RS-24-093, Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests
| ML24284A313 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 10/10/2024 |
| From: | Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-24-093, NMP1L3607 | |
| Download: ML24284A313 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.ConstellationEnergy.com 10 CFR 50.55a RS-24-093 NMP1L3607 October 10, 2024 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
Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests October 11, 2024 Page 2 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 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:
Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests
References:
- 1) Letter from David P. Helker (Constellation Energy Generation, LLC) to Document Control Desk (U.S. Nuclear Regulatory Commission), Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests dated April 30, 2024 (ML24122C614)
- 2) Electronic mail message from Scott P. Wall (U.S. Nuclear Regulatory Commission) to Jesse Brown (Constellation Energy Generation, LLC),
FINAL RAI - Constellation Energy Generation, LLC - Fleet Request -
Proposed Alternative to Utilize Code Case OMN-32 (L-2024-LLR-0030) dated September 6, 2024 (ML24250A106)
By letter dated April 30, 2024 (Reference 1), and in accordance with 10 CFR 50.55a, Codes and standards, Constellation Energy Generation, LLC (CEG) requested NRC approval of a proposed alternative request associated with the use of ASME Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests.
By email dated September 6, 2024 (Reference 2), the U.S Nuclear Regulatory Commission requested additional information necessary to complete the requested review.
The attachment to this letter provides the request for additional information as well as the CEG response.
Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests October 11, 2024 Page 3 There are no regulatory commitments contained in this letter.
If you have any questions concerning this letter, please contact Steven Bowers at 267-533-5101.
Respectfully, Wendi Para Sr Manager - Licensing Constellation Energy Generation, LLC
Attachment:
Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests 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, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - R.E. Ginna Nuclear Power Plant
ATTACHMENT Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18
Attachment Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Page 1 of 4 NRC Mechanical Engineering & Inservice Testing Branch (EMIB) Questions Applicable Regulation and Guidance The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in paragraph 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
10 CFR 50.55a(b)(6), Conditions on ASME OM Code Cases, states that licensees may apply ASME OM Code Cases listed in Revision 5 to NRC Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code, Revision 5, dated March 2024 (ML23291A006), as incorporated by reference in 10 CFR 50.55a, paragraph (a)(3)(iii).
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Background===
ASME OM Code Case OMN-6, Alternate Rules for Digital Instruments, states that digital instruments may be selected such that the reference value does not exceed 90% of the calibration range of the instrument in lieu of the 70% of calibration range.
ASME OM Code Case OMN-32 is not currently approved for use in RG 1.192, Revision 5. The NRC staff has following comments on published Code Case OMN-32.
- 1. ASME OM Code Case OMN-32 does not include the requirements of ASME OM Code, Subsection ISTB, paragraph ISTB-3510(a) when a parameter is determined by an analytical method instead of measurements.
Attachment Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Page 2 of 4
- 2. ASME OM Code, paragraph ISTB-3510(b)(2) of the ASME OM Code-2001 through 2004 editions including OMa-2005 Addenda states that Digital instruments shall be selected such that the reference value does not exceed 70% of the calibrated range of the instrument. ASME OM Code, paragraph ISTB-3510(b)(2) of the ASME OMb-2006 Addenda through ASME OM Code-2022 edition states that Digital instruments shall be selected such that the reference value does not exceed 90% of the calibrated range of the instrument. Further, Code Case OMN-6, Alternate Rules for Digital Instruments, allows alternative requirements to ISTB-3510(b)(2) (OM-2001 through 2005a) and states that digital instruments may be selected such that the reference value does not exceed 90% of the calculated range of the instrument. The ISTB committee is requested to address how both 70% and 90% calibrations or Code Case OMN-6 are taken into account in Code Case OMN-32 while calculating the required instrument accuracy as specified in Table 1.
RAI-EMIB-01 ASME OM Code Case OMN-32 was approved by the ASME Operation and Maintenance Standards Committee in September 2023, with the NRC representative voting in the affirmative with comments. Code Case OMN-32 was subsequently published [ ] on the ASME website, but did not incorporate the NRC staff comments. The licensee proposes to adopt Code Case OMN-32, which the NRC has not accepted for use in RG 1.192 at this time. The licensee is requested to address the following aspects for the proposed implementation of Code Case OMN-32 at the Constellation Fleet nuclear power plants:
Instrument accuracy shall be within the limits of Table ISTB-3510-1. If a parameter is determined by analytical methods instead of measurement, then the determination shall meet the parameter accuracy requirements of Table ISTB-3510-1 (e.g. flow rate determination shall be accurate to within +/- 2% of actual). For individual analog instruments, the required accuracy is percent of the full-scale. For digital instruments, the required accuracy is over the calibrated range. For a combination of instruments, the required accuracy is loop accuracy. [emphasis added]
The published ASME OM Code Case OMN-32 does not include the requirements if a licensee uses an analytical method to determine the parameters instead of an instrument.
Please address the instrument accuracy parameters determined by the analytical method instead of an instrument (when no instrument is installed) at the CEG facilities in the Alternative Request while using Code Case OMN-32.
Attachment Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Page 3 of 4 CEG RESPONSE Constellation Energy Generation, LLC (CEG) does utilize analytical methods to determine pump test parameters. However, CEG will not be utilizing American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) Code Case OMN-32 for parameters determined by analytical methods. CEG facilities will follow the OM Code requirements or pre-authorized alternatives as approved without modification when a pump test parameter is determined by analytical methods instead of measurement. CEG will include guidance in governance procedures to ensure OMN-32 is not applied to pump test parameters determined by analytical methods.
RAI-EMIB-02 ASME OM Code, paragraph ISTB-3510(b)(2) of the ASME OM Code-2001 through 2004 editions including OMa-2005 Addenda states that Digital instruments shall be selected such that the reference value does not exceed 70% of the calibrated range of the instrument. ASME OM Code, paragraph ISTB-3510(b)(2) of the ASME OMb-2006 Addenda through ASME OM Code-2022 edition states that Digital instruments shall be selected such that the reference value does not exceed 90% of the calibrated range of the instrument. Further, Code Case OMN-6, Alternate Rules for Digital Instruments, allows alternative requirements to ISTB-3510(b)(2) (OM-2001 through 2005a) and states that digital instruments may be selected such that the reference value does not exceed 90% of the calculated range of the instrument.
The licensee is requested to address how both 70% and 90% calibrations or Code Case OMN-6 (if used) are taken into account in Code Case OMN-32 while calculating the required instrument accuracy as specified in Table 1.
CEG RESPONSE All CEG facilities are committed to the 2004 / 2006 Addenda, 2012 or 2017 OM Code Editions as detailed in Table 2.1, of the Reference. Each of the applicable OM Code Editions contain the range requirement that digital instruments shall be selected such that the reference value does not exceed 90% of calibrated range of the instrument. No CEG facilities implement earlier OM Code Editions that contain the 70% of the calibrated range requirement nor use Code Case OMN-6.
CEG facilities will follow the Code Case OMN-32 Range requirement and ensure the reference value does not exceed 90% of the calibrated range of a digital instrument as required in each facilities OM Code of Record.
Attachment Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests Page 4 of 4 RAI-EMIB-03 Alternative Request, Section 2, second paragraph, states that CEG has verified that the currently approved Alternative and Relief Requests for all other sites listed in Table 2.1 are not impacted by the applicability of this Alternative Request.
- 1. Please describe any impact of this request on the authorized Alternative Request RP-04 at LaSalle for use of Code Case OMN-19, Alternative Upper Limit for the Comprehensive Pump Test (ML17024A265).
- 2. Please describe any impact of this request on the authorized Alternative Request 11-PRR-1 at Limerick for use of Code Case OMN-16, Use of a Pump Curve for Testing (ML20280A757) for emergency service water (ESW) pumps 0A-P548, 0B-P548, 0C-P548 and 0D-P548.
CEG RESPONSE CEG will utilize Code Case OMN-32 as an option when implementing LaSalles RP-04 and Limericks 11-PRR-1 existing approved Alternative Requests.
LaSalle Alternative Request RP-04 was approved to utilize Code Case OMN-19, Alternative Upper Limit for the Comprehensive Pump Test. Code Case OMN-19 provides an option that a multiplier of 1.06 times the reference value may be used in lieu of the 1.03 multiplier for the comprehensive pump tests upper Acceptable Range criteria and Required Action Range, High criteria referenced in the ISTB test acceptance criteria tables as listed in Code Case OMN-19, Table 1. Code Case OMN-19 does not alter the OM Code test instrumentation requirements. Code Case OMN-32 has been determined to have equivalent instrument requirements to the existing OM Code requirement and therefore application of Code Case OMN-32 does not impact LaSalles approved Alternative Request RP-04.
Limerick Alternative Request 11-PRR-1 was approved to utilize Code Case OMN-16, Revision 1, Use of a Pump Curve for Testing. Code Case OMN-16 provides an option to use a reference curve and acceptance criteria in lieu of a single reference point when system flow is impractical to adjust to a specific reference value. Code Case OMN-16 does not alter the OM Code test instrumentation requirements. Code Case OMN-32 has been determined to have equivalent instrument requirements to the existing OM Code requirement and therefore application of Code Case OMN-32 does not impact Limericks approved Alternative Request 11-PRR-1.