ML120180451

Regulatory Audit Plan for License Amendment Request to Implement NFPA 805, Risk-Informed, Performance-Based, Fire Protection Program Pursuant to 10 CFR 50.48(c)

ML120180451
Person / Time
Site:	Callaway
Issue date:	01/19/2012
From:	Thadani M Plant Licensing Branch IV
To:	Heflin A Union Electric Co
Thadani, M C, NRR/DORL/LP4, 415-1476
References
TAC ME7046
Download: ML120180451 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 19, 2012 Mr. Adam C. Heflin Senior Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, MO 65251

SUBJECT:

CALLAWAY PLANT, UNIT 1 - REGULATORY AUDIT PLAN FOR LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION PROGRAM, PURSUANT TO TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PARAGRAPH 50.48(C)

(TAC NO. ME7046)

Dear Mr. Heflin:

By application dated August 29, 2011, as supplemented by letter dated November 9, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML112420020 and ML113140044, respectively), Union Electric Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff's approval of a license amendment request (LAR) to adopt National Fire Protection Association (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, at Callaway Plant, Unit 1 (Callaway).

The NRC staff's review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulation's (NRR's) Office Instruction LlC-1 01, "License Amendment Review Procedures." The NRC staff has determined that a regulatory audit of the Callaway LAR should be conducted in accordance with LlC-111, "Regulatory Audits," for the NRC staff to gain a better understanding of the licensee's calculations, proposed plant modifications, and other areas of the LAR This letter forwards the enclosed NRC staff's audit plan for your information.

The staff of the NRC's Fire Protection Branch and Probabilistic Risk Assessment Licensing Branch, and contractor personnel will conduct the audit. Other NRC staff members will also be present at the audit as observers.

A. Heflin Ifthere are any questions, please contact me at (301) 415-1476, or e-mail mohan.thadani@nrc.gov.

Sincerely, Mohan C. Thadani, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-483

Enclosure:

As stated cc w/encl: Distribution via Listserv

REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 DOCKET NO. 50-483 I. BACKGROUND By application dated August 29, 2011, as supplemented by letter dated November 9, 2011 (References 1 and 2), Union Electric Company (the licensee) requested the U.S. Nuclear Regulatory Commission (NRC) staff's approval of a license amendment request (LAR) for Callaway Plant, Unit 1 (Callaway), to change its fire protection program (FPP) to one based on National Fire Protection Association (NFPA) Standard 80S, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants," 2001 Edition, as incorporated into Section 50.48, "Fire protection," of Title 10 of the Code of Federal Regulations (10 CFR).

The NRC staff's review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulation's (NRR) Office Instruction L1C-101, "License Amendment Review Procedures." The NRC staff has determined that a regulatory audit of the Callaway LAR should be conducted in accordance with L1C-111, "Regulatory Audits," for the staff to gain a better understanding of the licensee's calculations, proposed plant modifications, and other aspects of the LAR.

A regulatory audit is a planned, license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit of the licensee's information is expected to assist the NRC staff in efficiently conducting its review or gain insights on the licensee's processes or procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under 10 CFR Section 50.71, "Making of records, making of reports," and/or 10 CFR 54.37, "Additional records and recordkeeping requirements," that, although not required to be submitted as part of the licensing action, would help the staff better understand the licensee's submitted information.

The objectives of this regulatory audit are to:

• Gain a better understanding of the detailed calculations, analyses, and bases underlying the NFPA 805 LAR and confirm the NRC staff's understanding of the LAR; Enclosure

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• Identify further information that is necessary for the licensee to submit for the NRC staff to reach a licensing or regulatory decision; this will result in requests for additional information (RAls);

• Verify that the licensee's planned process for self-approval of FPP changes will meet the proposed NFPA 805 license condition and quality requirements;

• Establish an understanding of proposed plant modifications necessary to implement NFPA 805; and,

• Verify the implementation of processes or procedures that the licensee committed to as part of NFPA 805 implementation.

II. REGULATORY AUDIT BASIS The basis of this audit is the licensee's LAR (References 1 and 2) and NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" (SRP),

Section 9.5.1.2, "Risk-Informed, Performance-Based (RI/PB) Fire Protection" (Reference 3).

Additional information that will be used to support the audit includes:

• Section 50.48, "Fire protection," of 10 CFR;

• National Fire Protection Agency (NFPA) Standard 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Stations," 2001 Edition (Reference 4);

• NRC Regulatory Guide 1.205, Revision 1, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," December 2009 (Reference 5);

• Nuclear Energy Institute, NEI 04-02, "Guidance for Implementing a Risk Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c),"

Revision 2, April 2008 (Reference 6); and

• Nuclear Energy Institute, NEI 00-01, Guidance for Post-Fire Safe Shutdown Analysis, Revision 2, May 2009 (Reference 7).

III. REGULATORY AUDIT SCOPE OR METHOD The NRC staff will review the licensee's NFPA 805 transition as proposed in the LAR. Key to this effort is the licensee's RIIPB FPP. The staff will review the fundamental FPP elements and minimum design requirements. A sample of fire protection engineering evaluations may be selected for review. In addition, the staff will review, as necessary, the regulatory basis, references, licensing actions, and existing engineering equivalency evaluations, and issues which the licensee has deemed "previously approved."

The scope of the review of nuclear safety performance criteria may include both at-power and non-power operational modes, and may require a sample of procedures and other

-3 documentation. The procedures will be reviewed by fire area and will, as necessary, include multiple spurious operations, the transition from operator manual actions to recovery actions, fire protection engineering evaluations, and NFPA 805 deterministic requirements. The audit may also include alternatives to compliance with NFPA 805 if any are identified.

The NRC staff may review a sample of fire risk assessments and plant change evaluations for one or more fire areas, the evaluation of the additional risk of recovery actions, the licensee's process for self-approving post-transition FPP changes, cumulative risk and combined changes, as well as uncertainty and sensitivity analyses. The review may also include licensee risk informed evaluations to ensure that defense in depth and safety margins have been evaluated and are maintained.

The NRC staff will also review the licensee's assessment of the technical adequacy of the probabilistic risk assessment (PRA) model used for any risk evaluations required to transition to a RIIPB FPP, including resolution of peer review findings and licensee self-assessments. This effort may include auditing a sample of logic models and calculations in the fire PRA model as well as the Internal Events PRA model. The review will include, as necessary, the licensee's processes that have been or will be implemented to maintain the quality of the PRA to support self-approval of risk-informed change evaluation after transition is completed.

The scope may also include the licensee's NFPA 805 monitoring program which is to establish and monitor acceptable levels of availability, reliability, and performance of fire protection systems and features relied upon for NFPA 805 compliance.

The scope will also include, as appropriate, selected plant modifications to confirm they have been appropriately characterized in the LAR. The NRC staff will review the process for controlling compensatory measures to confirm their adequacy while they remain in effect until the modifications are completed.

In addition, the audit will review program documentation, configuration control, and the FPP quality assurance program. The FPP design basis document will be reviewed, as well as other documentation of fire hazards identification and nuclear safety capability assessments. The review will include configuration control of the FPP design basis document, the fire PRA methods and model, and other relevant documentation as necessary. The NRC staff may also review the FPP quality assurance program, and sample fire models and fire model calculations.

Walkdowns may be performed as necessary to confirm features of the licensee's FPP and design elements.

- 4 IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY AUDIT The NRC audit team will require access to licensee personnel knowledgeable regarding the technical aspects of the Callaway LAR. At a minimum, a hard copy and electronic copy of the following documentation should be available to the audit team:

• Calculational models and supporting documentation for PRA models used in support of the LAR, including peer review history and resolution of peer review significant findings;

• Calculational models and supporting documentation for fire models used in support of the LAR;

• Procedures that have been modified or developed to transition to the NFPA 805 licensing basis;

• Procedures that have been modified or developed to maintain the NFPA 805 licensing basis after transition is completed;

• Documentation of changes made to PRA models in support of change analysis;

• Documentation about PRA configuration control and procedures to support self approval of risk-informed plant changes after transition;

• Documentation of plant modifications or operational changes identified, screened, and considered (or planned for) during the licensee's transition to NFPA 805;

• Calculations and evaluations used to transition to NFPA 805 such as plant change evaluations, engineering equivalency evaluations, and recovery action evaluations; and,

• Other documents, which the licensee deems as necessary to support the NRC staff's audit, outlined under audit activities.

V. TEAM ASSIGNMENTS The audit will be conducted by NRC staff from NRR and contractors from the Center for Nuclear Waste and Regulatory Analysis (CNWRA). The NRR Division of Risk Assessment's (DRA's)

Fire Protection Branch (AFPB) and the PRA licensing Branch (APLA) staff, and contractor personnel knowledgeable in PRA, safe shutdown and circuits analysis, and fire protection engineering, will comprise the audit team. NRC staff from other organizations may be assigned to the team as appropriate and others may participate as observers. Observers at the audit may include NRR program managers and various regional inspectors.

- 5 The NRC team lead for this audit will be Harold T. Barrett, NRRlDRAlAFPB. The tables below show (1) audit milestones and schedule, and (2) planned audit team composition and their assigned areas for review during the audit.

Audit Milestones and Schedule Relative to First Audit Day Onsite (1/23/12)

Activity Time Frame Comments Onsite Audit Kick-off 01/23/12 Request Licensee provides an NFPA 805 LAR Meeting overview presentation with important site specific information.

Onsite Escorted Tour 01/24/12 Tour of risk-significant power-block areas.

End of Day Summary 01/23 26/12 Meet with licensee to provide a summary of any Meeting significant findings and requests for additional assistance.

Provide Break-out Areas 01/23 26/12 Facilitate discussion between site and staff technical areas.

Onsite Audit Exit Meeting 01/27/12 Reviewers at licensee location for five days.

Audit Summary (see VIII) 02/27/12 To document the audit Regulatory Audit Team and Assignments SRP 9.5.1.2

• Section Audit Plan Review Areas Lead Support 111.1.2 Modifications Team Team 111.1.3 Licensee self-approval Harold Barrett Jay Robinson 111.2 Fundamental FPP and design elements Alayna Pearson Dennis Andrukat 111.3.1.2 Multiple spurious operation Thinh Dinh Harold Barrett 111.3.2 Fire area compliance Team Team 111.3.2 Engineering evaluations, existing engineering Team Team equivalency evaluations (EEEEs). previous approval 111.3.2.2 Operations guidance for fire modeling PB Dennis Andrukat Jason Huczek method 111.3.2.2 Recovery actions Team Team 111.3.3 Non-power operation Thinh Dinh Harold Barrett 111.5.3-5.6 Risk assessments Ray Gallucci 1Andy Howe I 111.5.1 PRA technical adequacy Ray Gallucci 1Andy Howe 111.5.2 Defense in depth and safety margins Team Team 111.6 Monitoring program Jay Robinson Pat Mackin 111.7.1-7.3 Documentation, configuration control, quality Jay Robinson Pat Mackin Plant walk-downs As needed As needed

-6 VI. LOGISTICS This regulatory audit is planned to take place during the week of January 23, 2012, and last approximately 5 days. This date is subject to change based on mutual agreement between the licensee and the NRC. An entrance meeting for this audit will be held on the first day at 9:45 a.m. CST., and an exit meeting will be held the final audit day at 8:30 a.m. to provide preliminary feedback to the licensee. The NRC audit leader should provide a daily progress update to licensee personnel on the second, third, and fourth day of the audit.

The audit will take place at the Callaway Learning Center near Fulton, Missouri, or other location agreed upon by the licensee and NRC audit leader where (1)the necessary reference material and (2) appropriate analysts will be available to support the review. Because the audit scope includes NRC staff walkdowns of selected fire areas, the regulatory audit must be conducted in a location that supports escorted access to the plant protected area.

VII. SPECIAL REQUESTS The regulatory audit team will require the following to support the regulatory audit:

• Escorted access to fire areas within the protected area.

• Two or more computers with internet access, and printing capability.

• Private conference room(s) to support document review, and audit team meetings.

• Access to the fire protection program documentation, including the Fire Hazards Analysis, Safe Shutdown Analysis, and the fire and internal events PRA.

• Access to licensee personnel knowledgeable in the fire protection program, and fire modeling, safe shutdown and circuit analysis, fire and internal events PRA, non-power operations, radiological release analysis, and the NFPA 805 fire protection design-basis document.

VIII. DELIVERABLES A regulatory audit summary will be issued within approximately 30 days of the completion of the audit. The summary will use the guidance of NRR Office Instruction LlC-111 for content. Since this audit will likely result in formal RAls to the licensee regarding the LAR, the summary itself is expected to be an internal memorandum from the audit team leader to the responsible supervisor. The audit summary will be placed in the Agencywide Documents Access and Management System (ADAMS).

-7 IX. REFERENCES

1. Maglio, S., Ameren Missouri, letter to U.S. Nuclear Regulatory Commission, "Request for License Amendment to Adopt NFPA 80S, 'Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)' (License Amendment Request LDCN 11-0012)," dated August 29,2011 (ADAMS Accession No. ML112420022).

2. Maglio, S., Ameren Missouri, to U.S. Nuclear Regulatory Commission, "Clarification of Information Contained in Request for License Amendment to Adopt NFPA 80S,

'Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)' (LDCN 11-0012)," dated November 9,2011 (ADAMS Accession No. ML113140044).

3. U.S. Nuclear Regulatory Commission, NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 9.S.1.2, "Risk-Informed, Performance-Based Fire Protection Program" (ADAMS Accession No. ML092S90S27).

4. National Fire Protection Association (NFPA), Standard 80S, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Stations,"

2001 Edition (ADAMS Accession No. ML010800360).

S. U.S. Nuclear Regulatory Commission, Regulatory Guide 1.20S, Revision 1, "Risk Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," December 2009 (ADAMS Accession No. ML092730314).

6. Nuclear Energy Institute, NEI 04-02, "Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR S0.48(c)," Revision 2, April 2008 (ADAMS Accession No. ML081130188).

7. Nuclear Energy Institute, NEI 00-01, Guidance for Post-Fire Safe Shutdown Analysis, Revision 2, May 2009 (ADAMS Accession No. ML09177026S).

ML120180451 *memo dated **via e-mail NRR/LPL4/LA NRRlDRAlAPLAlBC NRR/DRAlAFPB/BC NRRlLPL4/BC NRRlLPL4/PM MMarkley JBurkhardt** DHarrison* AKlein* (JRHall for) MThadani

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