ML21153A447
| ML21153A447 | |
| Person / Time | |
|---|---|
| Issue date: | 05/05/2021 |
| From: | Kent Howard Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, K, ACRS | |
| References | |
| NRC-1503 | |
| Download: ML21153A447 (88) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Joint Fire Protection and Probabilistic Risk Assessment Subcommittee Docket Number:
N/A Location:
Videoconference Date:
May 5, 2021 Work Order No.:
NRC-1503 Pages 1-53 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
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3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
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UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION 3
+ + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 JOINT FIRE PROTECTION AND PROBABILISTIC RISK 8
ASSESSMENT SUBCOMMITTEE 9
+ + + + +
10 WEDNESDAY 11 MAY 5, 2021 12
+ + + + +
13 The Subcommittee met via Videoconference, 14 at 9:30 a.m. EDT, Dennis Bley, Chairman, presiding.
15 16 COMMITTEE MEMBERS:
17 DENNIS BLEY, Chair 18 VICKI BIER, Member 19 CHARLES H. BROWN, JR. Member 20 VESNA B. DIMITRIJEVIC, Member 21 GREG HALNON, Member 22 WALTER L. KIRCHNER, Member 23 JOSE MARCH-LEUBA, Member 24 DAVID A. PETTI, Member 25 JOY L. REMPE, Vice Chairman NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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MATTHEW W. SUNSERI, Member 2
3 ACRS CONSULTANT:
4 STEPHEN SCHULTZ 5
6 DESIGNATED FEDERAL OFFICIAL:
7 HOWARD KENT 8
10 ALSO PRESENT:
11 VICTORIA ANDERSON, NEI 12 THINH DINH, NRR 13 SCOTT MOORE, Executive Director, ACRS 14 CHARLES MOULTON, NRR 15 SHILP VASAVADA, NRR 16 JENNIFER WHITMAN, NRR 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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TABLE OF CONTENTS 2
- 1. Opening Remarks, Dennis Bley,.........
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- 2. Staff Remarks, Jennifer Whitman,.......
8 4
- 3. NRC Staff Presentation, Charles Moulton,...
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6
- 4. Nuclear Energy Institute (NEI) Presentation, Victoria Anderson,............... 39 7
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P-R-O-C-E-E-D-I-N-G-S 2
9:30 a.m.
3 CHAIR BLEY: Good morning, the meeting 4
will now come to order. This is a joint meeting of 5
the Advisory Committee on Reactor Safeguard Fire 6
Protection and Probabilistic Risk Assessment 7
Subcommittees.
8 I'm Dennis
- Bley, Chairman for the 9
probabilistic Risk Subcommittees and Matt Sunseri is 10 Chairman of the Fire Protection Subcommittee.
11 ACRS Members in attendance are Joy Rempe, 12 Charlie Brown, Walt Kirchner, Dave Petti, Vesna 13 Dimitrijevic, Jose March-Leuba, Greg Halnon, and our 14 consultant Steven Schultz, who's also in attendance.
15 We're expecting a couple of others but I 16 don't see them here. Kent Howard and Weidong Wang are 17 the ACRS Staff that are the designated federal 18 officials for this meeting.
19 The purpose of today's meeting is to 20 discuss the revisions to Reg Guides 1.189, Fire 21 Protection for Nuclear Power-plants, and 1.205, 22 Risk-informed Performance-based Fire Protection for 23 Existing Light-water Nuclear Power-plants, as well as 24 an overview of NFPA 805 and 10 CFR 50.38(c).
25 The revision to Reg Guide 1.189 includes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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many changes to areas such as transition from 2
operating plant to permanent shutdown status, multiple 3
changes to electric circuit station blackout 4
improvision with risk-informed reg guides.
5 Reg Guide 1.205 and the associated 10 CFR 6
50.38(c) and NFPA 805, in their reply to operating 7
plants the SAB believes that their operating plants 8
with the long-standing non-compliances are rules 9
50.38(b), Appendix R, which drove licensees to 10 implement NFP 805.
11 However, the changes brought by that 12 process are significant. We think it's also likely 13 that the guidance in this reg guide will become the 14 basis of reviews of fire protection PRAs associated 15 with the license applications.
16 To the extent that a risk-informed 17 performance-based fire protection program for combined 18 license application would be similar in the 805 19 program.
20 The reason that we requested today's 21 briefing is that very few of our current Members were 22 on board 10 to 15 years when we reviewed the 50.48C 23 implementation.
24 The joint Subcommittee will gather 25 information, analyze relevant issues, and formulate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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their proposed positions and actions as appropriate.
2 However, at the Subcommittee's discretion many matters 3
will be considered for presentation to the full 4
Committee if necessary.
5 The ACRS was established by statute and is 6
governed by the Federal Advisory Committee Act, FACA.
7 We have since implemented FACA in accordance with its 8
regulations found in Title 10 of the Code of Federal 9
Regulations Part 7.
10 The Committee can only speak to its 11 published letter reports. We hold meetings to gather 12 information and perform preparatory work that will 13 support our deliberations at full Committee meetings.
14 The rules for participation in all ACRS 15 meetings including today's were announced previously 16 in the Federal Register.
17 The ACRS Section of the U.S. NRC public 18 website provides our charter bylaws, agendas, letter 19 reports, and transcripts of all full and Subcommittee 20 meetings including side presentations.
21 Committee notice and agenda for this 22 meeting were posted there. As stated in the Federal 23 Register notice and in the public meeting notice 24 posted at the website, member of the public who desire 25 to provide written or oral input to the Subcommittee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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may do so and should contact the designated federal 2
official five days prior to the meeting as 3
practicable.
4 Today's meeting is open to the public 5
attendance and there will be a time set aside at the 6
end of the meeting for spontaneous comments from 7
members of the public attending or listening to our 8
meeting.
9 Due to the COVID-19 pandemic, today's 10 meeting is being held over Microsoft Teams, the ACRS, 11 NRC, and Nuclear Energy Institute Staff are attendees.
12 There is also a telephone bridge line around 13 participation to the public.
14 A transcript of today's meeting is being 15
- kept, therefore, we request that the meeting 16 participants on the bridge line identify themselves 17 when they're asked to speak and to speak with 18 sufficient clarity and volume so that they can be 19 readily heard.
20 But at this time I ask the attendees on 21 Teams and on the bridge line keep their devices on 22 mute to minimize disruptions and unmute only when 23 speaking.
24 We will now proceed with the meeting and 25 I call upon Jennifer Whitman, our Chief of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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probablistic risk assessment licensing Branch of the 2
NRR to make her remarks. So, Jennifer, please go 3
ahead?
4 MS. WHITMAN: Good morning, as was said, 5
my name is Jennifer Whitman and I'm currently the 6
Acting Deputy Director of the Division of Risk 7
Assessment in the Office of NRR.
8 So, Id like to start off by thanking the 9
Committee by providing the Staff the opportunity to 10 share with you the changes that we've made to two of 11 the Regulatory Guides that address fire protection and 12 provide an overview of the framework of 10 CFR 50.38c 13 for the risk-informed performance-based fire 14 protection programs, which incorporate portions of 15 NFPA 805.
16 The Staff in industry have done a lot of 17 great work since Reg Guide 1.189 and Reg Guide 1.205 18 were last updated in 2018 and 2009 respectively. I 19 really want to thank all of the Staff including our 20 partners in the Office of Research for the work that 21 was done to put the guidance together that has been 22 incorporated in these revisions.
23 So, the revisions you'll hear about today 24 incorporate the latest guidance and all that great 25 Staff and industry work with respect to circuit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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analysis and the close-out of the frequently asked 2
questions process that was utilized as nearly half of 3
the industry transitioned to NFPA 805.
4 So, both of the Regulatory Guides were 5
issued for public comment and the Staff didn't 6
encounter any substantial disagreements on those 7
proposed revisions.
8 So during our presentation today the Staff 9
will provide details on the revision and an overview 10 of how address the comments that we receive from both 11 industry and the public.
12 The Staff is not requesting that the ACRS 13 write a letter on the Reg Guides but as always, if the 14 Committee wishes to do so we'll welcome it. So, Id 15 like to thank you again for your time and 16 consideration and just indicate that we look forward 17 to addressing any questions or feedback from the 18 Committee.
19 And so with that, I'll turn things over 20 to Chuck Moulton.
21 MR. MOULTON: I'm Charles Moulton, fire 22 protection engineer, NPRA Licensing Branch B, Division 23 of Risk Assessment in the Office of Nuclear Reactor 24 Regulation.
25 Today's presentation will start with a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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brief discussion of the revisions to the two fire 2
protection Reg Guides 1.189, Fire Protection for 3
Nuclear Power-plants, and 1.205 Risk-informed 4
Performance-based Fire Protection for Existing Light-5 water Nuclear Plants.
6 It will then be followed by an overview of 7
risk-informed performance-based fire protection under 8
10 CFR 48(c)as well as a discuss of specific technical 9
topics related to the implementation of that rule.
10 So, the main purpose of the revision for 11 Reg Guide 1.189 and the other Reg Guide as well was 12 the incorporation of updated guidance, specifically 13 guidance on fire-induced circuit failures.
14 This material was essentially endorsing 15 portions of a new revision of NEI-00-01 implementation 16 guidance for post-fire safe shutdown circuit analysis 17 based on the material found in NUREG CR-7150 joint 18 assessment of able damage and planification of effects 19 from fire, AKA JACQUE-FIRE, three volumes of that 20 report.
21 1.189 also incorporated organizational 22 changes and format changes to align with the current 23 Regulatory Guide format at the NRC. So, we received 24 25 public comments, due to those comments we made 25 various clarity edits in sections of the reg guide, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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well as increasing the discussion of some of the 2
circuit analysis details from the NUREG and NEI-00-01 3
to incorporate more text in the reg guide rather than 4
at the end simply referencing those documents.
5 There were a few comments that were not 6
incorporated, one was about changing the definition of 7
not adversely affects safe shutdown to remove 8
discussion of sufficient safety margins in the text 9
section on the standard license condition and self-10 approval of changes.
11 The Staff's position was that this text 12 has been unchanged since Revision 1 of the reg guide 13 in 2007 and has been successfully used by the fleet 14 with no problems or issues known to the Staff.
15 The other comment that we received that we 16 did not incorporate was to expand the guidance in this 17 reg guide to include passively safe advanced reactor 18 designs. The Staff felt this was beyond the scope of 19 the current revision.
20 Additionally, 10 CFR Part 53 is under 21 development to include these reactor designs and will 22 have separate implementing guidance, including for 23 fire protection, so on a separate reg guide 24 completely.
25 MEMBER MARCH-LEUBA: Charles, this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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Jose, just for my information, the understanding is 2
Part 53 will invalidate every single reg guide that is 3
in the books and we'll have to write a new one?
4 MR. MOULTON: No, but the implementation 5
plan for Part 53 is to have a separate reg guide for 6
the plants licensed under that part of the rule.
7 MEMBER MARCH-LEUBA: Reg guide for fire?
8 MR. MOULTON: Yes.
9 MEMBER MARCH-LEUBA: So, you already had 10 discussions for the fire reg guide. For other reg 11 guides, will that be applicable or not? Or should I 12 ask the 53 guys?
13 MR. MOULTON: You should ask the 53 guys, 14 I don't know that answer.
15 MEMBER MARCH-LEUBA: Thank you.
16 CHAIR BLEY: Dennis Bley following up on 17 that. Has work begun on a revision of this reg guide 18 to fit in with Part 53 or is that something in the 19 future?
20 MR. MOULTON: That's in the future. The 21 work on the rule language text just began last week.
22 CHAIR BLEY: Thank you.
23 MR. MOULTON: The specific fire protection 24 rule language I mean.
25 CHAIR BLEY: Understood, go ahead.
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MR. MOULTON: Okay, so the changes for 2
1.205, again to incorporate updated guidance this reg 3
guide endorses NEI 0402 new revision and that document 4
incorporates the outstanding closed NFPA 805 5
frequently asked questions.
6 And in addition to that, we also included 7
8 MEMBER REMPE: Sorry, I didn't hear you, 9
could you repeat what you said? It broke up.
10 MS. WHITMAN: On mine it looks like Chuck 11 is still frozen.
12 CHAIR BLEY: I think we've lost him.
13 Chuck, if you can hear us you might have to drop off 14 and come back. We had this problem for a while, or if 15 one of you from the Staff could give him a quick call 16 and let him know we can't hear him any longer, that 17 would be helpful.
18 MEMBER MARCH-LEUBA: I'm doing that.
19 CHAIR BLEY: Thank you.
20 MEMBER BROWN: Dennis, this is Charlie, 21 you said something in your opening remarks and I 22 forgot the nuance of it. There's two documents, 1.205 23 and the other is 1.89 I guess or 189.
24 Those are two different reg guides, you 25 said one of them applies to operating plants only, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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when I was looking at them I was trying to figure out 2
what the difference was and didn't see it. What's the 3
other one apply to?
4 CHAIR BLEY: Everybody I think, the Staff 5
can correct us on that but I think that one is 6
continuing. It's 1.205 that was third to implement 7
the NFPA 805 material that was resumed at the current 8
operating fleet.
9 And they pretty well worked their way 10 through all of those already.
11 MEMBER BROWN: 1.189 is what, for new 12 design plants or everybody also?
13 CHAIR BLEY:
Everybody, 1.189 is 14 everybody.
15 MEMBER BROWN: So, 1.205 is effectively 16 the implementation of 805?
17 CHAIR BLEY: Correct.
18 MEMBER BROWN: Now I got it, thank you 19 very much.
20 MR. MOULTON: All right, I'm back.
21 MEMBER MARCH-LEUBA: Chuck, it may help if 22 you turn your radio off, maybe that's it.
23 MR. MOULTON: Okay, can you see the slide 24 again?
25 MEMBER REMPE: Yes.
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MR. MOULTON: So, I think this is where I 2
dropped off.
3 MEMBER BROWN: Actually, the slide got 4
smaller for some reason on that screen.
5 MR. MOULTON: Yes, because I'm not in full 6
screen --
7 (Simultaneous Speaking.)
8
-- slideshow again.
9 MEMBER BROWN: Sorry about that, thank 10 you.
11 MR. MOULTON: So, the new revision of 12 1.205 endorses the NEI implementation guidance for 13 adopting the risk-informed performance-based fire 14 protection
- program, that new revision which 15 incorporates the remaining outstanding NFPA 805 last 16 questions that had been closed out prior to the 17 conclusion of that process.
18 Also, it includes the updates fire induced 19 circuit failure guidance, again endorsing portions of 20 NEI 00-01 and the JACQUE-FIRE reports.
21 We received six public comments that 22 resulted in expanded discussion of NFP 805 Section 1.7 23 equivalency to closer align the reg guide text with 24 what the issued license conditions actually say.
25 That's the presentation on the reg guides.
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Now we can move into the features of the fire 2
protection program under 10 CFR 50 48(c).
3 So the rule endorses NFP 805, it was 4
issued in 2004 and incorporates the standard by 5
reference with exceptions, clarifications, and 6
supplementations.
7 This new rule is a voluntary alternative 8
to the existing prescriptive terministic fire 9
protection regulations usually known as Appendix R.
10 So, the features of 805 are that the 11 requirements are applied to all phases of plant 12 operation, there are fundamental program elements and 13 design features for fire protection systems that are 14 established and allows the nuclear safety performance 15 criteria to be satisfied deterministically or using a 16 performance-based approach.
17 Implementation of the performance-based 18 approach includes the inspiration of risk, defense 19 in-depth, and safety margin considerations. The 805 20 allows licensees to self-approve certain changes in 21 the fire protection program using performance-based 22 methods.
23 This is similar to the standard license 24 condition for plants that have not adopted the rule.
25 We have a table describing the differences so 805 has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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the concept of achieving safe and stable conditions 2
for the fuel versus hot shutdown and cold shutdown 3
requirements in Appendix R.
4 805 also has the concept of a success path 5
rather than a train and again, Appendix R is only 6
applicable at power operation.
7 MEMBER HALNON: Chuck, this is Greg 8
Halnon, just real quick, on the self-approved changes, 9
how does the NRC give oversight?
10 Is it inspections willingly or do the 11 licensees have to report 5059 with their changes to be 12 sent to you to do some reviews? Give me just a quick 13 breakdown on how the oversight is on those self-14 approved changes.
15 MR. MOULTON: So, I'll touch on this a 16 little bit more later on but essentially, the 17 licensees are required to document plant change 18 evaluations including considerations of the safety 19 margins and those are in documents that are available 20 for inspection.
21 MEMBER HALNON: So, there's been a 22 periodic fire protection inspection regime that they 23 do then?
24 MR. MOULTON: Yes, now there's a threshold 25 where a change is too major for self-approvals, those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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changes need to be approved by the Staff.
2 MEMBER HALNON: If I have more questions 3
I'll get you later on.
4 CHAIR BLEY: Chuck, Dennis Bley again, do 5
you have two microphones open? At least where I am 6
I'm hearing a lot of echo, it might just be the 7
connection.
8 MEMBER REMPE: It looked like it was 9
coming from Greg when Greg was asking his question.
10 CHAIR BLEY: Okay, go ahead.
11 MR. MOULTON: So, other differences, the 12 lighting requirements for operator actions are 13 performance-based in 805 and deterministic in Appendix 14 R.
15 For 805 operator actions are also 16 demonstrate compliance on the performance-based 17 approach and not also demonstrate compliance without 18 Staff approval for Appendix R.
19 And also in 805, the radiological release 20 criteria from firefighting activities are explicit in 21 the standard.
22 MEMBER KIRCHNER: This is Walt Kirchner, 23 just one quick question on that comparison between --
24 what does it mean actually in practice to say no 25 deterministic emergencies while editing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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requirements?
2 As a former operator I would like to know 3
for sure I had some lighting availability.
4 MR. MOULTON: So, in practice it doesn't 5
mean much necessarily but in 805 part of the -- the 6
open-ended actions to be credited for the PRA and for 7
performance-based compliance need to be determined to 8
be feasible.
9 Part of the feasibility evaluation is the 10 lighting for the operators where they're taking the 11 action and their transit routes. So, practically, 12 there may not be a lot of difference.
13 MEMBER KIRCHNER: A follow-on to Greg's 14 question, I was trying to think what that meant in 15 terms of you, the Staff, doing, say, an inspection or 16 an audit of a licensee's program.
17 MR. MOULTON: So, a licensee will have a 18 documented feasibility evaluation for each action that 19 will include consideration of lighting.
20 TD: This is Thinh Dinh, under Appendix R 21 you need to have fixed emergency lighting and under 22 the PA you can use portable, that's pretty much the 23 difference.
24 MEMBER KIRCHNER: Thank you, that's what 25 I was guessing was the distinction, thank you.
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MR. MOULTON: Okay, so license condition.
2 This is where we get into self-approval of program 3
changes. So, risk-informed changes to the fire 4
protection program without prior approval are 5
available if the risk succession of the chain shows 6
acceptance criteria are met.
7 There's either a risk decrease or a delta 8
CBF and delta of less than 1e to the -7, that's 1e to 9
the -8, respectively. These acceptance criteria and 10 the acceptance criteria for risk changes in the 11 initial transition reviews were developed starting 12 from the Reg Guide 1.174 guidelines.
13 The risk-informed changes that are self-14 approved must also be consistent with the defense 15 in-depth and maintain safety margin, and the approach 16 methods and data need to be acceptable to the NRC.
17 Practically, that means peer-reviewed PRA 18 are methods that have been approved for 805 19 applications in general, methods that have been 20 demonstrated to bound the risk change.
21 There are other changes that can be made 22 without prior approval, changes that have no more than 23 minimal risk impact, certain functionally equivalent 24 changes to Chapter 3, that is the fundamental fire 25 protection program features and design elements, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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changes that are adequate for the hazard for certain 2
fire protection active and passive systems, fire 3
alarms, fire protection discretion systems and fire 4
barriers.
5 Also, with 805 there's a transition period 6
and there's a transition license condition. During 7
the transition period the plant cannot self-approve 8
risk-informed changes unless it's no more than a 9
minimal impact or it's a risk decrease.
10 There are lists of modifications and 11 permatic implementation items that are necessary for 12 a full compliance and a commended schedule for the 13 completion of those items for the typically 14 modifications that have compensatory measures 15 involved.
16 Those compensatory measures must be kept 17 in place until the completion of the modification.
18 CHAIR BLEY: Chuck?
19 MR. MOULTON: Yes?
20 CHAIR BLEY: Are there still many plants 21 in the middle of this process?
22 MR. MOULTON: Yes, there are three units, 23 Davis-Besse and the two Hatch units.
24 CHAIR BLEY: Okay, and just for our 25 information, are they almost finished, are they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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expected to be complete, say, sometimes this year or 2
no?
3 MR. MOULTON: Davis-Besse is expected to 4
be complete next year and Hatch, because of outage 5
timing to do some of the modifications, both units are 6
expected to be completed in 2024.
7 CHAIR BLEY: Okay, thanks.
8 MR. MOULTON: So, a couple technical 9
topics for implementation of 805, success path, a 10 success path is a comprehensive list of systems and 11 equipment and their inter-relationships.
12 The components required to achieve each of 13 the nuclear safety performance criteria make up 14 success paths.
15 The components required to achieve and 16 obtain nuclear safety functions and components whose 17 fire-induced failure could prevent the operational 18 results in the mal-operation of these components 19 needed to meet the nuclear safety criteria are also 20 incorporated in the nuclear success path.
21 So, this approach identifies the systems 22 per nuclear safety criteria and considers the 23 essential mechanical and environmental support and 24 sessional electrical systems for each of those other 25 systems, identifies the equipment that are various NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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operations concerns and is performance-based.
2 Every system and equipment identification 3
definition includes the related cables to that piece 4
of equipment or system. Moving on, recovery actions, 5
in Appendix R these are generally known as Operator 6
Manual Actions.
7 Recovery actions are essentially operator 8
actions outside of the main control room or primary 9
control station that are required to at least help 10 achieve the nuclear safety performance criteria.
11 You can see here a flow chart and recovery 12 actions generally fall into two groups, actions that 13 are required to demonstrate the availability of a 14 success path, and those that are simply assist in 15 achieving the quoted safety criteria.
16 The difference is that for recovery 17 actions required to demonstrate the availability of a 18 success path, the additional risk of the recovery 19 action versus the deterministic separation criteria 20 needs to evaluated and reported to the NRC as part of 21 the transition to this new program.
22 Otherwise, the feasibility and/or 23 liability requirements, the proceduralization 24 requirements, and the inclusion in the PRA are the 25 same for both types.
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MEMBER HALNON: Chuck what is the primary 2
control station, is that the fire protection panel?
3 MR. MOULTON: So, we were just getting 4
there. This was a big discussion the last time we did 5
a revision of this reg guide.
6 Essentially, it's either the ultimate 7
shutdown panel when command and control has been 8
transferred there from the main control room, or a 9
dedicated shutdown panel that is the only location 10 where a piece of equipment could be controlled from.
11 MEMBER HALNON: So, it could be a local --
12 (Simultaneous Speaking.)
13 MR. MOULTON: It could be, there are not 14 actually a ton of those.
15 MEMBER HALNON: So, primary control 16 station doesn't necessarily indicate another spot that 17 everything comes in the ultimate shutdown panel? It 18 could be distributed throughout the plant?
19 MR. MOULTON: Well, generally it's one 20 spot, it's the spot where command and control resides 21 at that moment.
22 MEMBER HALNON: You're talking about the 23 integrated Command and control?
24 MR. MOULTON: Yes, so basically, we're 25 talking about for the ultimate shutdown panels control NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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room abandonment.
2 MEMBER HALNON: Okay.
3 MR. MOULTON: So, performance-based 4
analysis, the nuclear safety criteria evaluation is 5
from the fire area by fire area basis. If a fire area 6
has a valiance from the deterministic separation 7
requirements, the licensee has a few choices.
8 They can modify the plant to gain 9
compliance, they can use the fire risk evaluation 10 approach, or they could use the fire modeling 11 approach, which essentially shows that risk is 12 negligible.
13 99 percent or plus of the time, the fire 14 risk evaluation approach was used. If a recovery 15 action to start with that a success path is available, 16 the additional risk must be assessed.
17 CHAIR BLEY: Chuck, if I use a fire risk 18 evaluation approach I've also got to include the fire 19 modeling to support my risk assessment, right?
20 MR. MOULTON: Yes, but in the standard 21 there's two separate approaches. In practice the 22 standard with the plant change evaluations which we'll 23 be getting to next drive the licensee to use the fire 24 risk evaluation approach, which includes as part of it 25 the use of fire modeling.
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(Simultaneous Speaking.)
2 CHAIR BLEY: -- not quite, but thanks, 3
that helps.
4 MR. MOULTON: In any case, using a 5
recovery action to demonstrate the availability of a 6
success path requires the use of the performance-based 7
approach using one of the general approaches, either 8
fire risk evaluation or fire modeling.
9 MEMBER KIRCHNER: Chuck, this is Walt 10 Kirchner. In practice, do you find lots of variances 11 in the actual plants in terms of deterministic 12 separation requirements?
13 MR. MOULTON: I would say there are quite 14 a few, I would also add that in general the variances 15 are concentrated in a few fire areas.
16 MEMBER KIRCHNER: I'm trying to think 17 where things come together where a designer laying out 18 a plant would have problems with the deterministic 19 separation coming into the control room panels.
20 MR.
MOULTON:
Control
- room, cable 21 spreading room, allow switchgear rooms, some general 22 ops-building areas.
23 MEMBER KIRCHNER: But in summary, as 24 Dennis was suggesting, when you do a fire risk 25 evaluation, part of that requires actual modeling, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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which I always think of as deterministic but that's 2
different. The deterministic separation you're 3
talking about is just fire code distances and such?
4 MR. MOULTON: Deterministic separation 5
criteria are for the separation with detection and 6
suppression, a one-hour fire barrier with the 7
detection and suppression or a three-hour fire 8
barrier.
9 MEMBER KIRCHNER: Thank you.
10 MR. MOULTON: So, plant change evaluation, 11 this is essentially the same thing as the fire risk 12 evaluation performance-based approach.
13 The risk-informed evaluation of a change 14 to a
previously approved program element and 15 integrated assessment of risk defense in-depth and 16 safety margins, and it shows that the public risk from 17 fire and nuclear fuel damage accidents is low, that 18 adequate defense in-depth safety margins are 19 maintained.
20 So, in summary, the revisions to these two 21 reg guides reflect the guidance available to the 22 Staff. The Staff found no substantial obligations or 23 alignment issues from the public comments and the NFP 24 805 provides the framework for a risk-informed 25 performance-based fire protection program.
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And that is the end of my slides.
2 CHAIR BLEY: Thank you very much. I'll 3
ask the Members if any Member have any questions for 4
Chuck before we move on?
5 MEMBER KIRCHNER: I do, Dennis, this is 6
Walt. Chuck, going back to my colleague, Jose's, 7
earlier questions, when I looked at 1.205 and this 8
risk approach, it seemed to me this would be a good 9
fit for any reactor, any generic reactor.
10 And hence, I would have assumed that 1.205 11 could be adopted as part of the guidance for any 10 12 CFR 53 rulemaking.
13 Is that a good assumption on my part to 14 think that this reg guide would actually work for, 15 essentially, all reactors, not just LWRs?
16 MR. MOULTON: In general, I think they 17 could, the difficulty I see is the rule language in 18 50.48(c) that discusses transition and some of the 19 assumptions in the standard that a new licensee, no 20 matter what the design, will not have the benefit of.
21 MEMBER KIRCHNER: So, in this case we 22 don't have a transition because one would expect if 23 the rule language is explicit with regards to GDC-3 or 24 something comparable to GDC-3 then you would start at 25 a high level at be consistent with 50.48(c), would you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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not?
2 MR. MOULTON: The thing is that let me 3
speculate a little bit since we're talking about 4
designs that haven't actually been developed yet.
5 The guidance that comes out for Part 53 6
will be substantially similar to what's in the 805 7
standard in terms of the general concepts and 8
requirements at a high level, that is correct.
9 It's the details that are complicated by 10 the concept of, for example, the technology-neutral 11 framework and approach that the Agency is taking.
12 So, for LWRs there's no concern about, 13 say, toxicity or flammability of any sort of coolant 14 involved, and that's the case for every advanced 15 design.
16 MS. WHITMAN: This is Jennifer Whitman, 17 the other thing, too, is a lot of the guidance in 18 1.205 is addressing the transition from the 19 deterministic to the risk-informed performance-based.
20 And so a lot of that will not apply to the 21 new designs because they're never going to have the 22 original deterministic framework. They're going to be 23 starting with the reinforce performance-based 24 framework.
25 So, while, like Chuck said, a lot of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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high-level concepts will remain the same, at this 2
point in time, as Chuck said, the rule language for 3
Part 53 is just starting to be worked on.
4 We anticipate it will be cleaner and 5
easier for everyone if there's new guidance 6
specifically for the advanced reactor fire protection.
7 MEMBER BROWN: Can I ask a question?
8 MS. WHITMAN: Yes.
9 MEMBER BROWN:
Technology-neutral 10 performance-based, that's chilly ground. Obviously 11 understand technology-neutral relative to my basic 12 area of digital INC and everything like that, how can 13 fire protection be technology-neutral?
14 Don't you have to spray it with water, 15 foam, or suppress the oxygen for fire-controlled 16 doors? I'm really struggling with the technology-17 neutral approach to fire protection.
18 MR. MOULTON: So, the hazards encountered 19 by fire protection activities are different in a non 20 light-water reactor, and also the requirements for 21 what is exactly safe and stable as a concept involves 22 maybe different for a non-large light-water reactor.
23 MEMBER BROWN: How does technology-neutral 24 get -- that's very difficult for me to understand.
25 MR. MOULTON: I look at different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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materials. A sodium reactor is a sodium reactor, you 2
really don't want it to touch water. What do you with 3
sodium, the regular sodium, in its elemental state in 4
a laboratory?
5 Isn't it in oil to keep it from exploding, 6
catching fire?
7 MS. WHITMAN: I was going to say we're 8
talking about technology-neutral from the rule 9
framework perspective so the rule is going to say 10 something along those lines of what GDC-3 currently 11 says, you have to protect against fire and fire 12 hazards and you have to maintain no radiological 13 releases or meet the criteria.
14 How you do that in any given type of 15 reactor, we might need to provide guidance for what 16 that means but the rule will be such that any 17 technology could come in and demonstrate how they are 18 planning to meet the rule.
19 Does that help?
20 MEMBER BROWN: I'll give up.
21 MEMBER KIRCHNER: Charlie, I was thinking 22 along the lines you were, too. Jennifer, it seems to 23 me your framework here on 1.205 would work and, yes, 24 a lot of it had transitioned from 48A to C but 25 ignoring that for the moment, the requirements that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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you put forth with the 805, and I hope I'm getting my 2
numbers correct.
3 And your defense in-depth, it seems to be 4
that. Obviously, what suppressions you use will 5
depend on the technology but the generic framework you 6
have just struck me as it would cover most 7
technologies, at least at a high level in terms of how 8
you would proceed with a fire protection program, 9
especially your defense in-depth concepts.
10 MR. VASAVADA: This is Shilp Vasavada from 11 the NRC Staff and I just wanted to, again, add some 12 perspective to the discussion as well as mention maybe 13 the rule and the guidance, the framework, that is 14 being discussed and laid out.
15 That framework supports of technology 16 includes the implementation because at a high-level, 17 you can say what to do although how to do, you can get 18 to a certain level of granularity but obviously, then 19 there can be technology and design-specific 20 differences which have to be reviewed by the Staff.
21 As an example, for the sodium cold, using 22 a risk-informed performance-based having a, let's say, 23 PRA to identify the vulnerabilities or whether there 24 is a risk or not in a particular fire area, that can 25 be done for any technology including the sodium cold NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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reactor.
2 And then if there is, let's say they have 3
a double-wall system where their outer wall, the outer 4
annulus is in order so that the sodium cannot interact 5
with air.
6 But there is a breach and there's a fire 7
against the pressure detection and all of that has to 8
be in place. It may be different for that one but 9
that would be handled on that particular 10 design-specific basis.
11 I hope that helps.
12 MEMBER BROWN:
For
- fire, 13 performance-based, if it won't put out the fire, you 14 use something that does, that means it's automatically 15 performance-based.
16 This is a very interesting area to discuss 17 from the standpoint of performance-based fires you 18 could put out, or it's not. And if it's something 19 that doesn't put it out, then it's obviously not 20 performing and you go to something else.
21 MR.
MOULTON:
In this
- case, 22 performance-based is not generally discussing at the 23 level of whether a suppression system is functional or 24 not to put out a fire, but rather at the nuclear 25 safety criteria level of achieving safe shutdown.
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MEMBER HALNON: Charlie, this is Greg 2
Halnon, I kind of just compartmentalized in my mind 3
the reg guide puzzled by written takes care of a 4
couple things.
5 One, it's really focused on transition 6
plants because you know the plants had it before and 7
it endorses any NEI document that's totally focused on 8
transition as opposed to building in the design, and 9
like you said, the transition required.
10 Therefore, it could be a much more 11 straightforward and smaller reg guide or at least more 12 step by step. Rather than endorsing the NEI document, 13 it would be more focused on the risk-informed aspects 14 built into the design originally.
15 Many of the existing operating plants when 16 they transition, one of the reasons they transition is 17 because they have so many exceptions or exemptions to 18 Appendix.
19 And they had to weigh the cost of 20 transitioning versus fixing those exemptions and 21 that's the focus of many of these plants that had 22 transitioned to 805 was how do I get rid of these 23 exemptions to Appendix R because they're very 24 expensive, typically, to fix.
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why this reg guide would work from the standpoint of 2
the overall framework of risk-informed yet the focus 3
of the reg guide, I don't know, it might be confusing 4
for somebody to take it word for word and establish a 5
program with an advanced reactor.
6 MEMBER BROWN: Okay, just griding through 7
1.189 and 1.205, they're very complicated, they're 8
very expansive, and they cover tons of requirements 9
and discussions in terms of things that ought to be 10 done.
11 I just thought putting out fires was a 12 little bit more you looked at what you had, you 13 determined what you needed to put it out or suppress 14 it or not allow it to start.
15 And you would not put wood in a place 16 where you knew you had fire hazards as opposed to 17 something that's non-flammable. So, it just boggles 18 my mind that this is that difficult. Now, Greg, I was 19 not in commercial plants.
20 In regular nuclear plants it's all steel 21 just about so fire hazards are far smaller quantities 22 and sizes, they're more oil-and-fuel-based for the 23 most part. So, I'll give up.
24 MEMBER BIER: This is Vicki, I think I 25 have a question for Staff that may help clarify this.
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MEMBER BROWN: Thank you.
2 MEMBER BIER: It seems to me that you 3
totally are coming from a
perspective of 4
performance-based is, well, you test the fire 5
protection equipment every month and does it work or 6
not?
7 But my understanding, if I'm not wrong, is 8
that performance-based actually does some type of risk 9
assessment or analysis to predict acceptable 10 performance overall. So, I don't know if Staff wants 11 to comment on that briefly?
12 MR. MOULTON: That's more risk-informed in 13 my view.
14 MEMBER BIER: Okay, so I may be 15 misinterpreting --
16 MR. MOULTON: Performance-based is instead 17 of deciding what -- because we're mainly focused on 18 separation between redundant pieces of equipment, 19 performance-based is demonstrating that in any fire 20 that will occur in a fire area you'll have at least 21 one available to shut the plant down.
22 MEMBER BIER: But how do you demonstrate 23 that?
24 MR. MOULTON: Using fire modeling.
25 MEMBER BIER: So, it's based on analysis?
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MR. MOULTON: Yes.
2 MEMBER BIER: Just not based in PRA?
3 MR. MOULTON: Correct.
4 MEMBER BROWN: But you said shut the plant 5
down. We shut the plant down in light-water reactors 6
with scramming the plant. You still have to put out 7
the fire even if you scram the plant.
8 MR. MOULTON: Scramming the plant is not 9
the --
10 MEMBER BROWN: You said safety --
11 MR. VASAVADA: This is Shilp, can I just 12 jump in? I think, as Chuck mentioned, it's about 13 meeting the nuclear safety objectives.
14 Essentially, the key safety functions, you 15 still have to have reactivity control and as Chuck was 16 pointing out, you need to demonstrate that you can 17 have that even if you have a fire in a fire area.
18 So, the deterministic ways, you have 20 19 feet of separation, you can say if one train goes away 20 does the other train, performance basis, all of what 21 Chuck mentioned.
22 It can be fire modeling, it can be risk 23 assessment, it can be a combination of both.
24 MEMBER BROWN: So, it could be two feet 25 apart as opposed to 20 feet part in the end?
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MR. VASAVADA: It could be but then they 2
would have to, again, in a performance-based manner, 3
and correct me if Im wrong, demonstrate that they 4
would still be able to meet the nuclear safety 5
objectives with that separation.
6 Or they might have to take a variation 7
from the deterministic requirements and make a plan 8
modification to be able to achieve that.
9 MEMBER BROWN: Okay, well, thanks, I will 10 let us get on with this, thank you for being patient.
11 CHAIR BLEY: Thanks, everybody, thanks for 12 the presentation, Chuck. I think you have nothing 13 more?
14 MR. MOULTON: I have nothing more.
15 CHAIR BLEY: We're about to take a break 16 before we move on. When we come back we'll hear from 17 Victoria Anderson from NEI and before we go I want to 18 correct my opening remarks because of the display 19 problem.
20 I didn't see that Vicki Bier was with us 21 this morning as a Member but she's already spoken up 22 that she was here so we've got that on record.
23 At this time, we'll release us for 20 24 minutes approximately, let's come back at 10 minutes 25 until the hour. We are in recess.
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(Whereupon, the above-entitled matter 2
went off the record at 10:28 a.m. and 3
resumed at 10:50 a.m.)
4 MS. ANDERSON: All right, so I'm Victoria 5
Anderson with NEI, I am a technical advisor for Risk 6
and Engineering and I've had responsibility for fire 7
protection topics at NEI for close to 10 years now so 8
I'll be giving a little bit of industry perspective on 9
our comment of draft guide 1359, which would be the 10 latest revision of Reg Guide 1.189.
11 So, we do appreciate the endorsement of 12 our most recent revision of NEI 00-01, which really 13 helps improve regulatory stability and predictability.
14 As Mr. Bolton indicated earlier, there 15 were very few, if any, exceptions in the endorsement 16 so we did appreciate that and we also appreciated that 17 the majority of our comments were incorporated into 18 the latest draft of the reg guide.
19 We did see a couple of comments in Section 20 1182 that weren't incorporated and Mr. Moulton had 21 referenced that these comments were on portions of the 22 Reg Guide that hadn't been changed since 2007.
23 I would like to point out that in each 24 draft revision that's been issued for comment, we have 25 made these comments and we continue to believe these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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changes are necessary to ensure we have regulatory 2
clarity and fire protection.
3 So, the first is an inappropriate 4
reference to sufficient safety margins. In this case, 5
we don't really need to have parity with Reg Guide 6
1.205.
7 I think Mr. Moulton also referenced that 8
we had comments on the standard fire protection 9
license condition because we see that is inconsistent 10 with relevant generic letters.
11 So, again, we've previously provided these 12 comments and we believe they remain critical to ensure 13 that we have consistency in all documents guiding fire 14 protection regulation. That's all I have, I'm 15 available for any questions.
16 CHAIR BLEY: Thanks, Victoria, it's nice 17 to have you back with us, it's been a while. Any 18 questions from the Committee?
19 MEMBER HALNON: This is Greg, I was 20 searching for that 1.1.8.2 and I guess I can't find it 21 in the reg guide that was sent out to us in 1.189 Rev 22 4, am I in the right Reg Guide?
23 CHAIR BLEY: I was having a hard time 24 finding that section.
25 MR. MOULTON: Excuse, it's actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1.8.1.2.
2 MS. ANDERSON: Sorry about that.
3 MEMBER HALNON: Got it now, thanks.
4 CHAIR BLEY: Anything else? Victoria, 5
thank you very much and thanks to the Staff for their 6
presentations.
7 Unless some Members have comments, and 8
I'll go around to them in a few minutes, it's not our 9
intent to write a letter on these two revisions to the 10 reg guides that this is primarily for the benefit of 11 the Members to see where things sit at this time for 12 a little bit of how we got there on fire protection 13 and associated risk assessments.
14 Can we get the public line open, please?
15 It's open?
16 MR. KENT: Dennis, I know they were having 17 problems earlier and I know they're trying to work on 18 it but Thomas, are you there, or Makeeka? So, Thomas, 19 the public line is open now, right, because I heard it 20 say mute off.
21 MEMBER BROWN: While we have that, Greg, 22 you couldn't find 1.1.8.2?
23 MEMBER HALNON: They corrected it, it was 24 just a transposition error. It's 1.8 --
25 MEMBER BROWN:
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clarification, I'm sorry, thank you.
2 MR. KENT: Hang on, Dennis. Thomas, 3
Makeeka, I heard the public line say mute off, is it 4
open now? Please verify.
5 MR. MOORE: This is Scott Moore, I'm on 6
the public line.
7 MR. KENT: Okay, so it's open then.
8 CHAIR BLEY: So, at this time, if there's 9
anyone who would like to make a comment, please 10 identify yourselves and give us your comment, please.
11 (Simultaneous Speaking.)
12 MR. DASHIELL: Unfortunately, I can't 13 unmute the public line.
14 CHAIR BLEY: I heard talk over talk but I 15 think we can close the public line, I don't think 16 there's anyone.
17 MR. MOORE: I'm on the public line now, 18 can you hear this in the room?
19 CHAIR BLEY: Yes.
20 MR. MOORE: So, anybody else on the public 21 line, if you have any comments, go ahead and talk.
22 CHAIR BLEY: The silence is deafening, I 23 think we'll close the public line, thank you, Scott.
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write a letter, please speak up and if you have any 2
other comments, go ahead.
3 MEMBER BIER: Dennis?
4 CHAIR BLEY: Yes.
5 MEMBER BIER: I don't think this rises to 6
the level that we would need to write a letter but I 7
think there is a philosophical point that I want to 8
raise regarding what performance-based means in this 9
context.
10 And it may be something the Committee has 11 already discussed extensively in the past. And 12 excuse, I'll go on a few-minute tangent but hopefully 13 brief.
14 If you look at the history of 15 performance-based regulation, it really started I 16 think in areas like pollution control from smoke 17 stacks, where we used to say you needed this kind of 18 scrubber and then people said, well, that's hampering 19 innovation in scrubber design so why don't we just say 20 your pollution has to be less than such and such and 21 any technology by which you meet that is totally fine.
22 So, that's real physical performance, 23 you're measuring exactly the thing you want to control 24 and however you control it is fine.
In 25 performance-based regulation for many parts of nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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safety, component availability and so forth, you're 2
not measuring the exact performance you want to 3
control.
4 Is the reactor going to have a meltdown or 5
whatever, but you're measuring tangible things, how 6
bad is the maintenance backlog, how bad is the 7
availability of certain components when you test them, 8
et cetera.
9 So, there's kind of a disconnect because 10 you can have managing to the indicator that people get 11 the measured performance down without necessarily 12 always getting the risk down.
13 But at least you're measuring physical 14 performance of something, and in fire regulation, and 15 it's not only for nuclear, there's performance-based 16 fire regulation in the commercial world for buildings 17 and whatever, you're not really measuring physical 18 performance like smoke detectors and fire 19 extinguishers work when you test them, you're 20 measuring calculated performance based on some type of 21 fire model or whatever.
22 And so that introduces a new level of 23 complexity or departure of not only are you not 24 measuring the exact thing you want to measure but 25 you're measuring it by calculation, not in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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physical world, and that means the assumptions of the 2
calculations are really important.
3 And I think you see a little bit of that 4
in the comments on the earlier draft where industry 5
was saying please clarify for us which kind of cabinet 6
fire scenarios we should be considering.
7 Because in the extreme you can have a 8
situation where we may specify certain scenario fires 9
for which performance has to be demonstrated and you 10 can demonstrate performance for those fire scenarios 11 by putting all the fire extinguishers where the 12 postulated fire starts.
13 You have a big room in the scenario fire 14 starts in one corner so you put all of your fire 15 extinguishers in that corner and you get good 16 performance in your fire model but maybe lousy 17 performance in the real world because there's other 18 scenario fires that are possible.
19 So, like I said, I don't think there's 20 necessarily a problem here that we need to comment on 21 but I just wanted to raise that as something to be 22 aware of, that performance-based, although the 23 terminology has gotten to be common, it means 24 different things in different contexts and I think we 25 need to be aware of that.
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So, anyway, sorry for the long tangent and 2
if this is something that's already been discussed in 3
the past.
4 CHAIR BLEY: It has been discussed many 5
times but that was a very cogent summary of it all.
6 It almost makes me want to ask you to put together a 7
white paper for the Committee, I think it would be 8
very helpful.
9 Anyone else in the Office?
10 MEMBER HALNON: This is Greg, I would like 11 to hear if it's appropriate what the Staff's rationale 12 is behind not incorporating the comment on if there 13 were sufficient safety margins.
14 To me I always point out some vague or 15 subjective words and I just would like to hear what 16 the response is for that if it's appropriate.
17 CHAIR BLEY: Sure, does someone on the 18 Staff want to address that for us, please?
19 MR. VASAVADA: Chuck, you want to go?
20 MR. MOULTON: Okay, I'll go, part of the 21 comment about sufficient safety margin along with the 22 other comments on that section was that the text in 23 this reg guide and going back to Revision 1 could not 24 be applied to the other plants that have the earlier 25 definition in their licensing basis without a backfit.
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So, Staff agrees with that, however, at 2
the same time, none of the earlier versions of the reg 3
guide have been deleted from the Staff list of 4
guidance.
5 So anyone who has one of the earlier 6
versions continues to use that to demonstrate 7
compliance, plus it had been a long-standing change 8
over ten years and we had not known any problems with 9
its implementation.
10 And finally, we were trying to focus the 11 efforts of our revision to be narrowly tailored to 12 adding the new circuit analysis guidance rather than 13 going through and editing the entire 100-plus pages of 14 material.
15 MEMBER HALNON: So, what determines 16 sufficient, is that just a
long-standing 17 understanding?
18 MR. MOULTON: Yes.
19 MEMBER HALNON: Okay, I assume that's 20 where the industry was coming from, was that it's 21 subjective and what the industry may feel is 22 sufficient may be different than what the NRC may feel 23 is sufficient.
24 Is that the rub here?
25 MR. MOULTON: It may be but I would add NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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that detail also exists in the fire risk evaluations 2
under the risk-informed performance-based rule.
3 MEMBER HALNON:
So, there's other 4
resources to go to help define or establish what is 5
sufficient?
6 MR. MOULTON: Yes.
7 MEMBER HALNON: Okay, thanks, Chuck, I 8
appreciate that.
9 MEMBER BROWN: This is Charlie Brown, on 10 the same subject in that same section, is there a 11 commonly understood, in the commercial world, metric 12 relative to maintaining safe shutdown.
13 Any time you shutdown you like to know 14 you're in a safe shutdown condition. In my old world, 15 if the watch hit the bottom, we would effectively 16 safely shutdown.
17 That's an overall general statement and 18 that's why over the last 12 years, I've applied the 19 same the process and I've made comments on other 20 issues, that safe shutdown is larger on the bottom and 21 you're subcritical.
22 And you stay that way, again, like Greg 23 just said, throwing in the other words about 24 sufficient safety margins, that adds an element of 25 swishiness to, hold it, does that mean our tolerances NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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get less?
2 Is there something else? So, that's why 3
I was asking the question.
4 MEMBER KIRCHNER: This is Walt, there are 5
a number of policy SECYs that address safe shutdown, 6
some of them are referenced in the first of these two 7
reg guides, I can give you those.
8 But basically, in short, it's everything 9
that you say but also controlling decay heat and 10 retaining, essentially, core coolability and fuel 11 integrity.
12 So, scram and shutdown in terms of 13 reactivity controls are necessary but not sufficient.
14 So, maybe offline I can just --
15 MEMBER BROWN: Walt, I understand and I 16 agree with that, I would agree that's the other 17 condition we think about.
18 But there, there's something you do, 19 you're cooling the core, you've got your systems up so 20 that you're temperatures aren't increasing.
21 Those types of
- things, those are 22 metrically known, whereas sufficient safety margin is 23 kind of a squishy word. I understand the industry's 24 the process on it, that's why I was asking the 25 question relative to safe shutdown.
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I agree with you, thank you for the 2
additional editions.
3 MEMBER HALNON: This is Greg, a lot of the 4
sufficient margin revolves around having enough 5
secondary water source to continue to cool the core 6
and remove heat.
7 That's one of the big NFPA 805 issues in 8
transition, making sure there's no secondary water.
9 So, it is incumbent upon sufficient to 10 show by analysis that you're going to be able to 11 maintain a stable condition, whether it's a hot 12 shutdown, a cold shutdown, or whatever the case may 13 be, wherever you want to be from your license 14 perspective.
15 MEMBER BROWN: So, from your perspective 16 is being in the commercial world, you and Matt had to 17 deal with that, you're all comfortable with that but 18 then NEI is not?
19 MEMBER HALNON: Again, the subjectivity of 20 it bothers me only from the standpoint of who is the 21 final authority and if that final authority's 22 expectations are clear and if it's a conversion of 23 other resources coming in where you can go point to as 24 long as the word actual sufficient, there's a goal 25 post that we continue to move.
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And that's my point but from my 2
remembrance of what we did in the commercial world, 3
there was very expensive modifications taken to put 4
additional emergency feedwater and other types of 5
feedwater in place, maybe not quality-oriented but 6
certainly from an NF P805 separation in fire protected 7
independence.
8 So, you could maintain a condition of safe 9
shutdown, whatever you define that as. So, the 10 sufficient word gets adjudicated I think in the 11 license application and with the analysis behind that.
12 And then I guess it gets questioned from there.
13 The problem is I don't think there's any 14 hard fast number or definition of what sufficient is.
15 And my sense is that's where the industry is having a 16 little bit of an issue with.
17 It's all about predictability in your 18 license amendment and making sure you don't spend 19 money where you don't have to.
20 MEMBER BROWN: I understand that, thank 21 you.
22 CHAIR BLEY: So, I understand from the 23 silence here it seems we're in a good frame and the 24 numbers are getting back and forth to just listen.
25 But if anything we've discussed raises your concerns NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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feel free to make a comment at this time.
2 MR. MOULTON: I would add in the last ten-3 plus years that this text has been in this reg guide, 4
I'm aware of no enforcement action where the 5
definition of what sufficient safety margin is has 6
been an issue.
7 CHAIR BLEY: Thank you, and that's because 8
there's been no problem. So, any other Members care 9
to say anything? I want to thank the Staff for their 10 presentations and the discussions, and NEI as well.
11 I guess I should alert you this afternoon 12 we begin our full Committee meeting and tomorrow I 13 think we have our planning meeting.
14 And it's not impossible that at that time 15 some Members of the Committee might take some of these 16 areas and write a letter.
17 So, it's still a possibility even though 18 the Subcommittee hasn't suggested it today. With 19 that, I'll --
20 (Simultaneous Speaking.)
21 MR. KENT: Dennis?
22 CHAIR BLEY: Yes?
23 MR. KENT: Excuse me, this is Kent. The 24 public line is open now, the problems were resolve so 25 could you reopen it again or how do you want to do it?
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CHAIR BLEY: It is open now or not?
2 MR. KENT: It is, it's been resolved, it's 3
open.
4 CHAIR BLEY: We'll give him another chance 5
but if there's anyone on the public line who would 6
like to make a comment, please identify yourself and 7
make your comment. Hearing none, this meeting is at 8
its close and at this time we are adjourned.
9 (Whereupon, the above-entitled matter 10 went off the record at 11:11 a.m.)
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings as recorded on tape(s) provided by the NRC.
________________________
2IILFLDO7UDQVFULEHU Neal R. Gross & Co., Inc.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com Location:
N/A Video Teleconference Name of Proceeding: Joint Fire Protection and Probabilistic Risk Assessment Subcommittee Docket Number:
Fire Protection Regulatory Guides and NFPA 805 Overview Briefing to the Advisory Committee on Reactor Safeguards May 5, 2021 Charles Moulton Fire Protection Engineer PRA Licensing Branch B Division of Risk Assessment Office of Nuclear Reactor Regulation
Outline
- Fire Protection Regulatory Guide Revisions
- Revision 4 to 1.189 Fire Protection for Nuclear Power Plants
- Revision 2 to 1.205 Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants
- Overview of Risk-Informed, Performance-Based Fire Protection Program [10 CFR 50.48(c)]
- Specific Technical Topics for Implementation of 10 CFR 50.48(c)
- Summary
Changes in RG 1.189, Revision 4 Purpose of revision was to include updated guidance
- Incorporates guidance on fire-induced circuit failures
- Endorses portions of Nuclear Energy Institute (NEI) 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 4
- NUREG/CR-7150, Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE), Volumes 1, 2, and 3
- Organizational changes to align with current regulatory guide format
Changes resulting from public comments
- 25 public comments received
- Expanded discussion of circuit analysis details from NUREG/CR-7150, Volume 3 and NEI 00-01
- Various clarity edits
Unincorporated comments
- Revise definition of not adversely affect safe shutdown to remove discussion of sufficient safety margins
- Current text included since RG 1.189, Revision 1, published in 2007
- Has not prevented successful use of RG 1.189 by the industry and the staff
- Expand guidance to include passively safe advanced reactor designs
- Beyond the scope of the current revision
- Part 53 is under development and will have separate guidance
Changes in RG 1.205, Revision 2 Purpose of revision was to include updated guidance
- Endorses NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 3
- Incorporation of remaining NFPA 805 Frequently Asked Questions
- Latest guidance on fire-induced circuit failures
- Endorses portions of NEI 00-01, Guidance for Post Fire Safe Shutdown Circuit Analysis, Revision 4
- NUREG/CR-7150, Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE), Volumes 1, 2, and 3
Changes from public comments
- 6 public comments received
- Expanded discussion of NFPA 805 Section 1.7 equivalency for closer alignment with issued license condition text
Features of a Fire Protection Program Under 50.48(c)
10 CFR 50.48(c) background
- Endorses NFPA 805
- Rule issued June 16, 2004
- Incorporates by reference the 2001 Edition of NFPA 805 with exceptions, clarifications, and supplementations
- Risk-informed, performance-based fire protection program is a voluntary alternative to the existing prescriptive, deterministic fire protection regulations (i.e., Appendix R)
NFPA 805 Features
- Requirements are applied during all phases of plant operation
- Establishes fundamental fire protection program elements and design requirements for fire protection systems and features
- Allows the nuclear safety performance criteria to be satisfied deterministically or using a performance-based approach
- Implementation of the performance-based approach includes an integrated assessment of risk, defense-in-depth, and safety margin
- NFPA 805 allows licensees to self approve certain changes to their fire protection program using performance-based methods
Differences from Appendix R NFPA 805
- All phases of operation
- Achieve & maintain fuel in safe and stable condition
- One success path free from fire damage Appendix R
- Power operation
- Hot shutdown and cold shutdown requirements
- One train free from fire damage
Differences from Appendix R (continued)
- No deterministic emergency lighting requirements
- Feasible recovery actions allowed for compliance in performance-based approach
- Radiological release criteria are explicit Appendix R
- Deterministic requirements for emergency lighting
- Operator manual actions cannot be used to demonstrate compliance with III.G.2
- Radiological release criteria are implicit
NFPA 805 License Condition Major Elements
Self-approval of program changes
- Risk-informed changes to FPP without prior NRC approval
- Risk assessment of the change shows acceptance criteria are met:
- risk decrease, or
- Acceptance criteria were developed starting from RG 1.174 guidelines
- Consistent with defense-in-depth and maintains sufficient safety margins
- Risk assessment approach, methods, and data shall be acceptable to the NRC
- methods used in the peer-reviewed fire PRA model
- methods that have been approved by NRC for use in NFPA 805 applications
- methods that have been demonstrated to bound the risk impact
Self-approval of program changes (continued)
- Other changes that may be made without prior approval
- Changes that Have No More than Minimal Risk Impact
- Changes to Chapter 3 fundamental requirements
- Functionally equivalent to the corresponding technical requirement
- Adequate for the hazard; only applies to 4 sections of Chapter 3:
- Fire Alarm and Detection Systems (Section 3.8);
- Automatic and Manual Water-Based Fire Suppression Systems (Section 3.9);
- Gaseous Fire Suppression Systems (Section 3.10); and,
- Passive Fire Protection Features (Section 3.11).
Transition license condition
- Cannot self-approve risk-informed changes unless there is no more than a minimal risk impact
- Modifications and programmatic implementation items
- Necessary for full compliance
- Committed schedule for completion
- Maintain appropriate compensatory measures in place until completion of the modifications
Specific Technical Topics for Implementation of 10 CFR 50.48(c)
Success Path
What is a success path?
- A comprehensive list of systems and equipment and their interrelationships
- The components required to achieve the nuclear safety performance criteria
- Components required to achieve and maintain the nuclear safety functions and components whose fire-induced failure could prevent the operation or result in the maloperation of those components needed to meet the nuclear safety performance criteria
Success path approach
- Identify plant systems required to achieve each of the nuclear safety criteria
- Also consider the essential mechanical/environmental support and essential electrical systems
- Equipment identification
- Identify equipment required to achieve the nuclear safety objectives
- Identify equipment whose spurious operation could prevent achieving the nuclear safety objectives
- Performance-based
- All system and equipment identification includes related cables
Recovery Actions Formerly Operator Manual Actions
Recovery Actions in NFPA 805 Activity to Achieve the Nuclear Safety Performance Criteria?
No Yes Action taken in the Main Control Room?
Action taken at the Primary Control Station?
RA to Demonstrate Availability of a Success Path?
Add RA to Fire Protection Program Activity Is a Recovery Action (RA)
Activity is Not a Recovery Action (RA)
Evaluate & Report Additional Risk Per §4.2.4 No No No Yes Yes Yes Done For each Fire Area
Primary control station
Performance-Based Analysis
Performance-based approach overview
- If a fire area has a variance from the deterministic separation requirements, the licensee may
- Modify the plant
- Use fire risk evaluation approach
- Use fire modeling approach (shows risk is negligible)
- If a success path recovery action is involved, the additional risk (compared to deterministic compliance) must be assessed
- May use fire modeling or fire risk evaluation approaches
- May be qualitative or quantitative; bounding is allowed
Plant Change Evaluations
- Risk-informed evaluation of a change to a previously approved fire protection program element:
- integrated assessment of risk, defense-in-depth, and safety margins
- Ensures public risk from fire-induced nuclear fuel damage accidents is low and that adequate defense-in-depth and safety margins are maintained
- Similar to Fire Risk Evaluation performance-based approach
Summary
- Revisions to RG 1.189 and 1.205 reflect latest guidance
- No substantial objections or alignment issues from public comments
- NFPA 805 provides the framework for a risk-informed, performance-based fire protection program
- AHJ - Authority Having Jurisdiction
- CDF - Core Damage Frequency
- CFR - Code of Federal Regulations
- FAQ - Frequently Asked Question
- GDC - General Design Criteria
- IEEE - Institute of Electrical and Electronics Engineers
Acronyms (continued)
- JACQUE-FIRE - Joint Assessment of Cable Damage and Quantification of Effects from Fire
- MCR - Main Control Room
- NEI - Nuclear Energy Institute
- NFPA - National Fire Protection Association
- NRC - Nuclear Regulatory Commission
Acronyms (continued)
- PSA - Probabilistic Safety Assessment
- PWR - Pressurized Water Reactor
- RA - Recovery Action
- RG - Regulatory Guide
©2021 Nuclear Energy Institute Industry Comments on DG-1359 ACRS Plant Operations and Fire Protection Subcommittee Meeting May 5, 2021
©2021 Nuclear Energy Institute 2 NEI appreciates endorsement of 2019 revision of NEI 00-01 to improve regulatory stability and predictability Majority of industry comments incorporated into latest RG draft Vital comments on Section 1.1.8.2 not incorporated Inappropriate reference to sufficient safety margins
Parity with RG 1.205 is unnecessary Definition of standard fire protection license condition inconsistent with GL 86-10 and GL 88-12 Language remains unchanged from previous revisions of RG 1.189
Industry has previously provided these comments and believes they remain critical Industry Feedback on DG-1359 Comment Resolution