ML13269A138

Enclosure 2 to ULNRC-06031 - License Condition Changes

ML13269A138
Person / Time
Site:	Callaway
Issue date:	09/24/2013
From:	Ameren Missouri
To:	Office of Nuclear Reactor Regulation
Shared Package
ML13269A147	List: ML13269A137 ML13269A138 ULNRC-06031, Union Electric Co. Facility Operating License NPF-30 Responses to RAI Set 4 Regarding Adoption of National Fire Protection Association Standard NFPA 805
References
ULNRC-06031
Download: ML13269A138 (38)

Text

Enclosure 2 to ULNRC-06031 Page 53 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report M. License Condition Changes 18 Pages Attached August 2011 Page M-1

to ULNRC-06031 Page 54 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Replace the current Callaway Plant Unit 1 fire protection operating license (OL) condition 2.C(5) with the standard operating license condition in Regulatory Position C.3.1 of Regulatory Guide 1.205, "Risk-Informed, Performance-Based Fire Protection for Light-Water Nuclear Power Plants," Revision 1, as modified by FAQ 06-0008 Revision 9 (ML073380976), as described below.

It is Ameren Missouri's understanding that implicit in the superseding of these license conditions, prior fire protection SERs and commitments have been superseded in their entirety by the revised license condition. However, Revision 056 to the Callaway Plant Unit 1 Operating License dated June 26, 2007, added OL condition C.15 "Mitigation Strategy License Condition" in response to Section 8.5.b of the February 25, 2002, "Interim Compensatory Measures Order" (EA-02-026) (TAC No.4518). This order requires that strategies for addressing large fires and explosions be maintained for key areas. This OL condition will remain in effect.

No other license conditions need to be superseded or revised. Ameren Missouri implemented the following process for determining that OL condition 2.C(5) is the only license condition required to be superseded to implement the new fire protection program which meets the requirements of 10 CFR 50.48(a) and 50.48(c):

A review of the Callaway Plant OL NPF 30, Revision 056 (which incorporated OL Condition C.15) and the current Revision 068 was performed by the Callaway Plant licensing staff and the NFPA 805 Transition Team. The review was performed by reviewing the OL and performing electronic searches using the Callaway Plant Licensing Research System (LRS). The Callaway Plant LRS contains Callaway Plant licensing documents, correspondence, and regulatory and guidance materials, including those documents pertaining to the operating license, the Technical Specifications, the fire protection program, the FSAR and subsequent revisions, correspondence sent to the NRC, and correspondence received from the NRC. The correspondence sent to the NRC includes any outstanding license amendment request submittals.

August 2011 Page M-2

to ULNRC-06031 Page 55 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Supersede the following license condition 2.C(5):

(5) Fire Protection (Section 9.5.1. 7 SER and Section 9.5.1.8, SSER #3)

(a) Deleted per Amendment No. 169.

(b) Deleted per Amendment No. 169.

(c) The licensee shall implement and maintain in effect all provisions of the approved fire protection program as described in the SNUPPS Final Safety Analysis Report for the facility through Revision 15, the Callaway site addendum through Revision 8, and as approved in the SER through Supplement 4, subject to provision d below.

(d) The licensee may make changes to the approved fire protection program without prior approval of the Commission only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(e) Deleted (see Amendment No. 30, January 13, 1988).

New License Condition:

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 license amendment request dated 8/29/2011 (and supplements dated 11/9/2011, 4/17/2012, 7/12/2012, 2/19/2013, 8/5/2013 and 9/24/2013) and as approved in the safety evaluation report dated MM/DDNYYY (and supplements dated MM/DDNYYY). 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 1 x 1o-7/year (yr) for CDF and less than 1 x 1o- 8/yr for 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.

August 2011 Page M-3

to ULNRC-06031 Page 56 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard." Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard. The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.1 0); and

• "Passive Fire Protection Features" (Section 3.11 ).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MM/DDNYYY to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk- I informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the items listed in Enclosure 2, Attachment S, Table S-3, "Implementation Items," of Ameren Missouri letter ULNRC-06031, dated September 24, 2013, by June 30, 2014.

August 2011 Page M-4

to ULNRC-06031 Page 57 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Operating License Markup 4 Pages Attached August 2011 Page M-5

to ULNRC-06031 Page 58 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report LDCN 11-0012 OPERATING LICENSE MARKUP License Condition 2.C.5 August 2011 Page M-6

to ULNRC-06031 Page 59 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Operating License Revision 068 (4) Surveillance of Hafnium Control Rods (Section 4.2.3.1 (1 0) SER and SSER #2)

Deleted per Amendment No. 169 Deleted per Amendment No. 169.

(7) NUREG-0737 Conditions (Section 22. SER)

Deleted per Amendment No. 169.

(8) Post-Fuel-Loading Initial Test Program (Section 14. SER)

Deleted per Amendment No. 169.

(9) lnservice Inspection Program (Sections 5.2.4 and 6.6. SER)

Deleted per Amendment No. 169.

(1 0) Emergency Planning Deleted per Amendment No. 169.

Amendment~

A140.0001 August 2011 Page M-7

to ULNRC-06031 Page 60 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report LDCN 11-0012 OLINSERT (5) Fire Protection 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 license amendment request dated 8/29/2011 (and supplements dated 11/9/2011, 4117/2012, 7/12/2012, 2/19/2013, 8/5/2013 and 9/24/2013) and as approved in the safety evaluation report dated MM/DDNYYY (and supplements dated MM/DD/YYYY). 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 ifthose 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 CDF and less than 1x10-8/yr for 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.

Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified August 2011 Page M-8

to ULNRC-06031 Page 61 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report LDCN 11-0012 OL INSERT (page 2) fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard."

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure, or physical arrangement, using a relevant technical requirement or standard. The four specific sections ofNFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3 .8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.1 0); and

• "Passive Fire Protection Features" (Section 3.11).

This License Condition does not apply to any demonstration of equivalency under Section 1. 7 of NFPA 805.

(2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MM/DD/YYYY to determine that certain fire protection program changes meet the minimal criterion. The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the items listed in Enclosure 2, AttachmentS, Table S-3, "Implementation Items," of Ameren Missouri letter ULNRC-06031, dated September 24, 2013, by June 30, 2014.

August 2011 Page M-9

to ULNRC-06031 Page 62 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Operating License Retype 9 Pages Attached August 2011 Page M-10

to ULNRC-06031 Page 63 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report (4) Surveillance of Hafnium Control Rods (Section 4.2.3.1 (1 0), SER and SSER #2)

Deleted per Amendment No. 169 (5) Fire Protection 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 license amendment request dated 8/29/2011 (and supplements dated 11/9/2011,4/17/2012,7/12/2012,2/19/2013,8/5/2013 and 9/24/2013) and as approved in the safety evaluation report dated MM/DD/YYYY (and supplements dated MM/DD/YYYY). 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.

Amendment###

August 2011 Page M-11

to ULNRC-06031 Page 64 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report (b) Prior NRC review and approval is not required for individual changes that result in a risk increase less than 1x1 o* 7/year (yr) for CDF and less than 1x1 o*8/yr for LEAF. 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.

• Other Changes that May Be Made Without Prior NRC Approval (1) Changes to NFPA 805, Chapter 3, Fundamental Fire Protection Program and Design Elements Prior NRC review and approval are not required for changes to the NFPA 805, Chapter 3, fundamental fire protection program elements and design requirements for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is functionally equivalent or adequate for the hazard. The licensee may use an engineering evaluation to demonstrate that a change to an NFPA 805, Chapter 3, element is functionally equivalent to the corresponding technical requirement. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard.

The licensee may use an engineering evaluation to demonstrate that changes to certain NFPA 805, Chapter 3, elements are acceptable because the alternative is "adequate for the hazard."

Prior NRC review and approval would not be required for alternatives to four specific sections of NFPA 805, Chapter 3, for which an engineering evaluation demonstrates that the alternative to the Chapter 3 element is adequate for the hazard. A qualified fire protection engineer shall perform the engineering evaluation and conclude that the change has not affected the functionality of the component, system, procedure or physical arrangement, using a relevant technical requirement or standard.

The four specific sections of NFPA 805, Chapter 3, are as follows:

• "Fire Alarm and Detection Systems" (Section 3.8);

• "Automatic and Manual Water-Based Fire Suppression Systems" (Section 3.9);

• "Gaseous Fire Suppression Systems" (Section 3.1 0); and

• "Passive Fire Protection Features" (Section 3.11 ).

This License Condition does not apply to any demonstration of equivalency under Section 1.7 of NFPA 805.

Amendment###

August 2011 Page M-12

to ULNRC-06031 Page 65 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report (2) Fire Protection Program Changes that Have No More than Minimal Risk Impact Prior NRC review and approval are not required for changes to the licensee's fire protection program that have been demonstrated to have no more than a minimal risk impact. The licensee may use its screening process as approved in the NRC safety evaluation report dated MM/DD/YYYY to determine that certain fire protection program changes meet the minimal criterion.

The licensee shall ensure that fire protection defense-in-depth and safety margins are maintained when changes are made to the fire protection program.

Transition License Conditions (1) Before achieving full compliance with 10 CFR 50.48(c), as specified by (2) below, risk-informed changes to the licensee's fire protection program may not be made without prior NRC review and approval unless the change has been demonstrated to have no more than a minimal risk impact, as described in (2) above.

(2) The licensee shall implement the items listed in Enclosure 1, AttachmentS, Table S-3, "Implementation Items," of Ameren Missouri letter ULNRC-06031, dated 9/24/2013, by June 30, 2014.

(6) Qualification of Personnel (Section 13.1.2, SSER #3, Section 18, SSER #1)

Deleted per Amendment No. 169.

(7) NUREG-0737 Conditions (Section 22. SER)

Deleted per Amendment No. 169.

(8) Post-Fuel-Loading Initial Test Program (Section 14, SER)

Deleted per Amendment No. 169.

(9) lnservice Inspection Program (Sections 5.2.4 and 6.6, SER)

Deleted per Amendment No. 169.

(1 0) Emergency Planning Deleted per Amendment No. 169.

Amendment###

August 2011 Page M-13

to ULNRC-06031 Page 66 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report (11) Steam Generator Tube Rupture (Section 15.4.4, SSER #3)

Deleted per Amendment No. 169.

(12) Low Temperature Overpressure Protection (Section 15, SSER #3)

Deleted per Amendment No. 169.

(13) LOCA Reanalysis (Section 15. SSER #3)

Deleted per Amendment No. 169.

(14) Generic Letter 83-28 Deleted per Amendment No. 169.

(15) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available, pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Amendment###

August 2011 Page M-14

to ULNRC-06031 Page 67 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report (16) Additional Conditions The Additional Conditions contained in Appendix C, as revised through Amendment No. 190, are hereby incorporated into this license. UE shall operate the facility in accordance with the Additional Conditions.

D. An Exemption from certain requirements of Appendix J to 10 CFR Part 50, are described in the October 9, 1984 staff letter. This exemption is authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. Therefore, this exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. UE shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The combined set of plans, which contain Safeguards Information protected under 10 CFR 10 CFR 73.21, are entitled: "Callaway Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 0" submitted by letter dated October 20, 2004, as supplemented by the letter May 11, 2006.

UE shall fully implement and maintain in effect all provisions of the Commission - approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Callaway Plant Unit 1 CSP was approved by License Amendment No. 203.

F. Deleted per Amendment No. 169.

G. UE shall have and maintain financial protection of such type and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

Amendment###

August 2011 Page M-15

to ULNRC-06031 Page 68 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report H. This license is effective as of the date of issuance and shall expire at Midnight on October 18, 2024.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED BY H. R.

DENTON Harold R. Denton, Director Office of Nuclear Reactor Regulation Amendment###

August 2011 Page M-16

to ULNRC-06031 Page 69 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachments/Appendices:

1. Attachment 1 (Deleted per Amendment No. 169)

2. Attachment 2 (Deleted per Amendment No. 169)

3. Appendix A- Technical Specifications (NUREG-1 058, Revision 1)

4. Appendix B - Environmental Protection Plan

5. Appendix C- Additional Conditions Date of Issuance: October 18, 1984 Amendment###

August 2011 Page M-17

to ULNRC-06031 Page 70 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report ATTACHMENT 1 Deleted per Amendment No. 169.

Amendment###

August 2011 Page M-18

to ULNRC-06031 Page 71 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report ATTACHMENT 2 Deleted per Amendment No. 169.

Amendment###

August 2011 Page M-19

Enclosure 2 to ULNRC-0603 I Page 72 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Tables S-1 and S-2, Plant Modifications Completed and Committed, respectively. Each of these tables provided below includes a description of the modifications along with the following information:

• A problem statement,

• Risk ranking of the modification based on estimated impact on the Fire PRA results (see legend),

• An indication if the modification is currently included in the FPRA,

• Compensatory Measure in place, and

• A risk-informed characterization of the modification and compensatory measure.

• The following legend should be used when reviewing the tables:

- High= Modification would have an appreciable impact on reducing overall fire CDF.

- Medium= Modification would have a measurable impact on reducing overall fire CDF.

- Low= Modification would have either an insignificant or no impact on reducing overall fire CDF.

August 2011 Page S-2

Enclosure 2 to ULNRC-06031 Page 73 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Completed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 05-3029* Install lower amperage fuses to Install lower amperage fuses N No This modification ensures there prevent damage to 14 AWG for various 14 AWG control are no secondary fires.

cables and prevent secondary circuits in the MCR. The NUREG/CR-6850 methodology fires from occurring in the MCR. majority of the modification does not address secondary fires, centers around the trip circuit but the issue of secondary fires fuses on NB, NB, PA, PB, and was raised during the pilot plant PG system breakers RAI process. Secondary fires are not modeled in the Callaway Fire PRA and an assessment of risk was not performed.

Compensatory measure for NFPA 805: In accordance with station procedures, appropriate compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in effect until this modification is complete.

Compensatory measure for Current Fire Protection Licensing Basis: None; the MCR is deterministically compliant with the Current Fire Protection Licensing Basis.

07-0066 M Buried carbon steel ESW system The buried carbon steel ESW y No Cables affect ESW cooling from piping needed replacement. As piping was replaced with high the UHS cooling towers, part of this piping modification, density polyethylene (HOPE) potentially failing both trains, but relocate cables currently in piping. During the piping could be mitigated by a recovery nonconformance with 20 foot replacement the cabling action (and the recovery action is separation criteria. associated with EFTE0067A no longer needed). This is judged and 68A was relocated to to have a medium impact on risk.

restore the required 20 foot separation criteria. Compensatory measure: None; modification complete August 2011 Page S-3

Enclosure 2 to ULNRC-06031 Page 74 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Completed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 07-0151

• L During a fire in the main control Install redundant fuses and y y PRA assumes that after a fire in room (MCR), selected cables to B isolation switches for MCR the main control room, the B train FPIP 14050 train related equipment fed from evacuation procedure OTO-ZZ- components are operable from NB02 will be isolated to prevent a 00001. the auxiliary shutdown panel multi-spurious hot short from without requiring replacement of stopping or starting safety fuses.

equipment. Circuits that have Compensatory measure for NFPA isolation switches but lack 805: In accordance with station redundant fuses are included in procedures, appropriate this modification. This compensatory measures will be modification will eliminate credit established when the NFPA 805 previously taken to have fire protection program becomes operators replace potentially effective and remain in effect until blown fuses prior to the NFPA this modification is complete.

805 transition.

Compensatory measure for Current Fire Protection Licensing Basis: None; the MCR is deterministically compliant with the Current Fire Protection Licensing Basis.

August 2011 Page S-4

Enclosure 2 to ULNRC-06031 Page 75 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Completed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 09-0025* M A fire in fire areas A-1, A-2, A-4, y y To protect against multiple This is judged to be a moderate A-8, A-16 (analysis area A-16S), spurious scenarios, the solution risk improvement. In A-1, A-2, A-FPIP 14050 A-27, C-18, C-21, C-22, C-23, C- is to run a single wire in a 4, A-8, A-16 (analysis area A-24, C-30, C-33, and RB-1 protected metal jacket such that 16S), A-27, C-18, C-21, C-22, C-(analysis areas RB1, RB2, RB3, spurious valve opening due to a 23, C-24, C-30, C-33, and RB-1 and RB4) could cause hot short affecting the valve (analysis areas RB1, RB2, RB3, EJHV8811A and/or B to control circuit is eliminated for and RB4), EJHV8811A/B are spuriously open due to direct these fire areas. assumed to not have potential for valve control cable damage and spurious opening due to valve begin draining the RWST to the control cable damage because of containment emergency sumps. the modification. EJHV8811A/B can still spuriously open if the MCC which powers the valve is involved in the fire, or in response to a valid or spurious Sl signal concurrent with a spurious RWST Low level signal.

Compensatory measure for NFPA 805: In accordance with station procedures, appropriate compensatory measures will be established when the NFPA 805 fire protection program becomes effective and remain in effect until this modification is complete.

Compensatory measure for Current Fire Protection Licensing Basis: None; fire areas A-1, A-2, A-4, A-8, A-16 (analysis area A-16S), A-27, C-18, C-21, C-22, C-23, C-24, C-30, C-33, and RB-1 (analysis areas RB1, RB2, RB3, and RB4) are deterministically compliant with the Current Fire Protection Licensing Basis.

August 2011 Page S-5

Enclosure 2 to ULNRC-06031 Page 76 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Completed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 10-0032 H Risk metrics indicated that Installed a non-safety related y4 No Fire PRA credits this modification additional defense in depth was AFW pump as diverse AFW for decay heat removal warranted for the AFW system. backup supply to the safety redundancy.

This modification provides margin related motor driven and for AFW system MSPI metrics. turbine driven pumps. Compensatory measure: None; modification complete 10-0038 H Improve Callaway Plant's Install four non-safety related y4 No Fire PRA credits this modification defense in depth to mitigate the diesel generators (8 MW) at the for electrical power redundancy consequences from a potential electric cooperative substation.

Station Black Out (SBO). Provide Either the electric cooperative Compensatory measure: None; an alternate emergency source of substation or the 4 non-safety modification installed. Additional power that is diverse from the diesel generators will be able to changes forthcoming that do not Emergency Diesel Generators power either Safety Related affect FPRA.

and offsite sources. bus in the event of a loss of AC power and failure of the Emergency Diesel Generators.

August 2011 Page S-6

Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Completed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure 201202154 L Quick response sprinkler heads Quick response sprinkler heads y No The risk condition is low. While were installed in cable chases A- in cable chases A-11, C-30 and the sprinkler heads do not 11, C-30 and C-31. Due to the C-31 were replaced with spray explicitly meet NFPA code they piping configuration, the quick nozzles. are installed and functional and response sprinkler heads were will activate in the event of a fire installed at an angle relative to and provide full coverage within the ceiling, as opposed to being the fire area.

parallel to it; the latter of which is typical. Compensatorv measure: None; modification is complete.

4 Refer to associated implementation item in Table S-3.

• Installation of modifications with an asterisk(*) is field complete and the equipment has been released to Operations. The modification package is still open for updates to lower tier documentation.

August 2011 Page S-7

Enclosure 2 to ULNRC-06031 Page 78 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-2, Items provided below are those modifications that will be completed prior to the implementation of the new NFPA 805 FP program. Any identified modifications will be field completed no later than June 30, 2013. Appropriate compensatory measures for any incomplete NFPA 805 related modifications will be maintained until the modifications are complete.

August 2011 Page S-8

Enclosure 2 to ULNRC-06031 Page 79 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S Plant Modifications Committed In Comp Item Rank Problem Statement Proposed Modification Risk Informed Characterization FPRA Measure None N/A N/A N/A N/A N/A N/A August 2011 Page S-9

Enclosure 2 to ULNRC-06031 Page 80 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3, Items provided below are those items (procedure changes, process updates, and training of affected plant personnel) that will be completed prior to the implementation of the new NFPA 805 FP program. This will be the later of 6 months after Refueling Outage 19 (currently scheduled for Spring of 2013) or 8 months after NRC approval.

August 2011 Page S-10

Enclosure 2 to ULNRC-06031 Page 81 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 07 -050A-001 Procedures will be revised to ensure that the hydrogen supply system is inspected annually and 4.1.2 and Attachment A maintained by Ameren Missouri.

07-050A-002 Dry vegetation and combustible material within 15 feet of the hydrogen supply area will be 4.1.2 and Attachment A removed. Additionally, procedures will be revised to ensure that the area within 15 feet of the hydrogen supply area is kept free of dry vegetation and combustible materials.

07-600-001 A safety and health policy will be documented for the Callaway Plant Fire Brigade. The policy will 4.1.2 and Attachment A satisfy the requirements of NFPA 600, Sections 2-1.4 and 2-2.4.

07-600-002 Fire brigade policy documents and procedures will be updated to include a requirement for a 4.1.2 and Attachment A standard system to identify and account for each industrial fire brigade member present at the scene of the emergency, in accordance with NFPA 600, Section 2-2.1.4.

The requirement will also meet NFPA 600, section 2-4.5, and will specify that industrial fire brigade members be issued identification for the following purposes:

(1) Assistance in reaching the incident in an emergency (2) Identification by security personnel (3) Establishing authority 07-600-003 A risk management policy will be written for emergency response. The risk management policy 4.1.2 and Attachment A shall be routinely reviewed with industrial fire brigade members and shall be based on the following recognized principles:

(1) Some risk to the safety of industrial fire brigade members is acceptable where saving human lives is possible.

(2) Minimal risk to the safety of the industrial fire brigade members, and only in a calculated manner, is acceptable where saving endangered property is possible.

(3) No risk to the safety of industrial fire brigade members is acceptable where saving lives or property is not possible.

07-600-004 The Callaway Plant Fire Brigade training program will be updated to include a periodic review of 4.1.2 and Attachment A NFPA 600.

07-805-001 1 Procedure APA-ZZ-00700, "Fire Protection Program," will be revised to clearly define the fire 4.1.2 and Attachment A protection interfaces with other organizations using the guidelines of Appendix A of NFPA 805.

August 2011 Page S-11

Enclosure 2 to ULNRC-06031 Page 82 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 07-805-002 The AHJ (i.e., NRC, NEIL) will be identified in procedure APA-ZZ-00700, "Fire Protection 4.1.2 and Attachment A Program," using the guidelines of Appendix A of NFPA 805.

07-805-004 Procedure APA-ZZ-00741, "Control of Combustible Materials," will be revised to include a 4.1.2 and Attachment A requirement for plastic sheeting used in the power block to have passed NFPA 701.

07-805-005 1 Sections 4.1.5.c and 4.1.5.e of procedure APA-ZZ-00741, "Control of Combustible Materials," will 4.1.2 and Attachment A be revised to include the removal of all waste, debris, scrap, and combustible packing materials from all areas, not only safety-related buildings and adjacent areas.

07-805-006 Procedure APA-ZZ-00742, "Control of Ignition Sources," will be revised to include requirements 4.1.2 and Attachment A for not allowing portable electric or fuel-fired heaters in plant areas containing equipment important to nuclear safety or where there is a potential for radiological releases resulting from a fire.

07-805-009 1 Procedures APA-ZZ-007 41, "Control of Combustible Materials," and MDP-ZZ-LM001, "Fluid 4. 1.2 and Attachment A Leak Management Program," will be revised to include a requirement for the prompt cleanup of combustible liquids discovered on insulation, including high flashpoint lubricating oils (instead of only performing an assessment of the potential for fire and the recording of appropriate recommendation in APA-ZZ-00741), and to keep such fluids from coming in contact with hot pipes and surfaces, including insulated pipes and surfaces.

07-805-013 Procedure FPP-ZZ-00009 will be revised to include an assessment of the proper use of pre-fire 4.1.2 and Attachment A plans and coordination with other groups during fire brigade drills, using the guidelines of Appendix A of NFPA 805.

07-805-014 Procedure FPP-ZZ-00009, "Fire Protection Training Program," will be updated to provide 4.1.2 and Attachment A requirements for drills to be conducted in various plant areas, especially in those areas identified to be essential to plant operation and to contain significant fire hazards, as required by NFPA 805.

07-805-015 A requirement that specifies that fire brigade protective clothing and respiratory protective 4.1.2 and Attachment A equipment shall conform to the applicable NFPA standard will be documented in APA-ZZ-00700.

August 2011 Page S-12

Enclosure 2 to ULNRC-06031 Page 83 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 07-805-017 Procedure APA-ZZ-00741, "Control of Combustible Materials," will be revised to include 4.1.2 and Attachment A requirements for maintaining adequate clearance, free of combustible material, around energized electrical equipment.

07-805-047 1 A statement will be added to procedure APA-ZZ-00700 to require that controlled copies of the 4.1.2 and Attachment A pre-fire plans be maintained in the Control Room and made available to the fire brigade.

11-080-007 The scope of Procedure SDP-KC-00002, "Fire Door Position Verification," will be revised to 4.1.2 and Attachment A include all doors credited to meet the requirements of NFPA 805.

11-080-008 The scope of Procedure OSP-KC-00015, "Fire Door Inspections," will be revised to include all 4.1.2 and Attachment A doors credited to meet the requirements of NFPA 805.

11-805-048 1 Procedures APA-ZZ-00700 and APA-ZZ-00703 will be revised to include inspection, testing, and 4. 1.2 and Attachment A maintenance requirements for all fire protection systems and features credited by the fire protection program.

11-805-049 Section 4.1.5.b of APA-ZZ-00741 will be revised to address that cribbing timbers 6 in. by 6 in. or 4.1.2 and Attachment A larger are not required to be fire-retardant treated.

11-805-050 Drawing E-2R8900 and procedure EDP-ZZ-04044 will be revised to require that, where wiring 4.1.2 and Attachment A must be installed above a suspended ceiling, it shall comply with NFPA 805 Section 3.3.5.1.

11-805-051 Section 4.1.3(c) of procedure APA-ZZ-00743, "Fire Team Organization and Duties," will be 4.1.2 and Attachment A revised to include the requirement that industrial fire brigade members shall have no other assigned normal plant duties that would prevent immediate response to a fire or other emergency as required.

11-805-052 Procedure APA-ZZ-00700 will be revised to identify that plant personnel who respond with the 4.1.2 and Attachment A industrial fire brigade are trained as to their responsibilities, potential hazards to be encountered, and interfacing with the industrial fire brigade.

11-805-053 1 OTO-ZZ-00001 and OTO-KC-00001 will be revised to incorporate credited Recovery Actions 4.2.1.3 and Attachment G consistent with Attachment C (Fire Area Transition).

August 2011 Page S-13

Enclosure 2 to ULNRC-06031 Page 84 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-31mplementation Items Item Unit Description LAR Section I Source 11-805-055 Non-Power Operations risk management strategies from the NFPA 805 NSCA (Callaway Plant 4.2.1 and Attachment D Calculation KC-26, "Nuclear Safety Capability Assessment") and the FSAs for fire areas with identified KSF pinch points will be incorporated into the plant fire response procedure(s), plant outage management procedures, and plant operating procedure(s).

11-805-056 1 Confirmation that plant modification MP 07-0151 has adequately modified the control circuitry for 4.2.4 and Attachment C Emergency Diesel Generator NE02, such that local isolation/transfer/control capability for the Main Control Room fire evacuation scenario is maintained without having to replace fuses, cut wires, or perform other repair activities with consideration given to fire induced multiple simultaneous hot shorts, open circuits, and shorts to ground per the criteria of NEI 00-01, will be made. Confirmation that the modification is correctly implemented into procedure OTO-ZZ-00001 will be made.

11-805-058 APA-ZZ-00700, "Fire Protection Program," will be revised to add NPO overview, definitions; road 4.3.2 and Attachment D map; and risk reduction requirements for all NPO, then HRE.

11-805-059 APA-ZZ-007 41, "Control of Combustible Materials," will be revised to add a section which 4.3.2 and Attachment D addresses outage roving fire watches with specific NPO scope.

11-805-061 APA-ZZ-00703, "Fire Protection Operability Criteria and Surveillance Requirements," contains 4.3.2 and Attachment D the compensatory actions to be implemented should a fire protection system required to be operable during HRE periods be found to be impaired. In these cases continuous fire watches will be implemented in the affected systems areas.

11-805-062 EDP-ZZ-04044, "Fire Protection Reviews," will be revised to add guidance to ensure that 4.3.2 and Attachment D changes to the fire protection program are reviewed for impact to the NPO requirements and risk reduction actions.

11-805-063 APA-ZZ-00315, "Configuration Risk Management," will be revised to reference NFPA 805 and 4.3.2 and Attachment D include some discussion of risk due to fire I NFPA 805 and NPO; and to add reference to APA-ZZ-00700.

11-805-064 Procedure OTN-BB-00002, "Reactor Coolant System Draining," will be revised to add the HRE 4.3.2 and Attachment D risk reduction actions as a prerequisite to procedure performance, to add a checklist for risk reduction actions, and to add a restoration checklist for risk reduction actions.

August 2011 Page S-14

Enclosure 2 to ULNRC-06031 Page 85 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 11-805-065 Procedure OTN-BB-00002, Addendum 7, "Raising RCS Level to 61nches Below the RX Vessel 4.3.2 and Attachment D Flange," will be revised to add a decision point to check level/ perform T-boil calculation to determine if HRE is exited and to add a restoration checklist for risk reduction actions.

11-805-066 OTN-BB-00001, "Reactor Coolant System," will be revised to add an action to monitor T-Boil to 4.3.2 and Attachment D determine when the HRE requirements can be exited and then to add a restoration checklist for risk reduction actions.

11-805-067 OTG-ZZ-00007, "Refueling Preparation, Performance and Recovery," will be revised to add an 4.3.2 and Attachment D action to monitor T-Boil to determine when the HRE requirements can be exited and then to add a restoration checklist for risk reduction actions.

11-805-068 1 EDP-ZZ-01129, "Callaway Plant Risk Assessment," and/or ODP-ZZ-00002 Appendix 2, "Risk 4.3.2 and Attachment D Management Actions for Planned Risk Significant Activities," will be revised to provide additional guidance to consider potential system unavailability as a result of a fire when developing a Key Safety Function Availability Checklist for a plant configuration change.

11-805-069 During the implementation of the NFPA 805Iicense basis, performance-based surveillance 4.1.2 and Attachment A frequencies will be established as described in Electric Power Research Institute (EPRI)

Technical Report TR-1006756, "Fire Protection Surveillance Optimization and Maintenance Guide for Fire Protection Systems and Features" and evaluated in Callaway Plant Calculation KC-162, "Performance Based Fire Protection Surveillance Frequency Program."

11-805-070 Documentation associated with the transition to NFPA 805 is being tracked as a plant 4.7 modification. Records associated with the transition are included as part of the modification package.

11-805-071 Drawings associated with the MCR cable trench will be updated to reflect adequate separation 4.2.4 between the MCR and the lower cable spreading room.

11-805-072 A fire PRA qualification standard will be developed to ensure individuals are appropriately 4.7.3 and Attachment V qualified per the requirements of NFPA 805 Section 2.7.3.4 to perform assigned work.

11-805-073 The audit scope requirements contained in OQAM Section 18.8.e will be relocated to FSAR SP 4.6.2 Section 9.5.1 and revised to add the Monitoring Program. Additionally the OQAM Section 18 will be revised to change the FP QA Audit frequency from 2 years to 3 years.

August 2011 Page S-15

Enclosure 2 to ULNRC-06031 Page 86 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 11-805-074 Procedure ODP-ZZ-00002, "Equipment Status Control," Attachment 3, "Operability Evaluations," 4.2.1.2 will be revised to ensure the assumed nitrogen inventory as described in Section 4.2.1.2 Safe and Stable Conditions for the Plant, is maintained in the ASD N2 accumulator tanks.

11-805-075 1 In accordance with ODP-ZZ-0016E, "Operations Technicians Watchstation Practices and 4.2.1.2 Rounds," a form will be initiated to change the data points for Operations Auto Tour to ensure the assumed nitrogen inventory as described in Section 4.2.1.2 Safe and Stable Conditions for the Plant, is maintained in the ASD N2 accumulator tanks.

11-805-076 1 The Fire Pre-Plan Manual will be revised as follows: 4.1.2 and Attachment A 4.4.2 and Attachment E

• The fire pre-plan attachments will be revised where the radiation release criteria are applicable for gaseous and liquid effluent as described in Table E-1/E-2 to include effluent controls and monitoring.

• New Pre-Fire Plans will be added for C-36 and C-37.

• Two new Attachments will be added, for Temporary Structures Inside the PA and for Temporary Structures Outside the PA, and existing Fire Attack Guidelines will be combined into each attachment.

11-805-077 FPP-ZZ-00009, "Fire Protection Training Program," will be revised to include the containment 4.4.2 and Attachment E and monitoring of fire suppression agents and products of combustion in potentially contaminated areas.

11-805-078 FPP-ZZ-00009, "Initial Traning Course Agenda," will be revised to include the containment and 4.4.2 and Attachment E monitoring of fire suppression agents and products of combustion in potentially contaminated areas.

11-805-079 FPP-ZZ-00009, "Retraining Courses and Activities," will be revised to include the containment 4.4.2 and Attachment E and monitoring of fire suppression agents and products of combustion in potentially contaminated areas.

11-805-080 1 Section 6 of HTP-ZZ-05006, "Fire Involving Radioactive Material or Entry into the Radiological 4.4.2 and Attachment E Controlled Area," will be revised to address Radiation Protection actions for monitoring and control of potentially contaminated effluents.

August 2011 Page S-16

Enclosure 2 to ULNRC-06031 Page 87 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 11-805-081 1 T66.0092 I Module 2 will be revised as follows: 4.4.2 and Attachment E

• Discussion of radiological considerations in ventilation decision process will be added to the Ventilation section.

• Discussion addressing potentially contaminated materials will be added to the Salvage and Overhaul section, and radiological considerations will be added in the water removal section.

• Discussion addressing radiological considerations for search and rescue actions on opening doors, etc. will be added to the Search and Rescue section.

11-805-082 The Power Plant Hazards section of T66.0092 I Module 3 will be revised to add discussion 4.4.2 and Attachment E addressing radiological release considerations.

11-805-083 The Fire Ground Safety section of T66.0092 I Module 4 will be revised to add discussion 4.4.2 and Attachment E addressing Radiological considerations to hazards discussion.

11-805-084 The initial size up guidance, ventilation, and overhaul considerations sections of T66.0092 I 4.4.2 and Attachment E Module 5 will be revised to add discussion addressing radiological release considerations.

11-805-085 APA-ZZ-01000, Appendix A, "Control Of Radioactive Material," will be revised to add reference to 4.4.2 and Attachment E Callaway Plant Calculation HPCI 10-04, "National Fire Protection Association (NFPA) Standard 805 Airborne and Liquid Effluents Offsite Dose," and to add discussion to Section 4 to discuss considerations of fire, gaseous and liquid effluents impacts on NFPA 805 compliance.

11-805-086 HTP-ZZ-02005, "Handling of Radioactive Material," will be revised to add reference to Callaway 4.4.2 and Attachment E Plant Calculation HPCI 10-04, "National Fire Protection Association (NFPA) Standard 805 Airborne and Liquid Effluents Offsite Dose," and to add discussion to Section 6 to discuss considerations of surveys to verify dose levels and calculation limits are adhered to. Actions to be taken should limits be exceeded will be added.

11-805-087 RTN-HC-01000, "Storage and Handling of Radwaste," will be revised to add reference to 4.4.2 and Attachment E Callaway Plant Calculation HPCI 10-04, "National Fire Protection Association (NFPA) Standard 805 Airborne and Liquid Effluents Offsite Dose," and to add discussion to Section 5 to discuss considerations of fire, gaseous and liquid effluents impacts on NFPA 805 compliance August 2011 Page S-17

Enclosure 2 to ULNRC-06031 Page 88 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 11-805-088 Configuration control mechanisms for the Fire PRA and NSCA will be revised to ensure the basis 4.2.1.4 and Attachment F for MSO inclusion/exclusion is maintained consistent with the current plant. The rationale for excluding generically identified MSOs from the Callaway Plant Fire PRA and Callaway Plant NSCA was documented in Callaway Plant Calculation 17671-002b, "Callaway NFPA 805 Fire PRA- MSO Expert Panel Report," and Callaway Plant Calculation KC-26, "Nuclear Safety Capability Assessment," respectively. Configuration control mechanisms will be reviewed to provide reasonable confidence that the exclusion basis remains valid.

11-805-089 1 The Monitoring program described in procedure EDP-ZZ-011 01, "Fire Protection Monitoring 4.6.2 Program Procedure, will be implemented after the safety evaluation issuance as part of the fire protection program transition to NFPA 805. Ameren Missouri will implement a monitoring program in accordance with FAQ 10-0059 Rev. 5 during implementation.

11-805-090 In order to adequately reflect the calculated reliability of recovery actions in the Fire HRA, the 4.2.1.3 and Attachment G Fire HRA will be updated once procedure updates, plant modifications, and recovery action training are complete.

11-805-091 The missing ceiling tiles in the suspended ceiling in fire compartments C-5 and C-6 will be 4.1.2 and Attachment A replaced in order to ensure proper operation of sprinkler system SKC34, which is credited in the Fire PRA, in accordance with NFPA 13-1976 Edition. Configuration control on the ceiling tiles will be ensured.

11-805-092 An administrative control will be implemented to ensure that the breaker (PB0406) for DPAE02 is 4.2.1.4 and Attachment F disabled open during at-power plant operation to address a potential MSO that may result in overfill of steam generators/overcooling of the RCS.

11-805-093 The current Fire PRA does include the phase #1 version of MP 10-0038, and the AEPS, MP 10- Attachment S 0032. As the modification packages are completed, the FPRA will be udpated if necessary to reflect the final configuration.

August 2011 Page S-18

Enclosure 2 to ULNRC-06031 Page 89 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-31mplementation Items Item Unit Description LAR Section I Source 12-805-001 All of the items labeled with footnote 1 in PRA RAI 1, Table 1, will be completed: Attachment U F&Os: 1-7, 1-14, 1-25, 1-3,1-13 and 1-15 These commitments involve updating the fire PRAto be consistent with upgrade items that were implemented in the internal events PRA update (Revision 5) after the Callaway Plant NFPA-805 LAR was submitted.

In addition, a self-assessment of the internal events PRA against the RG 1.200, Rev 2 clarifications and qualifications to determine if any gaps exist is in progress and will be completed, with any resolutions completed before transition to NFPA 805 occurs.

12-805-002 Technical details demonstrating the Control Room Abandonment models are used within the Attachment J validated range of NUREG-1824 "Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications," Final Report, April2007, as well as any justification of models outside the range, will be documented in the next update to Callaway Calculation 17671-010b "Callaway NFPA 805 Fire PRA- Main Control Room Fire Analysis."

12-805-003 The fire PRA LERF model will be updated to be consistent with the lE-PRA LERF model 4.5.1 and Attachment W phenomenology, split fractions, and probabilities during the next Fire PRA update.

12-805-004 APA-ZZ-00741, "Control of Combustible Materials," will be revised to implement "No Storage" Attachment V and "No Hotwork" controls for Fire Areas A-1, A-11, A-12, A-27, C-1, C-2, C-3, C-7, C-8, C-9, C-10, C-11, C-12, C-17, C-18, C-19, C-20, C-21, C-22, C-23, C-24, C-25, C-26, C-30, C-31, C-32, C-33, C-34, C-36, and C-37.

12-805-005 Upon completion of all Fire PRA credited implementation items in Transition Report Table S-2, Attachment W verify the validity of the change-in-risk provided in Attachment W. This includes consideration of the following plant modifications: 05-3029, 07-0151 and 09-0025. If this verification determines that the risk metrics have changed such that the RG 1 .205 acceptance guidelines are not met, the new Implementation Item 12-805-005 will require implementation of additional analytical efforts, and/or procedure changes, and/or plant modifications to assure the RG 1.205 risk acceptance criteria are met.

August 2011 Page S-19

Enclosure 2 to ULNRC-06031 Page 90 of90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table S-3 Implementation Items Item Unit Description LAR Section I Source 13-805-001 Callaway will revise its Fire PRA analysis to utilize alternate analyses specifically by modifying PRA RAI36 the PRA model to provide detailed HRA of all actions required after Control Room evacuation.

This evaluation will be accomplished using the EPRI HRA calculator and be conducted in accordance with the guidance in NUREG-1921 prior to use of the Fire PRA for evaluation of post-transition changes to the Fire Protection Program.

13-805-002 Callaway will revise its Fire PRA analysis to utilize the Fractional Influence Factors (e.g., 0.0, 0.1, PRA RAI37 0.3, 1.0, 3.0, 10, or 50) in FAQ 12-0064 and ensure that all evaluated locations have a total influence factor greater than 0.0 prior to use of the Fire PRA for post-transition changes.

13-805-003 Callaway will revise the Fire PRA to utilize the total ignition frequency for Bus Duct fires (BIN PRA RAI38 16.2) which are specified in Supplement 1 to NUREG/CR-6850 prior to use of the Fire PRA for evaluation of post-transition changes to the Fire Protection Program.

13-805-004 1 Callaway will revise the Fire PRAto utilize the specific CPT treatment guidance provided in a PRA RAI39 Letter to Joe G. Giitter from Richard P. Correia dated June 14th, 2013 titled "Interim Technical Guidance on Fire Induced Circuit Failure Mode Likelihood Analysis" prior to use of the Fire PRA for evaluation of post-transition changes to the Fire Protection Program.

13-805-005 Callaway will revise the Fire PRA to utilize the fire growth time to peak heat release rate for trash PRA RAI40 fires of 8 minutes specified in FAQ 08-0052 incorporated in Supplement 1 to NUREG/CR-6850 (EPRI 1011989) for the Main Control Room transient fires prior to use of the Fire PRA for evaluation of post-transition changes to the Fire Protection Program.

13-805-006 Callaway will implement the uncertainty methodology used in response to PRA RAJ 09-B to PRA RAI41 estimate the change in risk associated with post-transition changes to the Fire Protection Program with the understanding that the uncertainty methodology can be refined to utilize parametric data evaluations.

13-805-007 Callaway will revise the Fire PRAto incorporate the Internal Events PRA Common Cause PRA RAI42 Failures (CCFs) such that both the current IE and Fire PRA are consistent regarding CCFs prior to using the Fire PRA to evaluate the change in risk associated with post-transition changes to the Fire Protection Program.

August 2011 Page S-20