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. Th e 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 list s the reference documents

.

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 N on-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.

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.

Category IDRequired Fire Protection Feature and System DetailsRequired?S L E R DNFPA 805 Regulatory BasisTable 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and FeaturesType Fire Area Fire ZoneDescriptionAmeren MissouriCallaway Plant NFPA 805 Transition ReportA-1Auxiliary Building - El. 1974, 19884.2.4.21101100Ionization Y N N N NGeneral Floor Area No. 1A-1Detection1101SKC43Pre-action Y N N N NGeneral Floor Area No. 1A-1Suppression1101NoneERFBS Y N N Y NGeneral Floor Area No. 1A-1Feature1102100Ionization Y N N N NChiller and Surge Tanks AreaA-1Detection 1102 101Ionization Y N N N NChiller and Surge Tanks AreaA-1Detection1102SKC43Pre-action Y N N N NChiller and Surge Tanks AreaA-1Suppression1102None N/A-----Chiller and Surge Tanks AreaA-1Feature1103None N/A-----Letdown Chiller Heat Exchanger RoomA-1Detection1103None N/A-----Letdown Chiller Heat Exchanger RoomA-1Suppression1103None N/A-----Letdown Chiller Heat Exchanger RoomA-1Feature1104None N/A-----Letdown Reheat Heat Exchanger RoomA-1Detection1104None N/A-----Letdown Reheat Heat Exchanger RoomA-1Suppression1104None N/A-----Letdown Reheat Heat Exchanger RoomA-1Feature 1105 None N/A-----Valve CompartmentA-1Detection1105None N/A-----Valve CompartmentA-1Suppression1105None N/A-----Valve CompartmentA-1Feature August 2011 Page 51 Category IDRequired Fire Protection Feature and System DetailsRequired?S L E R DNFPA 805 Regulatory BasisTable 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and FeaturesType Fire Area Fire ZoneDescriptionAmeren MissouriCallaway Plant NFPA 805 Transition Report1206120Ionization Y N N N NPipe ChaseA-1Detection1206SKC48Wet Pipe Y N N N NPipe ChaseA-1Suppression1206None20-ft Separation Zone Y N N N NPipe ChaseA-1Feature1206NoneERFBS Y N N Y NPipe ChaseA-1Feature 1207 120Ionization Y N N N NPipe ChaseA-1Detection1207SKC48Wet Pipe Y N N N NPipe ChaseA-1Suppression1207None20-ft Separation Zone Y N N N NPipe ChaseA-1Feature1207NoneERFBS Y N N Y NPipe ChaseA-1Feature1329None N/A-----VestibuleA-1Detection1329None N/A-----VestibuleA-1Suppression1329None N/A-----VestibuleA-1Feature August 2011 Page 55 Category IDRequired Fire Protection Feature and System DetailsRequired?S L E R DNFPA 805 Regulatory BasisTable 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and FeaturesType Fire Area Fire ZoneDescriptionAmeren MissouriCallaway Plant NFPA 805 Transition ReportA-24Containment Mechanical Piping Penetration Room A4.2.4.21323117Ionization Y N N Y NPipe Penetration Room AA-24Detection1323None N/A-----Pipe Penetration Room AA-24Suppression1323NoneERFBS Y N N Y NPipe Penetration Room AA-24FeatureA-25Pipe Penetration Room B 4.2.3.2 1322 117Ionization N N N N NPipe Penetration Room BA-25Detection1322None N/A-----Pipe Penetration Room BA-25Suppression1322None N/A-----Pipe Penetration Room BA-25FeatureA-26Ops Storage/I&C Hot Shop4.2.3.21405118Ionization N N N N NOps Storage/I&C Hot ShopA-26Detection1405None N/A-----Ops Storage/I&C Hot ShopA-26Suppression1405None N/A-----Ops Storage/I&C Hot ShopA-26Feature August 2011 Page 71 Category IDRequired Fire Protection Feature and System DetailsRequired?S L E R DNFPA 805 Regulatory BasisTable 4-3 Summary of NFPA 805 Compliance Basis and Required Fire Protection Systems and FeaturesType Fire Area Fire ZoneDescriptionAmeren MissouriCallaway Plant NFPA 805 Transition Report C-8Control Building Cable Chase B, Control Building. El. 19844.2.3.23229300Ionization N N N N NElectrical Chase (South)

C-8Detection3229SKC37Wet Pipe N N N N NElectrical Chase (South)

C-8Suppression3229None N/A-----Electrical Chase (South)

C-8Feature C-9ESF Switchgear Room A 4.2.4.2 3301 314Ionization N N N Y NESF Switchgear Room No. 1 C-9Detection3301315Ionization N N N Y NESF Switchgear Room No. 1 C-9Detection3301SKC01Halon N N N Y NESF Switchgear Room No. 1 C-9Suppression3301None N/A-----ESF Switchgear Room No. 1 C-9Feature C-10ESF Switchgear Room B4.2.4.23302316Ionization N N N Y NESF Switchgear Room No. 2 C-10Detection3302317Ionization N N N Y NESF Switchgear Room No. 2 C-10Detection3302SKC01Halon N N N Y NESF Switchgear Room No. 2 C-10Suppression3302NoneERFBS N N N Y NESF Switchgear Room No. 2 C-10Feature August 2011 Page 83 NFPA 805 Ch. 3 Ref.Requirements/GuidanceCompliance StatementCompliance BasisReference DocumentAmeren Missouri Callaway Plant N FPA 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*$,-"/012'%22'&*"2212'125&12"~12'125&10"~262'72~&52'%:~2222'211~2222'August 2011 Page A-39 FPE RAI 18 NFPA 805 Ch. 3 Ref.Requirements/GuidanceCompliance StatementCompliance BasisReference DocumentAmeren Missouri Callaway Plant N FPA 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 TransitionN?A@-@General@statementB@No@technical requirements N/A3.9 Automatic and Manual Water-Based Fire Suppression Systems N/A N/AN?A@-@General@statementB@No@technical requirements N/A 3.9.1 If an automatic or manual water-based fire suppression system is required to 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:

N/ARequired sprinkler systems are identified in Table 4-3. Those sprinkler systems comply with NFPA@CD-CEHI@or@CEJD@Kditions@except as identified below.Complies with Clarification3.9.1(1) NFPA 13, Standard for the Installation of Sprinkler SystemsCalculation KC-27, NFPA Code Conformance Review, Rev. 0 / Appendix A, Sections 13.1976 and 13.1983NFPA 13, Standard for the Installation of Sprinkler Systems, 1976 Ed ition / AllNFPA 13, Standard for the Installation of Sprinkler Systems, 1983 Ed ition / AllRFR 201202154, Evaluate Sprinkler System in Rooms 3617, 3618 & 1335 / All August 2011 Page A-78 NFPA 805 Ch. 3 Ref.Requirements/GuidanceCompliance StatementCompliance BasisReference DocumentAmeren Missouri Callaway Plant N FPA 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 TransitionFor the non-ceiling level sprinklers that were installed under obstructions at the request of the NRC, sprinkler deflectors are located greater than 18 inches below noncombustible roof decks. Per Section 9.5.1.1 of NUREG-0830 Supplement 3, "The SER states that the automatic sprinkler systems would be designed to the recommendations of National Fire Protection Association (NFPA) Standard 13. During its site visit, the staff noted that in some corridor areas (e.g., auxiliary building corridor, elevation 1974 feet, west side), the sprinkler heads are located at the ceiling and there are a large number of cable trays, conduits, pipes, and vent ducts beneath the sprinkler heads. These obstructions may render the sprinkler system ineffective against a floor-level exposure fire, and are not in accordance with NFPA 13, which is recommended by Section C.6.c of BTP CMEB 9.5-1.By letter dated February 24, 1984, 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 Complies by Previous NRC ApprovalCalculation KC-27, NFPA Code Conformance Review, Rev. 0 / Appendix A, Section 13.1976Letter SLNRC 81-050 from Petrick (SNUPPS) to Denton (NRC), dated June 29, 1981 / Attachment, Page 9.5B-225Letter SLNRC 84-0037 from Petrick (SNUPPS) to Denton (NRC), dated February 24, 1984 /

AllNFPA 13, Standard for the Installation of Sprinkler Systems, 1976 Edition / Sections 4-3.2.1 and 4-3.2.3FSAR SP, Appendix 9.5B, Rev. OL-14b / Section A.8.4NUREG-0830, Safety Evaluation Report related to the operation of Callaway Plant, Unit No. 1, Supplement 3, dated May 01, 1984 / Section 9.5.1.1NUREG-0830, Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No. 1, dated October 01, 1981 / Page 33 August 2011 Page A-79 NFPA 805 Ch. 3 Ref.Requirements/GuidanceCompliance StatementCompliance BasisReference DocumentAmeren Missouri Callaway Plant N FPA 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 Transitionpostulated 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@SLNRM@JCOQTQU@A@fixed, manually charged, closed head sprinkler system is provided over the cable trays in Zones RB-3 and@RVOWA@manual@system@is@installed to prevent an inadvertent actuation of the sprinklers during August 2011 Page A-80 NFPA 805 Ch. 3 Ref.Requirements/GuidanceCompliance StatementCompliance BasisReference DocumentAmeren Missouri Callaway Plant N FPA 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 Transitionnormal@plant@operationX@Per Page 33 of NUREG-0830, "A fixed, manually charged closed head sprinkler system is provided over the two cable tray penetration areasVased@on@its@reviewU@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.See implementation item identified below.Complies, with Required ActionIMPLEMENTATION ITEMS: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@SYMDWU@which@is@credited@in@the@Fire@PRAU@in@accordance@with@NFPA@CD-CEHI@KditionX@@Monfiguration@control@on@the@ceiling tiles will be ensured.11-805-091CAR 200902315, NFPA 805 Transition -

Site Organizations Support Tracking CAR August 2011 Page A-81 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1Regulatory Basis4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptionsFire ZoneDescription1101General Floor Area No. 11102Chiller and Surge Tanks Area1103Letdown Chiller Heat Exchanger Room1104Letdown Reheat Heat Exchanger Room1105Valve Compartment1106Moderating Heat Exchanger Room1115Normal Charging Pump Room1120General Floor Area No. 21121Access Pit1122General Floor Area No. 3 & Auxiliary Building Tool Issue Area1123Passage1124Valve Compartment1125Letdown Heat Exchanger Room1128Storeroom No. 31129Auxiliary Condenser Recovery and Storage Tank Room1130North Corridor1201Vestibule1202Access Area B & Chiller Surge Tank Area1203Pipe Space B1204Pipe Space A1205Access Area A1206Pipe Chase1207Pipe Chase1329Vestibule Page C-2 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 Performance GoalDecay Heat Removal - CSDMethod of AccomplishmentCommentsUse RHR Train A, with cooling water provided by CCW Pumps A and C.Process MonitoringRCS Pressure Channel IPressurizer Pressure Channel I Pressurizer Level Channel I Ex-core Neutron Monitoring Channel IRCS Loop A (1) T-hot Temperature Channel I RCS Loop A (1) T-cold Temperature Channel II Steam Gen. A Pressure Channel ISteam Gen. A Wide Range Level Channel ISteam Gen. A Atmos. Steam Dump Pressure Channel IAux. Feedwater Flow to Steam Gen. A Channel I RCS Loop D (4) T-hot Temperature Channels II and VIRCS Loop D (4) T-cold Temperature Channels I and VISteam Gen. D Pressure Channel ISteam Gen. D Wide Range Level Channel IVSteam Gen. D Atmos. Steam Dump Pressure Channel IVAux. 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 IISteam Gen. B Pressure Channel ISteam Gen. B Wide Range Level Channel IISteam Gen. B Atmos. Steam Dump Pressure Channel IIAux. Feedwater Flow to Steam Gen. B Channels I and IIRCS Loop C (3) T-hot Temperature Channels II and VRCS Loop C (3) T-cold Temperature Channels I and V Steam Gen. C Pressure Channel ISteam Gen. C Wide Range Level Channel IIISteam Gen. C Atmos. Steam Dump Pressure Channel IIIAux. Feedwater Flow to Steam Gen. C Channels I and III Aux. Feedwater Pump A Suction Pressure Channel IDecay Heat Removal - HSBSteam 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.

Page C-3 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1RCS Inventory ControlTurbine Driven Aux. Feedwater Pump Suction Pressure Channel IIRefueling Water Storage Tank Level Channel IVolume Control Tank Level Channels I and IVContainment Pressure Channels II, III, and IVCore Exit Thermocouples Train A (Channel I and V) and Train B (C hannel IV and VI)Maintain inventory and RCP seal integrity using Charging Pump A via the Boron Injection flowpath and the Alternate RCP Seal Injection flowpath. RCP Thermal Barrier Cooling is credited, with cooling water provided by CCW Pumps A and C. RCS RV Head Vent flowpath Train A is available for letdown of RCS inventory, if necessary.Reactivity ControlTrip reactor from Control Room. Use Charging Pump A to inject borated water from the RWST.Vital AuxiliariesOperate CCW Pumps A, C, and ESW Pumps A and B.Offsite power to NB01 and NB02 credited.

HVAC credited for Main Control Room and Containment (Train A credited).See VFDR No. A-01-001, A-01-002, A-01-003, A-01-004, A-01-005, A-01-006, A-01-007, A-01-008, A-01-009, A-01-010See VFDR No. A-01-012RCS Pressure ControlControl pressure using Pressurizer Heater Backup Group A. Use PORV (BBPCV0455A) to depressurize.See VFDR No. A-01-011Reference DocumentsCalculation KC-26, Nuclear Safety Capability Assessment, Rev. 0 Page C-4 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1Licensing ActionsDeviation from Section D.1.j of Appendix A to BTP ASB 9.5-1 for Unrated Watertight DoorsDeviation 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, Supplem ent 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.SummaryLicensing Action TitleThis deviation is active. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.Deviation from Section D.1.j of Appendix A to BTP ASB 9.5-1 for Elevator and Dumbwaiter DoorsDeviation 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, Supplem ent 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.SummaryLicensing Action TitleThis deviation is active. The bases identified, and accepted by the NRC, reflect the current plant configuration and remain valid.Page C-5 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for HatchwaysDeviation 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.SummaryLicensing Action TitleThis 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.Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Partial Detection SystemDeviation 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.SummaryLicensing Action TitleThis 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.Deviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Partial Suppression SystemDeviation 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.SummaryLicensing Action TitleThis 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.

Page C-6 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1Existing Enginering Equivalency Evaluations (EEEE)Engineering Evaluation RFR 200906330An excessive gap in the bottom of Door DSK11271 connecting Fire Areas A-1 and A-6 is acceptable based on the lack of intervenin g 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.SummaryEEEE TitleEngineering Evaluation RFR 200906322The 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.SummaryEEEE TitleEngineering Evaluation RFR 201009031Auxiliary 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.SummaryEEEE Title Page C-7 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 Variances from Deterministic Requirements (VFDR)

DispositionVFDR No. A-01-001BBHV8141A - 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 fro m 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.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.

DispositionVFDR No. A-01-002BBHV8141B - 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 fro m 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.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.

Page C-8 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 DispositionVFDR No. A-01-003BGHV8149A - 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.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.

DispositionVFDR 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 issueThe 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.

DispositionVFDR No. A-01-005BGHV8149C - 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.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.

Page C-9 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 DispositionVFDR No. A-01-006BGLCV0112B - 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.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.

DispositionVFDR No. A-01-007BGLCV0112B-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 b y 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. 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.

Page C-10 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 DispositionVFDR No. A-01-008BGLCV0112C-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.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.

DispositionVFDR 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 issu e.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.

Page C-11 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 DispositionVFDR No. A-01-010EMHV8803A - 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 fir e 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.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.

DispositionVFDR No. A-01-011PZR-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).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.

Page C-12 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1 DispositionVFDR No. A-01-012SGK05B - 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. 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.

Page C-13 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1Required Fire Protection Systems and FeaturesNotes Fire ZoneCategoryRequired?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURESIonization 100Detection N N N Y1101 NPre-action SKC43Suppression N N N Y N ERFBSNoneFeature N N Y Y NIonization 100Detection N N N Y1102 NIonization 101Detection N N N Y NPre-action SKC43Suppression N N N Y N N/ANoneFeatureN/ANoneDetection1103N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1104N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1105N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1106N/ANoneSuppression N/ANoneFeatureIonization 101Detection N N N N1115 N N/ANoneSuppression N/ANoneFeaturePage C-14 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1NotesFire ZoneCategory Required?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURESIonization 101Detection N N N N1120 NIonization 102Detection N N N N NPre-action SKC43Suppression N Y N Y Nprovides water curtain for hatch N/ANoneFeatureIonization 101Detection N N N N1121 N N/ANoneSuppression N/ANoneFeatureIonization 100Detection N Y N Y1122 Nactivates hatch water curtainIonization 101Detection N N N N NPre-action SKC43Suppression N Y N Y Nprovides water curtain for hatch N/ANoneFeatureN/ANoneDetection1123N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1124N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1125N/ANoneSuppression N/ANoneFeatureIonization 117Detection N N N N1128 N N/ANoneSuppression N/ANoneFeaturePage C-15 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1NotesFire ZoneCategory Required?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURES N/ANoneDetection1129N/ANoneSuppression N/ANoneFeatureIonization 100Detection N Y N Y1130 NPre-action SKC43Suppression N N N Y N N/ANoneFeatureIonization 102Detection N N N N1201 N N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1202N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1203N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1204N/ANoneSuppression N/ANoneFeatureN/ANoneDetection1205N/ANoneSuppression N/ANoneFeaturePage C-16 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1NotesFire ZoneCategory Required?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURESIonization 120Detection N N N Y1206 NWet Pipe SKC48Suppression N N N Y N 20-ft Separation ZoneNoneFeature N N N Y N ERFBSNoneFeature N N Y Y NIonization 120Detection N N N Y1207 NWet Pipe SKC48Suppression N N N Y N20-ft Separation ZoneNoneFeature N N N Y N ERFBSNoneFeature N N Y Y N N/ANoneDetection1329N/ANoneSuppression N/ANoneFeatureS L E R D- Required for Chapter 4 Separation Criteria- Required for NRC-Approved Licensing Action- Required for Existing Engineering Equivalency Evaluation- Required for Risk Significance- Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk EvaluationRequired? Legend:

Page C-17 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-1Auxiliary Building - El. 1974, 1988 Unit 1To 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.Fire Area CommentsFire Suppression Effects on Nuclear Safety Per formance CriteriaThe 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.

Page C-18 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1Regulatory Basis Performance GoalDecay Heat Removal - CSDMethod of AccomplishmentCommentsUse RHR Train B, with cooling water provided by CCW Pumps B and D.Process MonitoringRCS Pressure Channels I and IIPressurizer Pressure Channel I Pressurizer Level Channel I Ex-core Neutron Monitoring Channel IRCS Loop A (1) T-hot Temperature Channel I RCS Loop A (1) T-cold Temperature Channel II Steam Gen. A Pressure Channel ISteam Gen. A Wide Range Level Channel ISteam Gen. A Atmos. Steam Dump Pressure Channel IAux. Feedwater Flow to Steam Gen. A Channels I and IV RCS Loop D (4) T-hot Temperature Channels II and VIRCS Loop D (4) T-cold Temperature Channels I and VISteam Gen. D Pressure Channel ISteam Gen. D Wide Range Level Channel IVSteam Gen. D Atmos. Steam Dump Pressure Channel IVAux. 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 IVCondensate Storage Tank Level Channel VI Refueling Water Storage Tank Level Channel I Volume Control Tank Level Channels I and IVContainment Pressure Channels II, III, and IV4.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptionsDecay Heat Removal - HSBSteam Generators A and D are supplied by MDAFW Pump B.See VFDR No. A-24-001 and A-24-002Fire ZoneDescription1323Pipe Penetration Room A Page C-180 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1RCS Inventory ControlCore Exit Thermocouples Train A (Channel I and V) and Train B (C hannel IV and VI)Maintain inventory and RCP seal integrity using Charging Pump B via the Boron Injection flowpath and the Alternate RCP Seal Injection flowpa th. RCS RV Head Vent flowpath Train B is available for letdown of RCS inventory, if necessary.Reactivity ControlTrip reactor from Control Room. Use Charging Pump B to inject borated water from the RWST.Vital AuxiliariesOperate 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).See VFDR No. A-24-003 and A-24-004RCS Pressure ControlControl pressure using Pressurizer Heater Backup Group B. Use PORV (BBPCV0456A) to depressurize.Reference DocumentsCalculation KC-26, Nuclear Safety Capability Assessment, Rev. 0Licensing ActionsDeviation from Section C.5.b of Appendix A to BTP ASB 9.5-1 for Containment Mechanical PenetrationsDeviation 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.SummaryLicensing Action TitleThis 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.

Page C-181 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1Existing Enginering Equivalency Evaluations (EEEE)Engineering Evaluation RFR 201009031Auxiliary 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.SummaryEEEE Title Page C-182 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1 Variances from Deterministic Requirements (VFDR)

DispositionVFDR No. A-24-001ABPV0002-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.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.

DispositionVFDR No. A-24-002ABPV0003-P - Cable damage (3ABI 20GA 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.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.

Page C-183 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1 DispositionVFDR No. A-24-003BGHV8105 - 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 require d closed to prevent potential adverse impact (i.e., flow diversion) to the NFPA 805 NSPC credited flowpaths of the chemical volum e and control system (i.e., the boron injection and the alternate RCP seal injection flowpaths). Either one of these valves is r equired 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.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.

DispositionVFDR No. A-24-004EMHV8801B - 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.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.

Page C-184 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescriptionA-24Containment Mechanical Piping Penetration Room A Unit 1Required Fire Protection Systems and FeaturesNotes Fire ZoneCategoryRequired?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURESIonization 117Detection N N Y Y1323 N N/ANoneSuppression ERFBSNoneFeature N N Y Y N S L E R D- Required for Chapter 4 Separation Criteria- Required for NRC-Approved Licensing Action- Required for Existing Engineering Equivalency Evaluation- Required for Risk Significance- Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk EvaluationRequired? Legend:NoneFire Area CommentsFire Suppression Effects on Nuclear Safety Performance CriteriaThere 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.

Page C-185 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1Regulatory Basis Performance GoalDecay Heat Removal - CSDMethod of AccomplishmentCommentsUse RHR Train A, with cooling water provided by CCW Pumps A and C.Process MonitoringRCS Inventory ControlRCS Pressure Channel IPressurizer Pressure Channel IPressurizer Level Channel I Ex-core Neutron Monitoring Channel I RCS Loop B (2) T-hot Temperature Channel ISteam Gen. B Pressure Channel ISteam Gen. B Narrow Range Level Channel IIIAux. Feedwater Flow to Steam Gen. B Channel IRCS Loop C (3) T-cold Temperature Channels I and VSteam Gen. C Pressure Channel ISteam Gen. C Wide Range Level Channel IIISteam Gen. C Atmos. Steam Dump Pressure Channel IIIAux. Feedwater Flow to Steam Gen. C Channels I and IIIAux. Feedwater Pump A Suction Pressure Channel IRefueling Water Storage Tank Level Channel IVolume Control Tank Level Channel IContainment Pressure Channels II, III, and IVCore Exit Thermocouples Train A (Channel I and V)Maintain inventory and RCP seal integrity using Charging Pump A via the Boron Injection flowpath and the Alternate RCP Seal Injection flowpa th. RCS RV Head Vent flowpath Train A is available for letdown of RCS inventory, if necessary.See VFDR No. C-10-003, C-10-004, C-10-006, and C-10-0074.2.4.2 - Performance-Based Approach - Fire Risk Evaluation with simplifying deterministic assumptionsDecay Heat Removal - HSBSteam Generators B and C are supplied by MDAFW Pump A.See VFDR No. C-10-001, C-10-002, C-10-005, and C-10-008Fire ZoneDescription3302ESF Switchgear Room No. 2 Page C-271 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1Reactivity ControlTrip reactor from Control Room. Use Charging Pump A to inject borated water from the RWST.Vital AuxiliariesOperate 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.RCS Pressure ControlControl pressure using Pressurizer Heater Backup Group A. Use PORV (BBPCV0455A) to depressurize.Reference DocumentsCalculation KC-26, Nuclear Safety Capability Assessment, Rev. 0Licensing ActionsNone Page C-272 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1Existing Enginering Equivalency Evaluations (EEEE)Engineering Evaluation RFR 201000502The 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.SummaryEEEE TitleEngineering Evaluation RFR 201009031Auxiliary 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.SummaryEEEE Title Page C-273 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1 Variances from Deterministic Requirements (VFDR)

DispositionVFDR No. C-10-001ABPV0002-P - Cable damage (2ABI20FE, 2ABI20FG, 2ABI20FH, 2ABI20FJ, 2 ABI20FK, 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.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.

DispositionVFDR No. C-10-002ABPV0004-P - Cable damage (4 ABI20HE, 4ABI20HG, 4ABI20HH, 4ABI20HJ, 4ABI 20HK, 4ABI20HL, 4 ABI20HM, 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 f or 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.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.

Page C-274 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1 DispositionVFDR No. C-10-003Valve 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/lo ad sequencer. This would start normally idle Charging Pump A (the credited charging pump for safe shutdown), which could then fai l 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.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.

DispositionVFDR No. C-10-004EMHV8803B-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.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.

Page C-275 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1 DispositionVFDR No. C-10-005FCHV0312-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.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.

DispositionVFDR No. C-10-006NB0201-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.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.

DispositionVFDR No. C-10-007NB0202-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 orde r 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 operatio ns. This condition represents a variance from the deterministic requirements of NFPA 805, Section 4.2.3. This is a separation issu e.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.

Page C-276 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1 DispositionVFDR No. C-10-008NB0205-P - Cable damage (4ALB01BA, 4ALB01BJ, 4ALB01BK, 4ALB01BL, 4ALB01BM, 4ALB01BN, 4R PK15AA, 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.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.

Page C-277 August 2011 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAttachment C - Table B-3 Fire AreaTransitionFire AreaDescription C-10ESF Switchgear Room B Unit 1Required Fire Protection Systems and FeaturesNotes Fire ZoneCategoryRequired?S R L E D IDTypeREQUIRED FIRE PROTECTION SYSTEMS AND FEATURESIonization 316Detection N N Y N3302 NIonization 317Detection N N Y N NHalon SKC01Suppression N N Y N N ERFBSNoneFeature N N Y N N S L E R

D- Required for Chapter 4 Separation Criteria- Required for NRC-Approved Licensing Action- Required for Existing Engineering Equivalency Evaluation

- Required for Risk Significance

- Required to Maintain an Adequate Balance of Defense-in-Depth in a Change Evaluation or Fire Risk EvaluationRequired? Legend:NoneFire Area CommentsFire Suppression Effects on Nuclear Safety Performance CriteriaHalon 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.Page C-278 August 2011 Attachment C - Table B-3 Fire Area TransitionAmeren MissouriCallaway Plant NFPA 805 Transition Report UnitFire AreaDescription C-28Control Room Service Area 1NoneExisting Enginering Equivalency Evaluations (EEEE)Variances from Deterministic Requirements (VFDR)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.Engineering Evaluation RFR 19347AKeeping Fire Door DSK36021 between the Control Room (Room 3601, Fire Area C-27) and the Control Room Pantry (Room 3602, Fire Ar ea 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.SummaryEEEE TitleEngineering Evaluation RFR 201009031Auxiliary 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.SummaryEEEE Title August 2011 PageC-480 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Barriers and Fire Barrier Penetrations (C.5 criteria)006Deviation 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 n ot 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 ac cepted by the NRC, reflect the current plant configuration and remain valid.

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

The 2/1/1984 SNUPPS le tter to the NRC states:The purpose of the comprehensiv e test program for SN UPPS 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 effe ctive 3-hour f ire barrier. All fire rated penetration seals we re 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, pro cedures, and results w ere 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.

Yes5/1984 August 2011 Page K-12 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Barriers and Fire Barrier Penetrations (C.5 criteria)006 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-663-0083These documents have been made available to the NRC staff fire protection auditor.NRC NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No.1," Supplement 3, dated May 1984In NUREG-0830, Supplement 3, dated 5/1984, the NRC states:The staff has continued its review of the Callaway fire pr otection program on the basis of a site audit and information provided by the applicant by letters dated February 1 and 24, 1984. Th e 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 PenetrationsWhere 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, w atertight, and missile-resistant doors, and equipment hatches in the auxiliary building.

For fire areas that do n ot have a 3-hour-fire-rated as sembly 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 de termine 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 desig ns for all fire penetration seals used in the penetration cable trays, condu its, and piping that pa ss 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 permi tted on the unexpos ed side by ASTM E-119. The applicant stated that the acceptance criterion used w as 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 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Barriers and Fire Barrier Penetrations (C.5 criteria)006period 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 sp ecific 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 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007Deviation 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 Ro om 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.

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

The 2/1/1984 SNUPPS le tter to the NRC states:The NRC auditors indicated that the design of the SNUPPS protection sys tem 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 lo cated 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 co nsist of four (4) mult iplexers and mu ltiple 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 ana lysis 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. MULTIPLEXERS1. Primary Power Supply

The primary power for the multiplexers is the non-Class 1E instrument ac system. The non-Class 1E Yes5/1984 August 2011 Page K-15 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007instrument ac system is continuously supplied by the Class 1E ac emerge ncy 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 an d power service.

2. Secondary Power SupplyThe 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 up on 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 emergenc y 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 continuo usly 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 (Stan dby) 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 batterie s a nd chargers are not installed in series. This maintains power to the system upon failure of either the charger or the battery if prim ary 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 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007integrity. 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 PanelsThe 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 DetectorsLoss 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 co ntrol room. Preaction Systems that incorporate these panels control suppression by a signal gen erated directly from the appropriate multiplexer. The early warning detection circuits associated with these Preaction Systems is supervised directly by the appro priate 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 DetectorsLoss 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 c ontrol 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 manu al (mechanic al) 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 Preacti on Control Panel; detection is maintained in the safety related area.

3. Local Panel Serving Halon 1301 SystemsLoss 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 ind ica tion of manual Halon system discharge is maintained.

4. Local Panels S erving Wet Pipe SystemsLoss 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 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007minimal 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 dcTotal 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 rel ated 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 Systemsc. Fuel Building RR Bayd. Turbine Building 2000, 2033Remote 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 sys tem 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 SNUPP S system c an be powere d by 125V batteries

.August 2011 Page K-18 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007The 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 (Artic le 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. Alt hough 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.NRC NUREG-0830, "Safety Evaluation Report Related to the Operation of Callaway Plant, Unit No.1," Supplement 3, dated May 1984In NUREG-0830, Supplement 3, dated 5/1984, the NRC states:The staff has continued its review of the Callaway fire pr otection program on the basis of a site audit and information provided by the applicant by letters dated February 1 and 24, 1984. Th e 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 SystemThe SER states that the plant fire detection system is installed in accordance with NFPA 72D. During its site visit, the staff noted that th e 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 circu itry compares to the requirements of NFPA 72D.

By letter dated February 1, 1984, the applicant provide d the comparison. The applicants comparison indicated that the primary and secondary power supplies comply with t he 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 Ameren MissouriCallaway Plant NFPA 805 Transition ReportAppendix A Deviation, Unit No. 1 Fire Detection System Power Supplies (C.6.a criteria)007guidelines in Section C.6.a of BTP CMEB 9.5-1, and is, therefore, acceptable.

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