ML20205Q640
| ML20205Q640 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/1999 |
| From: | Hannon J NRC (Affiliation Not Assigned) |
| To: | Holahan G NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9904210356 | |
| Download: ML20205Q640 (25) | |
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UNITED STATES g.
g NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20066-0001
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April 15,1999 MEMORANDUM TO: Gary M. Holahan, Director Division of Systems Safety and Analysis Office of Nuclear Reactor Reg ati n FROM:
John N. Hannon, Chief Plant Systems Branch Division of Systems S ty and Analysis Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF NRC MEETING WITH THE NUCLEAR ENERGY INSTITUTE HELD ON MARCH 25,1999 During a December 2,1998, meeting with the Nuclear Energy Institute (NEI), the U.S. Nuclear Regulatory Commission (NRC) staff requested additionalinformation about NEl's reactor fire protection initiatives and their interfaces with NRC initiatives. By letter dated January 19,1999, NEl responded to the staff request. On March 25,1999, the Office of Nuclear Reactor Regulation (NRR) and the Office of Nuclear Regulatory Research (RES) held a one-day meeting with NEl to discuss these initiatives and other reactor fire protection topics. The main topics of the meeting were:
Reactor fire protection inspection and assessment e
Fire protection standards and guidance development e
e Fire-induced circuit failures e Development and use of risk methods is the meeting agenda and Attachment 2 is a list of meeting attendees.
NRR staff established the context for the meeting by presenting its newly-developed " Reactor Fire Protection Master Plan" diagram (Attachment 3, originally titled " Planned Fire Protection Regulatory Process"). The diagram shows the interrelationships batween the existing fire protection regulatory requirements and guidance, planned requirements and guidance, major technical and safety issues, major fire research activities, licensee efforts (e.g., Individual Plant
,k Examination of Extemal Events and self-assessments), existing NRC inspection procedures, fU the fire protection functional inspection (FPFI) pilot program, the proposed reactor oversight y
process fire protection inspection procedures, ongoing and future initiatives related to fire protection inspections (e.g., fire protection program performance indicators and the method mg(h CONTACT:
L. Whitney, SPLB/DSSA/NRR Vh 301-415-3081
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Gary M. Holahan 2
NRR is developing for assessing the risk significance of such fire protection deficiencies as inspection findings), and new inspection procedures for use at plants that change their fire protection programs in the future to be risk-informed and performance-based. For each of the aforementioned meeting topics and for each element of the master plan, the meeting participants discussed the scope of work, schedules and status; organizationalinterfaces; and opportunities for coordination and cooperation.
The meeting participants discussed the significance of fire risk at U.S. commercial reactor plants and agreed that fire can be an important and even a dominant contributor to risk at some plants. To aid future discussions, after the meeting the staff prepared a ' fire risk fact sheet.
This fact sheet is included as Attachment 4.
I J.S. Hyslop, Probabilistic Safety Assessment Branch, NRR, led a discussion of the method NRR is developing to assess the risk significance of fire protection deficiencies (e.g., inspection findings). The staff plans to incorporate this methodology into the new reactor oversight process. Attachment 5 is the set of slides used for the discussion. The staff agreed to share with industry the supporting methodology documentation as part of the development of the new reactor oversight process.
The NRC staff and the NEl representatives agreed that the meeting was usefulin fostering a common understanding of ongoing and planned reactor fire protection initiatives. For each topical issue, plans, milestones, and schedules were agreed upon. Overall, the resolution of the fire-induced circuit failure issue, the continued development of NFPA 805, the development of the new reactor oversight process (fire protection inspection procedures and fire risk assessment methodology), and development of FPFI recommendations for Commission consideration will continue to be given high priority; the development of performance indicators, self-assessment procedures, and the comprehensive fire protection regulatory guide are of secondary importance; and NEl's proposal to develop specific risk applications is of lower priority and will be deferred in the short term. Attachments 6,7,8 and 9 provide additional background information and detailed summaries of the discussions of the four major reactor fire protection topicalissues discussed during the meeting.
Project No. 689 cc w/ attachments: See next page Attachments:
- 1. Meeting agenda.
- 2. List of meeting attendees.
- 3. Planned Fire Protection Regulatory Process (Revision 0) Chart
- 4. Fire Risk Fact Sheet
- 5. Slides for a presentation of proposed fire risk assessment method
- 6. Summary of discussions relating to fire protection inspection and assessment
- 7. Summary of discussions regarding fire protection standards and guidance development
- 8. Summary of discussions regarding fire-induced circuit failures
- 9. Summary of discussions regarding the development of risk methods 1j
r O
Nuclear Energy Institute Project No. 689 cc:
Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief NuclearOfficer Nuclear Energy Institute Nuclear Energy institute Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director Programs Washington Operations Nuclear Energy Institute ABB-Combustion Engineering, Inc.
Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Engineering Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director c
Licensing Nuclear Encrgy institute Suite 400 1776 l Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 555 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708
t s
Gary M. holahan l
SUBJECT:
SUMMARY
OF NRC MEETING WITH THE NUCLET.R ENERGY INSTITUTE HELD ON MARCH 25,1999 DISTRIBUTION:
Central File SStein SPLB R/F MJohnson SCollins MBranch BSheron AMadison GParry JBrady JHannon BBoger SWest FGillespie LWhitney TKing, RES EConnell MCunningham, RES JHolmes WRuland, Ri PMadden KLandis, Ril DOudinot RGardner, R!ll MSalley DPowers, RIV TEaton TShediosky, RI RJenkins WRogers, Ril RBarrett SBurgess, Rlli AEl-Bassioni WJones, RIV SWong PUBLIC JSHys'op PWilson DCoe RWoods, RES ARubin, RES NSlu, RES MDey, RES ASingh, ACRS a
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ATTACHMENT 1 NRC/NEl Meeting Agenda Discussion of Issues from NEl Letter of January 19,1999 Date: March 25,1999 j
Location: One White Flint North, Rm O-12-B-4 Rockville, Maryland 9:30 -12:00 Executive Session Planned Fire Protection Regulatory Process Chart (NRC e
Handout)
Fire Risk Significance at U.S. Comm. Reactors e
Presentation: FP Degradation and Deficiency Risk e
Assessment Methodoiogy (SPLB/NRR) 12:00 -1:00 Lunch Break 1:00 -2 00 Staff Discussion, Issue 1 - FP Insp. & Assessment 2:00 - 3:00 Staff Discussion, issue 2 - Fire Protection Standards and Guidance D2velopment 3:00 - 3:15 Break 3:15 - 4:00 Staff Discussion, Issue 3 - Fire Induced Circuit Failures 4:00 - 4:45 Staff Discussion, Issue 4 - Fire Protection Risk Application Development 4:45 - 5:00 Wrap-up and Adjourn
Proposed Agenda for Meeting with NEl issue 1: Fire Protection inspection and Assessment Executive Session Development of an agreed upon set of fire protection performance indicators (Pis) for all e
areas of fire protection defense-in-depth could allow a reduction in the level of direct inspection effort in the NRC's fire protection baseline proposal.
Should the draft Pi development process reach closure through a joint NRC/ industry effort, or independent work by either NEl or NRC for presentation to the other organization?
Staff Discussion NEl letter of January 19,1999 topics:
Discussion of a potentialindustry self-assessment program using FPFI inspection guidance (with reduced FPFI frequency or FPFI phaseout).
Discussion of the NEl position that full-scope FPFI team inspections should be conducted only when licensee performance in the fire protection and safe shutdown areas approaches the Unacceptable Performance Band.
Dlscussion of the difference between " regulatory requirement modules" and
- performance j
enhancement modules" as phrased in the NEl letter.
Discussion of the NEl proposal that there should be Joint NRC/ industry development of l
fire protection performance indicators. [See the PI topicalitem for consideration during the Executive Session above.]
2-
Proposed Agenda for Meeting with NEl Issue 2: Fire Protection Standards and Guidance Development Executive Session The NFPA 805 Standard, if given NRC endorsement, would offer an independent, self-e con *31ned altemative approach for the establishment of licensee fire protection programs and regulatory compliance. Would 't then be appropriate for its features to be used selectively within the existing Appendix R regulatory compliance process?
Staff Discussion Discussion of possible select:ve use of NFPA 805 risk-informed, performance based fire e
protection standard features by licensees within the existing, deterministic 10 CFR 50.48/ Appendix R/NUREG 0800 regulatory process.
Discussion of the schedule for NEl provision of detailed comments on the o
Comprehensive Fire Protection Regulatory Guide outline.
Discussion of the staff's stated plan within the Comprehensive Fire Protection Regulatory e
Guide program to collect the existing reguiatory guidance information and also enhance the guidance where it has weaknesses or is lacking.
i 1
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i Proposed Agenda for Meeting with NEl l
Issue 3: Fire-induced Circuit Failures Executive Session Discussion of schedules for industry to come forward with products (e.g. topical reports) aimed at reaching closure on the fire-induced circuit failures issue.
Staff Discussion The NEl letter of January 19,1999 stated in essence that:
Discussion of NEl Step 1: A future generic method for screening multiple " mechanistic" e
cable to cable circuit failures / interactions.
Discussion of NEl Step 2: Plant-specific risk methods to determine the safety significance of potential circuit interactions not screened out in NEl Step 1. If the numerical risk product of 1) damaging fire frequency,2) failure to recover redundant equipment, and 3) unavailability of [non-analyzed?] equipment [that can be used for post-fire safe shutdown?] is below a set threshold, screen out the interaction.
Discussion of NEl Step 3: Analysis of remaining potential failures deterministic-ally and take appropriate actions, which may include some instances of " multiple spurious interactions."
Discussion of the potential for NEl's risk-informed method to eliminate certain licensee circuit analyses (specifically multiple, non hi/lo interface, spurious electrical interactions) previously expected by the NRC, resulting in "non-compliance." NEl stated that "In the spirit of COMSAJ-97-008, industry and NRC should agree on how to determine the safety significance of potential fire-induced circuit failures and have licensees address those which are safety significant."
l.
i Proposed Agenda for Meeting with NEl issue 4: Fire Protection Risk Application Development Executive Session Discuss the overall FP Master Plan with a view toward understanding how risk e
applications can be applied to help reach closure on fire protection issues.
Discuss staff and resource commitments needed to complete additional research.
Staff Discussion Develop a preliminary consensus on priorities for risk-informed applications development, e
employing criteria developed in executive session.
Conduct preliminary discussion conceming scope and closure methodology for higher priority applications.
Discuss schedule and process for developing and applying risk-informed methods for closing fire protection issues. Include discussions of NEl-proposed near term milestones and an NRC-proposed process.
l Identify additional research needed and establish milestones for action.
e i
ATTACHMENT 2 MEETING ATTENDEES NAME ORGANIZATION Gary Holahan Div. Systems Safety and Analysis /NRR John Hannon Plant Systems Branch /NRR Steven West Plant Systems Branch /NRR Patrick Madden Plant Systems Branch /NRR Ed Connell Plant Systems Branch /NRR Leon Whitney Plant Systems Branch /NRR J.S. Hyslop Probabilistic Safety Assessment Branch /NRR See-Meng Wong Proba5::istic Safety Assessment Branch /NRR Steve Stein Inspection Program Branch /NRR Morris Branch Inspection Program Branch /NRR Thomas King Division of Systems Technology /RES Alan Rubin Probabilistic Risk Analysis Branch /RES Nathan Siu Probabilistic Risk Analysis Branch /RES l
Moni Dey Probabilistic Risk Analysis Branch /RES David Modeen Nuclear Generating Division /NEl Fred Emerson Nuclear Generating Division /NEl Sheldon Trubatch Winston and Strawn David Stellfox McGraw-Hill Mike Cooper Entergy-ANO Theresa Sutter Bechtel E.R. Schmidt Scientech Mike Callahan Seti
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ATTACHMENT 4 FIRE RISK FACT SHEET The average reported fire frequency at operating plants for the period 1965-1994 is 3.3E-e 1/yr' The average reporld fire frequency for the pre-Appendix R implementation period 1965 -
1985 is 3.8E-1/yr' The average reported fire frequency for the post-Appendix R implementation period 1985 e
- 1994 is 2.8E-1/yr' During the post-Appendix R implementtJon period (1986-1994) there were two fire e
events that resulted in a scram and a loss of function of cae safety related division or a loss of offs;te power. This compares to 10 such events (not including the Browns Ferry fire) during the pre-Appendix R implementation period (1965-1985).'
There were 41 fire events that resulting in a plant scram with no loss of function of a e
safety related division in the 20 year pre-Appendix R implementation period and 40 such events in the 8 year post-Appendix R period.'
ThMeen large losses from fire events at nuclear power plants during the period from e
1966 - 1995 resulted in a total reported monetary loss of approximately $800 million, with
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an average monetary loss per event of approximately $62 million.2 On June 21,1991, the NRC issued GL 88-20, Supplement 4, requesting licensees to e
perform an Individual Plant Examination of External Events (IPEEE) to (1) develop an appreciation of severe accident behavior, (2) understand the most likely severe accident sequences, (3) gain a cualitative understanding of the overalllikelihood of core damage and radioactive release, and (4) if necessary, to reduce the overalllikelihood of core damage and radioactive release by modifying hardware and procedures tbst would help l
prever,t or mitigate severe accidents.
Based on the IPEEE results, fire events are important contributors to the reported core damage frequency (CDF) for a majority of plants. The reported CDF contribution from fire events can in some cases, approach (or even exceed) that from internal events.'
'Special Study Fire Events - Feedback of U.S. Operating Experience, June 1997, James R. Houghton, Office for Analysis and Evaluation of Operational Data, USNRC 2
A 30-Year review of Large Losses in the Gas and Electric Utility Industry - 1966 - 1995, James B. Biggins, J&H Marsh & McLennan,1997 8
NUREG 1407 - Procedural and Submittal Guidance for the Individual Plant Examination of Extemal Events (IPEEE) for Severe Accident Vulnerabilities, USNRC, June 1991
" January 20,1998, memorandum to the Commissioners from L Joseph Callan, Executive Director for Operations, Prehminary IPEEE Insights Report
The reported IPEEE fire CDFs range on the order of E-9/yr to E-4/yr, with the majority of plants reporting a fire CDF in the range from 1E-6/yr to 1E-4/yr.5 A majority of plants have proposed or implemented plant improvements to address concerns identified through the IPEEE.*
Although most licensees have reported numerical fire CDF estimates, it is important to note that the accuracy of such estimates has not been validated under the IPEEE submittal review. Because simplifying assumptions and approximate procedures may have been used in the analyses, the quantified CDF estimates reported in the licensees' IPEEE submittals should only serve as a generalindicator of plant risk. With that in mind the following preliminary information is provided.
Fire CDFs for approximately 40 units were greater than or equal to 1E-5/yr.
e Fire CDFs for approximately 11 units were greater than or equal to 1E-4/yr.
Of those 29 units whose fire CDF was between 1E-5/yr and 1E-4/yr, approximately 17 had a repo'ted fire CDF greater than or equal to the reported intemal events CDF.
Of those 11 units whose fire CDF was greater than or equal to 1E-4/yr,9 units had a fire CDF greater than or equal to the reported internal events CDF. For the remaining 2 units the fire CDF was comparable to the internal events CDF.
51his range includes all plants except Quad Cities. The licensee for Quad Cities will submit a revised and updated IPEEK fire analysis during May 1999.
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ATTACHMENT 6 FIRE PROTECTIONINSPECTION AND ASSESSMENT Until April 12,1999 the NRC's reactor oversight process task force willinformally collect comments on the draft inspectable area baseline procedures, including those for fire protection.
By the end of April 1999, the staff willissue revised versions of the baseline inspection procedures for use during the new reactor oversight process pilot program. The pilot program is scheduled to begin in June 1999. The staff plans to conduct a public workshop on performance indicators in mid April 1999.
The meeting participants agreed that it would be difficult to develop performance indicators for reactor fire protection programs (an area which includes fire protection features and post fire sale shutdown capability). NEl stated that it had formed an issues task force to develop such performance Indicators. NEl plans to complete small-scale performance indicator pilot trials at reactor sites 5y July 2000. The staff indicated that if valid fire protection performance indicators are developed, it would consider how to take advantago of them in the reactor oversight process. For example, the staff would c'atermine if they should be used to change the scope or frequency of the baseline fire protection inspection program.
NEl stated that an NEl issue task force is developing procedures to help licensees conduct self-assessments of reactor fire protection programs. NEl indicated that its future self-assessment procedures could by used by licensees on a voluntary basis to benchmark its fire protection and post-fire safe shutdown configurations as appropriate. For example,in advance of NRC baseline fire protection inspections. NEl plans to phase in the licensee self-assessments beginning the summer of 1999. Conceptually, the self-assessments would involve detailed, plant-specific, commitment reviews followed by focused assessments against the risk-prioritized commitments. Higherlevel self-assessments (conducted in response to findings of the commitment reviews or the self-assessment itself) would use a " vertical slice" approach and could be equivalent in scope and depth to that of the NRC's pilot fire protection functional inspections (FPFI).
The NRC staff informed NEl that its proposed baseline fire protection procedure directs the NRC inspection team to incorporate the results of licensee self assessments, when available, into the inspection plans for the triennial baseline fire protection inspections.
The NEl representatives asked whether the " potential fire related vulnerabilities" section of the pilot FPFI procedure (which focused on potential fire related events not necessarily addressed within regulatory requirements) would be retained in the new reactor oversight process. The NRC staf! stated that ln the baseline fire protection procedure it would reference the version of the pilot FPFI procedure that was used to inspect the Prairie Island self-assessment during the FPFI pilot program. This version does include the
- potential fire related vulnerabilities" section.
However, the NRC staff stated that the long-term retention of this FPFI procedure section had not been determined.
NEl also asked whether the staff would break the FPFI procedure into separate modules, as the staff oiscussed during the FPFI workshop. The NRC staff stated that when it finalizes the l
FPFi procedures (as part of the implementation of the new reactor oversight process),it would reformat the FPFI procedure to emphasize its existing modular nature.
I
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1 ATTACHMENT 7 FIRE PROTECTION STANDARDS AND GUIDANCE DEVELOPMENT The staff and NEl agreed that the continued development of NFPA 805 was a high priority while the development of the comprehensive fire protection regulatory guide was of secondary importance.
NFPA 805 The NRC staff and NEl agreed that the development of the standard was more challenging than originally anticipated and agreed to continue leveraging its resources and technical expertise as needed to support NFPA's efforts to complete the standard. RES indicated that it was now using technical assistance contractors to cupport its work on the standard and NRR indicated that it would consider doing so in the future if necessary.
The discussions focused on technical issues that could have policy implications. The first issue i
dealt with the concept of the " baseline" fire protection program that is specified in the current draft of the standard and how this concept could affect a licensee's decision to adopt the final standard. The staff indicated that it would continue to work with the NFPA 805 technical committee on this issue. Nevertheless, the staff indicated that this issue could have policy implications if the final NFPA standard (1) specifies a " baseline" fire protection program that many licensees do not urrently meet or (2) would require significant licensee resources to
- re-baseline" existing grams before they could adopt the standard.
4 The second issue cc 7med whether or not the NRC would accept the use of the risk methods that will be embodied i.. NFPA 805 to make risk-informed changes to existing fire protection programs without opting for the new risk informed, performance-based reactor fire protection regulation. (The proposed risk-informed, performance-based reactor fire protection regulation is planned as a voluntary attemative to the existing regulatory requirements. NFPA 805, if successfully developed and endorsed by the NRC, would be an acceptable means of meeting the new regulatory requirements.) The NRC staff indicated that the existing regulatory process would not preclude the use of the risk methods that will be specified in NFPA 805 to make risk-informed changes to existing fire protection programs. The staff postulated, for example, thet a licensee could use an NFPA 805 method under RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions in Plant-specific Changes to the Licensing Basis."
The staff noted that one of the Commission's objectives in going forward with an optional risk-informed, performance-based reactor fire protection regulation was to eliminate or minimize the need for future exemptions. For the Appendix R plants, using the risk methods specified NFPA 805, without opting for the new regulation as its licensing basis, could result in the need for new exemptions. Since this possibility is counter to the Commission's objective, this may present a new policy issue.
Comorehensive Fire Protection Reoulatory Guide NEl repeated a request it had made during a meeting of February 25,1999; that the NRC make available for stakeholder comment an early draft of the proposed regulatory guide (RG) before its formal publication in the Federal Reaister. NEl stated that this would give the licensees an opportunity to compare the proposed RG to the existing reactor licensing bases and identify staff positions, if any, that are embedded in a plant-specific basis, but were not captured in the
b n
4 ATTACHMENT 8 FIRE-INDUCED CIRCUIT FAILURES The staff and NEl agreed that ongoing efforts to address and resolve the fire-induced circuit failure issue should continue to receive high priority.
NEl described its three-step risk-based methodology for addressing fire-induced circuit failures.
Step 1 is the development of a " Characterization Criteria Document." This potentiallicensee guidance document will identify potential circuit failure modes for specific conditions and arrangements. By June 1999, after peer review, NEl plans to submit for NRC review the first draft of this document. NEl stated that Step 1 was the current controlling path for the NEl risk-informed methodology effort, and could involve formal fire testing. NEl requested that the NRC staff provide informal feedback before NEl begins pilot use of the first draft.
Step 2 of the NEl involves the development of risk-infonned arguments regarding the likelihood of fires in plant-specific locations and their potential to cause multiple circuit failures. The second draf t of Step 2 of the methodology is currently undergoing intemal NEl review.
Step 3 involves the development of a deterministic circuit failure analysis methodology which could be applied to plant-specific configurations that are not screened in Step 1 or Step 2.
NEl stated that it recognized that the NRC staff had been holding up generic action on this issue until NEl and the Boiling Water Reactor Owners Group (BWROG) complete their products. NEl asked for NRC feedback as to what time frame would be considered timely for submitting the first draft of the three-step NEl methodology. Further, NEl stated that, if requested, it would meet with the staff before submitting the draft for review. NEl also requested feedback on how the NRC staff sees the NEl methodology being used by industry.
The NRC staff stated that Step 1 of the NEl methodology was similar to an ongoing NRC Office of Research project on factors that could affect circuit failures. An initid hies product is scheduled for delivery in September 1999, The NRC staff stated that it would need to understand the status of the BWROG Appendix R Committee circuit analysis guidance document before responding regarding schedules and possible industry uses.
l l
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4 l
ATTACHMENT 9 APPLICATION OF RISK INFORMATION IN RESOLVING FIRE PROTECTION ISSUES The staff and NEl discussed NEl's proposal to collaborate with the NRC to develop reference documents for fire protection risk applications. NEl provided specific suggestions in of its letter of January 19,1999. The meeting agenda included the following two major items for discussion:
The NRC's " Planned Fire Protection Regulatory Process" chart (subsequently re-named e
" Reactor Fire Protection Master Plan") with a view toward understanding how risk applications could support closure of plant-specific fire protection issues.
Resources needed to complete additional research and activities in the risk applications area.
The staff presented the following possible uses of fire protection risk application reference documents:
Deciding which fire protection risk methods are appropriate for use by licensees within e
the framework of Reg Guide 1.174,"An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions on Plant-specific Changes to the Licensing Basis."
Establishing agreed upon risk-informed methods for expedited closure of future licensing issues (outside of the RG 1.174 framework),
Closing anticipated issues arising from the application of risk-informed, performance-o based methods from the future NFPA 805 standard.
The above items correspond to the following boxes from the NRC's Reactor Fire Protection Master Plan (discussed in the cover memorandum): (1) RG 1.174 (guidance for optional use by licensees), (2) the technical issue on "Use of Risk Technology," and (3) NFPA 805.
The NRC staff and NEl agreed that risk application reference documents could be developed and used to address fire protection issues that are amenable to the use of risk insights, methods, and tools. The reference documents could also be used to develop input for assessing proposed modifications to existing reactor fire protection programs. NEl indicated that it had been thinking about starting work on reference documents. However, in consideration of other priorities, resource constraints, and the ongoing work of the NFPA 805 technical committee, it was agreed that it would be appropriate to defer development of specific risk application documents until after the NFPA 805 methods become available.
The staff noted that if it endorses the method that NEl is currently developing to address the fire-induced circuit failure issue, that method may serve as a model for the development of additional risk application documents.
NEl indicated that it would defer work in this area for the short term. The next action for this NEl-proposed activity will be for NEl to let the NRC staff know when it is ready to reopen the dialogue on a cooperative effort.
I
el Gary M. Holahrn 2
8 NRR is developing for assessing the risk significance of such fire protection deficiencies as inspection findings), and new inspection procedures for use at plants that change their fire protection programs in the future to be risk-informed and performance-based. For each of the aforementioned meeting topics and for each element of the master plan, the meeting participants discussed the scope of work, schedules and status; organizational interfaces; and opportunities for coordination and cooperation.
The meeting participants discussed the significance of fire risk at U.S. commercial reactor plants and agreed that fire can be an imponant and even a dominant contributor to risk at sr plants. To aid future discussions, after the meeting the staff prepared a " fire risk fact sheet."
This fact sheet is included as Attachment 4.
t
)
J.S. Hyslop, Probabilistic Safety Assessment Branch, NRR, led a discussion of the method NRR is developing to assess the risk significance of fire protection deficiencies (e.g., inspection findings). The staff plans to incorporate this methodology into the new reactor oversight process. Attachment 5 is the set of slides used for the discussion. The staff agreed to share with industry the supporting methodology documentation as part of the development of the new reactor oversight process.
The meeting participants agreed that the meeting was usefulin fostering a cummon understanding of the various reactor fire protection initiatives currently being conducted and planned. For each topicalissue, plans, milestones, and schedules were agreed upon. Overall, the NRC staff and the NEl representatives agreed that the resolution of the fire-induced circuit failure issue and the continued development of NFPA BOS should continue to be given high priority; the development of performance indicators, self assessment procedures, and the comprehensive fire protection regulatory guide were of secondary importance; and the development of specific risk applications was of lower priority and could be deferred in the short term. Attachments 6,7,8 and 9 provide additional back mond information and detailed summaries of the discussions of the four major reactor fire protection topicalissues discussed during the meeting.
Project No. 689 cc w/ attachments: See next page Attachments:
- 1. Meeting agenda.
- 2. List of meeting attendees.
- 3. Planned Fire Protection Regulatory Process (Revision 0) Chart
- 4. Fire Risk Fact Sheet
- 5. Slides for a presentation of proposed fire risk assessment method
- 6. Summary of discussions relating to fire protection inspection and assessment
- 7. Summary of discussions regarding fire protection standards and guidance development
- 8. Summary of discussions regarding fire-induced circuit failures
- 9. Summary of discussions regarding the development of risk methods DISTRIBUTION: SEE NEXT PAGE DOCUMENT NAME: G:\\SECTIONB\\ WHITNEY \\NEIMTG31WPD j
- SEE PREVIOUS CONCURRENCE
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s 4
ATTACHMENT 7 FIRE PROTECTION STANDARDS AND GUIDANCE DEVELOPMENT The staff and NEl agreed that the continued development of NFPA 805 was a high priority while the development of the comprehensive fire protection regulatory guide was of secondary importance.
NFPA 805 The NRC staff and NEl agreed that the development of the standard was more challenging than originally anticipated and agreed to continue leveraging its resources and technical expertise as needed to support NFPA's efforts to complete the standard. RES indicated that it was now using technical assistance contractors to support its work on the standard and NRR indicated that it would consider doing so in the future if necessary.
The discussions focused on technicalissues that could have policy imphcations. The first sue dealt with the concept of the " baseline" fire protection program that is specified in the curr6.it draft of the standard and how this concept could affect a licensee's decision to adopt the final standard. The staff indicated that it would continue to work with the NFPA 805 technical committee on this issue. Nevertheless, the staff indicated that this issue could have policy implications if the final NFPA standard (1) specifies a
- baseline" fire protection program that many licensees do not currantly meet or (2) would require significant licensee resources to "re-baseline" existing programs before they could adopt the standard.
The second issue concemed whether or not the NRC would accept the use of the risk methods that will be embodied in NFPA 805 to make risk-informed changes to existing fire protection programs without opting for the new risk-informed, oerformance-based reactor fire protection regulation. (The proposed risk-informed, performance-based reactor fire protection regulation is planned as a voluntary altemative to the existing regulatory requirements. NFPA 805, if successfully developed and endorsed by the NRC, would be an acceptable means of meeting the new regulatory requirements.) The NRC staff indicated that the existing regulatory process would not preclude the use of the risk methods that will be specified in NFPA 805 to make risk-informed changes to existing fire protection programs. The staff postulated, for example, that a licensee could use an NFPA 805 method under RG 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions in Plant-specific Changes to the Licensing Basis."
The staff noted that one of the Commission's objectives in going forward with an optional risk-informed, performance-based reactor fire protection regulation was to eliminate or minimize the need for future exemptions. For the Appendix R plants, using the risk methods specified NFPA 805, without opting for the new regulation as its licensing basis, could result in the need for new exemptions. Since this possibility is counter to the Commission's objective, this may present a new policy issue.
Comorehensive Fire Protection Reaulatorv Guide NEl repeated a request it had made during a meeting of February 25,1999; that the NRC make l
available for stakeholder comment an early draft of the proposed regulatory guide (RG) before its formal publication in the Fgderal Reaister. NEl stated that this would give the licensees an opportunity to compare the proposed RG to the existing reactor licensing bases and identify staff positions, if any, that are embedded in a plant-specific basis, but were not captured in the 1
l
I d
4 proposed RG. The NRC staff indicated that it probably could not complete this additional step within the current schedule, but agreed that it could add value to the RG since the staff is focusing on the exit ting generic guidance and staff positions to develop the RG. The staff also agreed that it could be more effective and efficient for the licensees, rather than the staff, to find any staf f position with generic implications that is embedded in a plant-specific licensing basis.
The staff agreed to consider ways to accommodate NEl's request. NEl agree to coordinate a timely industry response.
The staff will include in the new RG new guidance where existing guidance is either weak or lacking (e.g., guidance for establishing the level and duration of interim compensatory measures). NEl agreed that new guidance may be helpfulin some areas, but requested that the staff handle any new guidance in a process separate from the new RG. The NRC staff indicated that it would follow its standard processes for new guidance and that it wouS consider ways to differentiate the new guidance from the existing guidance in the new RG.
2 l
y 6
4 ATTACHMENT 8 j
FIRE-INDUCED CIRCUlT FAILURES The staff and NEl agreed that ongoing efforts to address and resolve the fire-induced circuit failure issue should continue to receive high priority.
NEl described its three-step risk-based methodology for ddressing fire-induced circuit failures.
Step 1 is the development of a " Characterization Criteria bocument." This potentiallicensee guidance document will identify potential circuit failure modes for specific conditions and arrangements. By June 1999, after peer review, NEl plans to submit for NRC review tha first.
draft of this document. NEl stated that Step 1 was the current controlling path for the NEl risk-informed methodology effort, and could involve formal fire testing. NEl requested that the NRC staff provide informal feedback before NEl begins pilot use of the first draft.
Step 2 of the NEl involves the development of risk-informed arguments regarding the likelihood of fires in plant-specific locations and their potential to cause multiple circuit failures. The second draft of Step 2 of the methodology is currently undergoing internal NEl review.
St:p 3 involves the development of a deterministic circuit failure analysis methodology which could be applied to plant-specific configurations that are not screened in Step 1 or Step 2.
NEl stated that it recognized that the NRC staff had been holding up generic action on this issue until NEl and the Boiling Water Reactor Owners Group (BWROG) complete their products. NEl asked for NRC feedback as to what time frame would be considered timely for I
submitting the first draft of the three-step NEl methodology. Further, NEl stated that, if requested, it would meet with the staff before submitting the draft for review. NEl also requested feedback on how the NRC staff sees the NEl methodology being used by industry.
The NRC staff stated that Step 1 of the NEl methodology was similar to an ongoing NRC Office 1
of Research project on factors that could affect circuit failures. An initial RES product is scheduled for delivery in September 1999, The NRC staff stated that it would need to understand the status of the BWROG Appendix R Cor?mittee circuit analysis guidance document before responding regarding schedules and possible industry uses.
4 4
ATTACHMENT 9 APPLICATION OF RISK INFORMATION IN RESOLVING FIRE PROTECTION ISSUES The staff and NEl discussed NEl's proposal to collaborate with the NRC to develop reference documents for fire protection risk applications. NEl provided specific suggestions in of its letter of January 19,1999. The meeting agenda included the following two major items for discussion:
The NRC's " Planned Fire Protection Regulatory Process" chart (subsequently re-named
" Reactor Fire Protection Master Plan") with a view toward understanding how risk applications could support closure of plant-specific fire protection issues.
Resources needed to complete additional research and activities in the risk applications area.
The staff presented the following possible uses of fire protection risk application reference documents:
j l
Deciding which fire protection risk methods are appropriate for use by licensees within e
the framework of Reg Guide 1.174,"An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions on Plant-specific Changes to the Licensing Basis."
Establishing agreed upon risk-informed methods for expedited closure of future licensing issues (outside of the RG 1.174 framework),
Closing anticipated issues arising from the application of risk-informed, performance-o based methods from the future NFPA 805 standard.
The above items correspond to the following boxes from the NRC's Reactor Fire Protection Master Plan (discussed in the cover memorandum): (1) RG 1.174 (guidance for optional use by licensees), (2) the technical issue on "Use of Risk Technology," and (3) NFPA 805.
The NRC staff and NEl agreed that risk application reference documents could be developed and used to address fire protection issues that are amenable to the use of risk insights, methods, and tools. The reference documents could also be used to develop input for assessing proposed modifications to existing reactor fire protection programs. NEl indicated that it had been thinking about starting ' work on reference documents. However, in consideration of other priorities, resource constraints, and the ongoing work of the NFPA 805 technical committee, it was agreed that it would be appropriate to defer development of specific
)
risk application documents until after the NFPA 805 methods become available.
l l
The staff noted that if it endorses the method that NEl is currently developing to address the fire-induced circuit failure issue, that mathod may serve as a model for the development of additional risk application documents.
NEl indicated that it would defer work in this area for the short term. The next action for this NEl-proposed activity will be for NEl to let the NRC staff know when it is ready to reopen the dialogue on a cooperative effort.
(
d Gary M. Holahan 2
8 NRR is developing for assessing the risk significance of such fire protection deficiencies as inspection findings), and new inspection procedures for use at plants that change their fire protection programs in the future to be risk-informed and performance-based. For each of the aforementioned meeting topics and for each element of the master plan, the meeting participants discussed the scope of work, schedules and status; organizationalinterfaces; and opportunities for coordination and cooperation.
The meeting participants discussed the significance of fire risk at U.S. commercial reactor plants and agreed that fire can be an important and even a dominant contributor to risk at some plants. To aid future discussions, after the meeting the staff prepared a " fire risk fact sheet."
This fact sheet is included as Attachment 4.
J.S. Hyslop, Probabilistic Safety Assessment Branch, NRR, led a discussion of the method NRR is developing to assess the risk significance of fire protection deficiencies (e.g., inspection findings). The staff plans to incorporate this methodology into the new reactor oversight process. Attachment 5 is the set of slides used for the discussion. The staff agreed to share with irviustry the supporting methodology documentation as part of the development of the new recett r oversight process.
The meeting participants agreed that the meeting was usefulin fostering a common understanding of the various reactor fire protection initiatives currently being conducted and planned. For each topicalissue, plans, milestones, and schedules were agreed upon. Overall, the NRC staff and the NEl representatives agreed that the resolution of the fire-induced circuit failure issue and the continued development of NFPA 805 should continue to be given high priority; the development of performance indicators, self-assessment procedures, and the comprehensive fire protection regulatory guide were of secondary importance; and the development of specific risk applications was of lower priority and could be deferred in the short term. Attachments 6,7,8 and 9 provide additional background information and detailed summaries of the discussions of the four major reactor fire protection topicalissues diset3 sed during the meeting.
Project No. 689 cc w/ attachments: See next page Attachments:
- 1. Meeting agenda.
- 2. List of meeting attendees.
- 3. Planned Fire Protection Regulatory Process (Revision 0) Chart
- 4. Fire Risk Fact Sheet
- 5. Slides for a presentation of proposed fire risk assessment method
)
- 6. Summary of discussions relating to fire protection inspection and assessment
- 7. Summary of discussions regarding fire protection standards and guidance development
- 8. Summary of discussions regarding fire-induced circuit failures
- 9. Summary of discussions regarding the development of risk methods DISTRIBUTION: SEE NEXT PAGE DOCUMENT NAME: G:\\SECTIONB\\ WHITNEY \\NEIMTG31WPD
- SEE PREVIOUS CONCURRENCE
- SPLB:DSSA
- SPLB:DSSA
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- SSA LEWhitney:lk KSWest R83arrett T
JHannon 04/ 08/99 04/08/99 04/12 /99 04/l /99 04/ [ 99 EXCEL LOG NUMBER OFFICIAL RECORD COPY