ML25289A276
| ML25289A276 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/22/2025 |
| From: | Ballard B NRC/NRR/DORL/LPL3 |
| To: | Mudrick C Constellation Energy Generation, Constellation Nuclear |
| Poole J, NRR/DORL/LPL3, 301-415-2048 | |
| References | |
| EPID L-2025-LLR-0040 | |
| Download: ML25289A276 (1) | |
Text
October 22, 2025 Mr. Christopher Mudrick Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CHRISTOPHER M. CRANE CLEAN ENERGY CENTER - USE OF PROVISIONS OF LATER EDITION OF THE ASME CODE FOR PERFORMING NON-DESTRUCTIVE EXAMINATIONS AND REPAIR/REPLACEMENT ACTIVITIES (EPID L-2025-LLR-0040)
Dear Mr. Mudrick:
By letter dated March 31, 2025, as supplemented by letter dated September 15, 2025, Constellation Energy Generation, LLC (CEG, the licensee), submitted a request to the U.S.
Nuclear Regulatory Commission (NRC) for the use of specific provisions of a later edition of the American Society of Mechanical Engineers(ASME) Boiler and Pressure Vessel Code (BPV Code),Section XI for the Christopher M. Crane Clean Energy Center (CCEC), formerly Three Mile Island Nuclear Station, Unit 1.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
the licensee requested to use the 2013 Edition of ASME Code,Section XI for the performance of inservice inspection (ISI) non-destructive examinations (NDE) and the performance of repair/replacement activities for ASME Code Class 1, 2, 3, MC and CC components, with some exceptions, subject to the conditions specified in 10 CFR 50.55a(b). The licensee noted that this alternative does not apply to the selection, planning, or scheduling of ISI examinations and tests as defined in IWB-, IWC-, IWD-, IWE-, IWF-, and IWL-2500 or NRC approved alternatives.
Therefore, ISI examinations and tests will be selected, planned, and scheduled in accordance with the present Code of Record, the 2004 Edition of ASME Code,Section XI.
The NRC staff has reviewed the subject request and concludes, as set forth in the enclosed safety evaluation, that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff approves the use of the provision in the 2013 Edition of the ASME Code,Section XI as outlined in Table 1 (inclusive of all notes) of the licensees submittal the remainder of the fourth 10-year ISI interval for CCEC, which would end when the remaining fourth 10-year ISI Interval examinations and tests are completed, which is anticipated to occur coincident with the resumption of power operations.
This approval is for the use of specific provisions of a later edition of Section XI of the ASME Code. The licensee did not request, nor does this approval authorize, any physical changes to the facility. The licensee has previously publicly communicated its plans to request approval
from the NRC to restart the facility. This approval does not authorize restart of the facility, nor approve the ISI program for the CCEC, or extend associated NRC approved alternatives.
All other ASME Code,Section XI requirements which are not modified by the NRC staffs approval of the licensees request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact the Project Manager, Brent Ballard, at Brent.Ballard@nrc.gov.
Sincerely, Ilka Berrios, Acting Chief Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289
Enclosure:
Safety Evaluation cc: ListServ ILKA BERRIOS Digitally signed by ILKA BERRIOS Date: 2025.10.22 10:46:54 -04'00'
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION USE OF PROVISIONS OF LATER CODE EDITION OF THE ASME CODE FOR NON-DESTRUCTIVE EXAMINATIONS AND REPAIR/REPLACEMENT ACTIVITIES CONSTELLATION ENERGY GENERATION, LLC CHRISTOPHER M. CRANE CLEAN ENERGY CENTER DOCKET NO. 50-289
1.0 INTRODUCTION
By letter dated March 31, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25090A036), as supplemented by letter dated September 15, 2025 (ML25258A149), Constellation Energy Generation, LLC (CEG, the licensee), requested U.S.
Nuclear Regulatory Commission (NRC) approval to use specific provisions of a later edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Section XI for the Christopher M. Crane Clean Energy Center (CCEC), formerly Three Mile Island Nuclear Station, Unit 11.
Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4)(iv),
the licensee proposed to use the 2013 Edition of ASME Code,Section XI for the performance of inservice inspection (ISI) non-destructive examinations (NDE) and the performance of repair/replacement activities for ASME Code Class 1, 2, 3, MC and CC components, with some exceptions, subject to the conditions specified in 10 CFR 50.55a(b). The licensee noted that this alternative does not apply to the selection, planning, or scheduling of ISI examinations and tests as defined in IWB-, IWC-, IWD-, IWE-, IWF-, and IWL-2500 or NRC-approved alternatives.
Therefore, ISI examinations and tests will be selected, planned, and scheduled in accordance with the present Code of Record, the 2004 Edition of ASME Code,Section XI.
2.0 REGULATORY EVALUATION
2.1 Regulatory Requirements Paragraph 10 CFR 50.55a(g)(4)(ii) requires, in part, that inservice examination of components and system pressure tests conducted during successive 10-year ISI intervals (i.e., after the initial 10-year interval) must comply with the latest edition and addenda of the ASME Code (or 1 The facility name was Three Mile Island Nuclear Station, Unit 1, when this request was submitted to the NRC. Subsequently, the NRC issued Amendment No. 306 (ML25100A006) to Renewed Facility License No. DPR-50, which changed the facility name to the Christopher M. Crane Clean Energy Center.
the optional ASME Code Cases) incorporated by reference in 10 CFR 50.55a(a) 18 months before the start of the 10-year ISI interval subject to the conditions listed in 10 CFR 50.55a(b).
The licensee is proposing to use a later edition and addenda of the ASME Code,Section XI, in accordance with 10 CFR 50.55a(g)(4)(iv), Applicable ISI Code: Use of subsequent Code editions and addenda, which 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.
2.2 Regulatory Guidance The NRC Regulatory Issue Summary (RIS) 2004-16, Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities, addresses the provisions for use of later editions and addenda of the ASME Code.
3.0 TECHNICAL EVALUATION
3.1 The Licensees Proposed Use of Later Code Editions and Addenda 3.1.1 ASME Code Components Affected The proposed request applies to ASME Code Class 1, 2, 3, MC and CC components, component supports, and welds.
3.1.2 Applicable ASME Code Edition and Addenda The current Code of Record for CCEC is the 2004 Edition of the ASME Code,Section XI which began on April 20, 2011.
3.1.3 Duration of the Use of the Later Code Edition and Addenda The licensee is requesting approval to use a later edition of Section XI of the ASME Code for the remainder of the fourth 10-year ISI interval, which commenced on April 20, 2011, and would end when the remaining fourth 10-year ISI Interval examinations and tests are completed, which is anticipated to occur coincident with the resumption of power operations. The staff notes that the fourth 10-year ISI interval was previously scheduled to end in 2022.
3.1.4 Proposed Code Edition and Basis for Use The performance of the NDE examinations and tests, and the performance of repair/replacement activities under the common CEG Repair/Replacement program are controlled by standardized corporate procedures, which currently are based on the 2013 Edition of the ASME Code,Section XI. Therefore, CEG is requesting to use the following provisions in the 2013 Edition of the ASME Code,Section XI for performing NDE activities associated with ISI examinations and tests and the performance of repair/replacement activities in lieu of the associated provisions in the 2004 Edition of Section XI:
Utilize the 2013 Edition of ASME Code,Section XI as conditioned by 10 CFR 50.55a for performing ISI-related NDE (examinations and tests) and performing repair/replacement activities as identified in Table 1 (inclusive of all notes) to of the licensees letter dated March 31, 2025.
Utilize all portions of Nonmandatory Appendices A through W in the 2013 Edition of ASME Code,Section XI that could be used or referenced for the performance of NDE (examinations and tests) and repair/replacement activities as conditioned by 10 CFR 50.55a. Use of Nonmandatory Appendix R in the 2013 Edition is prohibited unless authorized for site-specific use by the NRC. CEG does not request approval for use of Nonmandatory Appendix R at CCEC. In addition, Nonmandatory Appendices F, I, and V do not exist in the 2004 Edition and 2013 Edition of Section XI and will not be used.
Utilize all portions of Mandatory Appendices of the 2013 Edition that could be used or referenced for the performance of NDE (examinations and tests) and performance of repair/replacement activities as conditioned by 10 CFR 50.55a.
The licensee will continue to utilize the 2004 Edition of the ASME Code,Section XI for the selection, planning, and scheduling of ISI examinations and tests as defined in IWB-, IWC-,
IWD-, IWE-, IWF-, and IWL-2500 or NRC approved ISI alternative. The specifics provisions are identified in Table 1 (inclusive of all notes) to Enclosure 1 of the licensees letter dated March 31, 2025. Note that this letter does not approve nor extend previous NRC-approved alternatives. CEG stated that it will comply with all applicable conditions and limitations specified in 10 CFR 50.55a(b) when using these provisions.
3.2
NRC Staff Evaluation
The licensee requested NRC approval to use the 2013 edition of the ASME Code,Section XI as delineated in Table 1 (inclusive of all notes) of their submittal for the ISI program in accordance with 10 CFR 50.55a(g)(4)(iv) for the planned restart of CCEC following permanent cessation of power operations in 2022. Even though the CCEC ceased operation, the NRC staff notes that there is still an applicable ISI program for CCEC, since the licensees supplemental letter dated September 15, 2025, stated that the licensee would use the CCEC fourth 10-year ISI interval Program Plan, TMI04.G03, for the remainder of the fourth 10-year ISI interval. Since all required documentation and records have been retained in accordance with the CEG records retention policies and are available for inspection, the NRC staff finds that TMI04.G03 is the ISI program to be modified to use the requested subsequent edition of the ASME Code,Section XI. The ISI program will include all of the remaining examinations for the third period of the fourth 10-year ISI interval, since all examinations required by the ASME Code,Section XI for the first and second periods of the fourth 10-year ISI interval have been completed.
For repair/replacement activities, CEG requests NRC approval to use the 2013 Edition of the ASME Code,Section XI as delineated in Table 1 (inclusive of all notes) of their submittal. A common Repair/Replacement Program procedure that is used across the CEG fleet will be used at CCEC, which meets the requirements of IWA-4000 (including IWA-4140 and IWA-4150 for owners responsibilities, quality assurance and completion of repair/replacement activities in accordance with a repair/replacement program and plan) to the 2013 Edition of the ASME Code,Section XI and is available for inspection. Therefore, the NRC staff approval of the request would include:
the licensee to use the 2013 edition of the ASME Code,Section X, as delineated in Table 1 (inclusive of all notes) to Enclosure 1 of their submittal, applicable for the Crane 4th ISI interval Program Plan, TMI04.G03, the licensees performance of repair/replacement activities using the common CEG Repair/Replacement Program in accordance with the 2013 Edition of the ASME Code,Section XI as delineated in Table 1 (inclusive of all notes) to Enclosure 1 of their submittal, applicable for the remainder of the fourth 10-year ISI interval, which will include all examinations and tests for the third period of the fourth 10-year ISI interval, end after the completion of all remaining fourth 10-year ISI interval examinations and tests (coincident with the resuming power operations), and the start of the fifth 10-year ISI interval would begin after resuming power operations.
Based on the requirements in 10 CFR 50.55a(g)(4)(iv) and the guidance in RIS 2004-16, the NRC staff considered the following criteria in its review of CEGs request:
- 1) The proposed edition/addendum of the ASME Code is incorporated by reference in 10 CFR 50.55a(a).
- 2) The proposed edition/addendum of the ASME Code is subject to the conditions listed in 10 CFR 50.55a(b).
- 3) The licensee shall request Commission approval to use the proposed edition and addenda of the ASME Code.
- 4) If only portions of editions or addenda are to be used, all related requirements of the respective editions or addenda must be met.
In the evaluation of the first criterion, the NRC staff notes that the licensee proposed to use the provisions in the 2013 Edition of the ASME Code,Section X, for performing the NDE activities and associated repair/replacement activities. The 2013 Edition of the ASME Code,Section XI is incorporated by reference into 10 CFR 50.55a(a)(1)(ii), except for subparagraph IWB-3112(a)(3), and subparagraph IWC-3112(a)(3). The licensee has not requested to use any of the excluded provisions and stated that they will comply with all the latest applicable NRC conditions and limitations specified in 10 CFR 50.55a(b)(2) as applicable to the use of each Edition of ASME Code,Section XI. Therefore, the first criterion of 10 CFR 50.55a(g)(4)(iv) has been satisfied.
The conditions in paragraphs (ii), (viii), (ix), (x), (xii), (xiv), (xviii)(A), (xviii)(D), (xix), (xxii), (xxv),
(xxvi), (xxvii), (xxviii), (xxxi), (xxxii), (xxxiii), (xxxiv), (xxxv), (xxxvi), (xxxviii), (xli), (xlii), (xliii) and (xlvii) of 10 CFR 50.55a(b)(2) are applicable to the provisions in the 2013 Edition of the ASME Code,Section XI that CEG has requested to use. The licensee stated in the application that it will comply with all applicable conditions and limitations specified in 10 CFR 50.55a(b) when using these provisions. Therefore, the second criterion of 10 CFR 50.55a(g)(4)(iv) has been satisfied.
In the evaluation of the third criterion, the NRC staff notes that the licensee's request constitutes a request to use subsequent editions and therefore, the third criterion of 10 CFR 50.55a(g)(4)(iv) has been satisfied.
CEG is requesting to use the provisions in the 2013 Edition of the ASME Code,Section XI for NDE activities associated with ISI examinations and tests. The specific provisions are listed in the application and identified in Section 3.1.4 of this safety evaluation. The NRC staff has reviewed the application and determined that CEG has requested to use all the provisions in the 2013 Edition of the ASME Code,Section XI applicable to performing NDE activities associated with ISI examinations and tests and also applicable to performing repair/replacement activities.
Therefore, the fourth criterion of 10 CFR 50.55a(g)(4)(iv) has been satisfied.
Based on the above evaluation, the NRC staff finds that the criteria contained in 10 CFR 50.55a(g)(4)(iv) are satisfied. Accordingly, the NRC staff finds that the licensee's use of the 2013 Edition of ASME Code,Section XI as identified in Table 1 (inclusive of all notes) to of the licensees letter dated March 31, 2025, is acceptable for the remainder of the fourth 10-year ISI interval at CCEC, which would end when the remaining fourth 10-year ISI interval examinations and tests are completed, which is anticipated to occur coincident with the resumption of power operations.
4.0 CONCLUSION
As set forth above, the NRC staff has determined that the licensee has adequately addressed all the regulatory requirements set forth in 10 CFR 50.55a(g)(4)(iv). Therefore, the NRC staff approves the use of the provision in the 2013 Edition of the ASME Code,Section XI as outlined in Table 1 (inclusive of all notes) of the licensees submittal the remainder of the 4th 10-year ISI interval for CCEC, which would end when the remaining fourth 10-year ISI Interval examinations and tests are completed, which is anticipated to occur coincident with the resumption of power operations.
This approval is for the use of specific provisions of a later edition of Section XI of the ASME Code. The licensee did not request, nor does this approval authorize, any physical changes to the facility. The licensee has previously publicly communicated its plans to request approval from the NRC to restart the facility. This approval does not authorize restart of the facility, nor approve the ISI program for the CCEC, or extend associated NRC approved alternatives.
All other ASME Code,Section XI requirements which are not modified by the NRC staffs approval of the licensees request remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: J. Honcharik, NRR Date of Issuance: October 22, 2025
ML25289A276 NRR-028 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DSS/NPHP/BC NRR/DORL/LPL3/BC (A)
NAME BBallard SLent MMitchell IBerrios DATE 10/16/2025 10/16/2025 10/10/2025 10/22/2025