ULNRC-06073, Answer and Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Callaway Plant Independent Spent Fuel Storage Installation

Answer and Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Callaway Plant Independent Spent Fuel Storage Installation

ML14016A135
Person / Time
Site:	Callaway
Issue date:	01/16/2014
From:	Abel S Ameren Missouri
To:	Document Control Desk, NRC/NMSS/SFST, Office of Nuclear Reactor Regulation
References
EA-13-237, ULNRC-06073
Download: ML14016A135 (5)

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--wAmeren Callaway Plant MISSOURI January 16, 2014 ULNRC-06073 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 10 CFR 72 Order No. EA 13-237 Ladies and Gentlemen:

DOCKET NUMBER 50-483 AND 72-1045 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 ANSWER AND RESPONSE TO THE ORDER FOR IMPLEMENTATION OF ADDITIONAL SECURITY MEASURES AND FINGERPRINTING FOR UNESCORTED ACCESS FOR CALLAWAY PLANT INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Reference:

Letter from NRC (Keith McConnell, Acting Director, Office of Nuclear Material Safety and Safeguards) to Ameren Missouri (Mr. Fadi Diya, Vice President-Nuclear Operations) dated December 30, 2013, "Issuance of Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Callaway Plant Independent Spent Fuel Storage Installation (EA-13-23 7)", ADAMS Accession No.: ML13357A495 As directed by EA-13-237, Union Electric Company, d/b/a Ameren Missouri, hereby submits information in response to the Order for Implementation of Additional Security Measures (ASM) and Fingerprinting for Unescorted Access for Callaway Plant Independent Spent Fuel Storage Installation (ISFSI) (hereinafter "Order").

Ameren Missouri consents to the Order as more fully set forth below, and specifically does not request a hearing on this Order. Upon implementation, Ameren Missouri will be able to comply with the requirements described in Enclosure 1, Attachments 1 and 2 of the Order and implementation of the requirements will not cause Ameren Missouri to be in violation of the provisions of any Commission PO Box 620 Fulton, MD 65251 AmerenMissouri.com

ULNRC-06073 January 16, 2014 Page 2 regulation or the facility license. Implementation of the requirements described in Enclosure 1, Attachments 1 and 2 of the Order will not adversely impact the safe storage of spent fuel. The first movement of spent fuel to the Callaway Plant ISFSI is currently scheduled to begin in April, 2015.

Ameren Missouri recognizes that the Order requires Callaway Plant to demonstrate compliance with certain security measures relative to Callaway Plant's ISFSI no later than 365 days from December 30, 2013 (or December 30, 2014), or 90 days before the first day fuel is initially placed in the ISFSI, whichever is first. However, Ameren Missouri is planning to use the Holtec HI-STORM UMAX MPC Storage System at Callaway Plant which is currently under review by the NRC and the review is expected to enter the rulemaking process on or about January 31, 2014. (Please reference USNRC Docket No. 72-1040, T AC No. 24626.) Due to the uncertainty of the timing of the rulemaking process, construction of the Callaway Plant ISFSI may not be to the stage that Ameren Missouri can demonstrate compliance with the ASM by December 30, 2014. Ameren Missouri does agree, however, to demonstrate compliance with the requirements in Attachments 1 and 2 to the Order no later than 90 days before the first day that spent fuel is initially placed in the ISFSI.

As provided for in Enclosure 1, Attachment 2 of the Order, Ameren Missouri has chosen to comply with the NRC approved reactor access authorization program currently in place at Callaway Plant as an alternative means to satisfy the provisions of sections B through G of Enclosure 1, Attachment 2.

Ameren Missouri will provide periodic updates of the ISFSI project status and will report to the Commission when it has achieved full compliance with the requirements described in Enclosure 1, Attachments 1 and 2 of the Order. Ameren Missouri will achieve full compliance with the Order no later than 90 days before the first day that spent fuel is initially placed in the ISFSI.

This communication contains one new commitment, which is described in Enclosure 1 to this letter.

If you have any questions with regard to this response, please contact me at or Mr. Scott Maglio at (573) 676-8719.

I declare under penalty of perjury that the foregoing is true and correct.

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Shannon Abel Director, Engineering Projects DS/nls

Enclosures:

1) List of Commitments

ULNRC-06073 January 16, 2014 Page 3 cc: U.S. Nuclear Regulatory Commission (Original)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Marc L. Dapas Regional Administrator U.S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Raynard Wharton Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 3 WFN, Mail Stop 14 C28 Washington, DC 20555-0001 Mr. Fred Lyon Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1 Washington, DC 20555-2738

ULNRC-06073 January 16, 2014 Page4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 4150 International Plaza Suite 820 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. 0. Reasoner III L. H. Graessle S. A. Maglio Corporate Communications NSRB Secretary S. L. Abel T. W. Pettus S. E. Ewens R. J. Lutz E. M. Ptasznik M.S. Corbin A.M. Lee T. B. Elwood S. E. Huber STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission Ms. Leanne Tippett Mosby (DNR)

ULNRC-06073 January 16, 2014 LIST OF COMMITMENTS The following table identifies those actions committed to by Ameren Missouri in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding this commitment to Mr. Scott Maglio at (573) 676-8719.

COMMITMENT Due Date/Event COMN Achieve full compliance with the provisions of No later than 90 days 50391 , Attachments 1 and 2 of the NRC before the first day that issued "Order for Implementation of Additional spent fuel is initially Security Measures and Fingerprinting for placed in the ISFSI.

Unescorted Access for Callaway Plant Independent Spent Fuel Storage Installation" (EA-13-237, dated. December 30, 2013).