RS-20-110, Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

Request to Use Provisions of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI

ML20246G735
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle, 05000253, University of New Mexico
Issue date:	09/02/2020
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-20-110
Download: ML20246G735 (7)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-20-110 September 2, 2020 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 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

U.S. Nuclear Regulatory Commission Request to Use Provisions of a Later Addenda of the ASME B&PV Code, Section XI September 2, 2020 Page 2 Peach Bottom Atomic Power Station, Units 2 and 3 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 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv), and the guidance provided in the referenced document, Exelon Generation Company, LLC (Exelon) 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, for the units identified above. Specifically, Exelon Generation Corporation, LLC (Exelon) requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code, Section XI.

Exelon requests approval of this request by October 16, 2020. There are no regulatory commitments in this letter.

If you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC

Attachment:

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

U.S. Nuclear Regulatory Commission Request to Use Provisions of a Later Addenda of the ASME B&PV Code, Section XI September 2, 2020 Page 3 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 Illinois Emergency Management Agency - Division of Nuclear Safety S. Seaman, State of Maryland A. L. Peterson, NYSERDA

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

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 1 In accordance with 10 CFR 50.55a, "Codes and standards," paragraph (g)(4)(iv) and the guidance provided in Reference 1, Exelon Generation Company, LLC (Exelon) 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, 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, Exelon Generation Company, LLC (Exelon) requests approval to use IWA-4540(b) of the 2017 Edition of the ASME B&PV Code, Section XI.

1. Component(s) Affected All Class 1, 2, and 3 items located in the ASME Section XI boundaries.

2. Requested Date for Approval Approval is requested by October 16, 2020.

3. Applicable Code Edition and Addenda

PLANT INTERVAL EDITION START END Braidwood Station, Units Fourth 2013 Edition August 29, 2018 July 28, 2028 1 and 2 October 17, 2018 October 16, 2028 Byron Station, Units Fourth 2007 Edition, through 2008 July 16, 2016 July 15, 2025 1 and 2 Addenda Calvert Cliffs Nuclear Fifth 2013 Edition July 1, 2019 June 30, 2029 Power Plant, Units 1 and 2

Clinton Power Station, Fourth 2013 Edition July 1, 2020 June 30, 2030 Unit 1 Dresden Nuclear Power Fifth 2007 Edition, through 2008 January 20, 2013 January 19, 2023 Station, Units 2 and 3 Addenda James A. FitzPatrick Fifth 2007 Edition, through 2008 August 1, 2017 June 15, 2027 Nuclear Power Plant Addenda LaSalle County Stations, Fourth 2007 Edition, through 2008 October 1, 2017 September 30, 2027 Units 1 and 2 Addenda Limerick Generating Fourth 2007 Edition, through 2008 February 1, 2017 January 31, 2027 Station, Units 1 and 2 Addenda

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 2 PLANT INTERVAL EDITION START END Nine Mile Point Nuclear Fifth 2013 Edition August 23, 2019 August 22, 2029 Station, Unit 1 Nine Mile Point Nuclear Fourth 2013 Edition August 23, 2018 August 22, 2028 Station, Unit 2 Peach Bottom Atomic Fifth 2013 Edition January 1, 2019 December 31, 2028 Power Station, Units 2 and 3 Quad Cities Nuclear Fifth 2007 Edition, through 2008 April 2, 2013 April 1, 2023 Power Station, Units 1 Addenda and 2 R. E. Ginna Nuclear Sixth 2013 Edition January 1, 2020 December 31, 2030 Power Plant

4. Proposed Subsequent Code Edition and Addenda (or Portion)

Pursuant to 10 CFR 50.55a(g)(4)(iv), Exelon requests permission to utilize IWA-4540(b) from the 2017 Edition of ASME Section XI in place of the requirements of IWA-4540(b) in the 2007 Edition through 2008 Addenda or the 2013 Edition of ASME B&PV Code, Section XI, as shown for the sites above. This subparagraph outlines items that are exempt from pressure testing after repair/replacement activities.

5. 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(b)(2) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2017 Edition as approved in Reference 3. 10 CFR 50.55a(b)(2) incorporates by reference Section XI, Division 1, of the ASME B&PV Code 2017 Edition as approved in Reference 3. Exelon is requesting the use of IWA-4540(b) of the 2017 Edition of ASME Section XI to utilize the exemptions listed. There are no related requirements or applicable conditions associated with this subparagraph, IWA-4540(b).

Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv)

Page 3

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

7. 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.

2. U.S. Nuclear Regulatory Commission Memorandum from D. Rudland (Senior Level Advisor, Division of New and Renewed Licenses) to Anna H. Bradford (Director, Division of New and Renewed Licenses), Summary of the June 25, 2020, Public Meeting with the Nuclear Industry to Discuss Title 10 of the Code of Federal Regulations Section 50.55a(b)(2)(xxvi) Condition on the Pressure Testing of Class 1, 2, and 3 Mechanical Joints, dated July 8, 2020 (ML20189A286)

3. Federal Register, 85 FR 26540, dated May 4, 2020

8. Precedents

• Letter from M. Markley (U.S. Nuclear Regulatory Commission) to C. Gayheart (Southern Nuclear Operating Co., Inc.), Vogtle Electric Generating Plant, Units 1 and 2 - Request to Use a Provision of a Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section (EPID L-2020-LLR-01 01), dated August 6, 2020

• Letter from J. Dixon-Herrity (U.S. Nuclear Regulatory Commission) to K. Peters (Vistra Operations Company LLC), Comanche Peak Nuclear Power Plant, Units No. 1 and 2 - Use of Later Code Edition to the Requirements of the ASME Code (EPID L-2020-LLR-0102), dated August 17, 2020