ML070460584
| ML070460584 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/21/2007 |
| From: | Donohew J NRC/NRR/ADRO/DORL/LPLIV |
| To: | Naslund C Union Electric Co |
| Donohew J, NRR/DORL/LP4, 415-1307 | |
| Shared Package | |
| ML070470147 | List: |
| References | |
| TAC MD2362 | |
| Download: ML070460584 (13) | |
Text
March 21, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: REVISION TO TECHNICAL SPECIFICATIONS FOR USE OF BEACON POWER DISTRIBUTION MONITORING SYSTEM (TAC NO. MD2362)
Dear Mr. Naslund:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 182 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 25, 2006 (ULNRC-05297), as supplemented by the letter dated March 12, 2007 (ULNRC-05380).
The amendment revised TSs 3.1.7, "Rod Position Indication," 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)," 3.2.4, "Quadrant Power Tilt Ratio (QPTR)," and 3.3.1, "Reactor Trip System (RTS) Instrumentation, to allow use of the Westinghouse proprietary computer code, the Best Estimate Analyzer for Core Operations - Nuclear (BEACON). Certain required actions, for when a limiting condition for operation is not met, and certain surveillance requirements are being changed to refer to power distribution measurements or measurement information of the core.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosures:
- 1. Amendment No. 182 to NPF-30
- 2. Safety Evaluation cc w/encls: See next page
March 21, 2007 Mr. Charles D. Naslund Senior Vice President and Chief Nuclear Officer Union Electric Company Post Office Box 620 Fulton, MO 65251
SUBJECT:
CALLAWAY PLANT, UNIT 1 - ISSUANCE OF AMENDMENT RE: REVISION TO TECHNICAL SPECIFICATIONS FOR USE OF BEACON POWER DISTRIBUTION MONITORING SYSTEM (TAC NO. MD2362)
Dear Mr. Naslund:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 182 to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 25, 2006 (ULNRC-05297), as supplemented by the letter dated March 12, 2007 (ULNRC-05380).
The amendment revised TSs 3.1.7, "Rod Position Indication," 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)," 3.2.4, "Quadrant Power Tilt Ratio (QPTR)," and 3.3.1, "Reactor Trip System (RTS) Instrumentation, to allow use of the Westinghouse proprietary computer code, the Best Estimate Analyzer for Core Operations - Nuclear (BEACON). Certain required actions, for when a limiting condition for operation is not met, and certain surveillance requirements are being changed to refer to power distribution measurements or measurement information of the core.
A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.
Sincerely,
/RA/
Jack Donohew, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483 DISTRIBUTION:
PUBLIC GHill
Enclosures:
- 1. Amendment No. 182 to NPF-30 LPLIV Reading RidsNrrDorlDpr
- 2. Safety Evaluation RidsNrrDorl RidsNrrDorlLpl4 cc w/encls: See next page RidsNrrPMJDonohew RidsNrrLALFeizollahi RidsOgcRp RidsAcrsAcnwMailCenter RidsRegion4MailCenter RidsNrrDirsItsb RidsNrrDssSpwbGCranston ACCESSION NO.: ML070460584 PKG. ML070470147 TS: ML070680350 NRR-058 OFFICE NRR/LPL4/PM NRR/LPL4/LA ITSB/BC SPWB/BC OGC NRR/LPL4/BC NAME JDonohew LFeizollahi TKobetz GCranston PMoulding DTerao DATE 3/15/07 3/19/07 03/02/07 02/28/07 03/13/07 3/19/07 OFFICIAL RECORD COPY
UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 182 License No. NPF-30 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Union Electric Company (UE, the licensee),
dated May 25, 2006, as supplemented by the letter dated March 12, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications and paragraph 2.C.(2) of Facility Operating License No. NPF-30 as indicated in the attachment to this license amendment.
3.
This amendment is effective as of its date of issuance, and shall be implemented before entry into Mode 2 in the plant restart from the refueling outage scheduled for the spring of 2007. This includes the incorporation of the identified changes to the Final Safety Analysis Report (FSAR) in Attachment 6 of the licensees application dated May 25, 2006, into the FSAR.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Facility Operating License and Technical Specifications Date of Issuance: March 21, 2007
ATTACHMENT TO LICENSE AMENDMENT NO. 182 FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following pages of the Facility Operating License No. NPF-30 and Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Operating License REMOVE INSERT Technical Specifications REMOVE INSERT 3.1-16 3.1-16 3.1-17 3.1-17 3.2-4 3.2-4 3.2-13 3.2-13 3.3-12 3.3-12 3.3-13 3.3-13
1 The ADAMS Accession number for the letter was not available on the date the amendment was issued.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 182 TO FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By application dated May 25, 2006, as supplemented by the letter dated March 12, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.
ML061570437 and MLXXXXXXXX1, respectively), Union Electric Company (the licensee) requested changes to Facility Operating License No. NPF-30 for the Callaway Plant, Unit 1 (Callaway). The licensee proposed to revise Technical Specifications (TSs) 3.1.7, "Rod Position Indication," 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)," 3.2.4, "Quadrant Power Tilt Ratio (QPTR)," and 3.3.1, "Reactor Trip System (RTS) Instrumentation.
The proposed changes are to allow use of the Westinghouse proprietary computer code, the Best Estimate Analyzer for Core Operations - Nuclear (BEACON). The new BEACON power distribution monitoring system (PDMS) would augment the functional capability of the neutron flux mapping system for the purposes of power distribution surveillances at Callaway. Certain required actions, for when a limiting condition for operation is not met, and certain surveillance requirements would be changed to refer to power distribution measurements or measurement information of the core.
The BEACON system was developed by Westinghouse to improve operational support for pressurized-water reactors (PWRs). It is a core monitoring and support package that uses Westinghouse standard instrumentation in conjunction with an analytical methodology for online generation of three-dimensional power distributions. The system provides core monitoring, core measurement reduction, core analysis, and core predictions. Since BEACON does not have any direct inputs to the reactor protection system, BEACON will not affect any of the accident analyses in the Callaway licensing basis. Furthermore, as stated in its application, the licensee will not use BEACON to relax the key safety parameter limits or levels of margin at Callaway.
In Attachments 5 and 6, respectively, to its application, the licensee identified changes to the TS Bases and to the Final Safety Analysis Report (FSAR). The changes to the FSAR provide additional detail not given in the licensees evaluation of the proposed amendment in Attachment 1 to its application, and the Nuclear Regulatory Commission (NRC) staff reviewed this information as part of its review of the license amendment request. The changes to the TS Bases would be made by the licensee in accordance with TS 5.5.14, Technical Specifications Bases Control Program, at the time that the amendment is implemented, if approved. These changes were reviewed to determine whether the NRC staff had any disagreements with the identified changes based on the proposed amendment.
The supplemental letter dated March 12, 2007, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination published in the Federal Register on July 18, 2006 (71 FR 40756).
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensure the operational capability of structures, systems, and components that are required to protect the health and safety of the public. The NRC's regulatory requirements related to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36), which requires that the TSs include items in the following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TSs. As stated in 10 CFR 50.36(c)(2)(i), the [l]imiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications... SRs are, in accordance with 10 CFR 50.36(c)(3), requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
As required by 10 CFR 50.36(c)(2)(ii), a limiting condition for operation must be included in the TSs for any item meeting one of the following four criteria:
Criterion 1:
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
Criterion 2:
A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 3:
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 4:
A structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
Those items that do not fall within or satisfy any of the above criteria do not need to be included in Section 3 of the TSs. The PDMS instrumentation does not meet any of the criteria of 10 CFR 50.36(c)(2)(ii) for inclusion in the TSs. Therefore, the licensee will include the PDMS instrumentation in an equipment control guideline (ECG). The ECGs are plant-specific administrative controls on equipment, similar to TS controls, but which are maintained by the licensee in accordance with 10 CFR 50.59.
There are no specific regulatory requirements on PDMSs, such as the Westinghouse Electric Company (WEC) BEACON system; however, the use of such systems by licensees in monitoring the power distribution in the reactor core during power operation must be consistent with the safe operation of the plant. The NRC staff must reach such a conclusion in approving the use of the BEACON system at Callaway.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes
In its application, the licensee proposed the following changes to TSs 3.1.7, 3.2.1, 3.2.4, and 3.3.1:
1.
For TS 3.1.7, replace the phrase movable incore detectors by the phrase core power distribution measurement information in Required Actions A.1, B.3, and C.1.
2.
For TS 3.2.1, replace the phrase flux maps by the phrase power distribution measurements in SR 3.2.1.2.
3.
For TS 3.2.4, replace the phrase the movable incore detectors by the phrase power distribution measurement information in SR 3.2.4.2.
4.
For TS 3.3.1, replace the word detector by the phrase power distribution in SRs 3.3.1.3 and 3.3.1.6. Also, delete the article the from SR 3.3.1.3.
3.2 Background
The licensee is proposing the changes to the TSs to allow the use of a PDMS at Callaway. The PDMS would be an enhancement to its core power distribution measurement and indication capability. The core power distribution information that is to be referred to in the proposed changes to TSs 3.1.7, 3.2.1, 3.2.4, and 3.3.1 would be information from either (1) the existing incore detector system or (2) the PDMS.
The PDMS to be used is the BEACON system (i.e., the BEACON PDMS), which was developed by Westinghouse to improve the monitoring support for Westinghouse-designed PWRs, such as Callaway. The BEACON PDMS is a core monitoring and support package, which uses Westinghouse standard instrumentation in conjunction with an analytical methodology for on-line generation of three-dimensional power distributions to provide core monitoring, core measurement reduction, core analysis, and core predictions. The BEACON PDMS is calibrated by the existing incore detector system.
The BEACON system is described in the topical report WCAP-12472-P, BEACON: Core Monitoring and Operations Support System, which was approved as WCAP-12472-P-A by the NRC staff for Westinghouse reactors in its letter dated February 16, 1994. The topical report WCAP-12472-P-A contains this NRC letter. The topical report had conditions specified in Section 4.0, Technical Position, of the Brookhaven National Laboratory Technical Evaluation Report (TER) dated November 18, 1993, Technical Evaluation of the BEACON Core Monitoring and Operations Support System Topical Report WCAP-12472-P, which was attached to the NRC staffs letter dated February 16, 1994. These conditions are the following:
1.
In the cycle-specific applications of BEACON, the power peaking uncertainties Uh and UQ must provide 95 percent probability upper tolerance limits at the 95-percent confidence level, 2.
In order to ensure that the assumptions made in the BEACON uncertainty analysis remain valid, the generic uncertainty components may require reevaluation when BEACON is applied to the plant or core designs that differ sufficiently to have a significant impact on the WCAP-12472-P database, and 3.
The BEACON technical specifications should be revised to include the changes described in Section 3.6 of the TER concerning Specifications 3.1.3.1 and 3.1.3.2, and the Core Operating Limits Report (COLR). The technical specifications applicable when BEACON is inoperable should be included in the BEACON specifications and not the COLR. Specifications 3.1.3.1 and 3.1.3.2 should be revised to address misaligned rods and shutdown margin, to require determination of control rod positions when a rod position or demand position is inoperable, and to apply to both Modes 1 and 2 of reactor operation.
In addressing the above conditions in Attachment 1 to its application, the licensee stated the following:
Criterion 1:
Although not specifically described in this submittal [the application], cycle-specific BEACON calibrations performed before startup and at beginning-of-cycle conditions will ensure that power peaking uncertainties provide 95%
probability upper tolerance limits at the 95% confidence level. These calibrations are to be performed using Westinghouse[-]approved methodology. Until these calibrations are complete, more conservative default uncertainties will be applied.
These calibrations will be documented and retained as records.
Criterion 2:
Callaway utilizes a Westinghouse 4-loop nuclear steam supply system (NSSS) with Westinghouse movable incore instrumentation. All fuel is presently of Westinghouse manufacture. Therefore, Callaway does not differ significantly from the plants that form the WCAP[-12472-P] database, and no additional review of WCAP applicability to Callaway is necessary.
During the review of the Westinghouse topical report WCAP-12472-P, the NRC requested additional information on how BEACON treats core loadings with fuel designs from multiple fuel vendors, and the impact to the BEACON uncertainty analysis. Westinghouse responded that for all BEACON applications, the previous operating cycle is examined to establish reference uncertainties. This examination accounts for loading of fuel supplied [by] multiple vendors by comparing a BEACON model to actual operating data over the cycle. At the beginning of cycle, thermocouple data is verified and calibration/uncertainty components are updated as necessary. In addition, the initial flux mapping at the start of the cycle [e]nsures model calibration factors that reflect the actual fuel in the reactor before the BEACON system is declared operable. [The licensee provided details on the initial plant startup with, and calibration of, the BEACON PDMS in its identified changes to Section 16.3.3.8.2 (item b.) of the FSAR.]
Criterion 3:
The WCAP[-12472-P] describes an application of BEACON where the core operating limits are changed. As noted previously [in its application], AmerenUE
[(the licensee)] is proposing only to use BEACON as a core Technical Specification monitor for conformance to Callaways existing limits. The TS changes of concern per this [criterion] or condition are not applicable or of concern to the more limited changes being proposed by AmerenUE for the intended use of BEACON. Therefore, this condition does not apply to the amendment requested for Callaway.
The NRC staff reviewed the licensees responses to the three criteria and concludes that the responses are acceptable. The licensee has not proposed changes to the COLR or the core safety limits for Callaway, and the proposed changes to TSs 3.1.7, 3.2.1, 3.2.4, and 3.3.1 are to allow the core power distribution to be determined at Callaway by either (1) the existing movable incore detector system or (2) the BEACON system; the proposed core power distribution measurements cover both. Also, as stated by the licensee and identified in the changes to the FSAR, the BEACON PDMS is considered inoperable, and thus is not used, below 25 percent rated thermal power (RTP) because the accuracy of the calculated core power distribution may not be bounded by the uncertainties in WCAP-12472-P. Based on this, the NRC staff concludes that the licensee has acceptably addressed the above NRC criteria and it is acceptable for the licensee to use the BEACON system described in WCAP-12472-P at Callaway.
In its application, the licensee stated that it intended to use BEACON to augment the functional capability of its core flux mapping system for the purpose of power distribution surveillances.
Although WCAP-12472-P discusses an application of BEACON in which there is continuous flux monitoring by control room operators, the licensee is proposing a more conservative application of BEACON in which the core power distribution limits themselves remain unchanged. The licensee intends to use the BEACON PDMS as the primary method for performing power distribution measurements and surveillances, and to use the flux mapping system as an alternative for such purposes, when the reactor power is greater than 25-percent RTP. At less than or equal to 25-percent RTP, or when the PDMS is inoperable, the existing movable incore detector system would be used.
In Attachment 2 to its application, the licensee addressed whether the PDMS needed to have an LCO added to the TSs to state that the system is required to be operable. The licensee concluded that an LCO for the PDMS was not required.
The PDMS instrumentation provides the capability to monitor core parameters at more frequent intervals than is currently required by the TSs. The PDMS combines inputs from currently installed plant instrumentation and design data for each fuel cycle, and does not modify or eliminate existing plant instrumentation. It provides a means to continuously monitor the power distribution limits including limiting peaking factors and quadrant power tilt ratio. The PDMS is used for periodic measurement of the core power distribution to confirm operation within design limits, and for periodic calibration of the excore detectors, and it does not initiate any automatic protection action. The PDMS instrumentation does not change any of the key safety parameter limits or levels of margin as considered in the reference design-basis evaluations. These limits are not revised by this license amendment, and can be determined independently of the operability of the PDMS. The PDMS itself does not meet any of the 10 CFR 50.36(c)(2)(ii) selection criteria (listed in Section 2.0 of this safety evaluation (SE)) for inclusion in the TSs.
Therefore, the NRC staff concludes that 10 CFR 50.36 does not require the PDMS to have an LCO in the TSs.
Based on its review of the proposed changes to TSs 3.1.7, 3.2.1, 3.2.4, and 3.3.1, which are identified in Section 3.1 of this SE, the NRC staff concludes that replacing the current TS references to incore detectors and neutron flux maps with the proposed references to core power distribution measurements or measurement information (from either the movable incore detector system or the BEACON system) is consistent with the technical requirements of the NRC-approved WCAP-12472-P, and, therefore, the proposed changes are acceptable. Based on this conclusion, the NRC staff further concludes that the proposed changes meet 10 CFR 50.36 and, therefore, the proposed amendment is acceptable.
The NRC staff reviewed the identified changes to the TS Bases and FSAR in Attachments 5 and 6, respectively, of the application. Based on its review, the NRC staff has no disagreements with identified changes to the TS Bases and FSAR. The changes to the TS Bases will be made in accordance with TS 5.5.14, Technical Specifications (TS) Bases Control Program. The changes to the FSAR include details in the licensees application that are addressed in this SE, but which do not appear in the changes to the TS Bases. In its letter dated March 12, 2007, the licensee agreed to incorporate the FSAR changes into the FSAR during its implementation of the amendment.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Missouri State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes SRs.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (71 FR 40756, published on July 18, 2006). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.
Principal Contributor: Jack Donohew Date: March 21, 2007
June 2006 Callaway Plant, Unit 1 cc:
Professional Nuclear Consulting, Inc.
19041 Raines Drive Derwood, MD 20855 John ONeill, Esq.
Pillsbury Winthrop Shaw Pittman LLP 2300 N. Street, N.W.
Washington, D.C. 20037 Mr. Keith A. Mills, Supervising Engineer Regional Regulatory Affairs/Safety Analysis AmerenUE P.O. Box 620 Fulton, MO 65251 U.S. Nuclear Regulatory Commission Resident Inspector Office 8201 NRC Road Steedman, MO 65077-1302 Mr. Les H. Kanuckel Manager, Quality Assurance AmerenUE P.O. Box 620 Fulton, MO 65251 Missouri Public Service Commission Governor Office Building 200 Madison Street Jefferson City, MO 65102-0360 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Mr. H. Floyd Gilzow Deputy Director for Policy Missouri Department of Natural Resources P.O. Box 176 Jefferson City, MO 65102-0176 Mr. Rick A. Muench President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Mr. Dan I. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, MO 63130 Mr. Lee Fritz, Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, MO 65151 Mr. David E. Shafer Superintendent, Licensing Regulatory Affairs AmerenUE P.O. Box 66149, MC 470 St. Louis, MO 63166-6149 Manager, Regulatory Affairs AmerenUE P.O. Box 620 Fulton, MO 65251 Mr. Keith G. Henke, Planner Division of Community and Public Health Office of Emergency Coordination 930 Wildwood P.O. Box 570 Jefferson City, MO 65102 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 Director, Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102-0116