ULNRC-05941, Proposed Revision to Final Safety Analysis Report FSAR-SP Sections 3.7(B) & 3.7(N), Seismic Design (License Amendment Request LDCN 12-0041)

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Proposed Revision to Final Safety Analysis Report FSAR-SP Sections 3.7(B) & 3.7(N), Seismic Design (License Amendment Request LDCN 12-0041)
ML13002A370
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/20/2012
From: Neterer D
Ameren Missouri, Union Electric Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-05941
Download: ML13002A370 (68)


Text

{{#Wiki_filter:~~ VAmeren MISSOURI Callaway Plant December 20, 2012 ULNRC-05941 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.90 10 CFR 50.59(c)(2)(viii) Ladies and Gentl~men: DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO. FACILITY OPERATING LICENSE NPF-30 PROPOSED REVISION TO FINAL SAFETY ANALYSIS REPORT FSAR-SP SECTIONS 3.7(B) & 3.7(N), "SEISMIC DESIGN" (LICENSE AMENDMENT REQUEST LDCN 12-0041) Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Union Electric (d/b/a Ameren Missouri) herewith transmits an application for amendment to Facility Operating License Number NPF-30 for the Callaway Plant in order to incorporate a proposed change to the Final Safety Analysis Report- Standard Plant, Section 3.7(N), "Seismic Design." The proposed amendment would revise a methodology in the licensing basis, as described in the Final Safety Analysis Report- Standard Plant (FSAR-SP), to include damping values for the seismic design and analysis of the integrated head assembly (IHA) that are consistent with the recommendations of Regulatory Guid~ (RG) 1.61, "Damping Values for Seismic Design ofNuclear Power Plants," Revision 1. The RG 1.61, Revision 1, Table 1 note allowing use of a "weighted average" for design-basis safe-shutdown earthquake (SSE) damping values applicable to steel structures of different connection types is also applied to determine the IHA design-basis operating-basis earthquake (OBE) damping values. Enclosure 1, "Evaluation- Proposed Revision to Final Safety Analysis Report FSAR-SP Sections 3.7(B), 3.7(N) and Appendix 3A," provides a description and evaluation of the proposed changes, in support of this amendment request.

*************************************************************************************************************************       PO Box 620                  Fulton, MO 65251                    AmerenMissouri.com

ULNRC-05941 December 20, 2012 Page2 It has been determined that this amendment application does not involve a significant hazard consideration as determined per 10 CFR 50.92, "Issuance of amendment." Pursuant to 10 CFR 51.22, "Criterion categorical exclusion or otherwise not requiring environmental review," Section (b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment. The Callaway Onsite Review Committee and a subcommittee of the Nuclear Safety Review Board have reviewed and approved the proposed changes and have approved the submittal of this amendment application. In accordance with 10 CFR 50.91 "Notice for public comment; State consultation," Section (b)(l), a copy of this amendment application is being provided to the designated Missouri State official. Ameren Missouri requests approval of the requested license amendment prior to September 30, 2013 in order to meet our internal design change package approval milestone. Ameren Missouri further requests that the license amendment be made effective upon NRC issuance, to be implemented within 90 days from the date of issuance. This letter does not contain new commitments. Please contact Scott Maglio, Regulatory Affairs Manager, at (573) 676-8719 for any questions you may have regarding this amendment application. I declare under Nnalty of petjury that the foregoing is true and correct. Sincerely, Executed on: /~ -.:l.d -tll..Or.L David W. Neterer Plant Director

Enclosures:

1. Evaluation- Proposed Revision to Final Safety Analysis Report FSAR-SP Sections 3.7(B),

3.7(N) and Appendix 3A.

ULNRC-05941 December 20, 2012 Page3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy) Attn: Document Control Desk Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr. Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Residept Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-05941 December 20, 2012 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.) Electronic distribution for the following can be made via FSAR ULNRC Distribution: A. C. Heflin F. M. Diya C. O. Reasoner III L. H. Graessle S. A. Maglio R. Holmes-Bobo NSRB Secretary T. B. Elwood Mr. Mike Westman (WCNOC) Mr. Tim Hope (Luminant Power) Mr. Ron Barnes (APS) Mr. Tom Baldwin (PG&E) Mr. Mike Murray (STPNOC) Ms. Linda Conklin (SCE) Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP) Missouri Public Service Commission

ULNRC-05941 Enclosure 1 Evaluation - Proposed Revision to Final Safety Analysis Report FSAR-SP Sections 3.7(B), 3.7(N) and Appendix 3A Page 1 to ULNRC-05941 EVALUATION 1.0

SUMMARY

DESCRIPTION ................................................................................ 3 2.0 DETAILED DESCRIPTION ................................................................................ 3

3.0 TECHNICAL EVALUATION

.............................................................................. 5 3.1 System Description ........................................................................................... 5 3.2 Proposed Damping Values ............................................................................... 6 3.3 IHA Seismic and LOCA Analysis .................................................................... 8 3.4 Summary......................................................................................................... 10

4.0 REGULATORY EVALUATION

....................................................................... 11 4.1 Applicable Regulatory Requirements/Criteria ............................................... 11 4.2 Precedents ....................................................................................................... 11 4.3 No Significant Hazards Consideration Determination ................................... 12 4.4 Conclusions .................................................................................................... 14

5.0 ENVIRONMENTAL CONSIDERATION

........................................................ 14

6.0 REFERENCES

..................................................................................................... 14 ATTACHMENTS:

Attachment 1: Integrated Head Assembly Figures Attachment 2: Stress Summary Tables Attachment 3: AREVA Document No. 38-9182306, Damping Values for Use in the IHA Seismic Response Analysis Attachment 4: Proposed FSAR Mark-Ups Page 2 to ULNRC-05941 EVALUATION 1.0

SUMMARY

DESCRIPTION The change proposed in this amendment application would revise the current licensing basis methodology of Regulatory Guide (RG) 1.61, Damping Values for Seismic Design of Nuclear Power Plants, Revision 0, as described in the Final Safety Analysis Report Update (FSAR), to include damping values for the seismic design and analysis of the integrated head assembly (IHA) that are consistent with the recommendations of RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 1. The RG 1.61, Revision 1, Table 1 note allowing use of a "weighted average" for design-basis Safe Shutdown Earthquake (SSE) damping values applicable to steel structures of different connection types is also applied to determine the IHA design-basis Operating Basis Earthquake (OBE) damping values. The proposed damping values are to be used in conjunction with the response spectrum analysis of the IHA to qualify various structural components in the IHA and in developing the reaction loads from the IHA on the replacement reactor vessel closure head (RRVCH) and on the containment cavity wall seismic embedments. The current licensing basis use of R.G. 1.61 Rev. 0 is retained for all structural analyses that do not address the structural qualification of the IHA. The IHA is analyzed for the following Callaway Plant design-basis seismic events: the operating-basis earthquake (OBE) and the safe-shutdown earthquake (SSE). These postulated seismic events are discussed in the FSAR, Sections 3.7(B) and 3.7(N), and in NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No. 1. 2.0 DETAILED DESCRIPTION 2.1 Proposed Changes The proposed change would revise FSAR-SP Section 3.7(N).1.3, Critical Damping Values, to include the following paragraph: The damping values for the integrated head assembly (IHA) are also given in Table 3.7(N)-1. These damping values are based on the note from Regulatory Guide 1.61 Revision 1, Table 1, allowing the use of a calculated weighted average damping value for a structure with a combination of different connection types, for the design-basis Safe Shutdown Earthquake (SSE). The note from Table 1 was also applied to Table 2 of Regulatory Guide 1.61 Revision 1 to determine the IHA design-basis Operating Basis Earthquake (OBE) damping value. This methodology was approved in the NRC Safety Evaluation Report dated ________, 2013 issued for Amendment __ to the Callaway Operating License. Page 3 to ULNRC-05941 FSAR Table Table 3.7(N)-1 will also be revised to include the damping values for the IHA, a steel structure with a combination of welded and bolted bearing connections, for the OBE and SSE, respectively, as shown below: Item Percent of Critical Damping OBE SSE Integrated Head Assembly 4.50*** 6.25*** The following footnote will also be added to FSAR-SP Table 3.7(N)-1:

                    ***     Conservative damping values for the IHA are based on the recommendations in RG 1.61, Revision 1, Tables 1 and 2, using a weighted average for "Welded Steel or Bolted Steel with Friction Connections" and "Bolted Steel with Bearing Connections, as supported by Amendment __ to the Callaway Operating License."

The proposed change will also add RG 1.61, Revision 1 to FSAR Appendix 3A, Conformance to NRC Regulatory Guides, as one of the Regulatory Guides to which Callaway conforms. A description of Callaways conditional conformance to the Regulatory Guide for the IHA will be included.

2.2 Background

RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," provides acceptable damping values to be used in the elastic dynamic seismic analysis and design of structures, systems, and components (SSCs), where energy dissipation is approximated by viscous damping unless otherwise specified. The seismic damping values contained in RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 0 are currently identified in the Callaway FSAR. The damping values listed in RG 1.61 Revision 0 were used for the design of the current reactor vessel closure head and the service structure located on top of the head. RG 1.61, Revision 1, Table 1, SSE Damping Values, contains a note allowing use of a "weighted average" for design-basis SSE damping values applicable to steel structures of different connection types. RG 1.61, Revision 1 also contains a table (Table 2, OBE Damping Values) that specifies damping values for OBE analyses. However, there is no note allowing use of a weighted average provided for Table 2. Since use of a weighted average should be acceptable for determining a damping value for OBE analysis, a weighted average will be applied to determine the IHA design-basis OBE damping value. In addition, the SSE weighted average damping value will also be used for the design-basis loss-of-coolant accident (LOCA) in the structural analysis of the IHA. Based on the above, for damping values used in the seismic design of the IHA, the FSAR will be revised to refer to RG 1.61, Revision 1, in order to allow the use of a Page 4 to ULNRC-05941 weighted average for the SSE damping value used in the IHA seismic design, as permitted per Revision 1 of the Regulatory Guide, as well as to allow use of a weighted average for the OBE damping values used in the IHA seismic design-basis. (In addition, the use of a weighted average, identical to the SSE weighted average damping value, will similarly be used for the damping value used in the analysis of LOCA loads in the IHA design basis.) Collectively, Ameren Missouri has determined that the proposed change requires prior NRC approval since it involves a departure from a methodology per 10 CFR 50.59(c)(2)(viii).

3.0 TECHNICAL EVALUATION

3.1 System Description

The IHA (see Figure 1 in Attachment 1) is primarily a bolted steel structure (with some welded connections but no bolted friction connections) consisting of various components designed to provide cooling for the control rod drive mechanisms (CRDMs), radiation shielding for workers performing activities near the RRVCH, seismic support for the CRDMs and other IHA components, and to facilitate lifting of the IHA and the RRVCH during refueling outages. The IHA is a new structure that does not have an existing equivalent. However, the IHA incorporates the functions of the former CRDM seismic support structure, the CRDM ventilation cooling system, and the head lift rig. The IHA consists of the following major components:

  • Integral ductwork supplying exhaust fans for the CRDM air cooling system (see Figure 2 in Attachment 1) (NOTE: The ductwork forms part of the IHA structure and is not composed of traditional round or rectangular sheet steel ducts such as described in Table 5 of RG 1.61, Revision 1. The ductwork inside the IHA shroud, is considered a structural component of the IHA and, therefore, RG 1.61, Revision 1 damping values corresponding to steel structures will be applied to those portions of the IHA that provide an air duct function.)
  • Seismic support structure for the CRDMs and other IHA components (see Figure 3 in Attachment 1)
  • Integral missile shield for postulated CRDM assembly missiles
  • Lift rig for IHA/RRVCH lifting and movement
  • Access ports for RRVCH nozzle inspection
  • Radiation shielding above the RRVCH in the IHA lower shroud region
  • Access ports for core exit thermocouple (CET) cable connections and other components
  • Supports for CET cable trays Page 5 to ULNRC-05941
  • Walkway for personnel access to IHA electrical cables and other components
  • Cable bridges to route IHA electrical and instrumentation cables to bulkheads on the refuel floor The above components are assembled together to form primarily a bolted steel structure that is bolted and pinned to the reactor vessel closure head. The IHA and RRVCH are lifted and moved as a single unit during refueling outages.

The integrated head assembly (IHA) employs two duct areas to route air from the CRDM assembly locations (above the reactor head insulation), through the middle shroud, and up to the plenum area where fans exhaust the air to the containment atmosphere. Figure 2 in Attachment 1 shows a cutaway view of the middle shroud to show the geometric shape of the two duct areas. The duct area shape, as shown in Figure 2, is representative of the duct area shape from the bottom of the IHA up to the bottom of the plenum. The seismic support structure assembly is an integral part of the IHA shroud assembly near the refueling floor elevation that provides lateral structural support for the IHA and CRDMs. Figure 3 in Attachment 1 shows the major components included in the seismic support structure assembly. (Some items that are attached to the support structure are excluded for clarity.) The seismic support structure assembly includes four seismic tie-rod restraints to transfer loads from the IHA and CRDMs to the cavity walls. Each tie-rod is pinned at both ends to connect the IHA to the reactor cavity concrete wall just below the refueling floor elevation. The CRDM seismic support assembly in the IHA includes a network of individual digital rod position indication (DRPI) plates that can transmit the seismic loads from the CRDM pressure housings to the seismic frame assembly at the top of the housings by means of impact after the gaps between the plates are closed during seismic excitation. By providing a lateral support for each CRDM at the top of the pressure housing unit, the loads on the RRVCH are reduced considerably. The outer section of the seismic support assembly interfaces with the containment walls through seismic tie-rods to form a continuous load path in the horizontal direction to transfer loads from the CRDMs to the containment walls. For the rest of the IHA components, one load path is through the IHA support columns and through the seismic tie-rods into the containment wall. The other load path is through the IHA support columns and lift rods into the RRVCH. 3.2 Proposed Damping Values The damping values in RG 1.61, Revision 0, were previously used for Callaway in the seismic analysis of seismic Category I structures, systems and components, except that higher damping values were used for cable tray systems, conduit support systems, and the primary reactor coolant loop system, as discussed in NUREG-0830 and as described in the Callaway FSAR. RG 1.61, Revision 1 updated the NRC guidance in RG 1.61, Page 6 to ULNRC-05941 Revision 0, to incorporate the latest data and information, and reduce unnecessary conservatism in specification of damping values for seismic design and analysis of SSCs in nuclear power plants. The various components of the IHA are generally connected with bolted bearing connections. However, the IHA includes a small number of welded connections. RG 1.61, Revision 0, does not provide damping value guidance for structures that include different types of connections. Therefore, the note in Table 1 of RG 1.61, Revision 1, was used, which states:

           "For steel structures with a combination of different connection types, use the lowest specified damping value, or as an alternative, use a "weighted" average damping value based on the number of each type present in the structure."

RG 1.61, Revision 1, Table 1 is applicable to system and component analysis for the design-basis SSE. RG 1.61, Revision 1, Table 2 for OBE damping values does not contain the same note found in Table 1 for SSE that describes how to address steel structures with different types of connections. However, use of the note for the determination of the OBE damping value is consistent with the use of the note for the determination of the SSE damping value, and a weighted average damping value more realistically represents the IHA structure. The IHA contains mostly bolted bearing connections, using the damping value associated with all connections being welded would be overly conservative. Therefore, the damping values associated with the weighted average of connection types were determined. The IHA connections that transfer a significant level of seismic inertia load were identified and categorized as either welded or bolted. Of 315 total significant load carrying connections, 48 connections are welded and the remaining 267 are bolted bearing/pinned connections. All pinned connections are treated as bolted bearing connections. A detailed discussion of the determination of the damping values based on the categorized number of welded and bolted bearing/pinned connections is provided in Attachment 3. Using the guidance provided by RG 1.61, Revision 1 along with the proposed damping values in Tables 1 and 2, for the given number of welded and bolted bearing/pinned connections in the IHA, the calculated damping values are 4.7% and 6.54% for OBE and SSE, respectively (see Attachment 3). However, slightly lower values (i.e. 4.5% for OBE and 6.25% for SSE) were actually used in the IHA seismic response analysis. NRC approval of this amendment request for the IHA will confirm the acceptability of this approach of applying the RG 1.61, Revision 1, Table 1 note to the OBE damping values in addition to the SSE damping values. Page 7 to ULNRC-05941 3.3 IHA Seismic and LOCA Analysis The Callaway Replacement Reactor Vessel Closure Head (RRVCH) will replace the reactor vessel head and CRDMs and add an Integrated Head Assembly (IHA) that provides a seismic support structure for the CRDMs, a missile shield and a lifting rig structure. The result is that there will be a net increase in overall weight due to the added weight of the IHA versus the current lift rig / platform, as well as a change in mass distribution of the upper portion of the reactor vessel head. As a result, the dynamic response(s) of the RRVCH for both OBE and SSE seismic events was determined, and response spectra for damping values of 0.5%, 1.0%, 2.0%, 3.0%, 4.0%, 5.0%, and 7.0% were generated. A finite element structural analysis model was created for the IHA as depicted in Figure 4 in Attachment 1. Shell elements were used to model IHA plate components, and beam elements were used to model IHA linear members such as columns and beams. The model included mass elements to represent the mass of components that were not explicitly included in the model such as the exhaust fans and pipe supports. The analysis model accounted for the tie-rod tension-only capability by adjusting the tie-rod stiffness for each of the three directions of seismic excitation such that modeled stiffness represents the stiffness associated with only the "active" tie-rods that resist applied loads in tension. Uniform support motion (USM) response spectrum analyses were performed for seismic (OBE, SSE) loading where envelopes of the building spectra at elevation 2047'- 6" and the RRVCH spectra are applied at the tie rod attachments to the cavity walls and the ring beam attachments to the RRVCH. The weighted damping approach was then applied in addressing damping in a structural assembly for which the connections are a combination of welded and bolted bearing/pinned. Conservatively, SSE response spectra plots for a weighted damping ratio of 6.25% damping were determined as envelopes of the 5% damped SSE spectra at the containment operating floor elevation and 6.25% damped SSE spectra at the center-of-gravity of the RRVCH. The 6.25% damped SSE spectra at the center-of-gravity of the RRVCH were determined by linear interpolation between the 5% damped and 7% damped spectra. In addition, OBE envelope spectra for 4.5% damping were calculated as the envelope of the 2% damped OBE spectra at the containment operating floor elevation and 4.5% damped OBE spectra at the center-of-gravity of the replacement reactor vessel closure head (RRVCH). The 4.5% damped OBE spectra at the center-of-gravity of the RRVCH were then determined by linear interpolation between the 4% damped and 5% damped OBE spectra. Consistent with Callaways licensing basis and as described in the FSAR, the response spectra for the containment building that is utilized in the IHA analysis, is conservatively based on the bounding spectra from the three SNUPPS standard plant sites (Callaway, Wolf Creek and Sterling). Page 8 to ULNRC-05941 For the OBE and SSE seismic analyses, the responses due to the North-South, East-West and vertical seismic analyses were combined by the square-root-of-the-sum-of-the-squares (SRSS) method to determine the stresses, loads and displacement for use in the IHA evaluation. The seismic analyses loads, stresses and displacements were combined with those due to other applicable loads such as deadweight and pressure to determine the total loads, stresses and displacements for the various components of the IHA. For the design and analysis of the IHA, all ASME Section III, Subsection NF and other safety-related components correspond to seismic Category I components, and the remaining non-safety-related components in the IHA correspond to non-seismic Category I components. Non-seismic Category I components are seismically qualified as required to preclude adverse effects on seismic Category I components per FSAR Section 3.7(B).2.8. The Callaway FSAR does not address loss-of-coolant accident (LOCA) loads or LOCA load analysis damping methods for structures such as the IHA. However, Ameren Missouri elected to determine reactor vessel closure head motions associated with LOCA events and to analyze the IHA for those motions. The RRVCH response spectra for LOCA were generated with the IHA structure attached to the RRVCH. The response spectra input used for the IHA LOCA analysis is the envelope of the response spectra associated with a pressurizer surge line break, residual heat removal (RHR) line break, and accumulator line break. Callaway is approved for leak-before-break for the reactor coolant loop, and therefore does not need to postulate breaks associated with the main reactor coolant loop for analyses such as the IHA structural analysis. LOCA load motions are applicable at the reactor head and were therefore applied at the center-of-gravity of the RRVCH, which includes the IHA. LOCA loads are Faulted loads, and therefore, they are combined with SSE loads (with the same damping values for both LOCA and SSE) by the SRSS method to qualify IHA seismic Category I components against the faulted allowables. Response spectra for LOCA analysis are at the same damping values as for the SSE. The 6.25% damped LOCA spectra of the RRVCH were determined by linear interpolation between the 5% damped and 7% damped LOCA spectra. The table below summarizes the seismic and LOCA load analysis methods used for the IHA. Analyses were performed using the Uniform Support Motion (USM) linear elastic response spectra method. Page 9 to ULNRC-05941 IHA Seismic and LOCA Load Analysis Method Summary OBE SSE LOCA Horizontal Vertical Horizontal Vertical Horizontal Vertical Analysis USM1 USM1 USM1 USM1 Response Response Method Response Response Response Response Spectra3 Spectra3 Spectra2 Spectra2 Spectra2 Spectra2 Damping 4.50% 4.50% 6.25% 6.25% 6.25% 6.25% 1 USM refers to the use of Uniform Support Motion (enveloped spectra) as input to the response spectra analysis. 2 OBE and SSE response spectra inputs were applied where the IHA tie rods are attached to the containment cavity wall and where the IHA lift rods and the bottom ring beam are attached to the RRVCH. 3 LOCA response spectra inputs were applied where the IHA lift rods and the bottom ring beam are attached to the RRVCH. Tables 1 through 4 of Attachment 2 provide the member stress summaries for the controlling load combination. Table 5 of Attachment 2 provides a summary of the evaluation of connections between seismic Category I components. The stress ratio is the calculated load or stress divided by the allowable value. Stress ratios equal to 1.0 represent an acceptable load or stress value with the required margin per the applicable code, and stress ratios below 1.0 represent additional margin beyond that required by the applicable code. Table 6 of Attachment 2 provides a list of the materials used for construction of the IHA. The resulting IHA loads and stresses for seismic Category I components were evaluated using acceptance criteria corresponding to the ASME Boiler and Pressure Vessel Code, Section III, Division 1, Subsection NF, Component Supports, 2001 Edition through 2003 Addenda, Class 1 (i.e., ASME NF Class 1). For seismic Category I and non-seismic Category I plate and shell components, the loads and stresses were evaluated using acceptance criteria corresponding to ASME NF Class 1. Non-seismic Category I linear component loads and stresses were evaluated using acceptance criteria corresponding to ASME NF Class 1 since design by analysis for Class 2 linear supports uses the same acceptance criteria as Class 1 per NF-3350. The complete IHA analysis includes hundreds of stress and load comparisons to allowable limits. All loads and stresses met acceptance limits. 3.4 Summary A finite element structural analysis model was created for the IHA using critical damping values consistent with RG 1.61, Revision 1. The Table 1 note in RG 1.61, Revision 1, allowing use of a "weighted average" for SSE damping values applicable to steel structures of different connection types, is also applied to the determination of OBE damping values. The IHA was evaluated for the following seismic events: OBE and SSE. The SSE loads were combined with LOCA loads by the SRSS method for seismic Category I components. The damping value used for LOCA is the same as the Page 10 to ULNRC-05941 one used for SSE. The resulting IHA loads and stresses were evaluated for acceptance using the ASME Boiler and Pressure Vessel Code, Section III, Division 1 - Subsection NF, "Component Supports," 2001 Edition through 2003 Addenda. All loads and stresses met acceptance limits.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Regulatory Guide (RG) 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 1 RG 1.61, Revision 1, specifies the damping values that the NRC staff currently considers acceptable for complying with the agency's regulations and guidance for seismic analysis. Revision 1 updated the NRC guidance for use in reviewing elastic modal (dynamic) seismic analysis of seismic Category I SSCs. This revision incorporates the latest data and information, and reduces unnecessary conservatism in specification of damping values for seismic design and analysis of SSCs in nuclear power plants. Section D, "Implementation," of Revision 1 states that "NRC staff will use the methods described in this guide to evaluate (1) submittals in connection with applications for construction permits, standard plant design certifications, operating licenses, early site permits, and combined licenses; and (2) submittals from operating reactor licensees who voluntarily propose to initiate system modifications if there is a clear nexus between the proposed modifications and the subject for which guidance is provided herein." The proposed calculated damping values for the seismic design and analysis of the IHA (4.7 for the OBE, and 6.54 for the SSE) are consistent with the recommendations of RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 1. The RG 1.61, Revision 1, Table 1 note allowing use of a "weighted average" for design-basis SSE damping values applicable to steel structures of different connection types is also applied to determine the design-basis OBE damping values. RG 1.61, Revision 1, Table 2 for OBE damping values does not contain the same note found in Table 1. However, use of the note for the determination of the OBE damping value is consistent with the use of the note for the determination of the SSE damping value, and a weighted average more realistically represents the IHA structure. 4.2 Precedents RG 1.61, Revision 1, has been approved for Diablo Canyon Power Plant, Units 1 and 2, through License Amendments No. 208 and 210, dated September 29, 2010. These amendments were made for the purpose of applying weighted average damping Page 11 to ULNRC-05941 values based on guidance provided in RG 1.61, Revision 1, for analysis of a similar integrated head assembly (IHA) installed at Diablo Canyon Power Plant, Units 1 and 2. 4.3 No Significant Hazards Consideration Determination The proposed change would revise the licensing basis as documented in the Final Safety Analysis Report (FSAR) to specify critical damping values consistent with Regulatory Guide (RG) 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 1, dated March 2007, for the seismic design and analysis of an integrated head assembly (IHA). The RG 1.61, Revision 1, Table 1 note allowing use of a "weighted average" for design-basis safe-shutdown earthquake (SSE) damping values applicable to steel structures of different connection types, is also applied to determine the IHA design-basis operating-basis earthquake (OBE) damping values. The IHA, installed with a replacement reactor vessel closure head (RRVCH), is primarily a bolted steel structure (with some welded connections but no bolted friction connections) consisting of various components designed to provide cooling for the control rod drive mechanisms (CRDMs), radiation shielding for workers performing activities near the RRVCH, seismic support for the CRDMs and other components, and to facilitate lifting the RRVCH and IHA during refueling outages. The IHA is a new structure that does not have an existing equivalent. However, the IHA incorporates the functions of the former CRDM seismic support structure, the CRDM ventilation cooling system, and the head lift rig. Ameren Missouri 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change would allow use of critical damping values consistent with the recommendations of RG 1.61, "Damping Values for Seismic Design of Nuclear Power Plants," Revision 1, dated March 2007, for the seismic design and analysis of the IHA. The RG 1.61, Revision 1, Table 1 note allowing use of a "weighted average" for design-basis SSE damping values applicable to steel structures of different connection types, is also applied to determine the IHA design-basis OBE damping values. RG 1.61, Revision 1, Table 2 for OBE damping values does not contain the same note found in Table 1. However use of the note for the determination of the OBE damping value is consistent with the use of the note for the determination of the SSE damping values, and a weighted average more realistically represents the IHA structure. Page 12 to ULNRC-05941 RG 1.61, Revision 1, specifies the damping values that the NRC staff currently considers acceptable for complying with the agency's regulations and guidance for seismic analysis. Revision 1 incorporates the latest data and information, and reduces unnecessary conservatism in specification of damping values for seismic design and analysis of SSCs. The proposed change does not change the design functions of the IHA or its response to design-basis events, nor does it affect the capability of related SSCs to perform their design or safety functions. The use of the proposed damping values in the seismic design and analysis of the IHA is related to the ability of the IHA to function in response to design-basis seismic events, and is unrelated to the probability of occurrence of those events, or other previously evaluated accidents. Therefore, the proposed change will not have any impact on the probability of an accident previously evaluated. The proposed damping values are an element of the seismic analyses performed to confirm the ability of the IHA to function under postulated seismic events while maintaining resulting stresses within ASME Section III allowable values. Therefore, the use of damping values consistent with the recommendations of RG 1.61, Revision 1 does not result in an increase in the consequences of accidents previously evaluated. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed change does not involve changes to any plant SSCs, nor does it involve changes to any plant operating practice or procedure. The damping values are an element of the seismic analyses performed to confirm the ability of the IHA to function under postulated seismic events while maintaining resulting stresses within ASME Section III allowable values. Therefore, no credible new failure mechanisms, malfunctions, or accident initiators not considered in the design and licensing bases are created that would create the possibility of a new or different kind of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No Page 13 to ULNRC-05941 The design basis of the plant requires structures to be capable of withstanding normal and accident loads including those from a design basis earthquake. The proposed change would allow the use of damping values in the IHA seismic analyses that are, in general, more realistic and, thus, more accurate than the damping values recommended in RG 1.61, Revision 0, used in the original analysis for the SSE, or the plant specific damping values used in the original analysis for the OBE. The damping values in RG 1.61, Revision 0, were based on limited data, expert opinion, and other information available in 1973. NRC and industry research since 1973 shows that the damping values provided in the original version of RG 1.61 may not reflect realistic damping values for SSCs. RG 1.61, Revision 1, therefore, provides damping values based on the updated research results that predict and estimate damping values for seismic design of SSCs in nuclear power plants, and similarly should not be regarded as an arbitrary lowering of the margins of safety. 4.4 Conclusions 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

Ameren Missouri has evaluated the proposed amendment and has determined that the proposed amendment does not involve: (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) 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 need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Regulatory Guide 1.61, "Damping Values for Seismic Design of Nuclear Power Plants,"

Revision 1, March 2007

2. Regulatory Guide 1.61, "Damping Values for Seismic Design of Nuclear Power Plants,"

Revision 0, October 1973

3. NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No. 1," dated October, 1981
4. NRC Letter from Mr. A. Wang to Mr. J. Conway, Diablo Canyon Power Plant, Unit Nos.

1 and 2 - Issuance of Amendments Re: Revision to Final Safety Analysis Report Update Section 3.7.1.3, Critical Damping Values (TAC Nos. ME4056 and ME4057), dated September 29, 2010 Page 14 to ULNRC-05941

5. Final Safety Analysis Report, Revision 19 ATTACHMENTS:

Attachment 1: Integrated Head Assembly Figures Attachment 2: Stress Summary Tables Attachment 3: AREVA Document No. 38-9182306, Damping Values for Use in the IHA Seismic Response Analysis. Attachment 4: Proposed FSAR Mark-Ups Page 15 to Enclosure 1 to ULNRC-05941 Attachment 1: Integrated Head Assembly Figures Page 1 to Enclosure 1 to ULNRC-05941 Figure 1: Integrated Head Assembly Page 2 to Enclosure 1 to ULNRC-05941 Figure 2: CRDM Ductwork inside IHA Shroud Page 3 to Enclosure 1 to ULNRC-05941 Figure 3: CRDM Seismic Support Assembly (ASME NF Component) Page 4 to Enclosure 1 to ULNRC-05941 Z Y X Figure 4: Finite Element Model of IHA Page 5 to Enclosure 1 to ULNRC-05941 Attachment 2: Stress Summary Tables Page 1 to Enclosure 1 to ULNRC-05941 Table 1 Member Stress Summary for Controlling Load Combination ASME Section III, Subsection NF, Safety-Related and Seismic Category I Linear Components Controlling Load Stress Component Description Combination Ratio Seismic Support Beam DL + P +/- srss(SSE + LOCA) 0.53 Seismic Ring Beam DL + P +/- srss(SSE + LOCA) 0.73 Seismic Reinforced Beam DL + P +/- srss(SSE + LOCA) 0.46 Seismic Support Beam at NW, NE Tie DL + P +/- srss(SSE + LOCA) 0.87 Rods Seismic Bar (Tie Rod Lug) DL + P +/- srss(SSE + LOCA) 0.31 Seismic Tie Rod Bracket, Radial DL + P +/- srss(SSE + LOCA) 0.86 Seismic Tie Rod DL + P +/- srss(SSE + LOCA) 0.74 Mid and Upper Shroud Support Column DL + P +/- srss(SSE + LOCA) 0.31 Lift Rod DL + P +/- srss(SSE + MI) 0.88 Bottom Ring Beam DL + P +/- srss(SSE + LOCA) 0.91 Duct Support in Lower, Mid and Upper DL + P +/- srss(SSE + LOCA) 0.92 Shroud Cable Support Ring Beam DL + P +/- srss(SSE + LOCA) 0.69 NW Cable Bridge Support Horizontal DL + P +/- OBE 0.61 Cross Pipe NW Cable Bridge Longitudinal Tube in DL + P +/- srss(SSE + LOCA) 0.45 Foldable Section NW Cable Bridge Lateral Tube in DL + P +/- srss(SSE + LOCA) 0.49 Foldable Section NW Cable Bridge Vertical Tube in DL + P +/- srss(SSE + LOCA) 0.44 Foldable Section NW Cable Bridge Lateral Tube in DL + P +/- srss(SSE + LOCA) 0.62 Foldable Section NW Cable Bridge Lifting Mechanism DL + P +/- srss(SSE + LOCA) 0.53 Horizontal Support Tube NW Cable Bridge Lifting Mechanism DL + P +/- srss(SSE + LOCA) 0.34 Tube Cable Bridge Support Tube Under Missile DL + P +/- srss(SSE + LOCA) 0.53 Shield CET Vertical Support Assembly at 30 and DL + P +/- srss(SSE + LOCA) 0.51 150 deg. Columns CET Vertical Cable Support Assembly DL + P +/- srss(SSE + LOCA) 0.78 Support Bracket Plates Page 2 to Enclosure 1 to ULNRC-05941 Table 1 Member Stress Summary for Controlling Load Combination ASME Section III, Subsection NF, Safety-Related and Seismic Category I Linear Components Controlling Load Stress Component Description Combination Ratio Angle Connecting Duct Sections - DL + P +/- OBE 0.61 Straight Sections Angle Connecting Duct Sections - Bent DL + P +/- OBE 0.73 Segment NW Cable Bridge Pipe Rod Connecting DL + P +/- srss(SSE + LOCA) 0.74 Cable Bridge and Lifting Mechanism Support Tubes Under Walkway at Bridges DL + P +/- srss(SSE + LOCA) 0.13 Tube Stiffeners Under Walkway at DL + P +/- srss(SSE + LOCA) 0.49 Bridges NW Cable Bridge Small Lateral Tube DL + P +/- srss(SSE + LOCA) 0.28 Bulkhead Panel Support Tubes DL + P + T +/- OBE 0.03 Support Tube Under Valve Platform DL + P +/- srss(SSE + LOCA) 0.57 Lower Support Column DL + P +/- srss(SSE + LOCA) 0.54 Symbols: DL: Dead Load P: Pressure Load OBE: Operating Basis Earthquake Load SSE: Safe Shutdown Earthquake Load SRSS: Square-Root-of-the-Sum-of-the-Squares Load Combination Method LOCA: Loss of Coolant Accident Load T: Temperature Load MI: Missile Impact Load ML: Maintenance Load (live load on walkways during maintenance activities) Notes:

1. ASME Section III, Subsection NF and other Seismic Category I components are classified as safety-related and are designed for seismic loads.
2. The IHA offers no resistance to reactor vessel thermal growth and therefore sustains no stress due to such growth. However, within the IHA components those components that are in contact with the CRDM discharge hot air are evaluated for thermal loads from the CRDM discharge hot air. Applicable service and accident temperatures are considered when determining material properties and material stress allowable.

Page 3 to Enclosure 1 to ULNRC-05941 Table 2 Member Stress Summary for Controlling Load Combination ASME Section III, Subsection NF, Safety-Related and Seismic Category I Plate Components Controlling Load Stress Component Description Combination Ratio Seismic Support Plate Attached to DL + P +/- OBE 0.94 Seismic Ring Beam CRDM DRPI and Filler Plates DL + P +/- srss(SSE + LOCA) 0.19 Missile Shield DL + P +/- OBE 0.22 Bottom Ring Beam Stiffener Plate DL + P +/- OBE 0.76 Support Bracket Connecting Monorail & DL + P + ML 0.87 Walkway to Column Walkway Plate at 0° and 180° DL + P + ML 0.77 Walkway Plate Edge Stiffener DL + P + ML 0.84 Walkway Plate Under Bridges DL + P + ML 0.76 NW Cable Bridge Vertical Support Plates DL + P +/- OBE 0.62 in Stationary Section NW Cable Bridge Support Cross Plates in DL + P +/- OBE 0.45 Stationary Section NW Cable Bridge Support Plate in DL + P +/- OBE 0.53 Foldable Section Stiffener Under Walkway at 0° and 180° DL + P + ML 0.70 RVHVS Support Platform DL + P +/- OBE 0.32 RVHVS Support Platform Edge Stiffener DL + P +/- srss(SSE + LOCA) 0.19 Stiffener Between Walkway and RVHVS DL + P + ML 0.37 Support Platform Bulkhead Panel DL + P +/- srss(SSE + LOCA) 0.19 Bulkhead Platform Floor Plate DL + P +/- OBE 0.19 Bulkhead Platform Kick Plate DL + P +/- OBE 0.39 Bulkhead Platform Stiffener DL + P +/- srss(SSE + LOCA) 0.11 Symbols: DL: Dead Load P: Pressure Load OBE: Operating Basis Earthquake Load SSE: Safe Shutdown Earthquake Load SRSS: Square-Root-of-the-Sum-of-the-Squares Load Combination Method LOCA: Loss of Coolant Accident Load T: Temperature Load MI: Missile Impact Load ML: Maintenance Load (live load on walkways during maintenance activities) Page 4 to Enclosure 1 to ULNRC-05941 Notes:

1. Stress ratios listed in Table 2 above are the maximum values between membrane stress and membrane plus bending stress.
2. ASME Section III, Subsection NF, and other Seismic Category I components are classified as safety-related and are designed for seismic loads.
3. The IHA offers no resistance to reactor vessel thermal growth and therefore sustains no stress due to such growth. However, within the IHA components those components that are in contact with the CRDM discharge hot air are evaluated for thermal loads from the CRDM discharge hot air. Applicable service and accident temperatures are considered when determining material properties and material stress allowable.

Page 5 to Enclosure 1 to ULNRC-05941 Table 3 Member Stress Summary for Controlling Load Combination Non-Safety-Related and Non-Seismic Category I Linear Components Controlling Load Stress Component Description Combination Ratio Angle Beam at Boundary of Each DL + P +/- SSE 0.30 Assembly Tripod Rod DL + P +/- SSE 0.08 Monorail for Stud Tensioner Hoist DL + P + ML 0.37 Baffle Support Beam DL + P +/- SSE 0.61 Duct Support Tubes in Lower Shroud DL + P +/- SSE 0.22 Stiffeners at CET Doors & Windows in DL + P +/- SSE 0.17 Duct Fan Support Top Horizontal Tee Ring DL + P +/- SSE 0.18 Fan Support Vertical Tube DL + P +/- SSE 0.86 Angles Connecting Lower and Upper DL + P +/- SSE 0.39 Duct Assemblies in Mid and Upper Shroud Stiffener at Base of Duct in Lower Shroud DL + P +/- SSE 0.50 Baffle Cover Support Angle DL + P +/- SSE 0.66 Pipe Rod for Plenum Center Column DL + P + ML 0.19 Angle Frame for Air Plenum DL + P + ML 0.96 Angle Attached to Duct at Top in Upper DL + P +/- SSE 0.49 Section Angle Stiffener Attached to Lower, Mid DL + P + ML 0.91 and Upper Shroud Lower Duct Cable Bundle Supports in Upper Duct DL + P +/- SSE 0.45 Fan Support Top Horizontal Tee Ring DL + P +/- SSE 0.15 with Cutout on Flange and Web Angle of Plenum Attached to Missile DL + P +/- SSE 0.30 Shield Ladder Tube Rail DL + P +/- SSE 0.86 Walkway Access Ladder Support Bracket DL + P + ML 0.37 Assembly Fan Cable Bridge Support DL + P +/- SSE 0.36 Fan Cable Bridge Link Pipe Support DL + P +/- SSE 0.05 Top Tube of Plenum DL + P +/- SSE 0.33 Air Plenum Vertical Tubes DL + P + ML 0.36 Vertical Angle Stiffeners in Lower Duct DL + P + ML 0.23 Vertical Angle Stiffeners in Upper Duct DL + P +/- SSE 0.09 Fan Support Bottom Horizontal Ring DL + P +/- SSE 0.55 Page 6 to Enclosure 1 to ULNRC-05941 Table 3 Member Stress Summary for Controlling Load Combination Non-Safety-Related and Non-Seismic Category I Linear Components Controlling Load Stress Component Description Combination Ratio Monorail End Support Bracket DL + P + ML 0.47 Fan Cable Bridge Longitudinal Beams DL + P +/- SSE 0.12 Stiffener Plate at CET Door in Lower DL + P +/- SSE 0.98 Duct Duct Support Tube in Middle and Upper DL + P +/- SSE 0.66 Shroud NE Cable Bridge Support Horizontal DL + P +/- SSE 0.14 Cross Pipe NE Cable Bridge Longitudinal Tube in DL + P +/- SSE 0.20 Foldable Section NE Cable Bridge Lateral Tube in Foldable DL + P +/- SSE 0.15 Section NE Cable Bridge Vertical Tube in DL + P +/- SSE 0.20 Foldable Section NE Cable Bridge Lifting Mechanism DL + P +/- SSE 0.30 Horizontal Support Tube NE Cable Bridge Lifting Mechanism DL + P +/- SSE 0.15 Tube NE Cable Bridge Pipe Rod Connecting DL + P +/- SSE 0.37 Cable Bridge and Mechanism NE Cable Bridge Small Lateral Tube DL + P +/- SSE 0.12 Symbols: DL: Dead Load P: Pressure Load OBE: Operating Basis Earthquake Load SSE: Safe Shutdown Earthquake Load SRSS: Square-Root-of-the-Sum-of-the-Squares Load Combination Method LOCA: Loss of Coolant Accident Load T: Temperature Load MI: Missile Impact Load ML: Maintenance Load (live load on walkways during maintenance activities) Notes:

1. Non-seismic Category I components are classified as non-safety-related and are designed for SSE seismic loads only.

Page 7 to Enclosure 1 to ULNRC-05941

2. The IHA offers no resistance to reactor vessel thermal growth and therefore sustains no stress due to such growth. However, within the IHA components those components that are in contact with the CRDM discharge hot air are evaluated for thermal loads from the CRDM discharge hot air. Applicable service and accident temperatures are considered when determining material properties and material stress allowable.

Page 8 to Enclosure 1 to ULNRC-05941 Table 4 Member Stress Summary for Controlling Load Combination Non-Safety-Related and Non-Seismic Category I Plate Components Controlling Load Stress Component Description Combination Ratio Baffle DL + P +/- SSE 0.26 Stiffener Plate at Top of Baffle DL + P +/- SSE 0.55 Radiation Shield Door DL + P +/- SSE 0.13 Lower Assembly Shroud Panel DL + P +/- SSE 0.25 Mid Assembly Shroud Panel DL + P +/- SSE 0.23 Lower Assembly Duct DL + P +/- SSE 0.37 Baffle Cover DL + P +/- SSE 0.30 Mid Assembly Duct DL + P +/- SSE 0.26 Upper Shroud Lower Panel DL + P +/- SSE 0.82 Upper Shroud Lower Duct DL + P +/- SSE 0.58 Upper Shroud Upper Panel DL + P +/- SSE 0.73 Upper Shroud Upper Duct DL + P +/- SSE 0.63 CET Access Doors in Lower Assembly DL + P +/- SSE 0.08 Duct Plenum Cover Plates DL + P + ML 0.42 Air Plenum Top Panel DL + P + ML 0.64 Air Plenum Side Panel DL + P +/- SSE 0.26 Fan Separator in Air Plenum DL + P +/- SSE 0.63 Fan Cable Bridge Support Plate DL + P +/- SSE 0.45 Walkway Plate at 270 Degrees DL + P + ML 0.46 NE Cable Bridge Vertical Support Plates DL + P +/- SSE 0.23 in Stationary Section NE Cable Bridge Support Cross Plates in DL + P +/- SSE 0.17 Stationary Section NE Cable Bridge Support Plate in DL + P +/- SSE 0.14 Foldable Section Symbols: DL: Dead Load P: Pressure Load OBE: Operating Basis Earthquake Load SSE: Safe Shutdown Earthquake Load SRSS: Square-Root-of-the-Sum-of-the-Squares Load Combination Method LOCA: Loss of Coolant Accident Load T: Temperature Load MI: Missile Impact Load ML: Maintenance Load (live load on walkways during maintenance activities) Page 9 to Enclosure 1 to ULNRC-05941 Notes:

1. Stress ratios listed in Table 4 above are the maximum values between membrane stress and membrane plus bending stress.
2. Non-seismic Category I components are classified as non-safety-related and are designed for SSE seismic loads only.
3. The IHA offers no resistance to reactor vessel thermal growth and therefore sustains no stress due to such growth. However, within the IHA components those components that are in contact with the CRDM discharge hot air are evaluated for thermal loads from the CRDM discharge hot air. Applicable service and accident temperatures are considered when determining material properties and material stress allowable.

Page 10 to Enclosure 1 to ULNRC-05941 Table 5 Summary of Evaluation of Connections between ASME Section III, Subsection NF Components and Between Safety-Related, Seismic Category I Components Connection Connection Description / Stress Number Controlling Component Controlling Load Combination Ratio SCN-01 Connection of Seismic Tie Rods DL + P + T +/- OBE 0.77 SCN-02 Connection of Lift Rod Clevis to DL + P + T +/- srss(SSE, MI) 0.38 RRVCH Lug SCN-03 Connection of Bottom Ring Beam to DL + P +/- srss(SSE, LOCA) 0.54 Intermediate Pads SCN-04 Connection of Bottom Ring Beam to DL + P + T +/- OBE 0.86 Lift Rod Clevis SCN-05 Connection of Stiffener Plate to DL + P + T +/- srss(SSE, LOCA) 0.89 Bottom Ring Beam SCN-06 Connection of Support Columns to DL + P + T +/- srss(SSE, LOCA) 0.77 Bottom Ring Beam SCN-07 Lower Splice Connection of DL + P + T +/- srss(SSE, LOCA) 0.46 Columns SCN-08 Mid Splice Connection of Columns DL + P + T +/- srss(SSE, LOCA) 0.31 SCN-09 Connection of Kick Plate to N/A N/A Walkway Plate (CJP weld - no evaluation) SCN-10 Connection of Bridge Support Frame N/A N/A Assembly to Seismic Ring Beam (CJP weld - no evaluation) SCN-11 Splice Connection of Walkway Kick DL + P + T +/- srss(SSE, LOCA) 0.84 Plates SCN-12 Connection of Kick Plate to Floor DL + P + T +/- srss(SSE, LOCA) 0.40 Plate on Valve Support Platform SCN-13 Connection of Bridge Support Tubes DL + P + T +/- srss(SSE, LOCA) 0.84 under Walkway to Walkway SCN-14 Connection of Seismic Ring Beam to DL + P + T +/- srss(SSE, LOCA) 0.89 Support Columns SCN-15 U-Bolt Connection of Lift Rod to DL + P + T +/- srss(SSE, LOCA) 0.11 Ring Angles SCN-16 Connection of Walkway to Support DL + P + ML 0.83 Brackets SCN-17 Connection of Monorail / Walkway DL + P + T +/- OBE 0.63 Support Brackets to Columns Page 11 to Enclosure 1 to ULNRC-05941 Table 5 Summary of Evaluation of Connections between ASME Section III, Subsection NF Components and Between Safety-Related, Seismic Category I Components Connection Connection Description / Stress Number Controlling Component Controlling Load Combination Ratio SCN-18 Connection of NW Cable Bridge DL + P + T +/- srss(SSE, LOCA) 0.71 Support to Walkway SCN-19 Connection of NW Bridge Support DL + P + T +/- srss(SSE, LOCA) 0.44 Vertical Side Plates to Front Plates SCN-20 Connection of NW Bridge Support DL + P +/- srss(SSE, LOCA) 0.78 Mid Plate to Vertical Side Plates SCN-21a Connection of Stiffeners to RVHVS DL + P +/- srss(SSE, LOCA) 0.52 Platform and Walkway (Weld) SCN-21b Connection of Stiffener Angle to DL + P +/- srss(SSE, LOCA) 0.52 RVHVS Platform and Walkway (Bolted Connection) SCN-22 Connection of NW Bridge Mid Plate DL + P +/- srss(SSE, LOCA) 0.45 to Front Plate SCN-23 Connection of NW Cable to DL + P + T +/- OBE 0.40 Stationary Section (Pivot) SCN-24a Connection of NW Bridge N/A N/A TS 5x3x1/4, TS 3x3x1/4 Tubes to TS 5x3x1/4, TS 3x3x1/4 Tubes (CJP weld - no evaluation) SCN-24b Connection of NW Bridge DL + P +/- srss(SSE, LOCA) 0.61 TS 2x2x1/4 Lateral Tubes to TS 5x3x1/4, TS 3x3x1/4 Longitudinal Tubes SCN-25 Connection of NW Bridge Vertical DL + P +/- srss(SSE, LOCA) 0.85 Tubes to Longitudinal Tubes SCN-26 Connection of the NW Bridge DL + P + T +/- srss(SSE, LOCA) 0.40 2x2x1/4 Lateral Tubes to the 2x2x1/4 Longitudinal Tubes SCN-27 Connection of NW Bridge DL + P + T +/- srss(SSE, LOCA) 0.58 TS 2x2x1/4 Longitudinal Tubes to TS 5x3x1/4 & TS 3x3x1/4 Lateral Tubes SCN-28 Connection of Stiffeners to Walkway DL + P + ML 0.86 Plate at 0 and 180 Degree Locations Page 12 to Enclosure 1 to ULNRC-05941 Table 5 Summary of Evaluation of Connections between ASME Section III, Subsection NF Components and Between Safety-Related, Seismic Category I Components Connection Connection Description / Stress Number Controlling Component Controlling Load Combination Ratio SCN-29 Connection of NW Cable Bridge DL + P +/- OBE 0.54 Link Pipes SCN-30a Connection of NW Bridge Lifting DL + P + T +/- srss(SSE, LOCA) 0.78 Mechanism Support Lateral Tubes to Ring Tubes SCN-30b Connection of NW Bridge Lifting DL + P + T +/- srss(SSE, LOCA) 0.76 Mechanism to Support Tubes SCN-31 Connection of Messenger Wire DL + P +/- srss(SSE, LOCA) 0.94 Support Ring Tube Assembly to Support Columns SCN-32 Connection of Upper Shroud Top DL + P + T +/- OBE 0.88 Ring Tube to Support Columns SCN-33 Connection of Adjusting Disks to DL + P + T +/- srss(SSE, LOCA) 0.18 Seismic Reinforced Beam SCN-34 Connection of Missile Shield to Tops DL + P + T +/- srss(SSE, LOCA) 0.65 of Columns at Alignment Pins SCN-35 Connection of Missile Shield to Lift N/A N/A Rods (thread engagement verified) SCN-36a Connection of Seismic Plate to N/A N/A Seismic Ring Beam (CJP weld - no evaluation) SCN-36b Connection of Seismic Plate to N/A N/A Reinforced Beam (CJP weld - no evaluation) SCN-37 Connection of CET Vertical Cable DL + P +/- srss(SSE, LOCA) 0.38 Supports to Support Brackets SCN-38 Connection of CET Vertical Cable DL + P + T +/- srss(SSE, LOCA) 0.47 Support Brackets to Duct Support Brackets SCN-39 Connection of Middle Shroud Ducts DL + P + T +/- OBE 0.60

                & Upper Shroud Lower Ducts to Support Brackets SCN-40       Connection of Middle Shroud Duct           DL + P + T +/- OBE         0.72
                  & Upper Shroud Lower Duct Support Brackets to Columns Page 13 to Enclosure 1 to ULNRC-05941 Table 5 Summary of Evaluation of Connections between ASME Section III, Subsection NF Components and Between Safety-Related, Seismic Category I Components Connection           Connection Description /                                        Stress Number              Controlling Component           Controlling Load Combination   Ratio SCN-41       Connection of Upper Shroud Upper             DL + P +/- OBE           0.90 Duct to Seismic Reinforced Beam SCN-42a       Weld Connection of Valve Support                   N/A                N/A Platform to Walkway (CJP weld - no evaluation)

SCN-42b Bolted Connection of Valve Support DL + P + T +/- OBE 0.09 Platform to Walkway SCN-43a Connection of NW, SW, & SE DL + P + T +/- srss(SSE, LOCA) 0.83 Seismic Brackets to Seismic Ring Beam SCN-43b Connection of NE Seismic Bracket to DL + P + T +/- srss(SSE, LOCA) 0.81 Seismic Ring Beam SCN-44 Connection of HVV Platform Floor DL + P + T +/- srss(SSE, LOCA) 0.62 Plate to Kick Plate SCN-45 Connection between Inner and Outer DL + P + T +/- srss(SSE, LOCA) 0.44 Kick Plates on HVV Platform SCN-46 Connection of HVV Bulkhead Panel DL + P + T +/- OBE 0.12 to Support Tubes SCN-47 Connection of HVV Bulkhead DL + P + T +/- srss(SSE, LOCA) 0.08 Support Tubes to Bulkhead Platform Floor Plate SCN-48 Connection between Stiffeners and DL + P + T +/- srss(SSE, LOCA) 0.83 Stiffeners to HVV Platform Floor Plate SCN-49 Connection of HVV Platform to DL + P + T +/- srss(SSE, LOCA) 0.62 Walkway SCN-50 Connection of Stiffener Tube to DL + P + T +/- srss(SSE, LOCA) 0.89 Valve Support Platform and Walkway SCN-51 Connection of Support Tube under DL + P + T +/- OBE 0.83 Valve Support Platform to Seismic Ring Beam SCN-52 Connection between Tubes in Bridge DL + P + T +/- srss(SSE, LOCA) 0.84 Support Frame Assembly Page 14 to Enclosure 1 to ULNRC-05941 Table 5 Summary of Evaluation of Connections between ASME Section III, Subsection NF Components and Between Safety-Related, Seismic Category I Components Connection Connection Description / Stress Number Controlling Component Controlling Load Combination Ratio SCN-53 Connection of NW Bridge Cross DL + P + T +/- srss(SSE, LOCA) 0.77 Pipe to Side Plates SCN-54 Connection of NW Bridge Bearing DL + P + T +/- srss(SSE, LOCA) 0.80 Plates to Tubes in Foldable Section SCN-55 Connection between Kick Plates in DL + P + T +/- srss(SSE, LOCA) 0.56 Valve Support Platform SCN-56 Connection between Kick Plates in DL + P + T +/- srss(SSE, LOCA) 0.83 HVV Cable Bulkhead Support Platform Symbols: DL: Dead Load P: Pressure Load OBE: Operating Basis Earthquake Load SSE: Safe Shutdown Earthquake Load SRSS: Square-Root-of-the-Sum-of-the-Squares Load Combination Method LOCA: Loss of Coolant Accident Load T: Temperature Load MI: Missile Impact Load ML: Maintenance Load (live load on walkways during maintenance activities) Notes:

1. ASME Section III, Subsection NF and other seismic Category I components are classified as safety-related and are designed for seismic and LOCA loads.
2. The IHA offers no resistance to reactor vessel thermal growth and therefore sustains no stress due to such growth. However, within the IHA components those components that are in contact with the CRDM discharge hot air are evaluated for thermal loads from the CRDM discharge hot air. Applicable service and accident temperatures are considered when determining material properties and material stress allowable.

Page 15 to Enclosure 1 to ULNRC-05941 Table 6 IHA Materials No. Component Description Component Material ASME Section III, Subsection NF and Safety Related, Seismic Category I Components

                         - Plates, Bars, Shapes and Tube Steels 1                Seismic Support Beam                 A514-94a, Grade E, F or Q(1) 2                 Seismic Ring Beam                   A514-94a, Grade E, F or Q(1) 3              Seismic Reinforced Beam                 A514-94a, Grade E or Q(1) 4       Seismic Support Beam at NW, NE Tie           A514-94a, Grade B, E, F or Q(1)

Rods 5 Seismic Bar (Tie Rod Lug) A588-97a, Grade A or B(2) 6 Seismic Tie Rod Bracket, Radial A500-99, Grade C(3) 7 Seismic Tie Rod A588-97a, Grade A or B(2) 8 Mid and Upper Shroud Support Column A500-99, Grade C(3) 9 Lift Rod A434-90a, Class BD(4) 10 Bottom Ring Beam A588-97a, Grade A or B(2) 11 Duct Support in Lower, Mid and Upper A514-94a, Grade B, E, F or Q(1) Shroud 12 Cable Support Ring Beam A500-99, Grade C(3) 13 NW Cable Bridge Support Horizontal ASME SA 106, Grade B Cross Pipe 14 NW Cable Bridge Longitudinal Tube in A500-99, Grade C(3) Foldable Section 15 NW Cable Bridge Lateral Tube in A500-99, Grade C(3) Foldable Section 16 NW Cable Bridge Vertical Tube in A500-99, Grade C(3) Foldable Section 17 NW Cable Bridge Lateral Tube in A500-99, Grade C(3) Foldable Section 18 NW Cable Bridge Lifting Mechanism A500-99, Grade C(3) Horizontal Support Tube 19 NW Cable Bridge Lifting Mechanism A500-99, Grade C(3) Tube 20 Cable Bridge Support Tube Under Missile A500-99, Grade C(3) Shield 21 CET Vertical Support Assembly at 30 and ASME SA-479, Type 304 150 deg. Columns 22 CET Vertical Cable Support Assembly ASME SA-240, Type 304 Support Bracket Plates 23 Angle Connecting Duct Sections - Straight ASME SA-479, Type 304 Sections Page 16 to Enclosure 1 to ULNRC-05941 Table 6 IHA Materials No. Component Description Component Material 24 Angle Connecting Duct Sections - Bent ASME SA-479, Type 304 Segment 25 NW Cable Bridge Pipe Rod Connecting ASME SA-106, Grade B Cable Bridge and Lifting Mechanism 26 Support Tubes Under Walkway at Bridges A500-99, Grade C(3) 27 Tube Stiffeners Under Walkway at Bridges A500-99, Grade C(3) 28 NW Cable Bridge Small Lateral Tube A500-99, Grade C(3) 29 Bulkhead Panel Support Tubes A500-99, Grade C(3) 30 Support Tube Under Valve Platform A500-99, Grade C(3) 31 Lower Support Column A500-99, Grade C(3) 32 Seismic Support Plate Attached to Seismic A514-94a, Grade B, E, F or Q(1) Ring Beam 33 CRDM DRPI and Filler Plates ASME SA-240, Type 304 34 Missile Shield A588-97a, Grade A or B(2) 35 Bottom Ring Beam Stiffener Plate A588-97a, Grade A or B(2) 36 Support Bracket Connecting Monorail & A514-94a, Grade B, E, F or Q(1) Walkway to Column 37 Walkway Plate at 0° and 180° A588-97a, Grade A or B(2) 38 Walkway Plate Edge Stiffener A588-97a, Grade A or B(2) 39 Walkway Plate Under Bridges A588-97a, Grade A or B(2) 40 NW Cable Bridge Vertical Support Plates A588-97a, Grade A or B(2) in Stationary Section 41 NW Cable Bridge Support Cross Plates in A588-97a, Grade A or B(2) Stationary Section 42 NW Cable Bridge Support Plate in A588-97a, Grade A or B(2) Foldable Section 43 Stiffener Under Walkway at 0° and 180° A588-97a, Grade A or B(2) 44 RVHVS Support Platform A588-97a, Grade A or B(2) 45 RVHVS Support Platform Edge Stiffener A588-97a, Grade A or B(2) 46 Stiffener Between Walkway and RVHVS A588-97a, Grade A or B(2) Support Platform 47 Bulkhead Panel ASME SA-240, Type 304 48 Bulkhead Platform Floor Plate A588-97a, Grade A or B(2) 49 Bulkhead Platform Kick Plate A588-97a, Grade A or B(2) 50 Bulkhead Platform Stiffener A588-97a, Grade A or B(2) Page 17 to Enclosure 1 to ULNRC-05941 Table 6 IHA Materials No. Component Description Component Material Non-Safety-Related and Non-Seismic Category I Components - Plates, Bars, Wires, Forgings, Shapes and Tube Steels 51 Angle Beam at Boundary of each ASTM A588, Grade A or B Assembly 52 Tripod Rod ASTM A434-90a, Class BD 53 Monorail for Stud Tensioner Hoist ASTM A572, Grade 50 54 Baffle Support Beam ASTM A240, Type 304 55 Duct Support Tubes in Lower Shroud ASTM A500, Grade C 56 Stiffeners at CET Doors & Windows in ASTM A479, Type 304 Duct 57 Fan Support Top Horizontal Tee Ring ASTM A588, Grade A or B 58 Fan Support Vertical Tube ASTM A500, Grade C 59 Angles Connecting Lower and Upper Duct ASTM A479, Type 304 Assemblies in Mid and Upper Shroud 60 Stiffener at Base of Duct in Lower Shroud ASTM A479, Type 304 61 Baffle Cover Support Angle ASTM A588, Grade A or B 62 Pipe Rod for Plenum Center Column ASTM A312 Grade TP304 63 Angle Frame for Air Plenum ASTM A479, Type 304 64 Angle Attached to Duct at Top in Upper ASTM A479, Type 304 Section 65 Angle Stiffener Attached to Lower Mid ASTM A479, Type 304 and Upper Shroud Lower Duct 66 Cable Bundle Supports in Upper Duct ASTM A479, Type 304 67 Fan Support Top Horizontal Tee Ring with ASTM A588, Grade A or B Cutout on Flange and Web 68 Angle of Plenum Attached to Missile ASTM A479, Type 304 Shield 69 Ladder Tube Rail ASTM A500, Grade B 70 Walkway Access Ladder Support Bracket ASTM A36 Assembly 71 Fan Cable Bridge Support ASTM A479, Type 304 72 Fan Cable Bridge Link Pipe Support ASTM A106, Grade B 73 Top Tube of Plenum ASTM A500, Grade C 74 Air Plenum Vertical Tubes ASTM A554, Type 304 75 Vertical Angle Stiffeners in Lower Duct ASTM A479, Type 304 76 Vertical Angle Stiffeners in Upper Duct ASTM A479, Type 304 77 Fan Support Bottom Horizontal Ring ASTM A588, Grade A or B 78 Monorail End Support Bracket ASTM A588, Grade A or B Page 18 to Enclosure 1 to ULNRC-05941 Table 6 IHA Materials No. Component Description Component Material 79 Fan Cable Bridge Longitudinal Beams ASTM A500, Grade C 80 Stiffener Plate at CET Door in Lower Duct ASTM A240, Type 304 81 Duct Support Tube in Middle and Upper ASTM A500, Grade C Shroud 82 NE Cable Bridge Support Horizontal Cross ASTM A106, Grade B Pipe 83 NE Cable Bridge Longitudinal Tube in ASTM A500, Grade C Foldable Section 84 NE Cable Bridge Lateral Tube in Foldable ASTM A500, Grade C Section 85 NE Cable Bridge Vertical Tube in ASTM A500, Grade C Foldable Section 86 NE Cable Bridge Lifting Mechanism ASTM A500, Grade C Horizontal Support Tube 87 NE Cable Bridge Lifting Mechanism Tube ASTM A500, Grade C 88 NE Cable Bridge Pipe Rod Connecting ASTM A106, Grade B Cable Bridge and Mechanism 89 NE Cable Bridge Small Lateral Tube ASTM A500, Grade C 90 Baffle ASTM A240, Type 304 91 Stiffener Plate at Top of Baffle ASTM A240, Type 304 92 Radiation Shield Door ASTM A36 93 Lower Assembly Shroud Panel ASTM A36 94 Mid Assembly Shroud Panel ASTM A36 95 Lower Assembly Duct ASTM A240, Type 304 96 Baffle Cover ASTM A240, Type 304 97 Mid Assembly Duct ASTM A240, Type 304 98 Upper Shroud Lower Panel ASTM A588, Grade A or B 99 Upper Shroud Lower Duct ASTM A240, Type 304 100 Upper Shroud Upper Panel ASTM A588, Grade A or B 101 Upper Shroud Upper Duct ASTM A240, Type 304 102 CET Access Doors in Lower Assembly ASTM A240, Type 304 Duct 103 Plenum Cover Plates ASTM A240, Type 304 104 Air Plenum Top Panel ASTM A240, Type 304 105 Air Plenum Side Panel ASTM A240, Type 304 106 Fan Separator in Air Plenum ASTM A240, Type 304 107 Fan Cable Bridge Support Plate ASTM A240, Type 304 108 Walkway Plate at 270 Degrees ASTM A588, Grade A or B Page 19 to Enclosure 1 to ULNRC-05941 Table 6 IHA Materials No. Component Description Component Material 109 NE Cable Bridge Vertical Support Plates ASTM A588, Grade A or B in Stationary Section 110 NE Cable Bridge Support Cross Plates in ASTM A588, Grade A or B Stationary Section 111 NE Cable Bridge Support Plate in Foldable ASTM A588, Grade A or B Section ASME Section III, Subsection NF, Safety-Related and Non-Safety-Related Bolts and Nuts 112 High Strength Stainless Steel Bolts ASME SA-193, Grade B8M, Class 2 for Safety- Related; ASTM A193, Grade B8M, Class 2 for Non-Safety-Related 113 High Strength Bolts ASME SA-193, Grade B8, Class 1 for Safety-Related; ASTM A193, Grade B8, Class 1 for Non-Safety-Related 114 High Strength Bolts ASME SA-540, B23, Class 3 for Safety-Related; ASTM A540, B23, Class 3 for Non-Safety-Related 115 Normal Bolts SS 18-8 116 High Strength Nuts ASME SA-194, Grade 7 or 7M for Safety-Related; ASTM A194, Grade 7 or 7M for Non-Safety-Related Notes: (1) ASME Code Case N-71-18 Material, Minimum Yield Strength = 90 ksi & Minimum Ultimate Strength = 100 ksi (2) ASME Code Case N-71-18 Material, Minimum Yield Strength = 50 ksi & Minimum Ultimate Strength = 70 ksi (3) ASME Code Case N-71-18 Material, Minimum Yield Strength = 50 ksi & Minimum Ultimate Strength = 62 ksi (4) ASME Code Case N-249-14 Material, Minimum Yield Strength = 105 ksi & Minimum Ultimate Strength = 135 ksi Page 20 to Enclosure 1 to ULNRC-05941 Attachment 3: AREVA Document 38-9182306, Damping Values for Use in the IHA Seismic Response Analysis Page 1 to Enclosure 1 to ULNRC-05941 Document No. 1 OOOGTR-05 Rev. 0 A A R EVA AREVA NP Inc. 38-9182306-000 Callaway Unit 1 Reactor Vessel Head Replacement Project Technical Report Damping Values for Use in the Integrated Head Assembly Seismic Response Analysis Prepared By: Harish Kamath Reviewed By: Approved By: t<. Ravi Baliga f>:d i '~ ADVENT Engineering Services, Inc. 12647 Alcosta Blvd., Suite 440 San Ramon, California, 94583 April, 2012 ADVENT Engineering Services, Inc. Sheet 1 of 11 Page 2 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 Revision Summary Rev. No. Description Affected Pages 0 Initial Issue All ADVENT Engineering Services, Inc. Sheet 2 of 11 Page 3 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 DAMPING VALUES FOR USE IN THE INTEGRATED HEAD ASSEMBLY SEISMIC RESPONSE ANALYSIS INTRODUCTION ADVENT is designing an Integrated Head Assembly (IHA) as a replacement structure for the existing reactor vessel head service structure at Callaway Unit 1. An isometric view of the IHA is provided in Figure 1 and its plan view in Figure 2. The concept of integrating all the removable upper reactor vessel head components into one removable structure is the object of this design. However, functionality of each head component is maintained in the integrated head assembly. The IHA is a steel structure that provides required support for the Control Rod Drive Mechanism (CRDM) cooling components, CRDM seismic components, CRDM missile shield structure, CRDM cooling fans, reactor vessel head lift rig structure, and for the head area cable routing. The IHA is a four-story high (approximately 43 feet tall) steel structure and has more than 10,000 parts assembled together by bolted and welded connections. The number of bolted connections is significantly larger than the number of welded connections in the IHA. In addition, all bolted connections in the IHA are bearing connections with specified snug-tight requirements. The IHA has no friction type bolted connections. The bolted and welded connections that are potentially critical for the transfer of loads and the dissipation of energy during a seismic event are listed in Table 1. The types of connection listed in Table 1 occur at numerous locations within the IHA. This report identifies the damping requirements for response spectrum analyses of steel structures such as IHA, per the guidance of Regulatory Guide 1.61, Revision 1. Based on the presence of critical connections in the IHA that are the primary source of dissipating seismic energy, this report presents the computation of weighted damping values for the IHA, based on the recommendations of the NRC Regulatory Guide 1.61, Revision 1. REGULATORY GUIDE 1.61 REVISION 1 REQUIREMENTS FOR DAMPING For bolted steel with bearing connections, Regulatory Guide 1.61, Revision 1 provides 5.0% and 7.0% damping values for the OBE and SSE earthquakes respectively. Sections 3.7(B).1.3 and 3.7(N).1.3 of the Callaway Unit 1 FSAR refer to Tables 3.7(B)-1 and 3.7(N)-1, for non-OEM and OEM components respectively, which present the critical damping values that are applicable to Seismic Category I (Safety Related) structures, systems and components. Since the integrated head assembly is an assembly of Seismic Category I (Safety Related) as well as Seismic Category II/I components (non-seismic category I components as described in the Callaway FSAR and defined by position C.2 of Regulatory Guide 1.29, Revision 3) and provides support of reactor coolant loop components (CRDM support), it is considered that this section of the FSAR is applicable to the IHA. Bolted connections which transmit load are categorized in the Regulatory Guide as either friction-type or bearing-type. The friction-type connection depends upon high clamping force to prevent slip of the connected parts under anticipated service conditions. This clamping force is developed by pre-torquing the bolt to a tension typically equal to 70% of its ultimate strength, and special surface preparation may be specified on the bearing members so as to achieve high friction force. This connection behaves more like a welded connection under the ADVENT Engineering Services, Inc. Sheet 3 of 11 Page 4 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 anticipated service loads. The bearing-type connection depends upon contact of the fastener shank against the sides of their holes to transfer the load from one connected part to another. With relatively easy slip between the joined members, the energy dissipation capacity of a bearing-type connection is much higher than that of the friction-type connection. The NRC issued Regulatory Guide 1.61, Revision, 1 in March 2007. Regulatory Guide 1.61, Revision 1 differentiates between a welded steel or bolted steel with friction connections and a bolted steel with bearing connection based on the differences in their energy absorbing capabilities. Per Regulatory Guide 1.61, Revision 1, the damping values for welded steel or bolted steel with friction connections are 3.0% for the Operating Basis Earthquake (OBE) and 4.0% for the Safe Shutdown Earthquake (SSE). The damping values for bolted steel with bearing connections are 5.0% for the OBE and 7.0% for the SSE. Regulatory Guide 1.61, Revision 1 requires that for steel structures with a combination of different connections, either the lowest specified damping value for the connections in the combination be used or a weighted average damping value, based on the number of each type of connection present in the structure, be computed. Table 1 lists different types of major connections in the IHA. The table includes a description of each connection, referenced drawing(s) that depict the connection, the type of each connection (welded, bolted, pinned, bearing) and the quantity of each connection. Welded connections of components of assemblies that are connected via bolts or pins to other major components of the IHA were excluded from Table 1, since the bolts/pins provide the major source of damping. Energy dissipation through a pin (or bearing) connection is addressed as it is for a bearing type bolted connection; a pin connection has a similar value of damping as does a bearing type bolted connection, based on the clearances provided in the pin-to-hole dimensions. DISCUSSION ON TYPES OF CONNECTION The integrated head assembly does not have any friction type connections. All bolted connections in the IHA are bearing type specified as being snug-tight. However, the IHA includes a small number of welded connections. The table identifies only one type of welded connection (shroud panels welded to columns). Certain welded connections are not included in Table 1 and are, therefore, not included in the calculation of the IHAs weighted damping value. These welds include:

  • Bottom Ring Beam Stiffener to Bottom Ring Beam The bottom ring beam stiffeners are welded to the bottom ring beam with a two sided weld (3/4 fillet & 3/4 bevel weld). The ring beam, along with the stiffeners, is considered to be one composite member and hence, it is concluded that this welded connection need not be considered as a component connection for the calculation of the weighted average.
  • Support Column Alignment Pins to Support Columns The support column alignment pin assemblies are complete joint penetration (CJP) welded to the support columns. Since the weld is a CJP weld, these assemblies are considered to be an integral part of the columns.

ADVENT Engineering Services, Inc. Sheet 4 of 11 Page 5 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0

  • Air Plenum Base Angle to Air Plenum Frame The air plenum base angle is welded to the air plenum to form a flange at the bottom of the air plenum to enable it to be bolted to the missile shield. The bolted connection between this angle and the missile shield is the critical connection in transferring loads from the air plenum to the missile shield. Hence, it is concluded that this welded connection need not be considered in the calculation of the weighted average.

Further, the integrated head assembly is a vertically standing structure bolted to three support pads on the replacement reactor vessel head (RRVCH) and pinned to three lift lugs on the replacement reactor vessel head. In addition to these six attachment points on the RRVCH, there are four seismic tie rods pinned to the IHA seismic ring beam at the refuel floor elevation. On the cavity wall side, these tie rods are pinned to wall lugs. All four seismic tie rod connections on both ends of the tie rods are pin connections (See Figures 1 and 2). WEIGHTED DAMPING VALUES FOR IHA RESPONSE SPECTRUM ANALYSIS As shown in Table 1, there are a total of 315 connections in the IHA which transfer a significant level of inertia load. Among these connections, there are a total of 48 welded connections and 267 bearing - bolted / pinned connections (84.8% bearing - bolted connections). Based on these quantities, the weighted average is calculated as below For OBE: (3% x 48 + 5% x 267) / (48+267) = 4.70% For SSE: (4% x 48 + 7% x 267) / (48+267) = 6.54% REFERENCES

1. Ameren Missouri, Callaway Plant Unit 1 Final Safety Analysis Report, Rev. 18.
2. Nuclear Regulatory Commission, Regulatory Guide 1.61, Revision 1, March, 2007, Damping Values for Seismic Design of Nuclear Power Plants.
3. AREVA Doc. No. 51-9170166-000, Engineering Information Record, Callaway Unit 1 Replacement Reactor Vessel Closure Head Metal Reflective Insulation ADVENT Engineering Services, Inc. Sheet 5 of 11 Page 6 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 Figure 1: Integrated Head Assembly - Isometric View ADVENT Engineering Services, Inc. Sheet 6 of 11 Page 7 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 Figure 2: Integrated Head Assembly - Plan (Top) View Tie Rod Under N-W Bridge (Not Shown)

ADVENT Engineering Services, Inc. Sheet 7 of 11 Page 8 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 Table 1: A List of Major Connections in the IHA Connection Connection Reference Type of QTY No. Description Drawings Connection(2) 1 Seismic Tie Rods to Seismic 10006-M-177, Pinned 4 Ring Beam/ Tie Rods Sheet 1 Brackets (Pin) 2 Lift Rod Clevis to RRVCH Lift 10006-M-201, Pinned 3 Lug (Pin) Sheet 1 3 Bottom Ring Beam to Lift Rod 10006-M-051, Bolted 6 Clevis Sheet 2 4 Support Columns to Bottom 10006-M-053, Bolted 6 Ring Beam Sheet 1 5 Support Column Splice 10006-M-005, Bolted 24 Connections Sheet 2 6 Seismic Tie Rod Brackets to 10006-M-170, Bolted 4 Seismic Ring Beam Sheet 1 7 Seismic Ring Beam to 10006-M-151, Bolted 6 Support Columns Sheet 1 8 Lift Rod Clevis to Lift Rod 10006-M-201, Bolted 3 Sheet 1 9 Lift Rod Leveling Nut to Lift 10006-M-201, Bolted 3(1) Rod Sheet 1 10 Seismic Tie Rod Clevis to 10006-M-177, Pinned 4 Adapter Plates (Pin) Sheet 1 11 Lift Rod Lift Nut to Lift Rod 10006-M-201, Bolted 3 (1) Sheet 1 12 U-Bolt Connection between 10006-M-054, Bolted 6 Lift Rod & Shroud Angles Sheet 1, 10006-M-104, Sheet 1 13 Adapter Plates to Wall Lug 10006-M-177, Pinned 4 (Pin) Sheet 1 14 CRDM Seismic (DRPI)Plates 10006-M-650, Bearing 44(3) to Seismic Reinforced Ring Sheet 1 15 Bottom Ring Beam to IHA 10006-M-051, Bolted 3 Support Lugs on the RRVCH Sheet 2 ADVENT Engineering Services, Inc. Sheet 8 of 11 Page 9 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 16 Shroud Panels to Columns 10006-M-059, Welded 48 Sheet 1, 10006-M-103, Sheet 1, 10006-M-154, Sheet 1, 10006-M-161, Sheet 1 17 Shroud Subassembly Angles 10006-M-054, Bolted 12(4) to Support Columns Sheet 1, 10006-M-104, Sheet 1, 10006-M-151, Sheet 1 18 Angles to Angles between 10006-M-005, Bolted 2 Shroud Subassemblies Sheet 1 19 Baffle to Baffle 10006-M-061, Bolted 2 Sheet 1 20 Baffle Support to Support 10006-M-062, Bolted 24 Columns Sheets 1 & 2 21 Radiation Shield Doors to 10006-M-055, Pinned(5) 24(5) Support Columns (Hinge) Sheet 1 & 10006-M-056, Sheet 1 Radiation Shield Door Latches 10006-M-058, Bolted(5) Sheets 1 & 2 22 Air Ducts to Support Columns 10006-M-065, Bolted 16 Sheet 1, 10006-M-105, Sheet 1, 10006-M-155, Sheet 1, 10006-M-162, Sheet 1 23 Air Duct Sub Assembly to Sub 10006-M-005, Bolted 4 Assembly Sheet 1 24 Messenger Wire Support Ring 10006-M-151, Bolted 6 Tube to Support Columns Sheets 1 and 2 25 Monorail Support Bracket to 10006-M-552, Bolted 6 Support Columns Sheet 1, 10006-M-553, Sheet 1, 10006-M-555, Sheet 1 26 Monorail to Monorail Support 10006-M-551, Bolted 6 Bracket Sheet 4 ADVENT Engineering Services, Inc. Sheet 9 of 11 Page 10 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 27 Monorail Support Bracket to 10006-M-451, Bolted 6 Walkway Sheet 1 28 Cable Bridge to Walkway 10006-M-250, Bolted 2 Sheet 1 29 Cable Bridge Stationary 10006-M-251, Pinned 2 Section to Foldable Section Sheets 1 & 2 30 Tripod Leg Upper Clevis to 10006-M-203, Pinned 3 Tripod Lift Eye (Pin) Sheet 1 31 Lift Block to Missile Shield 10006-M-203, Bolted 3 Sheet 1 32 Tripod Leg Lower Clevis to Lift 10006-M-203, Pinned 3 Block Sheet 1 33 Air Plenum Base Angle to 10006-M-005, Bolted 1 Missile Shield Sheet 1 34 Cooling Fan to Cooling Fan 10006-M-015, Bolted 4 Support Sheet 1 35 Cooling Fan Support to 10006-M-302, Bolted 4 Missile Shield Sheets 1,2,3 & 4 36 Missile Shield to Support 10006-M-152, Pinned 6 Column (Pin) Sheets1,2, 4, 5, 6

                                                       & 10006-M-206, Sheet 1 37          Cable Bridge Link Assembly       1006-M-251,                Pinned                 8 to Cable Bridge (Pin)            Sheet 1 & 1006-M-252, Sheet 1 38          RVLIS and RVHVS Support to       10006-M-500,                Bolted               2(6)

Support Column Sheet 1, 10006-M-501, Sheet 1 39 RRVCH Insulation Support To See Note (7) Bolted 1 Bottom Ring Beam Total 315(1) Notes: (1) For connections 9 and 11, the missile shield is restrained in the vertical direction, by the lift nuts against upward motion and the leveling nuts against downward motion. Only either the lift nuts (connection 11) or the leveling nuts (connection 9), are addressed in the determination of effective connections in the vertical load path from the IHA missile shield to the RVCH. (2) All bolted connections are bearing connections. ADVENT Engineering Services, Inc. Sheet 10 of 11 Page 11 to Enclosure 1 to ULNRC-05941 Document No. 10006TR-05 Rev. 0 (3) For Connection 14, bearing connections between the seismic plates have been conservatively ignored. (4) For Connection 17, the number of bolted connections has been conservatively determined. At each elevation, although there are two back-to-back angles that are each bolted to the columns, only one is considered in the connection count. (5) For Connection No. 21, Radiation Shield Doors to Support Columns, the net effect of the two hinges and the latches is considered to be one connection per door (24 doors). (6) For the number connections of the RVLIS and RVHVS Supports to the Support Columns (Connection 38), it is conservatively been assumed that each of the RVLIS and RVHVS lines has only one support connected to the support columns, although there are several such supports (7) See section 4.5 of Reference 3. ADVENT Engineering Services, Inc. Sheet 11 of 11 Page 12 to Enclosure 1 to ULNRC-05941 Attachment 4: Proposed FSAR Mark-Ups Page 1 to Enclosure 1 to ULNRC-05941 CALLAWAY- SP 3.7(8) SEISMIC DESIGN The following material is in addition to Section 3.7(N) and applies to structures, systems, and components not supplied by Westinghouse. This section describes the techniques and discusses the parameters used to develop seismic loadings and criteria for seismic Category I structures, systems, and components. The seismic responses of the major seismic Category I structures (containment, auxiliary/control, diesel generator, and fuel building) were originally generated for four sites (Callaway, Wolf Creek, Sterling, and Tyrone). Seismic design envelopes were developed by use of the most restrictive site conditions imposed by any one of the four original sites or by generic design criteria which are conservative for each of the sites. With the cancellation of the Tyrone plant, however, the four site enveloping approach was modified, for work not yet completed, to include only the remaining three sites. The seismic design envelopes were not revised to reflect the cancellation of the Sterling plant; therefore, since the design of all power block structures, systems, and components is based on the responses for three or four sites, the power block design is conservative for the remaining two sites. A further discussion of the multiple-site enveloping criteria, as applied to the seismic design of the SNUPPS power block, is contained in Section 3.7(8).2.2. 3.7(8).1 SEISMIC INPUT 3.7(8).1.1 Design Response Spectra The site design response spectra in compliance with Regulatory Guide 1.60 are illustrated in Figures 3.7(8)-1 and 3.7(8)-2, in both the horizontal and vertical directions for the SSE. For the 08E, the design response spectra values were taken as 60 percent of the SSE. The values shown are for the site with maximum amplification. Section 2.5.2 of each Site Addendum and Section 2.5 of 8C-TOP-4-A (Ref. 3) discuss the effects of focal and epicentral distances from the site, depths between the focus of the seismic disturbances and the site, existing earthquake records, and the associated amplification of the response spectra. 3.7(8)-1 Rev. OL-19 5/12 Page 2 to Enclosure 1 CALLAWAY- SP to ULNRC-05941 3.7(N) SEISMIC DESIGN For the OBE loading condition, the nuclear steam supply system is designed to be capable of continued safe operation. The design for the SSE is intended to ensure:

a. That the integrity of the reactor coolant pressure boundary is not compromised;
b. That the capability to shut down the reactor and maintain it in a safe condition is not compromised; and
c. That the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the guideline exposures of 10 CFR 100 is not compromised.

It is necessary to ensure that required critical structures and components do not lose their capability to perform their safety function. Not all critical components have the same functional safety requirements. For example, a safety injection pump must retain its capability to function normally during the SSE. Therefore, the deformation in the pump must be restricted to appropriate limits in order to ensure its ability to function. On the other hand, many components can experience significant permanent deformation without loss of function. Piping and vessels are examples of the latter where the principal requirement is that they retain their contents and allow fluid flow. The seismic requirements for safety-related instrumentation and electrical equipment are covered in Sections 3.1O(N) and (B). The safety class definitions, classification lists, operating condition categories, and the methods used for seismic qualification of mechanical equipment are given in Section 3.2. 3.7(N).1 SEISMIC INPUT

3. 7(N).1.1 Design Response Spectra Refer to Section 3. 7(8).1.1.
3. 7(N).1.2 Design Time History Refer to Section 3. 7(8).1.2.

3.7(N).1.3 The damping values given i able 3.?(N)-1 are used for the systems analysis of Westinghouse e ui men hese are consistent with the damping values recommended in Regulatory Guide 1.6 , xcept in the case of the primary coolant loop system components and large piping (excluding reactor pressure vessel internals) for which the damping values of 2 percent and 4 percent are used as established in testing programs 3.7(N)-1 Rev. OL-13 5/03 Page 3 to Enclosure 1 to ULNRC-05941 reported in Reference . The damping values for control rod drive mechanisms (CRDMs) and the fuel assemblies of the nuclear steam supply system. when used in seismic system analysis, are in conformance with the values fo . d/or bolted steel structures (as appropriate) listed in Regulatory Guide . ~ JeN. fl. Tests on fuel assembly bundles justified conservative component damping values of 7 percent for OBE and 10 percent for SSE to be used in the fuel assembly component qualification. Documentation of the fuel assembly tests is found in Reference 2 . The damping values used in component analysis of CRDMs and their seismic supports were developed by testing programs performed by Westinghouse. These tests were performed during the design of the CRDM support; the support was designed so that the damping in Table 3.7(N)-1 could be conservatively used in the seismic analysis. The CRDM support system is designed with plates at the top of the mechanism and gaps between mechanisms. These are encircled by a box section frame which is attached by tie rods to the refueling cavity wall. The test conducted was on a full-size CRDM complete with rod position indicator coils. attachment to a simulated vessel head, and variable gap between the top of the pressure housing support plate and a rigid bumper representing the support. The internal pressure of the CRDM was 2,250 psi. and the temperature on the outside of the pressure housing was 400°F. The program consisted of transient vibration tests in which the CRDM was deflected a specified initial amount and suddenly released. A logarithmic decrement analysis of the decaying transient provides the effective damping of the assembly. The effect on damping of variations in the drive shaft axial position. upper seismic support clearance, and initial deflection amplitude was investigated. The upper support clearance had the largest effect on the CRDM damping, with the damping increasing with increasing clearance . With an upper clearance of 0.06 inch, the measured damping was approximately 8 percent. The clearance in a typical upper seismic CRDM support is a minimum of 0.10 inch. The increasing damping with increasing clearances trend from the test results indicated that the damping would be greater than 8 percent for both the OBE and the SSE, based on a comparison between typical deflections during these seismic events to the initial deflections of the mechanisms in the test. Component damping values of 5 percent are, therefore, conservative for both the OBE and the SSE. These damping values are used and a plie to CRDM component analysis by response spectra techniques. 3.7(N).1.4 Refer to Section 3.7(8).1.4. 3.7(N)-2 Rev. OL-13 5/03 Page 4 to Enclosure 1 to ULNRC-05941 INSERT A The damping values for the Integrated Head Assembly (IHA) are also given in Table 3.7(N)-1. These damping values are based on the note from Regulatory Guide 1.61 Revision 1, Table 1, allowing the use of a calculated "weighted average" damping value for a structure with a combination of different connection types, for the design-basis Safe Shutdown Earthquake (SSE). The note from Table 1 was also applied to Table 2 of Regulatory Guide 1.61 Revision 1 to determine the IHA design-basis Operating Basis Earthquake (OBE) damping value. This methodology was approved in the NRC Safety Evaluation Report dated , 2013 issued for Amendment _ to the Callaway Operating License. Page 5 to Enclosure 1 CALLAWAY- SP to ULNRC-05941 3.7(N).2 SEISMIC SYSTEM ANALYSIS This section describes the methods of seismic analysis perforiJled for safety-related...t, , components and systems within Westinghouse's scope, l/14../e-S~ IV"'ted o ~ke,..w t$e. 3.7(N).2.1 Seismic Analysis Methods Those components and systems that must remain functional in the event of the SSE (seismic Category I) are identified by applying the criteria of Section 3.2.1 . In general, the dynamic analyses are performed, using a modal analysis plus either the response spectrum analysis or integration of the uncoupled modal equations as described in Sections 3. 7(N).2.1.3 and 3. 7(N).2.1.4, respectively, or by direct integration of the coupled differential equations of motion described in Section 3.7(N).2.1.5.

3. 7(N).2.1.1 Dynamic Analysis - Mathematical Model The first step in any dynamic analysis is to model the structure or component, i.e.,

convert the real structure or component into a system of masses, springs, and dashpots suitable for mathematical analysis. The essence of this step is to select a model so that the displacements obtained will be a good representation of the motion of the structure or component. Stated differently, the true inertia forces should not be altered so as to appreciably affect the internal stresses in the structure or component. Some typical modeling techniques are presented in Reference 3. Equations of Motion Consider the multidegree of freedom system shown in Figure 3. 7(N)-1 . Making a force balance on each mass point r, the equations of motion can be written in the form: (3.7(N)-1) where: mr = the value of the mass or mass moment of rotational inertia at mass point r Yr

                   = absolute translational or angular acceleration of mass point r Cri     = damping coefficient- external force or moment required at mass point r to produce a unit translational or angular velocity at mass point i, maintaining zero translational or angular velocity at all other mass points. Force or moment is positive in the direction of positive translational or angular velocity 3.7(N)-3                            Rev. OL-13 5/03 Page 6 to Enclosure 1 to ULNRC-05941                            CALLAWAY- SP 3.7(N).2.13    Methods for Seismic Analysis of Dams Refer to Section 3.7(8).2.13.

3.7(N).2.14 Determination of Seismic Category I Structure Overturning Moments Refer to Section 3. 7(8).2.14. 3.7(N).2.15 Analysis Procedure for Damping 3.7(N).3.1 Seismic Analysis Methods Seismic analysis methods for subsystems within Westinghouse's scope of responsibility are given in Section 3.7(N).2.1 .

3. 7(N).3.2 Determination of Number of Earthquake Cycles For each 08E, the system and component will have a maximum response corresponding to the maximum induced stresses.

The effect of these maximum stresses for the total number of 08Es must be evaluated to assure resistance to cyclic loading. The 08E is conseryatively assumed to occur 20 times over the life of the plant. The number of maximum stress cycles for each occurrence depends on the system and component damping values, complexity of the system and component, and duration and frequency contents of the input earthquake. A precise determination of the number of maximum stress cycles can only be made, using time-history analysis for each item which is not feasible. Instead, a time-history study has been conducted to arrive at a realistic number of maximum stress cycles for all Westinghouse systems and components. To determine the conservative equivalent number of cycles of maximum stress associated with each occurrence, an evaluation was performed, considering both equipment and its supporting building structure as single degree of freedom systems. 3.7(N)-17 Rev. OL-13 5/03 Page 7 to Enclosure 1 to ULNRC-05941 CALLAWAY- SP TABLE 3.7(N)-1 DAMPING VALUES USED FOR SEISMIC SYSTEMS ANALYSIS FOR WESTINGHOUSE SUPPLIED EQUIPMEN) ~ REPLACEMENT SGS Mil :CI-{A Damping (Percent of Critical) Upset Conditions Faulted Condition Item (OBE) (SSE. DBA) Primary coolant loop system components and large piping*** 2 4 Small piping** 1 2 Welded steel structures 2 4 7

  • Applicable to 12-inch or larger diame
   **     Code Case N-411-1, Alternate Damping Values for Response Spectra Analysis of Classes 1, 2, and 3 Piping, Section Ill, Division 1, may also be applied subject to the conditions imposed by the NRC staff in Regulatory Guide 1.84.

Rev. OL-15 5/06 Page 8 to Enclosure 1 to ULNRC-05941 INSERT B Integrated Head Assembly (IHA) 4.50*** 6.25*** INSERT C

      ***    Conservative damping values for the IHA are based on the recommendations in Regulatory Guide 1.61 Revision 1, Tables 1 and 2, using a weighted average for "Welded Steel or Bolted Steel with Friction Connections" and "Bolted Steel with Bearing Connections," as approved by the NRC via Operating License Amendment_ for Callaway.

Page 9 to Enclosure 1 CALLAWAY- SP to ULNRC-05941 The recommendations of this regulatory guide are met for the design of safety-related structures, systems and components. Refer to Section 3.4. Also, refer to Section 3.4 in each Site Addendum . REGULATORY GUIDE 1.60 REVISION 1 DATED 12/73 Design Response Spectra for Seismic Design of Nuclear Power Plants DISCUSSION: The recommendations of this regulatory guide are used for the non-NSSS design as the basis for the ground design response spectra. Refer to Section 3. 7(8).1 .1. Westinghouse utilizes the design response spectra of this regulatory guide in conjunction with the damping values approved by the NRC in WCAP-7921-AR, dated May 1974. REGULATORY GUIDE 1.61 Rev. 0 Dated 10/73 Damping Values for Seismic Design of Nuclear Power Plants DISCUSSION: The recommendations of this regulatory guide are met as described in Section 3. 7(8).1 .3 for those items not supplied by Westinghouse, with the following exceptions. Supports for Class 1E cable tray are designed for the SSE considering up to 20-percent damping. Likewise, Class 1E conduit supports are designed for the SSE based on 7-percent damping. In accordance with Regulatory Position C.2, these damping values were established as the result of a test program. Further discussion is included in Section 3.10(8).3. The Westinghouse-supplied equipment satisfies the damping values suggested by the regulatory guide with the exception of the damping value (3 percent critical) for the faulted condition of large piping systems. Higher damping values , when justified by documented data, are allowed by Regulatory Position C.2. A conservative value of 4 percent critical has therefore been justified by testing for the Westinghouse reactor coolant loop configuration in WCAP-7921-AR and has been approved by the NRC. See Section 3. 7(N).1.3 for further discussion. Code Case N-411-1 , Alternative Damping Values for Response Spectra Analysis of Classes 1, 2, and 3 Piping, Section Ill , Division 1, may also be applied subject to the conditions imposed by theN *

  • 1.84.

DATED 10/73 Manual Initiation of Protective Actions 3A-19 Rev. OL-19 5/12 Page 10 to Enclosure 1 to ULNRC-05941 INSERT D REGULATORY GUIDE 1.61 Rev. 1 Dated 3/07 Damping Values for Seismic Design of Nuclear Power Plants DISCUSSION: The recommendations of this regulatory guide were used in the analysis of the AREVA-supplied integrated head assembly (IHA). The Regulatory Guide 1.61 Revision 1, Table 1 note allowing use of a "weighted average" for the design-basis Safe Shutdown Earthquake (SSE) damping value applicable to steel structures of different connection types is also applied to determine the IHA design-basis Operating Basis Earthquake (OBE) damping value, as approved by the NRC via Amendment_ to the Callaway Operating License. Damping values more conservative (i.e. lower) than the calculated "weighted average" damping values have been used in conjunction with the response spectrum analysis of the IHA to qualify various structural components in the IHA and in developing the reaction loads from the IHA on the replacement reactor vessel closure head (RRVCH) and on the containment cavity wall seismic embedments. The current licensing basis use of Regulatory Guide 1.61 Revision 0 is retained for all structural analyses that do not address the structural qualification of the IHA. Page 11 to Enclosure 1 to ULNRC-05941 CALLAWAY- SP LIST OF TABLES (Continued) Number Title 3.7(8)-8V Response Shear Forces (KIPS) Diesel Generator Building OBE East-West Direction 3.7(B)-8W Response Axial Forces (KIPS) Diesel Generator Building OBE Vertical Direction 3.7(8)-SX Response Bending Moments (Millions of KIP-Feet) Diesel Generator Building OBE North-South Direction 3.7(B)-8Y Response Bending Moments (Millions of KIP-Feet) Diesel Generator Building OBE East-West Direction 3.7(B)-8Z Response Displacements (Inches) Diesel Generator Building OBE North-South Direction 3.7(B)-8M Response Displacements (Inches) Diesel Generator Building OBE East-West Direction 3.7(8)-8AB Response Displacements (Inches) Diesel Generator Building OBE Vertical Direction 3.78-9 DESIGN COMPARISON WITH R.G. 1.12, REVISION 1, DATED APRIL 1974, TITLED INSTRUMENTATION FOR EARTHQUAKES 3.7(N)-1 3.8-1 3.8-2 Maximum Allowable Offset in Final Welded Joints of Reactor Building Liner Plate 3.8-3 Stress Limits for Steel Portions of Concrete Containments Designed in Accordance with Subsection NE of the Asme Code 3.8-4 Load Combinations and Load Factors for Category I Concrete Structures 3.8-5 Load Combinations and Load Factors for Category I Steel Structures 3.9(B)-1 Computer Programs Used in Analysis 3.9(8)-2 Design Loading Combinations for Asme Code Class 2 and 3 Components 3.0-xxiv Rev. OL-14 12/04 Page 12}}