ULNRC-05781, Callaway Plant NFPA 805 Transition Report, Attachment M - License Condition Changes
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Ameren Missouri M. August 2011 Callaway Plant NFPA 805 Transition Report License Condition Changes 18 Pages Attached Page M-1 Ameren Missouri Callaway Plant NFPA 805 Transition Report Replace the current Callaway Plant Unit 1 fire protection operating license (OL) condition 2.C(S) with the standard operating license condition in Regulatory Position C.3.1 of Regulatory Guide 1.20S, "Risk-Informed, Performance-Based Fire Protection for Light-Water Nuclear Power Plants," Revision 1, as modified by FAQ 06-0008 Revision 9 (ML073380976), as described below. It is Ameren Missouri's understanding that implicit in the superseding of these license conditions, prior fire protection SERs and commitments have been superseded in their entirety by the revised license condition.
However, Revision OS6 to the Callaway Plant Unit 1 Operating License dated June 26, 2007, added OL condition C.1S "Mitigation Strategy License Condition" in response to Section B.S.b of the February 2S, 2002, "Interim Compensatory Measures Order" (EA-02-026) (TAC No.4S18).
This order requires that strategies for addressing large fires and explosions be maintained for key areas. This OL condition will remain in effect. No other license conditions need to be superseded or revised. Ameren Missouri implemented the following process for determining that OL condition 2.C(S) is the only license condition required to be superseded to implement the new fire protection program which meets the requirements of 10 CFR S0.48(a) and SO.48(c):
A review of the Callaway Plant OL NPF 30, Revision OS6 (which incorporated OL Condition C.1S) and the current Revision 068 was performed by the Callaway Plant licensing staff and the NFPA 80S Transition Team. The review was performed by reviewing the OL and performing electronic searches using the Callaway Plant Licensing Research System (LRS). The Callaway Plant LRS contains Callaway Plant licensing documents, correspondence, and regulatory and guidance materials, including those documents pertaining to the operating license, the Technical Specifications, the fire protection program, the FSAR and subsequent revisions, correspondence sent to the NRC, and correspondence received from the NRC. The correspondence sent to the NRC includes any outstanding license amendment request submittals.
August 2011 Page M-2 Ameren Missouri Callaway Plant NFPA 805 Transition Report Supersede the following license condition 2.C(S): (5) Fire Protection (Section 9.5.1.7 SER and Section 9.5.1.8, SSER #3) (a) Deleted per Amendment No. 169. (b) Deleted per Amendment No. 169. (c) The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 15, the Callaway site addendum through Revision 8, and as approved in the SER through Supplement 4, subject to provision d below. (d) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire. (e) Deleted (see Amendment No. 30, January 13, 1988). New License Condition:
Union Electric shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated MM/DDIYYYY (and supplements dated MM/DDIYYYY) and as approved in the safety evaluation report dated MM/DDIYYYY (and supplements dated MM/DDIYYYY).
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satiSfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk impact. (a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. (b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10-7/year (yr) for CDF and less than 1 x 1 0-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
August 2011 Page M-3 Ameren Missouri Callaway Plant NFPA 805 Transition Report Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement.
A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard.
The four specific sections of NFPA 805, Chapter 3, are as follows: * "Fire Alarm and Detection Systems" (Section 3.8); * "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9); * "Gaseous Fire Suppression Systems" (Section 3.10); and * "Passive Fire Protection Features" (Section 3.11). (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MM/DDIYYYY to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program. Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above. (2) The licensee shall implement the modifications described in the August ##, 2011 submittal of the Callaway Plant NFPA 805 Transition Report Table S-2, "Plant Modifications Committed," to complete the transition to full compliance with 10 CFR 50.48(c) by June 30, 2013. August 2011 Page M-4 Ameren Missouri Callaway Plant NFPA 805 Transition Report (3) The licensee shall maintain appropriate compensatory measures in place until completion of the modifications delineated above. August 2011 Page M-5 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report Operating License Markup 4 Pages Attached Page M-6 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report LDCN 11*0012 OPERA TING LICENSE MARKUP U(ense Condition 2.C.S Page M-7 Ameren Missouri Callaway Plant NFPA 805 Transition Report August 2011 11"002.. Operating License Revision 068 (4) Surveillance of Hafnlym Control Bods (Sect i on 4.2.3.1(10)
SER and SSER#2) T licensee may make chan to the approved fire tection program without prior a val of the Commission only If those changes would not advers feet the ability to achieve and maintain safe shutdown In the e (6) Qualification of personnel (Sactjon 13 1 2 SSER #3. Section 18. SSER#1) Deleted per Amendment No. 169. (7) NUBEG-0737 CondHlons (Section 22 SEB) Deleted per Amendment No. 169. (8) post-Fuel-Loadlng Initial Test program (Sectlgn 14. SEB) Deleted per Amendment No. 169. (9) Inservlce Inspection program (Sectlgns 52 4 and 8.8. SEB) Deleted per Amendment No. 169. (10) Emergency planning Deleted per Amendment No. 169.
A140.0001 Page M-8 Ameren Missouri Callaway Plant NFPA 805 Transition Report LDCN 11-0012 OLINSERT (5) Fire Protection Union Electric shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated MMlDONYYY (and supplements dated MMIDONYYY) and as approved in the safety evaluation report dated MMlDONYYY (and supplements dated MMlDONYYY).
Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Risk-Informed Changes that May Be Made Without Prior NRC Approval A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, operated, and maintained plant; and reflect the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFP A 805 risk assessments, or methods that have been demonstrated to bound the risk impact. (a) Prior NRC review and approval is not required for changes that clearly result in a decrease in risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation. (b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1 x 10.7 /year (yr) for COF and less than 1 xl 0-8/yr for LERF. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement.
A qualified August 2011 Page M-9 Ameren Missouri Callaway Plant NFPA 805 Transition Report LDCN 11-0012 OL INSERT (page 2) fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The four specific sections ofNFPA 805, Chapter 3, are as follows: * "Fire Alarm and Detection Systems" (Section 3.8); * "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9); * "Gaseous Fire Suppression Systems" (Section 3.10); and * "Passive Fire Protection Features" (Section 3.11). (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MMlDD/YYYY to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program. Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above. (2) The licensee shall implement the modifications described in the August ##,2011 submittal of the Callaway Plant NFPA 805 Transition Report Table S-2, "Plant Modifications Committed," to complete the transition to full compliance with 10 CFR 50.48(c) by June 30, 2013. (3) The licensee shall maintain appropriate compensatory measures in place until completion of the modifications delineated above. August 2011 Page M-10 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report Operating License Retype 8 Pages Attached Page M-11 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report (4) Syrveillance of Hafnium Control Rods (Section 42.31 (1 Q) SER and SSER #2) Deleted per Amendment No. 169 (5) Fire Protectlgn Union Electric shall Implement and maintain In effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the license amendment request dated MMJDDNYVY (and supplements dated MMJDD/yyVY) and as approved in the safety evaluation report dated MM/DD/YVYY (and supplements dated MM/OOIYYYY) . Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satiSfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.
Bills-I nformed Cbanges tbat May Be Made Wlthoyt prlQr NBC Approyal A risk assessment of the change must demonstrate that the acceptance criteria below are met. The risk assessment approach, methods, and data shall be acceptable to the NRC and shall be appropriate for the nature and scope of the change being evaluated; be based on the as-built, as-operated, and maintained plant; and refled the operating experience at the plant. Acceptable methods to assess the risk of the change may include methods that have been used in the peer-reviewed fire PRA model, methods that have been approved by NRC through a plant-specific license amendment or NRC approval of generic methods specifically for use in NFPA 805 risk assessments, or methods that have been demonstrated to bound the risk Impact. (a) Prior NRC review and approval Is not required for changes that clearly result In a decrease In risk. The proposed change must also be consistent with the defense-in-depth philosophy and must maintain sufficient safety margins. The change may be implemented following completion of the plant change evaluation.
Amendment
- If. Page M-12 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report w5-(b) Prior NRC review and approval is not requirad for individual changes that result In a risk increase less than 1)(1 0*7/year (yr) for CDF and less than 1 >>e10*8/yr for LERF. The proposed change must also be consistent with the defense-In-depth philosophy and must maintain sufficient safety margins. The change may be Implemented following completion ofthe plant change evaluation.
Other Changes that Mav Be Made VYlthout prior NRC ARproyal (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element Is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element Is functionally equivalent to the corresponding technical requirement.
A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component.
system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The licensee may use an engineering evaluation to demonstrate that ohanges to certain NFPA 805, Chapter 3, elements are acceptable because the alternative Is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.
The four specific sections of NFPA 805, Chapter 3, are as follows: "Fire Alarm and Detection Systems" (Section 3.8); "Automatic and Manual water-Based Fire Suppression Systems" (Section 3.9); "Gaseous Fire Suppression Systems" (Section 3.10); and "Passive Fire Protection Features" (Section 3.11 ). Amendment
- Page M-13 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MM/CC/YVYY to determine that certain fire protection program changes meet the minimal criterion.
The licensee shall ensure that fire protection defense-In-depth and safety margins are maintained when changes are made to the fire protection program. Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, rlsk*lnformed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described In (2) above. (2) The licensee shall implement the modifications described In the August #I, 2011 submittal of the Callaway Plant NFPA 805 Transition Report Table S-2, "Plant Modifications Committed," to complete the transition to full eompliance with 10 CFR 50.48(c) by June 30, 2013. (3) The licensee shall maintain appropriate eompensatory measures in place until eompletion of the modifications delineated above. (6) Qualjfication of personnel (Section 131 2 SSEB"3 Section 18 SSEB #1) Celeted per Amendment No. 169. (7) NUBEG-OZ37 Conditions (Section 22 SgB) Deleted per Amendment No. 169. (8) post.Fyel-Loading Initial Test program (Section 14 SEB) Deleted per Amendment No. 169. Amendment
- Page M-14 Ameren Missouri August 2011 Callaway Plant NFPA 805 Transition Report (9) Inservloe Inapeetlon program (Sedlons 5 24 and § § SER) Deleted per Amendment No. 169. (10) !imergenR" planning Deleted per Amendment No. 169. (11) Steam Generator Tybe Ruptyre (Sedion 1544 SSER #3) Deleted per Amendment No. 169. (12) Low Tempe@ture Overpressure protection (Section 15 SSeB #3) Deleted per Amendment No. 169. (13) LOCA Reanalysis (Section 15 SS ER #3) Deleted per Amendment No. 169. (14) Generic Letter 83-28 Deleted per Amendment No. 169. (15) Mitigation Strategy L1ans. Condltign Develop and maintain strategies for addressing large flres and explosions and that loolude the following key areas: (a) Fire fighting response strategy with the following elements: 1 . Pre-defined coordinated fire response strategy and guidance 2. Assessment of mutual aid fire fighting assets 3. Designated staging areas for eqUipment and materials
- 4. Command and control 5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:
- 1. Protection and use of personnel assets 2. Communications
- 3. Minimizing fire spread 4. Procedures for implementing integrated fire response strategy 5. Identification of readily-available, pre-staged eqUipment
- 6. Training on integrated fire response strategy 7. Spent fuel pool mitigation measures Amendment
- 2. Dose to onslte responders (16) Additional Conditions The Additional Conditions contained In Appendix C, as revised through Amendment No. 190. are hereby Incorporated Into this license. UE shall operate the facility In accordance with the Additional Conditions. D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50. are described In the October 9, 1984 staff letter. This exemption Is authorized by law and will not endanger life or property or the common defense and security and are otherwise In the public interest.
Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate. to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission. E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans Including amendments made pursuant to provisions of the Mlsce"aneous Amendments and Search Requirements revisions to 1 0 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21 , are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006. F. Deleted per Amendment No. 169. G. UE shall have and maintain financial protection of such type and In such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954. 8S amended, to cover public liability claims. H. This license Is effective as of the date oflssuanee and shall expire at Midnight on October 18, 2024. FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY H. R. DENTON Harold R. Denton, Director Office of Nuclear Reactor Regulation Amendment
- 1. Attachment 1 (Deleted per Amendment No.1 69) 2. Attachment 2 (Deleted per Amendment No. 169) 3. Appendix A -Technical Specifications (NUREG-1058, Revision 1) 4. Appendix B -Environmental Protection Plan 5. Appendix C -Additional Conditions Date of Issuance:
October 18, 1984 Amendment
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