ML13296A584

Issuance of Amendment No. 273, Revise Current Licensing Basis of Pipe Break Criteria for High Energy Line Breaks (Exigent Circumstances)

ML13296A584
Person / Time
Site:	Fort Calhoun
Issue date:	10/25/2013
From:	Joseph Sebrosky Plant Licensing Branch IV
To:	Cortopassi L Omaha Public Power District
Sebrosky J
References
TAC MF2869
Download: ML13296A584 (26)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 25, 2013 Mr. Louis P. Cortopassi Site Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station 9610 Power Lane, Mail Stop FC-2-4 Omaha, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 -ISSUANCE OF EXIGENT AMENDMENT RE: REVISE CURRENT LICENSING BASIS FOR PIPE BREAK CRITERIA FOR HIGH ENERGY PIPING OUTSIDE OF CONTAINMENT (TAC NO. MF2869)

Dear Mr. Cortopassi:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 273 to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1.

The amendment consists of changes to the Updated Safety Analysis Report (USAR) in response to your application dated October 6, 2013, as supplemented by letters dated October 15, 21, and 22, 2013, and two letters dated October 23, 2013.

The amendment authorizes the use of NRC guidance provided in Branch Technical Position Mechanical Engineering Branch 3-1, Revision 2, which allows for the exemption of specific piping sections from postulated failures if certain criteria are met.

This amendment is being issued under exigent circumstances in accordance with paragraph 50.91 (a)(6) of Title 10 of the Code of Federal Regulations. The exigent circumstances and final no significant hazards considerations are addressed in Sections 4.0 and 5.0 of the enclosed Safety Evaluation.

L. Cortopassi The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Jo e M. Sebrosky, Senior Pr PI nt Licensing Branch IV vision of Operating Reactor Licensing ffice of Nuclear Reactor Regulation Docket No. 50-285

Enclosures:

1. Amendment No. 273 to DPR-40

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OMAHA PUBLIC POWER DISTRICT DOCKET NO. 50-285 FORT CALHOUN STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 273 Renewed License No. DPR-40

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Omaha Public Power District (the licensee), dated October 6, 2013, as supplemented by letters dated October 15, 21, 22, 2013, and two letters dated October 23, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changes to the Fort Calhoun Station, Unit 1, Updated Safety Analysis Report and, as indicated in the attachment to this license amendment, and paragraph 3.B. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 273, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented upon approval.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and Technical Specifications Date of Issuance: October 25, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 273 RENEWED FACILITY OPERATING LICENSE NO. DPR-40 DOCKET NO. 50-285 Replace the following page of the Renewed Facility Operating License No. DPR-40 with the attached revised page. The revised page is identified by amendment number and contains vertical lines indicating the areas of change.

License Page REMOVE INSERT (4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is, subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 273 are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

OPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The OPPD CSP was approved by License Amendment No. 266.

Renewed Operating License No. DPR-40 Amendment No. 273

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 273 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By application dated October 6, 2013 (Reference 1), as supplemented by letters dated October 15, 21, and 22, 2013 (References 2, 3, and 4), and two letters dated October 23, 2013 (References 5 and 6), Omaha Public Power District (OPPD, the licensee) submitted a license amendment request (LAR) that proposes to revise the Fort Calhoun Station, Unit 1 (FCS),

Updated Safety Analysis Report (USAR) for pipe break criteria for high energy piping outside of containment. The amendment allows the use of U.S. Nuclear Regulatory Commission (NRC) guidance provided in Branch Technical Position (BTP) Mechanical Engineering Branch (MEB) 3-1, Revision 2, which allows for the exemption of specific piping sections from postulated failures if certain criteria are met.

The supplemental letters dated October 15, 21, and 22, 2013, and the two letters dated October 23, 2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published in the Omaha-World Herald located in Omaha, Nebraska, from October 9 through October 15, 2013.

2.0 REGULATORY EVALUATION

FCS was licensed to the draft General Design Criteria (GDC) published for comment in the Federal Register (32 FR 10213) on July 11, 1967, and FCS USAR Appendix G, "Responses to 70 Criteria," contains discussions for how the plant design meets each of the 70 draft GDC.

Draft GDC 40, "Missile Protection," states, "protection for engineered safety features shall be provided against dynamic effects and missiles that might result from plant equipment failures."

The Appendix G discussion of draft GDC 40 concludes that the criterion is met.

Analyses for the dynamic effects of high energy piping ruptures outside the containment were performed in response to a letter from the Atomic Energy Commission (AEC) dated Enclosure 2

December 14, 1972 (herein referred to as the Giambusso Letter) 1 . The Giambusso Letter detailed required information for the evaluation of the effects of a high-energy line break (HELB). Criteria provided in the Giambusso Letter were used to identify high energy systems, evaluate the effects of a HELB at FCS, and determine the subsequent availability of equipment required to shut down the reactor. The results of this analysis were submitted to the AEC and were approved in a safety evaluation (SE) dated April 23, 1973 (Reference 8).

FCS USAR Appendix M, "Postulated High Energy Line Rupture Outside the Containment,"

summarizes the analysis that was performed in response to the Giambusso Letter. Appendix M identifies the high energy systems at FCS and also identifies those systems that require protection from the effects of a HELB.

The licensee is proposing in Reference 1 to incorporate into the current licensing basis (CLB) criteria for postulating pipe failures outside containment that are contained in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants:

LWR [Light-Water Reactor] Edition," (SRP) Sections 3.6.2 BTP MEB 3-1, Revision 2.

According to FCS's USAR, Appendix M, the CLB criteria for postulating high energy line piping failures outside containment are in accordance with the Giambusso Letter. This letter is referred to as the "AEC criteria". According to the AEC criteria, a licensee is required to postulate HELBs at terminal ends, including containment penetrations, which are not based on pipe break stress threshold criteria. In addition, according to the AEC criteria, a licensee is required to postulate critical pipe cracks at the most adverse locations, which could be anywhere along the pipe. The AEC criteria did not allow postulation of high-energy line cracks (HELCs) based on piping stress threshold criteria. The licensee has proposed to incorporate, in the FCS licensing basis, certain sections of the BTP MEB 3-1, Revision 2 stress threshold criteria pertaining to American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code), Section Ill Class 2 and 3 piping, including the section of MEB 3-1 which excludes postulating piping failures, breaks and cracks, in the containment penetration areas (including containment penetrations), if certain criteria are met, including meeting pipe stress threshold criteria. In applying the pipe stress threshold criteria for breaks and cracks, the MEB 3-1, Revision 2 code of Reference for pipe stress analysis is the ASME Code, Section Ill, 1986 Edition.

3.0 TECHNICAL EVALUATION

The LAR proposes several modifications to the FCS USAR including the following:

• An editorial change to the definition of a high energy system in USAR Appendix M and removes a portion of the nitrogen system from the list of high energy systems in Table M-2-1.

Appendix B of NUREG-0800, Chapter 3, BTP 3-3, Revision 3, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment," dated March 2007 (Reference 7) consists of the attachment to the Giambusso Letter. Appendix B of BTP 3-3, Revision 3, also includes an errata sheet for the attachment that was sent in January 1973 to recipients of the original letters. Appendix B of BTP 3-3, Revision 3, has been corrected for the errata.

• The addition of Table M-2-2 to the USAR, detailing the modified break postulation criteria from MEB 3-1 that would be applied to high energy systems.

• Incorporation in the licensing basis of certain sections of the BTP MEB 3-1, Revision 2 stress threshold criteria pertaining to ASME Code, Section Ill Class 2 and 3 piping. The incorporation of the proposed MEB 3-1, Revision 2 criteria are to be utilized in the postulation of HELBs and HELCs for portions of the following systems: Chemical Volume Control System (CVCS), Steam Generator Slowdown, and Main Steam Supply to the Turbine-Driven Auxiliary Feed Pump.

Section 3.1 of this SE provides an evaluation of the change to the definition of high energy systems and the addition of Table M-2-2 to the USAR. Section 3.2 of this SE provides an evaluation of the incorporation of certain section of BTP MEB 3-1, Revision 2.

3.1 Evaluation of Definition of High Energy Systems and Addition of Table M-2-2 to the USAR FCS USAR Appendix M defines a high energy system as "all systems outside the containment whose design temperatures exceed 200°F [degrees Fahrenheit] or whose design pressures exceed 275 psig [pounds per square inch gauge)." Appendix M, Table M-2-1, lists the systems that meet these criteria at FCS.

The LAR revises the definition of a high energy system in USAR Appendix M to state, "all systems outside the containment whose service temperatures exceed 200°F or whose design pressures exceed 275 psig." Use of the service temperature, rather than design temperature, to define high energy systems matches existing statements in later sections of USAR Appendix M.

The NRC staff compared the proposed revision to the definition of a high energy system to the text of the Giambusso Letter and the original licensing correspondence referenced in the LAR.

The Giambusso Letter defines a high energy system based on the service temperature, and not the design temperature. The original licensing submittal dated May 15, 1973, from the licensee to the AEC defined high energy systems based on the service temperature. In its review, the NRC staff did not discover any documentation to indicate that design temperatures, rather than service temperatures, were previously used at FCS to identify high energy systems. Therefore, the NRC staff concludes that the proposed change to the definition of a high energy system in USAR Appendix M is an editorial correction and has no impact on the existing systems identified as high energy systems.

The LAR removes a portion of the nitrogen system from the listing of high energy systems in Table M-2-1. This portion of the nitrogen system has a listed service temperature of 100 °F and a design pressure of 275 psig. These conditions do not meet either the previous or the revised definition of a high energy system found in the current version of the USAR or the definition proposed in the LAR. Nor does it meet the definition for a high energy system found in the Giambusso Letter. This portion of the nitrogen system has a relatively low internal energy and, therefore, is not required to be treated as a high energy system. The NRC staff concludes that the removal of this portion of the nitrogen system from Table M-2-1 is acceptable, because it does not meet the definition of a high energy system.

The LAR requests the use of criteria from MEB 3-1 in order to exclude postulated HELB locations based on pipe stress and other factors. These adopted criteria are captured in proposed USAR Table M-2-2. By letter dated October 22, 2013 (Reference 4), in response to EMCB-RAI-7 of the NRC staff's request for additional information (RAI) dated October 9, 2013 (Reference 9), the licensee proposed the addition of criteria B.3.c(2), B.3.c(3), and B.3.c(4) of MEB 3-1, with modifications, to Table M-2-2.

Criterion B.3.c(2) was modified to remove a Reference to moderate energy lines. The current licensing basis does not address postulated leakage cracks in moderate energy piping.

Therefore, the NRC staff concludes that the addition of MEB 3-1 Criterion B.3.c(2), as modified, is acceptable.

Criterion B.3.c(3) was not modified from the text of MEB 3-1. The NRC staff concludes that the addition of this criterion is acceptable.

Criterion B.3.c(4) was modified to state, "The flow from the leakage crack should be assumed to result in an environment that wets all unprotected components within the vicinity, with consequent flooding in the compartment and communicating compartments." The guidance of MEB 3-1 suggests assuming an environment that wets all unprotected components within the compartment. By letter dated October 22, 2013 (Reference 4), in response to the NRC staff's EMCB-RAI-7 dated October 9, 2013, the licensee described how "components within the vicinity" of a leakage crack would be identified. High-temperature, high-pressure lines are considered capable of wetting components within a distance of 10 pipe diameters. Low-temperature lines are considered capable of wetting components within the range of a liquid spray from the leakage crack. Lines with high temperature and low pressure will be considered capable of wetting components within 10 pipe diameters or the distance of a liquid spray from the leakage crack, whichever is farthest.

The NRC staff compared the proposed modification of Criterion B.3.c(4) to the original text in MEB 3-1. The assumption that a leakage crack wets all components in a compartment is provided in MEB 3-1 for conservatism. The actual distance of spray from a leakage crack will vary with the conditions at each postulated crack. The use of 10 pipe diameters as the distance for wetting from a leakage crack in a high-temperature, high-pressure line is based upon data provided in NUREG/CR-2913, "Two-Phase Jet Loads," January 1983 (Reference 10). For a leakage crack in a high-temperature, high-pressure line, wetting within 10 pipe diameters does not comprise the full set of environmental effects. Necessary components further than 10 pipe diameters from the leakage crack must still be designed for the increased humidity and any other environmental effects resulting from a leakage crack in a high-temperature, high-pressure line. The liquid spray from a leakage crack in a low temperature line travels a distance that can be calculated based on the conditions in the piping at that point. As described, the modified Criterion B.3.c(4) represents a case-by-case calculation of the potential distance for wetting effects resulting from a leakage crack and does not eliminate or reduce the requirement to protect necessary components from additional environmental effects within the compartment.

Therefore, the NRC staff concludes that the addition of MEB 3-1 Criterion B.3.c(4), as modified, is acceptable.

By letter dated October 15, 2013 (Reference 2), in response to EMCB-RAI-11 dated October 9, 2013, the licensee proposed the addition of MEB 3-1 Criterion B.1.c(5), with modifications, to

USAR Table M-2-2. The original text of Criterion B.1.c(5) states, "safety-related equipment must be environmentally qualified in accordance with SRP Section 3.11." However, the environmental qualification of equipment at FCS is not licensed to the guidance of SRP Section 3.11. The modified wording proposed by the licensee details how environmental qualification for safety-related equipment will be provided through currently licensed programs.

The use of existing plant processes for environmental qualification of equipment with respect to the effects of postulated pipe ruptures and leakage cracks meets the intent of the original criterion. Therefore, the NRC staff concludes that the addition of MEB 3-1 Criterion B.1.c(5) acceptable.

By letter dated October 15, 2013 (Reference 2), in response to SBPB-RAI-3 dated October 9, 2013, the licensee provided additional information describing modifications related to HELB mitigation that were made to the plant. These modifications were performed via the 10 CFR 50.59 process and are not addressed in the LAR.

By letter dated October 15, 2013 (Reference 2), in response to SBPB-RAI-4 dated October 9, 2013, the licensee clarified that the licensing basis for high energy systems at FCS excludes those systems that that are not normally pressurized. The exclusion of these systems is stated in the original licensing submittal approved by the AEC in the SE dated April 23, 1973. No modification to the list of systems classified as high energy was made in the LAR.

3.1.1 Conclusion Regarding Definition of High Energy Systems and Addition of Table M-2-2 to the USAR The LAR proposes an editorial change to the definition of a high energy system in USAR Appendix M and removes a portion of the nitrogen system from the list of high energy systems in Table M-2-1. As described in the LAR, these changes correct the content of USAR Appendix M with respect to licensing basis for identifying high energy systems. The LAR proposed the addition of Table M-2-2 to the USAR, detailing the modified break postulation criteria from MEB 3-1 that would be applied to high energy systems. The NRC staff has reviewed the LAR and RAI responses, as supplemented, and concludes that the proposed changes to the HELB licensing basis are acceptable.

3.2 Evaluation of BTP MEB 3-1. Revision 2 Stress Threshold Criteria Pertaining to ASME Section Ill Class 2 and 3 Piping Outside Containment According to the licensee's letter dated October 6, 2013 (Reference 1), the incorporation of the proposed MEB 3-1, Revision 2 criteria are to be utilized in the postulation of HELBs and HELCs for the following high energy line piping:

• eves Charging o High energy portion of the Charging system piping from the Charging pump discharge (CH-1A/1 B/1 C) to the containment penetration.

• CVCS Letdown

o High energy portion of the Letdown system piping from the containment penetration to PCV-21 0.

• Steam Generator Slowdown o High energy portion of the Steam Generator Slowdown (SGBD) piping from the containment penetration to the Slowdown Tank FW-7, the Slowdown Tank to the SGBD transfer pumps (FW-34NB), and from the SGBD transfer pumps to the Raw Water system branch tee.

• Main Steam Supply to Turbine Driven Auxiliary Feed Pump FW-10 o High energy portion of the Main Steam supply lines from the Main Steam Line Branch tees to YCV-1045.

The NRC staff's review focused on the effects that the proposed LAR may have on the implementation of criteria for postulating HELBs and HELCs in high energy lines outside containment.

In order to use the MEB 3-1, Revision 2 pipe stress threshold criteria in Reference 1, the piping stress analysis shall be performed in accordance with the 1986 ASME Section Ill and material allowable values from the original code of construction shall be utilized. The licensee confirmed in its letters dated October 6 and 15, 2013, that this is how the pipe stress analysis is being performed.

For allowance of implementing pipe break stress threshold criteria from MEB 3-1, Revision 2 in FCS's CLB that Reference 1 requested, stresses developed in the pipe pressure boundary wall due to pipe integral welded attachments (IWA) shall be added to the code stress equations. By letter dated October 15, 2013, in response to EMCB RAI-2 dated October 9, 2013, the licensee demonstrated that stresses due to IWA are calculated and added to code pipe stresses in accordance to current design basis (CDB) procedures, which include NRC approved code cases N-318 and N-392. Therefore, the NRC staff concludes that the licensee's response for considering stresses due pipe IWA is acceptable when implementing the proposed LAR pipe break stress threshold criteria from MEB 3-1, Revision 2.

The licensee's response to staff's EMCB RAI-3 (Reference 2) also demonstrated that calculated pipe stresses in the Reference 1 pipe break stress threshold criteria from MEB 3-1, Revision 2, in addition to considering seismic loads in the piping analysis shall also include any other applicable loads from the station's CDB procedures for normal and upset (level A and level B) operating conditions, including applicable safety relief valve loadings. This meets the intent of MEB 3-1, Revision 2, Footnote 2 for pipe stresses developed from plant Level A and Level B loading conditions and, therefore, is acceptable. in Reference 1 identifies plant modifications that the licensee has installed to satisfy MEB 3-1, Revision 2 requirements. The licensee has stated that if additional modifications are required, those will be evaluated under the 10 CFR 50.59 process.

3.2.1 Use of SRP 3.6.2, MEB 3-1, Revision 2, Section B.1.b for the Postulation of Breaks and Cracks in Containment Penetration Areas The licensee has requested to utilize Section B.1.b to establish exclusion zones specifically for breaks and cracks in containment penetration areas for the CVCS Charging and Letdown, and the SGBD lines.

According to Section B.1.b, breaks and cracks need not be postulated in those portions of piping from containment wall to and including the inboard and outboard isolation valves if certain requirements are met. The proposed LAR shows that the Section B.1.b criteria shall be met to qualify excluding breaks and cracks in these containment penetration areas for the above mentioned lines and, therefore, the NRC staff concludes that using Section B.1.b is acceptable for the above-mentioned lines.

3.2.2 Use of SRP 3.6.2, MEB 3-1, Revision 2, Subarticle B.1.c(2) for Postulation of Pipe Breaks in Class 2 and Class 3 (ASME Section Ill) piping in Areas Other than Containment Penetration The licensee has requested to utilize Subparagraphs B.1.c(2)(b)(i) and B.1.c(2)(b)(ii) for postulating HELBs outside containment in the CVCS Charging and Letdown, and Main Steam supply lines to the auxiliary feedwater pump turbine.

According to Paragraph B.1.c(2)(a), breaks need to be postulated for each piping and branch run at terminal ends. In addition, breaks need to be postulated at intermediate locations either by piping configuration outlined in B.1.c(2)(b)(i) or by certain pipe stress threshold criteria defined in B.1.c(2)(b)(ii). The LAR shows that either the configuration requirements of B.1.c(2)(b)(i) or the pipe stress break threshold criteria of B.1.c(2)(b)(ii) shall be utilized for postulating breaks in the above mentioned pipe lines and, therefore, the NRC staff concludes that using Subparagraphs B.1.c(2)(b)(i) and B.1.c(2)(b)(ii) is acceptable.

MEB 3-1, Revision 2, Article B.1.c provides a definition for terminal ends which clearly explains in what cases a branch connection is not classified as a terminal end. The AEC criteria did not provide a specific definition for terminal ends. Although the AEC criteria did not provide a specific definition, it included the following statement in Footnote 3:

A piping run interconnects components such as pressure vessels, pumps, and rigidly fixed valves that may act to restrain pipe movement beyond that required for design thermal displacement. A branch run differs from a piping run only in that it originates at a piping intersection, as a branch of the main pipe run.

MEB 3-1, Revision 2, Footnote 3 provides the following terminal end definition:

Extremities of piping runs that connect to structures, components (e.g., vessels, pumps, valves), or pipe anchors that act as rigid constraints to piping motion and thermal expansion. A branch connection to a main piping run is a terminal end of the branch run, except where the branch run is classified as part of a main run in the stress analysis and is shown to have a significant effect on the main run behavior. In piping runs that are maintained pressurized during normal plant

conditions for only a portion of the run (i.e., up to the first normally closed valve),

a terminal end of such a runs is the piping connection to this closed valve."

By letter dated October 23, 2013 (Reference 5), in response to EMCB RAI-4 dated October 9, 2013, the licensee proposed to include Paragraph B.1.c(2)(a) along with the above MEB 3-1 Footnote 3 terminal end definition, with the following supplemental note:

A normally closed valve is not considered a terminal end if the valve is part of the pipe the stress analysis (which includes seismic) and the valve is not supported as an anchor.

The proposed definition provides a clear direction as to when to take a terminal end break. It also meets both the intent of MEB 3-1, which identifies when a branch connection is defined as terminal end, and the intent of the AEC criteria, which imply that when a valve is rigidly fixed, it then qualifies as a terminal end. Therefore, the NRC staff concludes that the licensee's proposed terminal end definition is acceptable.

3.2.3 Use of SRP 3.6.2, MEB 3-1, Revision 2, Subarticles B.1.c(3) and B1.c(4)

The licensee requested to utilize Subarticle B.1.c(3) for postulating HELBs outside containment at intermediate locations in the SGBD lines.

According to Subarticle B.1.c(3) breaks in seismically analyzed non-ASME Code Class piping are postulated according to the same requirements for ASME Code Class 2 and 3 piping shown above in Subarticle B.1.c(2). The NRC staff notes that the intension of the AEC criteria, included postulating breaks in seismically analyzed non-ASME Code Class piping using the same criteria as those used to postulate breaks for ASME Class 2 and 3 piping. Therefore, the NRC staff concludes that the proposed request to adopt Subarticle B.1.c(3) is acceptable.

In Footnote 4, Subarticle B.1.c(3) provides guidance for the interaction of non-Category I (non-seismically analyzed) piping with seismic Category I piping. By letter dated October 23, 2013 (Reference 6), in response to EMCB RAI-6 dated October 9, 2013, the licensee stated that non-Category I piping systems shall be designed to be isolated from any seismic Category I piping system by either a constraint or barrier or should be located remotely from the seismic Category I piping system. If isolation of the Category I piping systems is not feasible or practical, adjacent non-Category I piping systems shall be analyzed similar to the Seismic Class I piping. The licensee's response to EMCB RAI-6 (Reference 6) also noted that the interface where non-Category I piping is attached to Category I piping will be designed in accordance with CDB plant procedures so as to not affect the structural integrity of the Category I piping. The NRC staff concludes that the licensee's response to EMCB RAI-6 is acceptable since it provides reasonable assurance that failure of any non-seismically analyzed piping will not cause a loss of function of any Category I or safety-related piping.

Additionally, by letter dated October 21, 2013 (Reference 3), the licensee responded to EMCB RAI-1 0 dated October 9, 2013, and added the following statement to Reference 1:

If a structure separates a high energy line from an essential component, that separating structure should be designed to withstand the consequences of the

pipe break in the high-energy line which produces the greatest effect at the structure.

The NRC staff concludes that the licensee's response is acceptable since it meets the intent of MEB 3-1, Revision 2, Subarticle B.1.c(4), which requires a licensee to consider the HELB with the greatest effect on structures designed to separate a high energy line from any other essential components.

3.2.4 Use of SRP 3.6.2, MEB 3-1, Revision 2, Article B.1.d Article B.1.d was fully adopted in the proposed LAR. The NRC staff concludes that the incorporation of Article B.1.d is acceptable since B.1.d specifies that a pipe designer identify each piping run considered when postulating break locations required by B.1.c. Article B.1.d also provides guidance for complex systems.

3.2.5 Use of SRP 3.6.2, MEB 3-1, Revision 2, Subarticles B.1.e(2) and B.1.e(3)

The licensee has requested to utilize Subarticle B.1.e(2) for postulating HELCs outside containment in the CVCS Charging and Letdown, SGBD, and Main Steam supply lines to the auxiliary feedwater pump turbine.

The AEC criteria required a licensee to postulate critical pipe cracks at the most adverse locations, which could be anywhere along a pipe. The AEC criteria did not allow postulation of cracks based on piping stress threshold criteria. In lieu of the AEC criteria for postulating cracks, the licensee is proposing, with the exception of those portions of piping identified in Article B.1.b (within Containment Penetrations) that was discussed above, to postulate leakage cracks for ASME Code, Section Ill Class 2 or 3 or non-safety class (not ASME Code Class 1, 2, or 3) piping in accordance with the pipe stress threshold criteria defined in Subarticle B.1.e(2).

The licensee indicated in EMCB RAI-8 (Reference 2) response that it would postulate cracks for non-safety-related non-analyzed piping in accordance with the criteria of Subarticle B.1.e(3),

which requires the licensee to postulate leakage cracks at axial locations that produce the most severe environmental effects. Therefore, the NRC staff concludes that the revised criteria to postulate cracks for the piping mentioned above, in accordance with the criteria of Subarticles B.1.e(2) and B.1.e(3), is acceptable.

3.2.6 Use of SRP 3.6.2, MEB 3-1, Revision 2, Subarticle B.3.c(1) and B.3.c(3)

The AEC criteria did not specify a cutoff pipe size for postulating pipe cracks. In July 1973, the AEC issued more refined criteria for postulating piping failures, in the "O'Leary Letter," which defined that through-wall leakage cracks need to be postulated in piping exceeding nominal pipe size of 1 inch. The licensee is proposing to adopt MEB 3-1, Revision 2, Subarticle B.3.c(1 ),

which specifies that leakage cracks need not be postulated in 1 inch and smaller piping. The NRC staff concludes that this requirement is similar to the criterion defined in the "O'Leary Letter" and is, therefore, acceptable.

The licensee is also proposing to utilize MEB 3-1, Revision 2, Subarticle B.3.c(3), which identifies the required size of a leakage crack. This crack size requirement is the same as the AEC criteria. Therefore, the NRC staff concludes that the use of Subarticle B.3.c(3) is acceptable.

3.2.3 Conclusion Regarding Use of BTP MEB 3-1, Revision 2 stress threshold criteria pertaining to ASME Section Ill Class 2 and 3 piping Based on the evaluation noted above, the NRC staff has determined that the proposed changes in methodology concerning postulation of locations for piping failures, breaks, and cracks, in the high energy piping sections outside containment that are included in the proposed LAR and identified above, are acceptable. The NRC staff also determined that there is reasonable assurance that structures, systems, and components (SSCs) important to safety will continue to meet the requirement of draft GDC-40 following plant required modifications described in the proposed LAR. Therefore, the NRC staff concludes that the licensee has provided reasonable assurance that the proposed methodology for postulated piping failures in high energy lines outside containment, which will be implemented by the licensee, provides an acceptable means to adequately protect SSCs important to safety.

4.0 EXIGENT CIRCUMSTANCES

The NRC's regulations contain provisions for issuance of amendments when the usual 30-day public comment period cannot be met. These provisions are applicable under exigent circumstances. Consistent with the requirements in 10 CFR 50.91 (a)(6), exigent circumstances exist when: (1) a licensee and the NRC must act quickly; (2) time does not permit the NRC to publish a Federal Register notice allowing 30 days for prior public comment. The NRC requires the licensee to explain the exigency and why the licensee cannot avoid it, and use its normal public notice and comment procedures.

As discussed in the licensee's application dated October 6, 2013, the licensee requested that the proposed amendment be processed by the NRC on an exigent basis.

In its October 6, 2013, letter, the licensee provided the following as the basis for exigency:

On June 13, 2013, an unevaluated break location in the steam supply to the auxiliary feedwater turbine located in Room 19 of the auxiliary building was identified. The next day, a deficiency was identified with verifying that the Electrical Equipment Qualification (EEQ) Program met all of the criteria for establishing pipe rupture locations in Room 13 of the auxiliary building. These issues are documented in the Fort Calhoun Station Corrective Action Program.

The consequence of these issues is that potential breaks or cracks in high-energy piping could result in environmental conditions being more severe than the equipment in Rooms 13 and 19 is analyzed to sustain during all modes of operation. OPPD promptly addressed these issues by installing a number of modifications as described in Attachment 2.

While these physical improvements were in progress, final discovery of the full extent of this condition was proceeding. This involved a significant effort on

OPPD's part and many resources to comprehensively research the design and licensing basis for high-energy line break (HELB) and the EEQ program at Fort Calhoun Station. These issues extend back to the early 1970's when the plant was licensed and the effort required an in-depth review of numerous calculations and modifications. Full discovery of the extent of condition and the appropriate means to reconcile the design of the plant with the licensing basis was only recently completed. This is due in part to the complexity of the issue in conjunction with the due diligence involved in reviewing the complete history comprising over forty years of calculations and modifications against NRC requirements.

Upon completion of the discovery process, extent of condition, and the design and licensing basis reviews, it was determined that modifications consistent with applicable regulatory standards are not sufficient to fully resolve the HELB and EEQ issues. The need to focus resources on making physical improvements to the plant while using many of the same resources to research the extent of condition and history of this issue prevented its resolution in a more timely manner. Two parallel success paths were pursued; one was to assess the replaced piping using the Part 9900 Operability Process and then implement Generic Letter 87-11 guidance after plant restart. The second was to request a license amendment. Following recent discussions with the NRC, OPPD has concluded that a license amendment is the only viable success path.

An amendment is necessary so that OPPD can consider the piping, mechanical, and electrical systems associated with high-energy line breaks and the EEQ Program operable. These systems and components are directly associated with heat-up of the reactor coolant system and must be returned to operable status to enable subsequent system lineups and testing to occur.

Due to the complex and integrated nature of the activities required to recover from an extended outage, a protracted delay in such a key activity would have a cascading, adverse impact.

The NRC will not use exigent procedures if it determines that the licensee has failed to use its best efforts to make a timely application for the amendment in order to create the exigency and to take advantage of this procedure. However, in this instance, the NRC staff concludes that the licensee made a timely application for the proposed amendment following identification of the issue. The NRC staff concludes that the licensee could not avoid the exigency because until recently OPPD believed that the USAR changes described in its application could be made via a license amendment after the unit was restarted.

OPPD's interpretation of Inspection Manual Chapter 9900, "Operability Determinations and Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety," led them to the initial conclusion that the SSCs associated with the USAR change were operable but non-conforming. However, OPPD only recently concluded that because its operability evaluation was based on changes to the licensing basis to reach the operable but non-conforming conclusion a licensing change was needed. Based on OPPD's

evaluation of the licensing basis change in accordance with 10 CFR 50.59, the licensee determined that prior NRC approval was needed for the licensing basis change.

The NRC staff also concluded that it needed to act quickly and that time did not permit the Commission to publish a Federal Register notice allowing 30 days for prior public comment because the amendment is necessary for the resumption of operations.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION Under the provisions in 10 CFR 50.91 (a)(6), if the NRC has determined that exigent circumstances exist, and if the NRC also determines that the amendment involves no significant hazards consideration, then it will either issue a Federal Register notice providing notice of an opportunity for hearing and allowing at least two weeks from the date of the notice for prior public comment; or it will use local media to provide reasonable notice to the public in the area surrounding a licensee's facility of the licensee's amendment and of its proposed determination consulting with the licensee on the proposed media release and on the geographical area of its coverage. In this case, the NRC published a notice in the Omaha-World Herald located in Omaha, Nebraska, from October 9 through 15, 2013.

The Commission may issue the license amendment before the expiration of the 60-day period provided that its final determination is that the amendment involves no significant hazards consideration. This amendment is being issued prior to the expiration of the 60-day period.

Therefore, a final finding of no significant hazards consideration follows.

The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commission's regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment does not

( 1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. As required by 10 CFR 50.91 (a), the licensee has provided its analysis of the issue of no significant hazards consideration which is presented below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change to the current licensing basis (CLB) utilizes NRC guidance (viz., Branch Technical Position (BTP) MEB 3-1, Revision 2, "Postulated Rupture Locations in Fluid System Piping Inside and Outside Containment" and NRC Generic Letter 87-11 ("Relaxation in Arbitrary Intermediate Pipe Rupture Requirements") regarding the locations where breaks and cracks in high energy piping systems outside containment are to be postulated.

Allowing the use of NRC Generic Letter 87-11 and select sections of BTP MEB 3-1 as the basis for determining postulated break and crack

locations does not result in an increase in either the probability of a high energy line break (HELB) outside containment or the consequences of such a break. The proposed change does not involve any physical changes to the affected high energy systems or components. These systems have previously been modified, as appropriate, to lower the stresses in the piping and to improve the ability to inspect the welds, in accordance with the relevant requirements of NRC Generic Letter 87-11 and BTP MEB 3-1.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change to the current licensing basis (CLB) is a methodology change and does not involve any physical changes to the affected high energy systems or components. No new equipment is being installed nor is any installed equipment being operated in a new or different manner. A HELB outside containment in the affected systems is an accident previously evaluated, as discussed in Section 4.0 of Appendix M to the Fort Calhoun Station, Updated Safety Analysis Report (USAR).

No new interactions between systems or components are created. No new failure mechanisms of associated systems will exist.

Therefore, the amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment provides the regulatory basis for changing the CLB to utilize updated NRC guidance regarding the locations where breaks and cracks in high energy piping systems outside containment are to be postulated. As stated in the Background section of BTP MEB 3-1, Rev. 2:

" ... observation of actual piping failures has indicated that they generally occur at high stress and fatigue locations, such as at the terminal ends of a piping system at its connection to the nozzles of a component. The rules of this position are intended to utilize the available piping design

information by postulating pipe ruptures at locations having relatively higher potential for failure, such that an adequate and practical/eve/ of protection may be achieved."

By requiring that the affected piping be maintained within the stress limits and other limits of Generic Letter 87-11 and the identified sections of BTP MEB 3-1, adequate levels of protection will be maintained.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

The NRC staff has reviewed the licensee's analysis and based on this review as supplemented by the additional considerations below, the staff has determined that the three standards of 10 CFR 50.92 are satisfied.

Regarding the first standard, the relevant aspects of the of postulated high energy line rupture outside of containment and their effect on essential structures and equipment is found in FCS USAR Appendix M. As stated in USAR Appendix M the current licensing basis requires that breaks be postulated at various locations, including the terminal ends of high energy piping sections including containment penetrations. The license amendment adoption of NRC guidance, provided in BTP MEB 3-1, Revision 2 allows the exemption of specific piping sections from postulated failures if certain criteria are met. The criteria found in BTP MEB 3-1, if met, ensures that pipe stresses are sufficiently low and pipe welds are rigorously inspected such that that a pipe break need not be postulated in the portion of the piping meeting the BTP MEB 3-1 criteria. Consequently, adopting the guidance in BTP MEB 3-1 ensures that there is not a significant increase in the probability and thus the consequences of a high energy line break.

Therefore, the NRC staff concludes that the first standard of 10 CFR 50.92 is satisfied.

Regarding the second standard, as discussed above the high energy line break outside containment evaluation is found in FCS USAR Appendix M. The adoption of BTP MEB 3-1 does not create the possibility of a new or different kind of accident from the accident previously evaluated in FCS USAR Appendix M. Rather the adoption of BTP MEB 3-1 provides a methodology for exempting certain piping section from postulated failures if certain criteria are met. Therefore, the NRC staff concludes that the second standard of 10 CFR 50.92 is satisfied.

Regarding the third standard, the NRC staff has approved the use of BTP MEB 3-1 as a methodology for excluding certain pipe sections from consideration. Since the change only removes arbitrary breaks and cracks outside containment and terminal breaks at the containment penetration, no new breaks are created that are not currently included as part of the FCS original design basis. Therefore, the amendment does not involve a significant reduction in a margin of safety. Consequently, the NRC staff concludes that the third standard of 10 CFR 50.92 is satisfied.

Therefore, the NRC staff has determined that the amendment does not involve a significant hazards consideration.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official was notified of the proposed issuance of the amendment. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission made a preliminary finding that the amendment involves no significant hazards consideration which was published in the Omaha-World Herald located in Omaha, Nebraska, from October 9 through 15, 2013.

In response to this publication, the NRC staff received two comments from the same individual.

One of the comments was dated October 15, 2013 (Reference 11 ), and the other comment was dated October 23, 2013 (Reference 12). The comment dated October 15, 2013, provided comments opposing the NRC staff's preliminary determination that the license amendment involved no significant hazards. The October 15, 2013, comment also opposed the LAR being processed under exigent circumstances. The comment dated October 23, 2013, referenced the licensee's RAI response dated October 15, 2013 (Reference 2), providing additional concerns based on the responses found in the licensee's letter. These two comment letters are discussed below.

October 15, 2013. Comment Associated with No Significant Hazards Consideration The portion of the letter applicable to the no significant hazards consideration includes the following information:

The modifications listed in the license amendment request and the requested change to the USAR involve high energy line breaks. A high energy line break raises serious safety issues. High energy line breaks refer to piping that carries pressurized hot water to feed the steam generators and the additional water to the reactor cooling system.

In addition to these modifications, we understand that there are no seals around the high pressure steam pipes, contrary to plant design, where the pipes penetrate walls throughout the plant. If there is ever a pipe break, the high pressure steam could escape through the gap created by the absence of seals and would not be contained in the room where the break occurred. This condition would allow the steam to migrate elsewhere in the facility to sensitive electronics and electrical panels outside the actual break area, causing shorting and extremely dangerous safety issues.

Adding to those safety issues, the public was informed at the public meeting in Omaha on September 24 that inspection has discovered an improper coating

having been applied to the containment building floor. The coating would allow water from a break in the high pressure steam lines to leak into the lower floor of the building. The equipment on the lower floor is not certified for exposure to steam and water.

This was a discovery of a significant safety issue and was not even part of the restart checklist. Just when the public is led to believe that OPPD and the NRC have thoroughly inspected the plant and identified all safety issues, we learn that a rupture in the steam lines could be catastrophic. The improper coating of the floor was a major deficiency that was present from the initial construction of the plant.

All of these facts require that a license amendment be required for the modifications needed to address these problems. And it is obvious that such a license amendment would involve significant hazards. OPPD should not be allowed to get by with simply tweaking the USAR for Fort Calhoun without addressing the real safety problems.

The issues regarding the lack of seals around the high-pressure steam pipes and improper coatings are both outside the scope of the no significant hazards consideration. Regarding the lack of seals around high-pressure steam pipes, the NRC staff believes the commenter is referring to issues identified in Auxiliary Building Room 19. Among other things, this room contains the turbine-driven auxiliary feedwater pump. The motive force for this pump is provided by steam.

The commenter raised a concern that the high-pressure steam could escape through the gap created by the absence of seals and would not be contained in the room where the break occurred. As noted in the licensee's letter dated October 15, 2013 (Reference 2), in response to SBPB RAI-3 dated October 9, 2013 (Reference 9), the licensee made a change to the guard pipes in room 19 in accordance with Engineering Change EC 53202. The change modified the guard pipe around the steam line where it penetrates the roof of Room 19, and extended the guard pipe, which protects the switchgear rooms. The change in the guard pipe prevents steam from reaching Room 19 for a pipe rupture inside the guard pipe and provides a vent path to Room 81, which is qualified for a harsh environment. Therefore, the issue with the guard pipes in Room 19 was addressed via a physical modification to the plant. The modification is subject to NRC inspection and follow-up in accordance with the NRC's inspection procedures. Because the issue has been corrected, it is outside the scope of the no significant hazards consideration.

Therefore, the NRC staff concludes that this comment does not change the staff's determination regarding the significant hazards consideration found in Section 5.0 of this SE.

The issue regarding the improper coating that was raised by the commenter is outside the scope of the LAR. The room that was discussed at the September 24, 2013, public meeting as having an issue with floor coatings is Room 81 in the auxiliary building. This room includes high energy piping that is subject to a postulated HELB including the consequences of such a break.

The concern with improper coatings in Room 81 is that a break in a high energy line in this room could lead to condensed water and steam going to lower rooms in the plant if Room 81 was not properly sealed.

The LAR approves the use of BTP MEB 3-1 as a methodology for excluding certain pipe sections from consideration for a high energy line break. If rooms with lines meet the criteria, a HELB would not have to be considered in these lines and the rooms would not have to be analyzed for the consequences for a break in these high energy lines. Therefore, the comment regarding coatings is outside the scope of this LAR, and, therefore, outside the scope of the no significant hazards consideration. The NRC staff concludes that this comment does not change the staff's determination regarding the significant hazards consideration found in Section 5.0 of this SE.

Although outside the scope of this LAR, the NRC staff will inspect OPPD's corrective action in this area as part of NRC's inspection activities. As appropriate, issues identified during the NRC's inspection process will be documented in an NRC inspection report.

October 15. 2013. Comments Associated with Exigent Circumstances The commenter also provided issues associated with the processing of the amendment under exigent circumstances. Although outside the scope of the no significant hazards consideration the NRC staff notes that its discussion of the exigent circumstances is provided in Section 4.0 of this SE. Heat-up of the plant is part of the start-up process, and the normal comment process would result in significant and unnecessary delays. The NRC staff's careful consideration of OPPD's LAR is presented above.

October 23. 2013. Comments Associated with October 15. 2013. RAI Response The comments include discussions of several of the RAI responses, a reference to a recent event report and a concluding sentence that a formal license amendment processing is required. The comments related to the RAI responses are outside the scope of the no significant hazards consideration. However, the staff's evaluation of the LAR, including the evaluation of the RAI responses can be found in Section 3.0 of this SE. The comment also references event report EN 49452 from FCS dated October 18, 2013. Event report EN 49452 involves the potential for a HELB on the letdown system outside of containment. This issue was identified by the licensee as part of its HELB resolution, and is outside the scope of the LAR.

Similar to issues discussed above, the licensee's resolution of the issues identified in EN 49452 is subject to NRC inspection and will be documented in an NRC inspection report as appropriate. The comment regarding the need for a formal license amendment proceeding is also outside the scope of the no significant hazards consideration. Regardless, the license amendment is being processed in accordance with the requirements found in 10 CFR 50.92, "Issuance of amendment." The opportunity for a public hearing will be provided after issuance of the amendment, pursuant to Commission regulations. Therefore, the NRC staff is issuing the amendment in accordance with the Commission regulations.

Conclusion The NRC staff has concluded, based on the considerations discussed above, that the amendment does not (a) involve a significant increase in the probability or consequences of an accident previously evaluated, or (b) create the possibility of a new or different kind of accident from any previously evaluated, or (c) involve a significant reduction in a margin of safety and, therefore, the amendment does not involve a significant hazards consideration.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

8.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

9.0 REFERENCES

1. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Exigent License Amendment Request 13-08 Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside Containment," dated October 6, 2013 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML13280A297).

2. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information (RAI) for Fort Calhoun Station (FCS) Exigent License Amendment Request (LAR) to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside of Containment," dated October 15, 2013 (ADAMS Accession No. ML13291A127).

3. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Supplemental Response to Request for Additional Information (RAI) for Fort Calhoun Station (FCS) Exigent License Amendment Request (LAR) to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside of Containment," dated October 21, 2013 (ADAMS Accession No. ML13295A080).

4. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Supplemental Response to Request for Additional Information (RAI) for Fort Calhoun Station (FCS) Exigent License Amendment Request (LAR) to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside of Containment, dated October 22, 2013 (ADAMS Accession No. ML13296A066).

5. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Supplemental Response to Request for Additional Information (RAI) for Fort Calhoun Station (FCS) Exigent License Amendment Request (LAR) to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside of

Containment," LIC-13-0154 2 , dated October 23, 2013 (ADAMS Accession No. ML13297A082).

6. Cortopassi, L. P., Omaha Public Power District, letter to U.S. Nuclear Regulatory Commission, "Supplemental Response to Request for Additional Information (RAI) for Fort Calhoun Station (FCS) Exigent License Amendment Request (LAR) to Revise Current Licensing Basis of Pipe Break Criteria for High Energy Piping Outside of Containment," LIC-13-0155 2 , dated October 23, 2013 (ADAMS Accession No. ML13297A083).

7. Appendix B of NUREG-0800, Chapter 3, Branch Technical Position (BTP) 3-3, Revision 3, "Protection Against Postulated Piping Failures in Fluid Systems Outside Containment," dated March 2007 (ADAMS Accession No. ML070800027).

8. U.S. Nuclear Regulatory Commission, "Safety Evaluation of the Omaha Public Power District Fort Calhoun Station, Unit No. 1," dated April 23, 1973 (ADAMS Legacy Accession No. 3001000314).

9. Sebrosky, J. M., U.S. Nuclear Regulatory Commission, e-mail to Omaha Public Power District, "Request for Additional Information Associated with Fort Calhoun High Energy Line Break License Amendment Request (MF2869)," dated October 9, 2013 (ADAMS Accession No. ML13290A002).

10. NUREG/CR-2913, "Two-Phase Jet Loads," January 1983 (ADAMS Accession No. ML073510076).

11. Taylor, W. L., Sierra Club, "Proposed Licensing Amendment at Ft. Calhoun Station Pipe Break Criteria for High Energy Piping," dated October 15, 2013 (ADAMS Accession No. ML13290A092).

12. Taylor, W. L., Sierra Club, "Ft Calhoun License Amendment," dated October 23, 2013 (ADAMS Accession No. ML13297A047).

Principal Contributors: Evan Davidson Alexander Tsirigotis Joe Sebrosky Date: October 25, 2013 2

Note: OPPD provided two supplements to the LAR on the same day (i.e., October 23, 2013).

OPPD's tracking identifier (i.e., LIC-13-0154 or LIC-13-0155) is added to delineate between the two supplements dated the same day.

ML13296A584 *via email OFFICE NRR/DORULPL4/PM NRR/DORULPL4/LA NRR/DE/EMCB/BC* NRR/DSS/SBPB/BC*

NAME JSebrosky JBurkhardt AMcMurtray GCasto DATE 10/25/13 10/25/13 10/24/13 10/25/13 OFFICE OGC (NLO) NRR/DORULPL4/BC NRR/DORULPL4/PM NAME BHarris MMarkley JSebrosky DATE 10/25/13 10/25/13 10/25/13