ML20151S419
| ML20151S419 | |
| Person / Time | |
|---|---|
| Issue date: | 09/01/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 9809080109 | |
| Download: ML20151S419 (4) | |
Text
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NUCLEAR REGULATORY COMMISSICH WASHINGTON. D.C. 2066MXm
%*****/ Septenber 1, 1998 Mr. James P. O'Hanlon '
Senior Vice President Virginia Power innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060
Dear Mr. O'Hanlon:
I am responding to your letter to Chairman Jackson of the U.S Nuclec Ogulatory Commission dated June 18,1998, in which you address the NRC staffs activities related to the development ;
of risk informed, performance-based fire protection regulation.
In a staff requirements memorandum (SRM) of June 30,1998 (copy enclosed), the I Commission approved the staffs recommendation to defer the development of a risk-informed, I performance-based fire protection rule and to pursue, with the National Fire Protection Association (NFPA) and the nuclear industry, the development of a risk-informed, performance-based consensus standard for fire protection at nuclear power plants. As described in SECY- l 098-058, dated March 26,1998, under this approach the Commission could accept the NFPA :
standard in a future rulemaking, as an alternative to the existing requirements, which licensees l could adopt on a voluntary basis to replace the current fire protection license condition at their {
facility, Licensees that elect not to adopt the NFPA standard and choose to maintain their i current fire protection license condition will not be required to rebaseline their fire protection i
program. i l
In your letter, you stated that the industry proposed Appendix S was rejected because "the staff )
was not ready to embrace risk information and performance bases in fire protection, because l they believed these tools were not sufficiently mature." The staff rejected the proposed I
(. Appendix S (as described in SECY-96134, dated June 21,1996) because it did not meet the '
objectives and criteria specified in SECY-94-090, dated March 31,1994, for a risk-informed, performance-based regulation. In addition, it was not apparent from the industry submittal that the proposed Appendix S would provide a level of safety equivalent to that provided by the current rule, or that the proposed Appendix S would even provide reasonable assurance of an adequate level of safety. SECY-96-134 also recommcnded that Appendix R to 10 CFR Part 50 be modified or removed and that 10 CFR 50.48 be revised to facilitate the use of risk-infomied and performance-based methods as they are developed, thus indicating the staff's willingness to adopt risk-informed, performance based methods to the extent supported by proven technologies.
In a letter dated September 15,1995, the ACRS found the proposed Appendix S defbat in that it did not meet the expectations of the ACRS for a risk-informed, performance-based regulation based on risk considerations, i
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- september 1, 1998 in a letter to Mr. L Joseph Callan, Executive Director for Operations, NRC, dated l December 11,1997, Mr. Ralph E. Beedle, Senior Vice President and Chief Nuciear Officer, Nuclear Generation, Nuclear Energy institute (NEI), provided the staff with the results of a survey conducted by NEl of all Chief Nuclear Officers, that indicated that a new fire protection rule was not desired, nor consided necessary by the industry to assure or improve safety.
On the basis of the feedback received from the interested stakeholders and the guidance specified in U.S. Government Circular Office of Management and Budget A 119 and Public Law 104-113, which encourages the adoption of national consensus standards by Govemment agencies, the staff s approach to risk-informed, performance-based fire protection has evolved to the recommendation described in SECv-098-058 and approved by the Commission in the SRM dated June 30,1998.
In your letter, you also indicated that the NEl Fire Protection Working Group is evaluating the risk implications of exemptions from the existing fire protection requirements at plants with high core damage frequencies from fire events. Ilook forward to the results of that evaluation.
The staff has worked r%sely with all the interested stakeholders in this area in the past and will continue that practs ein future activities. I hope this letter clanfies the past and future activities of the NRC related to the development of risk-informed, performance-based fire protection regulation for nuclear power plants.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosure:
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- '8 %,,). ENCLOSURE 1
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MEMORANDUM TO L Joseph Callan Executivepirscyr f,or Operatnons ,
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C. Hoyle, ecretary
SUBJECT:
STAFF REOUlREMENTS: SECY 98-058 - DEVELOPMENT OF A t RISK INFORMED, PERFORMANCE-BASED REGULATION FOR FIRE PROTECTlON AT NUCLEAR POWER Pt. ANTS The Commission approved the staffs proposal to defer development of a risk-informed, j
performance-based 6re protection rule at this time and, instead, to pursue with the National Fire i Protecbon Association (NFPA) and the nuclear industry the development of a risk informed, and !
ultimately performance-based consensus standard for Are protechon at nuclear power plants
] (Option 2 of SECY-96-058). Under this approach, the NRC staff would endorse the consensus standard, if suocessfully developed, in a rulemasung to serve as an allemative method for boonsees to meet NRC 6re protection requirements. In implementing Option 2, the staff is dirovsd to take the following actions:
1.
Work closely with the NFPA so that the consensus standard is developed on an expedited basis and to ensure that the proper risk informed, performance-based approach is maintained. The staff is diroded to update the Commission on the status of A NFPA activities, providing an assessment of progress and direcbon.
(EDO) (SECY Suspense: 11/1/90)
- 2. F ursue rulemaksn , to amend section lil M .f Appendix R to 10 CFr. Part 50 ta Miminate the requirement for non-comt ustible penetration wal material and make other minor changes to fire protectic.. regulations.
(EDO) (SECY Suspense: 11/1/98)
- 3. Closely examine plants whose individual plant examinations for extemal events
(!PEEEs) show fire protection vulnerabilities to gain a thorough understanding of the parbcular nsk contnbutors. In evaluating those facilities, consadoration le to be given to the cumulative effects of exemptions to current regulations to ensure that an adequate 4
SECY NOTE This SRM and the Commission Voting Record for SECY 98-058 will be made publicly available 5 working days from the date of the final SRM.
SECY 98 058 was made publicly available at a Commission meeting on M*'ch3' '998 nivi01u W1 29 f.
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- evel of fire protec: en .s ma nta.ne *e staff s cirected to report to the Commission the resu'ts of 'essces earnes "cr,: e .PEEE eNorts sEDOI ,SECY Suspense 5/30/99) 4 Continue to consol.cate erstung regulatcry positsons to generate a ccmprehenssve fire protection regulatory guide to be used in meeting the existing fire protection regulations (EDO) iSECY Suspense 9/30/09) 5 Summanze NRC's fire protectson related research sctsvit es conducted to date and seek Commission approval before nitiating further research (EDO) (SECY Suspense 10/1/98)
- 6. Inform the Commission on now and when the fire protection issues as listed in SECY.
97127 will be closed (EDO) .SECY Suspense. 10/1/98) cc: Chairman Jackson Commissioner D.cus Commissioner Diaz Commissioner McGaffigan !
OGC CIO CFO OCA OPA OlG Office directors, regions ACRS. ACNW. ASLBP (by E Mail)
POR DCS i
. James O'Hanlon 2
'e On the basis of the feedback received from the interested stakeholders and the guidance specified in U.S. Govemment Circular Office of Management and Budget A-119 and Public Law 104-113, which encourages the adoption of national consensus standards by Govemment agencies, the staff's approach to risk-informed, performance-based fire protection has evolve,d '
to the recommendation described in SECY-098-058 and approved by the Commission in the' SRM dated June 30,1998.
/
In your letter, you also indicated that the NEl Fire Protection Working Group is evalpIing the risk implications of exemptions from the existing fire protection requirements at plants with high core damage frequencies from fire events. Ilook forward to the results of that evaluation.
The staff has worked closely with all the interested stakeholders in this areaIn the past and will continue that practice in future activities. I hope this letter clarifies the past and future activities of the NRC related to the development of risk-informed, performance-based fire protection regulation for nuclear power plants.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated DISTRIBUITON: Public Central File SPLB R/F TJCarter (CRC-98-0450) LMarsh GHolahan $Newberry BSheron SWest PMadden Econnell Doudinot LWhitney JHolmes CBajwa POualls MSalley SPLB Ticket File PMagnanelli (CRC-98-0450) SECY OGC EDO R/F OCA OPA MKnapp CFO CIO JCa!!an AThadani HThompson PNorry JBlaha SBums FMiraglia :Wilins BBoger BTravers JRoe RZimmerman Chairman Jacksor. Commissioner Dicus Commissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\0HANLON WPD
- See Previous Concurrence SPLB.DSSA SPLB DSSA BC:SPLB.DSSA Tech Editor EConnell.' KSWest* LBMarsh' Holahan BCalure' 8/10 /98 8/10 /98 8/14 /98 8/p /98 8/13 /98 NRR- DT NRR.DD NRR.D BS ron FJMiraglia SCollins
/98 8/ /98 8/ /98 OFFICIAL RECORD COPY
James O'Hanlon 2 1
Appendix S would even provide reasonable assurance of an adequate level of safety.
SECY 96-134 also recommended that Appendix R to 10 CFR Part 50 be modified or removed and 10 CFR 50.48 be revised to facilitate the use of risk-informed and performance-based methods as they are developed, indicating the staff's willingness to adopt risk-informed, performance-based methods to the extent supported by proven technologies, in a letter dated September 15,1995, the ACRS found the proposed Appendix S deficient in that it did not meet the expectations of the ACRS for a risk-informed, performance-based regulation based on risk considerstiuns.
Based on the feedback received from the interested stakeholders and the guidance specified in U.S. Govemment Circular Office of Management and Budget A-119 and Public Law 104-113, ,
that encourages the adoption of national consensus standards by Govemment agencies, the staffs approach to risk-informed, performance-based fire protection has evolved to the ;
recommendation described in SECY 098-058 and approved by the Commission in the SRM dated June 30,1998.
In your lettor you also indicated that the NEl Fire Protection Working Group is evaluating the risk implications of exemptions from the existing fire protection requirements at plants with high core damage frequencies from fire events. Ilook forward to the results of that evaluation.
The staff has worked closely with all the interested stakeholders in this area in the past and will continue that practice in future activities. I hope this letter clarifies the past and future activities of the NRC related to the development of risk-informed, performance-based fire protection regulation for nuclear power plants.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated DISTRIBUITON: Public Central File SPLB R/F TJCarter (CRC-98-0450) LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinot LWhitney JHolmes OBajwa POualls MSalley SPLB Ticket File PMagnanelli (CRC-98-0450) SECY OGC EDO R/F OCA OPA MKnapp CFO CIO JCallan AThadani HThompson PNorry JBlaha SBums FMiraglia SCollins BBopr BTravers JRoe RZimmerman Chairman Jackson Commissioner Dieus Cornmissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\OHANLON.WPD
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BCalure 8/10/9 8/ lU98 /98 8/ /98 NRR:AADT NRR:DD NRR D BSheron FJMiraglia SCollins 8/ /98 8/ /98 8/ /98 OFFICIAL RECORD COPY l