ULNRC-05797, Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request

Request for Extension of Enforcement Discretion and Commitment to Submittal Date for 10 CFR 50.48(c) License Amendment Request

ML111791614
Person / Time
Site:	Callaway
Issue date:	06/28/2011
From:	Maglio S Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME0060, ULNRC-05797
Download: ML111791614 (5)

Text

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WAmeren Callaway Plant MISSOURI June 28, 2011 ULNRC-05797 u.s. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.48(c)

Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 REQUEST FOR EXTENSION OF ENFORCEMENT DISCRETION AND COMMITMENT TO SUBMITTAL DATE FOR 10 CFR 50.48(c) LICENSE AMENDMENT REQUEST

References:

1) SECY-II-0061, "A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48)," dated April 29, 2011

2) Staff Requirements Memorandum (SRM) SECY-11-0061, "A Request to Revise the Interim Enforcement Policy for Fire Protection Issues on 10 CFR 50.48(c) to Allow Licensees to Submit License Amendment Requests in a Staggered Approach (RIN 3150-AG48),"

dated June 10, 2011

3) ULNRC-05541 Letter from Callaway Plant to Document Control Desk (NRC), "Request for Extension of Enforcement Discretion,"

dated September 29,2008

4) Letter from NRC to Union Electric Company, "Callaway Plant Unit 1

- Evaluation of the Request for an Extension of Enforcement Discretion in Accordance with the Interim Enforcement Policy for Fire Protection Issues during Transition to National Fire Protection Standard NFPA 805 (TAC No. ME0060)," dated December 8,2008 PO Box 620 Fulton, MO 65251 AmerenMissouri.com

ULNRC-05797 June 28, 2011 Page 2 In accordance with Reference 1, and as approved by the Commission per Reference 2, Union Electric Company (dba Ameren Missouri) commits to submitting the License Amendment Request (LAR) for implementing 10 CFR 50.48(c) at Callaway Plant, Unit 1 no later than September 2, 2011.

In accordance with Reference 3 the current enforcement discretion period for submitting an NFP A 805 LAR expires 6 months after the date of the NRC's safety evaluation approving the second pilot plant LAR, which is on June 29,2011. Ameren Missouri has made substantial progress in development of the Callaway Plant LAR for adopting the provisions of 10 CFR 50.48(c). The enforcement discretion extension to September 2, 2011 would provide Ameren Missouri the additional time necessary to finalize the site acceptance review of associated vendor documents/calculations prepared in support of the transition to NFPA 805. The license amendment request is currently undergoing site review and Onsite Review Committee approval. Any comments generated during the site review and approval process will require disposition prior to submittal of the LAR.

The following modifications have recently been completed which have substantially improved the risk metrics associated with the operation of the Callaway Plant. Incorporation of the design features of these modifications in the Fire Probabilistic Risk Assessment models required substantial rework that contributed to the need for this request for enforcement discretion extension.

• Completed installation ofa non-safety related Auxiliary Feedwater Pump that is electrically powered by the new offsite alternate emergency supply discussed below. This non-safety related Auxiliary F eedwater Pump is a diverse backup to the safety related Motor Driven and Turbine Driven Auxiliary F eedwater Pumps.

• Completed installation of 4 non-safety related diesel generators (8 MW total) at a nearby electric cooperative substation. These generators are capable of supplying power to either safety related bus and the non-safety related Auxiliary F eedwater Pump under Station Blackout conditions.

Ameren Missouri requests that the enforcement discretion be extended to correspond to the LAR submittal commitment date. Per the enforcement discretion policy, once the LAR is submitted, the enforcement discretion would then continue until the NRC dispositions the LAR and the license amendment is implemented for transition to NFPA 805, consistent with Reference 1.

This request for enforcement discretion extension is a change to the schedule submitted in Reference 3 with approval granted in Reference 4. This letter contains one new commitment (as identified on page 5).

If there are any questions, please contact Scott Maglio at 573-823-4970 or Roger Wink at 314-225-1561.

Sincerely,

~t{A.~

Scott A. Maglio Regulatory Affairs Manager RCW/nls

ULNRC-05797 June 28, 2011 Page 3 cc: U.S. Nuclear Regulatory Commission (Original and 1 copy)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Elmo E. Collins, Jr.

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Mr. RoyP. Zimmerman Director, Office of Enforcement U.S. Nuclear Regulatory Commission Mail Stop 4-A15A Washington, DC 20555-2738 Senior Resident Inspector Callaway Resident Office U. S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Mohan C. Thadani (2 copies)

Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8G 14 Washington, DC 20555-2738 Mr. James Polickoski Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1A Washington, DC 20555-2738

ULNRC-05797 June 28, 2011 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed. )

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

A. C. Heflin F. M. Diya C. O. Reasoner ITI L. H. Graessle S. A. Maglio S. L. Gallagher NSRB Secretary T. B. Elwood Ms. Diane M. Hooper (WCNOC)

Mr. Tim Hope (Luminant Power)

Mr. Ron Barnes (APS)

Mr. Tom Baldwin (pG&E)

Mr. Wayne Harrison (STPNOC)

Ms. Linda Conklin (SCE)

Mr. John O'Neill (pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Mr. Dru Buntin (DNR)

ULNRC-05797 June 28, 2011 Page 5 LIST OF COMMITMENTS The following table identifies those actions committed to by Arneren Missouri in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Thomas B. Elwood at 314-225-1905:

COMMITMENT Due DatelEvent COMN The LAR associated with the transition to NFPA 805 will be September 2,2011 50142 submitted.