ML18208A409: Difference between revisions
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{{#Wiki_filter:/RA by Charles Moulton for}} | {{#Wiki_filter:August 7, 2018 MEMORANDUM TO: APLB Files FROM: Greg A. Casto, Chief /RA by Charles Moulton for PRA Licensing Branch B Division of Risk Assessment Office of Nuclear Reactor Regulation | ||
==SUBJECT:== | |||
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION FREQUENTLY ASKED QUESTION 10-0059 ON NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 MONITORING Background/Discussion On March 19, 2012, the Nuclear Regulatory Commission (NRC) issued close-out memorandum for National Fire Protection Association Standard 805 (NFPA 805), Frequently Asked Question (FAQ) 10-0059, NFPA 805 Monitoring (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML120750108), and indicated that FAQ 10-0059, Revision 5 (ADAMS Accession No. ML120410589), was acceptable for use. | |||
On October 16, 2016, the Nuclear Energy Institute (NEI) submitted a revision to FAQ 10-0059 (ADAMS Accession No. ML16312A023). | |||
On May 15, 2017 (ADAMS Accession No. ML17167A159), the NRC staff met with NEI/Industry representatives to discuss Industrys proposed revisions to FAQ 10-0059. NEI/Industry discussed how the use of the maintenance rule thresholds is sufficient to meet the monitoring requirements of NFPA 805. NEI/Industry indicated that two sites received findings related to Maintenance Rule unavailability being higher than that modeled in the fire probabilistic risk assessment (FPRA) because FAQ 10-0059, Revision 5, states that the action level should be no lower than the FPRA assumptions. | |||
After the meeting, the NRC staff provided the following comments on NFPA 805 FAQ 10-0059, Revision 6: | |||
: 1. Add an appendix to the FAQ which provides explicit examples of components that follow each of the paths in the flowchart (Figure E-2) in the FAQ and the corresponding monitoring that will be performed. | |||
: 2. Add language to include the need for sensitivities in case the target value is different from the mean value in section 4 of the FAQ, under the discussion of Phase 3. Such language exists in the details section but not in the discussion of Phase 3. | |||
CONTACT: Jay Robinson, NRR/DRA (301) 415-2878 | |||
APLB Files 2 | |||
: 3. The Industry provided examples of how the maintenance rule thresholds are calculated. | |||
In case of the demand failure, the example gives a threshold of 2 failures based on the 90% probability of failure from a binomial model and the underlying mean failure probability. In the PRA model, the binomial distribution is not explicitly invoked because of the concern with 1 failure in 1 demand and the result of the binomial model for that case is the mean failure probability. What is proposed appears to be different from what is used in the PRA model. | |||
NEI/Industry submitted a revised version of FAQ 10-0059 (ADAMS Accession No. | |||
ML18180A260) that incorporated the NRC staffs previous comments. The final version of FAQ 10-0059, Revision 6, is included as an enclosure to this memorandum and is available at ADAMS Accession No. ML18208A450). | |||
Conclusion The NRC staff has reviewed the proposed changes to NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c), Revision 2, (ADAMS Accession No. ML081130188), as presented in FAQ 10-0059, Revision 6, and finds that nothing in this version of the FAQ would prevent continued endorsement of NEI 04-02. In accordance with Regulatory Issue Summary (RIS) 2007-19, Process For Communicating Clarifications Of Staff Positions Provided In Regulatory Guide 1.205 Concerning Issues Identified During The Pilot Application Of National Fire Protection Association Standard 805, (ADAMS Accession No. ML071590227), the guidance in this FAQ is acceptable for use by licensees in transition. The final endorsement of this FAQ will be addressed by the next revision to Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, (ADAMS Accession No. ML092730314). | |||
Enclosure | |||
: 1. FAQ 10-0059, Revision 6 | |||
APLB Files 3 | |||
==SUBJECT:== | |||
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION FREQUENTLY ASKED QUESTION 10-0059 ON NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 MONITORING, Dated August 7, 2018 DISTRIBUTION: | |||
C. Moulton, DRA/APLB RidsNrrDraAplb RidsNrrDra Nrr_Dra_Aplb vka@nei.org ADAMS Package Accession No.: ML18208A454 OFFICE DRA/APLB DRA/APLB NAME JRobinson GCasto DATE 08 / 07 /18 08 / 07 /18 OFFICIAL RECORD COPY}} | |||
Revision as of 20:32, 20 October 2019
| ML18208A409 | |
| Person / Time | |
|---|---|
| Issue date: | 08/07/2018 |
| From: | Casto G NRC/NRR/DRA |
| To: | NRC/NRR/DRA |
| Robinson J | |
| Shared Package | |
| ML18208A454 | List: |
| References | |
| Download: ML18208A409 (3) | |
Text
August 7, 2018 MEMORANDUM TO: APLB Files FROM: Greg A. Casto, Chief /RA by Charles Moulton for PRA Licensing Branch B Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION FREQUENTLY ASKED QUESTION 10-0059 ON NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 MONITORING Background/Discussion On March 19, 2012, the Nuclear Regulatory Commission (NRC) issued close-out memorandum for National Fire Protection Association Standard 805 (NFPA 805), Frequently Asked Question (FAQ) 10-0059, NFPA 805 Monitoring (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML120750108), and indicated that FAQ 10-0059, Revision 5 (ADAMS Accession No. ML120410589), was acceptable for use.
On October 16, 2016, the Nuclear Energy Institute (NEI) submitted a revision to FAQ 10-0059 (ADAMS Accession No. ML16312A023).
On May 15, 2017 (ADAMS Accession No. ML17167A159), the NRC staff met with NEI/Industry representatives to discuss Industrys proposed revisions to FAQ 10-0059. NEI/Industry discussed how the use of the maintenance rule thresholds is sufficient to meet the monitoring requirements of NFPA 805. NEI/Industry indicated that two sites received findings related to Maintenance Rule unavailability being higher than that modeled in the fire probabilistic risk assessment (FPRA) because FAQ 10-0059, Revision 5, states that the action level should be no lower than the FPRA assumptions.
After the meeting, the NRC staff provided the following comments on NFPA 805 FAQ 10-0059, Revision 6:
- 1. Add an appendix to the FAQ which provides explicit examples of components that follow each of the paths in the flowchart (Figure E-2) in the FAQ and the corresponding monitoring that will be performed.
- 2. Add language to include the need for sensitivities in case the target value is different from the mean value in section 4 of the FAQ, under the discussion of Phase 3. Such language exists in the details section but not in the discussion of Phase 3.
CONTACT: Jay Robinson, NRR/DRA (301) 415-2878
APLB Files 2
- 3. The Industry provided examples of how the maintenance rule thresholds are calculated.
In case of the demand failure, the example gives a threshold of 2 failures based on the 90% probability of failure from a binomial model and the underlying mean failure probability. In the PRA model, the binomial distribution is not explicitly invoked because of the concern with 1 failure in 1 demand and the result of the binomial model for that case is the mean failure probability. What is proposed appears to be different from what is used in the PRA model.
NEI/Industry submitted a revised version of FAQ 10-0059 (ADAMS Accession No.
ML18180A260) that incorporated the NRC staffs previous comments. The final version of FAQ 10-0059, Revision 6, is included as an enclosure to this memorandum and is available at ADAMS Accession No. ML18208A450).
Conclusion The NRC staff has reviewed the proposed changes to NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c), Revision 2, (ADAMS Accession No. ML081130188), as presented in FAQ 10-0059, Revision 6, and finds that nothing in this version of the FAQ would prevent continued endorsement of NEI 04-02. In accordance with Regulatory Issue Summary (RIS) 2007-19, Process For Communicating Clarifications Of Staff Positions Provided In Regulatory Guide 1.205 Concerning Issues Identified During The Pilot Application Of National Fire Protection Association Standard 805, (ADAMS Accession No. ML071590227), the guidance in this FAQ is acceptable for use by licensees in transition. The final endorsement of this FAQ will be addressed by the next revision to Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants, (ADAMS Accession No. ML092730314).
Enclosure
- 1. FAQ 10-0059, Revision 6
APLB Files 3
SUBJECT:
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION FREQUENTLY ASKED QUESTION 10-0059 ON NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 MONITORING, Dated August 7, 2018 DISTRIBUTION:
C. Moulton, DRA/APLB RidsNrrDraAplb RidsNrrDra Nrr_Dra_Aplb vka@nei.org ADAMS Package Accession No.: ML18208A454 OFFICE DRA/APLB DRA/APLB NAME JRobinson GCasto DATE 08 / 07 /18 08 / 07 /18 OFFICIAL RECORD COPY