ML081400292: Difference between revisions
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{{#Wiki_filter:August 20, 2008 MEMORANDUM TO: AFPB File | {{#Wiki_filter:August 20, 2008 MEMORANDUM TO: AFPB File FROM: Alexander Klein, Chief /RA/ | ||
Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation | |||
FROM: | |||
==SUBJECT:== | ==SUBJECT:== | ||
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FREQUENTLY ASKED QUESTION 07-0032, CLARIFICATION OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50.48(c), 50.48(a) AND GENERAL DESIGN CRITERION 3 | CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FREQUENTLY ASKED QUESTION 07-0032, CLARIFICATION OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50.48(c), 50.48(a) AND GENERAL DESIGN CRITERION 3 The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Frequently Asked Question (FAQ) 07-0032, Revision 2. FAQ 07-0032, Revision 2 was proposed by the transition team at the Shearon Harris nuclear plant (the authors) to clarify that satisfying Title 10 of the Code of Federal Regulations Part 50.48(c) (10 CFR 50.48(c)) will satisfy 10 CFR 50.48(a) and General Design Criterion 3 (GDC 3) in 10 CFR Part 50 Appendix A. | ||
The need for this Frequently Asked Question was identified during several National Fire Protection Association (NFPA) 805 Pilot Observation Meetings between the NRC staff and the technical staff of the two NFPA 805 Pilot Plants. The existing industry guidance document developed to assist in NFPA 805 transition, Nuclear Energy Institute document NEI 04-02, Guidance for Implementing a Performance-Based, Risk-Informed Fire Protection Program Under 10 CFR 50.48(c) (NEI 04-02) contains an overview of the new rule in Section 2.1 but does not clearly explain how meeting 10 CFR 50.48(c) satisfies 10 CFR 50.48(a) and GDC 3. | |||
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Frequently Asked Question (FAQ) 07-0032, Revision 2. FAQ 07-0032, Revision 2 was proposed by the transition team at the Shearon Harris nuclear plant (the authors) to clarify that satisfying Title 10 of the Code of Federal Regulations Part 50.48(c) (10 CFR 50.48(c)) will satisfy 10 CFR 50.48(a) and General Design Criterion 3 (GDC 3) in 10 CFR Part 50 Appendix A. | The authors of FAQ 07-0032, Revision 2, included a line by line review of the requirements in 10 CFR 50.48(a) and GDC 3 and compared them to the requirements in National Fire Protection Association Standard 805 (NFPA 805). The authors have documented that all requirements in 10 CFR 50.48(a) and GDC 3 would be met through corresponding requirements in NFPA 805. | ||
The need for this Frequently Asked Question was identified during several National Fire Protection Association (NFPA) 805 Pilot Observation Meetings between the NRC staff and the technical staff of the two NFPA 805 Pilot Plants. The existing industry guidance document developed to assist in NFPA 805 transition, Nuclear Energy Institute document NEI 04-02, | Industry Proposal The authors of FAQ 07-0032, Revision 2 proposed revising NEI 04-02, Section 2.2.2, Relationship to Other Fire Protection Requirements, to discuss the relationship between 10 CFR 50.48(a), 10 CFR 50.48(c) and GDC 3. | ||
CONTACT: Harry Barrett, NRR/DRA (301) 415-1402 | |||
The authors of FAQ 07-0032, Revision 2, included a line by line review of the requirements in 10 CFR 50.48(a) and GDC 3 and compared them to the requirements in National Fire Protection Association Standard 805 (NFPA 805). The authors have documented that all requirements in 10 CFR 50.48(a) and GDC 3 would be met through corresponding requirements in NFPA 805. | |||
A. Klein The authors stated that the new rule does not supersede the requirements of GDC 3 or 10 CFR 50.48(a). By implementing a fire protection program that meets the requirements of NFPA 805 in accordance with 10 CFR 50.48(c), the requirements of 10 CFR 50.48(a) and GDC 3 will be met. | |||
The authors stated that the new rule does not supersede the requirements of GDC 3 or | |||
===NRC Staff Evaluation=== | |||
The NRC staff (the staff) has evaluated the FAQ 07-0032, Revision 2 proposal with respect to regulatory compliance and technical adequacy. | The NRC staff (the staff) has evaluated the FAQ 07-0032, Revision 2 proposal with respect to regulatory compliance and technical adequacy. | ||
The proposed additions to NEI 04-02 are consistent with the regulation as well as the explanation provided in the statements of consideration for the final rule. The proposed changes are technically adequate because each of the requirements contained in NFPA 805 meet or exceed the requirements in 10 CFR 50.48(a) and GDC 3. Therefore, the staff finds the proposed changes to NEI 04-02 to be acceptable. | The proposed additions to NEI 04-02 are consistent with the regulation as well as the explanation provided in the statements of consideration for the final rule. The proposed changes are technically adequate because each of the requirements contained in NFPA 805 meet or exceed the requirements in 10 CFR 50.48(a) and GDC 3. Therefore, the staff finds the proposed changes to NEI 04-02 to be acceptable. | ||
The staff has reviewed the proposed changes to NEI 04-02 as presented in FAQ 07-0032, Revision 2 and finds that nothing in this FAQ would prevent continued endorsement of | The staff has reviewed the proposed changes to NEI 04-02 as presented in FAQ 07-0032, Revision 2 and finds that nothing in this FAQ would prevent continued endorsement of NEI 04-02. In accordance with RIS 2007-19, 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. | ||
See the enclosure to this memorandum for a chronological history of this FAQ. | See the enclosure to this memorandum for a chronological history of this FAQ. | ||
==References:== | ==References:== | ||
Line 50: | Line 44: | ||
* NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 1, (ADAMS accession number ML052590476) | * NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 1, (ADAMS accession number ML052590476) | ||
* NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (available through the Public Document Room or NFPA) | * NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (available through the Public Document Room or NFPA) | ||
A. Klein | |||
* Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants (ADAMS accession number ML061100174) | * Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants (ADAMS accession number ML061100174) | ||
* NRC Regulatory Information Summary 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 number ML071590227) | * NRC Regulatory Information Summary 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 number ML071590227) | ||
==Enclosure:== | ==Enclosure:== | ||
As Stated | |||
ML081400292 NRR-106 OFFICE NRR/DRA/AFPB NRR/DRA/AFPB NRR/DRA/AFPB OGC NAME H Barrett DFrumkin AKlein BJones DATE 06 / 28 /08 06 / 30 /08 07 / 01 /08 08 / 20 /08 | |||
FAQ 07-0032 History INITIAL FREQUENTLY ASKED QUESTION FAQ 07-0032 PROPOSAL The National Fire Protection Association (NFPA) 805 Transition Team at the Shearon Harris nuclear plant initiated FAQ 07-0032 and processed it through the Nuclear Energy Institutes NFPA 805 Task Force in order to provide guidance to licensees transitioning to NFPA 805 clarifying that satisfying Title 10 of The Code of Federal Regulations Part 50 (10 CFR 50.48(c) will satisfy 10 CFR 50.48(a) and General Design Criterion 3 (GDC 3). | |||
NRC STAFF RESPONSE TO FAQ 07-0032, REVISION 0 The U.S. Nuclear Regulatory Commission (NRC) staff responded with a comment that the FAQ as written adequately addressed the discussion regarding systems, structures and components (SSCs) important to safety, but did not address the other sections of GDC 3 and 10 CFR 50.48(a). The comment also pointed out that 10 CFR 50.48(a)(1)(iv) has a requirement that the fire protection program plan must outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. The language in the regulation does not limit fire damage to only SSCs. | |||
FAQ 07-0032, REVISION 1 The FAQ authors added a comprehensive list of attributes included in GDC 3 and 10 CFR 50.48(a) and indicated how each of those attributes is addressed in the NFPA 805 standard. In addition, revision 1 also removed proposed changes to the License Amendment Request template provided in Appendix H in NEI 04-02. | |||
NRC STAFF RESPONSE TO FAQ 07-0032 The NRC staff identified minor issues with the table listing the requirements in GDC 3 and 10 CFR 50.48(a) and how some of the attributes are addressed in NFPA 805. | NRC STAFF RESPONSE TO FAQ 07-0032 The NRC staff identified minor issues with the table listing the requirements in GDC 3 and 10 CFR 50.48(a) and how some of the attributes are addressed in NFPA 805. | ||
FAQ 07-0032, Revision 2 The FAQ authors addressed all the NRC staff comments.}} | FAQ 07-0032, Revision 2 The FAQ authors addressed all the NRC staff comments. | ||
ENCLOSURE}} |
Revision as of 17:33, 14 November 2019
ML081400292 | |
Person / Time | |
---|---|
Site: | Harris ![]() |
Issue date: | 08/20/2008 |
From: | Klein A NRC/NRR/DRA/AFPB |
To: | NRC/NRR/DRA/AFPB |
Barrett H | |
References | |
FAQ 07-0032 | |
Download: ML081400292 (5) | |
Text
August 20, 2008 MEMORANDUM TO: AFPB File FROM: Alexander Klein, Chief /RA/
Fire Protection Branch Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT:
CLOSE-OUT OF NATIONAL FIRE PROTECTION ASSOCIATION STANDARD 805 FREQUENTLY ASKED QUESTION 07-0032, CLARIFICATION OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS PART 50.48(c), 50.48(a) AND GENERAL DESIGN CRITERION 3 The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Frequently Asked Question (FAQ) 07-0032, Revision 2. FAQ 07-0032, Revision 2 was proposed by the transition team at the Shearon Harris nuclear plant (the authors) to clarify that satisfying Title 10 of the Code of Federal Regulations Part 50.48(c) (10 CFR 50.48(c)) will satisfy 10 CFR 50.48(a) and General Design Criterion 3 (GDC 3) in 10 CFR Part 50 Appendix A.
The need for this Frequently Asked Question was identified during several National Fire Protection Association (NFPA) 805 Pilot Observation Meetings between the NRC staff and the technical staff of the two NFPA 805 Pilot Plants. The existing industry guidance document developed to assist in NFPA 805 transition, Nuclear Energy Institute document NEI 04-02, Guidance for Implementing a Performance-Based, Risk-Informed Fire Protection Program Under 10 CFR 50.48(c) (NEI 04-02) contains an overview of the new rule in Section 2.1 but does not clearly explain how meeting 10 CFR 50.48(c) satisfies 10 CFR 50.48(a) and GDC 3.
The authors of FAQ 07-0032, Revision 2, included a line by line review of the requirements in 10 CFR 50.48(a) and GDC 3 and compared them to the requirements in National Fire Protection Association Standard 805 (NFPA 805). The authors have documented that all requirements in 10 CFR 50.48(a) and GDC 3 would be met through corresponding requirements in NFPA 805.
Industry Proposal The authors of FAQ 07-0032, Revision 2 proposed revising NEI 04-02, Section 2.2.2, Relationship to Other Fire Protection Requirements, to discuss the relationship between 10 CFR 50.48(a), 10 CFR 50.48(c) and GDC 3.
CONTACT: Harry Barrett, NRR/DRA (301) 415-1402
A. Klein The authors stated that the new rule does not supersede the requirements of GDC 3 or 10 CFR 50.48(a). By implementing a fire protection program that meets the requirements of NFPA 805 in accordance with 10 CFR 50.48(c), the requirements of 10 CFR 50.48(a) and GDC 3 will be met.
NRC Staff Evaluation
The NRC staff (the staff) has evaluated the FAQ 07-0032, Revision 2 proposal with respect to regulatory compliance and technical adequacy.
The proposed additions to NEI 04-02 are consistent with the regulation as well as the explanation provided in the statements of consideration for the final rule. The proposed changes are technically adequate because each of the requirements contained in NFPA 805 meet or exceed the requirements in 10 CFR 50.48(a) and GDC 3. Therefore, the staff finds the proposed changes to NEI 04-02 to be acceptable.
The staff has reviewed the proposed changes to NEI 04-02 as presented in FAQ 07-0032, Revision 2 and finds that nothing in this FAQ would prevent continued endorsement of NEI 04-02. In accordance with RIS 2007-19, 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.
See the enclosure to this memorandum for a chronological history of this FAQ.
References:
For details regarding this FAQ, please see the following:
- FAQ 07-0032, Revision 0 (7/07) (ADAMS accession number ML071930378)
- NRC Staff Response to FAQ 07-0032, Revision 0, (10/07) (ADAMS accession number ML073060492)
- FAQ 07-0032, Revision 1 (3/08) (ADAMS accession number ML080700411)
- NRC Staff Response to FAQ 07-0032, Revision 1, (5/08) (ADAMS accession number ML081300689
- FAQ 07-0032, Revision 2 (5/08) (ADAMS accession number ML081300697)
- NEI 04-02, Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program Under 10 CFR 50.48(c), Revision 1, (ADAMS accession number ML052590476)
- NFPA 805, Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants, 2001 Edition (available through the Public Document Room or NFPA)
A. Klein
- Regulatory Guide 1.205, Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants (ADAMS accession number ML061100174)
- NRC Regulatory Information Summary 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 number ML071590227)
Enclosure:
As Stated
ML081400292 NRR-106 OFFICE NRR/DRA/AFPB NRR/DRA/AFPB NRR/DRA/AFPB OGC NAME H Barrett DFrumkin AKlein BJones DATE 06 / 28 /08 06 / 30 /08 07 / 01 /08 08 / 20 /08
FAQ 07-0032 History INITIAL FREQUENTLY ASKED QUESTION FAQ 07-0032 PROPOSAL The National Fire Protection Association (NFPA) 805 Transition Team at the Shearon Harris nuclear plant initiated FAQ 07-0032 and processed it through the Nuclear Energy Institutes NFPA 805 Task Force in order to provide guidance to licensees transitioning to NFPA 805 clarifying that satisfying Title 10 of The Code of Federal Regulations Part 50 (10 CFR 50.48(c) will satisfy 10 CFR 50.48(a) and General Design Criterion 3 (GDC 3).
NRC STAFF RESPONSE TO FAQ 07-0032, REVISION 0 The U.S. Nuclear Regulatory Commission (NRC) staff responded with a comment that the FAQ as written adequately addressed the discussion regarding systems, structures and components (SSCs) important to safety, but did not address the other sections of GDC 3 and 10 CFR 50.48(a). The comment also pointed out that 10 CFR 50.48(a)(1)(iv) has a requirement that the fire protection program plan must outline the plans for fire protection, fire detection and suppression capability, and limitation of fire damage. The language in the regulation does not limit fire damage to only SSCs.
FAQ 07-0032, REVISION 1 The FAQ authors added a comprehensive list of attributes included in GDC 3 and 10 CFR 50.48(a) and indicated how each of those attributes is addressed in the NFPA 805 standard. In addition, revision 1 also removed proposed changes to the License Amendment Request template provided in Appendix H in NEI 04-02.
NRC STAFF RESPONSE TO FAQ 07-0032 The NRC staff identified minor issues with the table listing the requirements in GDC 3 and 10 CFR 50.48(a) and how some of the attributes are addressed in NFPA 805.
FAQ 07-0032, Revision 2 The FAQ authors addressed all the NRC staff comments.
ENCLOSURE