ML20231A891
| ML20231A891 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/2020 |
| From: | Michael Eudy NRC/RES/DE |
| To: | |
| References | |
| DG-1360, RG-1.205, Rev. 2 | |
| Download: ML20231A891 (2) | |
Text
REGULATORY ANALYSIS DRAFT REGULATORY GUIDE DG-1360 RISK-INFORMED, PERFORMANCE-BASED FIRE PROTECTION FOR EXISTING LIGHT-WATER NUCLEAR POWER PLANTS (Proposed Revision 2 of Regulatory Guide 1.205, dated November 2020)
- 1. Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering revising Regulatory Guide 1.205, " Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants," to update guidance with respect to risk-informed, performance-based fire protection programs. The NRC published Regulatory Issue Summary (RIS) 2007-019 Process for Communicating Clarifications of Staff Positions Provided in Regulatory Guide 1.205 Concerning Issues Identified During the Pilot Application of National Fire Protection Association Standard 805, (ML071590227) in August 2007 to describe a process for communicating clarifications of existing NRC staff positions regarding risk-informed, performance-based fire protection programs. The RIS stated that clarifications would be finalized through a new revision of Regulatory Guide 1.205, and that new revision would complete this process. The NRC published the current version (Revision 1) of Regulatory Guide 1.205 in December 2009 to provide licensees and applicants with the then-current agency-approved guidance for risk-informed, performance-based fire protection programs, but Revision 1 does not contain all of the latest available guidance. In addition, several clarifications were finalized in Revision 1, but subsequent questions from stakeholders indicated that additional clarifications were necessary, and they could be addressed in a 2nd Revision to RG 1.205.
- 2. Objective The objective of this regulatory analysis is to assess whether to update the RG to include the current guidance regarding risk-informed, performance-based fire protection programs and close out the commitment the NRC published in RIS 2007-019.
- 3. Alternative Approaches The NRC staff considered the following alternative approaches:
- 1. Do not revise Regulatory Guide 1.205
- 2. Withdraw Regulatory Guide 1.205
- 3. Revise Regulatory Guide 1.205 to address the current methods and procedures.
Alternative 1: Do Not Revise Regulatory Guide 1.205 Under this alternative, the NRC would not revise the guidance, and the current guidance would be retained. If the NRC does not take action, then there would not be any changes in costs or benefit to the public, licensees, or the NRC. This alternative is considered the no-action alternative and provides a baseline condition from which any other alternatives will be assessed. However, the no-action alternative would not include the finalized clarifications, and the action from RIS 2007-019 would remain open.
Alternative 2: Withdraw Regulatory Guide 1.205 Under this alternative, the NRC would withdraw this regulatory gui e. This would eliminate the problems identified above regarding the regulatory guide. It would also eliminate the only readily available description of the methods the NRC staff considers acceptable for demonstrating compliance with 10 CFR 50.48(c) for risk-informed, performance-based fire protection programs. Although this alternative would be less costly to the NRC in the short term than the proposed alternative 3, it would impede the publics accessibility to the most current regulatory guidance and would be expected to be more costly in the long term to the NRC, the public, and licensees because a void in guidance reduces predictability, efficiency, and regulatory stability. Further, the action from RIS 2007-019 would not be closed.
Alternative 3: Revise Regulatory Guide 1.205 Under this alternative, the NRC would revise Regulatory Guide 1.205. This revision would incorporate the latest information concerning risk-informed, performance-based fire protection programs and supporting guidance. By doing so, the NRC would ensure that the regulatory guidance available in this area is current and accurately reflects the staffs positions.
This would also complete the NRC action from RIS 2007-019.
The impact to the NRC would be the costs associated with preparing and issuing the regulatory guide revision. The impact to the public would be the voluntary costs associated with reviewing and providing comments to the NRC during the public comment period. The value to the NRC staff and licensees would be the benefits associated with enhanced efficiency and effectiveness in using a common guidance document as the technical basis for license and license amendment applications and other interactions between the NRC and its regulated entities.
- 4. Conclusion Based on this regulatory analysis, the NRC staff recommends the revision of Regulatory Guide 1.205. The staff concludes that the proposed action will clarify current regulatory guidance with respect to risk-informed, performance-based fire protection programs, and incorporate all clarifications developed since publication of the current version. The increased clarity in this subject area would reduce unnecessary regulatory burdens by providing a predictable and stable regulatory framework for assessing licensee compliance. It could also lead to cost savings for licensees.
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