ENGINEERING EVALUATION

ENGINEERING EVALUATION

Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESO No.: FA5270Date: 01/30/19 of 7

1.0 Summary

This engineering evaluation addresses the condition and suitability of the existingout of service 6-inch nitrogen supply piping system to be repurposed forsupplying natural gas to C-1 00, C-200, and C-300 to support the HVAC ServiceReplacement projects.

TjTis evaluation determines that the nitrogen Dipina meets all the engineerinadesicm reQyirements to be repurposed for natural gas supDly. The_pMnfls u ppo rts however, will require some modifications to meet th e seismicreauirements. The evaluation does not consider the other aspects that will haveto be addressed during the design phase to make it a complete system andready fQLservtce.

2.0 Detailed Problem Statement

The HVAC replacement projects require a natural gas supply. The plant has anatural gas supply near C-600 at the package steam boilers. The existing out ofservice 6 inch nitrogen system piping runs above ground on pipe support racksthroughout the plant. A section of the nitrogen piping runs from the C-600 gaslines to the buildings planned for HVAC Replacement. Reusing the nitrogenpiping to supply natural gas to these areas will save the cost and time ofinstalling approximately 2,500 feet of new piping, thus offering significant projectcost savings. To reuse the nitrogen piping for natural gas supply, the piping mustmeet applicable code requirements. This evaluation will review those coderequirements and conclude if those requirements are or can be satisfied.

3.0 Assumptions

As noted in evaluation.

4.0 References

4.1 NFPA 54 National Fuel Gas Code-20184.2 ASME B31.8 Gas Transmission and Distribution Piping Systems- 2018

Page 1 of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESO No.: FA5270Date: 01,30/19 of 7

4.3 Master Specification for Process Services - Nitrogen System, Section 42-CFebruary 28,19524.4 Natural Gas Supplier (Atmos Energy) conference meeting held on January 9,20194.5 NG Piping-Design Pressure, Min Wall Thickness Calculation-RevC 2019-01304.6 Ultrasonic Thickness Inspection Report WP#18100265 dated 10/18/20184.7 Natural Gas Piping-Hoop Stress Calculation-RevD 2019-01304.8 ASME B31 Ea-2010 Addenda to ASME B31 E-2008 Standard for SeismicDesign and Retrofit of Above-Ground Piping Systems4.9 ASCE 7-10 Minimum Design Loads for Buildings and Other Structures4.10 Drawing C19-540-M, Rev. 2, Outside Services- Above Ground Supports &Anchors for Pipes4.11 Drawing C19-530-M, Rev. 4, Outside Services- Above Ground Steam,Condensate, Dry Air, Nitrogen & Fluorine Piping Supports4.12 Drawing: C19-501-M, Rev. 6c, Outside Services- Above Ground Steam,Condensate, Dry Air, Nitrogen & Fluorine Plan4.13 Drawing C15-1-S, Rev. 8, Placement Plan4.14 Drawing C15-2-S, Rev. 11, Line Support Details4.15 Drawing C45-1-S, Rev. 4, Placement Plan - Pipe Supports & Anchors4.16 Drawing C45-2-S, Rev. 3, Details - Pipe Supports & Anchors4.17 Drawing S7DC60000A001, Rev. 3, C-600 Area Package Boilers - ConcretePad - Pipe Support Location Plan

5.0 Impact on Nuclear Safety

There is no accident of concern. A failure of the piping could result in a fire, butthe line is located away from nuclear facilities. Failure of the line would not affectany NCS systems or controls.

6.0 Evaluation

This evaluation consists of review of the applicable codes for natural gas supplypiping to the plant users and confirming the requirements are met by therepurposed nitrogen piping.

Page 2 of 21


Title: Repurposjng Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESQ No.: FA5270Date: 01/30/19 of 7

The applicable codes for natural gas piping supply were determined to be:1. NFPA 54 National Fuel Gas Code-2018 (reference 4.1)2. ASME B31.8 Gas Transmission and Distribution Piping Systems- 2018

(reference 4.2)

NFPA 54 code is the most applicable code for the plant's natural gas supplypiping as it applies to natural gas piping from the point of delivery to theappliance connection (para. 1.1 .1.1 (A)). The plant, a natural gas customer,receives its supply from Atmos Energy. The supply connection is located at thenorth property line after the regulating and metering station. The piping runssouth underground from this point, surfacing near and supplying natural gas tothe steam package boilers, northeast of C-600. New piping will be tee'd into thesupply line at the package boiler's supply and routed to connect to nearby 6-inchnitrogen piping, which will be repurposed to supply natural gas for building HVACreplacement projects at C-100, C-200, and C-300.

Although ASME B31.8 code does not apply to piping beyond the customer'smeter set assembly, it was also used in this evaluation to provide a second levelconfidence review, noting that the repurposed nitrogen piping is acting as a largedistribution header throughout the plant site.

The following details the specific requirements from the codes for natural gaspiping:

6.1 Pipe Material:According to the installed material specification reference 4.3, nitrogen piping 2-inch and greater is seamless or lap welded black steel, schedule 40, ASTM ASScarbon steel.

NFPA 54 para.5.6.2.2 permits use of both of these materials, thus thisrequirement is met.

ASME B31.8 para. 814.1 .1 permits use of both of these materials, thus thisrequirement is also met.

For the purpose of this evaluation, it is assumed that the nitrogen piping is lapwelded, which is the most conservative; lap welded has lower stress values thanseamless.

Page 3 of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESQ No.: FA5270Date: 01,30/19 of 7

6.2 Maximum Design Pressure:Atmos Energy's maximum design distribution pressure is 400 psig. Atmosregulates their distribution pressure down to 330 psig to the intet supply of thepressure regulator that supplies the PGDP site. Atmos Energy uses multipleregulators to drop the pressure to the PGDP site down to 55 psig (reference 4.4,Attachment A). The normal supply pressure observed by PGDP operations isbetween 58 to 67 psig.

NFPA 54 para. 5.5.1 states the maximum operating pressure shall not exceed125 psi, thus this requirement is met by pressure regulators maintaining 55 psig.Atmos Energy uses Mooney Flow Grid 30 pressure regulators which only allow

for pressure ranges of 25 psig to 90 psig.

ASME B31.8 para. 841 .1.1 a provides a steel pipe design formula to calculate themaximum design pressure. Per that calculation, reference 4.5, Attachment B, themaximum design pressure is 634 psig, thus also meeting this requirement.

6.3 Minimum Pipe Wall Thickness:Per the nitrogen piping installed material specification, reference 4.3, the 6-inchnitrogen piping is schedule 40.

NFPA 54 para. 5.6.2.2 states steel pipe shall be at least schedule 10, and para5.6.7.1 requires piping to be at least schedule 40 if threaded connections areused, thus these requirements are met.

ASME B31.8 para. 841 .1.1 a provides a steel pipe design formula to calculate themaximum design pressure. Solving for (t), nominal pipe wall thickness, and usinga maximum pressure of 125 psig, the calculated nominal wall thickness required(t) is 0.055 inches for 6-inch piping, reference 4.5, Attachment B. The nominalwall of 6-inch schedule 40 piping originally installed is 0.280 inches, 0.245 inchesminimum allowed per manufacturing minus tolerances of 12.5%, reference 4.5Attachment B. This meets this requirement by a large margin, over 4 times therequired thickness.

To confirm the condition of the nitrogen piping, a visual inspection walkdown ofthe piping to be reused was conducted, as well as ultrasonic thickness testingwas done. The visual inspection of the piping showed the outside surface of the

Page 4 of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EVBC-CMD-18-12 Rev. 0ESONo.:FA5270Date: 01,30/19 of 7

piping to be in very good condition, with only minor surface rusting through thepaint coating. Additionally, all the pipe welds appeared in good condition with nonoticeable pitting or cracks. During the walkdown, with no concerning rustlocations, only the low point locations were selected and marked for ultrasonicthickness testing. This was based on the belief that had the nitrogen containedany moisture, it would collect at these locations and that is where possiblecorrosion would exist. The minimum wall thickness of the installed piping, perthe manufacturing specifications and calculations noted in reference 4.5,Attachment B, is 0.245 inches. Ultrasonic thickness testing was conducted onOctober 18, 2018. Per the testing report, reference 4.6, Attachment C, all of the7 locations tested (19 total measurements), had measurements greater than0.245 inches, with only two less than 0.250 inches, those being, 0.247 and 0.249inches. This confirms that the piping appears to be in excellent condition andmeets the minimum wall thickness requirement.

6.4 Use of Existing Steel Pipe:NFPA 54 para. 2.6.1.2 states pipe shall not be used again unless it is free offoreign materials and has been ascertained to be adequate for service intended.The repurposed nitrogen piping supplied plant facilities with dry nitrogen until thenitrogen system was removed from service in September 2017. During thisremoval, disconnect modifications revealed the piping internal to be in pristinecondition. During the piping line commissioning for natural gas service, it willrequire purging to remove any foreign materials. These actions will ensure theexisting piping is adequate for the service intended.

B31.8 para. 817.1.2 also allows reuse of steel piping for low stress level service(hoop stress is less than 6000 psi) where no close coiling or close bending is tobe done, provided careful visual examination indicates it is in good condition andfree from split seams or other defects that would cause leakage. The nitrogenpiping at 125 psig design pressure has a hoop stress of 1479 psi, reference 4.7,Attachment D. The piping being reused, as detailed above appears to be in verygood condition with no weld problems and thus this requirement is also met.

6.5 Structural Supports:As part of this evaluation, the structural supports for the natural gas piping hasbeen assessed for compliance with applicable codes and standards, references4.8 and 4.9.

Page 5 of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESQ No.: FA5270Date: 01,30/19 of 7

On October 30, 2018 a field walkdown was performed to identify the specificroute of the proposed natural gas distribution pipe. The route identified begins atthe natural gas connection northwest of the existing package boiler pad adjacentto C-600. From there, proceeding east and then south, new piping could besupported on the existing pipe supports which were constructed as part of thepackage boiler installation.

The new piping could then be connected to the existing nitrogen distributionpiping supported on existing structures along the north and west sides of the fueloil containment dike. New piping could then be run west and connected to theexisting nitrogen distribution piping at a location southeast of C-600. Newsupports would have to be designed and installed to support this piping. Thenitrogen distribution piping being repurposed proceeds south to a point behind C-200 and then east behind C-709 and C-710 and terminates at a point adjacent toC-300.

Based on a review of the structural drawings (References 4.10 through 4.17) forthe existing steam, air, and nitrogen distribution piping system supports, it can beseen that the existing supports were not originally designed to account forseismic loading. Initial assessment indicated that some or all of the supportsmay be inadequate to provide seismic support in compliance with currentapplicable codes. However, with selective modifications, these supports can beseismically upgraded to function adequately. Detailed analysis and calculationswill be needed to identify the specific design needs for the supports.

These modifications may take the form of strengthening the connectionsbetween vertical and horizontal support members, and providing lateral restraintto the existing pipes being supported in order to prevent interaction between thepipes during a seismic event. In the instances where the supports elevate thepiping over roadways or railroad tracks, somewhat more substantialmodifications may be required. These modifications would provide a connectingstructure to enable the existing supports to work together in resisting longitudinalseismic loads.

7.0 Conclusions and Recommendations

The 6-inch nitrogen piping and supports to be repurposed for natural gas supply,as described in this evaluation, appear to be in excellent condition. The piping

Page 6 of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMID-18-12 Rev. 0ESO No.: FA5270Date: 01/30/19 Page7of7

meets the engineering design requirements of the applicabie codes for reuse.The supports however, as noted in Section 6.5, will require detailed analysis anddesign modifications to meet seismic requirements. Additionaliy, the piping wilirequire modifications to meet requirements for operation and maintenance of anatural gas supply system, such as purging, pressure testing, new supply feedpipe & valving, painting, etc., whjch should be addressed during the projectdetailed design phase.

8.0 Approval

Prepared By: Û^lo^ / ^ JLÎ^- _/ oi/3D//cl(Printed Name) (Signed Name) (Date)

Reviewed By:/^^M^/ / /^jÔÂ^M I -fA^(Printed Name) (SianecTName) / (Da'te)

Nuclear ,

Safety: f^m^lw^ / ^J^â^> _/ ^3/'.^(Printed Name) (Signed Name) (Date)

Approved Bv:3TohkC FltWu^q / ^^lJl)3dlM^ _/jXUll.(Printed Name}- (Signed Nar^6) } (Date)

of 21


Title: Repurposing Nitrogen Distribution Piping for Natural Gas Service EvaluationEngineering Evaluation: EV-C-CMD-18-12 Rev. 0ESO No.: FA5270Date: 01,30/19

Attachments:A. Reference 4.4 Natural Gas Supplier (Atmos Energy) conference meeting held on

Januarys, 2019

B. Reference 4.5 NG Piping-Design Pressure, Min Wall Thickness Calculation-RevC 2019-0130

C. Reference 4.6 Ultrasonic Thickness Inspection Report WP#18100265 dated 10/18/2018

D. Reference 4.7 Natural Gas Piping-Hoop Stress Calculation-RevD 2019-01 30

of 21

EV-C-CMD-18-12

Attachment A (Ref4.4 pg 1/8) j

FW: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

Henderson, Brandon <[email protected]>

Wed 1/9/2019 12:21 PM

Snbox

To'.Terry Fletcher <[email protected]>; Mike Buckner <mJke.buckner@soldiercreekengineering,com>; Ken Kaylor

<[email protected]>; Harve Smith <[email protected]>;

CcKendall Holt <[email protected]>; Keith Thorn <[email protected]>; Cook, Stacy

<[email protected]>; Anderson, Andy <[email protected]>; Rigdon, Dave <[email protected]>;

Windhorst, David <[email protected]>; Matthews, Donnie <[email protected]>;

® 2 attadiments (2 MB)

regulators_broc_flowgrid.pdf; ATMOS ENERGY Gas Chemistry Reportpdf;

Attached is the information that Ryne White from Atn-ios Energy sent: me about the Mlooney Regulators. Ryne stated in themeeting today that they use the Flow Grid 30 models.

I have also attached the Atmos Energy Gas Chemistry report they provided us today.

Some notes from today''s meeting.

• A key for Atmos Energy in support us as their customer is communication.

• Atinos is on average supplying the PGDP 138 CFM/day of natural gas. This does vary day-to-day and season-to-season.

• Tlie inlet pressure at the Atmos regulator is 330 psig.

• Atmos can tweak the regulator to adjust pressure, they currently tweak this down to 55 psig (outlet of the MooneyRegulators). If this needs to be tweaked for future demands, Atmos may have. to bless this change depending onincreases.

® Terry made comment about planning for 70 psi max pressure on the new system and that we would test the line to105psi

® Ryne White checked with one of his resources that the Mooney Regulator springs allow for adjustment in pressurefrom 25-90psi

• Robert Cook made comment about capabilities to pull load sheets from Atmos energy (Daily, Monthly, etc.) Andyhas capabilities to pull this for FRNP.

® The PGD.P is sei'vcd by two major pipelines which allows for the PGDP to buy natural gas at the cheapest rate Atmos

can provide (G2 intcrruptible rate). This also means that tbcrc is some mixing of gas some of the time, therefore thegas chemistry may change (reference the gas chemistry report for one point). Changes are not expected to be greatnor cause significant BTU output deltas.

• Atmos does not measure moisture content, but tbe gas is always below spec (FERC tariff to keep below 4 Ibs H20

per Million CF gas), typically below 2 Ibs H20 per Million CF gas.• Teny requested to see cut sheets for the Mooney Regulators Atmos uses (F''G-30 model used for the PGDP supply).

(attached)• Atmos performs manual annual inspections of the regulators.

• The lower and upper explosion limits may be found from the Texas Gas Safety Sheets, Atmos uses 5-15%, but statedthat the safety sheets calls out 5-15.4%.

• Request from Atmos Energy to FRNP. Look in to setting up a lock inside a lock for the fencing around the meter so

that Atmos can access as needed. This is located outside the limited area.

Brandon Henderson of 21

Optimization Engineering | Engineer ISI

Four Rivers Nuciear Partnership, LLC

Office: (270) 441-5818Mobile: (270) 559-5831Brandon.Henderson@)Dad.t3|3p^gov:^••f^^^-As;^^^^^"';,, y~^. ^'"'4 ^i (i ^-s: ^••\ .,* s. k, ^^a*1 <KS"i\ y:yAIC"~2ff2T'.'. Fftl fR RIVFR^-vy'V-Vs.tV F'\^W"\ I \ i5 V In R^,,?

EV-C-CMD-18-12

Attachment A (Ref4.4 pg 2/8)

From: White, Ryne L [mailto:[email protected]]Sent: Wednesday, January 09, 2019 10:53 AMTo; Henderson, Brandon; Cook, Robert R

Cc: Anderson/ Andy; Cook, Stacy; Rigdon, Dave; Windhorst, David; Matthews, DonnieSubjects RE: Four Rivers Nuclear Partnership/ LLC Contractor for US DOE

Please see attached the spec sheet for FG Mooneys

Ryne White270-929-1706

From: Henderson, Brandon [mailto:[email protected]]

Sent: Friday, January 4, 2019 1:04 PM

To: White, Ryne L <[email protected]>; Cook, Robert R <[email protected]>

Cc: Anderson, Andy <[email protected]>; Cook, Stacy <[email protected]>; Rigdon/ Dave

<[email protected]>; Windhorst, David <[email protected]>; Matthews, Donnie

<[email protected]>; Arnold, Robert H <[email protected]>; Mattingly, Pat T

<[email protected]>; Rice, Craig C <[email protected]>; Brown, Bobby S

<[email protected]>

Subject: RE: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

CAUTION - THIS IS AN EXTERNAL EMAIL. Do not open attachments or dick links from unknown sources or unexpected email.

Sounds great! We would like to discuss the following.

We are looking at making some changes to the demand at the site from FRNP's usage. We have some estimates on demand,

but they may change and we know we need to keep Atmos in the loop on our demands since Atmos is our supplier. We wantto discuss these plans and understand what may be needed to move forward. We also have some questions (below) we wouldlike to discuss. Please let us know if we need to provide more detail prior to the meeting.

1. Data on the specific natural gas chemistry, etc.

o Specific gravity

o Specific volume

o Density

o Percentages of gas for example: methane 80%, ethane 15%, propane 4%, others

o Flammability range

o Lower explosive limit

o Upper explosive limit

l. ATMOS has provided a basic description of the pressure regulators layout. Could more details be

provided on the arrangement and equipment (model numbers, etc) for the pressure regulators that are

protecting our system?

2. ATMOS has stated that the gas is DRY. Could ATMOS provide further numerical detail for our analysis

and documentation?

of 21

3. What flexibility/range can ATMOS vary the output pressure to the plant?

4. For the existing regulators what control range could we expect. For example 65 psig +/-1?Some demands that are anticipate are below.

EV-C-CMD-18-12

Attachment A (Ref 4.4 pg 3/8)

BuildingC-757

C-752-A

C-600

C-100

Complex

C-200

C-300

Description

Gas Powered Heaters (UH-1 and UH-2)

Qty 5 -107,900 BTU/hr

Qty 1 - 45,650 BTU/hr

Gas Powered Heaters (2 heaters)

Assume same as C-757 (until I can confirm)

Packaged Boilers (19/500 Ibs/hr steam each max, and 2 used

max)

Assume 15,000 Ibs/hr max use

This may get decreased with installation at 100/200/300

New hot water boilers

New heating equipment (may be reduced by electric heat

install)

New hot water boilers

MCF/month

38533

417

10,693

4,277

1,604

535

TOTAL 17943

Brandon Henderson

Optimization Engineering ) Engineer III

Four Rivers Nuclear Partnership, LLC

Office: (270) 441-5818Mobile: (270) 559-5831Brandon.Henderson@pad.(3|3[3Q,gQY

J UK Kl:NVi

From: White, Ryne L [mailto:[email protected]]Sent: Friday, January 04, 2019 9:53 AMTo; Henderson, Brandon; Cook, Robert R

Cc: Anderson, Andy; Cook, Stacy; Rigdon, Dave; Windhorst, David; Matthews, Donnie; Arnold, Robert H; Mattingly, Pat T;Rice, Craig C; Brown, Bobby SSubject: RE: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

10:00 am Central Time would be great. We can host at the local Atmos Office and can accommodate that amount.

3510Coleman Rd.

Paducah KY

What is the scope of what you would like to discuss? I would like to make sure we are prepared to help answer your

questions effectively.


From: Henderson, Brandon [mailto:Brandon.Hendersonl@pad.|3t3|3^gQy]

Sent: Friday, January 4, 2019 8:43 AM of 21

IEV-C-CMD-18-12

jAttachment A (Ref 4.4 pg 4/8)To: White, Ryne L <Byne.White(S)atmosenergv.com>; Cook, Robert R <Robert.Cook(5)atmosenergy_com?"

Cc: Anderson, Andy <AndY.Anderson(5)pad.t3|3RO,gQV>; Cook, Stacy <Sta£v£[email protected]_{3|3|3o,gQY>; Rigdon, Dave

<[email protected]^3RR.o;gQy>; Windhorst, David <David.Windhorst(5)pad.|3|3|3ago\/>; Matthews, Donnie

<[email protected]|3t30;goY>


CAUTION " THIS iS AN EXTERNAL EMAIL. Do not open attachments or click links from unknown sources or unexpected email.

That's great. Either day could be accommodated, but I think Wednesday would be better for us just do to potentialconflictions we have with other meetings. We do have a separate meeting scheduled for 7:30-8:30AM on Wednesday, so ifwe could sdicdule something around 9 or 9:30AM (or aftef) Wednesday, that would be great. If we could meet at the localAtmos Office that would be helpful as well.

We would anticipate bringing up to ten people (5 from FRNP and 5 from FRNP's subonctractcd engineering firm. Soldier

Creek Engineering). Would the Atmos Office be able to accommodate this amount? We could tighten up tlie number ifneeded.

Thanks for the quick response.

Brandon Henderson

Optimization Engineering j Engineer III

Four Rivers Nuclear Partnership, ULC

Office: (270) 441-5818Mobile: (270) 559-5831Brandon.Henderson@pad.|3|3Ro,gQy

A|Nff!*'; PHI IR RIVFRC;• •i..»,,i«v^.^ r !L/ \j i^ y\ i ~t/ c l"^<.?

From: White/ Ryne L [mailto:Rvne.White(a)atmosenerav.com;Sent: Thursday, January 03, 2019 8:12 PMTo: Henderson, Brandon; Cook, Robert R

Cc: Anderson, Andy; Cook, Stacy; Rigdon, Dave; Windhorst/ David; Matthews/ DonnieSubject: Re: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

Yes we can do that. Would Tuesday or Wednesday morning work? We could have it at our local atmos office if thathelps.

Rync White, PESr. Engineer

Atmus Energy Corporation

270-929-1706

Sent via the Samsung Galaxy Note9

Original messageFrom: "Henderson, Brandon" <Brandon.Hendersonir(i>pad.gi3]30,goy>

Date: 1/3/19 6:09 PM(GMT-06:00)To: "White, Ryne L" <R.yne.White{%atmosenergy.com>, "Cook, Robert R" <Robert.Cook(%atmosenergy^com.>

Cc: "Andcrson, Andy" <Andy.Anderson(%pad.RRpo,gQy>, "Cook, Stacy" <Stacy_Cook@fiad,RpBO-ga^>^ "Rigdon,

Dave" <Dave.Rigdon(tt'pad.pppo.gov>. "Windhorst. David" <David.Windhorstra).pad.Rgpo,gQY>, "Matthews,

Donnie" <Donnie.Matthews(%Dad.QHQagoY>

EV-C-CMD-18-12

Attachment A (Ref 4.4 pg 5/8)Subject: RE: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

CAUTION " THIS IS AN EXTERNAL EMAIL. Do not open attachments or click Sinks from unknown sources or unexpected email.

Ryne/Robcrt,

FRNP is moving forward some plans on potentially changing the natural gas demands at the PGDP (per some discussion a

few months ago). We would like to meet with you, as well as invite a subcontractor performing some design work for us toattend. I believe we have some questions and would like to discuss some items to help us appropriately plan. Would it be

possible to meet sometime next week? FRNP could set up a meeting location. I can also send some of the questions we have

come up with thus far.

Look forward to hearing from you.

Thanks,

Brandon Henderson

Optimization Engineering j Engineer ill

Four Rivers Nuclear Partnership, LIC

Office: (270) 441-5818Mobile: (270) 559-5831Brandon.Henderson@pad,R|3|3o,goy

From: White/ Ryne L [mailto:[email protected];Sent: Thursday, November 01, 2018 3:04 PMTo: Henderson, Brandon; Cook, Robert R.


Please see below my comments in Blue:

1. What are the normal, max, & min pressures SLipplied?

58 to 67 psig I believe you are correct, f would have to confirm with local operations to be sure.

2. Are these pressures at the property line after the meter and valving station?

Yes

3. How is max pressure controlled?Dual headers with series regulators. Should the downstream regulator exceed the desired set pressure, the upstream

regulator lower the pressure. Iflm not mistaken, there are worker/monitur regulutors

4. Is there a PRV to prevent over-pressurization on the line sei-vicing the PGDP site?

No Actually, yes there should be over pressure protection. The monitor regulator is the over pressure protection in

this case.

5, What is design pressure ofscmce feed piping?

>400 psig, Current pressure is 340 psig

6. NFPA 54 Sect 7.2.4 requires sloping (1/4" ,15') for other than dry gas to prevent traps. Sect 7.6 , requires dripswhere condcnsate could collect if gas is not dry, but not located where it could freeze. Per code definition 3.3.33, DryGas is a gas having a moisture & hydrocarbon dew point below any normal temperature to which the gas piping is

exposed. Is the gas supplied considered dry or wet?Dry T would su.spucl it would be considered dry.

7. If not dry, can you advise or point us to engineering designs that are used to handle the condensate?

It is dry, moisture is not; a concern Andy will be <i great resource fur those type questions.

8. Do you have any suggestions on locations of vent lines? Top of pipe bridges? Difficult to reach. Lower elevations

(12 O'clock position)? Easy to engage block valves. Lower Elevations (6 O'clock position)? Easy to engage, but of 21

1EV-C-CMD-18-12

lAttachment A (Ref 4.4 pg 6/8)could create freezing issues if moisture collects. How many over a standard distance? Genei^TmTe^rtHumGT

Lower elevations for vent lines at the 12 O' Clock position on the pipe. No determination has been made on thequantity of vents needed, other than for FRNP to consider have a vent line and block valve on stem lines and then

maybe just one vent on the m'am header. One vent on the main header does not allow for gas that may be trapped

upslream or downstream on opposite sides of pipe bridges. This may be mitigated with pressurizing with nitrogen on

line that has reached equilibrium and performing multiple cycles ofpressuring'/pm'ging.

9. Suggested type of meters? FRNP is required by our client DOE to install meters on any new construction utility

services at the site, therefore will have to supply gas meters local to facilities used. This may seem redundant, but arequirement for FRNP until it can be discussed in more detail with the client. I would direct you to Damn Ruddy,

with tristatc meter, on any redundant meler sizing questions, damn ruddy (tristatemeter@,gmail.com)


From: Henderson, Brandon [mai|to:[email protected],gQv]

Sent: Thursday, November 1, 2018 1:48 PM

To: Cook, Robert R. <Robert.Cook(5)atmosenerev.com>

Cc: White, Ryne L <Rvne,White(5)atmosenergy.com>; Bates, Thomas R <[email protected]>


CAUTION ~ THIS IS AN EXTERNAL EMAIL. Do not open attachments or click links from unknown sources or unexpected email.

Thank you Robert. I did get Andy's email from you with Andy Newquist's contact information and about the dry vs wet gas.

Thunk you for sending, I will contact Ryne as POC.

Brandon Henderson

Optimization Engineering | Engineer IS!


Office: (270) 441-5818Mobile: (270) 559-5831Brandon.HendersonODad.Rdfiagoy^^^^^:^j^^^ r^^^. % f. i^ ^Si '^i .f.'^ y\^FOUR

From: Cook, Robert R. [mailto:Robert.Cook(aatmosenergy.com]Sent: Thursday, November 01, 2018 1:17 PMTo: Henderson, Brandon

Cc; White, Ryne L; Bates, Thomas RSubject: Re: Four Rivers Nuclear Partnership, LLC Contractor for US DOE

Good afternoon Brandon,

I am thinking that Ryne White, our PE with Atmos Energy, would be your point of contact for this email and all information

needed. I did send Andy a contact to call for metering inside your buildings, and the answer from our Compliance and

Measurements Manager concerning dry vs wet gas.

I am on vacation, but let me know if I can help get you more information.

Thanks,

Robert Cook

Atmos Energy Sales page 14 of 21

EV-C-CMD-18-12

Attachment A (Ref4.4 pg 7/8)Sent from my iPhone

On Nov I/ 2018, at 12:40 PM, Henderson, Brandon <Brandon.Hendersonl(5)pad.[3|3BO;goy> wrote:

CAUTION -TH!S !S AN EXTERNAL EMAIL. Do not open attachments or elicit iinks from unknown sources or

unexpected email.

Hello,

Have any of you had a chance to review the below email yet? [just wanted to send a reminder out.

Thanks,

Brandon Henderson

Optimization Engineering | Engineer III


Office: (270) 441-5818Mobile: (270) 559-5831Brandon.Henderson@pad.(3|3Ro,gQV

<image001 .png>

From: Henderson, BrandonSent; Monday/ October 29, 2018 4:46 PMTo; '[email protected]; '[email protected]'; 'rvan.bates@)atmoseneray.com1

Subject; Four Rivers Nuclear Partnership, LLC Contractor for US DOE

Gentlemen,

I spoke with a couple of you this afternoon. I would like to thank you for the prompt responses back via phoneand appreciate the discussions. As mentioned on the phone, FRNP is evaluating repurposing our old Nitrogenline for usage of natural gas. This line has not been in use over the past year, but was sealed duringdeactivation. It is a 6 inch line that travels near all of the facilities we plan to install natural gas powered boilersused to generate steam/hot water for HVAC use. FRNP has been evaluating the line to be in compliance withNFPA 54 as well as ASME B31.8, and arc currently evaluating ASME B3 IE for retrofitting pipe for

repLirposing of a different service and seismic considerations to take. We believe this is headed in a positivedirection for the plant site to make use of this pipe, which will provide a significant cost savings for our client.With that brief recap of the conversation and the plans that FRNP is intending to move forward with, we do

have some questions. Those questions are below and the text in red is what we believe to be the answers.

Please review and comment. We look forward to the future conversations to occur.

1. What are the normal,, max, & min pressures supplied?

58 to 67 psig2. Are these pressures at the property line after the meter and valving station?

Yes

3. How is max pressure controlled?

Dual headers with series regulators. Should the downstream regulator exceed t'he desired set pressure,

the upstream regulator lower the pressure.

4. Is there a PRV to prevent over-pressurization on the line servicing the PGDP site?

No

5. What is design pressure of service feed piping?

>40() psig. Current pressure is 340 psig

6. NFPA 54 Sect 7.2.4 requires sloping (1/4" ,15') for other than dry gas to prevent traps. Sect 7.6 ,requires drips where condensate could collect if gas is not dry, but not located where it coi^ldfrp^zp^J'er

IEV-C-CMD-18-12

jAttachment A (Ref 4.4 pg 8/8)code definition 3.3.33, Diy Gas is a gas having a moisture & hydrocarbon dew point BeToW^iiyTiormaT

temperature to which the gas piping is exposed. Is the gas supplied considered dry or wet?

Dry7. If not dry, can you advise or point us to engineering designs tliat are used to handle the condensate?

It is dry, moisture is not a concern

8. Do you have any suggestions on locations of vent lines? Top of pipe bridges? Difficult to reach.Lower elevations (12 O'clock position)? Easy to engage block valves. Lower Elevations (6 O'clock

position)? Easy to engage, but could create freezing issues if moisture collects. How many over a

standard distance? General rule of thumb?

Lower elevations for vent lines at the 12 0' Clock position on the pipe. No cletennmation has beenmade on the quantity of vents needed, other than for FRNP to consider have a vent line and block valve

oil .stem lines and then maybe Just one vent on the main lieauer. One vent un the main header does notallow for gas that may be trapped upstream or downstream on opposite sides of pipe bridges. This maybe mitigated with pressurizing with nitrogen on line that has reached equilibrium and performing

multiple cycles ofpressuring/purging.

9. Suggested type of meters? FRNP is required by our client DOE to install meters on any newconstruction utility services at. the site, therefore will have to supply gas meters local to facilities used.This may seem redundant, but a requirement for FRNP until it can be discussed in more detail with the

client.

Thanks,

Brandon Henderson

Optimization Engineering j Engineer ISS

Four Rivers (Muciear Partnership, LLC

Office: (270) 441-5818Mobile; (270) [email protected]|3|30,goy

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IEV-C-CMD-18-12

lAttachment B (Ref4.5 pg 1/1 )j

Calculation-Design Pressure, Mjnimum Wall Thickness per B31.8-2016

Rev: C 01/30/19 By: KL Kaylor

Reflpg38 841.1.la

Ref2Refl pg37

Ref4 pgl8

Ref3 pg6

Given:

para. 840.2.2c

Assume:

Steel Pipe Design Formula

P= (2St/D)(FET) pslg

D= nominal outside diameter (in)

E= longitudinal joint factor, Table 841,1,7-1

F= design factor, Table 841.1.6-1

P= design pressure, psig

S= specified minimum yield strength, psi

T= temperature derating factor, Table 841.1.8-1

t= nominal wall thickness, (in)

Pipe is 6" nitrogen system piping; joints are butt welded

Material is carbon steel pipe, sch 40 ASTM ASS lap weldedLocation class 3

Max temperature to be ambient 120F

Calculate (P) design pressure for given piping:

Refl pgl38Ref3 pgllRef3 pgllRefl pg40Refl pg42Refl pg42

Appendix DTable X2.2

Table X2.2

Table 841.1.6-1

Table 841.1.7-1

Table 841.1.8-1

:

s=

t=

D=

F=

E=

T=

p=

25000 psi0.280 in

6.625 in

0.50

0.60

1.000

634 psig

Table D-l, A53, Type F, BW

6" sch 40

6" sch 40

location class 3

A53 furnace butt welded (lap welded)temperature 250F or lower

:Using the Steel Pipe Design formula above, solve for t, nominal wall thickness:

t= PD/((2S)(FET)) in

max allowable

Given: Design pressure:

5.5.1 P= 125 psi

Using above valves, calculate t, nominal wall thickness:

s=

D=

F=

E=

T=

t=

25000 psi6.625 in

0.50

0.60

1.000

0.055 in

Nominal wall thickness of the given pipe material: 6" sch 40 ASS from above is;

0.280 in

Manufacturing specification-thickness tolerance:

16.3 12.5%

0.280 in

0.245 in

minus thickness tolerance of nominal wall allowed

nominal wall from above

minimum wall thickness wall allowed by manufacturing

Therefore, piping wall is; 445% greater than required minimum

References:

Refl ASME B31.8 Gas Transmission and Distribution Piping Systems- 2018

Ref2 Master Specification for Process Services - Nitrogen System, Section 42-C February 28,1952

Ref3 ASTM A53 Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless

Ref4 NFPA 54 National Fuel Gas Code-2018

NG Piping-Design Pressure, Min Wall Thickness Calculation-RevC 2019-0130Printed: 1/30/2019

Page 1 of 1

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EV-C-CMD-18-12

Attachment C (Ref4.6 pg 1/3)

ULTRASONTC INSPECTION REPORT

Ultrasonic Thickness Inspection Report

WP Number: 18100265 Date: 10/18/2018

Procedure Number: CP4-QA-2111Drawing Number: N/A

Location: See attached location sheet

Building Number: See attached location sheet Material Size: 6" Schedule 40 Pipe

Equipment Identification: Nitrogen Line

Instrument and Transducer Used:

160736502 & 1029101Frequency:5 MHZ

M&TEH): 03063 Due Date: 10/25/20

Initial Setup Readings: .098" & .499"Post Setup Readings: .097" & .499"

Post Setup Acceptance (±.002) Accepted or D Rejected

Readings:

Marker #1 12 O'clock-.288 5 O'clock - .263 6 O'clock - .247 7 O'clock - ,262

Marker #2 12 O'clock - .26'! 3 O'clock - .255 6 O'clock-,253 9 O'clock - .274

Marker #3 12 O'clock-.271 } O'clock-.271 4 O'clock - .268 5 O'clock-.271 6 O'clock - .274

7 O'clock - .273 8 O'clock - .277 11 O'clock - .269

Marker #4 12 O'clock - .252 I O'clock - .278 2 O'clock - .280 5 O'clock - .274 6 O'clock - .285

7 O'clock - .283 1 1 O'clock - .272

Marker #5 12 O'clock-.276 1 O'clock - .265 5 O'clock - .275 6 O'clock - .261 7 O'clock - .274

11 O'clock-.286

Marker)')'6 12 O'clocic-.268 3 O'clock - .249 6 O'clock - .263 9 O'clock - .269

Marker #7 12 O'clock-.294 5 O'clock - .276 6 O'clock - .297 7 O'clock-.290 11 O'clock-.291

y- f

Remarks:

"NA"=Does not apply to this inspection.

-Mf< .T"—rrUItrasonic Inspection: n Accepted or ^ected-J^krfld.'^ o ft //

QC Inspector: ^?oL ^/8^Badge Number

CP4-QA-21H-F01FR1'

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rE\AC-CMD-18-12~

jAtfachment C (Ref4.6 pg 2/3)

Ultrasonic thickness check on nitrogen pipeline

Parameters measured against

Schedule 40 pipe outer diameter perASTM ASS {inches}:

Specified wall thickness Schedule 40 pipe perASTM A53 (inches)::(Assumed Maximum'} wall thickness Schedule 50 pipe perASTM A53 {inches}:.|(Assumed Minimum} wall thickness Schedule 30 pipe per'ASTM A53 (inches);

6.625

0.280

0.312 Upper tolerance may be acceptable depending on flow demands0.250 Lower tolerance may be acceptable depending on system pressure •

Marker number:

Nominal pipe size (inches):Location description:

Position to perform UT check

Readings from UT check

16

North east ofC-302 facing south marked '

12 O'clock

L̂O1vc

1 O'clock

x2 O'clock

L" on blue nitrogen header st ground ieve3 O'clock^4 O'clock 5 O'clock

^6 O'clock

.^k.

7 O'clock

^^

8 O'clock

x9 O'clock 10 O'clock 11 O'clock

Notes:

Marker number:

Nominal pipe size (inches):

Location description:



Notes:

26

North of C-709 facing south marked "2" on blue nitrogen header at ground levei (near low point/plug)

12 O'clock

^1 O'clock

XE2 O'clock

x3 O'clock

/_

4 O'clock

x5 O'clock

x6 O'Ctock

^7 O'clock

x8 O'clock

s9 O'clock

.^

10 O'clock

x11 O'clock

xMarker number:




3-6

North west side ofC-710 facing south marked "3" on blue nitrogen header at ground level (near low point/plug)

12 O'clock

,,n

1 O'clock

,^v

2 O'clock

x3 O'clock

x4 O'clock

^5 O'clock

^6 O'clock

^7 O'clock

^8 O'Ciock

.ffl

9 O'clock 10 O'clock5TOx 11 O'clock

frNotes:

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Marker number:

EV-C-CMD-18-12

Attachment C (Ref4.6 pg 3/3)

Nominal pipe size (inches):Location description; North west side of C-200 at pipe bridge facing south marked "4" on blue nitrogen header at ground level

Position to perform UT check j 12 O'clock | 1 O'clock | 2 O'Ciock j 3 O'clock f 4 O'clock | 5 O'clock ! 6 O'clock | 7 O'clock | 8 O'clock i 9 O'clock I 10 O'clock ! 11 O'clock


.6^ ^ ^ ^ x054°' $Notes:

Marker number;




56

North west side of C-750 facing west marked "5" on blue nitrogen header at ground level (near tow point/plug)

12 O'Cfock

Î

1 O'clock

^V

2 O'clock

x3 O'clock

x4 O'clock 5 O'clock

^6 O'clock

.^

7 O'clock

^8 O'clock 9 O'clock

xx̂10 O'clock 11 O'clock

^Notes:

Marker number:

Nominal pipe size (inches):

Location description:



\L 6T

Soutêastîde of C-409 at pipe bridge facing west marked "6" on blue nitrogen header at ground level12 O'clock

^1 O'clock

x2 O'clock

x3 O'clock

^4 O'clock

x5 O'clock

x6 O'clock

^7 O'CJock

x8 O'clock

x9 O'clock

.^

10 O'clock

x11 O'Cfock

xNotes:

Marker number:

Nominal pipe size (inches):Location description: South east side of C-600 at pipe bridge facing west marked "7" on blue nitrogen header at ground level (near low point/ptug)

Position to perform UT check ) 12 O'Ctock | 1 O'clock | 2 O'clock | 3 O'clock | 4 O'clock | 5 O'clock | 6 O'aock | 7 O'clock | 8 O'clock ] 9 O'clock | 10 O'clock | 11 O'clock

Readings from UT check.^̂ $̂ ^

Notes:7^ loC-^'o^ /S Q-C^li,/ ôcrf-^ ^<s^ 0-F ^-z^9.

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EV-C-CMD-18-12

Attachment D (Ref4.7 pg 1/1)

Calculation-Hoop Stress per B31.8-2016

Rev: D 01/30/19 By: KL Kaylor

Ref 1 pg9 805,2.3

Hoop Stress

Sh= PD/2t psi

P= design pressure, psig

t= nominal wall thickness

D= nominal outside diameter (in)

Given: Pipe is 6" nitrogen system piping; joints are butt welded

Ref2 Material is carbon steel pipe, sch 40 ASTM A53 lap weldedDesign pressure:

P= 125 psiCalculate (Sh) hoop stress for given piping:

Ref3 pgllRef3 pgll

Table X2.2

Table X2.2

t=

D=

0.280 in

6.625 in

6" sch 40

6" sch 40

Sh= 1479 psi

References:

Refl ASME 831.8 Gas Transmission and Distribution Piping Systems- 2018

Ref2 Master Specification for Process Services - Nitrogen System, Section 42-C February 28,1951

Ref3 ASTM ASS Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless

Natural Gas Piping-Hoop Stress Calculation-RevD 2019-0130Printed: 1/30/2019

Page 1 of 1

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ENGINEERING EVALUATION

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