ML23277A156
| ML23277A156 | |
| Person / Time | |
|---|---|
| Issue date: | 03/25/2024 |
| From: | NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23277A105 | List:
|
| References | |
| DANU-ISG-2022-09, NRC-2022-0082, ML23277A105 | |
| Download: ML23277A156 (16) | |
Text
1 Analysis of Public Comments on Draft DANU-ISG-2022-09 Advanced Reactor Content of Application Project Risk-Informed, Performance-Based Fire Protection Program (for Operations)
Comments on the draft interim staff guidance (ISG) are available electronically at http://www.nrc.gov/reading-rm/adams.html. From this page, the public can access the Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the U. S.
Nuclear Regulatory Commission (NRC) public documents. The following table lists the comments the NRC received on the draft ISG.
Comment Number ADAMS Accession Number Commenter Affiliation Commenter Name NRC-2022-0082-DRAFT-0002 ML23167A522 Hybrid Power Technologies LLC Michael F. Keller NRC-2022-0082-DRAFT-0003 ML23194A203 Hybrid Power Technologies LLC Michael F. Keller NRC-2022-0074-DRAFT-0006 ML23229A120 Nuclear Energy Institute Ben Holtzman NRC-2022-0075-DRAFT-0004 ML23234A052 X-energy, LLC Travis Chapman Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response NRC-2022-0082-DRAFT-0002-1 Regulations.gov Site Not Applicable Include in regulations.gov, as downloadable files, all documents for which public comments are being solicited The NRC staff responded to the request as documented in ML23174A004. The response states in part:
the regulations.gov website identifies the documents (the ARCAP
[advanced reactor content of application project] ISGs [interim staff guidance] and the TICAP
[technology inclusive content of application project] DG [draft guide])
for which the NRC staff is seeking
2 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response public comment. While the Federal Register notices for the ARCAP ISGs reference NRC-issued, approved, or endorsed documents, the NRC staff is only requesting comment on the ARCAP ISGs proposed use of the referenced documents, and not the referenced documents themselves. As such, the NRC staff will not be providing documents referenced in the ARCAP ISGs on regulations.gov as this could imply that the NRC staff is seeking comments on these documents.
NRC-2022-0082-DRAFT-0002-2 Extension of Comment Period Not Applicable Alter the Federal Register notices to establish a reasonable, staggered schedule for document review and comment by the public.
The NRC staff responded to the request as documented in ML23174A004. As a result of this request and request from the Nuclear Energy Institute (ML23171B098) the NRC staff extended the comment period for nine interim staff guidance documents and draft guide (DG) 1404, revision 0, from July 10, 2023, to August 10, 2023.
NRC-2022-0082-DRAFT-0003 - 1 Purpose, p1
- a. Add statement that ISG provides supplemental guidance to applicants using NEI 21-07 for application content and NFPA 805/806 for fire protection program elements.
The Nuclear Modernization Act unambiguously gives codes/standards precedence over guidance documents.
The NRC staff disagrees with this comment.
The Background section of the ISG describes the relationship between the ARCAP and TICAP guidance documents. This ISG is part of ARCAP. Nuclear Energy Institute (NEI) 21-07 is a TICAP document.
The ISG states that the guidance in this ISG supplements the guidance found in (ARCAP document) DANU-ISG-2022-01, Review of Risk-Informed, Technology-Inclusive
3 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response Advanced Reactor Applications -
Roadmap.
There is no need to reference NEI 21-07 since that document does not provide guidance for an application description of the fire protection program.
National Fire Protection Association (NFPA) 804, 805 and 806 are already referenced in this ISG. These references address the text in the Nuclear Energy Innovation and Modernization Act (NEIMA) to incorporate consensus-based codes and standards into the regulatory framework.
No change has been made to the ISG.
NRC-2022-0082-DRAFT-0003 - 2 General (a) P1, Purpose, 2nd Paragraph (b) P2,
Background
2nd Paragraph (a) Delete references to speculative changes to CFRs, including proposed 10CFR53.
(b) Delete all requirements in the ISG that rely on speculative elements in the unapproved 10CFR53 and planned amendments to 10CFR50 and 52
- c. Delete 2ndParagraph, both sections.
Citing the unapproved 10CFR53 or intended amendments to 10CFR50/52 as a justification for new requirements, even on an interim basis, is of doubtful validity. If simplifications (i.e.
fewer requirements) are intended for advanced reactors, then state reason for such simplifications (e.g. simply refer to Nuclear Modernization Act).
The NRC staff disagrees with this comment.
The guidance in the ISG is based on the requirements in existing regulations (i.e., 10 CFR Parts 50 and 52). The references to future Part 53 are only for general background information. The ISG does not address any proposed Part 53 requirements.
The NEIMA, in part, specifies that the NRC develop strategies for the increased use of risk-informed, performance-based licensing evaluation techniques and guidance for commercial advanced nuclear
4 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response reactors within the existing regulatory framework. The ARCAP and this ISG are part of the implementation of that strategy.
No change has been made to the ISG.
NRC-2022-0082-DRAFT-0003 - 3 General Design Criteria Guidance, p3, 1st paragraph Delete all sentences starting with However, the general design criterion GDC 3 (Fire Protection) is relevant to all advanced reactors. Discussing the need for new Principal Design Criteria for advanced reactors is not relevant to this specific ISG.
The NRC staff disagrees with this comment.
The general design criteria (GDC) of 10 CFR Part 50, Appendix A are considered guidance for non-LWR applicants. These applicants must propose principal design criteria in accordance with 10 CFR 50.34, Contents of applications; technical information, and 10 CFR 52.79, Contents of applications; technical information in final safety analysis report.
No change has been made to the ISG.
NRC-2022-0082-DRAFT-0003 - 4 Prescriptiveness Guidance, p3, 2nd paragraph.
P4, 1st paragraph Delete, replace with: The operational fire protection program establishes day-to-day programmatic measures to insure (sic) key nuclear safety functions are properly protected against fires during plant operation. These key nuclear safety functions are Safety-Related and to a lesser degree Risk-Significant. The applicant must identify the general features of the operational program, as linked to specific provisions of governing industry codes/standards.
The paragraphs are overly prescriptive. Fire detection, suppression, and mitigation measures are not safety-related, while other risk-The NRC staff disagrees with this comment.
The commenters suggested text does not provide sufficient guidance to applicants regarding the content of their applications with respect to the fire protection program. For the ISG to be useful, it needs to provide a level of specificity. Nevertheless, the ISG is only guidance and, thus, applicants can propose alternative application content. The elements addressed in this ISG are consistent with the guidance provided in industry
5 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response significant items are of varying (including lesser) degrees of importance. As such, the license application involving fire protection operational controls should be general in nature, but tied to specific provisions in applicable codes and standard.
standards related to fire protection programs. The application needs to have sufficient information for the NRC staff reviewer to understand the applicants fire protection program and to be able to reach and document the applicable safety findings for this topic in the NRC staffs safety evaluation report.
No change has been made to the ISG.
NRC-2022-0082-DRAFT-0003 - 5 NFPA 805 Guidance, p4, Delete identified content in the sentence This regulation incorporates by reference NFPA 805 with certain exceptions, clarifications, and expansions..
Effectively coerces applicant to use lower tier guidance regulations. However, the Nuclear Modernization Act unambiguously gives codes/standards priority. The codes/standards were developed by experts in the field, whereas the staff does not possess such credentials.
Further, the Code of Federal Regulations does not explicitly require staff endorsements. Also, there are numerous routinely used codes/standards that are not endorsed by the staff, nor has a licensee explicitly justified their use.
The NRC staff disagrees with this comment.
The regulation referenced in this ISG text includes the clarifying statement that the regulation incorporates by reference NFPA 805 with certain exceptions, clarifications, and supplementation. Adopting the change suggested by the commenter would inappropriately alter the intent of the regulation text.
Regarding the NEIMA, refer to the response to comment NRC-2022-0082-DRAFT-0003 - 1 and ARCAP Roadmap comment response NRC-2022-0074-DRAFT-0005-3.
The ISG has been edited to substitute supplementation, which is used in 10 CFR 50.48(c), for expansions.
No other changes have been made to this ISG.
6 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response NRC-2022-0082-DRAFT-0003 - 6 Design Guidance, p4, last paragraph Delete all content after 1st sentence.
Not relevant to ISG, while only serving to set the stage for new requirements.
The NRC staff disagrees with this comment.
The text in this paragraph (after the first sentence) is making the distinction between programmatic aspects of the fire protection program and fire protection system design, which is not addressed in this ISG.
The information is intended to assist applicants in identifying the scope of this application section. This text does not set the stage for any new requirements.
No change has been made to this ISG.
NRC-2022-0082-DRAFT-0003 - 7 PDC Regulatory Basis, 1st paragraph, items 1 & 2 PDC 3 is not a part of RG 1.232. Alter the sentence to properly reflect the relationship.
PDC 3 is a requirement of the CFR, whereas RG 1.232 is a guidance document. The staff is confusing requirements versus suggestions.
The NRC staff disagrees with this comment.
Guidance in regulatory guide (RG) 1.232, Developing Principal Design Criteria for Non-Light Water Reactors, describes advanced reactor design criteria (ARDC) to aid applicants in developing their principal design criteria (PDC) in accordance with the regulations in 10 CFR 50.34 and 10 CFR 52.79. The reference to principal design criteria (PDC) 3 (fire protection) in the ISG corresponds to the ARDC related to GDC 3 (fire protection) in RG 1.232.
No change has been made to this ISG.
7 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response NRC-2022-0082-DRAFT-0003 - 8 Design Regulatory Basis, 2nd paragraph, item 4
Delete reference to RG 1.189.
Fundamentally discusses design features as opposed to plant operational programs and as such is not particularly relevant. Introduces the likely potential to create unnecessary requirements, contrary to Modernization Act.
The NRC staff disagrees with this comment.
RG 1.189, Fire Protection for Nuclear Power Plants, provides staff accepted guidance regarding how an applicant can meet the requirements in 10 CFR 50.48, Fire Protection, including requirements related to the fire protection program. As stated in this ISG, elements and concepts in RG 1.189 can be applied to non-LWRs with justified exceptions or deviations, where appropriate.
Regarding the NEIMA, refer to the response to comment NRC-2022-0082-DRAFT-0003-2.
No change has been made to this ISG.
NRC-2022-0082-DRAFT-0003 - 9 Quality assurance (a) Application Guidance - Fire Protection Program (Administrative Programs during Operations), P6 thru 13, items 1 thru 16.
(b) Item 7 (c) Item 8 (a) Only list key topic areas; delete explanatory text. Applicant to generally identify how implementation occurs and what industry codes/standards apply. How implementation occurs is the subject of applicable industry codes/standards. The staff is attempting to add specific implementation requirements that are not justified considering that fire protection is not Safety-Related. The staff requirements are at odds with the risk informed considerations of the Modernization Act.
(b) Delete all references to QA. See comment
- 4 and above item (a). There are no CFR requirements for fire protection QA. Item #7 is clear regulatory overreach.
(c) Delete this item in its entirety. See comment
- 4 and item (a) above. There are no fire a) The NRC staff disagrees with this comment. The purpose of the ISG is to provide guidance to applicants regarding the development of their fire protection programs. Listing the elements to be addressed in the fire protection program description is useful guidance. As stated in this ISG, the fire protection program description should identify what industry codes and standards related to fire protection the applicant used to develop the program. Regarding the NEIMA, refer to the response
8 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response protection V&V CFR requirements. Item #8 is clear regulatory overreach.
to comments NRC-2022-0082-DRAFT-0003 - 1 and - 2.
b) The NRC staff disagrees with this comment. RG 1.189, Section C.1.7 provides the staffs position regarding quality assurance guidance applicable to fire protection programs. The quality assurance elements described in this ISG as applicable to the fire protection program are consistent with the guidance in RG 1.189.
c) The NRC staff disagrees with this comment. RG 1.189, Section C.1.8.7 provides the staffs position regarding verification and validation (V&V) of fire models.
The V&V guidance described in this ISG is consistent with the guidance in RG 1.189.
No change has been made to this ISG.
NRC-2022-0082-DRAFT-0003 - 10 RG 1.189 Staff Review Guidance -
Acceptance Criteria, items 1 thru 9 Delete all items and replace with list of key topic areas (see comment #9 (a)) and statement that the staff reviews are to use the applicants specifically identified industry codes/standards elements as the basis for review and acceptance.
The Acceptance Criteria are open ended while RG1.189 is regulatory overreach on a vast scale in the light of the Modernizations Acts requirements concerning risk informed considerations and the priority of industry codes/standards.
The NRC staff disagrees with this comment.
The staff acceptance criteria listed in Section C of this ISG reflect the guidance described in Sections A and B. While this guidance does reference elements described in codes/standards (e.g., NFPA 805) there are other elements that the staff needs to evaluate to determine fire protection program adequacy.
9 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response RG 1.189 provides the staffs position regarding the adequacy of an applicants fire protection program.
Therefore, it is appropriate for this ISG to reference the guidance in this RG.
Regarding the NEIMA, refer to the response to comments NRC-2022-0082-DRAFT-0003 - 1 and - 2.
No changes have been made to this ISG.
NRC-2022-0082-DRAFT-0003 - 11 Backfitting Backfitting And Issue Finality Discussion Delete all requirements in the ISG that rely on speculation of prospective elements in the proposed and unapproved 10CFR53 and planned amendments to 10CFR50 and 52.
Appears the staff is attempting to use the ISG for back fitting, considering that a number of new requirements are apparently being proposed that are outside the existing Code of Federal Regulations and industry codes/standards. Citing the unapproved 10CFR53 or intended amendments to 10CFR50/52 as a justification for new requirements, even on an interim basis, is of doubtful validity. If simplifications (i.e. fewer requirement) are intended, then state reason for such simplifications (e.g. refer to Nuclear Modernization Act).
The NRC staff disagrees with this comment.
The guidance in the ISG is based on the requirements in existing regulations (i.e., 10 CFR Parts 50 and 52). The references to future Part 53 are only for general background information. The ISG does not address any proposed Part 53 requirements.
Regarding the NEIMA, refer to the response to comment NRC-2022-0082-DRAFT-0003 - 2.
No change has been made to this ISG.
NRC-2022 0074-DRAFT-0006-1 General General Please rephrase to indicate the guidance is technology-inclusive and is equally applicable to both LWR and non-LWR designs.
Throughout all the documents of the package, there are statements that this guidance is The NRC staff disagrees with this comment. The NRC staff is considering expanding the applicability of ARCAP guidance documents beyond non-light water reactors (non-LWRs). However,
10 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response applicable to nonLight Water Reactors (LWRs). However, all the guidance is technology-inclusive and is equally applicable to LWRs. ARCAP is supposed to be applicable for any technology (non-LWR and LWR), any licensing approach (LMP, classical, etc.), and any licensing path (CP, COL, DC etc.).
For the ARCAP guidance, industry specifically requested the NRC develop guidance applicable to both non-LWRs and LWR SMRs, and we were informed in various meetings that this would be the NRCs approach. While NEI 18-04 and NEI 21-07 were developed specifically for advanced non-LWRs, applicants with LWR designs should also be able to use the Licensing Modernization Project (LMP) methodology if they elect to do so (e.g., NEI 18-04 and NEI 21-07). It would be up to the applicants to justify the use of the guidance documents and associated regulatory guides.
expansion of the guidance beyond non-LWRs at this time is premature.
The final ISG continues to note that the NRC is developing an optional performance-based, technology-inclusive regulatory framework for licensing nuclear power plants designated as 10 CFR Part 53, Licensing and Regulation of Advanced Nuclear Reactors, (RIN 3150-AK31). It is envisioned that the 10 CFR Part 53 guidance would be applicable to both LWR and non-LWRs. Should the 10 CFR Part 53 rulemaking include requirements for both LWR and non-LWRs, the NRC staff envisions that the concepts found in the ARCAP ISGs guidance would be expanded beyond non-LWRs. In the interim, the NRC staff notes that the applicability section of the ISG notes that applicants desiring to use the ISG for a light water reactor application should contact the NRC staff to hold pre-application discussions on their proposed approach.
NRC-2022 0074-DRAFT-0006-2 General General Please provide a statement of what is expected for the CPA.
This guidance describes the advanced reactor fire protection program as an operational program. What is the NRC expecting to see, if anything, in regards to plant fire protection for the Construction Permit Application (CPA)?
The NRC staff disagrees with this comment.
As stated in the Applicability section, this ISG is (only) applicable to applicants submitting risk-informed, performance-based applications for an OL under 10 CFR Part 50 or a COL under 10 CFR Part
- 52.
11 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response This ISG is not applicable to a CP applicant because a CP application under Part 50 is not expected to contain a description of the fire protection program for operations.
The NRC staff notes that 10 CFR 50.34(a)(6) requires the PSAR to provide A preliminary plan for the applicant's organization, training of personnel, and conduct of operations.
This requirement is noted in DANU-ISG-2022-05, Advanced Reactor Content of Application Project Chapter 11, Organization and Human-System Interface Considerations.
The need to describe fire protection design features in a CP application is addressed in RG 1.253, Chapters 3 through 7, and the ARCAP Roadmap ISG.
Additionally, as noted in footnote 3, this ISG does not provide guidance on the licensing requirements for fire protection requirements before receipt of byproduct, source, or special nuclear material under 10 CFR Parts 30, 40, and 70. A CP applicant may address these fire protection licensing requirements with its CP application (in accordance with 10 CFR 50.31, Combining applications) or separately from the CP application.
12 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response No changes have been made to this ISG.
NRC-2022 0074-DRAFT-0006-3 NFPA 804
- p. 5 No change required, just further engagements to explore the possibility of endorsing NFPA 804 for advanced reactors.
Is the NRC willing to consider endorsing NFPA 804?
At the present time, NRC has no plans to formally endorse NFPA 804 in the near term. Note that this ISG does state the following regarding this NFPA standard: provides useful information when used in conjunction with NRC regulations and guidance -
the NRC has not formally endorsed NFPA 804, and some of the information in the NFPA standard may conflict with regulatory requirements which may require an exemption if utilized. Applicants should discuss their use of NFPA 804 with NRC staff during preapplication interactions.
No changes have been made to this ISG.
NRC-2022 0074-DRAFT-0006-4
- p. 6-11 Provide updated guidance or relaxation for fire brigades at advanced reactors that demonstrate a fire cannot impact safe shutdown and cannot violate offsite dose releases in 50.34.
The guidance that a plant should have a five-man fire brigade is based on the design basis fire causing a radioactive release to the public, and the manual suppression from the fire brigade mitigates the consequences of the design basis fire. The new ARCAP guidance continues to mention fire brigade should be addressed in the fire protection program.
Advanced reactors following the NEI 18-04 process may demonstrate the fire design basis hazard levels (DBHLs) do not cause a radiation The NRC staff disagrees with this comment.
This ISG references RG 1.189, which is a comprehensive fire protection guidance document and identifies the scope and depth of fire protection that the NRC staff would consider acceptable for nuclear power plants.
This ISG also refers to elements and concepts in NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as well as the guidance in NFPA 804, Standard for Fire Protection for
13 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response release to the public and environment that exceed the limits of 50.34. Therefore, is the NRC staff considering relaxing or rewording fire brigade requirements if manual suppression is not required for nuclear safety, in order to prevent exemption requests? Is the NRC considering adding to the guidance in RG 1.189 or revising the guidance in RG 1.189 to relax fire brigade requirements for advanced reactor technologies that do not require manual suppression?
Advanced Light Water Reactor Electric Generating Plants, that can be used by non-LWR applicants to develop their fire protection programs.
The NRC staff has no near-term plans to revise RG 1.189 to change guidance for fire brigade staffing.
The fire protection program description should identify what industry codes and standards related to fire protection the applicant used to develop the program and how the program is integrated with the design of the fire protection systems and features. Applicants using approaches that differ from those in RG 1.189 should explain and provide appropriate justification for their programs.
No changes have been made to this ISG.
NRC-2022 0074-DRAFT-0006-5
- p. 6 in B.2.iii Replace as noted.
The document calls for identification of Authority Having Jurisdiction (AHJ). The term AHJ is specific to NFPA codes, and should not be used in this document as alternative codes and standards could be used, meaning that this term would not be relevant. A generic term such as parties with responsibilities should be used instead.
The NRC staff disagrees with this comment.
This ISG references RG 1.189, Regulatory Position C.1.1, and NFPA 805, Section 3.2.2, which contain additional guidance on this topic. The term Authority Having Jurisdiction is an industry standard term used in these guidance documents. If an applicant chooses to deviate from this guidance or chooses to use alternate codes and standards, then the
14 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response applicant should provide a basis in their application.
No changes have been made to this ISG.
NRC-2022 0074-DRAFT-0006-6
- p. 8-9 Please consider including guidance related to these regulatory requirements, including the kind of information NRC would be looking for to meet the intent of the regulations or in exemption requests.
There are several fire protection related regulatory requirements that may be less relevant and/or less important to smaller SMRs or microreactors. Such requirements include:
(1) Fire protection staff training and qualification requirements.
(2) Manual fire fighting capabilities that do not rely on having a fire brigade. Having some generic guidance related to how smaller SMRs or microreactors can meet the intent of these regulations, or the type of information NRC would be looking for in an exemption request to these requirements, would be helpful to industry. Especially as demonstrating why some of these things may not be needed would require a developer/potential licensee to prove a negative.
The NRC staff disagrees with this comment.
This ISG is applicable to non-LWRs (refer to the response to comment NRC-2022-0074-DRAFT-0006-1).
This ISG notes that elements and concepts in standards developed for LWRs, such as NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition, as well as the guidance in RG 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, can be used by non-LWR applicants to develop their fire protection programs (i.e., in lieu of the more prescriptive guidance in RG 1.189). Given the wide range of possible advanced reactor designs it is not practical for the NRC to provide more specific guidance for each reactor type.
No changes have been made to this ISG.
NRC-2022 0074-DRAFT-0006-7
- p. 9 in B.11 Section should be removed.
The NRC staff disagrees with this comment.
15 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response The document describes a monitoring program similar to that performed for NFPA 805 and for maintenance rule. The purpose of such a program is to ensure that the risk-informed inputs to the fire protection program remain valid; such a monitoring program is not applicable to a non-NFPA 805 plant.
This ISG provides guidance for applicants submitting a risk-informed, performance-based application for an operating license (OL) under 10 CFR Part 50 or for a combined license (COL) under 10 CFR Part 52. Given that the application is risk-informed and performance-based, the fire protection program description should include a monitoring program to ensure the availability and reliability of the fire protection systems and features, assess the performance of the fire protection program in meeting the performance criteria, and ensure the assumptions in the engineering analyses remain valid.
No change has been made to this ISG.
NRC-2022-0075-DRAFT-0004-37 General Please provide guidance for 10 CFR 50 Construction Permit applicants who are not requesting design finality.
This guidance describes the advanced reactor fire protection program as an operational program. What is the NRC expecting to see, if anything, in regards to plant fire protection content for a 10 CFR 50 Construction Permit application versus and Operating License application?
Refer to the response to Comment NRC-2022-0074-DRAFT-0006-2.
NRC-2022-0075-DRAFT-0004-38 Page 5 of 13 No change suggested, however, X-energy is interested in further engagements to explore the possibility of endorsing NFPA 804 for advanced reactors.
Is the NRC considering endorsing NFPA 804?
Refer to the response to Comment NRC-2022-0074-DRAFT-0006-3.
16 Commenter Identifier Topics Section of Document Specific Comment NRC Staff Response NRC-2022-0075-DRAFT-0004-39 Pages 6-11 of 13 Please provide updated guidance or relaxation for fire brigades at advanced reactors that demonstrate a fire cannot impact safe shutdown and cannot violate offsite dose releases in 50.34.
The guidance that a plant should have a five man fire brigade is based on the design basis fire causing a radioactive release to the public, and the manual suppression from the fire brigade mitigates the consequences of the design basis fire. The new ARCAP guidance continues to mention fire brigade should be addressed in the fire protection program.
Advanced reactors following the NEI 18-04 process may demonstrate the fire design basis hazard levels (DBHLs) do not cause a radiation release to the public and environment that exceed the limits of 50.34. Therefore, is the NRC staff considering relaxing or rewording fire brigade requirements if manual suppression is not required for nuclear safety, in order to prevent exemption requests? Is the NRC considering adding to the guidance in RG 1.189 or revising the guidance in RG 1.189 to relax fire brigade requirements for advanced reactor technologies that do not require manual suppression?
Refer to the response to Comment NRC-2022-0074-DRAFT-0006-4.