ML070800007
| ML070800007 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/20/2007 |
| From: | Ertman J Progress Energy Co |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NFPA 805 FAQ 06-0008, Rev 2d | |
| Download: ML070800007 (5) | |
Text
FAQ Number 06-0008 FAQ Revision 2 d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 1 of 5 FAQ 06-0008R2d.doc Plant: Harris Date:2/15/2007 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 protec tion license conditions.
The process/method discussed in this FAQ will be submitted for approval as part of the transition license amendment request (LAR). Post-transition, licensees will use this process/method to self approve acceptable fire prot ection 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. 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 ar e not conditional based up on Chapter 4 requirements. Current licensing basis allows flexibility to use performance
-based technical analysis per G eneric L etter 86-10. An alternative method (approach) is needed to allow this flexibility following transition to NFPA 805.
Detail contentious points if licensee and NRC have not reached consensus on the facts and circumstances:
FAQ Number 06-0008 FAQ Revision 2 d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 2 of 5 FAQ 06-0008R2d.doc 10 CFR 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4) provide for performance-based methods and alternatives to NFPA 805 as a means of meeting fire protec tion regulations, 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)/10 CFR 50.48(c)(4) License Amendment Request has not yet been agreed upon.
Potentially relevant existing FAQ numbers:
FAQ 06-0004 includes a process for defining fire protection system s 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 flex ibility afforded by 10 CF R 50.48(c)(2)(vii) and 10 CFR 50.48(c)(4) to develop a process to maintain the current flexibility available to licensees under Generic Letter (G L) 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, unle ss 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 withou t prior NRC approval as long as the changes do not adversely affect the plant's 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 applicati on is within the bounds of NRC approval of the proposed methods/processes.
The licensees' process/methodology must request an amendment under 10 CFR 50.90, using the flexibility available under 10 CFR 50.48(c)(v ii) and 10 CFR 50.48(c)(iv) to allow 10 CFR 50.48(c) licensees to establish a process that enables them to make change s to Chapter 3 of NFPA 805, as long as those change s only affect the referenced st andards 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 FAQ Number 06-0008 FAQ Revision 2 d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 3 of 5 FAQ 06-0008R2d.doc 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 NFPA codes or listings.
Changes to other portions of Chapte r 3 of NFPA 805 would continue to require individual 10 CFR 50.90 license amendment requests addressing the specific deviation.
PROCESS "License es may perform change evaluations for deviations from the NFPA codes mentioned in NFPA 805, and listings for rated components, without a 10 CFR 50.90 submittal, as long as the specific requirement for the feature is not include d 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.
Section Title FAQ 06-008 Process Applicable Chapter 4 Conditional Section FAQ 06-008 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 and Responsibility X 3.2.3 Procedures X 3.3 Prevention X 3.3.1 Fire Prevention for Operational 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
FAQ Number 06-0008 FAQ Revision 2 d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 4 of 5 FAQ 06-0008R2d.doc Section Title FAQ 06-008 Process Applicable Chapter 4 Conditional Section FAQ 06-008 Process and Chapter 4 Not Applicable 3.3.8 Bulk Storage of Flammable and Combustible Liquids X 3.3.9 Transformers X 3.3.10 Hot Pipes and Surfaces X 3.3.11 Electrical Equipment X 3.3.12 Reactor Coolant Pumps 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 Interface X 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 X 3.9 Automatic and Manual Water-Based Fire Suppression Systems X 3.10. Gaseous Fire Suppression Systems X 3.11 Passive Fire Protection Features X 3.11.1 Building Separation X 3.11.2 Fire Barriers X 3.11.3 Fire Barrier Penetrations X 3.11.4 Through Penetration Fire Stops X 3.11.5 Electrical Raceway Fire Barrier Systems (ERFBS) X FAQ Number 06-0008 FAQ Revision 2 d FAQ Title Alternative Method for Fire Protection Engineering Analyses Page 5 of 5 FAQ 06-0008R2d.doc 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 a nd 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 N FPA 805 change process (NFPA 805 performance goals/objectives/criteria, defense-in-depth and safety marg ins 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 as is currently allowed under the Generic Letter 86-10 license condi tion, without prior NRC approval.
CONCLUSION This process/method will permit a risk-informed, performance-based approach to evaluate Fire Protection Program changes within th e bounds of secondary codes and listings. F ollowing NRC approval of a 10 CFR 50.90 license amendment, this process/methodology will permit licensees to evaluate fire protection features without pr ior NRC approval. Other issues not addressed by NFPA codes or listings would have to be submitted for NRC approval on a case by case basis.
If appropriate, provide proposed rewording of guidance for inclusion in the next Revision:
[To be provided following review and disc ussion on the approach with the NRC.] A proposed method/process is to include the text from the "Process and Example" sections above in section 5.3 of NEI 04-02. Note this is similar to guidance from NEI 02-03 Appendix A. The new process/method for changes would be cross-re ferenced in the other sections of NEI 04-02 (i.e., 2.3, 2.4, 4.3.1, 4.6.1, Appendix H, and Appendix I).