ML16252A419
| ML16252A419 | |
| Person / Time | |
|---|---|
| Issue date: | 09/08/2016 |
| From: | Daniel Frumkin NRC/NRR/DRA/AFPB |
| To: | Anderson V, Jeffrey Reed Nuclear Energy Institute |
| Frumkin D | |
| References | |
| Download: ML16252A419 (33) | |
Text
Frumkin, Daniel From: Frumkin, Daniel Sent: Thursday, September 08, 2016 2:32 PM To: REED, Joseph Cc: ANDERSON, Victoria (vka@nei.org); Casto, Greg
Subject:
PDF Version of NRR Slides for 2016 Fire Protection Forum Attachments: 2016 FPIF - NFPA 805 Status.pdf; 2016 FPIF - PRA Update Forum Presentation.pdf; 2016 FPIF - Regulatory Guide Updates.pdf; 2016 FPIF - VEWFDS Forum Presentation.pdf
- Joseph, Attached are PDF versions of the slides I sent you earlier if you need them. They are for the four presentations that I have at the 2016 NEI Fire Protection Information Forum. These slides are identical to the previous slides
- so please use whichever works best for your setup.
See you next week.
Dan Daniel M. Frumkin Sr. Fire Protection Engineer NRR/DRA/AFPB 301-415-2280 1
NFPA 805 Status Daniel M. Frumkin Senior Fire Protection Engineer NRR/DRA/AFPB 2016 NEI Fire Protection Information Forum
This is a diagram that the NRC has used to explain the stages of transition.
Licensee Completes Implementation Items and Plant Modifications NRC Issues Safety Evaluation and License Licensee Submits LAR Licensee Submits Letter of Intent Stage 1 Stage 2 2/18/2016 - 2/25/2016 Stage 3 Stage 4 NFPA 805 LAR NRC Reviews NFPA 805 License NFPA 805 License Development NFPA 805 LAR Transition Period Post-Transition Period 2/18/2016 - 2/25/2016 2/18/2016 - 2/25/2016 2/18/2016 - 2/25/2016 Enforcement Discretion Limited Self Approval Self Approval
Out of 100 licensed reactors, 46 intend to or have transitioned to NFPA 805.
Licensee Completes Implementation Items and Plant Modifications NRC Issues Safety Evaluation and License Licensee Submits LAR Licensee Submits Letter of Intent Stage 1 Stage 2 2/18/2016 - 2/25/2016 Stage 3 Stage 4 NFPA 805 LAR NRC Reviews NFPA 805 License NFPA 805 License Development NFPA 805 LAR Transition Period Post-Transition Period Two Enforcement Discretion Eleven 2/18/2016 - 2/25/2016 Twenty-two 2/18/2016 - 2/25/2016 Limited Self Approval Eleven 2/18/2016 - 2/25/2016 Self Approval reactors reactors reactors reactors Leaving 54 reactors with no documented intent to adopt NFPA 805 as of August 2016.
Or if we look at amendments, the NRC has reviewed or expects to review 29 amendments.
Licensee Completes Implementation Items and Plant Modifications NRC Issues Safety Evaluation and License Licensee Submits LAR Licensee Submits Letter of Intent Stage 1 Stage 2 2/18/2016 - 2/25/2016 Stage 3 Stage 4 NFPA 805 LAR NRC Reviews NFPA 805 License NFPA 805 License Development NFPA 805 LAR Transition Period Post-Transition Period One Enforcement Discretion Seven 2/18/2016 - 2/25/2016 Thirteen 2/18/2016 - 2/25/2016 Limited Self Approval Eight 2/18/2016 - 2/25/2016 Self Approval LAR LARs LARs LARs Estimate as of end of August 2016.
The NRC has one active letter of intent. The request is expected in 2018 Plant Hatch
There are nine applications under review, most are expected to be completed by early 2017.
Will others adopt NFPA 805? Depends on licensee experience with the transition and use.
NRR is supporting each first NFPA 805 triennial, and developed inspector training on NFPA 805.
Supplemental Slide Results from 2014 fire protection metrics report, see ML15124A908.
Fire PRA Updates and FAQ 16-0076 Daniel M. Frumkin Senior Fire Protection Engineer NRR/DRA/AFPB 2016 NEI Fire Protection Information Forum
NEI and NRC staff have been working on information to clarify fire PRA updates.
New Accepted Methods New Operating Experience Support of Applications 2
This effort started as an industry white paper, but has transformed into FAQ 16-0076.
Industry Proposal for Implementation of New Methods and Data, Including 2014 Ignition Frequencies ML15260A588 3
NRC staff and industry stakeholders are revising the FAQ to support a common understanding.
FAQ 16-0076 - NFPA 805 Fire PRA Update Process ML16208A082 4
Per the PRA standard (not NFPA 805) Upgrade and Maintenance have specific meanings.
Maintenance:
More frequent Less involved Are both Updates to the Upgrade: considered Fire PRA Less frequent More involved 5
After the August 9, 2016, industry stakeholders agreed to work together to revise FAQ 16-76.
There is general agreement on the concepts, but there is more work to be done.
Language needs to be clear to staff and stakeholders. Public meeting planned to write and resolve FAQ language.
Stable Regulatory Framework 7
Fire Protection Regulatory Guide Updates Daniel M. Frumkin Senior Fire Protection Engineer NRR/DRA/AFPB 2016 NEI Fire Protection Information Forum
There are two regulatory guides associated with nuclear power plant fire protection.
RG 1.189 RG 1.205 General Fire Protection NFPA 805 Fire Protection
Draft revision of NEI 00-01 is expected to be shared with NRC staff in September 2016.
Jacque-Fire 3 - NUREG/CR-7150 Treatment of spurious operations Treatment of other circuit issues NEI 00 Industry Implementing Guidance NEI intends to add Rev. 2 RG Jacque-Fire 3 Other operating experience language Begin development of RG 1.189
The current Regulatory Guide 1.205 endorses portions of NEI 04-02.
NEI 04-02, Revision 2:
Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c)
Draft revision of NEI 04-02, could be to the NRC in the middle of October 2016.
NEI 04 Industry implementing guidance for NFPA 805 Other industry lessons Incorporate FAQs learned Begin development of RG 1.205
The receipt by NRC of NEI 00-01 and 04-02, will start a process to review those documents.
Following review of NEI 00-01 and 04 NEI will issue the documents as final and the NRC will begin the regulatory guide update process which takes at least 11 months.
Supplemental Slide TIA 2013-02, regarding single spurious actuation assumption.
Single Spurious Assumption for Braidwood and Byron Stations Safe-Shutdown Methodology March 31, 2014 - NRC issued TIA 2013-02 (ML12194A500)
June 24, 2014 - NEI commented back to the NRC about the TIA conclusion - (ML14178B223 and ML14178B222)
VEWFDS and FAQ 08-0046 -
Regulatory Perspectives Daniel M. Frumkin Senior Fire Protection Engineer NRR/DRA/AFPB 2016 NEI Fire Protection Information Forum
There are three sources for Very Early Warning Fire Detection (VEWFDS) methods.
NUREG/CR-6850 NFPA 805 FAQ 08-0046 Draft NUREG-2180 2
The content and methods in NUREG-2180 will be discussed by NRC Research staff.
June 2015 - Draft Report Published for Public Comment ML15162A416 3
The staff held a public meeting on April 26, 2016 to discuss the technical content of the NUREG.
Meeting Summary ML16144A498, ML16144A499, and ML16145A522 4
Public meeting to discuss NEI letter regarding results of industry tabletop exercise.
Four concerns (from public meeting announcement):
- 1 - Completeness
- 2 - Risk Improvement
- 3 - Wording in Appendix D
- 4 - Component vs. Cabinet Damage NEI Letter Accession numbers ML16237A403 and ML16211A327 Meeting Notice Accession Number ML16237A420 5
Based on NUREG-2180, the staff recognized that FAQ 46 credit could not be confirmed.
NRC retired FAQ 46 in July 2016 to stop future use.
Continued use of the FAQ is dependent each plants NFPA 805 licensing basis.
FAQ Retirement Letter ML16167A444 6
There are different expectations for plants in Licensee Completes Implementation Items and Plant Modifications different stages NFPA 805 transition.
NRC Issues Safety Evaluation and License Licensee Submits LAR Licensee Submits Letter of Intent 1 Stage LAR 1 3Stage LARs2 2/18/2016 - 2/25/2016 Stage 3 10 LARs Stage 4 NFPA 805 LAR NRC Reviews NFPA 805 License NFPA 805 License Development NFPA 805 LAR Transition Period Post-Transition Period 2/18/2016 - 2/25/2016 2/18/2016 - 2/25/2016 2/18/2016 - 2/25/2016 Enforcement Discretion Limited Self Approval Self Approval Dont use FAQ 46 . . . VEWFDS credit . . . [E]valuate [VEWFDS
- Use latest OpE will be assessed on a credit] in accordance and guidance plant by plant basis. with licensing basis.
upon submittal.
- Use sensitivity to
- FAQ 46 is part of current understand delta licensing basis.
risk/RG 1.174.
- Incorporate latest OpE as
- Continue to final NRC scheduled for review. implementation.
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