LIC-15-0043, OPPD Response to Second Round NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-04, Request to Adopt ASME Code, Section Ill, 1980 Edition (No Addenda) as an Alternative to Current Code of Record

OPPD Response to Second Round NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-04, Request to Adopt ASME Code, Section Ill, 1980 Edition (No Addenda) as an Alternative to Current Code of Record

ML15086A545
Person / Time
Site:	Fort Calhoun
Issue date:	03/27/2015
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 14-04, LIC-15-0043, TAC MF4160
Download: ML15086A545 (13)

Text

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fjjjjjfj Omaha Public Power District 444 South 16h Street Mall Omaha, NE 68102-2247 LIC-15-0043 March 27, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

OPPD Response to Second Round NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-04, Request to Adopt ASME Code, Section Ill, 1980 Edition (no Addenda) as an Alternative to Current Code of Record (TAC No. MF4160)

References:

See Page 3 This letter is responding to the Round 2 NRC request for additional information (RAI)

(Reference 4) regarding License Amendment Request (LAR) 14-04 (Reference 1). The Omaha Public Power District (OPPD) responded to the Round 1 NRC RAI (Reference 2) in Reference 3.

LAR 14-04 proposes to revise the Fort Calhoun Station (FCS) Updated Safety Analysis Report (USAR) to allow pipe stress analysis of non-reactor coolant system safety-related piping to be performed in accordance with the ASME BPV Code, Section 1111980 Edition (no Addenda) as an alternative to the current Code of Record.

OPPD's response to the Round 2 NRC RAI is attached.

This letter contains no regulatory commitments.

In accordance with 10 CFR 50.91 , a copy of this letter is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402*

533*6894.

Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LIC-15-0043 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 27,2015.

Respectfully, Louis P. Cortopassi Site Vice President and CNO LPC/CTH/mle Attachments: 1. OPPD Response to Second Round NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-04

2. USAR Markup Pages

3. USAR Clean Pages c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S.M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

U. S. Nuclear Regulatory Commission LIC-15-0043 Page3

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "License Amendment Request (LAR) 14-04, Revise Current Licensing Basis to Adopt American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, Section Ill, 1980 Edition, (no Addenda) as an Alternative to Current Code of Record," dated May 16, 2014 (LIC-14-0043) (ML14143A370)

2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No.1- Request for Additional Information RE: License Amendment Request to Adopt ASME Code, Section Ill, 1980 Edition (no Addenda) as an Alternative to Current Code of Record (TAC No. MF4160)," dated September 24, 2014 (NRC-14-0110)

(ML14259A365)

3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "OPPD Response to NRC Request for Additional Information Round 2 Regarding License Amendment Request (LAR) 14-04, Request to Adopt ASME Code, Section Ill, 1980 Edition (no Addenda) as an Alternative to Current Code of Record (TAC No.

MF4160)," dated January 9, 2015 (UC-15-0002) (ML15009A319)

4. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1 - Request for Additional Information Round 2 Re: License Amendment Request to Adopt ASME Code, Section Ill, 1980 Edition (no Addenda) as an Alternative to Current Code of Record (TAC No. MF4160)," dated February 25, 2015 (NRC-15-005) (ML15043A061)

Ll C-15-0043 Page 1 OPPD Response to Second Round NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-04:

Revise Current Licensing Basis to Adopt American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV)

Code, Section Ill, 1980 Edition, (no Addenda) as Alternative to Current Code of Record

LIC-15-0043 Page2 REQUEST FOR ADDITIONAL INFORMATION OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 By letter dated May 16, 2014, as supplemented by letter dated January 9, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML14143A370 and ML15009A319, respectively), Omaha Public Power District (the licensee) submitted a license amendment request to revise the current licensing basis to adopt the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section Ill, 1980 Edition (no Addenda), as an alternative to the current Code of record.

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in the licensee's application and determined that the additional information below is required in order to complete its formal review.

NRC Question

1. Please verify that the equation numbers listed in the Load Combination Table associated with Note {e) are from the ASME Code, Section Ill, 1980 Edition {no Addenda), and indicate the proposed changes as necessary.

OPPD Response The equation numbers provided in Note (e) of the markup and clean versions of USAR Table F-1 submitted in OPPD's license amendment request (Reference 11) and OPPD's Round 1 RAI response (Reference 3) are incorrect with respect to ASME Code, Section Ill, 1980 (no Addenda). The correct equation numbers for the 1980 Code Edition (no Addenda) are 9, 11, and 13 for Class 2 and 3 piping (Subsections NC and ND). However, rather than correct the equation numbers in Note (e) of USAR Table F-1, the equation numbers will be completely removed. This is necessary because USAR Table F-1 and subsequently Note (e) of Table F-1 are intended to be used for Class 1, 2, and 3 piping and the equations numbers for Class 1 piping do not align with those for Class 2 and 3 piping.

In addition, the load combinations for Service Level A were consolidated to ensure the table is applicable to all three piping classes. The previous separation of Service Level A loads did not translate well when considering Class 1 piping for which the equations and methodology differ when compared to Class 2 and 3 piping.

NRC Question

2. Table F-1 provides a list of Load Combinations; however, only deadweight loads are considered for Service Level A (equation 8 of ASME Code, Section Ill, 1980 Edition).

According to the ASME Code, all sustained loads {including, but not limited to, deadweight loads) must be considered for steam pipe lines or air service piping lines 1

References in this attachment are those noted on Page 3 of the cover letter.

L1 C-15-0043 Page3 which do not contain water. Please explain the basis for limiting the load combinations to only deadweight loads.

OPPD Response The load combination for Service Level A is not only limited to dead weight but also includes pressure and other sustained mechanical loads. Clarification has been provided for Service Level A to indicate that these additional loads must be included. It should be noted that the Load Combination table provided in Note (e) shows how the existing USAR Table F-1 load combinations' will be compared to the service limits provided by the ASME Code. However, the requirements for performing stress analysis in accordance with the ASME code will still be applied as necessary in addition to the load combination stated in the table.

For example, stress analysis of Class 1 piping using Level 8 Service Limits will include consideration of primary and secondary stresses as required by Subsection N8 of the 1980 ASME Code. This requirement is not explicitly stated in the load combination table of Note (e) but will be performed because it is a Code requirement.

• Service Level A load combinations are the exception as they were not originally included in Table F-1 because they were directly governed by the original design code.

NRC Question

3. Service Level C for Note (e) refers to Note (d), which states that the listed load cases and limits apply only to the pressurizer relief valve piping and supports (reactor coolant system (RCS) as defined in Updated Safety Analysis Report (USAR) Table 4.3-6). However, Note (e) of the proposed USAR change, applies only to non-RCS safety-related piping analysis. Therefore, load combinations for non-RCS piping system should not be limited to RCS fluid transient loading as indicated in Service Level C.

Please clarify this apparent inconsistency.

OPPD Response As discussed in the original license amendment request (Reference 1), this change is to be applied to all piping originally designed to the USAS 831.7 Code which specifically excludes the reactor coolant loop piping because it was designed to USAS 831.1. In this case, "non-RCS" was intended to mean non-reactor coolant loop piping. The text of Note (e) has been revised to clarify the piping that is excluded.

NRC Question

4. The licensee indicated that dynamic effects, as applicable to specific operating and accident conditions, were considered in the piping and component design. However, Table F-1 in the proposed USAR change does not address occasional dynamic loadings. Please explain this discrepancy and address where loading from pipe breaks is included.

OPPD Response The original load combinations provided in USAR Table F-1 are simplified and do not provide details of exactly how design and normal operating loadings are composed. More detailed

L1 C-15-0043 Page4 information is provided in FCS procedure CC-FC-309-1 011-AD-MSS-11 , "Design Specification for Piping and Pipe Supports." This procedure indicates which dynamic loads must be considered and references the applicable design code or USAR Table F-1 for stress limits.

LIC-15-0043 Page 1 USAR Markup Pages

USAR-Appendix F Information Use Page 9 of 40 Classification of Structures and Rev. 10 Equipment and Seismic Criteria Table F-1 -Loading Combinations and Primary Stress Limits Primarv Stress Limits Loading Combinations Design Loading +

Vessels

~ ~

1. PM 5. SM PM 5. 1.2Sh Working Design Earthquake Stress Ps + PL ~ 1.5SM Ps + PM ~ 1.2Sh Anchor Bolts F.S.?_4.0 (d)

2. Normal Operating PM< So PM 5. So Within Loadings ~ximum Yield 2

Hypothetical Earthquake Pe ~ 1.5 [1- (~:) ] S0 Pe ~~So cos(!!. x 7r 2 PM)

SD Anchor Bolts

+ (Fluid Transient F.S.?_ 2.0 (d)

Lo~

(d )!gll (b) (c)

3. Normal Operating PM< SL PM~SL Deflection of supports Loadings @pe limited to Rupture + Maximum Hypothetical Earthquak G Pe ~ 1.5 [1- (~) ] SL 2

Pe ~ ~SL cos(!!. x 7r 2 PM)

SL maintain supported equipment within (b) (a), (c) limits shown

USAR-Appendix F Information Use Page 10 of 40 Classification of Structures and Rev. 10 Equipment and Seismic Criteria Table F-1 -Loading Combinations and Primary Stress Limits (Continued)

NOTES:

(a) These stress criteria are not applied to a piping run within which a pipe break is considered to have occurred.

(b) Loading combinations 2 and 3, stress limits for vessels, are also used in evaluating the effects of local loads imposed on vessels and/or piping, with the symbol PM changed to PL.

(c) The tabulated limits for piping are based on a minimum "shape factor". These limits are modified to incorporate the shape factor of the particular piping being analyzed.

(d) These load cases and limits apply only to the Pressurizer relief valve piping and supports.

(e) As an alternative to USAS 831.7. 1968. Class 1. 2. and 3. non-reactor coolant loop piping analysis may also be performed in accordance with ASME Ill. 1980 Edjtion (no Addenda). Material properties shall be from the original code of record (i.e .. USAS 831.7. 1968). Associated stress limits shall be in accordance with ASME Ill. 1980 Edition (no Addenda) for Service Levels as shown below:

Load Combination Service Level A- Design Loading cpressure Weight Other Mechanical Loadings, and Thermal wbera Senlice_i.eveiB:_Oesian Loadinn+ Desian Earthauake Service Level C* Normal Operating Loadings + (Maximum Hypothetical Earthquake + (fluid Transient Loadina (d\Uan Service Level 0: Normal Operating Loadings + (Maximum Hypothetical Earthquake + Pipe Rupture Jg},},

(f) Support analysis will continue to be performed in accordance with the existing licensing basis (i.e .. Seventh Edition.

AISC. American lnstjtute of Steel Construction),

(g) Square-Root-Sum-of-the-Squares may be used to combine loads.

LIC-15-0043 Page 1 USAR Clean Pages

USAR-Appendix F Information Use Page 9 of 40 Classification of Structures and Rev. 10 Equipment and Seismic Criteria Table F Loading Combinations and Primary Stress Limits Primarv Stress Limits Loading Combinations Vessels Piping (e) Supports (f)

1. Design Loading + PM :5. SM PM :5. 1.2Sh Working Design Earthquake Stress Ps + PL :5. 1.5SM Ps + PM :5. 1.2Sh Anchor Bolts F.S.~4.0 (d)

2. Normal Operating PM :5. So PM :5. So Within Loadings + (Maximum Yield Hypothetical Earthquake P8 s; 1.5 [1- (~:/] S0 rr (tr P8 s; -4 S0 cos - X -PM) 2 s0 Anchor Bolts

+(Fluid Transient F.S.~ 2.0 (d)

Loadings (d))(g)) (b) (c)

3. Normal Operating PM :5. SL PM< SL Deflection of supports Loadings+ (Pipe limited to Rupture + Maximum P8 S: 1.5 [ 1- (~~/] SL Ps s; ~SL cos(!!.. x 1r 2 PM)

SL maintain supported Hypothetical Earthquake(g)) equipment within (b) (a), (c) limits shown

USAR-Appendix F Information Use Page 10 of 40 Classification of Structures and Rev. 10 Equipment and Seismic Criteria Table F-1 -Loading Combinations and Primary Stress Limits (Continued)

NOTES:

(a) These stress criteria are not applied to a piping run within which a pipe break is considered to have occurred.

(b) Loading combinations 2 and 3, stress limits for vessels, are also used in evaluating the effects of local loads imposed on vessels and/or piping, with the symbol PM changed to PL.

(c) The tabulated limits for piping are based on a minimum "shape factor". These limits are modified to incorporate the shape factor of the particular piping being analyzed.

(d) These load cases and limits apply only to the Pressurizer relief valve piping and supports.

(e) As an alternative to USAS 831.7, 1968, Class 1, 2, and 3, non-reactor coolant loop piping analysis may also be performed in accordance with ASME Ill, 1980 Edition (no Addenda). Material properties shall be from the original code of record (i.e., USAS 831.7, 1968). Associated stress limits shall be in accordance with ASME Ill, 1980 Edition (no Addenda) for Service Levels as shown below:

Load Combination Service Level A: Design Loading (Pressure, Weight, Other Mechanical Loadings, and Thermal where applicable)

Service Level B: Design Loading + Design Earthquake Service Level C: Normal Operating Loadings + (Maximum Hypothetical Earthquake + (Fluid Transient LoadinQ (d)) (Q))

Service Level D: Normal Operating Loadings + (Maximum Hypothetical Earthquake + Pipe Rupture (Q))

(f) Support analysis will continue to be performed in accordance with the existing licensing basis (i.e., Seventh Edition, AISC, American Institute of Steel Construction).

(g) Square-Root-Sum-of-the-Squares may be used to combine loads.