RS-25-032, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI
| ML25090A036 | |
| Person / Time | |
|---|---|
| Site: | Crane  (DPR-050) |
| Issue date: | 03/31/2025 |
| From: | Moore D Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-25-032 | |
| Download: ML25090A036 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 RS-25-032 10 CFR 50.55a March 31, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code,Section XI
References:
- 1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004 [ADAMS Accession No. ML042090436].
- 2. Three Mile Island Nuclear Station, Unit 1 - Regulatory Path to Reauthorize Power Operations, dated November 4, 2024 [ADAMS Accession No. ML24310A104].
- 3. Three Mile Island Nuclear Station, Unit 1 - Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated November 19, 2024 [ADAMS Accession No. ML24324A048].
In accordance with 10 CFR 50.55a(g)(4)(iv) and the guidance provided in the referenced document (Reference 1), Constellation Energy Generation, LLC (CEG) hereby requests NRC approval to use specific provisions of a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, for Three Mile Island Nuclear Station, Unit 1 (TMI-1). Specifically, CEG requests approval to update TMI-1 to the 2013 Edition of the ASME BPV Code for performing Non-Destructive Examination (NDE) and Repair and Replacement (R&R) for ASME BPV Section XI related activities.
On September 20, 2024, CEG announced the planned restart of TMI-1 and its intent to change TMI-1s name to the Christopher M. Crane Clean Energy Center. In conjunction with this announcement, CEG held a public meeting with the NRC in Rockville, MD, on October 25, 2024, to introduce its technical approach and regulatory activities intended to support NRC reauthorization of the TMI-1 Operating License. On November 4, 2024, CEG submitted a letter
U.S. Nuclear Regulatory Commission Page 2 (Reference 2) to the NRC proposing a regulatory path to reauthorize power operations at TMI-1 consistent with Inspection Manual Chapter 2562, Lightwater Reactor Inspection Program for Restart of Reactor Facilities Following Permanent Cessation of Power Operations. On November 19, 2024, CEG submitted a request for exemption from certain termination of license requirements of 10 CFR 50.82 formally initiating the regulatory process for obtaining NRC authorization for resumption of power operations (Reference 3).
In the regulatory path letter (Reference 2), 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).
This request is being submitted to support performance of ASME BPV Section XI related activities prior to the resumption of power operations of TMI-1. CEG requests approval of this request by December 15, 2025.
There are no regulatory commitments contained within this letter.
Should you have any questions concerning this letter, please contact Craig Smith at craig.smith3@constellation.com.
Respectfully, Dennis M. Moore Sr. Manager Licensing Constellation Energy Generation, LLC :
Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv) cc:
NRC Regional Administrator - Region I NRC Director, NRR - DORL NRC Deputy Director, NRR - DORL NRC Project Manager, NRR-DORL - Three Mile Island, Unit 1 NRC Project Manager, NMSS - Three Mile Island, Unit 1 Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection 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: 2025.03.28 10:17:16 -04'00' Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
(Page 1 of 5) 1.
ASME Code Components Affected All Class 1, 2, 3, MC, and CC components, component supports, and welds located in the American Society of Mechanical Engineers (ASME)Section XI boundaries.
===2.
Applicable Code Edition and Addenda===
The ASME Boiler and Pressure Vessel (BPV) Code of Record for the Fourth Inservice Inspection (ISI) Interval at Three Mile Island Nuclear Station, Unit 1 (TMI-1) is the 2004 Edition with No Addenda.
3.
Proposed Subsequent Code Edition and Addenda (or Portion)
All Constellation Energy Generation (CEG) plants perform ISI related non-destructive examination (NDE) activities in accordance with standardized fleet programs. These standardized programs are based on a common Edition of ASME Section XI which, at present, is the 2013 Edition. While the TMI-1 ISI Program Plan is controlled in site-specific documents, the NDE program is controlled in common corporate program procedures that are implemented across the entire CEG nuclear fleet.
Similarly, all CEG plants perform ASME Section XI IWA-4000 Repair and Replacement (R&R) activities in accordance with standardized fleet programs. These standardized fleet programs are based on Editions and Addenda of ASME Section XI which, at present, are the 2007 Edition with the 2008 Addenda, the 2013 Edition, and the 2017 Edition. Much like the NDE program, the R&R program is controlled in common corporate program procedures that are implemented across the entire CEG nuclear fleet.
Pursuant to 10 CFR 50.55a(g)(4)(iv), CEG requests permission to utilize the 2013 Edition of ASME Section XI for performing ISI-related NDE and R&R activities as identified in Table 1 of Enclosure 1. In implementing this proposal, CEG will also 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 Section XI.
It is important to note that this request 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 at TMI-1 as described in Section 2 above. See Table 1 of Enclosure 1 for specific details regarding this proposal.
4.
Related Requirements 10 CFR 50.55a(g)(4)(iv) states:
Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
(Page 2 of 5)
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.
CEG is requesting to use the 2013 Edition of ASME Section XI for performing ISI-related NDE and R&R activities for the remainder of the TMI-1 Fourth ISI interval, except where otherwise conditioned by the NRC in 10 CFR 50.55a(b)(2). In making this request, CEG will comply with all related requirements in ASME Section XI as described below and delineated in Table 1 of Enclosure 1:
x CEG has proposed to utilize all Articles (e.g. IWA-1000, IWA-2000, IWA-4000) from every Subsection (e.g. IWA, IWB, etc.) of the 2013 Edition that could be used or referenced for the performance of NDE and R&R activities.
x CEG has proposed to utilize all portions of Mandatory Appendices of the 2013 Edition that could be used or referenced for the performance of NDE and R&R activities. Mandatory Appendices provide supplemental requirements to specific code articles (or paragraphs) in ASME Section XI. It should be noted that the reason CEG has chosen to use the 2013 Edition for all Mandatory Appendices is that these Mandatory Appendices provide supplemental requirements to ASME Code articles and paragraphs that are also being used from the 2013 Edition.
x CEG has proposed to utilize all portions of Nonmandatory Appendices A through W in the 2013 Edition that could be used or referenced for the performance of NDE and R&R activities.
x With regard to the performance of ISI examinations and tests, CEG will select, plan, and schedule these ISI inspection activities, as specified in IWA-, IWB-,
IWC-, IWD-, IWE-, IWF-, and IWL-2500 or NRC approved ISI alternatives, in accordance with the current TMI-1 ISI Program Plan, for which the 2004 Edition with No Addenda is the ASME Section XI Code of Record.
5.
Duration of Proposed Request The duration of this request will continue for the remainder of the TMI-1 Fourth ISI 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 XI, dated July 28, 2004 [ADAMS Accession No. ML042090436]
- 2. Three Mile Island Nuclear Station, Unit 1 - Regulatory Path to Reauthorize Power Operations, dated November 4, 2024 [ADAMS Accession No. ML24310A104]
- 3. Three Mile Island Nuclear Station, Unit 1 - Request for Exemption from Certain Termination of License Requirements of 10 CFR 50.82, dated November 19, 2024 Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
(Page 3 of 5)
[ADAMS Accession No. ML24324A048]
===7.
Precedents===
This request is similar to the following requests which were submitted in accordance with 10 CFR 50.55a(g)(4)(iv), approved by the NRC, and allowed nuclear plants to use a later Edition/Addenda of ASME Section XI performing ISI related activities such as NDE and R&R while the ISI Code of Record for these plants was an earlier Edition/Addenda.
x Letter from N. Salgado (U.S. Nuclear Regulatory Commission) to B. Hanson (Exelon Generation Company, LLC), Byron Station, Unit Nos. 1 and 2; 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; and Quad Cities Nuclear Power Station, Units 1 and 2 - Request to Use Provisions in the 2013 Edition of the ASME Boiler and Pressure Vessel Code for Performing Non-Destructive Examinations (EPID L-2019-LLR-0080), dated April 17, 2020 [ADAMS Accession No. ML20099D955]
x Letter from R. Pascarelli (U.S. Nuclear Regulatory Commission) to B. Ford (Entergy Operation, Inc.), Arkansas Nuclear One, Unit 2 and Indian Point Nuclear Generating Station, Unit No. 3 - Relief Request EN-ISI-16-1 Regarding Use of Later Edition and Addenda of the ASME Code (CAC Nos. MF8905 and MF8906), dated July 12, 2017 [ADAMS Accession No. ML17174B144]
Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
(Page 4 of 5)
Table 1 - Proposed ASME Section XI Codes of Record1 Code Provision ASME Section XI Edition/Addenda2 Sub-section Article 2004 Edition with No Addenda 2013 Edition IWA-General Requirements IWA-1000 X3 X3 IWA-2000 X4 X4 IWA-3000 X
IWA-4000 X
IWB-Requirements for Class 1 Components IWB-1000 X5 IWB-2000 X5 IWB-3000 X
IWC-Requirements for Class 2 Components IWC-1000 X5 IWC-2000 X5 IWD-Requirements for Class 3 Components IWD-1000 X5 IWD-2000 X5 IWE-Requirements for Class MC Components IWE-1000 X5 IWE-2000 X5,6 X5,6 IWF-Requirements for Class 1,2,3 and MC Supports IWF-1000 X5 IWF-2000 X5 IWL-Requirements for Class CC Components IWL-1000 X5 IWL-2000 X5,7 X7 Mandatory Appendices8 I - X X
Nonmandatory Appendices9,10 A - W X
Notes:
- 1. CEG will use the Articles, Mandatory Appendices, and Nonmandatory Appendices as shown in Table 1 for NDE and R&R related activities. Articles, Mandatory Appendices, and Nonmandatory Appendices not identified in Table 1 will use the 2004 Edition with No Addenda.
- 2. CEG will comply with all NRC conditions, limitations, and restrictions specified in 10 CFR 50.55a(b)(2) for the applicable Edition referenced.
- 3. CEG will use the referenced standards from the 2013 Edition in IWA-1600 in relation to NDE related activities. All other paragraphs will utilize the 2004 Edition with No Addenda.
Proposed Use of a Subsequent Edition of the ASME BPV Code,Section XI in Accordance with 10 CFR 50.55a(g)(4)(iv)
(Page 5 of 5)
- 4. CEG is proposing to use IWA-2100, -2200, and -2300 from the 2013 Edition for requirements applicable to authorized inspection, examination methods, and qualification of personnel. However, TMI-1 will use the 2004 Edition with No Addenda when using IWA-2400, -2500, and -2600 for selection, planning, and scheduling of ISI examinations and tests.
- 5. The selection, planning, and scheduling of ISI examinations and tests will comply with these ASME Section XI articles (e.g., IWB-1000 and -2000) from the 2004 Edition with No Addenda or applicable NRC approved alternatives specified in the TMI-1 ISI Program Plan.
- 6. CEG will use IWE-2300 from the 2013 Edition for requirements applicable to examination methods and qualification of personnel. All other subarticles of IWE-2000 will use the 2004 Edition with No Addenda.
- 7. CEG will use IWL-2310 related to visual examination and IWL-2320 related to personnel qualification from the 2013 Edition. All other subarticles of IWL-2000 will use the 2004 Edition with No Addenda. Note that IWL-2320 in the 2004 Edition with No Addenda is related to the Responsible Engineer, while in the 2013 Edition the Responsible Engineer is covered in IWL-2330. CEG will use IWL-2320 from the 2004 Edition with No Addenda for the requirements of the Responsible Engineer.
- 8. Appendix VII will be implemented from the 2013 Edition as amended by 10 CFR 50.55a(b)(2)(xviii)(D) to use Table VII-4110-1 and Appendix VIII, Subarticle VII-2200 from the 2010 Edition. As allowed by 10 CFR 50.55a, CEG implements the latest approved Edition of Appendix VIII incorporated in 10 CFR 50.55a(a)(1)(ii).
- 9. Nonmandatory Appendices F, I, and V do not exist in either the 2004 Edition with No Addenda or the 2013 Edition of ASME Section XI.
- 10. Nonmandatory Appendices Q, R, S, T, U, and W exist in the 2013 Edition but do not exist in the 2004 Edition with No Addenda of ASME Section XI. CEG proposes to use these Nonmandatory Appendices from the 2013 Edition of ASME Section XI, as conditioned, limited, or restricted 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 is not requesting approval for use of Nonmandatory Appendix R at TMI-1.