ML071080099

NFPA-805 Transition Pilot Plant FAQ 06-0008, Revision 4

ML071080099
Person / Time
Site:	Harris
Issue date:	04/09/2007
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
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FAQ 06-0008
Download: ML071080099 (20)

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Plant: Harris Date: 4/9/07

Contact:

Jeff Ertman Phone: 919-546-3681 Email: jeffrey.ertman@pgnmail.com Distribution: (NEI Internal Use) 805 TF FPWG RATF RIRWG BWROG PWROG Purpose of FAQ:

The purpose of FAQ 06-0008 is to provide a process/method for the use of fire protection engineering analyses post-transition to address NFPA 805 Chapter 3 requirements. Currently, licensees may self approve these evaluations under the existing fire protection license conditions.

The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). The process/method to be submitted in the LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Post-transition, licensees will use this process/method to self approve acceptable fire protection engineering analyses.

Is this Interpretation of guidance? Yes / No Proposed new guidance not in NEI 04-02? Yes / No Details:

NEI 04-02 guidance needing interpretation (include section, paragraph, and line numbers as applicable):

Sections 2.3, 2.4, 4.3.1, 4.6.1, 5.3.2, Appendix H, and Appendix I of NEI 04-02 Revision 1.

Circumstances requiring guidance interpretation or new guidance:

Risk-informed, performance-based fire protection engineering analyses are an acceptable alternative to the deterministic approaches in NFPA 805 Chapter 4. Some sections of Chapter 3 are conditional based upon Chapter 4 requirements; therefore, risk-informed, performance-based methods are allowed for those sections under NFPA 805 / 10 CFR 50.48 (c). Risk-informed, performance-based fire protection engineering analyses may also be needed to document the acceptability of fire protection systems and features addressed in NFPA 805 Chapter 3 sections that are not conditional based upon Chapter 4 requirements. Current licensing basis allows flexibility to use performance-based technical analysis per Generic Letter 86-10. An approach Deleted: An alternative method using these types of analyses is needed to allow this flexibility following transition to NFPA 805. (approach)

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:

The fire protection program elements and minimum design requirements of NFPA 805 Chapter 3 may be subject to the performance-based methods permitted elsewhere in NFPA 805 per 10 CFR 50.48(c)(2)(vii), as long as the appropriate regulatory processes (i.e., a license amendment request) are utilized.

A process for a 10 CFR 50.48(c)(2)(vii) License Amendment Request has not yet been agreed upon.

Potentially relevant existing FAQ numbers:

FAQ 06-0004 includes a process for defining fire protection systems and features required to meet NFPA 805 Chapter 3 criteria.

Response Section:

Proposed resolution of FAQ and the basis for the proposal:

A high-level purpose of NFPA 805, as implemented under the endorsement of 10 CFR 50.48(c),

is to clarify how licensees may use the flexibility afforded by 10 CFR 50.48(c)(2)(vii) to develop a process to maintain the current flexibility available to licensees under Generic Letter (GL) 86-10 evaluations.

BACKGROUND 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this FAQ to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA Page 2 of 8 FAQ 06-0008 rev 4a engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4. These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

PROCESS Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205):

Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.

Licensees may also perform change evaluations for deviations from the NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following provides the sections of NFPA 805 that will utilize this process/method. Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Column Heading Definition:

Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.

Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this FAQ is not applicable and would be outside the scope of the associated LAR.

Section Title FP Eng. Analysis Chapter 4 FP Eng.

Process Conditional Analysis Applicable Section Process and Chapter 4 Not Applicable 3.1 General X 3.2 Fire Protection Plan X 3.2.1 Intent X Management Policy Direction and 3.2.2 Responsibility X 3.2.3 Procedures X 3.3 Prevention X Fire Prevention for Operational 3.3.1 Activities X 3.3.2 Structural X 3.3.3 Interior Finishes X 3.3.4 Insulation Materials X 3.3.5 Electrical X 3.3.6 Roofs X 3.3.7 Bulk Flammable Gas Storage X Bulk Storage of Flammable and 3.3.8 Combustible Liquids X 3.3.9 Transformers X 3.3.10 Hot Pipes and Surfaces X 3.3.11 Electrical Equipment (Note 1) X 3.3.12 Reactor Coolant Pumps (Note 1) X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X 3.4.2 Pre-Fire Plans X Page 4 of 8 FAQ 06-0008 rev 4a engineering analyses.doc

FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses Section Title FP Eng. Analysis Chapter 4 FP Eng.

Process Conditional Analysis Applicable Section Process and Chapter 4 Not Applicable 3.4.3 Training and Drills X 3.4.4 Fire Fighting Equipment X 3.4.5 Off-Site Fire Department Interface X 3.4.6 Communications X 3.5 Water Supply X 3.6 Standpipe and Hose Stations X 3.7 Fire Extinguishers X Deleted: X 3.8 Fire Alarm and Detection Systems 3.8.1 Fire Alarm X 3.8.2 Detection X Automatic and Manual Water-3.9 Based Fire Suppression Systems X Gaseous Fire Suppression 3.10. Systems X 3.11 Passive Fire Protection Features X Deleted: X 3.11.1 Building Separation (Note 3) X 3.11.2 Fire Barriers X 3.11.3 Fire Barrier Penetrations X Through Penetration Fire Stops 3.11.4 (Note 2) X Electrical Raceway Fire Barrier 3.11.5 Systems (ERFBS) X Note 1 - Separate FAQs will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.

Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)

Note 3 - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis.

The process in this FAQ is not applicable.

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses EXAMPLE Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

JUSTIFICATION Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives /

criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to NFPA 805 Chapter 4 conditional sections and the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner as is currently allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

The method will ensure that the following requirements are met:

10 CFR 50.48(c)(2)(vii) Requirement Method of Accomplishment (a) The required NFPA 805 performance The fire protection engineering analysis process includes goals, performance objectives, and the assessment of impact on NFPA 805 performance goals, performance criteria are satisfied. performance objectives, and performance criteria are satisfied. Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.

(b) Safety margins are maintained. Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

(c) Fire protection defense-in-depth is Maintaining fire protection defense-in-depth will be ensured maintained. using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:

RG 1.205 Guidance Method of Accomplishment (a) detailed description of the The process is not considered an alternative method. Deleted: The alternative method will be described in the LAR in detail, or a alternative risk-informed, Existing risk-informed, performance-based methods will be reference to NEI 04-02 will be performance-based method applied, but for a limited scope of NFPA 805 Chapter 3 provided once the process is added sections: to this document.

When the Chapter 3 requirements are conditional Formatted: Bullets and Numbering based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805.

(b) description of how the method will Risk-informed, performance based fire protection engineering be applied, the aspects of the FPP to analyses will be allowed to be applied which it will applied, and the When the Chapter 3 requirements are conditional circumstances under which it will be based upon NFPA 805 Chapter 4; and applied For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805 (c) acceptance criteria, including risk Acceptance criteria for changes will use the risk-informed, increase acceptance criteria, that the performance-based change process in NEI 04-02 Chapter 5 licensee will apply when determining and Appendices I and J (and supplemented by RG 1.205 whether the results of an evaluation Section 3.2).

that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria (d) for PSA-based methodologies, an Technical adequacy of the PSA used in the risk-informed, explanation of how the PSA is of performance-based approach will be in accordance with RG sufficient technical adequacy for 1.205.

evaluation of the changes to which it will be applied (e) for PSA-based methodologies, a Peer review of the PSA used in the risk-informed, description of the peer review and performance-based approach will be in accordance with RG how the review findings have been 1.205.

addressed CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.

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FAQ Number 06-0008 FAQ Revision 4a FAQ Title Alternative Method for Fire Protection Engineering Analyses If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:

[See attached proposed revision to NEI 04-02]

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Section 2.2, page 7, 3rd paragraph:

Performance-Based Methods, § 50.48(c)(2)(vii) - The prohibition in Section 3.1 of NFPA 805 that does not permit the use of performance-based methods for the Chapter 3 fundamental fire protection program elements and minimum design criteria is not endorsed. The NRC takes this exception in order to provide licensees greater flexibility in meeting the fire protection program elements and minimum design requirements of Chapter 3 by the use of performance-based methods (including the use of risk-informed methods) described in the NFPA 805 standard. Licensees who wish to deviate from Chapter 3 requirements must submit a license amendment request for NRC approval.

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

o When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and o For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 2.3, page 9, 2nd paragraph:

Compliance with Chapter 3 of NFPA 805 may be demonstrated by showing that the specific requirements are met either directly or by the use of alternative methods and analytical approaches. Alternative methods and analytical approaches must be accepted by the NRC in a license amendment per 10 CFR 50.48(c)(4). Contrary to Section 3.1 of NFPA 805, performance-based methods may be used. (See 10 CFR 50.48(c)(2)(vii)). Note licensees contemplating applying for permission to use an alternative method or analytical approach could pursue a generic approval process with other utilities and/or NEI. See Section 2.4 of this document.

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.1.1, page 21, 1st paragraph:

For areas of the fire protection program that are not in compliance with NFPA 805, Chapter 3, the licensee may utilize the alternate performance-based methods as long as the method is FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 1

approved by the NRC in a License Amendment. The NRC has taken exception to NFPA 805, Section 3.1 (See 10 CFR 50.48.c (2)(vii)).

Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.3.1, page 27, add new paragraph to this section at the end Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 4.6.1, page 34 insert new paragraph before last sentence A sample LAR Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

Section 5.3.1, page 43

.Under the risk-informed, performance-based regulatory framework, Fire Protection Program changes will be made without prior NRC approval, except where required by:

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10 CFR 50.59, Other regulatory processes (i.e., Technical Specifications),

10CFR 50.48(c) (certain changes to Chapter 3 requirements or Nuclear Safety Changes that do not meet the acceptance criteria of NFPA Section 2.4.4.)

Changes that have been evaluated using performance-based methods other than the those Deleted: NFPA 805 Section 1.7 Equivalency states that Nothing in this acceptable to the AHJ standard is intended to prevent the use of systems, methods, or devices of Changes that have been evaluated using performance-based methods other than the equivalent or superior quality, strength, approaches in NFPA 805 (i.e., fire modeling and risk evaluation) fire resistance, effectiveness, durability and safety over those prescribed by this Except as noted, in general changes that have been previously approved by the NRC or that do standard. Technical documentation shall be submitted to the authority having not deviate from a specific NFPA 805 requirement related to systems, methods, or devices need jurisdiction to demonstrate equivalency.

not be submitted for AHJ approval Licensees can deviate from the NFPA standards referenced in NFPA 805 Chapter 3 without NRC approval if

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allowed by the code of record, so long as the evaluated condition is in accordance Section 5.3.2, page 46, starting with 7th paragraph: with the terms of the code of record or if the code does not dictate the specific issue (e.g., adequacy of coverage of Additional consideration should be given to changes to Fundamental Program Elements and suppression and detection systems). In Minimum Design Requirements. 10 CFR 50.48(c)(2)(vii) allows licensees to use performance- addition to the performance-based methods outlined in NFPA 805, the NRC based methods to demonstrate compliance with NFPA 805 Chapter 3 requirements. However, will provide guidance on Analytical these alternate methods must be approved via the license amendment process (10 CFR methods and tools and methods acceptable for use in NFPA 805 50.48(c)(4)). applications in the Regulatory Guide for the adoption of 10 CFR 50.48. Therefore approval will be required for:¶ Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed Deleted: out NRC approval if allowed by the code of record, so long as the methods/processes. evaluated condition is in accordance with the terms of the code of record (e.g.,

Nothing in this standard is intended to Most changes to the Fundamental Program Elements and Minimum Design Requirements should restrict new technologies or alternate not require a License Amendment request, since they are evaluations that demonstrate arrangements, providing the level of safety prescribed by the standard is not compliance with requirements of Chapter 3 of NFPA 805. Licensees can deviate from the NFPA lowered. - Excerpt from 1985 edition of standards referenced in NFPA 805 Chapter 3 within the bounds discussed in Appendix L. NFPA 13) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection Examples of changes that would not require a License Amendment are: systems).

Deleted: <#>Changing the surveillance Replacing a fire rated component (e.g., penetration seal, door, wrap, etc.) with a different frequency of a fire protection feature or component/material having the same or greater fire rating. This does not require a license system based on NFPA standard as long as the underlying basis for the NFPA amendment because it meets the appropriate code. standard frequency is the same. This does not require a license amendment because Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of the surveillance frequency would satisfy that specified in the current edition of NFPA 805 and the referenced code do not dictate where a sprinkler system should be NFPA codes for providing reasonable assurance that the system or component is maintained in an operable condition.¶ FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 3

installed. Therefore the adequacy of the coverage should be evaluated with respect to the nuclear safety component(s) the sprinkler system is protecting.

Evaluating a broken/missing hanger on a fire suppression system. The acceptability of this deviation can be evaluated to show that the support of the system is still adequate with the broken/missing hanger and is therefore equivalent to a code compliant system as allowed by the code of record.

Conversely, examples of changes that would require a License Amendment are:

Deleted: <#>Revision of concentration Reducing the number of fire brigade members required on-site to below five. of an agent to a value less than that required by the respective code or Elimination of the Fire Prevention Program at the plant previously approved value.¶ NFPA 805 Section 4.1, states that, Deterministic requirements shall be deemed to satisfy the performance criteria and require no further engineering analysis. Chapter 4 of NFPA 805 provides the requirements for the baseline evaluation of the fire protection programs ability to achieve the performance criteria outlined in Section 1.5 of NFPA 805. The deemed to satisfy with out additional engineering analysis does not imply that a Plant Change Evaluation would not be performed. For example if a licensee was changing its current licensing basis in a fire area to a deterministic method, that change would require a Plant Change Evaluation. Note the Defense in Depth and Safety Margin portion of the Plant Change Evaluation would be satisfied by the fact that a deterministic option was chosen for compliance (See Sections 2.4.4.2 and 2.4.4.3 of NFPA 805).

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Appendix I, page I-2 (note: changes are shown to approved FAQ 06-0002, rather than rev. 1 of NEI 04-02).

FIRE PROTECTION PROGRAM FUNDAMENTAL ELEMENT / MINIMUM DESIGN REQUIREMENT CHANGE QUESTIONS Considering the proposed change, answer the following questions, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s).

3. Does the proposed change involve an NFPA 805 Chapter 3 requirement as defined in [Insert appropriate document reference]? For those fire protection program changes that involve a Nuclear Safety Compliance Strategy requirement or a Radioactive Release requirement, ensure the effect of the change is evaluated in Appendix I, Sections 1.0 and 2.0, respectively.

• Yes - Proceed to Question 3.a.

• No - Document basis and proceed to Question 2

a. Is the change editorial or trivial in nature? (See Attachment 1) o Yes Document basis and stop.

o No Proceed to Question 3.b.

b. Does the change meet NFPA 805 Chapter 3 requirements or the previously approved alternative as defined in [Insert appropriate document reference]?

Previously approved alternatives include fire protection engineering analyses that are allowed based upon an approved license amendment described in NEI 04-02, Appendix L. (See Deleted: Changes that deviate from the Attachment 2) NFPA standards referenced in NFPA 805 Chapter 3 can be made without NRC o Yes Document conclusions, complete remaining sections. approval if allowed by the code of record (so long as the evaluated condition is in o No License Amendment Request must be processed for NRC approval. accordance with the terms of the code of Complete remaining sections. record) or if the code does not dictate the specific issue (e.g., adequacy of coverage of suppression and detection systems).

Ensure documentation for determination

_______________________________________________________________________ of acceptability is included and meets

___________________________________________________________________________ NEI 04-02 requirements for

___________________________________________________________________________ documentation.

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Appendix I - Attachment 2, page I-8 Refer to Appendix L for a process/method to be submitted in the transition LAR is to allow fire protection engineering analyses to address NFPA 805 Chapter 3 requirements:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated components in NFPA 805.

Approval of a license amendment for the use of this process would constitute a previously approved alternative that would allow the use of this process without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes.

The following are examples of changes that do not require NRC approval: Deleted: In general, deviations from Chapter 3 must be submitted for NRC Replacing a fire rated component (e.g., fire rated penetration seal, fire door, fire rated approval per the Rule. However, licensees can deviate from the NFPA wrap, etc.) with a different component having the same or greater fire rating. standards referenced in Chapter 3 without NRC approval if allowed by the code of Use of fire hoses manufactured from a different material. record and the changed condition is in accordance with the terms of the code of Use of a valve assembly supplied by a different manufacturer for a suppression system. record (e.g., many earlier editions of NFPA Codes included the following Changes to Fire Brigade Training requirements that do not affect performance. statement: Nothing in this standard is intended to restrict new technologies or Evaluating a blocked sprinkler head(s) for adequate coverage in the area. Chapter 3 of alternate arrangements, providing the level of safety prescribed by the standard NFPA 805 and the referenced code do not dictate where a sprinkler system should be is not lowered. - From 1985 edition of installed. Therefore the adequacy of the coverage should be evaluated with respect to the NFPA 13) or if the code (including NFPA 805, Chapter 3) does not dictate the nuclear safety component(s) the sprinkler system is protecting. specific issue (e.g., suppression system or detection system coverage).

Deleted: <#>Changing the surveillance

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frequency for a fire protection feature, as long as the new frequency is bounded by the NFPA code of record (and does not increase CDF or LERF), providing reasonable assurance that the system or component is maintained in an operable condition.¶ FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 6

Appendix L - Alternative Method for Engineering Analyses This Appendix is based upon Frequently Asked Question 06-0008, Revision [TBD], approved by the NRC in Closure memo dated [TBD], as documented in Regulatory Issues Summary (RIS) 2007-[TBD], dated [TBD] ADAMS Accession No. [TBD].

L.1 Background 10 CFR 50.48(c) requires licensees to submit 10 CFR 50.90 license amendment requests for any changes to Chapter 3 features of NFPA 805, unless they have been previously approved by the NRC. Under the standard license condition of GL 86-10, licensees are allowed to make certain types of changes without prior NRC approval as long as the changes do not adversely affect the plants ability to safely shutdown in the event of a fire.

To apply this process/method, licensees must send the proposed process/methods outlined in this Appendix to the NRC for approval. Then, they may use the approved processes/methods without prior approval for specific applications, as long as the application is within the bounds of NRC approval of the proposed methods/processes. Approval of a license amendment for the use of this process would constitute a previously approved alternative as discussed in NFPA 805 Section 3.1.

The licensees process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(2)(vii), Performance-Based Methods, to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make changes to Chapter 3 of NFPA 805, as long as those changes only affect the referenced standards and listings, such as Underwriters Laboratory, Inc. or Factory Mutual listings. Under the proposal the licensee will commit to a process to evaluate deviations from secondary codes and listings required by NFPA 805 Chapter 3. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

Therefore, application of this process/method requires two steps. First, the process/methods and bounds of the process must be submitted to the NRC for approval. Second, following approval by the NRC, all plant specific changes made under this license amendment will undergo the same evaluation process as part of 10 CFR 50.48(c)(2)(vii). This second step, application of the process/method, will not require NRC approval.

This process/method would not apply to NFPA 805 Chapter 3 changes that do not relate to either NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4.

These types of changes would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.

L.2 Process Proposed addition to the post-NFPA transition fire protection standard license condition (Section C.3.1 of Regulatory Guide 1.205:

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Appendix L - Alternative Method for Engineering Analyses Licensees may perform change evaluations for fundamental fire protection program and design elements of NFPA 805 Chapter 3 that are conditional based on NFPA 805 Chapter 4 requirements.

Licensees may also perform change evaluations for deviations from the NFPA codes and listings for rated components mentioned in NFPA 805, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not included in NFPA 805 Chapter 3 itself, and the NFPA 805 change process is used.

The following table provides the sections of NFPA 805 that will utilize this process/method.

Sections that are addressed conditionally by Chapter 4 performance-based process are also identified for completeness.

Column Heading Definition:

Fire Protection Engineering Analysis Process Applicable: Sections of NFPA 805 Chapter 3 containing referenced codes and listings. Note the Applicability would only apply to the referenced codes and listings contained within these sections, and the process could not be used to change the NFPA 805 Chapter 3 specific requirements.

Chapter 4 Conditional Section: These NFPA 805 Chapter 3 sections are conditional based upon NFPA 805 Chapter 4 requirements. The requested use of fire protection engineering evaluations for these sections are not limited to referenced codes and listings.

Fire Protection Engineering Analysis and Chapter 4 Not Applicable: These NFPA 805 Chapter 3 sections do not have NFPA 805 Chapter 4 conditions and do not have referenced codes and listings. Therefore, the process/method associated with this Appendix is not applicable and would be outside the scope of the associated LAR.

Section Title FP Eng. Analysis Chapter 4 FP Eng.

Process Conditional Analysis Applicable Section Process and Chapter 4 Not Applicable 3.1 General X 3.2 Fire Protection Plan X 3.2.1 Intent X 3.2.2 Management Policy Direction X and Responsibility 3.2.3 Procedures X 3.3 Prevention X 3.3.1 Fire Prevention for Operational X Activities 3.3.2 Structural X 3.3.3 Interior Finishes X FAQ 06-0008 rev. 4a - NEI 04-02 markup - Page 8

Appendix L - Alternative Method for Engineering Analyses Section Title FP Eng. Analysis Chapter 4 FP Eng.

Process Conditional Analysis Applicable Section Process and Chapter 4 Not Applicable 3.3.4 Insulation Materials X 3.3.5 Electrical X 3.3.6 Roofs X 3.3.7 Bulk Flammable Gas Storage X 3.3.8 Bulk Storage of Flammable and X Combustible Liquids 3.3.9 Transformers X 3.3.10 Hot Pipes and Surfaces X 3.3.11 Electrical Equipment (Note 1) X 3.3.12 Reactor Coolant Pumps (Note 1) X 3.4 Industrial Fire Brigade 3.4.1 On-Site Fire Fighting Capability X 3.4.2 Pre-Fire Plans X 3.4.3 Training and Drills X 3.4.4 Fire Fighting Equipment X 3.4.5 Off-Site Fire Department X Interface 3.4.6 Communications X 3.5 Water Supply X 3.6 Standpipe and Hose Stations X 3.7 Fire Extinguishers X 3.8 Fire Alarm and Detection Systems 3.8.1 Fire Alarm X 3.8.2 Detection X 3.9 Automatic and Manual Water- X Based Fire Suppression Systems 3.10. Gaseous Fire Suppression X Systems 3.11 Passive Fire Protection Features X 3.11.1 Building Separation (Note 3) X 3.11.2 Fire Barriers X 3.11.3 Fire Barrier Penetrations X 3.11.4 Through Penetration Fire Stops X (Note 2)

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Appendix L - Alternative Method for Engineering Analyses Section Title FP Eng. Analysis Chapter 4 FP Eng.

Process Conditional Analysis Applicable Section Process and Chapter 4 Not Applicable 3.11.5 Electrical Raceway Fire Barrier X Systems (ERFBS)

Note 1 - Separate clarifications [TBD] will be used to clarify the applicability of engineering analyses to the requirements of Section 3.3.11 and 3.3.12 of NFPA 805.

Note 2 - Through penetration fire stops referenced in Section 3.11.4 of NFPA 805 are considered conditional based upon NFPA 805 Chapter 4 requirements, since they are integral to fire barriers (Section 3.11.2)

Note 3 - Section 3.11.1 of NFPA 805 contains an exception for performance-based analysis.

The process in this FAQ is not applicable.

L.3 Example Section 3.6.1 of NFPA 805 requires a hose system to be installed per NFPA 14. Using this process/method, a hose system must be available and have access to all power block buildings, and must also be a Class III standpipe, but may deviate from other specific requirements of NFPA 14. These deviations must not contradict other text in Chapter 3 of NFPA 805. The NFPA 805 change evaluation process will be used to ensure that nuclear safety performance goals, objectives and criteria are satisfied along with defense-in-depth and safety margins, as described in 10 CFR 50.48(c)(2)(vii).

L.4 Justification Since this process/method will be approved by the NRC as part of the 10 CFR 50.90 submittal, it will meet the legal requirement of 10 CFR 50.48(c)(2)(vii). The basis for the change evaluation to be included in the 10 CFR 50.90 submittal will be that each individual change will be evaluated against the NFPA 805 change process (NFPA 805 performance goals / objectives

/criteria, defense-in-depth and safety margins evaluation), and providing this flexibility does not adversely impact the features required by Chapter 3 of NFPA 805 to ensure the NFPA 805 performance goals, performance objectives, and performance criteria are satisfied. By only allowing changes to the secondary codes and listings, the changes are bounded. All features required by Chapter 3 will continue to be required (unless specifically addressed separately from this process in an LAR). Secondary features may be changed based on an evaluation, using the required methods in a similar manner that was previously allowed under the Generic Letter 86-10 license condition, without prior NRC approval.

The method will ensure that the following requirements are met:

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Appendix L - Alternative Method for Engineering Analyses 10 CFR 50.48(c)(2)(vii) Requirement Method of Accomplishment (a) The required NFPA 805 performance The fire protection engineering analysis process includes goals, performance objectives, and the assessment of impact on NFPA 805 performance goals, performance criteria are satisfied. performance objectives, and performance criteria are satisfied. Impact will be assessed per risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section 3.2.

(b) Safety margins are maintained. Maintaining safety margins will be ensured using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

(c) Fire protection defense-in-depth is Maintaining fire protection defense-in-depth will be ensured maintained. using the risk-informed, performance-based change process in NEI 04-02 Chapter 5 and Appendices I and J and supplemented by RG 1.205 Section C.3.2.

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Appendix L - Alternative Method for Engineering Analyses The LAR will contain the following information per Regulatory Guide 1.205 Section C.3.2.3:

RG 1.205 Guidance Method of Accomplishment (a) detailed description of the The process is not considered an alternative method.

alternative risk-informed, Existing risk-informed, performance-based methods will be performance-based method applied, but for a limited scope of NFPA 805 Chapter 3 sections:

When the Chapter 3 requirements are conditional based upon NFPA 805 Chapter 4; and For deviations from the NFPA codes and listings for rated Formatted: table bullets components mentioned in NFPA 805.

(b) description of how the method will Risk-informed, performance based fire protection engineering be applied, the aspects of the FPP to analyses will be allowed to be applied:

which it will applied, and the When the Chapter 3 requirements are conditional based Formatted: Bullets and Numbering circumstances under which it will be upon NFPA 805 Chapter 4; and applied For deviations from the NFPA codes and listings for rated components mentioned in NFPA 805.

(c) acceptance criteria, including risk Acceptance criteria for changes will use the risk-informed, increase acceptance criteria, that the performance-based change process in NEI 04-02 Chapter 5 licensee will apply when determining and Appendices I and J (and supplemented by RG 1.205 whether the results of an evaluation Section 3.2).

that uses this methodology meet the required NFPA 805 performance goals, performance objectives, and performance criteria (d) for PSA-based methodologies, an Technical adequacy of the PSA used in the risk-informed, explanation of how the PSA is of performance-based approach will be in accordance with RG sufficient technical adequacy for 1.205.

evaluation of the changes to which it will be applied (e) for PSA-based methodologies, a Peer review of the PSA used in the risk-informed, description of the peer review and performance-based approach will be in accordance with RG how the review findings have been 1.205.

addressed L.5 Conclusion This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within the bounds of secondary codes and listings or changes that are conditional based on NFPA 805 Chapter 4. Following NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without prior NRC approval. Other issues, not involving NFPA codes or listings or changes that are not conditional based on NFPA 805 Chapter 4, would have to be submitted for NRC approval on a case by case basis.

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