ML20218A410
| ML20218A410 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/03/2020 |
| From: | Mahesh Chawla Plant Licensing Branch IV |
| To: | Diya F Ameren Missouri |
| Chawla M | |
| References | |
| EPID L-2019-LLA-0246 | |
| Download: ML20218A410 (14) | |
Text
November 3, 2020 Mr. Fadi Diya Senior Vice President and Chief Nuclear Officer Ameren Missouri Callaway Energy Center 8315 County Road 459 Fulton, MO 65077
SUBJECT:
CALLAWAY PLANT, UNIT NO. 1 - ISSUANCE OF AMENDMENT NO. 224 RE: PERFORMANCE BASED METHOD ALTERNATIVE FOR THERMAL INSULATION MATERIAL (EPID L-2019-LLA-0246)
Dear Mr. Diya:
The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 224 to Renewed Facility Operating License (FOL) No. NPF-30 for the Callaway Plant, Unit No. 1. The amendment consists of changes to the Callaways Renewed FOL in response to your application dated November 7, 2019, as supplemented by letter dated January 15, 2020.
The amendment revises the license condition in Callaways Renewed FOL associated with Callaways Fire Protection Program, which is authorized under Title 10 of the Code of Federal Regulations, Section 50.48(c), National Fire Protection Association (NFPA) Standard 805.
A copy of the related Safety Evaluation is also enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Mahesh L. Chawla, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483
Enclosures:
- 1. Amendment No. 224 to NPF-30
- 2. Safety Evaluation cc: Listserv
UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 License No. NPF-30
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Union Electric Company (the licensee), dated November 7, 2019, as supplemented by letter dated January 15, 2020, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions 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 Commissions 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 Commissions regulations and all applicable requirements have been satisfied.
Enclosure 1
- 2. Accordingly, the license is amended by changes as indicated in the attachment to this license amendment, and paragraph 2.C.(5) of Renewed Facility Operating License No. NPF-30 is hereby amended to read in part, as follows:
(5) Fire Protection Program 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 licensee amendment requests dated 8/29/2011 and 11/7/2019 (and supplements dated 11/9/2011, 4/17/2012, 7/12/2012, 2/19/2013, 8/5/2013, 9/24/2013, 12/19/2013 and 1/15/2020) and as approved in the safety evaluation reports dated 1/13/2014 and 11/3/2020. 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.
- 3. This amendment is effective as of its date of issuance, and shall be implemented within 90 days of the date of issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Digitally signed by Jennifer L. Jennifer L. Dixon-Herrity Date: 2020.11.03 Dixon-Herrity 13:12:39 -05'00' Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the Renewed Facility Operating License No. NPF-30 Date of Issuance: November 3, 2020
ATTACHMENT TO LICENSE AMENDMENT NO. 224 CALLAWAY PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. NPF-30 DOCKET NO. 50-483 Replace the following page of the Renewed Facility Operating License No. NPF-30 with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.
Renewed Facility Operating License REMOVE INSERT (4) Surveillance of Hafnium Control Rods (Section 4.2.3.1(10), SER and SSER #2)
Deleted per Amendment No. 169.
(5) Fire Protection Program 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 licensee amendment requests dated 8/29/2011 and 11/7/2019 (and supplements dated 11/9/2011, 4/17/2012, 7/12/2012, 2/19/2013, 8/5/2013, 9/24/2013, 12/19/2013 and 1/15/2020) and as approved in the safety evaluation reports dated 1/13/2014 and 11/3/2020. 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 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.
(b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x10-7/year (yr) for core damage frequency (CDF) and less than 1x10-8/yr for large early release frequency (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.
Renewed License No. NPF-30 Amendment No. 224
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 224 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-30 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT NO. 1 DOCKET NO. 50-483
1.0 INTRODUCTION
By application dated November 7, 2019 (Reference 1), as supplemented by letter dated January 15, 2020 (Reference 2), Union Electric Company dba Ameren Missouri (the licensee) submitted a license amendment request (LAR) for Callaway Plant, Unit No. 1 (Callaway),
requesting a change to its approved Fire Protection Program (FPP).
The proposed amendment would revise License Condition 2.C.(5), Fire Protection Program, of the Callaways Renewed Facility Operating License, which is authorized under Title 10 of the Code of Federal Regulations (10 CFR), Section 50.48(c), National Fire Protection Association (NFPA) Standard 805. Specifically, the licensee requested approval for the use of a performance-based (PB) method to demonstrate an equivalent level of fire protection for the requirements of NFPA Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (Reference 3),
Section 3.3.4, Insulation Materials.
The supplemental letter dated January 15, 2020, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the U.S. Nuclear Regulatory Commission (NRC or the Commission) staffs original proposed no significant hazards consideration determination as published in the Federal Register on January 14, 2020 (85 FR 2161).
2.0 REGULATORY EVALUATION
2.1 Program Description In the 1990s, the NRC worked with the NFPA and industry to develop a risk-informed (RI)/PB, consensus standard for fire protection. In 2001, the NFPA Standards Council issued NFPA 805, which describes a methodology for establishing fundamental FPP design requirements and elements, determining required fire protection systems and features, applying PB requirements, and administering fire protection for existing light-water reactors during Enclosure 2
operation, decommissioning, and permanent shutdown. It provides for the establishment of a minimum set of fire protection requirements but allows PB or deterministic approaches to be used to meet performance criteria. By letter dated January 13, 2014 (Reference 4), the NRC staff approved the adoption of NFPA 805 for Callaway.
2.2 Licensees Proposed Changes In its LAR dated November 7, 2019, the licensee proposed to modify the Callaway FPP to allow the use of a PB method to demonstrate an equivalent level of fire protection for the requirements of NFPA 805, Section 3.3.4, in order to retain certain currently installed thermal insulation materials (i.e., polyisocyanurate/foam insulation), and to allow the future use of these insulation materials in limited applications subject to appropriate engineering reviews and controls. The licensee submitted its request to use a PB method in accordance with the requirements of 10 CFR 50.48(c)(2)(vii).
The licensee also proposed the following changes to the Callaway FPP License Condition 2.C.(5) for Renewed Facility Operating License No. NPF-30 (changes shown in bold):
(5) Fire Protection Program 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 licensee amendment requests dated 8/29/2011 and 11/7/2019 (and supplements dated 11/9/2011, 4/17/2012, 7/12/2012, 2/19/2013, 8/5/2013, 9/24/2013, 12/19/2013 and 1/15/2020) and as approved in the safety evaluation reports dated 1/13/2014 and 11/3/2020. 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.
2.3 Regulatory Requirements The following regulations address fire protection:
Section 50.48, Fire protection, of 10 CFR, provides the NRCs requirements for nuclear power plant fire protection. The NRC regulations include specific requirements for requesting approval for a RI/PB FPP based on the provisions of NFPA 805. Additional requirements are provided in 10 CFR Part 50, Appendix R (Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979).
Section 50.48(a)(1) of 10 CFR requires that each holder of an operating license have a FPP that satisfies General Design Criterion (GDC) 3, Fire Protection, of Appendix A General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50.
Section 50.48(c) of 10 CFR incorporates NFPA 805 (2001 Edition) by reference, with certain exceptions, modifications, and supplementation. This regulation establishes the requirements
for using an RI/PB FPP in conformance with NFPA 805 as an alternative to the requirements associated with 10 CFR 50.48(b) and Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979, to 10 CFR Part 50, or the specific plant fire protection license condition. The regulation also includes specific requirements for requesting approval for an RI/PB FPP based on the provisions of NFPA 805.
Section 50.48(c)(3)(i) of 10 CFR states that:
A licensee may maintain a fire protection program that complies with NFPA 805 as an alternative to complying with paragraph b [10 CFR 50.48(b)] of this section for plants licensed to operate before January 1, 1979, or the fire protection license conditions for plants licensed to operate after January 1, 1979. The licensee shall submit a request to comply with NFPA 805 in the form of an application for license amendment under [10 CFR] 50.90. The application must identify any orders and license conditions that must be revised or superseded and contain any necessary revisions to the plants technical specifications and the bases thereof. The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the licensee has identified orders, license conditions, and the technical specifications that must be revised or superseded, and that any necessary revisions are adequate. Any approval by the Director or the designee must be in the form of a license amendment approving the use of NFPA 805 together with any necessary revisions to the technical specifications.
Section 50.48(c)(3)(ii) of 10 CFR states that:
The licensee shall complete its implementation of the methodology in Chapter 2 of NFPA 805 (including all required evaluations and analyses) and, upon completion, modify the fire protection plan required by paragraph (a) of this section to reflect the licensees decision to comply with NFPA 805, before changing its fire protection program or nuclear power plant as permitted by NFPA 805.
The purpose of 10 CFR 50.48(c)(3)(ii) is explained in the statement of considerations for the Final Rule, Voluntary Fire Protection Requirements for Light Water Reactors; Adoption of NFPA 805 as a Risk-Informed, Performance-Based Alternative (69 FR 33536; June 16, 2004),
which states, in part:
This paragraph requires licensees to complete all of the Chapter 2 methodology (including evaluations and analyses) and to modify their fire protection plan before making changes to the fire protection program or to the plant configuration. This process ensures that the transition to an NFPA 805 configuration is conducted in a complete, controlled, integrated, and organized manner. This requirement also precludes licensees from implementing NFPA 805 on a partial or selective basis (e.g., in some fire areas and not others, or truncating the methodology within a given fire area).
Appendix A to 10 CFR Part 50, GDC 3, states that:
Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability
and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems are designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components.
The regulations allow for flexibility that was not included in the NFPA 805 standard. Licensees who choose to adopt 10 CFR 50.48(c) but wish to use the PB methods permitted elsewhere in the standard to meet the fire protection requirements of NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements, may do so by submitting a LAR in accordance with 10 CFR 50.48(c)(2)(vii). This regulation further states that:
The Director of the Office of Nuclear Reactor Regulation, or a designee of the Director, may approve the application if the Director or designee determines that the performance-based approach; (A) Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (B) Maintains safety margins; and (C) Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
Alternatively, licensees may choose to use RI or PB alternatives to comply with NFPA 805 by submitting a LAR in accordance with 10 CFR 50.48(c)(4), which states, in part:
The Director of the Office of Nuclear Reactor Regulation, or designee of the Director, may approve the application if the Director or designee determines that the proposed alternatives:
(i) Satisfy the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; (ii) Maintain safety margins; and (iii) Maintain fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
2.4 Applicable Codes, Standards, Regulatory Guides, and Other Guidance Documents The 2001 edition of NFPA 805, specifies the minimum fire protection requirements for existing light-water nuclear power plants during all phases of plant operations, including shutdown, degraded conditions, and decommissioning. NFPA 805 was developed to provide a comprehensive RI/PB standard for fire protection. The NFPA 805 Technical Committee on Nuclear Facilities is composed of nuclear plant licensees, the NRC, insurers, equipment
manufacturers, and subject matter experts. The standard was developed in accordance with NFPA processes and consisted of a number of technical meetings and reviews of draft documents by committee and industry representatives. The scope of NFPA 805 includes goals related to nuclear safety, radioactive release, life safety, and plant damage/business interruption. The standard addresses fire protection requirements for nuclear plants during all plant operating modes and conditions, including shutdown and decommissioning, which had not been explicitly addressed by previous requirements and guidelines. NFPA 805 became effective on February 9, 2001.
RG 1.205, Revision 1, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, December 2009 (Reference 5), provides guidance for use in complying with the requirements that the NRC has promulgated for RI/PB FPPs that comply with 10 CFR 50.48 and the referenced 2001 Edition of the NFPA 805 standard. RG 1.205 sets forth regulatory positions; clarifies the requirements of 10 CFR 50.48(c) and NFPA 805; clarifies the guidance in Nuclear Energy Institute (NEI) 04-02, Revision 2, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c),
April 2008 (Reference 6); and provides exceptions to the NEI 04-02 guidance where required.
Should a conflict occur between NEI 04-02 and RG 1.205, the regulatory positions in RG 1.205 govern.
NEI 04-02, provides guidance for implementing the requirements of 10 CFR 50.48(c), and represents methods for implementing in whole, or in part, a RI/PB FPP. This implementing guidance for NFPA 805 has two primary purposes: (1) provide direction and clarification for adopting NFPA 805 as an acceptable approach to fire protection, consistent with 10 CFR 50.48(c); and (2) provide additional supplemental technical guidance and methods for using NFPA 805 and its appendices to demonstrate compliance with fire protection requirements. Although there is a significant amount of detail in NFPA 805 and its appendices, clarification and additional guidance for select issues help ensure consistency and effective utilization of the standard.
3.0 TECHNICAL EVALUATION
3.1 Background/Discussion In its LAR, the licensee requested approval of a PB method to demonstrate an equivalent level of fire protection for the NFPA 805, Section 3.3.4 requirement that thermal insulation materials, radiation shielding materials, ventilation duct materials, and soundproofing materials be noncombustible or limited combustible. Specifically, the licensee stated that in several areas, exposed thermal insulation materials are installed on various heating, ventilation and air conditioning system piping to prevent sweating, and that although these materials comply with the flame spreading rating of 25 or less, these materials do not meet the definition of limited combustible due to the heat value exceeding 3,500 British thermal units/pound (Btu/lb).
The licensee stated that there are specifically identified locations where closed cell foam thermal insulation material is used as thermal insulation on system piping/equipment for the purpose of maintaining system efficiency and/or preventing pipe sweat.
In order for a licensee to use a PB method to demonstrate an equivalent level of fire protection for an NFPA 805 Chapter 3 requirement, the licensee must demonstrate that the alternative satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release, that the alternative maintains
safety margins, and that it also maintains fire protection defense-in-depth (DID) (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
3.2 Licensees Request In its LAR, the licensee provided the basis for the request, including a DID and safety margin evaluation. The licensee stated that future installations of these insulation materials (i.e.,
polyisocyanurate/foam insulation) are subject to engineering evaluation using the plant design change control process before such material is installed, which includes screening and review for FPP impact, including impacts on existing fire scenarios as applicable.
The licensee concluded that its alternative approach outlined in the LAR achieves the following criteria:
Satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release; Maintains safety margins; and Maintains fire protection defense-in-depth (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
3.3 NRC Staff Evaluation The NRC staff reviewed the information provided by the licensee in its LAR, which included discussions of the impact of the proposed change on the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release, DID, and safety margins as required by 10 CFR 50.48(c)(2)(vii).
The NRC staff determined that the proposed change satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release because the insulation materials (i.e., polyisocyanurate/foam insulation): (1) are installed in limited number of areas throughout the plant only on certain equipment associated with heating, ventilation and air conditioning systems, or installed in small quantities for personnel safety applications; (2) will not contribute significantly to fire because they do not support continued progressive combustion because the flame spread rating is 25 or less; (3) meet the intent of the revised limited combustible material definition because the materials have a flame spread rating of 25 or less which is half of the maximum value of 50 allowed by NFPA 805; (4) do not represent a secondary combustible beyond those currently analyzed in the fire probabilistic risk assessment due to the limited areas and small quantities; (5) do not result in increased combustible loading that would challenge the design bases of the installed fire protection systems; and (6) do not affect the plants ability to contain potentially contaminated water and to monitor smoke.
The NRC staff determined that the proposed change maintains fire protection DID because the insulation materials are not considered a method for preventing fires from starting, or detecting, controlling, or extinguishing fires. In addition, the level of fire protection that will be provided so that a fire will not prevent essential safety functions from being performed is not changed because the limited areas and small quantities of insulation materials do not impact the availability and reliability of fire protection systems and features.
The NRC staff also determined that the proposed change continues to maintain adequate safety margins. The NRC staff determined that the change does not impact any codes and standards, or their alternatives accepted for use by the NRC because the licensee demonstrated that the insulation materials meet the flame spread and smoke developed criteria in American Society of Testing and Materials (ASTM) E84, Standard Test Method for Surface Burning Characteristics of Building Materials (Reference 7), and will not support progressive continued combustion.
The NRC staff further determined that the change does not impact any safety analysis acceptance criteria used in the licensing basis because the licensee demonstrated that the thermal insulation materials will not compromise automatic or manual fire suppression functions or post fire safe shutdown capability and are bound by the fire probabilistic risk assessment as discussed in item (4) above.
3.4 NRC Staff Conclusion
Based on its review of the information submitted by the licensee, and in accordance with 10 CFR 50.48(c)(2)(vii), the NRC staff concludes that the proposed PB method to justify the continued use of certain thermal insulation materials (i.e., polyisocyanurate/foam insulation) is an acceptable alternative to the corresponding NFPA 805, Section 3.3.4 requirement, because it satisfies the performance goals, performance objectives, and performance criteria specified in NFPA 805 related to nuclear safety and radiological release, maintains safety margins, and maintains fire protection DID (fire prevention, fire detection, fire suppression, mitigation, and post-fire safe shutdown capability).
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the State of Missouri official was notified of the proposed issuance of the amendment on July 27, 2020. On July 28, 2020, the State official confirmed that the State of Missouri had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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, published in the Federal Register on January 14, 2020 (85 FR 2161), and there has been no public comment on such finding. 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) there is reasonable assurance that such activities will be conducted in compliance with the Commissions 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.
7.0 REFERENCES
1 Wink, R. C., Ameren Missouri, letter to U.S. Nuclear Regulatory Commission, "Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Renewed Facility Operating License NPF-30, Performance Based Method Alternative for Thermal Insulation Material (LDCN 19-0012)," dated November 7, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19312B657).
2 Bianco, F. J., Ameren Missouri, letter to U.S. Nuclaer Regulatory Commission, "Docket Number 50-483, Callaway Plant Unit 1, Union Electric Co., Renewed Facility Operating License NPF-30, Supplement to License Amendment Request Regarding Performance Based Method Alternative for Thermal Insulation Material (LDCN 19-0012)," dated January 15, 2020 (ADAMS Accession No. ML20015A279).
3 National Fire Protection Association, NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," Standard 805, 2001 Edition, Quincy, Massachusetts.
4 Lyon, C. F., U.S. Nuclear Regulatory Commission, letter to Adam C. Heflin, Union Electric Company, "Callaway Plant, Unit 1 - Issuance of Amendment Regarding Transition to a Risk-Informed, Performance-Based Fire Protection Program in Accordance with 10 CFR 50.48(c)
(TAC No. ME7046)," dated January 13, 2014 (ADAMS Accession No. ML13274A596).
5 U.S. Nuclear Regulatory Commission, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," Regulatory Guide 1.205, Revision 1, December 2009 (ADAMS Accession No. ML092730314).
6 Nuclear Energy Institute, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)," NEI 04-02, Revision 2, Washington, DC, April 2008 (ADAMS Accession No. ML081130188).
7 American Society for Testing and Materials, "Standard Test Method for Surface Burning Characteristics of Building Materials," ASTM E84, West Conshohocken, Pennsylvania.
Principal Contributors: J. Robinson R. Vettori Date: November 3, 2020
ML20218A410 *via e-mail **via memo OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA* NRR/DRA/APLB/BC**
NAME MChawla PBlechman JWhitman DATE 9/22/2020 9/17/2020 04/15/2020 OFFICE OGC -NLO* NRR/DORL/LPL4/BC* NRR/DORL/LPL4/PM*
NAME STurk JDixon-Herrity MChawla DATE 10/16/2020 11/02/2020 11/03/2020