ML23214A295
| ML23214A295 | |
| Person / Time | |
|---|---|
| Issue date: | 10/26/2023 |
| From: | NRC/NRR/DRA |
| To: | |
| Shared Package | |
| ML23214A263 | List: |
| References | |
| RG-1.189, Rev. 5 | |
| Download: ML23214A295 (2) | |
Text
REGULATORY ANALYSIS REGULATORY GUIDE (RG) 1.189 FIRE PROTECTION FOR NUCLEAR POWER PLANTS (Proposed Revision 5 of RG 1.189 Revision 4 issued May 2021)
- 1. Introduction This document presents the results of a regulatory analysis of the U.S. Nuclear Regulatory Commissions (NRCs) determination of whether to Revise Regulatory Guide (RG) 1.189 Fire Protection for Nuclear Power Plants. The analysis is to provide the public with insight into how the NRC arrives at a decision.
Statement of the Problem RG 1.189 describes an approach that is acceptable to the staff of the NRC to meet the regulatory requirements of Title 10 of the Code of Federal Regulations (10 CFR) section 50.48(a) and (b), and 10 CFR Part 50, Appendix R, Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979. These regulations state the requirements governing a civilian nuclear power generating plants fire protection program. The NRC issued Revision 4 of RG 1.189 in May 2021(Agencywide Documents Access and Management System Accession No. ML21048A411) to update guidance with respect to the treatment of fire-induced circuit failures.
Recently it was noted that there is a clerical error in the labeling of the guidance in Section C.5.3.1.1 Protection for the Safe-Shutdown Success Path. This section contains two paragraphs that were incorrectly labeled. On page 79 of the RG, the paragraph currently identified as c is incorrect, in that that paragraph is correctly part of item b. There is a conforming change where the current d should be c. The balance of the text of the RG reflects the correct labeling of these paragraphs.
Objective The objective of this regulatory analysis is to assess the need to update RG 1.189 to make the identified correction using the Administrative Change process for RGs, as outlined in Management Directive 6.6, Regulatory Guides. (ML22010A233).
Identification and Analysis of Alternative Approaches The NRC staff considered the following alternative approaches:
- 1. Do not revise Regulatory Guide 1.189
- 2. Revise Regulatory Guide 1.189 Alternative 1: Do Not Revise Regulatory Guide 1.189 Under this alternative, the NRC would not revise this guidance, and applicants would continue to use the present version of this regulatory guide. This is considered the No Action alternative. If NRC takes no action, there would be no cost to NRC in revising the guide.
However, the no-action alternative would not address the issue of incorrect labeling within Section C.5.3.1.1 Protection for the Safe-Shutdown Success Path. Furthermore, the balance of the RG is written as if this section is correctly labeled, and this may cause confusion for stakeholders. For example, later in this section, there is a discussion of detection and suppression systems for items b and c, but the guidance is meant to apply to the information currently in item d, and makes no sense for the current item c.
Alternative 2: Revise Regulatory Guide 1.189 Under this alternative, the NRC would revise Regulatory Guide 1.189 to correct the incorrect labeling within Section C.5.3.1.1 Protection for the Safe-Shutdown Success Path.
The value to NRC staff and applicants in revising the guide would be the benefits associated with correcting what is a modest error to preclude inquiries from stakeholders. The impact on the NRC would be the costs associated with preparing and issuing the regulatory guide which will be modest in this case.
Comparison of Alternatives The two alternatives were compared against each other with respect to safety, as well as NRC and applicant resources.
Alternative 1, the no action option, would not result in unsafe conditions as the relabeling would not change the regulatory positions. The only cost is in responding to future inquiries. Alternative 2 would be superior to Alternative 1 in that it would update the RG to correct the labeling within Section C.5.3.1.1 Protection for the Safe-Shutdown Success Path, eliminating any confusion where those paragraphs are referenced elsewhere in the RG.
With regard to NRC resources, Alternative 2 represents the greater initial cost to the NRC, which is attributable to the modest cost associated with preparing and issuing a revised regulatory guide. When considered over the lifetime of the RG and the potential for expenditures, the overall cost to the NRC as well as applicants/licensees of Alternative 2 is anticipated to be close to or less than the overall cost of Alternative 1.
Decision Rationale Based on this regulatory analysis, the NRC staff concludes that revision of Regulatory Guide 1.189 is warranted using the Administrative Change process for RGs. The proposed action will enhance an applicants ability to prepare submittals to NRC. An updated guide will reduce staff review time and the need for requests for additional information thus reducing costs to applicants, licensees, and the NRC, when compared to taking no action. Thus, the cost to NRC in revising the RG and to applicants and licensees in adapting to a revised RG are deemed to be less than the costs accrued by responding to RAIs related to the uncorrected error.