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| | issue date = 11/09/2011 | | | issue date = 11/09/2011 |
| | title = Clarification of Information Contained in Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (LDCN 11-0012) | | | title = Clarification of Information Contained in Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (LDCN 11-0012) |
| | author name = Maglio S A | | | author name = Maglio S |
| | author affiliation = Ameren Missouri, Union Electric Co | | | author affiliation = Ameren Missouri, Union Electric Co |
| | addressee name = | | | addressee name = |
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MONTHYEARML1124200222011-08-29029 August 2011 Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (License Amendment Request Ldcn 11-0012) Project stage: Request ULNRC-05823, Clarification of Information Contained in Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (LDCN 11-0012)2011-11-0909 November 2011 Clarification of Information Contained in Request for License Amendment to Adopt NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition) (LDCN 11-0012) Project stage: Request ML1132602802011-11-22022 November 2011 Acceptance Review Email, Request for License Amendment to Adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: Acceptance Review ML1132604512011-11-22022 November 2011 Correction Acceptance Review Email, Request for License Amendment to Adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: Acceptance Review ML1201804512012-01-19019 January 2012 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) Project stage: Other ML1206004022012-02-15015 February 2012 Email, Request for Additional Information, Request to Adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML1206004072012-02-15015 February 2012 Email, Request for Additional Information, Request to Adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML1206001862012-03-0202 March 2012 Request for Additional Information, Amendment Request to Adopt National Fire Protection Association (NFPA) Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML12108A2402012-04-17017 April 2012 Enclosure 1 to ULNRC-05851, Request for Additional Information (RAI) with Callaway Plant Response Project stage: Request ULNRC-05851, Response to Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA 8052012-04-17017 April 2012 Response to Request for Additional Information Regarding Adoption of National Fire Protection Association Standard NFPA 805 Project stage: Response to RAI ML12159A0942012-06-0606 June 2012 Email Request for Additional Information Round 2, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: Request ML12159A1032012-06-0606 June 2012 PRA Requests for Additional Information, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML12159A1112012-06-0606 June 2012 Fire Modeling Requests for Additional Information, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML1217104322012-06-19019 June 2012 Email, Request for Additional Information Round 3, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML1217104442012-06-19019 June 2012 Apla, Request for Additional Information Round 3, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML1217104392012-06-19019 June 2012 Afpb, Request for Additional Information Round 3, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ULNRC-05876, Response to Request for Additional Information Re Adoption of National Fire Protection Association Standard NFPA 8052012-07-12012 July 2012 Response to Request for Additional Information Re Adoption of National Fire Protection Association Standard NFPA 805 Project stage: Response to RAI ML12335A2322012-12-11011 December 2012 Request for Additional Information, Round 2, Amendment Request to Adopt National Fire Protection Association Standard 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML13008A3542013-01-0303 January 2013 Email Request for Additional Information,License Amendment Request to Adopt NFPA 805 Project stage: RAI ML13008A3502013-01-0808 January 2013 Email, Request for Additional Information License Amendment Request to Adopt NFPA 805 Project stage: RAI ML13022A0242013-01-22022 January 2013 Email, Two Revised Requests for Additional Information from 12/11/12 Ltr, Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants. Project stage: RAI ULNRC-05952, Regarding Adoption of National Fire Protection Association Standard NFPA 8052013-02-19019 February 2013 Regarding Adoption of National Fire Protection Association Standard NFPA 805 Project stage: Other ML13051A4502013-02-19019 February 2013 Enclosure 1, W/Attachments to ULNRC-05952 - Request for Additional Information (RAI) with Callaway Plant, Response Project stage: Request ML13204A2232013-07-30030 July 2013 Request for Additional Information, License Amendment Request to Adopt National Fire Protection Association Standard NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML13260A5912013-08-16016 August 2013 Request for Additional Information Email, Nrr/Dra/Afpb 18.01, License Amendment Request to Adopt NFPA 805, Performance-Based Standard for Fire Protection for LWR Generating Plants (2001 Edition) Project stage: RAI ML13296A5302013-10-23023 October 2013 NRR E-mail Capture - Callaway - Request for NFPA 805 License Amendment Factual Accuracy Review Project stage: Acceptance Review ML13246A3502013-10-31031 October 2013 NFPA-805 LAR F&O Table Project stage: Other ML13318A1222013-11-14014 November 2013 NRR E-mail Capture - FW: Callaway NFPA 805 LAR, Fpe RAI 20 Project stage: RAI ML13274A5962014-01-13013 January 2014 Issuance of Amendment No. 206, Adopt National Fire Protection Association Standard 805, Performance Based Standard for Fire Protection for LWR Generating Plants Project stage: Approval ML14045A2842014-02-14014 February 2014 Amendment 31 to License Renewal Application Regarding Fire Protection Project stage: Other 2012-07-12
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Category:Letter type:ULNRC
MONTHYEARULNRC-06891, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00052024-06-26026 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0005 ULNRC-06892, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00062024-06-26026 June 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0006 ULNRC-06884, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00022024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0002 ULNRC-06885, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00032024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0003 ULNRC-06886, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00042024-06-12012 June 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0004 ULNRC-06882, Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC00122024-05-16016 May 2024 Independent Spent Fuel Storage Installation Registration of Dry Spent Fuel Storage Canister HGMPC0012 ULNRC-06877, Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 252024-05-0606 May 2024 Final Safety Analysis Report Revision OL-27 and Technical Specification Bases Revision 25 ULNRC-06856, CFR 50.59 and 10 CFR 72.48 Summary Report2024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06869, Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report2024-04-30030 April 2024 Submittal of Callaway, Unit 1, 2023 Annual Radiological Environmental Operating Report ULNRC-06876, Registration of Dry Spent Fuel Storage Canister HGMPC00102024-04-25025 April 2024 Registration of Dry Spent Fuel Storage Canister HGMPC0010 ULNRC-06866, Submittal of Cycle 26 Commitment Change Summary Report2024-04-17017 April 2024 Submittal of Cycle 26 Commitment Change Summary Report ULNRC-06871, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00072024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0007 ULNRC-06872, Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC00082024-04-17017 April 2024 Independent Spent Fuel Storage Installation, Registration of Dry Spent Fuel Storage Canister HGMPC0008 ULNRC-06863, Submittal of Annual Exposure Report for 20232024-03-20020 March 2024 Submittal of Annual Exposure Report for 2023 ULNRC-06852, Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 262024-03-0505 March 2024 Owners Activity Reports (OAR-1 Forms) for Cycle/Refuel 26 ULNRC-06858, Completion of License Renewal Activities Prior to Entering the Period of Extended Operation2024-02-21021 February 2024 Completion of License Renewal Activities Prior to Entering the Period of Extended Operation ULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023 Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01) ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023 Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023 Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak ULNRC-06223, Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004)2023-07-25025 July 2023 Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004) ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023 Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023 Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate . ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023 Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06812, Submittal of 2022 Annual Radiological Environmental Operating Report2023-04-27027 April 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ULNRC-06806, Submittal of Radiological Emergency Response Plan, Revision 552023-04-12012 April 2023 Submittal of Radiological Emergency Response Plan, Revision 55 ULNRC-06807, Submittal of Single Positive Test Forms2023-04-0303 April 2023 Submittal of Single Positive Test Forms ULNRC-06801, CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions2023-03-30030 March 2023 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06798, Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan2023-03-30030 March 2023 Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan ULNRC-06803, Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection2023-03-29029 March 2023 Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control2023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control ULNRC-06804, Submittal of Nuclear Property Insurance Reporting2023-03-29029 March 2023 Submittal of Nuclear Property Insurance Reporting ULNRC-06805, Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days2023-03-21021 March 2023 Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days ULNRC-06802, Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument2023-03-0909 March 2023 Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument ULNRC-06795, Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms2023-01-24024 January 2023 Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms ULNRC-06794, Submittal of Fitness for Duty Program Data for 20222023-01-24024 January 2023 Submittal of Fitness for Duty Program Data for 2022 ULNRC-06787, Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-12-0808 December 2022 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2022-12-0101 December 2022 License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06780, Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0072022-11-30030 November 2022 Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-007 ULNRC-06772, 10 CFR 50.59 and 10 CFR 72.48 Summary Report2022-11-23023 November 2022 10 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06777, Operating Quality Assurance Manual (Oqam) Revision 362022-11-16016 November 2022 Operating Quality Assurance Manual (Oqam) Revision 36 ULNRC-06779, ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves2022-11-14014 November 2022 ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves ULNRC-06765, License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004)2022-11-0303 November 2022 License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004) ULNRC-06773, Results of Steam Generator Tube In-Service Inspection2022-11-0101 November 2022 Results of Steam Generator Tube In-Service Inspection 2024-06-26
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WAmeren MISSOURI November 9, 2011 ULNRC-05823 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Ladies and Gentlemen:
10 CFR 50.90 DOCKET NUMBER 50-483 CALLA WAY PLANT UNIT 1 UNION ELECTRIC CO. Callaway Plant FACILITY OPERATING LICENSE NPF-30 CLARIFICATION OF INFORMATION CONTAINED IN REQUEST FOR LICENSE AMENDMENT TO ADOPT NFPA 805, "PERFORMANCE-BASED STANDARD FOR FIRE PROTECTION FOR LIGHT WATER REACTOR GENERATING PLANTS (2001 EDITION>" (LDCN 11-0012)
Reference:
- 1) Ameren Missouri Letter ULNRC-05781, "Request for License Amendment to Adopt NFPA 805, 'Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)' (License Amendment Request LDCN 11-0012)," dated August 29, 2011 In the referenced letter, Union Electric Company ( dba Ameren Missouri) requested an amendment to Facility Operating License Number NPF-30 for the Callaway Plant pursuant to 10 CFR 50.90. The letter and its attachments were submitted for the purpose of adopting a new fire protection licensing basis based on NFPA 805 and which complies with the requirements in 10 CFR 50.48(a) and (c) and the guidance in Revision 1 ofRegulatory Guide (RG) 1.205, "Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants." Ameren Missouri's request is now under review by the NRC staff. In a teleconference conducted on October 27, 2011, the NRC Staff requested that Ameren Missouri clarify certain information contained in the amendment application.
The attachment to this letter accordingly contains the requested clarifications.
The provided clarifications do not impact the 10 CFR 50.92 evaluation of"No Significant Hazards Consideration" previously provided in the referenced application.
Further, this letter makes no new commitments or changes to any commitments.
PO Box 620 Fulton, MO 65251 AmerenMissouri.com ULNRC-05823 November 9, 2011 Page2 Ifthere are any questions, please contact Scott Maglio at 573-676-8719 or Roger Wink at 314-225-1561.
I declare under penalty of perjury that the foregoing is true and correct. Sincerely, Executed on: --------L l I C1 I toll Regulatory Affairs Manager RCW/nls
Attachment:
Request for Clarifying Information ULNRC-05823 November 9, 20II Page3 cc: Mr. Elmo E. Collins, Jr. Regional Administrator U.S. Nuclear Regulatory Commission Region IV 6I2 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4I25 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 820 I 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 0-8B I Washington, DC 20555-2738 ULNRC-05823 November 9, 2011 Page4 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 Responses and Reports ULNRC Distribution:
A. C. Heflin F. M. Diya C. 0. Reasoner ill L. H. Graessle S.M. Maglio T. B. Elwood R. C. Wink R. Holmes-Bobo NSFU3 Secretary Mr. Paul Parmenter, Director (SEMA) Mr. Thomas Mohr, Senior REP Planner (SEMA) Mr. John Campbell, REP Planner (SEMA) 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) Mr. Dru Buntin (DNR)
Attachment to ULNRC-05823 Page I of4 Request for Clarifying Information
References:
- 1) Ameren Missouri Letter ULNRC-05781, "Request for License Amendment to Adopt NFPA 805, 'Performance-Based Standard for Fire Protection for Light Water Reactor Generating Plants (2001 Edition)' (License Amendment Request LDCN 11-0012)," dated August 29,2011 2) NRC Regulatory Guide 1.174 (Revision 1), "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," dated November 2002 (ADAMS Accession Number ML023240437)
During a teleconference held on October 27, 2011 between NRC staff and Callaway personnel, the Staff requested that information contained in the Transition Report of the above referenced license amendment request (LAR) be clarified to assist the Staff in completing the Callaway Plant NFP A 805 LAR Acceptance Review. Each clarification/information request is identified and addressed below. 1. In attachment U ofEnclosure 1 to ULNRC-05781, Callaway Plant stated that the internal events PRA underwent a gap assessment against the Capability Category II requirements of ASME RA-S-2002, "Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications," with ASME RA-Sa-2003 and ASME RA-Sb-2005 Addenda, ASME, 2005. The Staff requests additional information on the scope of the gap assessment (e.g. a review of resolutions for previous findings, a focused scope review or a full scope review) as well as clarification on which version of the ASME PRA Standard was used to evaluate the PRA during the gap assessment.
Response:
Callaway Plant considers the Internal Events gap assessment conducted in 2006 and referenced in Attachment U of the LAR to meet the criteria of a full scope peer review against the requirements of ASME RA-Sb-2005.
The formal report for the subject gap assessment was titled "Callaway PRA Gap Analysis Report." The assessment was titled in this way due to the generic use of the term 'gap assessment' (as commonly used at the time) to mean an assessment of performance relative to a standard.
It was not intended to reflect the formal definition of a PRA gap assessment as the term is currently used. The assessment that was performed was an independent, full-scope peer review of the entire PRA model using the most current available versions of applicable Standards.
The following excerpts from the final report provide additional detail on the scope of the review as well as the standards applied: " ... AmerenUE [now Ameren Missouri]
has chosen to perform a gap analysis to identify the areas of the PRA which need to be strengthened in order to assure that the Callaway PRA conforms to all the existing standards in sufficient depth to address all currently envisioned applications."
Attachment to ULNRC-05823 Page 2 of4 "This report documents the results of the gap analysis conducted of the complete Callaway PRA model, data and documentation in accordance with the Category II requirements of the ASME Standard for Probabilistic Risk Assessment for Nuclear Power Plant Applications, updated to include Addenda B [ASME RA-Sb-2005], the Category II requirements of ANSI/ANS-58.21-2003, "American National Standard External-Events PRA Methodology," and the expected requirements of the ANS Low Power and Shutdown PRA Standard (draft being written).
The review was conducted by a team of three senior experts with experience in performing NEI PRA Certifications and pre-Certification reviews with support from a sister plant PRA staff member and experts in the areas of shutdown risk analyses and human reliability analyses." The subject matter experts discussed above were contractors and an industry peer brought in to conduct the review, all of whom would have met the current peer review team qualification requirements of section 1-6.2 of the combined PRA standard (ASME/ANS RA-Sa-2009).
- 2. In attachment W ofEnclosure 1 to ULNRC-5781, Callaway Plant stated that total plant risk is not higher than 1E-4 for core damage frequency (CDF) or 1E-5 for large early release frequency (LERF). These values correspond to the baseline risk criteria specified in Regulatory Guide 1.174 (Reference
- 2) for small changes in risk resulting from plant specific changes to the licensing basis. The Staff requests additional detail on this statement in the form of total CDF and LERF values, along with the values for individual significant contributors (e.g. internal events, fire, other external events) to these totals. Response:
Callaway Plant does not have quantified models for seismic or other non-fire external events. Following the guidance provided by the NRC in NUREG-1407, Callaway Plant performed and submitted with the IPEEE a focused-scope seismic margins assessment (SMA) in accordance with EPRI NP-6041-SL.
Callaway Plant has not developed a quantifiable seismic risk model since completion of the original SMA. However, in response to Generic Issue 199, "Generic Issue 199 (GI-199) Implications ofUpdated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants," the NRC developed a Safety/Risk Assessment ofGI-199 1 which quantified seismic risk using Callaway site-specific SMA results and updated seismic hazard curves. A Seismic CDF (SCDF) estimate was developed by integrating the mean seismic hazard curve and the mean plant-level fragility curve. This method, developed by Kennedy (1997), is discussed in Section 10.B.9 of ASME/ANS RA-Sa-2009 and has previously been used by the Staff in the resolution ofGI-194, "Implications ofUpdated Probabilistic Seismic Hazard Estimates," and is the basis for the seismic performance-based approach for determining the site Safe Shutdown Earthquake as described in Regulatory Guide 1.208. 1 Letter from Patrick Hiland to Brian Sheron dated September 2, 2010, "Generic Issue 199 (GI-199) Implications of Updated Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants Safety/Risk Assessment" Attachment to ULNRC-05823 Page 3 of4 SCDF estimates for Callaway Plant in this analysis were produced using two sets of mean seismic hazard curves generated by the following:
(1) NRC, based on U.S. Geological Survey, 2008, and (2) Lawrence Livermore National Laboratory, 1994. The results are provided in Table 1, "Seismic Risk Estimates." Table 1: Seismic Risk Estimates Controlling Simple IPEEE Weakest PGA 10Hz 5Hz 1Hz Max Weighted Link Curve Avg Avg Model Seismic Frequencies 2008 USGS Seismic Hazard Curves 1.8E-6 1.9E-6 6.3E-7 1.5E-7 1.9E-6 10Hz l.lE-6 l.OE-6 2.0E-6 Seismic Core-Damage Frequencies Using 1994 LLNL Seismic Hazard Curves 2.3E-6 1.7E-6 1.8E-6 3.6E-7 2.3E-6 PGA 1.5E-6 1.4E-6 2.3E-6 Based on the results of this analysis as well as the results of the original seismic margins assessment, the contribution from seismic risk is minimal. The highest risk estimate from this analysis in conjunction with the internal events and fire risk estimates exhibit significant margin to the total risk thresholds specified in Regulatory Guide 1.174, as shown in Table 2, "Total Risk and Contributors." (See next page.) Risk-informed technical assessments may generally be conducted using CDF, LERF, public dose (person-rem), or a combination of these risk metrics. The selection of the appropriate risk metric(s) to assess an issue depends on the specific nature of the issue being assessed.
Seismic risk assessments involve the implications of probabilistic seismic hazard estimates that describe the distribution (frequency and size) of seismically induced site vibratory ground motions. Although each of the three risk metrics (CDF, LERF, and public dose) depends on the seismic hazard, SCDF is expected to be the most sensitive to changes in the seismic hazard. Thus, the seismic Safety/Risk Assessment did not generate seismic LERF estimates.
Seismic LERF risk is expected to be essentially proportional to the SCDF which would result in only a small contribution to LERF. Given the margin between the LERF estimates and the risk thresholds, LERF contributions from seismic risk are considered negligible.
The IPEEE review concluded that the Callaway Plant design conforms to the screening criteria (1975 Standard Review Plan) and that no potential vulnerabilities from high winds and other external events exist that have not been included in the original design analysis.
Therefore, these hazards were screened and the quantitative risk is considered to be negligible.
Attachment to ULNRC-05823 Page 4 of4 Table 2: Total Risk and Contributors CDF Internal Events Fire Seismic 2 Other External Events 2.61E-5 /yr 2.03E-5 /yr 2.30E-6 /yr Negligible Total CDF 4.87E-5 /yr LERF Internal Events Fire Seismic and Other External Events Total LERF 4.20E-7 /yr 3.99E-7 /yr negligible 8.19E-7 /yr 3. It appears that based on the description provided in section 4.6 of the Transition Report (Enclosure 1 of the LAR), the Callaway Plant Monitoring Program may be separate and independent from the Maintenance Rule program. If this is so, more detailed information is needed to explain how monitoring will be accomplished for Nuclear Safety systems, structures and components.
Response:
Callaway Plant's NFPA 805 Monitoring Program will not be separate and independent from the Callaway Plant Maintenance Rule Program and will be developed in accordance with the final approved revision ofNRC FAQ 10-0059. 2 Seismic Core-Damage Frequencies Using 1994 LLNL Seismic Hazard Curves-Weakest Link Model