ML072050214
| ML072050214 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/19/2007 |
| From: | NRC/NRR/ADRA/DRA/AFPB |
| To: | |
| References | |
| FAQ 06-0008 | |
| Download: ML072050214 (23) | |
Text
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 8 FAQ 06-0008 rev 5a Plant:____Harris_______
Date:___5/2/07_________
Contact:
__Jeff Ertman____
Phone:__919-546-3681___
Email:__jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use)
X 805TF X FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:
The purpose of FAQ 06-0008 is to provide a process/method for the use of fire protection engineering analyses post-transition to address NFPA 805 Chapter 3 requirements.
Currently, licensees may self approve these evaluations under the existing fire protection license conditions. The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). The process/method to be submitted in the LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
- When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and
Post-transition, licensees will use this process/method to self approve acceptable fire protection engineering analyses.
Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:
NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):
Sections 2.2, 2.3, 2.4, 4.3.1, 4.6.1, 5.3.2, Appendix H, and Appendix I of NEI 04-02 Revision 1.
Circumstances requiring guidance interpretation or new guidance:
Risk-informed, performance-based fire protection engineering analyses are an acceptable alternative to the deterministic approaches in NFPA 805 Chapter 4. Some sections of Chapter 3 are conditional based upon Chapter 4 requirements; therefore, risk-informed, performance-based methods are allowed for those sections under NFPA 805 / 10 CFR 50.48 (c). Risk-informed, performance-based fire protection engineering analyses may also be needed to document the acceptability of fire protection systems and features addressed in NFPA 805 Chapter 3 sections that are not conditional based upon Chapter 4 requirements. Current licensing basis allows flexibility to use performance-based technical b engineering analyses.doc
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc analysis per Generic Letter 86-10. An approach using these types of analyses is needed to allow this flexibility following transition to NFPA 805.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
The fire protection program elements and minimum design requirements of NFPA 805 Chapter 3 may be subject to the performance-based methods permitted elsewhere in NFPA 805 per 10 CFR 50.48(c)(2)(vii), as long as the appropriate regulatory processes (i.e., a license amendment request) are utilized.
A process for a 10 CFR 50.48(c)(2)(vii) License Amendment Request has not yet been agreed upon.
Potentially relevant existing FAQ numbers:
FAQ 06-0004 includes a process for defining fire protection systems and features required to meet NFPA 805 Chapter 3 criteria.
Response Section:
Proposed resolution of FAQ and the basis for the proposal:
A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c), is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) to develop a process to maintain the current flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.
BACKGROUND The rulemaking performed to implement 10 CFR 50.48(c) identified the need to be able to utilize performance-based methods on the fundamental fire protection program elements and design requirements in Chapter 3. To address this need, 10 CFR 50.48(c) included a provision that allows licensees to use performance-based methods on Chapter 3 attributes, upon receipt of NRC approval.
Prior to transition, under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to achieve and maintain safe shutdown in the event of a fire.
10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.
To apply this process/method, licensees must send the proposed process/methods outlined in this FAQ to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc application is within the bounds of NRC approval of the proposed methods/processes.
Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.
The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to features required by Chapter 3 of NFPA 805, as long as those changes only affect the referenced codes, standards and listings, such as NFPA, Underwriters Laboratory, Inc. or Factory Mutual listings (Note that referenced codes and standards refer to the code of record as defined in section 1.8 of NFPA 805. A licensees code of record may be different than those referenced in NFPA 805). Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).
Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval.
Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii).
This second step, application of the process/method, will not require NRC approval.
This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4. These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.
PROCESS This FAQ proposes to utilize the NFPA 805 Change Evaluation process as defined in NEI 04-02 (including consideration of Defense-in-Depth and Safety Margins), as the process for determining acceptability for changes to NFPA 805 Chapter 3 requirements that are implemented through referenced codes, standards and listings.
To apply this method, licensees must send the proposed methods outlined in this FAQ (the Change Evaluation process defined in NEI 04-02) to the NRC for approval. Then, they may use the approved method without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods.
Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.
The licensee must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods. Once approved, the license amendment would allow licensees to make changes to NFPA 805 Chapter 3 requirements, as long as those changes only affect the referenced codes, standards and listings, such as NFPA, Underwriters Laboratory, Inc. or Factory Mutual listings (Note that
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc referenced codes, standards and listings refer to the code of record as defined in section 1.8 of NFPA 805. A licensees code of record may be different than those referenced in NFPA 805). Under the proposal the licensee will commit to a process to evaluate deviations from referenced codes, standards and listings required by NFPA 805 Chapter
- 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).
Therefore, application of this method requires two steps. First, the methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made using the method proposed and approved under this license amendment will undergo the same evaluation process as required by 10 CFR 50.48(c)(2)(vii). This second step, application of the method, will not require NRC approval.
This method would not apply to NFPA 805 Chapter 3 changes that do not refer to codes, standards or listings. These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.
Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205):
Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.
Licensees may also perform change evaluations for deviations from the NFPA codes, standards and listings referenced in NFPA 805 Chapter 3 for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.
The following provides the sections of NFPA 805 that will utilize this process/method.
Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.
Column Heading Definition:
Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes, standards and listings. Note the Applicability would only apply to the referenced codes, standards and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 6 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 7 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes, standards and listings. Therefore, the process/method associated with this FAQ is not applicable and would be outside the scope of the associated LAR.
Section Title FP Eng.
Analysis Process Applicable Chapter 4 Conditional Section FP Eng.
Analysis Process and Chapter 4 Not Applicable 3.1 General X
3.2 Fire Protection Plan X
3.2.1 Intent X
3.2.2 Management Policy Direction and Responsibility X
3.2.3 Procedures X
3.3 Prevention X
3.3.1 Fire Prevention for Operational Activities X
3.3.2 Structural X
3.3.3 Interior Finishes X
3.3.4 Insulation Materials X
3.3.5 Electrical X
3.3.6 Roofs X
3.3.7 Bulk Flammable Gas Storage X
3.3.8 Bulk Storage of Flammable and Combustible Liquids X
3.3.9 Transformers X
3.3.10 Hot Pipes and Surfaces X
3.3.11 Electrical Equipment (Note 1)
X 3.3.12 Reactor Coolant Pumps (Note 1)
X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X
3.4.2 Pre-Fire Plans X
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 8 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc Section Title FP Eng.
Analysis Process Applicable Chapter 4 Conditional Section FP Eng.
Analysis Process and Chapter 4 Not Applicable 3.4.3 Training and Drills X
3.4.4 Fire Fighting Equipment X
3.4.5 Off-Site Fire Department Interface X
3.4.6 Communications X
3.5 Water Supply X
3.6 Standpipe and Hose Stations X
3.7 Fire Extinguishers X
3.8 Fire Alarm and Detection Systems X
3.8.1 Fire Alarm X
3.8.2 Detection X
3.9 Automatic and Manual Water-Based Fire Suppression Systems X
3.10.
Gaseous Fire Suppression Systems X
3.11 Passive Fire Protection Features X
3.11.1 Building Separation (Note 3)
X 3.11.2 Fire Barriers X
3.11.3 Fire Barrier Penetrations X
3.11.4 Through Penetration Fire Stops (Note 2)
X 3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS)
X Note 1 - Separate FAQs will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.
Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)
Note 3 - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis. The process in this FAQ is not applicable.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 9 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc EXAMPLE Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14 if the deviation is evaluated and found to be acceptable using this methodology. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).
JUSTIFICATION Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives / criteria, defense-in-depth and safety margins evaluation),
and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to NFPA 805 Chapter 34 conditional sections and the secondary referenced codes, standards and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). NFPA 805 Chapter 3 features addressed by Secondary referenced codes, standards and listings features may be changed based on an evaluation, using the required methods described in this FAQ (once reviewed and approved by the NRC in the license amendment) in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.
The method will ensure that the following requirements are met:
10 CFR 50.48(c)(2)(vii) Requirement Method of Accomplishment (a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.
The fire protection engineering analysis process includes the assessment of impact on NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.
Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.
(b) Safety margins are maintained.
Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.
(c) Fire protection defense-in-depth is maintained.
Maintaining fire protection defense-in-depth will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 10 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc and supplemented by RG 1.205 Section C.3.2.
The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:
RG 1.205 Guidance Method of Accomplishment (a) detailed description of the alternative risk-informed, performance-based method The process is not considered an alternative method.
Existing risk-informed, performance-based methods will be applied, but for a limited scope of NFPA 805 Chapter 3 sections:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805.
(b) description of how the method will be applied, the aspects of the FPP to which it will applied, and the circumstances under which it will be applied Risk-informed, performance based fire protection engineering analyses will be allowed to be applied When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805 (c) acceptance criteria, including risk increase acceptance criteria, that the licensee will apply when determining whether the results of an evaluation that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria Acceptance criteria for changes will use the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J (and supplemented by RG 1.205 Section 3.2).
(d) for PSA-based methodologies, an explanation of how the PSA is of sufficient technical adequacy for evaluation of the changes to which it will be applied Technical adequacy of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.
(e) for PSA-based methodologies, a description of the peer review and how the review findings have been addressed Peer review of the PSA used in the risk-informed, performance-based approach will be in accordance with RG 1.205.
CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes to features required by NFPA 805 Chapter 3 within the bounds of secondary referenced codes, standards and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate Chapter 3 fire protection features in referenced codes standards and listings without prior NRC approval. Other NFPA 805 Chapter 3 issues not involving NFPA codes, standards or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
FAQ Number __06-0008______________ FAQ Revision ____5ab________________
FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 11 of 8 FAQ 06-0008 rev 5ab engineering analyses.doc If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
[See attached proposed revision to NEI 04-02]
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 1 Section 2.2, page 7, 3rd paragraph:
Performance-Based Methods, § 50.48(c)(2)(vii) - The prohibition in Section 3.1 of NFPA 805 that does not permit the use of performance-based methods for the Chapter 3 fundamental fire protection program elements and minimum design criteria is not endorsed. The NRC takes this exception in order to provide licensees greater flexibility in meeting the fire protection program elements and minimum design requirements of Chapter 3 by the use of performance-based methods (including the use of risk-informed methods) described in the NFPA 805 standard.
Licensees who wish to deviate from Chapter 3 requirements must submit a license amendment request for NRC approval.
Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
o When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and o for deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Section 2.3, page 9, 2nd paragraph:
Compliance with Chapter 3 of NFPA 805 may be demonstrated by showing that the specific requirements are met either directly or by the use of alternative methods and analytical approaches.
Alternative methods and analytical approaches must be accepted by the NRC in a license amendment per 10 CFR 50.48(c)(4). Contrary to Section 3.1 of NFPA 805, performance-based methods may be used.
(See 10 CFR 50.48(c)(2)(vii)). Note licensees contemplating applying for permission to use an alternative method or analytical approach could pursue a generic approval process with other utilities and/or NEI.
See Section 2.4 of this document.
Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Section 4.1.1, page 21, 1st paragraph:
For areas of the fire protection program that are not in compliance with NFPA 805, Chapter 3, the licensee may utilize the alternate performance-based methods as long as the method is
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 2 approved by the NRC in a License Amendment. The NRC has taken exception to NFPA 805, Section 3.1 (See 10 CFR 50.48.c (2)(vii)).
Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Section 4.3.1, page 27, add new paragraph to this section at the end Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Section 4.6.1, page 34 insert new paragraph before last sentence A sample LAR Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Section 5.3.1, page 43
.Under the risk-informed, performance-based regulatory framework, Fire Protection Program changes will be made without prior NRC approval, except where required by:
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 3 10 CFR 50.59, Other regulatory processes (i.e., Technical Specifications),
10CFR 50.48(c) (certain changes to Chapter 3 requirements or Nuclear Safety Changes that do not meet the acceptance criteria of NFPA Section 2.4.4.)
Changes that have been evaluated using performance-based methods other than those acceptable to the AHJ Changes that have been evaluated using performance-based methods other than the approaches in NFPA 805 (i.e., fire modeling and risk evaluation)
Except as noted, in general changes that have been previously approved by the NRC or that do not deviate from a specific NFPA 805 requirement related to systems, methods, or devices need not be submitted for AHJ approval Section 5.3.2, page 46, starting with 7th paragraph:
Additional consideration should be given to changes to Fundamental Program Elements and Minimum Design Requirements. 10 CFR 50.48(c)(2)(vii) allows licensees to use performance-based methods to demonstrate compliance with NFPA 805 Chapter 3 requirements. However, these alternate methods must be approved via the license amendment process (10 CFR 50.48(c)(4)).
Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
Most changes to the Fundamental Program Elements and Minimum Design Requirements should not require a License Amendment request, since they are evaluations that demonstrate compliance with requirements of Chapter 3 of NFPA 805. Licensees can deviate from the NFPA standards referenced in NFPA 805 Chapter 3 within the bounds discussed in Appendix L.
Examples of changes that would not require a License Amendment are:
Replacing a fire rated component (e.g., penetration seal, door, wrap, etc.) with a different component/material having the same or greater fire rating. This does not require a license amendment because it meets the appropriate code.
Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of NFPA 805 and the referenced code do not dictate where a sprinkler system should be installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.
Evaluating a broken/missing hanger on a fire suppression system. The acceptability of this deviation can be evaluated to show that the support of the system is still adequate with the broken/missing hanger and is therefore equivalent to a code compliant system as allowed by the code of record.
Conversely, examples of changes that would require a License Amendment are:
Reducing the number of fire brigade members required on-site to below five.
Elimination of the Fire Prevention Program at the plant
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 4 NFPA 805 Section 4.1, states that, Deterministic requirements shall be deemed to satisfy the performance criteria and require no further engineering analysis. Chapter 4 of NFPA 805 provides the requirements for the baseline evaluation of the fire protection programs ability to achieve the performance criteria outlined in Section 1.5 of NFPA 805. The deemed to satisfy with out additional engineering analysis does not imply that a Plant Change Evaluation would not be performed. For example if a licensee was changing its current licensing basis in a fire area to a deterministic method, that change would require a Plant Change Evaluation. Note the Defense in Depth and Safety Margin portion of the Plant Change Evaluation would be satisfied by the fact that a deterministic option was chosen for compliance (See Sections 2.4.4.2 and 2.4.4.3 of NFPA 805).
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 5 Appendix I, page I-2 (note: changes are shown to approved FAQ 06-0002, rather than rev. 1 of NEI 04-02).
Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).
- 3.
Does the proposed change involve an NFPA 805 Chapter 3 requirement as defined in [Insert appropriate document reference]? For those fire protection program changes that involve a Nuclear Safety Compliance Strategy requirement or a Radioactive Release requirement, ensure the effect of the change is evaluated in Appendix I, Sections 1.0 and 2.0, respectively.
Yes - Proceed to Question 3.a.
No - Document basis and proceed to Question 2
- a. Is the change editorial or trivial in nature? (See Attachment 1) o Yes Document basis and stop.
o No Proceed to Question 3.b.
- b. Does the change meet NFPA 805 Chapter 3 requirements or the previously approved Alternative as defined in [Insert appropriate document reference]?
Previously approved alternatives include fire protection engineering analyses that are allowed based upon an approved license amendment described in NEI 04-02, Appendix L. (See )
o Yes Document conclusions, complete remaining sections.
o No License Amendment Request must be processed for NRC approval. Complete remaining sections.
FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT / MINIMUM DESIGN REQUIREMENT CHANGE QUESTIONS
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 6 Appendix I - Attachment 2, page I-8 Refer to Appendix L for a process/method to be submitted in the transition LAR to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:
When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and Ffor deviations from the referenced NFPA codes and listings for rated components in NFPA 805.
Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.
The following are examples of changes that do not require NRC approval:
Replacing a fire rated component (e.g., fire rated penetration seal, fire door, fire rated wrap, etc.) with a different component having the same or greater fire rating.
Use of fire hoses manufactured from a different material.
Use of a valve assembly supplied by a different manufacturer for a suppression system.
Changes to Fire Brigade Training requirements that do not affect performance.
Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of NFPA 805 and the referenced code do not dictate where a sprinkler system should be installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 7 PLACEHOLDER FOR A DESCRIPTION OF NRC POSITION ON THIS FAQ.
L.1 Background 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.
To apply this process/method, licensees must send the proposed process/methods outlined in this Appendix to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.
The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to features required by Chapter 3 of NFPA 805, as long as those changes only affect the referenced codes, standards and listings, such as NFPA, Underwriters Laboratory, Inc. or Factory Mutual listings (Note that referenced codes and standards refer to the code of record as defined in section 1.8 of NFPA-805. A licensees code of record may be different than those referenced in NFPA-805). Under the proposal the licensee will commit to a process to evaluate deviations from secondary referenced codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).
Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as required by part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.
This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4.
These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.
L.2 Process Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205:
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 8 Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.
Licensees may also perform change evaluations for deviations from the referenced NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.
The following table provides the sections of NFPA 805 that will utilize this process/method.
Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.
Column Heading Definition:
Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.
Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.
Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this Appendix is not applicable and would be outside the scope of the associated LAR.
Section Title FP Eng.
Analysis Process Applicable FP Eng.
Analysis Process Not Applicable 3.1 General X
3.2 Fire Protection Plan X
3.2.1 Intent X
3.2.2 Management Policy Direction and Responsibility X
3.2.3 Procedures X
3.3 Prevention X
3.3.1 Fire Prevention for Operational Activities X
3.3.2 Structural X
3.3.3 Interior Finishes X
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 9 Section Title FP Eng.
Analysis Process Applicable FP Eng.
Analysis Process Not Applicable 3.3.4 Insulation Materials X
3.3.5 Electrical X
3.3.6 Roofs X
3.3.7 Bulk Flammable Gas Storage X
3.3.8 Bulk Storage of Flammable and Combustible Liquids X
3.3.9 Transformers X
3.3.10 Hot Pipes and Surfaces X
3.3.11 Electrical Equipment (Note 1)
X 3.3.12 Reactor Coolant Pumps (Note 1)
X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X
3.4.2 Pre-Fire Plans X
3.4.3 Training and Drills X
3.4.4 Fire Fighting Equipment X
3.4.5 Off-Site Fire Department Interface X
3.4.6 Communications X
3.5 Water Supply X
3.6 Standpipe and Hose Stations X
3.7 Fire Extinguishers X
3.11.1 Building Separation (See Note)
X Note - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis.
The process in this FAQ is not applicable.
L.3 Example Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14 if the deviation is evaluated and found to be acceptable using this methodology. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).
L.4 Justification Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation being included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 10
/criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to the referenced codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). NFPA-805 Chapter 3 features addressed by referenced codes and standards may be changed based on an evaluation, using the required methods described in this appendix (once reviewed and approved by the NRC in the license amendment) in a similar manner that was previously allowed under the Generic Letter 86-10 license condition, without prior NRC approval.
The method will ensure that the following requirements are met:
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 11 10 CFR 50.48(c)(2)(vii) Requirement Method of Accomplishment (a) The required NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.
The fire protection engineering analysis process includes the assessment of impact on NFPA 805 performance goals, performance objectives, and performance criteria are satisfied.
Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J as endorsed by RG 1.205 Section 3.2.
(b) Safety margins are maintained.
Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J as endorsed by RG 1.205 Section C.3.2.
(c) Fire protection defense-in-depth is maintained.
Maintaining fire protection defense-in-depth will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J as endorsed by RG 1.205 Section C.3.2.
NRC Response to FAQ 06-0008, Revision 5 [HXB] {7/19/2007}
Appendix L - Alternative Method for Engineering Analyses FAQ 06-0008 rev. 5b - NEI 04-02 markup - Page 12 L.5 Conclusion This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes to NFPA-805 Chapter 3 features requirements within the bounds of secondary referenced codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other NFPA-805 Chapter 3 issues, not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.