ML041400441
| ML041400441 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/11/2004 |
| From: | Hauser E Caldon |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| ER-404, Rev 2 | |
| Download: ML041400441 (3) | |
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Caldon, Inc.
May 11, 2004 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Caldon, Inc. NRC Project Number 1311
Subject:
PROPRIETARY DOCUMENT Review of Caldon Engineering Report ER-404, Revision 2
References:
I. Letter from Exelon Nuclear, Peach Bottom Atomic Power Station, Units 2 and 3 to US NRC "Review of Caldon Engineering Report ER-404, Revision 2" dated December 19, 2003 with Attachments
- 2. Caldon, Inc., Engineering Report ER-SOP, "Topical Report - Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM CheckTm System," dated March 1997.
- 3. Caldon, Inc., Engineering Report ER-157P, "Supplement to Topical Report ER-80P:
Basis for a Power Uprate with the LEFM CheckTm or LEFM ChecklPlusT"' System,"
dated October 2001.
- 4. Letter from US NRC to CL. Terry (Texas Utilities Electric), "Comanche Peak Steam Electric Station, Units I & 2 - Review of Caldon Engineering Topical Report ER-80P,
'Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM Check'm System'," dated March 8, 1999.
- 5. Letter from US NRC to M. A. Krupa (Entergy Operation, Inc.), "Waterford Steam Electric Station, Unit 3; River Bend Station; and Grand Gulf Nuclear Station - Review of Caldon, Inc., Engineering Report ER-I 57P," dated December 20, 2001.
Caldon, Inc. requests your review and approval of Engineering Report ER-404, "Topical Report Enhanced Accuracy of LEFM CheckPlus Systems in Backup Modes of Operation," Revision 2, dated December 2003 for use at Peach Bottom Atomic Power Station, Units 2 and 3 and other licensee utilizing the LEFM CheckPlusTm System for Power Uprates.
This Engineering Report, ER-404, was previously submitted by Peach Bottom Atomic Power Station, Units 2 and 3 on December 19, 2003 (Reference I) to the US Nuclear Regulatory Commission for review on their NRC Docket Nos. 50-277 and 50-278. On April 29,2004, Mr. G. Stewart of Peach Bottom Atomic Power Station was informed by Mr. G. Wunder, US NRC Project Manager, that the NRC could not review Engineering Report ER-404 on Peach Bottom Atomic Power Station, Units 2 and 3's NRC docket without a license amendment request. It was then suggested that Caldon submit this document on their docket for review and approval. Therefore Caldon is submitting Engineering Report ER-404 with the request for review and approval by the NRC on our project number 1311.
This letter reiterates the points highlighted in Peach Bottom Atomic Power Station, Units 2 and 3's original submittal of December 19,2003.
1070 Banksville Avenue
- Pittsburgh, PA 15216 Tel: 412-341-9920
- Fax: 412-341-9951
- Web: www.caldon.net
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Review of Caldon Engineering Report ER404, Revision 2 Docket No.
May 11, 2004 Page 2 Caldon Engineering Report ER-8OP (Reference 2), as supplemented by Entgineering Report ER-157P (Reference 3), documents the theory, design and operation features of the LEFM CheckPlus§" System and its ability to achieve increased accuracy of flow measurement. The NRC approved the use of ER-80P and ER-157P in Safety Evaluations dated March 8, 1999 (Reference 4), and December 20, 2001 (Reference 5),
respectively.
Caldon Engineering Report ER-404 supplements Engineering Reports ER-80P and ER-157P by providing additional information on the capability of the LEFM CheckPlusTN System to maintain the accuracy of feedwater flow measurements in a variety of system configurations. This report provides additional operational flexibility by allowing continued plant operation at the highest safe power level in the event of multiple component failures without having to consider the LEFM CheckPlusTm System inoperable. Caldon Engineering Report ER-404 satisfies the criteria for a topical report described in Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-500, "Processing Request for Review of Topical Reports,"
Revision 1, dated October 18, 2002, as indicated below.
- 1. The report deals with a specific safety-related subject regarding a nuclear power plant that requires a safety assessment by the NRC staff, for example, component design, analytical models or techniques, or performance testing of components and/or systems that can be evaluated independently of specific license application.
Typically, the instrumentation for measuring feedwater flow rate consists of a venturi, an orifice, or a flow nozzle that generates a differential pressure which is proportional to the feedwater velocity in the pipe. The Caldon LEFM CheckPlusT'~ System technology involves transit time methodology which uses ultrasonic pulse transmission in multiple acoustic paths across pipe cross sections to more accurately measure feedwater flow. The theory, design and operating features of the Caldon LEFM CheckPlusTrt System are documented in Caldon Engineering Reports ER-80P and ER-157P as previously approved by the NRC. However, Caldon Engineering Report ER-404 is a generic report that provides additional details not provided in the previous reports on operation of the LEFM CheckPlusTm System in a variety of system configuration. These details build upon data gathered from actual operation experience with LEFM CheckPlusTm Systems. While the use of the LEFM CheckPlusT'm System for Power level determination is not safety-related, plant power level determination is important to safety since power level is controlled by the plant facility operating license.
- 2. The report is, or is expected to be, referenced in a number of license amendments or standardized reference design approval applications.
Caldon Engineering Report ER-404 is a generic report that supplements the previous Caldon Engineering Reports (ER-80P and ER-157P; also generic) which were referenced in licensing actions by Texas Utilities Electric, Entergy Operations, Inc., and Exelon that requested power uprates based on the installation of the Caldon LEFM CheckPlusTm System. This report, together with the other Caldon Engineering Reports for the LEFM CheckPlus'm System, provides the basis for any future licensing actions on the part of the above mentioned licensees or others who wish to take advantage of the reduction of feedwater flow measurement uncertainties through installation of the LEFM CheckPlusTm System.
- 3. The report contains complete and detailed information on the specific subject presented. Conceptual or incomplete preliminary information will not be reviewed.
Review of Caldon Engineering Report ER-404, Revision 2 Docket No.
May 11, 2004 Page 3 Caldon Engineering Report ER-404 is complete and provides detailed information necessary for operation of the LEFM CheckPlusTm System in a variety of system configurations while maintaining the accuracy of feedwater flow measurements.
- 4. NRC approval of the report will increase the efficiency of the review process for applications that reference the report.
NRC approval of generic Caldon Engineering Report ER-404 would minimize industry and NRC time and effort by providing for a single upfront review and approval of the capability of the Caldon LEFM CheckPlusTm System to maintain the accuracy of feedwater flow measurements while functioning in a variety of system configurations. Once approved by the NRC, nuclear power plants that have the Caldon LEFM CheckPlusT§t System (e.g. Beaver Valley, Unit 2; Waterford, Unit 3; River Bend; Grand Gulf; H.B. Robinson; D.C. Cook, Units I and 2; and Peach Bottom, Units 2 and 3) would then be able to take advantage of the operational flexibility provided in the report under the requirements of 10 CFR 50.59. In addition, any utility licensee that whishes to install a Caldon LEFM CheckPlusTrm System in their plant may reference Engineering Report ER-404 in conjunction with Engineering Reports ER-80P and ER-157P in any licensing actions related to power uprate.
Copies of both the proprietary (ER-404) and non-proprietary (ER-404NP) versions of the report were provided with Exelon Nuclear, Peach Bottom Atomic Power Station Units 2 and 3's December 19, 2003 submittal to the NRC. An Affidavit, signed by an officer of Caldon, Inc., in support of a request that the proprietary version of the report be withheld form public disclosure in accordance with the requirements of IOCFR2.790(a)(4), was also provided as an attachment to the December 19, 2003 submittal.
Caldon requests approval of Caldon Engineering Report ER-404 by August 2004.
There are not commitments contained within this letter.
If you have any questions or require additional information, please contact Ernie Hauser at 412-341-9920.
- Regards, Ernest M. Hauser President, Caldon Nuclear cc: Bill Mason, NRC Project Manager
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