Text

License Amendment Request (LAR) 15-02, Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.14-2011
	ML15258A680
Person / Time
Site:	Fort Calhoun
Issue date:	09/10/2015
From:	Cortopassi L; Omaha Public Power District
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	ANSI/ANS-58.14-2011, LAR 15-02, LIC-15-0081
	Download: ML15258A680 (61)
	v • d • e

{{#Wiki_filter:OmahaPublic Power District 444 South 16th Street Mall Omaha, NE 68102-2247 LIC-1 5-008 1 September 10, 2015 10 CFR 50.90 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:

License Amendment Request (LAR) 15-02, Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSIIANS-58.1 4-2011 In accordance with the provisions of 10 CFR 50.90, the Omaha Public Power District (OPPD) requests an amendment to revise the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No. 1. The proposed amendment would modify the FCS Updated Safety Analysis Report (USAR) to allow use of the equipment classification methodology in ANSI/ANS-58.14-201 1, Safety and Pressure Integrity ClassificationCriteria for Light Water Reactors. The enclosure contains a description of the proposed changes, the supporting technical analyses, and the significant hazards consideration determination. Attachment 1 of the enclosure provides the existing USAR pages marked-up to show the proposed changes. Attachment 2 of the enclosure provides retyped (clean) pages with the changes proposed by Attachment 1 and denoted by revision bars in the margin. The proposed changes have been reviewed and approved by the Fort Calhoun Station Plant Operations Review Committee (PORC) and by the Nuclear Safety Review Board (NSRB). OPPD requests approval of the proposed amendment by September 30, 2016 in order to minimize the impact on the Design and Licensing Bases Equipment Classification Project, which is part of the Design and Licensing Bases Reconstitution Project that OPPD committed in Reference 6.7 to complete by December 31, 2018. The License Amendment will be implemented by September 30, 2018 following completion of classification of FCS equipment per ANSI/ANS-58.14-201 1. Major milestones to support implementation of the proposed change; Complete initial classification of equipment: December 2016 Scope identified deficiencies into 2018 refueling outage (RFO) March 2017 Complete resolution of deficiencies requiring RFO 2018 RFO Complete final classification of equipment June 2018 Final implementation of LAR September 2018 Employment with Equal Opportunity ,n

U. S. Nuclear Regulatory Commission LIC-1 5-0081 Page 2 The next refueling outage is scheduled for Fall 2016 which would not allow sufficient time to modify any newly classified components that require an outage to perform the work. In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official. There are no regulatory commitments contained within this letter. If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher at (402) 533-6894. I declare under penalty of perjury that the foregoing is true and correct. Executed on September 10, 2015. Louis P. Cortopassi Site Vice President and ONO LPC/MTF/brh

Enclosure:

OPPD's Evaluation of the Proposed Change 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

LIC-1 5-008 1 Enclosure Page 3 OPPD's Evaluation of the Proposed Change License Amendment Request (LAR) 15-02, Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.1 4-2011 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Evaluation 4.3 Precedent 4.4 No Significant Hazards Consideration 4.5 Conclusions 5.0 ENVIRONMENTAL-CONSIDERATION

6.0 REFERENCES

ATTACHMENTS:

1. Markup of Updated Safety Analysis Pages

2. Clean Updated Safety Analysis Pages

LIC-1 5-0081 Enclosure Page 4 1.0

SUMMARY

DESCRIPTION The Omaha Public Power District (OPPD) hereby requests an amendment to the Fort Calhoun Station (ECS), Unit I Renewed Facility Operating License No. DPR-40 to revise the method of equipment classification at FCS as described in the Updated Safety Analysis Report (USAR). OPPD proposes to use the methodology described in ANSI/ANS-58.14-2011, Safety and Pressure Integrity ClassificationCriteria for Light Water Reactors, to classify structures, systems and components (SSCs). This request enables fulfillment of the commitment from Reference 6.7 as stated below: After restart, OPPD will complete a significant effort to perform a risk focused reconstitution of the design basis, the/licensing basis, and the Updated Safety Analysis Report. As part of this reconstitution, OPPD wi// ensure proper classification of equipment. 2.0 DETAILED DESCRIPTION USAR Appendix N, Reclassification of Systems, identifies ANSI/ANS-51 .1-1983 as the guidance document utilized in the establishment of the system safety classification criteria. ANSI/ANS-51 .1-1 983 was incorporated into the USAR subsequent to the original license to use as a guideline to apply to changes to the plant without modifying the existing systems to fully comply with the standard. This has resulted in inconsistent application of the requirements of the standard. ANSI/ANS-51.1-1983 is not directly applicable to ECS since many of the references in the standard were not used in the FCS design, because they either did not exist when the plant was licensed or a different basis was provided in the Licensing Bases. ANSI/ANS 51.1-1983 provides functional criteria based on the associated systems and criteria being applied in 1983. OPPD is currently conducting an equipment classification project at FCS for classification of SSCs in accordance with the FCS Current Licensing Basis (CLB). Application of ANSI/ANS 51.1-1 983 would require significant plant modifications in order to fully comply or approval of numerous deviations from the standard. It is proposed to replace ANSI/ANS-51 .1-1 983 with ANSI/ANS-58.14-2011I in USAR Appendix N since it provides a methodology that can be applied to equipment classification regardless of the year of license. The proposed change to use the methodology of ANSI/ANS-58.14-201 1 also requires related changes to the terminology currently in USAR Appendix N from Critical Quality Element (CQE) (i.e., safety-related), Limited CQE (non-safety-related), and Non-CQE (non-safety-related) to safety-related (Q), non-safety-related with augmented requirements (A), and non-safety-related (N). The potential exists for equipment misclassifications to be identified during the equipment classification project. Should equipment classification upgrades (e.g., from Non-CQE to A or Q, or Limited CQE to Q) be identified, project procedures require that these misclassifications be entered promptly into the FCS corrective action program (CAP) per FCS procedures and processed per FCS procedures, which includes screening by Operations Shift Management for immediate operability and reportability of the misclassified equipment, subsequent review by FCS management, and resolution of the misclassified equipment (e.g., through analysis, commercial grade dedication, modification, licensing change, or other means, as applicable). Should equipment classification downgrades (e.g., from CQE to A or N, or Limited CQE to N) be identified, project procedures allow for multiple equipment misclassifications to be grouped and entered into CAP as one condition report (CR) since downgrades are not operability or functionality concerns. Processing of equipment downgrade CRs are processed per FCS procedures the same as equipment classification upgrade CRs.

LIC-1 5-0081 Enclosure Page 5

3.0 TECHNICAL EVALUATION

The current USAR Appendix N references ANSI/ANS-51 .1-1983 as guidance for equipment classification of mechanical systems. ANSI/ANS-51 .1-1983 provides various design criteria and guidance on the classification of systems. The criteria in ANSI/ANS-51 .1-1 983 are system focused and were written for application to the new designs of pressurized water reactors available in the 1983 time frame. Direct application of ANSI/ANS-51 .1-1 983 is not appropriate since many of the referenced standards and codes were not in existence when FCS was originally designed and licensed. For example, ANSI/ANS-51 .1-1983 references ASME Ill, Class MC for reactor containment steel; however, FCS USAR Section 5.5, Containment Design Criteria, indicates that the FCS containment structure was designed to the requirements of the ASME Boiler and Pressure Vessel Code, Section III, Class B vessels. The specific CLB are contained in the set of NRC requirements applicable to a specific plant and a licensee's' written commitments for ensuring compliance with and operation within applicable NRC requirements and the plant-specific design basis (including all modifications and additions to such commitments over the life of the license) that are docketed and in effect. The CLB includes the NRC regulations contained in 10 CFR Parts 2, 19, 20, 21, 26, 30, 40, 50, 51, 52, 54, 55, 70, 72, 73, 100, and appendices thereto; orders; license conditions; exemptions; and technical specifications. It also includes the plant-specific design-basis information defined in 10 CFR 50.2 as documented in the most recent final safety analysis report (FSAR) as required by 10 CFR 50.71 and the licensee's commitments remaining in effect that were made in docketed licensing correspondence such as licensee responses to NRC bulletins, generic letters, and enforcement actions, as well as licensee commitments documented in NRC safety evaluations or licensee event reports. Specific changes to the original design and licensing basis, such as commitments to later industry guidelines and standards, have been documented in Licensing Basis Documents. For purposes of equipment classification, the criteria and methodology in ANSI/ANS-51.1-1983 are primarily subjective and mechanical system focused. The ANSI/ANS-51.1-1 983 standard does not provide a methodology or approach that can be used to classify equipment based on a plant unique Licensing and Design Basis (i.e., CLB). It also does not provide detailed guidance on addressing boundaries between different mechanical pressure integrity classes (e.g., ASME Ill Class 1 to Non-Safety-Related) or between electrical Class 1E systems and Non-Safety-Related electrical equipment. Therefore, OPPD requests to use the methodology in ANSI/ANS-58.1 4-2011, applied in accordance with the CLB to classify equipment. The criteria in ANSI/ANS-58.14-2011 is primarily objective and is applicable to all nuclear power plant functions, SSCs, and parts. The standard provides a methodology for classification of equipment based on plant specific design and licensing basis. In accordance with the definition of Safety-Related, a Safety-Related SSC or function is: A function, SSC, or part that is relied upon during or following a Design Basis Event to ensure:

1. the integrity of the Reactor Coolant Pressure Boundary (RCPB);

2. the capability to shut down the reactor and maintain it in a safe shutdown condition; or

3. the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the guideline exposures in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

LIC-1 5-008 1 Enclosure Page 6 The methodology of ANSI/ANS-58.14-201 1 includes the following basic steps to identify safety-related items in accordance with the Licensing Basis:

1. Identify design basis events

2. Determine plant-level safety-related functions

3. Determine safety-related systems and structures

4. Determine safety-related components

5. Determine safety-related parts

6. Determine non-safety-related with augmented requirements SSCs

7. Determine non-safety-related SSCs Once the SSCs have been classified as Safety-Related (0), Non-Safety-Related with Augmented Requirements (A)or Non-Safety-Related (N), additional attributes such as Pressure Integrity Class, Electrical Class (Class 1E or Non-Class 1E) and Seismic Category are determined. Seismic Categories' are defined as follows:

Seismic Category I: The designation of an SSC that is designed to perform at least one safety-related function during or following a Design Basis Earthquake. Seismic Category I1: The designation of an SSC that is not Seismic Category I but whose failure mode could prevent a safety-related function during or following a Design Basis Earthquake. Safety-related SSCs (except pipe whip restraints) meet Seismic Category I requirements if they are relied upon during or following a design basis earthquake. SSCs that have not been classified safety-related and whose failure could prevent a safety-related function relied upon during or following a design basis earthquake, and pipe whip restraints that are not classified Seismic Category I, meet Seismic Category II requirements. These SSCs are classified non-safety-related with augmented requirements. ANSI/ANS-58.14-201 1 includes the following classification categories as well as guidance on applying these based on a plant CLB: Safety Class Pressure Integrity Class 2 '3 Electrical Class Seismic Q C-1, 0-2, or 0-3 1E Seismic Category I A C-4 (Non ASME, Section Non 1E Seismic Category III) IIor Non Seismic N C-5 (Non ASME, Section Non 1E Non Seismic Ill) _____________ _______________ 1 Seismic Categories I and Il correspond to Regulatory Guide 1.29, Paragraph C.1 and 0.2, respectively. 2 C-1 corresponds to Quality Group A as defined in 10 CFR 50.55a and C-2, 0-3, and 0-4 correspond to Quality Groups B, C. and D as defined in Regulatory Guide 1.26 3Note that OPPD letter LIC-1 4-0043, License Amendment Request (LAR) 14.04, Revise Current Licensing Basis to Adopt a New Piping Design Code, June 1, 2014, requests acceptance of use of ASME Section IIIfor the analysis of FCS piping.

LIC-1 5-0081 Enclosure Page 7 ANSI/ANS-58.1 4-2011 also provides considerable guidance on the handling of boundaries, such as isolation between electrical Class 1 E systems and non-safety-related electrical equipment or between different mechanical pressure integrity classes (e.g., ASME Ill Class 1 to Class 5) at containment penetrations. For example, a system that has a safety-related function may be connected at a normally closed valve to a system that has no safety-related functions. The boundary from a safety or pressure integrity standpoint may be at the valve; however, unless the valve was supported by a seismic anchor, the analysis would have to extend past the valve to a physical or analytical anchor. Based on the guidance from ANSI/ANS 58.14-2011 Paragraph 4.5.2 (2), some of the supports on the non-safety-related portion may need to be evaluated to assure the safety-related function is maintained. The subject supports would be classified as non-safety-related with augmented requirements, Seismic Category II.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

           .Design Criterion The applicable criteria for SSC quality classification is 10 CFR 50, Appendix A, GDC 1, "Quality Standards and Records." ECS was licensed for construction prior to May 21, 1971, and is committed to the draft General Design Criteria published for comment in the Federal Register on July 11, 1967 (32 FR 10213) in lieu of 10 CFR 50, Appendix A.

Appendix G of the FCS USAR shows that draft GDC 1 is most applicable to the proposed amendment. USAR APPENDIX G, CRITERION 1, QUALITY STANDARDS, Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes or standardson design, materials, fabrication, and inspection are used, they shall be identified. Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modified as necessary. Qualityassurance programs, test procedures, andinspection acceptance levels to be used shall be identified. A showing of sufficiency and applicabilityof codes, standards,quality assuranceprograms, test procedures, and inspection acceptance levels used is required. This criterion is met. Components of the engineeredsafeguards systems are designed and fabricatedin accordance with establishedcodes and/or standardsas required to assure that their qualfity is in keeping with the safety function of the component.

           .NRC Regqulatory Guide 1.26. Quality Group~Classificationsand Standardsfor Water-.
           .Steam-, and Radioactive-Waste-ContaininqComponents of Nuclear Power Plants "This guide describes a method for determining acceptable quality standards for the remaining safety-related components containing radioactive material, water, or steam, i.e.,

quality Group B, C, and D components. Other systems not covered by this guide, such as instrument and service air, diesel engine and its generators and auxiliary support systems, diesel fuel, emergency and normal ventilation, fuel handling, and radioactive waste management systems, should be designed, fabricated, erected, and tested to quality standards commensurate with the safety function to be performed."

LIC-1 5-008 1 Enclosure Page 8 4.2 Evaluation Based on the review of the applicable Code of Federal Regulations, Design Criteria and regulatory guidance, the following conclusions can be drawn: 4.2.1 Design Basis (USAR) Revising the License to use the methodology of ANSI/ANS-58.14-201 1 to classify SSCs in accordance with the FCS Design and Licensing Basis does not impact the ability of existing and future equipment to meet their required safety functions or affect compliance with USAR Appendix G, Criterion 1. The plant will maintain the ability to safely shutdown and be maintained in a safe shutdown condition during the spectrum of Design Basis Events specified in the FCS USAR. Using the methodology from ANSI/ANS-58.14-201 1 will assure that the CLB will be consistently applied to the equipment classification. 4.2.2 Approved Methodologies

10 CFR 50.55a, Codes and Standards.
Regulatory Guide 1.26, Revision 3, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants
Draft General Design Criteria (GDC) published for comment in the Federal Register (32 FR 10213) on July 11, 1967
Regulatory Guide 1.206, Regulatory Position Part I: Standard Format and Content of Combined License Applications, Section C.l.6.3.2.3, Applicable Codes and Classifications 4.3 Precedent ANSI/ANS-58.14-201 1 provides additional guidance that is being used by the industry to classify nuclear systems in accordance with associated regulatory guides and regulations, based on the following from Regulatory Guide 1.206, Regulatory Position Part I: Standard Format and Content of Combined License Applications, Section C.1.6.3.2.3, Applicable Codes and Classifications, which states:

              "The applicant should identify the applicable industry codes and classifications for the design of the system. An acceptable method to implement safety and pressure integrity classification of ECOS components is to use ANSI/ANS-58.14-1 993 (or later version).

ANSI/ANS-58.14-201 1 is based on NRC regulations and guidance and provides a methodology that has been used at many nuclear power plants to facilitate equipment classification. The standard assures conformance with 10 CFR 50.55a and Regulatory Guide 1.26.

LIC-1 5-0081 Enclosure Page 9 4.4 No Significant Hazards Consideration The Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed 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 Updated Safety Analysis Report (USAR) allows the use of the methodology from ANSI/ANS-58.14-20-11, Safety and Pressure Integrity Classification Criteriafor Light Water Reactors, for the classification of structures, systems and components (SSCs) in accordance with the Current Licensing Basis (CLB). These changes are applicable only to the classification of equipment and have no impact on the accidents and transients as defined in the Current Licensing Basis. The methodology of the standard requires that the plant design basis be reviewed and applied to the classification process which assures that there is no significant change in the probability or consequences of accidents. The USAR accident analyses assume the proper functioning of systems in demonstrating the adequacy of the plant's design. The methodology of ANSI/ANS-58.14-2011 is intended to assure equipment is classified correctly and in accordance with the CLB. This change, therefore, does not change the intended function of any plant equipment nor does this change affect or increase the probability of equipment malfunction which could increase the probability or consequences of an accident previously evaluated in the USAR. The proposed change does not degrade the performance of a system assumed to function in the accident analyses. Also, this change does not increase the challenges to safety systems assumed to function in the accident analysis such that safety system performance is degraded below the design basis without compensating effects. FCS is licensed to the requirements of 10 CFR 50.67 and 10 CFR 20. These licensed limits are maintained by radiological barrier performance which is unaffected by this change. Hence, there will be no change in radiological barrier performance that would increase the dose to on-site personnel (10 CFR 20) or the public at the site boundary (10 CFR 100.11/10 CFR 50.67). Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated in the USAR.

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 amendment allows the use of the NRC approved methodology of ANSI/ANS-58.14-2011ito facilitate proper equipment classification. This standard will be used to confirm that equipment has been properly classified in accordance with the FCS Current Licensing Basis. This approach will not introduce any methods or

LIC-1 5-0081 Enclosure Page 10 analytical techniques that could create the possibility of a new or different kind of accident. Application of a classification methodology does not create an accident. No new unanalyzed interactions between systems or components will be created by the application of ANSI/ANS-58.14-201 1. The proposed change does not create a new failure mechanism or new accident initiator. The proposed amendment does not involve a change in methods governing the operation of the plant systems or components. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated in the USAR.

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

Response: No This proposed amendment revises the CLB to allow the use of ANSI/ANS-58.14-201 1 for equipment classification. The proposed change will not modify, change, revise or otherwise affect any current calculations concerning the plant accident analysis or supporting basis for which the Technical Specifications, Technical Specification Bases or USAR safety margins were established. The proposed amendment is consistent with regulatory guidance. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety. Based on the above, OPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified. 4.5 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review of the proposed amendment has determined that the proposed amendment may change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CER 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 (c)(9). Therefore, pursuant to 10 CFR 51 .22(b), no environmental impact statement or environmental assessment needs be prepared in connection with the proposed amendment.

LIC-1 5-0081 Enclosure Page 11

6.0 REFERENCES

6.1 10 CFR 50.55a, Codes and Standards 6.2 Regulatory Guide 1.26, Revision 3, Quality Group Classifications and Standards for Water-, Steam-, and Radioactive-Waste-Containing Components of Nuclear Power Plants 6.3 ANSI/ANS-51 .1-1983, Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants 6.4 ANSI/ANS-58.1 4-2011, Safety and Pressure Integrity Classification Criteria for Light Water Reactors 6.5 Regulatory Guide 1.206, Regulatory Position Part I: Standard Format and Content of Combined License Applications, Section C.1.6.3.2.3, Applicable Codes and Classifications 6.6 NRC Regulatory Guide 1.29, Revision 3, Seismic Design Classification 6.7 Letter from OPPD (L. P. Cortopassi) to NRC (M. L. Dapas), "Integrated Report to Support Restart of Fort Calhoun Station and Post-Restart Commitments for Sustained Improvement," dated December 2, 2013 (LIC-13-0164) (ML13336A785) 6.8 Letter from NRC (M. L. Dapas) to OPPD (L. P. Cortopassi), "Confirmatory Action Letter

          - Fort Calhoun Station," dated December 17, 2013 (N RC-13-0154) (ML13351A395)

LIC-1 5-008 1 Enclosure Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Mark-up of Updated Safety Analysis Report Pages

             /Word-processor mark-ups using "double underline/strikeeut" feature for "new text/deleted text" respectively.]

LIC-1 5-008 1 Enclosure Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 Clean Updated Safety Analysis Report Pages

Page 1 of 30 IUSAR Appendix.N

                         * " "Classification of Structures. Systems, and Components Rev 11 Safety Classification:                Usagle Level:

II I I. .I II Safety Information J No. Chn Chan e No.: Reason for Change: Preparer: Issued: Fort Calhoun Station

USAR Appendix N Information Use Page 2 of 30 Rocla.s.ificati,-,n of Systems" Classification of Structures Systems, and Components Rev. 11 Table of Contents 1.0 PURPOSE.............................................................................. ........ 4 2.0 SAFETY CLASSIFICATION CRITERIA ..................................................... 5 1 .1 Safc,, C"la.se,,5 3.0 SAFETY CLASS INTERFACES..............................................................1 1 2 aftyClsslneo fr rosuo ntgrt o"f Fluid Syste'ms.......11 1* .3"Racto Colans'to"P....r Boun dary... .... c.......- *,............1 15 Exceptons,, to-,,the* Dof...n..d Safet Class, ,,t*a+,,........,..1 2

1. Safety Class Int,,.ila.. f Othero*,, Eqipment*................1

1.0 CORREDL

lv

             ,--,ATIONlk... BETWEEN SAFETY CLASS_            ,.,,qA~NJD EQUIPMENIIkT DEIGN~t*_k CODE*~r  .... 14

5. QUALIT *ASSURANCE "16 1.0 PURPOSE ........................................................................... 4 2.0 SAFETY CLASSIFICATIONS 5 3.0 PRESSURE INTEGRITY CLASSIFICATIONS 11 4.0 SEISMIC CLASSIFICATIONS 14 5.0 BASIC DESIGN REQUIREMENTS 16

6.0 REFERENCES

USAR Appendix N Information Use Page 3 of 30 Reclassification"' of S"y'tem" Classification of Structures Systems, and Components Rev. 11 List of Tables Table N-i - Sy"om*- Safoty Classification*-* Basic Design Requirements............. 19 Table N Cor. a..ion;,,, ,ctc+

                                  .... foty+, Class.. ,,, ,;u....nt Design and,, Qua,.ity, Ass..n.....

System Pressure Integrity Class 30

USAR Appendix N Information Use Page 4 of 30 Rec,.ass.ficaion,, of, S,,tems. Classification of Structures Systems, and Components Rev. 11 1.0 PURPOSE The-,* purpose of this- apndixl is. to* clas-sifythe FCS mechaYr~nica! ytoms.bas'odk** upon, cr~responding#piping,÷*and, componen'*-t codes- of..consrucIon.l_/; Th"e orgnal'lic ,e~nsingh, basis'"*fo the F"o"""3*"".. CahunSato (ECS).....did catgoiz

                                                                       .. "not" sytm       based' on safety"""

Current,-, indust,,-+n sta,-,-ndards* (RG 1.26 and,,- ANI/,AM.NS 51 ....coreat i ....s safety*+, classes.."* o,> to ASME Section. I,, cod.clsse... Because.of.the.similarity. between.the with B3! .7 code"clas.e. This appendix describes the safety. pressure integrity, and seismic classifications used at Fort Calhoun Station (FCS) for structures, systems. and components (SSCs). Regulatory Guido 1.26, rovision 3,1976, Quality Group Classifications and Standards for Water, Stoam, and Radioactive Waste Containing Components of Nuclear Powor Plants. ANSUANS 51.1,1983, Nucloar Safoty Critoria for the Design of Stationary Pressurized Water Reactors.

USAR Appendix N Information Use Page 5 of 30 Reclassificati.o+.n of* Systems-.. Classification of Structures Systems. and Components Rev. 11 2.0 SAFE=TY CLASSIFICATION CRITERIA AmcrIcan~*I1 Nainl Stal I*4,,.ndard ANSI/ANSM 511 Nuclear M* Saf at" Criteria I for the Des VIgn of Stationa,'*.,** DPressunrized Water*, Reator,J,*,*- is the* guidance-*,,,, document,*n utilized, in' the,. establis.hment-, of, the* system-,- safety clasIficatio-.,n criteria.; Based* upn,,, this. standar,*,I-mecrhanical equipment of the nuclear powe plant. Classification shall be done on the bas*is o. deini*.L1.**1.tions contine L *in*. secti onl*.l,* I~qand the. interface/ll%.*V requiremenI,/%#*.*.ts N..1%v*/ of#%.1 ~i. interface for. t.. he FCS mechanical,* systems.- 2.1 SaVI Ity-G IlasseeIVI

IVIV**I Equipment. shall .......be. assigned. to. one of,~,.... the, fi*,.Velclasses, in..* accordanc wit N.,*,.2.1,,

                                                                                                                                   ,.1,,,*,,.,

throughrl ,N21,.5. Teequpmen assigned*, to* SC÷f1h, 2 rll i thatl

                                                                                                            ;relied         upnhn h onem1*4systmv* onl its ownm~           satisfies allV*nula              safety reVIlae        sytmsrqurmet (e~g,   rdunanc, caaciy),   dverityhe    attr sallbe           lasifid       t1th correspondi-,,*w,*ng Safet           Class andb,the' additional system~l                asq,NNS.k,,J *~o,*\

USAR Appendix N Information Use Page 6 of 30 Roclassificatio+;,n of Systca ms, Classification of Structures Systems. and Components Rev. 11 A suppor,,"t'l sha"ll bc" c.'lassified,- to,' thc morc," stringen class,* cor',rcspe*,'nding,, to,.. tIhe funct.ion jeoparize.th f.unction of the* supported* oquipmont; or" (b)*'diecl by* the' supor itsel (eg, esmcCteo' lIcodton). Ehxcepns' , may bc\made,,+h for intcrmcdiate;+*, cleent,(.g.a+h, , load+,.,, beain housi,, ngsof lectricmeter,!valve operators, ,,,, hea.t.,~, .. s~hall be c*lassi--;fiedas- S*C 3_or. NNlSl( in accordance, wit;h eit(her N.2l .3" "h or,.2.1" At, asJ o-f mech,'anicam-,,*l equip.;ment that for-m partv'l ef the Reor,,*, Coo'-lant Pressure* B ..ounda (RPB wh,,- ose failur could cause los of...'" reactor.,v. coolan in excessoo f the reacor'+ coo*lantl norman,-l makeup.. capaboility., The RCPBI is and vales w.. hich are: PartL v of the reco coatsytm n hscotxheratroln I"stom include the,-,.,, reactor,1*oola,-- ntlhoop betweena+ han including',,, the,',,i vessel,-and h,,, ress rize ,'or-+, ,,,.,o'. ,,',ok +,^a 1i,', ,; h penetrates.. ,,,p+mah, t reacto cotimn -,,l, t

                                                                                          ,*+....t          n         ,, ,,;...

nri=r rnnn nntinnl

c. The reactor coolant system safety and relief valves.

USAR Appendix N Information Use Page 7 of 30 Reclassification.. of Systems" Classification of Structures Systems. and Components Rev. 11 whch re onnetedto hc ractr Compnens colan sytem nd re oftcrato oln prsur oudi ,a bo of a leso ,safetyclass pr-ovidod.l+.l r the, co.,mpo,'.mn entis'* orcn be isol,-*ated from,- tlho roactor coo,,,,lantl syste'lm-, by, two.-- valves,(ot/,*h clI,,ose,- botvlh open*,,, or* oner cl.1osed- and~r onemopen). Each..l-opnvle utb capblo auomtio reot attio anasmn the thorvale isopen it cloure imemustbe uch,, that. inv th veto

                 ,valve,' remainh*s operab,-+le* and- the reactor--* can* be* shut dowr-,;n and'r coo,,',I*le                                            do,',wn in' an-orderly manner,*.~l.l,,                 assum  .      ,l   ~iing maeu
                                                                                  ,               poided. by,.,theL reactorvv i,.s,.4v.*                       I+,.            cooI **.V',
                                                                                                                                           ,*.*..l*,ant in-S               and is des+*igned*, andl reliedupo to*-.acco'r,'.mplish the, follow*ing, nuc,'lear' 12_'
                    .. .            .,s.,-., ,.f ..v .,              vu. ...,,,, ,.,,..,.,,.,.v, .v ,,v .v ,r,,.,. . . .. . . ...                               ,,.

b. Proide.lnn emergency+ n,+ het emvafr.h pimrcotanmn atmosphere+1V to an inV*I*I l,~*.termedniate hea sinkI or./ eme

                                                                                                                  *+**11rgenc           remo
                                                                                                                                      *I%,val,,II        of+I*%*%*11 radi* +-oative matril,,      h,-,          fromth prima*ry,               otimetamshee(.

contaInment' spray)..,,,.,.v,,.,.,v,,,,.

c. ntroduc emrec eaierecilyt aete eco uciia (e.g, boron..n.ecionsystem

                                                     ,..,,.,v.,                           orrestric
                                                                                           ,              the~ add""Ition" of positive            rectvity..,

via press .l, ,, reh bo.,,+/ ndar eq im n."I ,,-÷-+ ,..,"l-* l m,', ,",,,,,+J

                                ,,,.Ensure,. emergency,.,    v,.. core1. cooling*'* whr               the-'*equipment.,.+,,        pro,,,vides coolant

e. Provideh- or maintain" sufficient reacto,,+r coolant invent,,,or",',fr, emergenc core cooling (e"g. SIRWT).

USAR Appendix N Information Use Reclassification;,* of+S,,stms.Classification of Structures Pa ev 311o Systems and Comnonents Rev. 11 2 .3

     ....          .. S... t. Cla........3 Safoty, ,,C'.'.la:ss 3'* ,(.,,.,               3, ,hal applyv,to cguip,mcnt,,, not*,nc,,v                                                            ed,,,           SC 1,or 2.,,,*,.

throaontwti-h cp ofth Su. B1.7ppigcoo b. Provide secondar cotimn t rad.i*vi*oavctvc mater"""*'ia'l* holup isolation, o hen l -rl m e V ll lyall*.1ll lt ~m.,I,(LIV 11**1*AInv ~ y I I II v c.

                      *m Rcmot'o ridiou*cti,-n m~teri2l from the *tmosnhere of confind enacoc outsid.....primar                           containment   ....                   (..g..otoom....                                    containing.....SC 1, 2..

Introduce negative reciitt ,;h ah;oe or maintain subcritical reato d, condit**,,v. *ion(e v.g*l n.,,bo o m akoup).lyI*

l*V iIO%,!l l'*,.li*,4 %.nnnl,, *l,,,s*,*

f. ain=!,iitain geometr~lny witblhinl theW reactorVIV to*. ellnsur corel reactivitly controIIIl or g.Stueur~l ladbor r roec S 1 ,n3i equ., bipmetntr,,,]

h. Provide radiation shielding.for the cnrol,pe.nnl romvrfs i, Ensure required4 coling for lqid cooled stre ÷ fuel*(og. spen .fuel,,.

storage pool- and..cooling. syste).**"

i. p4 J. l....................

                               .......                    :.J*    I*          ....... .#   ........... I  *r

r" ........

4 *'1 * * *J *v1*4,

s....
I* .. .. *-'i*'r- *..:.J* .......

iY~ u [1 ill [lrl l*- U r[lU mitU-Jl UIm 31 -- l -- UIr -- H -l UVUI. II-J,1 UI*[- , ,!UnIUU lubrication of SC 2 or -3 pumps, or..pro.ide fueli oi to the emergency. Prvwl.lidel.q an~ acceptable environment for SCV 1,.i 2,l or. 31%. equipment and k. opertin personnel ,,,*. 3 Thisapplie to concotnoorl stool strucuo htaontwti h cp ftoppn oeo component,

                  ..       upporting....             structure.

USAR Appendix N Information Use Page 9 of 30 Reclasificaton;" of Systems" Classification of Structures Systems, and Components Rev. 11 2m .1A Nn Nucii*Iv*.lea SafetyW. CI.las 1 included in*,StC'_ 1, 2,'or 3 that is d4osignod4 and, roliod4 uponr' to* acco,'-mpIish one,.,

orslete, or utliitd reurmet pciidt.esr ccpal pcdornanc oif specific NNS* functJ.L*iions.I4 The selcte requirements arcII*IMI established* ona- as b case11,,I*M basicomensrat with the-÷,specific*÷ NNS functionmilll.4pedermed~i*$,.*VlTh funci$ tions*.VIII* po Ire by thm**'*IV'Ie N N CV'lassI**IJ 1LIequa.ipmen iaire i i ml *i i i a.Poes eiat enae rsoerdocivewse e.'Strcturall loatd bea orpotc.N2eqimetprvdigan fh involving,- radioactie-,;, ma,*teriaels withou,t undue, , risk to' the health and4 saety,

i. anle,1 spen.t fuel., the,failur of..w:hich could result.. in.;fuel damage... suh

j. Ensure reactivity con..trol of stored, fuel.

shutdown,, following,; fire. I. Flow paths for water deposited post LOCA in the refueling cavity and reactor cavity to flow back to the containment sump.

USAR Appendix N Information Use Page 10 of 30 Roca.sification,, of* S,,tems. Classification of Structures Systems. and Components Rev. 11 2.5 No**lnl*,Nucler Safctyl*, C"la,- 2 2.0 SAFETY CLASSIFICATIONS ANSI/ANS-58.14-201 1 is used for determining the safety classification of ECS SSCs based on the function(s') performed by each SSC during or following a Design Basis Event (DBE'). The safety classifications of ECS SS~s are: safety-related (Q'). non-safety-related with auamented requirements (A'). and non-safety-related (N'). Per 10 CFR 50.2. safety-related SSCs are those SSCs that are relied upon to remain functional during and following DBEs to assure: (1') the integrity of the reactor coolant pressure boundary (RCPB'). (2') the capability to shut down the reactor and maintain it in a safe shutdown condition. or (3') the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a')(1') or 10 CFR 100.11. as applicable. Safety classifications used at FCS are defined as follows: Safety-Related (Q'): Those SSCs that are relied upon during or following a design basis event to ensure the following functions: (1) the integrity of the RCPB. (2') the capability to shut down the reactor and maintain it in a safe shutdown condition, or (3') the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the guideline exposures in 10 CFR 50.34(a')(1'). 10 CER 50.67(b')(2'). or 10 CFR 100.11. as applicable. Non-Safety-Related with Augmented Reguirements (A'): Those SS~s that are not safety-related but are relied upon during a special event (e.g.. station blackout') or to which a licensing reguirement or commitment applies. Non-Safety-Related (N'): Those SSCs that are not safety-related. The steps to classify SSCs are in ANSl/ANS-58.14-201 1. ANSl/ANS-58.14-201 1 is used for determining safety-related/non-safety-related interface reguirements. SSCs that do not perform a safety-related function and are connected to or interface with safety-related SSCs may be classified non-safety-related if (a') the safety-related SSCs are isolated by safety-related isolation devices (e.g.. circuit breakers. optical isolators. automatic valves, locked closed manual valves') from the effects of failures in the non-safety-related SSCs or (b') an evaluation justifies an assertion that a failure in the non-safety-related SS~s (including a potential common-cause failure') will not prevent accomplishment of a safety-related function of

USAR Appendix N Information Use 11of3 DR-I'olassiication o--f S,,otem- Classification of Structures Paev Systems, and Components Rev. 11 the safety-related SSCs. Single-failure criterion will determine the number of isolation d~evices required at an interface between safety-related and non-safety-related SSCs. The application of single-failure criterion meets USAR Appendix G.

3. SAFEll:lTY CLASS IINTERFACES=

3.1 ,Safety Class. Interace for. Pressure.... Itgity,,;, of+Fluid Syste÷ms,

         ,Amembrane (e.g. ,""heat" exchangeri,*., tb,,,,.,, bellows,,v,,, pi,,stonv,* o- rigln         flange) that*

pIdspesr onayspraino qimn lse c'es as,therqure u~rriur U~LWUUII ~iiy LWU UI~AU ~, ~II U ~IIUII UU U~LU~UII~UU LU LiI~ 111UU ~L~III~UIIL UIU~. Where equipment of differing classes is interconnected, the more stringent class extends to and includes the cited barriers. Otherwise, the interface shall be in accordance with the following criteria. In...ae. arrer.orislatonde.ce connecting........ Safety or

                                                                                           .......      Fluid.system equpmet afey oter     t     Cassequpmet               sallbe          apale     of bllm tln   theII los of fluid loss of fluid. The+;lsshf lidshl       be        assessed fh*or*      the full. duratio of theevent The; 4

The acolicable deco criteria is orevided in USAR. Section 11.

USAR Appendix N Information Use Page 12 of 30 Reclassificat.,+ion of S,,stms.Classification of Structures Systems, and Components Rev. 11

3. Rcactor,*v Coolant* Pres-ur, ,Boundry InteP+rfac Tho roa..o coolant p.+rossuro bouda..(.P. interface from+S-C, 1**..*- to SCO. 2, 3 o N b,.l. The,. secondl*. ofi.+.l.1 the tw va./n.l ve n..i*ormlycoe uigpwroeain p.The second ofvtwo val...es whic.. ,;-h are capab.,ile,., of+automat,*ico remote. actuation.++;-,.

wihcouetmssfiintt lo h.eco obesudw n olddw inanl~ ordely',..+man-ner' assum+,"i+*ng mako up is.",'..",,

                                                                  ,. 'JIA                     proide         by then reactor.+,"        coolH",ant,.,HH",,

m akei up system only.~"Jw=*'IIg~l'll'li.tl-mlll*l+f*tl/i 8 ++l#'lh£*tP 9 ii"PnA ~ n

d. low A rs'ricor sied't limit he"flo though the"postulate "' failure*., of the loer safotylasslm compo-÷+neAnth uhta h oc a b htdw n olddw in an orderVly*I**mannerIasuIngImakeu%#I~l i lea s provided byIW*%.4l**%, theA reactor coolantVI*V makoup+' systo o...nly ,+. .. - h-++- . . ,,. b i.,, 4... ., .,.,,,,,i, ..

Generally,* any f+/-*luidl*l system penertothogtoprmrcnaietadis less str.ingent+afo,-t,+, class+than SC-2 (.o.,. SC 3)_Q on either side of tho e netratio-÷m'-,..,n+,.hon t÷he interface t SC. 2_s.ha-ll be* atJits* connectio,+n to a prima,'ry contA innt**,,.*pene,*trationl-assemb'nly. Detaledl,*. contai÷,.+*-.nment÷ isolation;'-, provisio'-;".ns areP provlided in USIAR:

3. Exceptio*nslr,: to the DeI*fined Sa.Fety+Class Interfaces, exlaato fo h lcetblt o h te eie ai r sflos Eceptionlln* toAh Section second-m,..

                                                   ".3.1'.'         pa       ,ragraphis takeHnfo th                   isolato       of Component;^,+.lh, Colig          aer(CW)t  te        acu          Daoatr                an     Prmay             aml        Cole    m         hch i prvddsll        by           valves HC,vv 2 ,w <8,5.B.*,l,         Those, s.*~inl          remote*i       manual'v vavesmprov,,,ide theIV~i SCl 3 tov NNl       CL intrae                          rdt      istaenfo sisicll                           supe.           d NS           L US. "B301i7 S w.-, piping and, non, CQE isolation.....                                    'e at..the equipment,-,.,,,l               ,-.,-,I by..the.I,(

CC.Ti scosdrda acceptable*. substitute,. for!. a second.'.l re'..tmomte+*.mana vamlvel1,. for lmite tis section of*. NNS CL 1 p,*,V~ Iping. 9

USAR Appendix N Information Use Page 13 of 30 Relasifoa.. tion-.e,-,Sy,,t.ms.Classification of Structures Systems, and Components Rev. 11 3.5 Safct,,/Classe Interf,..cc, .fo-r Othelk*-r-., ,Equipment,,v Tho c~la'ssi.i"fication-* droirm,'ont 'for support-s and moc,'hanial m,,ovors' or link-s shall bo as*T*I., roqulrode in .2A. N,.,o inte.,face, barIerQ "Is requ*..Ire I w~*/* inteconncte

                                                                                    *hen            mechan, "Ic"al equipmet of consits ifferin   Safet    Classe,   mechnicleupmn*ontdt this criteria ÷ is-,'--

a open mn ,,÷,-rvavml,..

                                    ÷single-              Al     which'canbe÷used
                                                                              ÷;e,      a a* class  Eb-una 3.0       PRESSURE INTEGRITY CLASSIFICATIONS ANSI/ANS-58.14-201 1 is used for determining the pressure integrity classification of ECS SSCs that are subiect to the reguirements of ASME Section III or other codes and standards that specify pressure integrity criteria. The pressure integrity classifications of FCS SSCs, including supports, are: Class 1 (C-1),. Class 2 (C-2'.

Class 3 (C-3'). Class 4 (C-4). and Class 5 (C-5). Pressure integrity classifications used at ECS are defined as follows: Class 1 (C-i1): Those pressure-retaining portions of mechanical SSCs that form part of the RCPB and whose failure could cause a loss of reactor coolant in excess of the reactor coolant normal makeup capability. Class 2 (C-2): Those pressure-retaining portions of the containment structure and other mechanical SSCs that are not assigned to C-i but whose reguirements are within the scope of ASME Section III. USAS B31 .1. USAS B31 .7. and other codes and standardsthat specify pressure integjrity criteria in accordance with the ECS Licensing Basis and are relied upon to accomplish one or more of the following safety-related functions:

during or following a design basis event whose consequence could result in potential off-site exposures comparable to the guideline exposures in applicable regulations to maintain pressure integrity of:
the containment, containment isolation, or extension of containment.
SSCs that (a' are exterior to the containment. (b' communicate with the RCPB or containment interior, and (c' are not normally isolated or cannot be automatically isolated or are not isolated following the design basis eyent. These typically include SSCs for:
emergency core cooling.
emergencv containment atmosphere control.

USAR Appendix N Information Use Classification of Structures Pa e14 of 30

.£v.*tem~q and Comnonents                                                                                 RAv ii

emergency fission product removal from the containment atmosphere,
emergency residual heat removal, or
SSCs that provide emergency necyative reactivity insertion (i.e.. control element drive mechanisms [CEDMs]/control element assemblies

[CEAsl'). Class 3 (C-3'): Those pressure-retaininci portions of SSCs that are not assigned to C-i or C-2 but are within the scope of codes and standards specified in available guidance and are relied upon to accomplish one or more safety-related functions during or following a design basis event whose consequences could result in potential off-site

        ,-vnA~n ir~e r'nmnl~r~hld   tn the ni uii~linc* ,'vnrnen nro  in mnnllri-ahlI- r-,nn,l~tinna   Twnuml examples of these functions include the following:

provide auxiliary building radioactive material holdup, isolation, or heat removal,
remove radioactive material from the atmosphere of spaces outside containment (e.g.. auxiliary building') containing C-i. C-2, or 0-3 SSCs.
provide or maintain sufficient component cooling water (CCW') inventory, or
provide an acceptable environment for C-i. C-2. or 0-3 SSCs or plant personnel.

Class 4 (C-4'): Those pressure-retaining portions of SSCs that are not assigned to C-

1. 0-2. or C-3 but are within the scope of the codes and standards specified in commitment. These SSCs typically include those that:

process, extract, encase, or store radioactiye waste.
monitor radioactive effluents to ensure that release rates or total releases are within limits established for design basis events.
resist failure that could prevent any C-1. C-2. or 0-3 SS0s from performing a safety-related function, or
protect SSCs necessary to attain or maintain safe shutdown following a fire.

Class 5 (C-5'): Those pressure-retaining SSCs that have been evaluated and have not been assigned to C-i. 0-2. 0-3. or 0-4. ,40n CarORRELATION* BEITWEE["N S AFETYr CLASS A*nD E-QUIPMENT DEIN-unn CODE As +thoASME pipin code ,wa... an "'+ .... "*h of USAS B31 .7, the, Clas.. 1,1, and Il,, designations ofB-,.7 orlt d..,ir,.ostly.+... with"'Clas , 2..and*+ 3' of..., AS.E Soction+I '

USAR Appendix N Information Use Reclassification-,, of+S,,otems Classification of Structures Page15 of3 Rv.*te.m.* aind Comr~nnnnts R~v Ii, v7 ....... I ......... p" ........ . .v.. , 13~Q1 7 /"l'cc A~ftAI Q*-,',*- III (l,'I. ,*- 2 II 2 The-,r USIAS 3 7cd osiue h C eig oefrppnpp itns n suppor,,ts-but doesr not.,.includeP piping,,-s,'ystem Q com7pon'ent', (val"es," heat,*,..,*r,,r exchangers,, tanks*, pumps;,-;,',,, et". Thef;,, design codesm-r',*r frli the pipin'I systemcomponent, "JI{,,*zasf-.. defIned,,., above,, wil,-uPreai as, specifiedm in t**;he origina cont*dract, specificaion-s,Ipurcase orders,",,r-'J-an ld I_-U lk Q P ' 6* n*n,,,J ~ .;,',. ,,-rlr,*,",,,,,,,,1-.A. F r+ , *,,,*,; The*.. original piping .,,,,.. code, v

of contrutio (US.A.S B3.1,.,,., ,.1

                                                                                                ,       t Code,,.*.,,

case , and ASM..E.,,..,,.,,*,*, Section*,*f;*r .II.N E o,C th e loop--;,-.,.,and',., US..,AS,,,,+,,,r,,+. f,-1c.7, C , '-lass"-or tehn remainni ngTmh,, Safet

USAR Appendix N Information Use Reca;ifiaton; of System Classification of Structures Paev16 of13 Sv~t*.m5_ *nd flnmnannnt* Rev 11 const÷, ruction Or. Iator editio-ns of the* const*ruction*,' code-,-cIg., $,ASE Sectiorn III for pipirng-ann Itlnlnn. r--eptanl murT compnunnin mriay miOOT a1 nr nnrulnn* nT TnI runluiirrlmon~u UT Eaercdtisofth cnsrutincoe roidd heprviios f O 13n Progra

           ,-. e-                            ,  *,,a,,,,.     .n         ,y&        ,,-m.e,    ,,-,,      .t-**:*,\v      **  v TabeN2    ontinsa             orrlatonbetee               saetyclssequpmnt                       esin       cod    o consrucion, ad        qaliy       asurnce.n The.Sismi,v      ate..,,.,d'     I requirements v,       specified"for specific- plant' s.ystems"- is shown... n nSARApndxF                       aeI        lsmyad3euimn                           scosdrdtob                       esi 4.0    SEISMIC CLASSIFICATIONS NRC Requlatory Guide 1.29. Revision 3. is used for determining the seismic classification of FCS SSCs. The seismic classifications of FCS SSCs are: Seismic Cateaorv I. Seismic Category II. and Non-Seismic.

Seismic classifications used at ECS are defined as follows: Seismic Cateaorv h: Those SSCs. including their foundations and supports. which are designed to withstand the effects of a design basis earthquake and remain functional to ensure: (1) the integrity of the RCPB. (2' the cap~ability to shut down the reactor and maintain it in a safe shutdown condition, or (3' the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the guideline exposures in 10 CER 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11. as applicable. Seismic Category I1: Those SSCs. or portions thereof, that are not reguired to function during or following a design basis earthquake. but whose failure could prevent a safety-related function during or following a design basis earthguake. Non-Seismic: Those SSCs that are not Seismic Cateaqory I or I1. 5.0 OnUALITY AssnURANCE functions,* lite in. ;.... .1through .o+..5haSCe quality l~eeLs asige 1 to* ensure th Class 1 systems

                  ..          suc        aso F;ic Poeton,,*,;-,D,;,,;,

Rdoatv Waste, a.4nd Limited*, CQE. Th.e.,

USAR Appendix N Information Use Page 17 of 30 rcclacz.ifiati,,n of* S,,toms.Classification of Structures Rv.*tem.* and ('nmncnnent.* Pmv 11 w7 ...... *1 ** vv,,,r-,*,,*,,-* * =vv. * , LI ....... *1"*1--...;*L t'* .=. I I*t ..... : .......... JL ... --1 P.I ... f'%rP

          !** _n_ I - V* _t _!_ --

I 1VI VilLI 1 llf!Tfl _I**_v_

                                                             *V*I*I n- th   9 1,Irpnn.*,
                                                                                                         '          nn 1 V.St.

pfnr- IAn *..,-llIIStdS in 1*-nl nffTI fif

                                                                                                                                                                               %   L SA)ISA fll          Ltd      *SAVS lfii*I *S J*                    i            i    .....      I;3L_r _               .,-,,,-*,,*,,.*.,.*

i%/* ,,.*.,-.-** *.*m *411%11 lll%.tnll%/lli.*.l T.I,*I*i.Iv I%.1 * *

                                                                                                                                                    *.o*..l*       v*   l*.l-*      .I.1,-.* I*..*1 n*.w*l,/1.t%.11.1v*.ll*    t.4ull.l    n*,,iP *..*1-',,I..

nv.4v*.i i nv*./ II 5.0 BASIC DESIGN REQUIREMENTS The basic design criteria applicable for SSCs assigned to each safety classification are alirmm~ri',-d in

          *UlIIIIIUl                   IL*U           II  I T~hle= NIl.1 I UUI*         I

I . Table N-2 li*t.* tvninal nre.*sure intenritv nla.*.*e.* fnr nnrtinn.*

of various FCS systems. More detailed boundary information is shown on the associated system P&lDs and in the OPPD Configuration Management System. Table N-i - Basic Design Requirements Pressure Safety Intearitv Electrical Seismic Q C-1, C-2, or 1Ea Seismic Categorv I C-3 _ _ _ _ _ _ _ A C-4 Non-1E Seismic Categorv II

                                                                                                                             .                                 or no reguirements specified N                  C-5                                            No reguirements                                No requirements are

_____ _________are specified specified 5.1 Pressure-Retaining SSCs The pressure-retaining portions of SSCs are assigned to C-i, C-2. C-3. C-4, or C-5 in accordance with the criteria in ANS1/ANS-58 14-2011 Safety-related nre5£mI~re-retaining SSCs are C-1, C-2. or C-S. Non-safety-related with auamented reguirements 5. 5.2 Electrical SSCs IEEE defines Class 1E as the safety classification of the electric eguipment and systems that are essential to emeraencv reactor shutdown, containment isolation. reactor core cooling, and containment and reactor heat removal. or otherwise are essential in preventing significant release of radioactive material to the environment. Safety-related electrical SSCs are designed to IEEE standards applicable at the time of construction or per FCS licensing reguirements or commitments. Certain electrical SSCs that have not been classified safety-related meet reguirements typically applied to IEEE Class 1E SSCs in accordance with FOS licensing reguirements or commitments. These SSCs are classified non-safety-related with augmented req ui reme nts.

USAR Appendix N Information Use Page 18 of 30 Rcc,.a-c-ifi,,+t,-,n of Sy'+tems Classification of Structures Systems, and Components Rev. 11 5.3 Seismic Category Safety-related SSCs (except pipe whip restraints) meet Seismic Cateaorv I requirements if they are relied uponl during or following a design basis earthquake. SSCs that have not been classified safety-related and whose failure could prevent a safety-related function relied upon during or following a design basis earthquake, and pipe whip restraints that are not classified Seismic Category I. meet Seismic Category II requirements. These SSCs are classified non-safety-related with augmented requirements.

USAR Appendix N Information Use Classification of Structures Page1 of 30 £v*lpm* iind Cnmnnn*.ntq .11

y*.v...*,I *,.* vv...r..*..*...*

RAY,

                                                                                                        , =v..   , ° Table N-1 System" Safc' 7'"Classification,,

N-2 System Pressure Inteqrity Class P&ID No. System Safety Pressure Integrity Class 1 1405-M-1 Containment HVAC 0 Containment Penetrations 8-G-2-C-2 4 Post-Accident H2 Control SO-3 C-3 0 Containment Air Cooling & Filtering 8SG-3 C-3 0 Balance of System 14iiN --, 4 C-4 1 1405-M-2 Auxiliary Bldg. HVAC

Flow path from fuel storage area NNS-CL=-I C-4 through filter VA-66 to stack
HVAC equip. and ductwork to NNS C-Ih1 C-4 cool safety related equipment 1 1405-M-5 Demineralized Water
Containment Penetrations SG C-2
Connections to Safety Injection and 8.C,-2 C-2 Containment Spray Pumps
Balance of System ,14N,8,,.GC-2 C-5 1 1405-M-6 Waste Disposal System
Containment Penetrations 80 C-2
Interface with SIRWT (SIRWT Cleanup) 80= C-2
El 995' - 6" Refueling Canal Low Point Drain in Containment NNHS-C-! C-4 o El 976' - 6", 4" F.D. to Containment Sump and Sump Pumps
Balance of System I4N C0L-!-&2 C-_

4&5 1 1405-M-7, Waste Disposal System 8,9 0 Containment Penetrations 80= C-2 0 Balance of System INll 0lI 4'1.. C-4&5

USAR Appendix N Information Use 20of3 Recla.sifi.ationof*... S,,c.emc. Classification of Structures Pa ev Systems, and Components Rev. 11 Table N-I- 2 (Continued) P&ID No. System Safety Pressure Integrity Class 1 1405-M-10 Component Cooling System

Control Room A/C piping C-3
Balance of System 53C-3 1 1405-M-1 1 Spent Fuel Pool Cooling 0 Pool Cooling Water System 804-C-_3_

0 Fuel Transfer Drain Pump Piping 804,- C-2 0 Spent Fuel Pool Cooling Emergency NNS-CL-4 C-4 Cross-Tie Piping 11405-M-12 Primary Plant Sampling S Containment Penetrations 50-2 C-2 0 Sampling System Outside Containment NNS -0i,.,=4,&.,-- C-4&5 Volume Control Tank Piping 80-3 C-3 0 Sample System Inside Containment 804-2 C-2 0 Reactor Coolant Pressure Boundary 804-1 C-i 1 1405-M-13 Plant Air

Containment Penetration 804, C-2
Balance of System NNS CL-2I-C-5

USAR Appendix SN Information Use Page 21 of 30

                               ,-of,,y.,en* Classification of Structures Rv~qtp~m~

y .......

And fltmnnn*.nt~q r" ........ Iv 1m1m i IVVo Table N--l- 2 (Continued) P&ID No. System ,Safety-Pressure Integjrity-Class 11405-M-40 Component Cooling System

Containment Penetrations ,SG4-2 C-2
Containment Air Cooling Piping inside 80-2 c-22 Containment o RCP Seal and Lube Oil Cooler Piping 802C-2 inside Containment
Piping adjacent to the RCP Seal Coolers 80-2-C-2
SI Leakage Cooler and Detector Well NNS-CL-! C-4 Cooler Piping
Balance of System 80-2 C-3 Nitrogen, Hydrogen, Methane, Propane, 11 405-M-42 and Oxygen Gas
Containment Penetrations 80= C-2
Nitrogen Piping connected to Safety 802C-2 Injection Tanks
Nitrogen Piping connected to Component 80,=-2 C-3 Cooling Surge Tank
Nitrogen Piping connected to Emergency 80C=-. C-3 FW Storage Tank
Nitrogen and Hydrogen Piping adjacent 80-2* C-2 to the Volume Control Tank
Piping Connected To Waste Disposal NNS-CL-!- C-4 System
Balance of System 4NNS-CL-2 C-5

USAR Appendix N Information Use Page 22 of 30 R,,ol.ssficton*,, ,,f S,,stem,, Classification of Structures .Rv.tp~m. And flnmnnn*.nt.* Rp~v 11 Table N-I--- 2 (Continued) P&ID No. System Safetv-Pressu re Integrity-Class 1 1405-M-97 Misc. HVAC System

Control Room HVAC 8*G- C-3
Emerg. Diesel Gen. Air Inlet, 80-3 C-3 Radiator Exhaust Dampers, and Duct
Balance of System NNS-CL-2 C-5 11 405-M-98 Waste Disposal System
Containment Penetrations
Piping connection from Volume Control so= 0-2 80=-3 C-3 Tank
Balance of System 14rS-CL-I-&2 C-4&5 11 405-M-99 Waste Disposal System Aux. Bldg. Floor 1N.S-CL-2 C-5 Drains 1 1405-M-100 Raw Water
Containment Penetration Piping to and 80-2 C-_*2 from Containment Cooling Units
Raw Water Supply Piping 80=-8 C-3
Discharge Piping in the Aux. Bldg. 80-3 0-3
Discharge piping in the Turbine Bldg. NNS-CL-! 0-4
Balance of System NNS-CL-2 C-5 1 1405-M-1 19 Component Cooling CEDM
Component Cooling Supply and Return 802C-2 Piping
Seal Leakage Piping t4NS-GL-2 0-*_5 1 1405-M-252 Steam System
Steam Piping from Steam Generators to 80= C-2 Main Steam Isolation Valves
Steam piping to Auxiliary Feedwater 80-,3 C-3 Pump Turbine Driver
Steam Exhaust from Auxiliary Feedwater 80-30C-3 Pump Turbine Driver

USAR Appendix N Information Use Reclasifcaton*,*÷, of* Syste*ms Classification of Structures 23of3 Pa ev Svstems. and Comnonents Rev. 11

Balance of System I*JS-CL-2 0-5

USAR Appendix N Information Use Recl,.ific.ion f,.+*,.. S,,s.+ems Classification of Structures Pa ev21o13 Systems, and Comoonents Rev. 11 Table N-1 2 (Continued) P&ID No. System Safety Pressure Integrity Class 1 1405-M-253 Steam Generator Feedwater and Blowdown

Blowdown from Steam Generators through Containment Penetrations NSG- C- 2C-
Balance of Blowdown System
Main Feedwater from Feedwater Isolation 80 C-2 Valves to Steam Generator
Balance of Main Feedwater System NNS CL-4 C-4 including Diesel Driven Feedwater Pump
Auxiliary Feedwater System from 80= C-2 Containment Penetrations to Steam Generators
Steam and Electric Drive Auxiliary ,8G=-8 C-3 Feedwater System from Storage Tank to Containment Isolation Valves
Balance of System NNS-GCU!1&2 C*_

4&5 1 1405-M254 Condensate System

Emergency Feedwater Storage Tank and C-3&4 Supply Piping to Auxiliary Feedwater Pumps
Balance of Condensate System NNS-GL-U!&2 C-4&5 NNS-CL-2 C-5 1 1405M-261 Condenser Evacuation 1 1405-M-262 Fuel Oil System/Lube Oil System
Emergency Diesel Generator Fuel Oil 804,- C-3 System
Diesel Driven Auxiliary Feedwater Pump NNS-CL-! C-4 Fuel Oil System
Balance of Systems NNS-CL-2 C-5 1 1405-M264 Instrument Air System
Containment Penetration 80= C-2
Air Supply to SlRWT Bubblers 80-a C-3
Air Supply to AOV's Requiring Actuation 80-a C-3 Post DBA

USAR Appendix N Information Use Rcc,.ss*,iatio*,n of* Systomo Classification of Structures 25 of3 Page Systems. and Comonennts pP~I Ii

7 ....... I ......... I"" ........ I L*V= m e

                                   . Balance of System       N4S-CL-2 0-5

USAR Appendix N Information Use Page 26 of 30 nR.oc..,las.s*,,*ificatioVl~n of Sy,. t ,, Classification oms,,,.,,,l*l of Structures Systems, and Comoonents Rev. 11 Table N--l- 2 (Continued) P&ID No. System Safety Pressure Initegrity Class 1 1405-M-266 Fire Protection

Control Room Charcoal adsorbers SG-,- C-3
Safe Shutdown Plant Areas M4S-CL-! C-4
Non-Safe Shutdown Plant Areas NNS-CL-2 C-5 627- D-8053 Waste Evaporator Package (abandoned in place) NNS-GL-I- C-4 C-41 75 Typical Valve Air Source Valve Configurations
Air Source for Safety Related Valves Required to Hold or Change Position SG3C-3
All Other Air Sources for Valve Actuation N4*-I=**C-2 C-5 Reactor Coolant Gas Vent System D-4078
Reactor Coolant Pressure Boundary up to SG--1 C-1 Orifice
Piping from Orifice to HCV-1 80 and 181 SG C-2
Piping Down Stream of HCV-180 and 181 NNS CGL- C-4 E-4144 FW-10 Lube Oil Schematic
Critical Lube Oil components SG-3 C-3
All Other Components NN.S-,L_2 C-5 E-23866-21 0-1 10 Reactor Coolant System
Main R. C. Loop Pressure Boundary *C-1
Pressurizer and Main Piping
Pressurizer Safety and Relief Valve M~4 C'-IL C-4 Discharge, Quench Tank and Tank Relief
Balance of System N4ll-GbCL2 C-5

USAR Appendix N Information Use Re,,,.,z-ifi,,.ti,,nof* S,,toms.Classification of Structures 27of3 Pa ev Systems. and Components Rev. 11 w,! v.-; .... , .......... r ............... Table N--l-2 (Continued) P&ID No. System Safety Pressure Integrity Class E-23866-21 0-120 Chemical and Volume Control System

Reactor Coolant Pressure Boundary Piping SG C-1
Charging Flowpath through Regenerative SG2c-22 Heat Exchanger (Shell Side)
Containment Penetrations 50-2-C-2
Charging Pump Flowpath from Boric Acid 504,- C-2 Supply to Containment Penetration
Volume Control Tank and Associated 5048 C-3 Piping
Chemical Addition Tank and Metering NN4S-GL-2 =C-5 Pump Flow Path
Alternate Flowpath from S.1. and 50-2-C-2 Refueling Water Tank through Valve LCV-2 18-3
Relief Valve Discharge and Drain Piping NNS-CL C-4 to Waste Disposal and Pressurizer Quench Tank
Flowpath through Letdown Heat Exchanger SO=-a C-3 Outside Containment
CVCS Ion Exchangers and Associated Piping 50-3 C-3
Resin Addition Tank and Drain Piping to NNS CL-01 C-4 Waste Disposal
Demineralized Water Supply Piping NIS-CL-2 C-5
Balance of System NNS-CL-2 C-5
SlRWT Cleanup Flowpath through CVCS 50=2- C-2 Ion Exchanger CH-9B and associated interface piping E-23866-210-121 Chemical and Volume Control System
Boric Acid Flowpath from Storage Tanks 50-2-C-2 to Charging Pumps
Boric Acid Batching Tank and Associated NNS-CL-2-C-5 Piping
Demineralized Water Connection and N7NS-CL-2 0-5 Balance of System

USAR Appendix N Information Use Rocl,, ifcton.*-**,- of S,,s.oms. Classification of Structures Paev28 of 30 Systems. and Comnonents R~v 11 --. F ....... I ......... r" ............... Table N--l- 2 (Continued) P&ID No. System Pressure Integrity Class E-23866-21 0-130 Safety Injection and Containment Spray System

Reactor Coolant Pressure Boundary Piping SC--1 C-i

                                                    - Safety Injection Tank and Associated                 8C C-2 Piping

Containment Spray Headers Inside SG C-2 Containment
Safety Injection Headers Inside SG C-2 Containment
Header from Safety Injection Leakage 8G-,2- C-2 Coolers to CVCS inside containment
Shutdown Cooling Suction Piping 8=-I- C-1 Containment Penetration (M-16)
Balance of Containment Penetrations SC-2 C-2
S.I. and Refueling and Water Tank and SC-2 Containment Sump through Pumps and Heat Exchangers Including Recirculation Piping
Alternate Flowpath from S.I. and SG2C-2 Refueling Water Tank through Valve LCV-218-3 to Charging Pumps
S.I. and Refueling Water Tank Vents ,N,,.8-0 L-I C-4
Relief Valve Discharge NrNS-CL-I C-4
LPSI System Jockey Pump 80,-2 C-2_
Balance of System ,Nf4,

                                                                                                     ,-,0C-2 C-5 B-i120-F03001                          Emergency Diesel Generator Lube Oil                    80-3 C-3 System B-i120-F04002                          Emergency Diesel Generator Jacket                      803C-3 Water System B-i120-F07001                          Emergency Diesel Generator Starting Air

Pressure Boundary from Air Receivers to 80-3, C-3 Air Start Motors
Air Compressors and Associated Piping 4NNS-CL-2 C-5 13007.54-EM-lA Post Accident Sampling System NNS CL-!&2 C-4&5 N4-1& -&

USAR Appendix N Information Use Page 29 of 30 Rcclac.zific.ati,, of* S,,y÷tcms,Classification of Structures Systems, and Components Rev. 11

6.0 REFERENCES

6.1 ANSI/ANS-58.14-201 1. Safety and PressureInteqrity ClassificationCriteriafor Light Water Reactors 6.2 10 CFR 50.2. Definitions 6.3 10 CFR 50.34. Contents of App/icatiOnS., Technical Information 6.4 10 CFR 50.67. Accident Source Term 6.5 10 CFR 50. Appendix A. General/DesignCriteriafor Nuclear Power Plants 6.6 10 CFR 100. Reactor Site Criteria 6.7 NRC Reaulatory Guide 1.29. Revision 3. Seismic Design Classification

USAR Appendix N Information Use Page 30 of 30 Reclassification of Systems Rev. 11 TabIcI N_ 2 Corvrelationr Iotweon Sa*fot, Class, gIpmo,*-nt Deign~r ,-nd Qual,,it;y Aesu,,-,'ranec-('A r-r-r*l/ If%l A (, iE'* r-- f'% i I i i'-i R R r-" i* i"r" * *,'r' r- a.' - ,,a** .rai-,. nf'*. n,-a-ri a'*.. t I ....... Illl I'.* *'J */'.1".'*-* '-' ~. . . . . . . ..... :~ZZ ,.. --,,-,,,,-.,,, ,,.,,..i U ,I , -, ,,,4 : ,._1,., -,. ,,,,. uu:~LI I Y ~ c£*-! Di*;r* B3!1.7, Class I 1968 draft Pipi;ng Systel-m Cor-p,-nonts÷-{4 Oigina*1*lConrac Spc*IfIcaIc1insl

         *-  U                                        Pu if     !.n.i                                                                        .....                ....    .....          _I .............                             CQE
                                                           **rI,..

Piping,, Syt,,, Cv...ov,,v.. Original. Contract* Spcification C-QE B3! .7, Class !!!- 1Q68 draft CQE Pip-ing- Syostem, Componentse-) Original.-* Conracvt*,*, Spec,;f;ic,-t DflE -CQE L%li%I C* /'%1 -(

                                                                                                                                                                                                                                       \v/
                    ,       ,-                        ri:- ln,y,                                                                             ,-,           I.

Piping*:: Systom,, Co,,,i.,o,,v, - *--.,*, :. : *.':*J :',:*[e ,.3 *. " D..~ I. I ~tFIU I~UW .. ~ (6) N41IM* ('*I _0 D;,-,;n,*

                                                      , .*. ,*                                                                               B31.1                                                                                     Noen-CQE Piping,, System,,,- C",o-,-,-,on÷ns4-                                                  B3!.! and Note 3                                                                          Non-CQE NQlrl~rES        I FI II/*--     -- I--     -- £  *  ....        * ..... L:--.--II     .......          L--- -- I----!       t--l--       -*--

i i i~ti ~titJii S'~ i ii iJUtt~ ~%J i~i i, i i.AhJi iS.diASiSJi i, ii iJttAiitAt1~~i IjL4U1~UU~~t1UI~V

2. 1 OFR5O*I: Append-iv B::applies to* all CQ1: equipment.

manufactur* r e;rs standardsr , etc.). ,,*1 ,,r*, r,,'lr*,*l '* -,r , ,,1*÷*A hI fr \11rr- r

v. * -"r'"*,.,nev,, tv,,,i, e, v alves,.*, heat

                                                                                                                           , ev,,,hangors,,,*.                             pum ps,.* et.,,.,,,., v ,,,,,                        ,* ,, ,,v      , ,v,,     .,,,.,,

6r. Lmitedm C-,QE*,,, Radioact,,,i,,ve.Waste Disposal., Fire4 Protection,*,, or

                                                                                                                                                                                 .Non,,               CQ, wthsecalreureens 7." Not"'applicable.,v to"FireProtecion.                                                                     ""'-'-v

Page 1 of 17 II USAR Appendix N Classification of Structures, Systems, and Components Rev 11 Safety Classification: Usage Level: IISafety II Information I Change No.: Reason for Change: Preparer: Issued: Fort Calhoun Station

USAR Appendix N Information Use Page 2 of 17 Classification of Structures Systems, and Components Rev. 11 Table of Contents 1.0 PURPOSE 4 2.0 SAFETY CLASSIFICATIONS 4 3.0 PRESSURE INTEGRITY CLASSIFICATIONS 5 4.0 SEISMIC CLASSIFICATIONS 6 5.0 BASIC DESIGN REQUIREMENTS 7

6.0 REFERENCES

USAR Appendix N Information Use Page 3 of 17 Classification of Structures Systems, and Components Rev. 11 List of Tables Table N-i - Basic Design Requirements............................................................ 7 Table N System Pressure Integrity Class= 9

USAR Appendix N Information Use Page 4of 17 Classification of Structures Systems, and Components Rev. 11 1.0 PURPOSE This appendix describes the safety, pressure integrity, and seismic classifications used at Fort Calhoun Station (ECS) for structures, systems, and components (SSCs). 2.0 SAFETY CLASSIFICATIONS ANSI/ANS-58.14-201 1 is used for determining the safety classification of ECS SSCs based on the function(s) performed by each SSC during or following a Design Basis Event (DBE). The safety classifications of ECS SSCs are: safety-related (0), non-safety-related with augmented requirements (A), and non-safety-related (N). Per 10 CFR 50.2, safety-related SSCs are those SSCs that are relied upon to remain functional during and following DBEs to assure: (1) the integrity of the reactor coolant pressure boundary (RCPB), (2) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 10 CFR 100.11, as applicable. Safety classifications used at FCS are defined as follows: Safety-Related (Q): Those SSCs that are relied upon during or following a design basis event to ensure the following functions: (1) the integrity of the RCPB, (2) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (3) the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the guideline exposures in 10 CFR 50.34(a)(1 ), 10 CER 50.67(b)(2), or 10 CFR 100.11, as applicable. Non-Safety-Related with Augmented Requirements (A): Those SSCs that are not safety-related but are relied upon during a special event (e.g., station blackout) or to which a licensing requirement or commitment applies. Non-Safety-Related (N): Those SSCs that are not safety-related. The steps to classify SSCs are in ANSI/ANS-58.14-201 1. ANSI/ANS-58.14-201 1 is used for determining safety-related/non-safety-related interface requirements. SSCs that do not perform a safety-related function and are connected to or interface with safety-related SSCs may be classified non-safety-related if (a) the safety-related SSCs are isolated by safety-related isolation devices (e.g., circuit breakers, optical isolators, automatic valves, locked closed manual valves) from the effects of failures in the non-safety-related SSCs or (b) an evaluation justifies an assertion that a failure in the non-safety-related SSCs (including a potential

USAR Appendix N Information Use Page 5 of 17 Classification of Structures Systems, and Components Rev. 11 common-cause failure) will not prevent accomplishment of a safety-related function of the safety-related SSCs. Single-failure criterion will determine the number of isolation devices required at an interface between safety-related and non-safety-related SSCs. The application of single-failure criterion meets USAR Appendix G. 3.0 PRESSURE INTEGRITY CLASSIFICATIONS ANSIIANS-58.14-201 1 is used for determining the pressure integrity classification of FOS SSCs that are subject to the requirements of ASME Section III or other codes and standards that specify pressure integrity criteria. The pressure integrity classifications of ECS SSCs, including supports, are: Class 1 (C-i), Class 2 (C-2), Class 3 (C-3), Class 4 (C-4), and Class 5 (C-5). Pressure integrity classifications used at ECS are defined as follows: Class 1 (C-i): Those pressure-retaining portions of mechanical SSCs that form part of the RCPB and whose failure could cause a loss of reactor coolant in excess of the reactor coolant normal makeup capability. Class 2 (C-2): Those pressure-retaining portions of the containment structure and other mechanical SSCs that are not assigned to C-i but whose requirements are within the scope of ASME Section III, USAS B31 .1, USAS B31 .7, and other codes and standardsthat specify pressure integrity criteria in accordance with the ECS Licensing Basis and are relied upon to accomplish one or more of the following safety-related functions:

during or following a design basis event whose consequence could result in potential off-site exposures comparable to the guideline exposures in applicable regulations to maintain pressure integrity of:
the containment, containment isolation, or extension of containment,
SSCs that (a) are exterior to the containment, (b) communicate with the RCPB or containment interior, and (c) are not normally isolated or cannot be automatically isolated or are not isolated following the design basis event. These typically include SSCs for:
emergency core cooling,
emergency containment atmosphere control,
emergency fission product removal from the containment atmosphere,
emergency residual heat removal, or
SSCs that provide emergency negative reactivity insertion (i.e., control element drive mechanisms [CEDMs]/control element assemblies

[CEAs]).

USAR Appendix N Information Use Page 6 of 17 Classification of Structures Systems, and Components Rev. 11 Class 3 (C-3): Those pressure-retaining portions of SSCs that are not assigned to C-i or C-2 but are within the scope of codes and standards specified in available guidance and are relied upon to accomplish one or more safety-related functions during or following a design basis event whose consequences could result in potential off-site exposures comparable to the guideline exposures in applicable regulations. Typical examples of these functions include the following:

provide auxiliary building radioactive material holdup, isolation, or heat removal,
remove radioactive material from the atmosphere of spaces outside containment (e.g., auxiliary building) containing C-i, C-2, or C-3 SSCs,
provide or maintain sufficient component cooling water (CCW) inventory, or
provide an acceptable environment for C-i, C-2, or C-3 SSCs or plant personnel.

Class 4 (C-4): Those pressure-retaining portions of SSCs that are not assigned to C-1, C-2, or C-3 but are within the scope of the codes and standards specified in available guidance and are subject to at least one significant licensing requirement or commitment. These SSCs typically include those that:

process, extract, encase, or store radioactive waste,
monitor radioactive effluents to ensure that release rates or total releases are within limits established for design basis events,
resist failure that could prevent any C-i, 0-2, or C-3 SSCs from performing a safety-related function, or
protect SSCs necessary to attain or maintain safe shutdown following a fire.

Class 5 (C-5): Those pressure-retaining SSCs that have been evaluated and have not been assigned to C-i, C-2, C-3, or C-4. 4.0 SEISMIC CLASSIFICATIONS NRC Regulatory Guide 1.29, Revision 3, is used for determining the seismic classification of FCS SSCs. The seismic classifications of ECS SSCs are: Seismic Category I, Seismic Category II, and Non-Seismic. Seismic classifications used at ECS are defined as follows: Seismic Category I: Those SSCs, including their foundations and supports, which are designed to withstand the effects of a design basis earthquake and remain functional to ensure: (1) the integrity of the RCPB, (2) the capability to shut down the reactor and maintain it in a safe shutdown condition, or (3) the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to the guideline exposures in 10 CER 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11, as applicable.

USAR Appendix N Information Use Page 7 of 17 Classification of Structures Systems, and Components Rev. 11 Seismic during orCategory following I1:a design Those basis SSCs,earthquake, or portions thereof, but whosethatfailure are not required could to function prevent a safety-related function during or following a design basis earthquake. Non-Seismic: Those SSCs that are not Seismic Category I or II. 5.0 BASIC DESIGN REQUIREMENTS The basic design criteria applicable for SSCs assigned to each safety classification are summarized in Table N-I. Table N-2 lists typical pressure integrity classes for portions of various FCS systems. More detailed boundary information is shown on the associated system P&lDs and in the OPPD Configuration Management System. Table N-i - Basic Design Requirements Pressure Safety Integrity Electrical Seismic Q C-i, C-2, or 1Ea Seismic Category I C-3 A C-4 Non-i1E Seismic Category II or no requirements specified N C-5 No requirements No requirements are ______________are specified specified 5.1 Pressure-Retaining SSCs The pressure-retaining portions of SSCs are assigned to C-i, C-2, C-3, C-4, or C-5 in accordance with the criteria in ANSI/ANS-58.14-201 1. Safety-related pressure-retaining SSCs are C-i, C-2, or C-3. Non-safety-related with augmented requirements pressure-retaining SSCs are C-4. Non-safety-related pressure-retaining SSCs are C-5. 5.2 Electrical SSCs IEEE defines Class 1E as the safety classification of the electric equipment and systems that are essential to emergency reactor shutdown, containment isolation, reactor core cooling, and containment and reactor heat removal, or otherwise are essential in preventing significant release of radioactive material to the environment. Safety-related electrical SSCs are designed to IEEE standards applicable at the time of construction or per ECS licensing requirements or commitments. Certain electrical SSCs that have not been classified safety-related meet requirements typically applied to IEEE Class 1 E SSCs in accordance with FCS licensing requirements or commitments. These SSCs are classified non-safety-related with augmented requirements.

USAR Appendix Classification N of Structures Systems,Information Use and Components Page Rev. 8 of 17 11 5.3 Seismic Category Safety-related SSCs (except pipe whip restraints) meet Seismic Category I requirements if they are relied upon during or following a design basis earthquake. SSCs that have not been classified safety-related and whose failure could prevent a safety-related function relied upon during or following a design basis earthquake, and pipe whip restraints that are not classified Seismic Category I, meet Seismic Category II requirements. These SSCs are classified non-safety-related with augmented requirements.

USAR Appendix N Information Use Page 9 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 System Pressure Integrity Class P&ID No. System F*ressure Integrity Class 1 1405-M-1 Containment HVAC 0 Containment Penetrations C-2 Post-Accident H2 Control C-3 S Containment Air Cooling & Filtering C-3 S Balance of System C-4 1 1405-M-2 Auxiliary Bldg. HVAC

Flow path from fuel storage area C-4 through filter VA-66 to stack
HVAC equip. and ductwork to C-4 cool safety related equipment 1 1405-M-5 Demineralized Water
Containment Penetrations C-2
Connections to Safety Injection and C-2 Containment Spray Pumps
Balance of System C-5 1 1405-M-6 Waste Disposal System
Containment Penetrations C-2
Interface with SIRWT (SIRWT Cleanup) C-2
El 995' - 6" Refueling Canal Low C-4 Point Drain in Containment
El 976' - 6", 4" F.D. to Containment C-4 Sump and Sump Pumps
Balance of System C-4&5 11405-M-7, Waste Disposal System 8,9
Containment Penetrations C-2
Balance of System C-4&5

USAR Appendix N Information Use Page 10 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&ID No. System Pressure InteQritv Class 1 1405-M-10 Component Cooling System

Control Room A/C piping C-3
Balance of System C-3 1 1405-M-1 1 Spent Fuel Pool Cooling S Pool Cooling Water System C-3 S

Fuel Transfer Drain Pump Piping C-2 S Spent Fuel Pool Cooling Emergency C-4 Cross-Tie Piping 1 1405-M-12 Primary Plant Sampling S Containment Penetrations C-2 S Sampling System Outside Containment C-4&5 a Volume Control Tank Piping C-3 S Sample System Inside Containment C-2 S Reactor Coolant Pressure Boundary C-1 1 1405-M-13 Plant Air

Containment Penetration C-2

                         - Balance of System                                  C-5

USAR Appendix N Classification of Structures Systems,Information Use and Components Page 11 of 17 Rev. 11 Table N-2 (Continued) P&ID No. System Pressure Integrity-Class 1 1405-M-40 Component Cooling System

Containment Penetrations C-2
Containment Air Cooling Piping inside C-2 Containment
RCP Seal and Lube Oil Cooler Piping C-2 inside Containment
Piping adjacent to the RCP Seal Coolers C-2
SI Leakage Cooler and Detector Well C-4 Cooler Piping
Balance of System C-3 1 1405-M-42 Nitrogen, Hydrogen, Methane, Propane, and Oxygen Gas
Containment Penetrations C-2
Nitrogen Piping connected to Safety C-2 Injection Tanks
Nitrogen Piping connected to Component C-3 Cooling Surge Tank
Nitrogen Piping connected to Emergency C-3 FW Storage Tank
Nitrogen and Hydrogen Piping adjacent C-2 to the Volume Control Tank
Piping Connected To Waste Disposal C-4 System
Balance of System C-5

USAR Appendix N Information Use Page 12 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&ID No. System Pressure lntearitv-Class 1 1405-M-97 Misc. HVAC System

Control Room HVAC C-3
Emerg. Diesel Gen. Air Inlet, C-3 Radiator Exhaust Dampers, and Duct
Balance of System C-5 11 405-M-98 Waste Disposal System
Containment Penetrations C-2
Piping connection from Volume Control C-3 Tank
Balance of System C-4&5 11 405-M-99 Waste Disposal System Aux. Bldg. Floor C-5 Drains 11405-M-100 Raw Water
Containment Penetration Piping to and C-2 from Containment Cooling Units
Raw Water Supply Piping C-3
Discharge Piping in the Aux. Bldg. C-3
Discharge piping in the Turbine Bldg. C-4
Balance of System C-5 1 1405-M-1 19 Component Cooling CEDM
Component Cooling Supply and Return C-2 Piping
Seal Leakage Piping C-5 11 405-M-252 Steam System
Steam Piping from Steam Generators to C-2 Main Steam Isolation Valves
Steam piping to Auxiliary Feedwater C-3 Pump Turbine Driver

                         - Steam Exhaust from Auxiliary Feedwater              C-3 Pump Turbine Driver

Balance of System C-5

USAR Appendix N Information Use Page 13 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&ID No. System Pressure Intecirity Class 1 1405-M-253 Steam Generator Feedwater and Blowdown

Blowdown from Steam Generators through C-2 Containment Penetrations
Balance of Blowdown System C-5
Main Feedwater from Feedwater Isolation C-2 Valves to Steam Generator
Balance of Main Feedwater System C-4 including Diesel Driven Feedwater Pump
Auxiliary Feedwater System from C-2 Containment Penetrations to Steam Generators
Steam and Electric Drive Auxiliary C-3 Feedwater System from Storage Tank to Containment Isolation Valves
Balance of System C-4&5 11 405-M-254 Condensate System
Supply Emergency Feedwater Storage Tank and C-3&4 Piping to Auxiliary Feedwater Pumps
Balance of Condensate System C-4&5 1 1405-M-261 Condenser Evacuation C-5 1 1405-M-262 Fuel Oil System/Lube Oil System
Emergency Diesel Generator Fuel Oil C-3 System
Diesel Driven Auxiliary Feedwater Pump C-4 Fuel Oil System
Balance of Systems C-5 1 1405-M-264 Instrument Air System
Containment Penetration C-2
Air Supply to SIRWT Bubblers C-3
Air Supply to AOV's Requiring Actuation C-3 Post DBA
Balance of System C-5

USAR Appendix N Information Use Page 14 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&ID No. System Pressure Integrity Class 1 1405-M-266 Fire Protection

Control Room Charcoal adsorbers C-3
Safe Shutdown Plant Areas C-4
Non-Safe Shutdown Plant Areas C-5 627-0-8053 *Waste Evaporator Package (abandoned in place) C-4 C-41 75 Typical Valve Air Source Valve Configurations
Air Source for Safety Related Valves Required to Hold or Change Position C-3
All Other Air Sources for Valve Actuation C-5 D-4078 Reactor Coolant Gas Vent System
Reactor Coolant Pressure Boundary up to C-i Orifice
Piping from Orifice to HCV-1 80 and 181 C-2
Piping Down Stream of HCV-1 80 and 181 C-4 E-4144 FW-10 Lube Oil Schematic
Critical Lube Oil components C-3
All Other Components C-5 E-23866-210-1 10 Reactor Coolant System
Main R. C. Loop Pressure Boundary C-1
Pressurizer and Main Piping C-i
Pressurizer Safety and Relief Valve C-4 Discharge, Quench Tank and Tank Relief
Balance of System C-5

USAR Appendix N Information Use Page 15 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&lD No. System Pressure Integrity Class E-23866-21 0-120 Chemical and Volume Control System

Reactor Coolant Pressure Boundary Piping C-i
Charging Flowpath through Regenerative C-2 Heat Exchanger (Shell Side)
Containment Penetrations C-2
Charging Pump Flowpath from Boric Acid C-2 Supply to Containment Penetration
Volume Control Tank and Associated C-3 Piping
Chemical Addition Tank and Metering C-5 Pump Flow Path
Alternate Flowpath from 3.1. and C-2 Refueling Water Tank through Valve LCV-21 8-3
Relief Valve Discharge and Drain Piping C-4 to Waste Disposal and Pressurizer Quench Tank
Flowpath through Letdown Heat Exchanger C-3 Outside Containment
CVCS Ion Exchangers and Associated Piping C-3
Resin Addition Tank and Drain Piping to C-4 Waste Disposal
Demineralized Water Supply Piping C-5
Balance of System C-S
SIRWT Cleanup Flowpath through CVCS C-2 Ion Exchanger CH-9B and associated interface piping E-23866-21 0-121 Chemical and Volume Control System
Boric Acid Flowpath from Storage Tanks C-2 to Charging Pumps
Boric Acid Batching Tank and Associated C-S Piping
Demineralized Water Connection and C-S Balance of System

USAR Appendix N Information Use Page 16 of 17 Classification of Structures Systems, and Components Rev. 11 Table N-2 (Continued) P&ID No. System Pressure Integqrity Class E-23866-21 0-130 Safety Injection and Containment Spray System

Reactor Coolant Pressure Boundary Piping C-i
Safety Injection Tank and Associated C-2 Piping
Containment Spray Headers Inside C-2 Containment
Safety Injection Headers Inside C-2 Containment
Header from Safety Injection Leakage C-2 Coolers to CVCS inside containment
Shutdown Cooling Suction Piping C-i Containment Penetration (M-i16)
Balance of Containment Penetrations C-2
S.I. and Refueling and Water Tank and SC-2 Containment Sump through Pumps and Heat Exchangers Including Recirculation Piping
Alternate Flowpath from S.I. and C-2 Refueling Water Tank through Valve LCV-21 8-3 to Charging Pumps
S.I. and Refueling Water Tank Vents C-4
Relief Valve Discharge C-4
LPSI System Jockey Pump C-2
Balance of System C-5 B-i120-F03001 Emergency Diesel Generator Lube Oil C-3 System B-i120-F04002 Emergency Diesel Generator Jacket C-3 Water System B-i120-F07001 Emergency Diesel Generator Starting Air
Pressure Boundary from Air Receivers to C-3 Air Start Motors
Air Compressors and Associated Piping C-5 13007.54-EM-iA Post Accident Sampling SystemC4& C-4&5

USAR Appendix N Information Use Page 17 of 17 Classification of Structures Systems, and Components Rev. 11

6.0 REFERENCES

6.1 ANSI/ANS-58. 14-2011, Safety and PressureIntegrity ClassificationCriteria for Light Water Reactors 6.2 10 CFR 50.2, Definitions 6.3 10 CFR 50.34, Contents of Applications, Technical In formation 6.4 10 CFR 50.67, Accident Source Term 6.5 10 CFR 50, Appendix A, General Design Criteriafor Nuclear Power Plants 6.6 10 CFR 100, Reactor Site Criteria 6.7 NRC Regulatory Guide 1.29, Revision 3, Seismic Design Classification

Memorandum Date: August 26, 2015 To: Lou Cortopassi Sit.e Vice President and ONO From: Darrell G. Eisenhut NSRB Chairman

Subject:

Fort Calhoun Licensing BasisStation, License to Allow Use ofAmendment Equipment Request to Revise Classification Current from Methodology ANSI/ANS-58.2011I In accordance with the provisions of 10 CER 50.90, the Omaha Public Power District* (OPPO),

is requesting an amendment to the Updated Safety Analysis Report (USAR) for Fort Calhoun Station (ECS), Unit No. 1 Specifically, the proposed amendment would modify the USAR to allow use of the equipment classification methodology in ANSI/ANS-58.14-201 1, Safety and pressure Integrity ClassificationCriteriafor Light Water Reactors.

The NSRB reviewed the proposed License Amendment Request. The FCS's Plant Operations Review Committee (PORC) previously reviewed and concurred with the proposed change. The NSRB APPROVED the proposed LAR for submittal to the NRC, but the NSRB did offer suggestions to clarify the submittal and to provide additional bases for the proposal. Management committed to review and consider the changeslto the submittal. A quorum of NSRB members was in attendance as follows: D. Eisenhut T. J. Doering D. Hanley Hoots B. Eaton Gi. Gellinch M.Virgillio S. Dean D. Wozniak

                                                                                                 'S
                                                                                        -MN@}}

v t e Letter Sequence Request
CAC:MF6721, (Withdrawn, Closed)
Initiation Request Acceptance Administration Questions 23 February 2016 27 May 2016 Answers 8 April 2016 Results Withdrawal Other:
MONTHYEAR2016-02-23 [Table View]

LIC-15-0081, License Amendment Request (LAR) 15-02, Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.14-2011

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6.0 REFERENCES

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4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

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LIC-15-0081, License Amendment Request (LAR) 15-02, Revise Current Licensing Basis to Allow Use of Equipment Classification Methodology from ANSI/ANS-58.14-2011

Text

SUBJECT:

Enclosure:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

6.0 REFERENCES

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

1.0 CORREDL

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