NMP1L3662, Constellation Energy Generation, LLC, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

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Constellation Energy Generation, LLC, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI
ML25308A009
Person / Time
Site: Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  
Issue date: 11/04/2025
From: Knowles J
Constellation Energy Generation
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
NMP1L3662, RS-25-147
Download: ML25308A009 (1)


Text

200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com NMP1L3662 RS-25-147 10 CFR 50.55a November 04, 2025 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Unit 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI November 04, 2025 Page 2 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

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 Xl," 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 a specific provision of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, incorporated in 10 CFR 50.55a(a)(1)(ii), for the units identified above. Specifically, CEG requests approval to use IWA-4142.1 (Alternative Quality Assurance Program Requirements for Owners) of the 2021 Edition of the ASME B&PV Code,Section XI.

CEG requests your review and approval of this fleet request by February 6, 2026 to support Spring refueling outages.

There are no regulatory commitments contained in this letter.

If you have any questions concerning this letter, please contact Jesse Brown at 267-533-6355 Respectfully, Justin Knowles Sr. Manager - Licensing Constellation Energy Generation, LLC

Knowles, Justin W Digitally signed by Knowles, Justin W Date: 2025.11.04 08:57:22 -05'00'

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI November 04, 2025 Page 3

Attachment:

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI cc:

Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Project Manager - Braidwood Station NRC Project Manager - Byron Station NRC Project Manager - Calvert Cliffs Nuclear Power Plant NRC Project Manager - Clinton Power Station NRC Project Manager - Dresden Nuclear Power Station NRC Project Manager - James A. FitzPatrick Nuclear Power Plant NRC Project Manager - LaSalle County Station NRC Project Manager - Limerick Generating Station NRC Project Manager - Nine Mile Point Nuclear Station NRC Project Manager - Peach Bottom Atomic Power Station NRC Project Manager - Quad Cities Nuclear Power Station NRC Project Manager - R.E. Ginna Nuclear Power Plant

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI November 04, 2025 Page 4 bcc:

Corporate Executive Distribution with attachments Braidwood Station Sr. Leadership Distribution Byron Station Sr. Leadership Distribution Calvert Cliffs Nuclear Power Plant Sr. Leadership Distribution Clinton Power Station Sr. Leadership Distribution Dresden Nuclear Power Station Sr. Leadership Distribution James A. FitzPatrick Nuclear Power Plant Sr. Leadership Distribution LaSalle County Station Sr. Leadership Distribution Limerick Generating Station Sr. Leadership Distribution Nine Mile Point Nuclear Station Sr. Leadership Distribution Peach Bottom Atomic Power Station Sr. Leadership Distribution Quad Cities Nuclear Power Station Sr. Leadership Distribution R.E. Ginna Nuclear Power Plant Sr. Leadership Distribution Corporate Licensing East Distribution Corporate Licensing West Distribution Braidwood Station RAM Byron Station RAM Calvert Cliffs Nuclear Power Plant RAM Clinton Power Station RAM Dresden Nuclear Power Station RAM James A. FitzPatrick Nuclear Power Plant RAM LaSalle County Station RAM Limerick Generating Station RAM Nine Mile Point Nuclear Station RAM Peach Bottom Atomic Power Station RAM Quad Cities Nuclear Power Station RAM R.E. Ginna Nuclear Power Plant RAM

Attachment Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 1 of 3)

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, incorporated in 10 CFR 50.55a(a)(1)(ii), for Braidwood Station, Units 1 and 2, Byron Station, Units 1 and 2, Calvert Cliffs Nuclear Power Plant, Units 1 and 2, Clinton Power Station, Unit 1, Dresden Nuclear Power Station, Units 2 and 3, James A. FitzPatrick Nuclear Power Plant, LaSalle County Station, Units 1 and 2, Limerick Generating Station, Units 1 and 2, Nine Mile Point Nuclear Station, Units 1 and 2, Peach Bottom Atomic Power Station, Units 2 and 3, Quad Cities Nuclear Power Station, Units 1 and 2, and R. E. Ginna Nuclear Power Plant.

Specifically, CEG requests approval to use IWA-4142.1 of the 2021 Edition of the ASME B&PV Code,Section XI.

1. ASME CODE COMPONENT(S) AFFECTED:

All ASME Class 1, 2, and 3 piping systems.

2. APPLICABLE CODE EDITION AND ADDENDA:

Table 1 summarizes the plants included in this request, the current Inservice Inspection (ISI)

Interval, and the applicable Edition and Addenda of the ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.

Table 1. Plants Included in This Request and Their Current ISI Intervals and Applicable ASME Code Section XI Editions/Addenda Plant/Unit(s)

ISI Interval ASME Section XI Code Edition / Addenda Interval Start Date Interval End Date Braidwood Station, Units 1 and 2 Fourth 2013 Edition August 29, 2018 November 5, 2018 July 28, 2028 October 16, 2028 Byron Station, Units 1 and 2 Fifth 2019 Edition July 16, 2025 July 15, 2037 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Fifth 2013 Edition July 1, 2019 June 30, 2029 Clinton Power Station, Unit 1 Fourth 2013 Edition July 1, 2020 June 30, 2030 Dresden Nuclear Power Station, Units 2 & 3 Sixth 2017 Edition January 20, 2023 January 19, 2035 James A. FitzPatrick Nuclear Power Plant Fifth 2007 Edition with the 2008 Addenda August 1, 2017 June 15, 2027

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 2 of 3)

Plant/Unit(s)

ISI Interval ASME Section XI Code Edition / Addenda Interval Start Date Interval End Date LaSalle County Station, Units 1 and 2 Fourth 2007 Edition with the 2008 Addenda October 1, 2017 September 30, 2027 Limerick Generating Station, Units 1 and 2 Fourth 2007 Edition with the 2008 Addenda February 1, 2017 January 31, 2027 Nine Mile Point Nuclear Station, Unit 1 Fifth 2013 Edition August 23, 2019 August 22, 2029 Nine Mile Point Nuclear Station, Unit 2 Fourth 2013 Edition October 06, 2018 August 22, 2028 Peach Bottom Atomic Power Station, Units 2 and 3 Fifth 2013 Edition January 1, 2019 December 31, 2028 Quad Cities Nuclear Power Station, Units 1 and 2 Sixth 2017 Edition April 2, 2023 April 1, 2035 R.E. Ginna Nuclear Power Plant Sixth 2013 Edition January 1, 2020 December 31, 2039

3. PROPOSED SUBSEQUENT CODE EDITION AND ADDENDA (OR PORTION):

Pursuant to 10 CFR 50.55a(g)(4)(iv), CEG requests permission to use IWA-4142.1 (Alternative Quality Assurance Program Requirements for Owners) of the 2021 Edition of the ASME B&PV Code,Section XI in lieu of similar alternative quality assurance requirements in the editions of the ASME B&PV Code contained in Table 1 above. This subparagraph outlines alternative Quality Assurance Program requirements for Owners for items subject to repair/replacement activities. IWA-4142.1 of the 2021 Edition of the ASME B&PV Code,Section XI allows CEG to credit actions taking by the supplier for meeting requirements to verify chemical composition and nondestructive examination required by the material specification, Construction Code, or Owners Requirements have been performed on each piece of unqualified source material.

4. 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(1)(ii)(C)(57) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2021 Edition. CEG requests permission to use IWA-4142.1 of the 2021 Edition of the ASME B&PV Code,Section XI to utilize the alternative Quality Assurance Program requirements for Owners for items subject to repair/replacement activities. In addition, the definitions of IWA-9000 (Glossary) of the 2021 Edition of the ASME B&PV Code, Section

Request to Use Provisions of a Later Edition of the ASME B&PV Code,Section XI In Accordance with 10 CFR 50.55a(g)(4)(iv)

(Page 3 of 3)

XI referenced by subparagraph IWA-4142.1 are applicable. There are no conditions in 10 CFR 50.55a(b)(2) associated with this subparagraph, IWA-4142.1.

5. DURATION OF PROPOSED REQUEST:

The duration of this request will continue for the remainder of the sites current Inservice Inspection interval.

6.

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. (ML042090436)
7. PRECEDENTS:

None