Text

Enclosure 1 to ULNRC-06031 - Request for Additional Information (RAI) Set #4 Responses
	ML13269A137
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: ML13269A137 (55)
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Enclosure 1 to ULNRC-06031 Page 1 of 3 REQUEST FOR ADDITIONAL INFORMATION (RAI)

SET #4 RESPONSES to ULNRC-06031 Page 2 of 3 Fire Protection Engineering RAI 18.01 In a letter dated August 5, 2013, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML13218A171), Ameren Missouri responded to Fire Protection Engineering Request for Additional Information (RAI) 18 and stated that Callaway complies with NFPA 805 Section 3.4.1(c).

The response further stated that that the Fire Brigade Leader position may be filled by either an Operating Supervisor or Operations Technician. Based on your description, it does not appear that the training and qualifications of the Operations Technician provides sufficient integrated plant/system operations knowledge of nuclear safety systems to understand the effects of fire and fire suppressants on nuclear safety performance criteria (NSPC). Consistent with the current guidance provided for non-National Fire Protection Association Standard 805 (NFPA 805) plants (Regulatory Guide 1.189, Revision 2), the Fire Brigade Leader should receive training sufficient to fully understand plant transient response and integrated plant impacts of potential fire/fire suppressant damage to front line and support systems. Although the training and qualifications provided to the Operations Technician includes review of nuclear safety systems and objectives including understanding the purpose, major system flow-paths, operation of major system components, indications, controls, and system operation during normal and off-normal conditions, it does not include higher level objectives that demonstrate integrated knowledge of plant operations.

Provide a revised response that addresses training and qualifications to meet the higher level objectives that demonstrate integrated knowledge of plant operations sufficient to fully understand plant transient response and integrated plant impacts of potential fire/fire suppressant damage to front line and support systems and how they are used to meet the nuclear safety performance criteria.

An approach acceptable to the staff for meeting this training and knowledge requirement is provided in Regulatory Guide 1.189, Revision 2, Section 1.6.4.1, Qualifications:

"The brigade leader and at least two brigade members should have sufficient training in or knowledge of plant systems to understand the effects of fire and fire suppressants on safe-shutdown capability. The brigade leader should be competent to assess the potential safety consequences of a fire and advise control room personnel. Such competence by the brigade leader may be evidenced by possession of an operator's license or equivalent knowledge of plant systems."

Another option available with regard to this attribute is to maintain your fire protection program consistent with existing commitments and utilize a compliance category of Complies by previous NRC Approval in accordance with NFPA 805 Section 3.1.

to ULNRC-06031 Page 3 of 3 Callaway Response:

Callaway complies with requirement NFPA 805 Section 3.4.1(c) via existing engineering equivalency evaluation (EEEE) 201300142. The program change and associated fire protection evaluation to allow a fully qualified Operations Technician to act as the Fire Brigade Team Leader was made under the current licensing basis.

LAR Attachment A Table B-1 section 3.4.1(c) Compliance Statement has been revised to state that Callaway will comply via the use of an existing engineering equivalency evaluation (EEEE) and lists the reference documents.

to ULNRC-06031 Page 1 of 90 Summary of LAR Changes LAR Table 4-3 LAR Table 4-3 is revised to correct a self-identified error involving five fire zones which contain Electrical Raceway Fire Barrier Systems (ERFBS) that were incorrectly identified as not required for risk reduction. LAR Table 4-3 pages 51, 55, 71 and 83 are revised to show these five zones as containing ERFBS that are credited for risk reduction.

LAR Attachment A Page A-39 is revised to address RAI 18.01. The compliance basis is revised to use of EEEE with credit for the EEEE performed which evaluated use of the Non-Licensed Operator as the Fire Brigade Team Leader. Note this is our Current Licensing Basis and the change was performed via our License Condition which allows changes without prior NRC approval as long as they do not adversely affect Safe Shutdown in the event of a fire.

Pages A-78 and 81 are revised to address the completed RFR related to the fast response sprinklers which was installed in June 2013. The open commitment item is removed from page A-81 and the new reference added to page A-78. Pages 79 and 80 do not contain any changes.

LAR Attachment C The self-identified error described above for LAR Table 4-3 is also shown in LAR Attachment C. Pages C-14, C-17, C-185 and C-278 are revised to show the ERFBS in five fire zones in Fire Areas A-1, A-24, and C-10 are credited for risk reduction. All of the pages for the affected Fire Areas are included for completeness, but only pages C-14, C-17, C-185 and C-278 contain changes.

Page C-480 is revised to address a self-identified error. EEEE RFR 201009031 should have been identified as applicable to fire area C-28 in the B-3 table, so the B-3 table for C-28 is revised to add the RFR.

LAR Attachment K Pages K-12 and K-15 are revised to correct a self-identified error. Licensing Actions 6 and 7 should have been noted as applicable to ALL fire areas instead of NONE. The two Licensing Actions are revised to note they are applicable to all plant fire areas as they are generic issues. All of the pages for Licensing Actions 6 and 7 are included, but only pages K-12 and K-15 contain changes.

LAR Attachment M Attachment M is revised to address the NFPA 805 Section 1.7 exception, to address the fact the modifications are completed and to reflect the current version of the Callaway license.

to ULNRC-06031 Page 2 of 90 LAR Attachment S Attachment S Table S-1 is revised to add completed modifications 05-3029, 07-0151, 09-0025, and RFR 201202154. Attachment S-2 is revised to note there are no longer any committed modifications because they have all been installed. Attachment S-3 is revised to reflect all current committed items as modified via all previous RAI responses.

to ULNRC-06031 Page 3 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Required? Required Fire Protection Area Zone Description Regulatory Category ID Type Feature and System Details Basis S L E R D A-1 Auxiliary Building - El. 4.2.4.2 1974, 1988 A-1 1101 General Floor Area No. 1 Detection 100 Ionization Y N N N N A-1 1101 General Floor Area No. 1 Suppression SKC43 Pre-action Y N N N N A-1 1101 General Floor Area No. 1 Feature None ERFBS Y N N Y N A-1 1102 Chiller and Surge Tanks Detection 100 Ionization Y N N N N Area A-1 1102 Chiller and Surge Tanks Detection 101 Ionization Y N N N N Area A-1 1102 Chiller and Surge Tanks Suppression SKC43 Pre-action Y N N N N Area A-1 1102 Chiller and Surge Tanks Feature None N/A - - - - -

Area A-1 1103 Letdown Chiller Heat Detection None N/A - - - - -

Exchanger Room A-1 1103 Letdown Chiller Heat Suppression None N/A - - - - -

Exchanger Room A-1 1103 Letdown Chiller Heat Feature None N/A - - - - -

Exchanger Room A-1 1104 Letdown Reheat Heat Detection None N/A - - - - -

Exchanger Room A-1 1104 Letdown Reheat Heat Suppression None N/A - - - - -

Exchanger Room A-1 1104 Letdown Reheat Heat Feature None N/A - - - - -

Exchanger Room A-1 1105 Valve Compartment Detection None N/A - - - - -

A-1 1105 Valve Compartment Suppression None N/A - - - - -

A-1 1105 Valve Compartment Feature None N/A - - - - -

August 2011 Page 51 to ULNRC-06031 Page 4 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Required? Required Fire Protection Area Zone Description Regulatory Category ID Type Feature and System Details Basis S L E R D A-1 1206 Pipe Chase Detection 120 Ionization Y N N N N A-1 1206 Pipe Chase Suppression SKC48 Wet Pipe Y N N N N A-1 1206 Pipe Chase Feature None 20-ft Separation Y N N N N Zone A-1 1206 Pipe Chase Feature None ERFBS Y N N Y N A-1 1207 Pipe Chase Detection 120 Ionization Y N N N N A-1 1207 Pipe Chase Suppression SKC48 Wet Pipe Y N N N N A-1 1207 Pipe Chase Feature None 20-ft Separation Y N N N N Zone A-1 1207 Pipe Chase Feature None ERFBS Y N N Y N A-1 1329 Vestibule Detection None N/A - - - - -

A-1 1329 Vestibule Suppression None N/A - - - - -

A-1 1329 Vestibule Feature None N/A - - - - -

August 2011 Page 55 to ULNRC-06031 Page 5 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Required? Required Fire Protection Area Zone Description Regulatory Category ID Type Feature and System Details Basis S L E R D A-24 Containment 4.2.4.2 Mechanical Piping Penetration Room A A-24 1323 Pipe Penetration Room Detection 117 Ionization Y N N Y N A

A-24 1323 Pipe Penetration Room Suppression None N/A - - - - -

A A-24 1323 Pipe Penetration Room Feature None ERFBS Y N N Y N A

A-25 Pipe Penetration Room 4.2.3.2 B

A-25 1322 Pipe Penetration Room Detection 117 Ionization N N N N N B

A-25 1322 Pipe Penetration Room Suppression None N/A - - - - -

B A-25 1322 Pipe Penetration Room Feature None N/A - - - - -

B A-26 Ops Storage/I&C Hot 4.2.3.2 Shop A-26 1405 Ops Storage/I&C Hot Detection 118 Ionization N N N N N Shop A-26 1405 Ops Storage/I&C Hot Suppression None N/A - - - - -

Shop A-26 1405 Ops Storage/I&C Hot Feature None N/A - - - - -

Shop August 2011 Page 71 to ULNRC-06031 Page 6 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Table 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and Features Fire Fire NFPA 805 Required? Required Fire Protection Area Zone Description Regulatory Category ID Type Feature and System Details Basis S L E R D C-8 Control Building Cable 4.2.3.2 Chase B, Control Building. El. 1984 C-8 3229 Electrical Chase (South) Detection 300 Ionization N N N N N C-8 3229 Electrical Chase (South) Suppression SKC37 Wet Pipe N N N N N C-8 3229 Electrical Chase (South) Feature None N/A - - - - -

C-9 ESF Switchgear Room 4.2.4.2 A

C-9 3301 ESF Switchgear Room Detection 314 Ionization N N N Y N No. 1 C-9 3301 ESF Switchgear Room Detection 315 Ionization N N N Y N No. 1 C-9 3301 ESF Switchgear Room Suppression SKC01 Halon N N N Y N No. 1 C-9 3301 ESF Switchgear Room Feature None N/A - - - - -

No. 1 C-10 ESF Switchgear Room 4.2.4.2 B

C-10 3302 ESF Switchgear Room Detection 316 Ionization N N N Y N No. 2 C-10 3302 ESF Switchgear Room Detection 317 Ionization N N N Y N No. 2 C-10 3302 ESF Switchgear Room Suppression SKC01 Halon N N N Y N No. 2 C-10 3302 ESF Switchgear Room Feature None ERFBS N N N Y N No. 2 August 2011 Page 83

Enclosure 2 to ULNRC-06031 Page 7 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment A . NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document

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August 2011 Page A-39

Enclosure 2 to ULNRC-06031 Page 8 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment A . NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document 3.9 Automatic and N/A N/A N/A - General statement; No N/A Manual Water-Based technical requirements Fire Suppression Systems 3.9.1 If an automatic or manual water-based N/A N/A - General statement; No N/A fire suppression system is required to technical requirements meet the performance or deterministic requirements of Chapter 4, then the system shall be installed in accordance with the appropriate NFPA standards including the following:

3.9.1(1) NFPA 13, Standard for the Installation of Complies with Required sprinkler systems are Calculation KC-27, NFPA Code Sprinkler Systems Clarification identified in Table 4-3. Those Conformance Review, Rev. 0 /

sprinkler systems comply with Appendix A, Sections 13.1976 NFPA 13-1976 or 1983 Editions and 13.1983 except as identified below.

NFPA 13, Standard for the Installation of Sprinkler Systems, 1976 Edition / All NFPA 13, Standard for the Installation of Sprinkler Systems, 1983 Edition / All RFR 201202154, Evaluate Sprinkler System in Rooms 3617, 3618 & 1335 / All August 2011 Page A-78

Enclosure 2 to ULNRC-06031 Page 9 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment A . NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document Complies by Previous For the non-ceiling level sprinklers Calculation KC-27, NFPA Code NRC Approval that were installed under Conformance Review, Rev. 0 /

obstructions at the request of the Appendix A, Section 13.1976 NRC, sprinkler deflectors are located greater than 18 inches Letter SLNRC 81-050 from below noncombustible roof decks. Petrick (SNUPPS) to Denton Per Section 9.5.1.1 of NUREG- (NRC), dated June 29, 1981 /

0830 Supplement 3, "The SER Attachment, Page 9.5B-225 states that the automatic sprinkler Letter SLNRC 84-0037 from systems would be designed to the Petrick (SNUPPS) to Denton recommendations of National Fire (NRC), dated February 24, 1984 /

Protection Association (NFPA) All Standard 13. During its site visit, the staff noted that in some NFPA 13, Standard for the corridor areas (e.g., auxiliary Installation of Sprinkler Systems, building corridor, elevation 1974 1976 Edition / Sections 4-3.2.1 feet, west side), the sprinkler and 4-3.2.3 heads are located at the ceiling and there are a large number of FSAR SP, Appendix 9.5B, Rev.

cable trays, conduits, pipes, and OL-14b / Section A.8.4 vent ducts beneath the sprinkler NUREG-0830, Safety Evaluation heads. These obstructions may Report related to the operation of render the sprinkler system Callaway Plant, Unit No. 1, ineffective against a floor-level Supplement 3, dated May 01, exposure fire, and are not in 1984 / Section 9.5.1.1 accordance with NFPA 13, which is recommended by Section C.6.c NUREG-0830, Safety Evaluation of BTP CMEB 9.5-1. Report Related to the Operation of Callaway Plant, Unit No. 1, By letter dated February 24, 1984, dated October 01, 1981 / Page 33 the applicant committed to perform the following modifications by October 1984:

(1) Additional sprinkler heads will be added in the auxiliary building on the 2000-foot elevation, west corridor (three-tray area), and the 2026-foot elevation, north end of east corridor, to protect against August 2011 Page A-79

Enclosure 2 to ULNRC-06031 Page 10 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment A . NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document postulated fires in transient combustibles.

(2) Sprinkler heads on the 1974-foot elevation of the auxiliary building west corridor that are partially obstructed by structural steel beams will be lowered to avoid spray obstructions.

On the basis of this commitment, the staff concludes that the sprinkler system will meet the guidelines in Section C.6.c of BTP CMEB 9.5-1, and is therefore acceptable."

Based on review of Section A.8.4 of FSAR SP Appendix 9.5B, this commitment has been implemented.

The obstruction of sprinkler heads, as approved in the referenced SER, is still in the same configuration as that which was approved. There have been no plant modifications or other changes that would invalidate the basis for approval.

Per page 9.5B-225 of the attachment to SLNRC 81-050, A fixed, manually charged, closed head sprinkler system is provided over the cable trays in Zones RB-3 and RB-4A manual system is installed to prevent an inadvertent actuation of the sprinklers during August 2011 Page A-80

Enclosure 2 to ULNRC-06031 Page 11 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment A . NEI 04-02 Table B Transition of Fundamental FP Program and Design Elements (NFPA 805 Chapter 3)

Table B NFPA 805 Ch. 3 Transition NFPA 805 Ch. 3 Ref. Requirements/Guidance Compliance Statement Compliance Basis Reference Document normal plant operation.

Per Page 33 of NUREG-0830, "A fixed, manually charged closed head sprinkler system is provided over the two cable tray penetration areasBased on its review, the staff conclude; that the fire protection for the containment meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable."

The manual sprinkler system protecting cable trays in Zones RB-3 and RB-4, as approved in the referenced SER, is still in the same configuration as that which was approved. There have been no plant modifications or other changes that would invalidate the basis for approval.

Complies, with See implementation item identified CAR 200902315, NFPA 805 Required Action below. Transition - Site Organizations Support Tracking CAR IMPLEMENTATION ITEMS:

11-805-091 The missing ceiling tiles in the suspended ceiling in fire compartments C-5 and C-6 will be 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.

August 2011 Page A-81

Enclosure 2 to ULNRC-06031 Page 12 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Fire Zone Description 1101 General Floor Area No. 1 1102 Chiller and Surge Tanks Area 1103 Letdown Chiller Heat Exchanger Room 1104 Letdown Reheat Heat Exchanger Room 1105 Valve Compartment 1106 Moderating Heat Exchanger Room 1115 Normal Charging Pump Room 1120 General Floor Area No. 2 1121 Access Pit 1122 General Floor Area No. 3 & Auxiliary Building Tool Issue Area 1123 Passage 1124 Valve Compartment 1125 Letdown Heat Exchanger Room 1128 Storeroom No. 3 1129 Auxiliary Condenser Recovery and Storage Tank Room 1130 North Corridor 1201 Vestibule 1202 Access Area B & Chiller Surge Tank Area 1203 Pipe Space B 1204 Pipe Space A 1205 Access Area A 1206 Pipe Chase 1207 Pipe Chase 1329 Vestibule Regulatory Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions August 2011 Page C-2

Enclosure 2 to ULNRC-06031 Page 13 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Performance Goal Method of Accomplishment Comments Decay Heat Removal - CSD Use RHR Train A, with cooling water provided by CCW Pumps A and C.

Decay Heat Removal - HSB Steam Generators B and C are supplied by MDAFW Pump A, or Steam Generators A, B, C, and D are supplied by the TDAFW Pump. Credited AFW Pump and Steam Generators depend on location of fire within Fire Area.

Process Monitoring RCS Pressure Channel I Pressurizer Pressure Channel I Pressurizer Level Channel I Ex-core Neutron Monitoring Channel I RCS Loop A (1) T-hot Temperature Channel I RCS Loop A (1) T-cold Temperature Channel II Steam Gen. A Pressure Channel I Steam Gen. A Wide Range Level Channel I Steam Gen. A Atmos. Steam Dump Pressure Channel I Aux. Feedwater Flow to Steam Gen. A Channel I RCS Loop D (4) T-hot Temperature Channels II and VI RCS Loop D (4) T-cold Temperature Channels I and VI Steam Gen. D Pressure Channel I Steam Gen. D Wide Range Level Channel IV Steam Gen. D Atmos. Steam Dump Pressure Channel IV Aux. Feedwater Flow to Steam Gen. D Channel IV RCS Loop B (2) T-hot Temperature Channel I RCS Loop B (2) T-cold Temperature Channel II Steam Gen. B Pressure Channel I Steam Gen. B Wide Range Level Channel II Steam Gen. B Atmos. Steam Dump Pressure Channel II Aux. Feedwater Flow to Steam Gen. B Channels I and II RCS Loop C (3) T-hot Temperature Channels II and V RCS Loop C (3) T-cold Temperature Channels I and V Steam Gen. C Pressure Channel I Steam Gen. C Wide Range Level Channel III Steam Gen. C Atmos. Steam Dump Pressure Channel III Aux. Feedwater Flow to Steam Gen. C Channels I and III Aux. Feedwater Pump A Suction Pressure Channel I August 2011 Page C-3

Enclosure 2 to ULNRC-06031 Page 14 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Turbine Driven Aux. Feedwater Pump Suction Pressure Channel II Refueling Water Storage Tank Level Channel I Volume Control Tank Level Channels I and IV Containment Pressure Channels II, III, and IV Core Exit Thermocouples Train A (Channel I and V) and Train B (Channel IV and VI)

RCS Inventory Control Maintain inventory and RCP seal integrity using Charging Pump A via the Boron See VFDR No. A-01-001, A-01-002, A Injection flowpath and the Alternate RCP Seal Injection flowpath. RCP Thermal 003, A-01-004, A-01-005, A-01-006, A Barrier Cooling is credited, with cooling water provided by CCW Pumps A and C. 007, A-01-008, A-01-009, A-01-010 RCS RV Head Vent flowpath Train A is available for letdown of RCS inventory, if necessary.

RCS Pressure Control Control pressure using Pressurizer Heater Backup Group A. Use PORV See VFDR No. A-01-011 (BBPCV0455A) to depressurize.

Reactivity Control Trip reactor from Control Room. Use Charging Pump A to inject borated water from the RWST.

Vital Auxiliaries Operate CCW Pumps A, C, and ESW Pumps A and B. See VFDR No. A-01-012 Offsite power to NB01 and NB02 credited.

HVAC credited for Main Control Room and Containment (Train A credited).

Reference Documents Calculation KC-26, Nuclear Safety Capability Assessment, Rev. 0 August 2011 Page C-4

Enclosure 2 to ULNRC-06031 Page 15 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Licensing Actions Licensing Action Title Deviation from Section D.1.j of Appendix A to BTP ASB 9.5-1 for Unrated Watertight Doors Summary Deviation submitted per 2/1/1984 SNUPPS letter to the NRC, as supplemented by SNUPPS submittal to the NRC dated 3/14/1984, justifying non-rated doors to maintain the 3-hr fire rating of barriers in which they are installed, was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. A fire test was performed in accordance with the Standard for Fire Tests of Door Assemblies, UL 10B.

2. The watertight doors without gaskets are classified by UL as Special-Purpose Type Fire Doors and Frame Assemblies, Rating 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months (A).

3. To achieve watertight integrity criteria, gasketing material was added to the door assembly in accordance with the manufacturer's recommendations.

This deviation is active. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

Licensing Action Title Deviation from Section D.1.j of Appendix A to BTP ASB 9.5-1 for Elevator and Dumbwaiter Doors Summary Deviation submitted per 2/1/1984 SNUPPS letter to the NRC, as supplemented by SNUPPS submittal to the NRC dated 3/14/1984, justifying non-rated doors to maintain the 3-hr fire rating of barriers in which they are installed, was approved by the NRC in NUREG-0830, Supplement 2, dated 05/1984 based on the following:

1. Elevator and dumbwaiter doors are rated at 1-1/2 hours as required by ANSI A17.1.

2. The 1-1/2 hour doors are an industry standard and, as stated in ANSI A17.1, are acceptable for use in a 2-hour rated elevator or dumbwaiter shaft.

3. For a fire to propagate from one floor elevation to another, it would have to penetrate two doors.

This deviation is active. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

August 2011 Page C-5

Enclosure 2 to ULNRC-06031 Page 16 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Licensing Action Title Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Hatchways Summary Deviation submitted per 6/29/1981 SNUPPS letter to the NRC, as supplemented by SNUPPS submittal to the NRC dated 3/14/1984, to justify the two sets of non-rated equipment hatchways in the northern and southern ends of the auxiliary building corridors, was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. Low fuel loading and configuration of equipment.

2. Steel hatch covers are provided for each hatchway.

3. Automatic sprinkler water curtains are provided for each hatchway at elevations 2000'-0", 2026'-0", and 2047'-0" to separate the corridor fire areas.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

Licensing Action Title Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Partial Detection System Summary Deviation submitted per 3/14/1984 SNUPPS letter to the NRC, providing justification for lack of full-area detection coverage (specifically no detection in Fire Zones 1103, 1104, 1105, 1106, 1123, 1124, 1125, 1129, 1202, 1203, 1204, and 1329), was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. Minimal fire hazards.

2. Availability of manual firefighting equipment.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

Licensing Action Title Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Partial Suppression System Summary Deviation submitted per 3/14/1984 SNUPPS letter to the NRC, providing justification for lack of full-area suppression coverage (specifically partial suppression in Fire Zone 1101 and no suppression in 1102, 1103, 1104, 1105, 1106, 1115, 1120, 1121, 1122, 1123, 1124, 1125, 1128, 1129, 1130, 1201, 1202, 1203, 1204, 1205, and 1329), was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. Minimal fire hazards.

2. Availability of manual firefighting equipment.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

August 2011 Page C-6

Enclosure 2 to ULNRC-06031 Page 17 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Existing Enginering Equivalency Evaluations (EEEE)

EEEE Title Engineering Evaluation RFR 200906330 Summary An excessive gap in the bottom of Door DSK11271 connecting Fire Areas A-1 and A-6 is acceptable based on the lack of intervening combustibles at/near the location of the door. Fire Area A-6 is a stairwell and, as such, no transient combustibles are expected near this doorway. Therefore DSK11271 is considered a non-rated feature commensurate with the fire hazards in the two areas and it provides an equivalent level of protection as a 3 hour3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months rated fire door by prohibiting the propagation of fire between the two fire areas.

EEEE Title Engineering Evaluation RFR 200906322 Summary The removal of Thermo-Lag fire barriers from RHR and containment spray hatch covers in Fire Zones 1203 and 1204 is acceptable based on the fact that there are no fixed ignition sources or fixed combustibles in the vicinity of the hatches, and the fact that the areas are infrequently accessed due to the fact that they are "locked high radiation areas." Further, gaps between the individual plates between A-1 and A-8 are acceptable based on the fact that heat transferred would be rapidly dissipated in the large volume of A-8; there are no combustibles in the immediate vicinity of the hatch covers; combustible loading in the area is very low; there are no ignition sources in the area of the plates; ventilation is not affected based on gap size; an automatic pre-action suppression system is installed in the area of the hatch on the 2000' elevation; and the fire brigade is trained to aggressively control fires in this area.

EEEE Title Engineering Evaluation RFR 201009031 Summary Auxiliary steel members that were not protected and represent thermal shorts have been evaluated and were found to have no adverse effect on the protected structural steel's function in the event of a fire, based on the fire hazards within the fire area.

August 2011 Page C-7

Enclosure 2 to ULNRC-06031 Page 18 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Variances from Deterministic Requirements (VFDR)

VFDR No. A-01-001 BBHV8141A - Cable damage (5BBK05AA) to BBHV8141A. Cable damage can spuriously close the Reactor Coolant Pump A Seal # 1 Water Outlet Isolation Valve, BBHV8141A (spurious closure is only credible assuming external hot shorts). This valve is required to remain open in order to maintain the effectiveness of thermal barrier cooling for the Reactor Coolant Pump Seal Package. This requirement is based on the latest Westinghouse Owners Group Analysis for the performance of the Reactor Coolant Pumps Seal Package following the loss of seal cooling. Note that Reactor Coolant Pump Seal Injection may be interrupted (until recovered) in this area due to fire damage potentially affecting the Charging Pump Suction Supply Valves from the Volume Control Tank (VCT), BGLCV0112B and BGLCV0112C, and the Refueling Water Storage Tank (RWST),

BNLCV0012D and BNLCV0112E (refer to the fire area A-01 VFDRS for equipment BGLCV0112B, BGLCV0112B-P, BGLCV0112C-P, and BNLCV0112D). With the exception of spurious closure of BBHV8141A, component cooling water for the Reactor Coolant Pump A Thermal barrier is unaffected and available in this area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-002 BBHV8141B - Cable damage (5BBK05BA) to BBHV8141B. Cable damage can spuriously close the Reactor Coolant Pump B Seal # 1 Water Outlet Isolation Valve, BBHV8141B (spurious closure is only credible assuming external hot shorts). This valve is required to remain open in order to maintain the effectiveness of Thermal Barrier Cooling for the Reactor Coolant Pump Seal Package. This requirement is based on the latest Westinghouse Owners Group Analysis for the performance of the Reactor Coolant Pumps Seal Package following the loss of Seal Cooling. Note that Reactor Coolant Pump Seal Injection may be interrupted (until recovered) in this area due to fire damage potentially affecting the Charging Pump Suction Supply Valves from the Volume Control Tank (VCT), BGLCV0112B and BGLCV0112C, and the Refueling Water Storage Tank (RWST),

BNLCV0112D and BNLCV0112E (refer to the fire area A-01 VFDRs for equipment BGLCV0112B, BGLCV0112B-P, and BGLCV0112C-P, and BNLCV0112D). With the exception of spurious closure of BBHV8141B, component cooling water for the Reactor Coolant Pump B Thermal barrier is unaffected and available in this area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 19 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 VFDR No. A-01-003 BGHV8149A - Cable damage (5BGK35AB and 5BGK35AD) to BGHV8149A. Cable damage can spuriously open or prevent closure of the Chemical Volume Control System Letdown Orifice A Outlet Isolation Valve, BGHV8149A. The valve is required closed to maintain positive control over RCS inventory and pressure. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-004 BGHV8149B - Cable damage (5BGK35BB and 5BGK35BD) to BGV8149B. Cable damage can spuriously open or prevent closure of the Chemical Volume Control System Letdown Orifice B Outlet Isolation Valve, BGHV8149B. The valve is required closed to maintain positive control over RCS inventory and pressure. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-005 BGHV8149C - Cable damage (5BGK35CB and 5BGK35CD) to BGHV8149C. Cable damage can spuriously open or prevent closure of the Chemical Volume Control System Letdown Orifice C Outlet Isolation Valve, BGHV8149C. The valve is required closed to maintain positive control over RCS inventory and pressure. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 20 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 VFDR No. A-01-006 BGLCV0112B - Cable damage (1BGG12AD) to BGLCV0112B. Cable damage can spuriously close the Chemical Volume Control System Volume Control Tank Outlet Upstream Isolation Valve, BGLCV0112B (spurious closure is only credible assuming external hot shorts), and may also cause the valve to fail as-is (open). Similar failure mode(s) may also occur for BGLCV0112C, the Chemical Volume Control System Volume Control Tank Outlet Downstream Isolation Valve, due to cable damage (4BGG12BD). Both of these valves are required open (i.e., to not spuriously close) to prevent failure of the Credited Charging Pump (when running) from a loss of suction. After the Charging Pump Suction flowpath has been aligned to the Refueling Water Storage Tank, either one of these valves is required to close on demand in order to isolate the Charging Pump Suction flowpath from the Volume Control tank to prevent gas binding of the Credited Charging Pump. Note that access to these valves requires the plant operator to transit through the fire affected area. The valve limit/torque switches for BGLCV0112B can be bypassed by fire damage to cable 1BGG12AD. No loss of the offsite power or spurious undervoltage is expected to NB01 and NB02 in this fire area. The valve limit/torque switches for BGLCV0112C cannot be bypassed by fire damage to Cable 4BGG12BD. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-007 BGLCV0112B-P - Cable damage (1BGG12AD) to BGLCV0112B. Cable damage can spuriously close the Chemical Volume control System Volume Control Tank Outlet Upstream Isolation Valve, BGLCV0112B (spurious closure is only credible assuming external hot shorts), and may also cause the valve to fail as-is (open). Similar failure mode(s) may also occur for BGLCV0112C-P, the Chemical Volume Control System Volume Control Tank Outlet Downstream Isolation Valve, due to cable damage (4BGG12BD). Both of these valves are required open (i.e. to not spuriously close) to prevent failure of the Credited Charging Pump (when running) from a loss of suction. After the Charging Pump Suction flowpath has been aligned to the Refueling Water Storage Tank, either one of these valves is required to close on demand in order to isolate the Charging Pump Suction flowpath from the Volume Control Tank to prevent gas binding of the Credited Charging Pump. Note that access to these valves requires the plant operator to transit through the fire affected area. The valve limit/torque switches for BGLCV0112B can be bypassed by fire damage to Cable 1BGG12AD. No loss of offsite power or spurious undervoltage is expected to NB01 and NB02 in this fire area. The valve limit/torque switches for BGLCV0112C cannot be bypassed by fire damage to cable 4BGG12BD. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 21 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 VFDR No. A-01-008 BGLCV0112C-P - Cable damage (4BGG12BD) to BGLCV0112C. Cable damage can spuriously close the Chemical Volume Control System Volume Control Tank Outlet Upstream Isolation Valve, BGLCV0112B (spurious closure is only credible assuming external hot shorts), may also cause the valve to fail as-is (open). Similar failure mode(s) may also occur for BGLCV0112B-P, the Chemical Volume Control System Volume Control tank Outlet Downstream Isolation Valve, due to cable damage (1BGG12AD).

Both of these valves are required open (i.e., to not spuriously close) to prevent failure of the Credited Charging Pump (when running) from a loss of suction. After the Charging Pump Suction flowpath has been aligned to the Refueling Water Storage Tank, either one of these valves is required to close on demand in order to isolate the Charging Pump Suction flowpath from the Volume Control tank to prevent gas binding of the Credited Charging Pump. Note that access to these valves requires the plant operator to transit through the fire affected area. The valve limit/torque switches for BGLCV0112B can be bypassed by fire damage to cable 1BGG12AD. No loss of offsite power or spurious undervoltage is expected to NB01 and NB02 in this fire area.

The valve limit/torque switches for BGLCV0112C cannot be bypassed by fire damage to cable 4BGG12BD. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-009 BNLCV0112D - Cable damage (1BNG01AA and 1BNG01AB) to BNLCV0112D. Cable damage cannot spuriously open or close Charging Pump A Suction from Refueling Water Storage Tank Isolation Valve, BNLCV0112D, but may cause the valve to fail as-is (closed). A similar failure mode may also occur for BNLCV0112E, the Charging Pump B Suction from Refueling Water Storage Tank Isolation Valve, due to cable damage (4BNG01BA and 4BNG01BB). Either one of these valves is required to open on demand to align the Refueling Water Storage Tank as the source of Reactor Coolant System Inventory makeup to the Credited Charging Pump, and to prevent failure of the Credited Charging Pump (when running) from a loss of suction. Note that access to these valves requires the plant operator to transit through the fire affected area. The valve limit/torque switches for BNLCV0112D can be bypassed by fire damage to cable 1BNG01AB. The valve limit/torque switches for BNLCV0112E can be bypassed by fire damage to cable 4BNG01BB. No loss of offsite power or spurious undervoltage is expected to NB01 and NB02 in this fire area.

This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

August 2011 Page C-11

Enclosure 2 to ULNRC-06031 Page 22 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 VFDR No. A-01-010 EMHV8803A - Cable damage (1EMG02AA and 1EMG02AB) to EMHV8803A. Boron Injection Header Supply from Charging Pump A Isolation Valve, EMHV8803A, cannot spuriously open or close due to cable damage (1EMG02AA and 1EMG02AB).

However, the valve may also fail as-is (closed). The desired position for this valve is throttled open to establish the train A Boron Injection Flowpath, which may become necessary to restore pressurize level (maintain positive control over RCS inventory and pressure) if RCS inventory makeup with alternate RCP Seal Injection is not sufficient. Note that access to this valve requires the plant operator to transit through the fire affected area. The valve limit/torque switches for EMHV8803A can be bypassed by fire damage to cable 1EMG02AB. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-01-011 PZR-HTR-BU-A - Backup Pressurizer Heater Groups A and B are subject to cable damage and/or loss of DC control power (cables 5BBG22AD and 5BBG22AG for the Group A Heaters, the breaker PG2101 close/trip control cables - cable 6PKG11BA for the Group B Heaters, the AC power cable to battery charger PK22, ultimately causing loss of DC control power for Breaker PG2201). Neither backup group of pressurizer heaters is available for safe shutdown in this fire area. Loss of pressurizer heater capability may adversely impact the ability of the plant to maintain safe and stable (potential adverse impact to RCS pressure control). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue. (Both backup groups of pressurizer heaters are recoverable with local manual operator actions).

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 23 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 VFDR No. A-01-012 SGK05B - No direct cable damage to SGK05B. Loss of battery charger - 125VDC No. 2, PK22, to Switchboard 125 VDC Bus, PK02, from cable damage (6PKG11BA) results in the eventual loss of 125 VDC power for the Fire Protection Interlock Circuit.

Loss of 125 VDC power for the Fire Protection Interlock will result in a loss of ventilation from the Train B ESF Switchgear rooms air conditioning unit, SGK05B. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 24 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 1101 Detection 100 Ionization Y N N N N Suppression SKC43 Pre-action Y N N N N Feature None ERFBS Y N N Y N 1102 Detection 100 Ionization Y N N N N Detection 101 Ionization Y N N N N Suppression SKC43 Pre-action Y N N N N Feature None N/A 1103 Detection None N/A Suppression None N/A Feature None N/A 1104 Detection None N/A Suppression None N/A Feature None N/A 1105 Detection None N/A Suppression None N/A Feature None N/A 1106 Detection None N/A Suppression None N/A Feature None N/A 1115 Detection 101 Ionization N N N N N Suppression None N/A Feature None N/A August 2011 Page C-14

Enclosure 2 to ULNRC-06031 Page 25 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 1120 Detection 101 Ionization N N N N N Detection 102 Ionization N N N N N Suppression SKC43 Pre-action Y Y N N N provides water curtain for hatch Feature None N/A 1121 Detection 101 Ionization N N N N N Suppression None N/A Feature None N/A 1122 Detection 100 Ionization Y Y N N N activates hatch water curtain Detection 101 Ionization N N N N N Suppression SKC43 Pre-action Y Y N N N provides water curtain for hatch Feature None N/A 1123 Detection None N/A Suppression None N/A Feature None N/A 1124 Detection None N/A Suppression None N/A Feature None N/A 1125 Detection None N/A Suppression None N/A Feature None N/A 1128 Detection 117 Ionization N N N N N Suppression None N/A Feature None N/A August 2011 Page C-15

Enclosure 2 to ULNRC-06031 Page 26 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 1129 Detection None N/A Suppression None N/A Feature None N/A 1130 Detection 100 Ionization Y Y N N N Suppression SKC43 Pre-action Y N N N N Feature None N/A 1201 Detection 102 Ionization N N N N N Suppression None N/A Feature None N/A 1202 Detection None N/A Suppression None N/A Feature None N/A 1203 Detection None N/A Suppression None N/A Feature None N/A 1204 Detection None N/A Suppression None N/A Feature None N/A 1205 Detection None N/A Suppression None N/A Feature None N/A August 2011 Page C-16

Enclosure 2 to ULNRC-06031 Page 27 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 1206 Detection 120 Ionization Y N N N N Suppression SKC48 Wet Pipe Y N N N N Feature None 20-ft Separation Zone Y N N N N Feature None ERFBS Y N N Y N 1207 Detection 120 Ionization Y N N N N Suppression SKC48 Wet Pipe Y N N N N Feature None 20-ft Separation Zone Y N N N N Feature None ERFBS Y N N Y N 1329 Detection None N/A Suppression None N/A Feature None N/A Legend: Required?

S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Licensing Action E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation August 2011 Page C-17

Enclosure 2 to ULNRC-06031 Page 28 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-1 Auxiliary Building - El. 1974, 1988 Fire Suppression Effects on Nuclear Safety Performance Criteria The effects of moderate energy line break and flooding which include rupture and inadvertent actuations from a Fire Protection System pipe break were evaluated as documented in FSAR Chapter 3. In FSAR Section 3.1.3 it states "Fire fighting systems are designed to assure that their rupture or inadvertent operation will not prevent systems important to safety from performing their design functions. In the areas, drains minimize the potential for flooding damage, such that the standing water would not affect safety-related equipment. Safety related electrical motors are on pedestals and are designed and sealed to be water resistant. Safety related electrical cable in tray is qualified for water exposure. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.

Fire Area Comments To meet deterministic separation criteria Fire Zones 1206 and 1207 have a 20-foot separation zone free of intervening combustibles with automatic detection and suppression. The 20-foot separation zone is clearly marked on the floor and designated as a "No Storage" location.

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Enclosure 2 to ULNRC-06031 Page 29 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A Fire Zone Description 1323 Pipe Penetration Room A Regulatory Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments Decay Heat Removal - CSD Use RHR Train B, with cooling water provided by CCW Pumps B and D.

Decay Heat Removal - HSB Steam Generators A and D are supplied by MDAFW Pump B. See VFDR No. A-24-001 and A-24-002 Process Monitoring RCS Pressure Channels I and II Pressurizer Pressure Channel I Pressurizer Level Channel I Ex-core Neutron Monitoring Channel I RCS Loop A (1) T-hot Temperature Channel I RCS Loop A (1) T-cold Temperature Channel II Steam Gen. A Pressure Channel I Steam Gen. A Wide Range Level Channel I Steam Gen. A Atmos. Steam Dump Pressure Channel I Aux. Feedwater Flow to Steam Gen. A Channels I and IV RCS Loop D (4) T-hot Temperature Channels II and VI RCS Loop D (4) T-cold Temperature Channels I and VI Steam Gen. D Pressure Channel I Steam Gen. D Wide Range Level Channel IV Steam Gen. D Atmos. Steam Dump Pressure Channel IV Aux. Feedwater Flow to Steam Gen. D Channel IV Aux. Feedwater Pump B Suction Pressure Channel IV Aux. Feedwater Pumps Low Suction Pressure (LSP - Auto Transfer to ESW)

Channels I and IV Condensate Storage Tank Level Channel VI Refueling Water Storage Tank Level Channel I Volume Control Tank Level Channels I and IV Containment Pressure Channels II, III, and IV August 2011 Page C-180

Enclosure 2 to ULNRC-06031 Page 30 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A Core Exit Thermocouples Train A (Channel I and V) and Train B (Channel IV and VI)

RCS Inventory Control Maintain inventory and RCP seal integrity using Charging Pump B via the Boron See VFDR No. A-24-003 and A-24-004 Injection flowpath and the Alternate RCP Seal Injection flowpath. RCS RV Head Vent flowpath Train B is available for letdown of RCS inventory, if necessary.

RCS Pressure Control Control pressure using Pressurizer Heater Backup Group B. Use PORV (BBPCV0456A) to depressurize.

Reactivity Control Trip reactor from Control Room. Use Charging Pump B to inject borated water from the RWST.

Vital Auxiliaries Operate CCW Pumps B and D, and ESW Pumps A and B. Offsite Power to NB01 and NB02 credited. HVAC credited for Main Control Room and Containment (Train B credited).

Reference Documents Calculation KC-26, Nuclear Safety Capability Assessment, Rev. 0 Licensing Actions Licensing Action Title Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Containment Mechanical Penetrations Summary Deviation submitted per 3/14/1984 SNUPPS letter to the NRC, justifying non-rated mechanical penetrations (process and sampling lines and containment purge penetration) in the reactor containment walls to Fire Areas A-19, A-20, A-23, A-24 and A-25, was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. The containment wall is 4-foot-thick reinforced concrete with a continuous 1/4-inch-thick steel liner.

2. Construction is capable of withstanding a 60-psig overpressure without failure.

3. Penetrations serve special nuclear safety-related purpose.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

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Enclosure 2 to ULNRC-06031 Page 31 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A Existing Enginering Equivalency Evaluations (EEEE)

EEEE Title Engineering Evaluation RFR 201009031 Summary Auxiliary steel members that were not protected and represent thermal shorts have been evaluated and were found to have no adverse effect on the protected structural steel's function in the event of a fire, based on the fire hazards within the fire area.

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Enclosure 2 to ULNRC-06031 Page 32 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A Variances from Deterministic Requirements (VFDR)

VFDR No. A-24-001 ABPV0002-P - Cable damage (2ABI20FE and 2ABI20FH) to Pressure Transmitter ABPT0002. Cable damage can spuriously open the Atmospheric Steam Dump Valve, ABPV0002. The valve is required closed to isolate the main steam pressure boundary for Steam Generator B, to maintain positive control over the rate of RCS cooldown, and to maintain RCS sub-cooling. Note that Steam Generator B is not credited for Decay Heat Removal in this fire area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

VFDR No. A-24-002 ABPV0003-P - Cable damage (3ABI20GA and 3ABI20GE) to Pressure Transmitter ABPT0003. Cable damage can spuriously open the Atmospheric Steam Dump Valve, ABPV0003. The valve is required closed to isolate the main steam pressure boundary for Steam Generator C, to maintain positive control over the rate of RCS cooldown, and to maintain RCS sub-cooling. Note that Steam Generator C is not credited for Decay Heat Removal in this fire area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

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Enclosure 2 to ULNRC-06031 Page 33 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A VFDR No. A-24-003 BGHV8105 - Cable damage (4BGG11AA and 4BGG11AB; and 1BGG11BA and 1BGG11BB) to BGHV8105 and BGHV8106 respectively. Cable damage cannot spuriously open or close Chemical Volume and Control System Charging Header to Regenerative Heat Exchanger Outer Containment Isolation Valves, BGHV8105 and BGHV8106. However, the valves may close in response to a valid or spurious SIS. In this case, cable damage could bypass the open/close limit/torque switches. However, the required position for these valves is closed. The valves may also fail as-is (open). Either one of these valves is required closed to prevent potential adverse impact (i.e., flow diversion) to the NFPA 805 NSPC credited flowpaths of the chemical volume and control system (i.e., the boron injection and the alternate RCP seal injection flowpaths). Either one of these valves is required closed to also mitigate spurious operation of downstream valves BGHV8145 (Pressurizer Auxiliary Spray), BGHV8146 (Loop 1 Cold Leg Injection), and BGHV8147 (Loop 4 Cold Leg Injection), which are not included in the safe shutdown model, and which could adversely impact the ability to maintain positive control over RCS Inventory and Pressure. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. A-24-004 EMHV8801B - Cable damage (4EMG02DA and 4EMG02DB) to EMHV8801B. Boron Injection Header Train B Outlet to Cold Legs Isolation Valve, EMHV8801B, cannot spuriously open or close due to cable damage (4EMG02DA and 4EMG02DB). However, the valve may also fail as-is (closed). The desired position for this valve is open to establish the Train B boron injection flowpath, which may become necessary to restore pressurizer level (maintain positive control over RCS Inventory and Pressure) if RCS inventory makeup with alternate RCP seal injection is not sufficient. Note that EMHV8801B is physically located in the fire affected area. The valve limit/torque switches for EMHV8801B can be bypassed by fire damage to cable 4EMG02DB. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

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Enclosure 2 to ULNRC-06031 Page 34 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 A-24 Containment Mechanical Piping Penetration Room A Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 1323 Detection 117 Ionization Y N N Y N Suppression None N/A Feature None ERFBS Y N N Y N Legend: Required?

S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Licensing Action E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria There are no automatic fire suppression systems in the fire area. In the areas, drains minimize the potential for flooding damage, such that the standing water would not affect safety-related equipment. Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.

Fire Area Comments None August 2011 Page C-185

Enclosure 2 to ULNRC-06031 Page 35 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B Fire Zone Description 3302 ESF Switchgear Room No. 2 Regulatory Basis 4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptions Performance Goal Method of Accomplishment Comments Decay Heat Removal - CSD Use RHR Train A, with cooling water provided by CCW Pumps A and C.

Decay Heat Removal - HSB Steam Generators B and C are supplied by MDAFW Pump A. See VFDR No. C-10-001, C-10-002, C 005, and C-10-008 Process Monitoring RCS Pressure Channel I Pressurizer Pressure Channel I Pressurizer Level Channel I Ex-core Neutron Monitoring Channel I RCS Loop B (2) T-hot Temperature Channel I Steam Gen. B Pressure Channel I Steam Gen. B Narrow Range Level Channel III Aux. Feedwater Flow to Steam Gen. B Channel I RCS Loop C (3) T-cold Temperature Channels I and V Steam Gen. C Pressure Channel I Steam Gen. C Wide Range Level Channel III Steam Gen. C Atmos. Steam Dump Pressure Channel III Aux. Feedwater Flow to Steam Gen. C Channels I and III Aux. Feedwater Pump A Suction Pressure Channel I Refueling Water Storage Tank Level Channel I Volume Control Tank Level Channel I Containment Pressure Channels II, III, and IV Core Exit Thermocouples Train A (Channel I and V)

RCS Inventory Control Maintain inventory and RCP seal integrity using Charging Pump A via the Boron See VFDR No. C-10-003, C-10-004, C Injection flowpath and the Alternate RCP Seal Injection flowpath. RCS RV Head Vent 006, and C-10-007 flowpath Train A is available for letdown of RCS inventory, if necessary.

August 2011 Page C-271

Enclosure 2 to ULNRC-06031 Page 36 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B RCS Pressure Control Control pressure using Pressurizer Heater Backup Group A. Use PORV (BBPCV0455A) to depressurize.

Reactivity Control Trip reactor from Control Room. Use Charging Pump A to inject borated water from the RWST.

Vital Auxiliaries Operate CCW Pumps A and C, and ESW Pump A.

Onsite power to NB01 credited.

HVAC credited for Main Control Room and Containment (Train A credited).

Thermal Barrier Cooling remains available for RCP Seal Cooling.

Reference Documents Calculation KC-26, Nuclear Safety Capability Assessment, Rev. 0 Licensing Actions None August 2011 Page C-272

Enclosure 2 to ULNRC-06031 Page 37 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B Existing Enginering Equivalency Evaluations (EEEE)

EEEE Title Engineering Evaluation RFR 201000502 Summary The detectors in beam pockets in Fire Zone 3302 that are not installed in accordance with Section 4-3.7.3 of NFPA 72E-1978 Edition are acceptable based on lack of ignition sources and the small width of beam pockets (4'). In addition, high air flow in the area is anticipated to spread out smoke to adjacent beam pocket spaces containing detectors.

EEEE Title Engineering Evaluation RFR 201009031 Summary Auxiliary steel members that were not protected and represent thermal shorts have been evaluated and were found to have no adverse effect on the protected structural steel's function in the event of a fire, based on the fire hazards within the fire area.

August 2011 Page C-273

Enclosure 2 to ULNRC-06031 Page 38 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B Variances from Deterministic Requirements (VFDR)

VFDR No. C-10-001 ABPV0002-P - Cable damage (2ABI20FE, 2ABI20FG, 2ABI20FH, 2ABI20FJ, 2ABI20FK, 2ABI20FL, 2ABI20FM, 2ABI20FN, and 2RPY09BA) to Pressure Transmitter ABPT0002. Cable damage can spuriously open the Atmospheric Steam Dump Valve, ABPV0002. The valve is required closed to isolate the main steam pressure boundary for Steam Generator B, to maintain positive control over the rate of RCS cooldown, and to maintain RCS sub-cooling. Note that Steam Generator B is credited for Decay Heat Removal in this fire area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

VFDR No. C-10-002 ABPV0004-P - Cable damage (4ABI20HE, 4ABI20HG, 4ABI20HH, 4ABI20HJ, 4ABI20HK, 4ABI20HL, 4ABI20HM, 4ABI20HN, and 4RPY09GA) to Pressure Transmitter ABPT0004. Cable damage can spuriously open the Atmospheric Steam Dump Valve, ABPV0004. The valve is required closed to isolate the main steam pressure boundary for Steam Generator D, to maintain positive control over the rate of RCS cooldown, and to maintain RCS sub-cooling. Note that Steam Generator D is not credited for Decay Heat Removal in this fire area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

August 2011 Page C-274

Enclosure 2 to ULNRC-06031 Page 39 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B VFDR No. C-10-003 Valve BGLCV0112C may spuriously close due to valve control cable damage (4BGG12BC and 4BGG12BD). Train A 4kV Switchgear NB01 may sustain a real or spurious loss of offsite power due to the following cable failures: 2NFK01CA, 2NFY01EA, 4NFK01CA, and 4NFY01EA (affecting LSELS-GRP1 - Train A load shed/load sequencer, NB01 voltage monitoring inputs);

5NBB06AA, 5NBB06AB, and 5NBB06AC (power cables from XNB01 to NB01 and NB02 breakers NB0112 and NB0212);

6NBA10AB and 6NBB03AB (protective trip cables for XNB01 switchyard feeder breaker MD523). A real or spurious loss of offsite power affecting train a 4kV Switchgear NB01 could initiate a loss of offsite power (LOOP) actuation of the Train A load shed/load sequencer. This would start normally idle Charging Pump A (the credited charging pump for safe shutdown), which could then fail due to loss of pump suction from spurious closure of BGLCV0112C. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. C-10-004 EMHV8803B-P - No cable damage to EMHV8803B. The Boron Injection Header Supply from Charging Pump B Isolation Valve, EMHV8803B, fails due to loss of power (from MCC NG04C). This non-credited train valve cannot be re-closed if opened by SIS and then subject to loss of power. The valve may need to be closed, or non-credited train Charging Pump B may need to be secured in order to ensure positive control over RCS Inventory and Pressure (to prevent pressurizer overfill). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

August 2011 Page C-275

Enclosure 2 to ULNRC-06031 Page 40 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B VFDR No. C-10-005 FCHV0312-P - Cable damage (2FCK23AA, 2FCK23AP, 2FCK23AQ, 2FCK23AR, 2FCK23AS, 2FCK23AT, 2FCK23AU, 2FCK23AX, 2RPK09BA, and 2RPK15CA) to FCHV0312-P. Cable damage can spuriously open Turbine Driven AFW Pump Trip and Throttle Valve FCHV0312-P, which could result in the inability to remotely secure the non-credited Turbine Driven AFW Pump. If running, the non-credited Turbine Driven AFW Pump could become an uncontrolled source of inventory addition into Steam Generators B and C, which could adversely impact the capability to maintain positive control over the rate of RCS cooldown, and to maintain RCS sub-cooling. Note that Steam Generators B and C are credited for Decay Heat Removal in this fire area. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

VFDR No. C-10-006 NB0201-P - Cable damage (4BGB01BA, 4BGB01BB, 4NBK15AA, and 4NBK15AB) to NB0201. Cable damage may result in spurious closure of the feeder breaker to Charging Pump B (PBG05B), NB0201. Non-credited train Charging Pump B may need to be secured, or non-credited train valve EMHV8803B may need to be closed in order to ensure positive control over RCS Inventory and Pressure (to prevent pressurizer overfill). This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition A Recovery Action (RA) is credited for this VFDR to reduce risk due to a fire in this fire area. The RA has been demonstrated to be feasible. Reliability is addressed within the FPRA using HRA methods.

VFDR No. C-10-007 NB0202-P - Cable damage (4EMB01BA, 4EMB01BB, 4NBK15AA, and 4NBK15AB) to NB0202. Cable damage may result in spurious closure of the feeder breaker to Safety Injection Pump B (PEM01B), NB0202. Non-credited train Safety Injection Pump B may need to be secured in order to prevent potential diversion of RWST inventory. The action to secure flow from the Safety Injection Pump is a conservative measure taken to mitigate the potential for pumped RWST flow diversion through the SIS test lines and/or the SIS accumulator fill lines, which have not been fully analyzed for all of the possible spurious valve operations.

This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

August 2011 Page C-276

Enclosure 2 to ULNRC-06031 Page 41 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B VFDR No. C-10-008 NB0205-P - Cable damage (4ALB01BA, 4ALB01BJ, 4ALB01BK, 4ALB01BL, 4ALB01BM, 4ALB01BN, 4RPK15AA, 4NBK15AA, 4ALB01BH, 4RPK09NA, 4ALB01B2, 4ALB01BG, and 4NBK15AB) to NB0205. Cable damage may result in spurious closure of the feeder breaker to Motor Driven Auxiliary Feedwater Pump B (PAL01B), NB0205. Non-credited train Motor Driven Auxiliary Feedwater Pump B may need to be secured in order to ensure positive control over the rate of RCS cooldown, and to maintain sub-cooling. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issue.

Disposition The VFDR has been evaluated and it was determined that the risk, safety margin, and defense-in-depth meet the acceptance criteria of NFPA 805 Section 4.2.4, therefore, no further action is required.

August 2011 Page C-277

Enclosure 2 to ULNRC-06031 Page 42 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire AreaTransition Unit Fire Area Description 1 C-10 ESF Switchgear Room B Required Fire Protection Systems and Features REQUIRED FIRE PROTECTION SYSTEMS AND FEATURES Required?

Fire Zone Category ID Type Notes S L E R D 3302 Detection 316 Ionization N N N Y N Detection 317 Ionization N N N Y N Suppression SKC01 Halon N N N Y N Feature None ERFBS N N N Y N Legend: Required?

S - Required for Chapter 4 Separation Criteria L - Required for NRC-Approved Licensing Action E - Required for Existing Engineering Equivalency Evaluation R - Required for Risk Significance D - Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk Evaluation Fire Suppression Effects on Nuclear Safety Performance Criteria Halon system actuations are not expected to adversely affect electrical equipment. Any fire can be extinguished manually with the portable extinguishers and/or hose stations after high-voltage equipment is de-energized. Safety related electrical cabinets are mounted on pedestals to protect against water effects and are sealed at the top. The water associated with manual fire suppression will drain out doors and as such standing water would not affect safety-related equipment.

Therefore, fire suppression activities are not expected to adversely affect achievement of the nuclear safety performance criteria.

Fire Area Comments None August 2011 Page C-278

Enclosure 2 to ULNRC-06031 Page 43 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report Attachment C - Table B-3 Fire Area Transition Unit Fire Area Description 1 C-28 Control Room Service Area

1. Minimal fire hazards.

2. Availability of manual firefighting equipment.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

Existing Enginering Equivalency Evaluations (EEEE)

EEEE Title Engineering Evaluation RFR 19347A Summary Keeping Fire Door DSK36021 between the Control Room (Room 3601, Fire Area C-27) and the Control Room Pantry (Room 3602, Fire Area C-28) in the held-open position is acceptable based on the fact that the door is in the direct view of Control Room operators, the Control Room is continuously manned, and a heat detector is installed in Room 3602.

EEEE Title Engineering Evaluation RFR 201009031 Summary Auxiliary steel members that were not protected and represent thermal shorts have been evaluated and were found to have no adverse effect on the protected structural steel's function in the event of a fire, based on the fire hazards within the fire area.

Variances from Deterministic Requirements (VFDR)

None August 2011 Page C-480

Enclosure 2 to ULNRC-06031 Page 44 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report

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%DVLV'DWH 5/1984 7R%H7UDQVLWLRQHG" Yes

%DVLV Deviation submitted per 2/1/1984 SNUPPS letter to the NRC, providing documentation of evidence that the SNUPPS penetration seal design will provide an effective 3-hr fire barrier, was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. ASTM E 119 test shows fire would not spread to the unexposed side of a protected fire barrier during a 3-hour test period.

2. Few, if any, fire areas in the plant contain 3-hour combustible loading.

This deviation is active per Section 9.5.1.2.2.3 of the current FSAR SP. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

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,QLWLDO5HTXHVW "Responses To NRC Fire Protection Audit Concerns," dated 2/1/1984.

The 2/1/1984 SNUPPS letter to the NRC states:

The purpose of the comprehensive test program for SNUPPS penetration seals is to provide documented evidence that penetration seals used on SNUPPS will satisfactorily withstand an ASTM E 119-80 fire exposure and conclusively demonstrate that these seals will provide an effective 3-hour fire barrier.

All fire rated penetration seals were tested by an independent testing laboratory utilizing the following for test guidance:

a. ASTM E 119-80, Standard Methods of Fire Tests of Building Construction and Materials.

b. ANI/MAERP Standard Method of Fire Tests of Cable and Pipe Penetration Fire Stops.

C. IEEE 634-1978, Cable Penetration Fire Stop Qualification Test.

The test program, procedures, and results were approved by ANI.

The acceptance criteria is consistent with the test standards identified above. They include:

1. Fire shall not propagate to the unexposed side of the test assembly nor shall any visible flaming occur.

2. No individual thermocouple of the unexposed surface of the fire stop shall exceed 325°F above ambient temperature.

3. No opening develops that permits a projection of water from the stream beyond the unexposed surface during the hose stream test.

All penetration seals used on SNUPPS meet or exceed those seals successfully tested as detailed above.

August 2011 Page K-12

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The following are vendor print register numbers to establish traceability of the reports in the plant filing system:

10466-M-663-0024 10466-M-663-0060 10466-M-663-0061 10466-M-663-0062 10466-M-663-0082 10466-M-663-0083 These documents have been made available to the NRC staff fire protection auditor.

6(5 NRC NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No.1," Supplement 3, dated May 1984 In NUREG-0830, Supplement 3, dated 5/1984, the NRC states:

The staff has continued its review of the Callaway fire protection program on the basis of a site audit and information provided by the applicant by letters dated February 1 and 24, 1984. The results of the review are discussed below. In addition to finding that the applicants program conforms to the staffs guidelines, the staff also approved three deviations from the guidelines. These areas of approved deviation, which also are discussed below, are: (1)penetration seals acceptance criteria Branch Technical Position (BTP)

CMEB 9.5-1, Section C.5.

Fire Barriers and Fire Barrier Penetrations Where safe shutdown equipment is enclosed by a fire barrier, all walls, ceilings, floors, and associated penetrations that enclose the equipment have a minimum fire rating of 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months with the following exceptions: 1-1/2 hour elevator doors, pressure, watertight, and missile-resistant doors, and equipment hatches in the auxiliary building. For fire areas that do not have a 3-hour-fire-rated assembly because of the installation of these doors, each area was evaluated with respect to its fuel load, fire suppression and detection systems, and proximity to safe shutdown equipment to determine if the fire-rated assemblies provided are adequate for the areas affected and meet the guidelines in Section D.1.j of Appendix A to BTP ASB 9.5-1. On the basis of this evaluation, the staff finds the above fire barriers for these areas acceptable.

The applicant has agreed to provide 3-hour-approved designs for all fire penetration seals used in the penetration cable trays, conduits, and piping that pass the penetration qualification tests, including the time-temperature exposure fire curve specified by Standard E-119, Fire Test of Building Construction and Materials, of the American Society for Testing and Materials (ASTM).

By letter dated February 1, 1984, the applicant stated that the acceptance criterion for the penetration qualification test was in excess of the 325°F maximum temperature permitted on the unexposed side by ASTM E-119. The applicant stated that the acceptance criterion used was a maximum temperature rise on the unexposed surface of the fire stop of 325°F above ambient. In addition, at no time during the test August 2011 Page K-13

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Barriers and Fire Barrier Penetrations (C.5 criteria) period did any visible flaming occur on the unexposed side of the test assembly, and no openings developed that permitted the hose stream test to penetrate the seals.

Although the penetration seals do not meet the specific ASTM E-119 temperature rise limitations, the test results showed that fire would not spread to the unexposed side of a protected fire barrier during a 3-hour test period. Few if any areas in the plant contain a 3-hour combustible loading. Therefore, the staff has reasonable assurance that the integrity and temperature transmission through the penetration assembly will not affect the capability to achieve and maintain safe shutdown considering the effects of a fire involving fixed and potential transient combustibles in the plant.

On the basis of its evaluation, the staff concludes that the protection provided for fire barriers and fire barrier penetrations is an acceptable deviation from the guidelines in Section C.5 of BTP CMEB 9.5-1, and is, therefore, acceptable.

August 2011 Page K-14

Enclosure 2 to ULNRC-06031 Page 47 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report

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%DVLV'DWH 5/1984 7R%H7UDQVLWLRQHG" Yes

%DVLV Deviation submitted per 2/1/1984 SNUPPS letter to the NRC, providing justification for the SNUPPS fire detection power supplies deviating from the recommended design of NFPA 72D, was approved by the NRC in NUREG-0830, Supplement 3, dated 05/1984 based on the following:

1. In the event of loss of power to the remote panels causing loss of automatic activation of some pre-action sprinklers, the Control Room would be alarmed and, per Plant Technical Specifications, a continuous fire watch would be established.

2. These sprinkler systems remain operable manually.

This deviation is active per Section 9.5.2.2.1 of the current FSAR SP. Per verification of plant fire panel drawings, this deviation reflects the current plant configuration. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.

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,QLWLDO5HTXHVW "Responses To NRC Fire Protection Audit Concerns," dated 2/1/1984.

The 2/1/1984 SNUPPS letter to the NRC states:

The NRC auditors indicated that the design of the SNUPPS protection system power was not in accordance with NFPA 72D and that standby power to remote fire protection panels and multiplexers should consist of 4 hr. rated batteries located at the panel.

The NRC previously questioned the design of the fire and smoke detection system. Refer to FSAR page 9.5D-5, attached. The following expands on the response.

The fire detection control panels provided for SNUPPS consist of four (4) multiplexers and multiple remote fire protection panels. The four multiplexers contain the systems transmitters/receivers which are in communication with a main annunciator/alarm panel. The remote fire protection panels provide the interface between suppression systems and the multiplexers. The following is an analysis of panel primary and backup power supplies. It serves as a basis for taking exception to the NRC interpretation of NFPA 72D requiring that the backup DC system consists of 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months rated batteries located at the local panels.

A. MULTIPLEXERS

1. Primary Power Supply The primary power for the multiplexers is the non-Class 1E instrument ac system. The non-Class 1E August 2011 Page K-15

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria) instrument ac system is continuously supplied by the Class 1E ac emergency power system.

The preferred and normal source of the Class 1E power system is the offsite power system. Two physically independent sources of offsite power are fed to the onsite power system. SNUPPS exceeds the minimum requirements of NFPA 72D (1979) which permits the primary power supply to consist of a single branch circuit connection to the light and power service.

2. Secondary Power Supply The standby power for the multiplexers is provided from multiple sources.

A. Secondary power is provided by the station emergency diesel generator to each 4.16 Kv bus. The arrangement, fuel supply etc. of the SNUPPS station diesel exceeds the minimum requirements of NFPA 72D (1979).

B. A backup power source is provided by the non-Class 1E 125V dc system. An automatic auctioneering circuit at each multiplexer selects the dc source upon failure of all ac sources, and reverts back to the ac source upon ac source restoration.

C. The non-Class 1E 125 V dc system is supplied through batteries and battery chargers. The battery chargers are sized to carry the total connected load indefinitely. The battery chargers are normally fed from the Class 1E emergency power system. The batteries and chargers are not installed in series. This maintains power to the system upon failure of either the charger or the battery if primary power is normal.

Upon failure of a battery charger, each separation group battery can carry the total connected load for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Additional load carrying time can be obtained by selective load shedding and/or closing the bus tie switches between the separation group buses.

B. REMOTE (LOCAL) FIRE PROTECTION PANELS

1. Primary Power Supply The primary power for the remote fire protection panels is provided by the non-Class 1E 125V dc system.

The multiplexers are utilized as power distribution panels for the remote panels. The non-Class 1E 125V dc system is continuously supplied by the 480V 1E bus via the battery chargers. The reliability of this power supply exceeds the requirements of NFPA 72D. Two physically independent offsite power sources provide the normal and preferred source to this system.

2. Secondary (Standby) Power Supply The standby power source for the secondary supply to the local panels is provided by the station emergency diesel generators. The arrangement, fuel supply, etc. of the station diesels exceeds the minimum requirements of NFPA 72D.

The non-Class 1E 125V dc system is supplied through batteries and battery chargers. The battery chargers are sized to carry the total connected load indefinitely. The battery chargers are fed from the Class 1E emergency power system. The batteries and chargers are not installed in series. This maintains power to the system upon failure of either the charger or the battery if primary power is normal.

In the event of a battery charger failure, each battery can carry the dc loads for approximately 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

This assumes that ac sources are still available for other non 1E loads. This exceeds the 4 hr.

requirement of NFPA 72D. Furthermore, all cables are routed to local panels in conduit and supervised for August 2011 Page K-16

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria) integrity. Loss of power to these local panels is immediately alarmed in the control room on the fire protection annunciator. Each local panel is powered through dedicated terminals at the multiplexer. No panels are powered in series.

3. Effects of Loss of dc to Local Panels The following is an analysis of the effects of dc power loss to local fire protection panels.

A. Loss of dc to Typical Local Panel Types

1. Pre-action Local Control Panels without Detectors Loss of dc power due to a power feed line break to a Preaction Control Panel that is not directly actuated by an automatic detection device will initiate an immediate trouble signal to the control room. Preaction Systems that incorporate these panels control suppression by a signal generated directly from the appropriate multiplexer. The early warning detection circuits associated with these Preaction Systems is supervised directly by the appropriate Multiplexer. Loss of dc power to the control panel will prevent the automatic activation of the suppression system. System actuation is maintained through direct manual (mechanical) means.

Where these systems are used to service safety related areas or equipment, automatic detection is maintained because the detection circuits are supervised directly by the Multiplexer which is not affected by loss of dc power to the Pre-action Control Panel.

2. Pre-action Local Control Panels with Thermal Detectors Loss of dc power due to a power feed line break to a Pre-action Control Panel directly actuated by thermal detection devices will initiate an immediate trouble signal in the control room. The panel will lose capability of transmitting a fire alarm signal to the annunciator control board and of automatically actuating the suppression system. System actuation is maintained through direct manual (mechanical) means.

Where these systems are used to service safety related areas or equipment, a primary independent detection system is incorporated in the fire detection system. The detection system consists of infrared or ionization early warning devices that are supervised directly by the appropriate multiplexer. The multiplexers are not affected by loss of dc power to the Preaction Control Panel; detection is maintained in the safety related area.

3. Local Panel Serving Halon 1301 Systems Loss of dc power to a local panel servicing a Halon 1301 system will not affect the detection capabilities for the area protected. The crossed zoned ionization detectors are fed by the multiplexer which is provided with ac and dc sources. Loss of dc to the local panel is immediately alarmed in the control room.

Detection capabilities are not lost for any area provided with Halon 1301 systems. This includes both safety and non-safety areas. Remote indication of manual Halon system discharge is maintained.

4. Local Panels Serving Wet Pipe Systems Loss of dc power due to a power feed line break to a local panel servicing a wet pipe system will have August 2011 Page K-17

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria) minimal effect on system operation. The only functional loss will be the local alarm bell that activates on water flow. Remote alarm of water flow in the control room will not be affected.

Detection provided in safety-related areas protected with wet pipe systems are not affected by loss of dc as they are fed from the multiplexers which have both ac and dc sources.

B. Total Loss of dc Total loss of dc power is not credible. However, the SNUPPS fire detection and suppression system design minimizes the effects of this event on automatic suppression and detection capabilities for safety-related areas. A review was done disregarding the multiple, independent power sources available for the local fire protection panels and conservatively assuming total loss of all dc power sources. Simultaneous line breaks of each power cable serving a local panel (a total of 42) would cause this.

In this event, total detection is not lost for any safety related area. Remote indication of suppression system manual actuation is maintained. Loss of power is immediately alarmed in the control room.

Only the following non-safety areas will lose both automatic suppression capabilities and detection:

a. Hydrogen Seal Oil Unit

b. Transformer Systems

c. Fuel Building RR Bay

d. Turbine Building 2000, 2033 Remote indication of manual actuation is maintained, and loss of dc power is immediately alarmed.

The primary and secondary power supplies provided for all panels in the fire detection system exceed the requirements of NFPA 72D. Also, if total loss of all dc power is conservatively assumed, only isolated, non-safety related areas will lose both automatic suppression capabilities and detection. Detection capabilities will be maintained for all areas containing safety-related equipment or circuits.

C. Compliance with NFPA 72D The basis for the NRC interpretation of NFPA 72D requiring the battery portion of the backup DC system to consist of 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months rated batteries located at the panels is an NFPA official interpretation dated August, 1977. This official interpretation was issued against the 1975 edition of NFPA 72D. A copy of this interpretation is included as Attachment A.

Official Interpretations (O.I.) are issued as a result of a question on a specific code application. They apply to all previous and subsequent code editions in which the text remains substantially unchanged. Per NFPA, due to the substantial rewrite of the power source section NFPA 72D in 1979, this O.I. was deleted on May 12, 1980 as it was no longer applicable.

Regardless of the status of the subject O.I., the power source configuration questioned is not similar to that provided for SNUPPS. The O.I. system has a secondary source consisting of a standby generator serving all locations and 4 hr. batteries for only the main control panel. As indicated by Attachment B, all panels in the SNUPPS system can be powered by 125V batteries.

August 2011 Page K-18

Enclosure 2 to ULNRC-06031 Page 51 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)

The O.I. specifies that given the indicated system power configuration, batteries with 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months capacity are required at location A. Location A is a campus building not specifically a panel. The intent of this O.I. is to reiterate the requirement that remotely located control equipment/panels be provided with primary and secondary power supplies as detailed in NFPA 72D, section 2-6 (Article 220 of 1975 edition). Clearly, the system described in the O.I. does not meet the intent of this section since a battery source is provided only to the control panel and is not provided to the local systems. Failure of the standby generator upon loss of normal power will render the local systems out of service due to the lack of a DC battery source.

As previously detailed, all SNUPPS panels are equipped with battery sources incorporated into the secondary power source. This ensures automatic continuing operation of all systems upon loss of primary power.

In summary, the primary and secondary power supplies provided for all panels in the fire detection system exceed the minimum requirements of NFPA 72D. Although the NFPA official interpretation is not applicable to the SNUPPS system, the preceding analysis provides an acceptable basis for taking exception to the NRC application of this interpretation.

6(5 NRC NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No.1," Supplement 3, dated May 1984 In NUREG-0830, Supplement 3, dated 5/1984, the NRC states:

The staff has continued its review of the Callaway fire protection program on the basis of a site audit and information provided by the applicant by letters dated February 1 and 24, 1984. The results of the review are discussed below. In addition to finding that the applicants program conforms to the staffs guidelines, the staff also approved three deviations from the guidelines. These areas of approved deviation, which also are discussed below, are: (3) fire detection power supplies (BTP CMEB 9.5-1, Section C.6.a)"

Fire Detection System The SER states that the plant fire detection system is installed in accordance with NFPA 72D. During its site visit, the staff noted that the back-up power supply may not meet the recommendations of NFPA 72D.

The applicant was unable to show compliance, and verbally agreed to prepare an analysis showing how the existing primary/back-up power supply circuitry compares to the requirements of NFPA 72D.

By letter dated February 1, 1984, the applicant provided the comparison. The applicants comparison indicated that the primary and secondary power supplies comply with the provision of NFPA 72D. In the event of loss of power to the remote panels, loss of automatic activation of some pre-action sprinklers would occur. Because the pre-action systems are continuously supervised, any loss of power would be alarmed in the control room. The Plant Technical Specifications would then require the establishment of a continuous fire watch. Because of the fire watch and the fact that the sprinkler systems remain operable manually, the staff finds this to be an acceptable deviation from its guidelines. On the basis of its review, the staff concludes that the fire detection system power supply is an acceptable deviation from its August 2011 Page K-19

Enclosure 2 to ULNRC-06031 Page 52 of 90 Ameren Missouri Callaway Plant NFPA 805 Transition Report

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/LFHQVLQJ$FWLRQ Appendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria) guidelines in Section C.6.a of BTP CMEB 9.5-1, and is, therefore, acceptable.

August 2011 Page K-20

ML13269A137

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