ML16015A416
| ML16015A416 | |
| Person / Time | |
|---|---|
| Issue date: | 03/02/2016 |
| From: | Boland A, Giitter J Division of Operating Reactor Licensing, NRC/NRR/DRA |
| To: | Tschiltz M Nuclear Energy Institute |
| Angela Wu, NRR/DRA 415-2995 | |
| References | |
| Download: ML16015A416 (3) | |
Text
March 2, 2016 Mr. Michael D. Tschiltz Director, Risk Assessment Nuclear Energy Institute 1201 F St., NW, Suite 1100 Washington, DC 20004-1218
SUBJECT:
RECOMMENDED CONTENT FOR LICENSE AMENDMENT REQUESTS THAT SEEK CHANGES TO LICENSE CONDITIONS THAT WERE ESTABLISHED IN AMENDMENTS TO ADOPT NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 BUT HAVE YET TO BE FULLY IMPLEMENTED
Dear Mr. Tschiltz,
As the U.S. Nuclear Regulatory Commission (NRC) continues to review and approve license amendment requests (LARs) to adopt a risk-informed, performance-based fire protection licensing basis under Title 10 of the Code of Federal Regulations (10 CFR) Section 50.48(c),
National Fire Protection Association Standard 805 (NFPA 805), Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, several licensees have expressed a desire to modify some of the implementation obligations of their NFPA 805 amendment after it has been issued, but before all obligations have been fully implemented. Because plant modifications associated with the transition to NFPA 805 are included as license conditions, licensees wishing to change or remove a plant modification must request NRC approval through the license amendment process in 10 CFR 50.90. Per their approved license condition, licensees must complete all plant modifications within a fixed and prompt timeframe. In recognition of these time constraints, this letter provides guidance that may be helpful in developing a LAR for a streamlined NRC review, i.e., one that might be completed within a relatively short schedule.
Option A:
The requested change to plant modifications is evaluated using the accepted fire PRA methods and approaches as summarized in the final safety evaluation accompanying the license amendment approving transition to NFPA 805. The NRC staff recommends that the licensee provide the following information:
- i. A summary of all changes to the modifications; ii. A summary of all changes to the probabilistic risk assessment (PRA) models and explanation for each change; iii. New, updated versions in their entirety of: the License Condition (Attachment M), list of plant modifications (Attachment S), and the summarizing area wide change-in-risk result tables (Attachment W); and iv. A statement that the defense-in-depth (DID) and safety margin evaluations associated with the original LAR have been completed on the proposed changes.
M. Tschiltz 2 Because the NRC staff has received and successfully incorporated changes to the modifications in the final months of an NFPA 805 LAR review with minimal schedule impacts, the NRC staff expects such submissions could be reviewed in a timely manner through the streamlined approach (Option A).
Option B:
The requested change to plant modifications is evaluated using fire PRA methods and approaches that have been accepted in other final safety evaluations for another station where the license amendment for the transition to NFPA 805 has been approved. The NRC staff recommends that the licensee provide the following information:
- i. A summary of all changes to the modifications; ii. A summary of all changes to the PRA models and explanations for each change; iii. New, updated versions in their entirety of: the License Condition (Attachment M), list of plant modifications (Attachment S), and the summarizing area wide change-in-risk result tables (Attachment W);
iv. A statement that the DID and safety margin evaluations associated with the original LAR have been completed on the proposed changes;
- v. A summary of all accepted PRA methods being used that werent used in the NFPA 805 amendment request and a reference to the NRC document accepting the method (i.e., the method should have been previously accepted by NRR staff);
vi. A demonstration of the applicability of the accepted method for the configuration and conditions to which it is being applied; vii. A summary of the changes made to the Nuclear Safety Capability Analysis (NSCA) and associated changes to LAR Attachments C and G that reflect any changes in compliance strategies being used on a fire area basis in redline/strikeout; and viii. A justification for the creation of new and/or removal of previously existing Variances from Deterministic Requirements (VFDRs) and Recovery Actions (RAs).
With this information, the NRC staff will make a judgement as to whether a streamlined review could be achieved (Option B). For some applications, more information may be required.
Option C:
For requested changes to plant modifications that are evaluated using fire PRA methods and approaches accepted by the NRC but different from those summarized in any final safety evaluation where the license amendment for the transition to NFPA 805 has been approved (i.e., new methods), the NRC staff will attempt to conduct the review as timely as resources allow. The NRC staff recommends that the licensee provide the following information:
- i. A summary of all changes to the modifications; ii. A summary of all changes to the PRA models and explanations for each change; iii. New, updated versions in their entirety of: the License Condition (Attachment M), list of plant modifications (Attachment S), and the summarizing area wide change-in-risk result tables (Attachment W);
M. Tschiltz 3 iv. A statement that the DID and safety margin evaluations associated with the original LAR have been completed on the proposed changes;
- v. A summary of all accepted PRA methods (both those referenced in previous safety evaluations and the new methods) being used that werent used in the NFPA 805 amendment request and a reference to the NRC document accepting the method (i.e., the method should have been previously accepted by NRR staff);
vi. An evaluation of the impact of all new accepted fire PRA methods available at the time of submittal (i.e., methods that increase risk and methods that decrease risk);
vii. A demonstration of the applicability of the accepted method for the configuration and conditions to which it is being applied, as included in submitted examples of the application; viii. A summary of the changes made to the NSCA and associated changes to LAR Attachments C and G that reflect any changes in compliance strategies being used on a fire area basis in redline/strikeout; and ix. A justification for the creation of new and/or removal of previously existing VFDRs and RAs.
The NRC cautions that submittal of a LAR in accordance with this guidance does not assure that the request will be approved, nor does it assure that the review will be completed in a specific timeframe. Accordingly, licensees must continue to meet their existing license obligations until any changes to the license are approved, and any LARs should be submitted well in advance of a licensees existing implementation deadlines.
Any questions regarding this guidance should be directed to Stacey Rosenberg at (301) 415-2357 or David Wrona at 301-415-2292.
Sincerely,
/RA/
Anne Boland, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
/RA/
Joseph G. Giitter, Director Division of Risk Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission
M. Tschiltz 3 iv. A statement that the DID and safety margin evaluations associated with the original LAR have been completed on the proposed changes;
- v. A summary of all accepted PRA methods (both those referenced in previous safety evaluations and the new methods) being used that werent used in the NFPA 805 amendment request and a reference to the NRC document accepting the method (i.e., the method should have been previously accepted by NRR staff);
vi. An evaluation of the impact of all new accepted fire PRA methods available at the time of submittal (i.e., methods that increase risk and methods that decrease risk);
vii. A demonstration of the applicability of the accepted method for the configuration and conditions to which it is being applied, as included in submitted examples of the application; viii. A summary of the changes made to the NSCA and associated changes to LAR Attachments C and G that reflect any changes in compliance strategies being used on a fire area basis in redline/strikeout; and ix. A justification for the creation of new and/or removal of previously existing VFDRs and RAs.
The NRC cautions that submittal of a LAR in accordance with this guidance does not assure that the request will be approved, nor does it assure that the review will be completed in a specific timeframe. Accordingly, licensees must continue to meet their existing license obligations until any changes to the license are approved, and any LARs should be submitted well in advance of a licensees existing implementation deadlines.
Any questions regarding this guidance should be directed to Stacey Rosenberg at (301) 415-2357 or David Wrona at 301-415-2292.
Sincerely, Anne Boland, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Joseph G. Giitter, Director Division of Risk Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission DISTRIBUTION:
DRA r/f AKlein SRosenberg ADAMS Letter Accession No.: ML16015A416 OFFICE NRR/DRA/APLA NRR/DRA/AFPB NRR/DRA NRR/DORL NAME SRosenberg AKlein JGiitter ABoland DATE 01 / 21 / 2016 01 / 21 / 2016 02 / 02 / 2016 03 / 02 / 2016 OFFICIAL RECORD COPY