CFR 50.55a(g) related to ASME In-service Inspection (ISI), are met or appropriate relief is obtained per the defined regulatory process. As such, this request is being submitted for NRC approval in accordance with 10 CFR 50.55a(g)(4)(iv).
The NRC staff requests the following information to complete its review in accordance with 10 CFR 50.55a(g)(4)(iv).
Regulatory Basis The regulations at 10 CFR 50.55a(g)(4)(iv), Applicable ISI Code: Use of subsequent Code editions and addenda," 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. NRC approval is not required when updating the ISI code of record before the start of an ISI interval in which the updated ISI code of record will be used and when using the latest edition incorporated by reference in (a)(1)(iv) of this section in its entirety, subject to the conditions listed in paragraph (b) of this section (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147 or NRC Regulatory Guide 1.192 as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section, respectively).
Response to Request for Additional Information Page 2 of 3 2
Question 1 a.
The request states that the duration is for the remainder of the 4th ISI interval. Provide the duration of the proposed extended 4th interval (start and end time) that would be requested for approval (e.g., from April 2011 up to fuel load, restart, etc.).
CEG Response: The Crane 4th ISI Interval began on April 20, 2011 (ML111040231). As allowed by IWA-2430(e) for plants out of service continuously for 6 months or more, CEG is extending the end of the Crane 4th ISI Interval. The 4th ISI Interval will conclude after the completion of all remaining 4th ISI Interval examinations and tests, which is anticipated to occur coincident with the resumption of power operations.
- b. Provide the time period for when the 5th ISI interval will begin, which this request would no longer be in effect.
CEG Response: CEG is extending the Crane 4th ISI Interval duration as detailed in response to Question 1(a) and is accordingly extending the pattern of future intervals as allowed by IWA-2430(e). The 5th ISI Interval will begin after the completion of all remaining 4th ISI Interval examinations and tests, which is anticipated to occur coincident with the resumption of power operations.
- c. The NRC staff notes that the 4th ISI interval was scheduled to end in 2022, and there is no documentation on whether the ISI Program and Plan exists or has been maintained in accordance with 10 CFR 50.55a during the decommissioning period that began in 2019.
- i.
Therefore, based on the above, provide what ISI Program will be used for this request, and whether the ISI Program records are still applicable and meet ASME Code requirements, and whether it is available for inspection.
CEG Response: CEG plans to use the Crane 4th ISI Interval Program Plan, TMI04.G03, as revised to meet NRC regulations and ASME Code requirements, for the remainder of the 4th ISI Interval. Cranes ISI Program documents and records have been retained, in accordance with CEG records retention policies and procedures, and are available for inspection.
ii.
In addition, provide the period of the 4th interval in accordance with Section XI of the ASME Code that this request applies to (e.g., all inspections from the 3rd period of the 4th interval).
CEG Response: This request applies to the remainder of the 3rd ISI Period of the 4th ISI Interval.
iii.
Also, specify if there is still a Repair/Replacement Program and Plan established that meets the requirements of IWA-4140 and IWA-4150 of Section XI of the ASME Code that will be used for this request, and whether it is available for inspection.
Response to Request for Additional Information Page 3 of 3 3
CEG Response: CEG has a common Repair/Replacement Program procedure implemented across the fleet to satisfy the requirements of IWA-4000, including IWA-4140 and IWA-4150. This common Repair/Replacement Program procedure is applicable to Crane, and it is available for inspection.
- d. Confirm that NDE and Repair/replacement activities to be performed during the remaining 4th ISI interval will use the following Editions of Section XI of the ASME Code, per Table 1 of the request, for these applicable paragraphs:
- i.
IWB-2420 (Successive Inspections), IWB-2430 (Additional Examinations) to the 2004 Edition; and IWB-3123 (Repair/Replacement Activity and Reexamination),
IWB-3132 (Acceptance), IWB-3142 (Acceptance) to the 2013 Edition, ii.
IWC-2420 (Successive Inspections), IWC-2430 (Additional Examinations), IWC-3122 (Acceptance), IWC-3124 (Repair/Replacement Activity and Reexamination), IWC-3130 (Inservice Visual Examinations), IWC-3200 (Supplemental Examinations) to the 2004 Edition, iii.
IWD-2420 (Successive Inspections), IWD-2430 (Additional Examinations), IWD-3120 (Inservice Examinations), IWD-3200 (Supplemental Examinations) to the 2004 Edition, iv.
IWE-2420 (Successive Inspections), IWE-3122 (Acceptance), IWE-3500 (Acceptance Standards) to the 2004 Edition,
- v.
IWF-2420 (Successive Inspections), IWF-2430 (Additional Examinations), IWF-3112 (Acceptance), IWF-3200 (Supplemental Examinations) to the 2004 Edition.
CEG Response: CEG has reviewed the specified paragraphs and confirms that this is correct.