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Byron, Units 1 & 2, Dresden, Units 2 & 3, James A. Fitzpatrick, Lasalle

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Byron, Units 1 & 2, Dresden, Units 2 & 3, James A. Fitzpatrick, Lasalle 200 Exelon Way Exelon Generation ® Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.55a RS-19-089 JAFP-19-0084 August 27, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 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 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 N RC Docket Nos. 50-373 and 50-37 4 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 N RC Docket Nos. 50-352 and 50-353 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 Subject: Request to Use a Provision 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 XI," dated July 28, 2004 U.S. Nuclear Regulatory Commission Request to Use a Provision of a Later Addenda of the ASME B&PV Code, Section XI August 27, 2019 Page 2 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 requests approval to update these plants to the 2013 Edition of the ASME B&PV Code for performing Non-Destructive Examination (NOE) for ASME B&PV Section XI related activities. Exelon requests approval of this request by August 27, 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, J 6-.., :J /. ,£, J yv--- David T. Gudger Sr. Manager - Licensing Exelon Generation Company, LLC Attachment: Request to Use a Portion of a Later Edition of the ASME B&PV Code, Section XI cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Byron 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 - Quad Cities Nuclear Power Station NRC Project Manager - Byron 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 - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Department of Nuclear Safety R. R. Janati, Bureau of Radiation Protection Attachment Request to Use a Portion 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 Byron Station, Units 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 which comply with the 2007 Edition/2008 Addenda. Specifically, Exelon requests approval to update these plants to the 2013 Edition of the ASME B&PV Code for performing ISi-reiated Non-Destructive Examination (NOE) activities. 1. ASME Code Component(s} Affected: All Class 1, 2, 3, MC, and CC components, component supports, and welds located in the ASME Section XI boundaries. 2. Applicable Code Edition and Addenda: PLANT INTERVAL EDITION START END Byron Station, Fourth 2007 Edition, through 2008 July 16, 2016 July 15, 2025 Units 1 and 2 Addenda 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 Quad Cities Nuclear Fifth 2007 Edition, through 2008 April 2, 2013 April 1, 2023 Power Station, Units 1 Addenda and 2 3. Proposed Subsequent Code Edition and Addenda (or Portion): All Exelon plants perform lnservice Inspection (ISi) related NOE activities in accordance with standardized fleet programs. These standardized programs are based on Editions of ASME Section XI which, at present, is the 2007 Edition with the 2008 Addenda and the 2013 Edition. While ISi Program Plans are controlled in site-specific documents, the NOE program is controlled in common corporate program procedures that are implemented across the entire nuclear fleet. Pursuant to 1O CFR 50.55a(g)(4)(iv), Exelon requests permission to utilize the Articles from the 2013 Edition for performing ISi related NOE activities as identified in Table 1 of Enclosure 1. In implementing this proposal, Exelon will also comply with all applicable NRC conditions and limitations specified in 1O CFR 50.55a(b) including those specified below. See Table 1 of Enclosure 1 for specific details regarding this proposal. Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv) Page2 • The NOE provision in IWA-4540(a)(2) of the 2001 Edition/2002 Addenda will be applied when performing system leakage tests after repair/replacement activities involving welding or brazing to comply with 10 CFR 50.55a(b)(2)(xx)(B). • Pressure testing of mechanical joints of Class 1, 2, and 3 items will be performed in accordance with IWA-4540(c) of the 1998 Edition/No Addenda to comply with 10 CFR 50.55a(b )(2)(xxvi). 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-, IWO-, IWE-, IWF-, and IWL-2500 or NRC approved ISi alternatives. Therefore, ISi examinations and tests will continue to be selected, planned, and scheduled in accordance with their present Code of Record as described in Section 2, above. See Table 1 of Enclosure 1 for specific details regarding this proposal. 4. Related Requirements: 1o CFR 50.55a(g)(4)(iv) states: "lnservice 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." Exelon is requesting to use the 2013 Edition of ASME Section XI for performing ISi related NOE activities except where otherwise conditioned by the NRC in 1O CFR 50.55a. In making this request, Exelon will comply with all related requirements in ASME Section XI as described below and delineated in Table 1 of Enclosure 1: • Exelon has proposed to utilize all "Articles" (e.g. IWA-1000, IWA-2000) from every "Subsection" (e.g. IWA, IWB, etc.) of the 2013 Edition that could be used or referenced for the performance of NOE activities. • Exelon has proposed to utilize all "Mandatory Appendices" of the 2013 Edition. Mandatory appendices provide supplemental requirements to specific code articles (or paragraphs) in ASME Section XI. It should be noted that the reason Exelon 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. • Exelon has proposed to utilize the 2013 Edition for Nonmandatory Appendices A through W, along with any applicable conditions specified through 1O CFR 50.55a when utilized for NOE related activities. • With regard to the performance of ISi examinations and tests, Exelon will continue to select, plan, and schedule these ISi inspection activities, as specified in IWA-, IWB-, IWC-, IWO-, IWE-, IWL-, and IWF-2500 or NRC approved ISi alternatives, in accordance with the current ISi Program Plans. Proposed Use of Subsequent ASME Code Edition and Addenda In Accordance with 10 CFR 50.55a(g)(4)(iv) Page3 5. Duration of Proposed Request: The duration of this request will continue for the remainder of the site's current lnservice Inspection interval. 6. References: 1. NRG 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 7. Precedents: This request is similar to the following requests which were submitted in accordance with 1O CFR 50.55a(g)(4)(iv), approved by the NRG and allowed nuclear plants to use a later Edition/Addenda of ASME Section XI performing ISi related activities such as NOE, PT, R&R while the ISi Code of Record for these plants was an earlier Edition/Addenda: • Letter from R.
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