ML18102B464
| ML18102B464 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Nine Mile Point, Kewaunee, Crystal River, San Onofre  |
| Issue date: | 01/31/2018 |
| From: | NRC/RES/DRA/PRB |
| To: | |
| D. Yeilding 301-415-0898 | |
| References | |
| Download: ML18102B464 (5) | |
Text
Risk-Informed, Performance-Based Fire Protection Implementation (NFPA 805)
The staff worked with the National Fire Protection Association (NFPA) to develop a consensus standard, NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition. In June 2004, NFPA 805 was incorporated by reference in 10 CFR 50.48(c) and published in the Federal Register (69 FR 33536). This Risk-Informed (RI) rule is a voluntary alternative to the existing deterministic fire protection requirements of 10 CFR 50.48(b).
In conjunction with the NFPA 805 rule, the Nuclear Energy Institute (NEI) developed an implementation guide, NEI 04-02, Guidance for Implementation a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c). In May 2006, NRC issued Regulatory Guide (RG) 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants endorsing Revision 1 of NEI 04-02. NEI 04-02 was again revised (Revision
- 2) in April 2008 and the staff endorsed the revision in RG 1.205, Rev. 1, December 2009. 51 operating nuclear power plant units sent the NRC a letter of intent to adopt NFPA 805 as their licensing basis; however several units withdrew their letters of intent, or decided not to pursue NFPA 805 for various reasons.
In 2005, the NRC chose two sites; Oconee and Shearon Harris to pilot their transition to the NFPA 805. From 2005 to 2008, observation visits were conducted with the pilot plants to document the progress and address any implementation issues. Trip reports documented the lessons learned from these visits.
In 2006, a Frequently Asked Question (FAQ) process was developed to review and establish a preliminary staff position on implementation issues identified during, or in parallel with the pilot plant reviews (RIS 2007-19). To date, the staff continues to hold monthly public meetings with the NEI NFPA 805 Task Force to address FAQs as they are identified and to status the current NFPA 805 reviews. Resolution of FAQs are documented in publicly available memos, and then incorporated into the next NEI 04-02 revision, which the NRC would endorse in a revision to RG 1.205, or other reference document (e.g., NEI 00-01, NUREG/CR-6850, etc.).
In 2008, the pilot plants submitted license amendment requests (LARs), per 10 CFR 50.90, to transition their 10 CFR 50.48(b) fire protection program to a risk-informed 10 CFR 50.48(c) program.
The LARs were 600 to 800 pages in length and had thousands of background calculations maintained at the site. Regulatory audits and clarification visits and calls were held to review these LARs and site calculations. NRC licensed facility set-up SharePoint Portals, so the staff could review these on-site calculations more efficiently. The staff asked numerous RAIs (requests for additional information) and the site supplied additional supplemental information to be reviewed and placed on the public docket. The staff also conducted Fire Probabilistic Risk Assessment (PRA) reviews to assure adequate quality and completeness for these applications. Subsequent plants are conducting independent industry peer reviews per industry standards, as endorsed by RG 1.200, and the staff is utilizing these peer reviews as part of the staff evaluations of the PRA quality.
The Shearon Harris and Oconee NFPA 805 applications to transition to NFPA 805 were approved in 2010.
The staff is currently reviewing 2 non-pilot NFPA 805 LARs; and expects one LAR by April of 2018.
The Office of Research continues to work with the Electric Power Research Institute (EPRI) to develop essential documents for the successful implementation of the NFPA 805 rule. The first document was NUREG/CR-6850, Fire PRA Methodology for Nuclear Power Facilities, September NRC Risk-Informed Activities Public Website - Annual Update January 2018 NRR/DRA
2005 and the second was NUREG-1824, Verification and Validation of Selected Fire Models for Nuclear Power Plant Applications, May 2007. Credible Fire PRAs and Fire Models help ensure the application of risk is appropriate for the NRCs fire protection regulation. Collaboration with EPRI brought together nationally recognized technical experts to document the state-of-the-art in Fire PRA methodology and verify and validate fire models.
The staff developed a Standard Review Plan (SRP) 9.5.1.2 to review the risk-informed fire protection LARs for plants transitioning to NFPA 805. This SRP builds off lessons learned from the pilot plant reviews, NEI 04-02, FAQs, and RG 1.205.
It has also been recognized that, for the near-term, fire PRA methods are being further refined and will evolve as they are used. To ensure new methods are acceptable, the industry has established a Fire PRA Methods Task Force to review these refinements or new methods. In parallel, NRR is taking the lead to interact with the industry task force.
Web-site: http://www.nrc.gov/reactors/operating/ops-experience/fire-protection.html Project Considerations: Lack of industry Fire PRA expertise has slowed the transition process as the limited expertise impacts the ability of licensees to develop the fire PRAs as well as impacting the availability of the experts to perform the related industry peer reviews.
Issues with new fire PRA analysis methods that are being submitted during the LAR is slowing the review process.
Completed Milestones DC Cook: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Duane Arnold: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Callaway: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Ft. Calhoun: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Waterford: Accepted LAR, Conducted Site Audit, Sent RAIs; Accepted Licensee Re-submittal of LAR, Conducted Site Audit, Sent RAIs, Issued SE VC Summer: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE ANO-2: Non-Accepted LAR for Review; LAR Re-submittal Accepted, Conducted Site Audit, Sent RAIs, Issued SE Cooper: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Nine Mile Point: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Turkey Point: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Prairie Island: Withdrew LAR, LAR Re-submittal accepted, Conducted Site Audit, Sent RAIs, Issued SE Farley: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Brunswick: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Palisades: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Browns Ferry: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE St. Lucie: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Ginna: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Point Beach: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Diablo Canyon: Accepted LAR, Conducted Site, Audit, Sent RAIs, Issued SE McGuire: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Robinson: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Catawba: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Calvert Cliffs: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Beaver Valley: Accepted LAR, Conducted Site Audit, Sent RAIs, Preparing SE ANO-1: Accepted LAR, Conducted Site Audit, Sent RAIs, Issued SE Davis Besse: Accepted LAR, Conducted Site Audit, Sent RAIs, Preparing SE Hatch: LAR to be Submitted April 4, 2018 NOTE: Monticello, Nine Mile Point 2, Kewaunee, Crystal River 3, and San Onofre 2&3 withdrew their commitments to transition to NFPA 805.
Selected Major Milestones and Schedules Major Milestones Target Date Revised Date SE Completion Date NRC Responsibility
- Disposition Duane Arnold LAR Aug 2013 Feb 2014 Sept 2013 NRR/DRA NRR/DORL
- Disposition Callaway LAR Sept 2013 Mar 2014 Jan 2014 NRR/DRA NRR/DORL
- Disposition Ft. Calhoun LAR Oct 2013 Apr 2014 June 2014 NRR/DRA NRR/DORL
- Disposition Waterford LAR Dec 2013 Jan 2016 June 2016 NRR/DRA NRR/DORL
- Disposition Cooper LAR June 2014 April 2014 NRR/DRA NRR/DORL
- Disposition Nine Mile Point LAR July 2014 June 2014 NRR/DRA NRR/DORL
- Disposition ANO-2 LAR Dec 2014 Feb 2015 NRR/DRA NRR/DORL
- Disposition Turkey Point LAR Apr 2014 Nov 2014 May 2015 NRR/DRA NRR/DORL
- Disposition Prairie Island Dec 2014 Dec 2016 Aug 2017 NRR/DRA NRR/DORL
- Disposition Farley LAR Sep 2014 Jan 2015 Mar 2015 NRR/DRA NRR/DORL
- Disposition Brunswick LAR Sep 2014 Nov 2014 Jan 2015 NRR/DRA NRR/DORL
- Disposition Palisades LAR Dec 2014 Feb 2015 NRR/DRA NRR/DORL
- Disposition Browns Ferry LAR Dec 2014 Oct 2015 Oct 2015 NRR/DRA NRR/DORL
- Disposition St. Lucie LAR Mar 2014 Nov 2015 Mar 2016 NRR/DRA NRR/DORL
- Disposition Ginna LAR Mar 2014 Nov 2015 Nov 2015 NRR/DRA NRR/DORL
- Disposition Point Beach LAR Jun 2014 Nov 2015 Sep 2016 NRR/DRA NRR/DORL
- Disposition Diablo Canyon LAR Jun 2014 Jun 2016 Apr 2016 NRR/DRA NRR/DORL
- Disposition Robinson LAR Sept 2015 Dec 2016 Feb 2017 NRR/DRA NRR/DORL
- Disposition Calvert Cliffs LAR Sept 2015 Dec 2015 Aug 2016 NRR/DRA NRR/DORL
- Disposition McGuire LAR Sept 2015 Oct 2016 Dec 2016 NRR/DRA NRR/DORL
- Disposition Catawba LAR Sept 2015 Oct 2016 Feb 2017 NRR/DRA NRR/DORL
- Disposition Beaver Valley LAR Sept 2015 Dec 2016 NRR/DRA NRR/DORL
- Disposition ANO1 LAR Nov 2015 Jan 2016 Oct 2016 NRR/DRA NRR/DORL
- Disposition Davis Besse LAR Dec 2017 May 2018 NRR/DRA NRR/DORL
- Disposition Hatch LAR Apr 2020 NRR/DRA NRR/DORL
- Exclusionary Memos have been published for the following plants currently under review:
Beaver Valley and Davis-Besse.