ML23283A122
| ML23283A122 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23283A092 | List: |
| References | |
| DANU-ISG-2022-09 | |
| Download: ML23283A122 (1) | |
Text
This draft comment resolution table is the latest version of the table that the NRC staff has publicly released to support interactions with the Advisory Committee on Reactor Safeguards (ACRS). This version is based on reviews by NRC staff and consideration of stakeholder input. The NRC staff expects to adopt further changes to the comment resolution table.
This comment resolution table has not been subject to complete NRC management or legal review, and its contents should not be interpreted as official agency positions. The NRC staff plans to continue working on the information provided in this document.
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 Topics Section of Specific Comment NRC Staff Response Identifier Document NRC-2022- Regulations.gov Not Applicable Include in regulations.gov, as downloadable The NRC staff responded to the 0082-DRAFT- Site files, all documents for which public comments request as documented in 0002-1 are being solicited ML23174A004. The response states in 1
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document 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 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- Extension of Not Applicable Alter the Federal Register notices to establish a The NRC staff responded to the 0082-DRAFT- Comment reasonable, staggered schedule for document request as documented in 0002-2 Period review and comment by the public. 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- Purpose, p1 a. Add statement that ISG provides The NRC staff disagrees with this 0082-DRAFT- supplemental guidance to applicants using NEI comment.
0003 - 1 21-07 for application content and NFPA 805/806 for fire protection program elements.
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document
- b. Cite NEI 21-07 and NFPA 805 and 806. The Background section of the ISG describes the relationship between the The Nuclear Modernization Act unambiguously ARCAP and TICAP guidance gives codes/standards precedence over guidance documents. This ISG is part of documents. 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 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- General (a) P1, (a) Delete references to speculative changes to The NRC staff disagrees with this 0082-DRAFT- Purpose, 2nd CFRs, including proposed 10CFR53. comment.
0003 - 2 Paragraph (b) Delete all requirements in the ISG that rely (b) P2, on speculative elements in the unapproved The guidance in the ISG is based on Background 10CFR53 and planned amendments to the requirements in existing 2nd Paragraph 10CFR50 and 52 regulations (i.e., 10 CFR Parts 50 and 3
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document
- c. Delete 2ndParagraph, both sections. 52). The references to future Part 53 are only for general background Citing the unapproved 10CFR53 or intended information. The ISG does not address amendments to 10CFR50/52 as a justification any proposed Part 53 requirements.
for new requirements, even on an interim basis, is of doubtful validity. If simplifications (i.e. The NEIMA, in part, specifies that the fewer requirements) are intended for advanced NRC develop strategies for the reactors, then state reason for such increased use of risk-informed, simplifications (e.g. simply refer to Nuclear performance-based licensing Modernization Act). evaluation techniques and guidance for commercial advanced nuclear 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- General Design Guidance, p3, Delete all sentences starting with However, the The NRC staff disagrees with this 0082-DRAFT- Criteria 1st paragraph general design criterion comment.
0003 - 3 GDC 3 (Fire Protection) is relevant to all The general design criteria (GDC) of advanced reactors. Discussing the need for new 10 CFR Part 50, Appendix A are Principal Design Criteria for advanced reactors considered guidance for non-LWR is not relevant to this specific ISG. 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- Prescriptiveness Guidance, p3, Delete, replace with: The operational fire The NRC staff disagrees with this 0082-DRAFT- 2nd paragraph. protection program establishes day-to-day comment.
0003 - 4 P4, 1st programmatic measures to insure (sic) key paragraph nuclear safety functions are properly protected 4
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document against fires during plant operation. These key The commenters suggested text does nuclear safety functions are Safety-Related and not provide sufficient guidance to to a lesser degree Risk-Significant. The applicants regarding the content of applicant must identify the general features of their applications with respect to the the operational program, as linked to specific fire protection program. For the ISG provisions of governing industry to be useful, it needs to provide a level codes/standards. of specificity. Nevertheless, the ISG is only guidance and, thus, applicants The paragraphs are overly prescriptive. Fire can propose alternative application detection, suppression, and mitigation measures content. The elements addressed in are not safety-related, while other risk- this ISG are consistent with the significant items are of varying (including guidance provided in industry lesser) degrees of importance. As such, the standards related to fire protection license application involving fire protection programs. The application needs to operational controls should be general in nature, have sufficient information for the but tied to specific provisions in applicable NRC staff reviewer to understand the codes and standard. applicants fire protection program and is 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- NFPA 805 Guidance, p4, Delete identified content in the sentence This The NRC staff disagrees with this 0082-DRAFT- regulation incorporates by reference NFPA 805 comment.
0003 - 5 with certain exceptions, clarifications, and expansions.. The regulation referenced in this ISG text includes the clarifying statement Effectively coerces applicant to use lower tier that the regulation incorporates by guidance regulations. However, the Nuclear reference NFPA 805 with certain Modernization Act unambiguously gives exceptions, clarifications, and codes/standards priority. The codes/standards expansions. Adopting the change were developed by experts in the field, whereas suggested by the commenter would the staff does not possess such credentials. inappropriately alter the intent of the Further, the Code of Federal Regulations does regulation text.
not explicitly require staff endorsements. Also, there are numerous routinely used 5
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document codes/standards that are not endorsed by the Regarding the NEIMA, refer to the staff, nor has a licensee explicitly justified their response to comment NRC-2022-use. 0082-DRAFT-0003 - 1 and ARCAP Roadmap comment response NRC-2022-0074-DRAFT-0005-3.
No change has been made to this ISG.
NRC-2022- Design Guidance, p4, Delete all content after 1st sentence. The NRC staff disagrees with this 0082-DRAFT- last paragraph comment.
0003 - 6 Not relevant to ISG, while only serving to set the stage for new requirements. 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- PDC Regulatory PDC 3 is not a part of RG 1.232. Alter the The NRC staff disagrees with this 0082-DRAFT- Basis, 1st sentence to properly reflect the relationship. comment.
0003 - 7 paragraph, items 1 & 2 PDC 3 is a requirement of the CFR, whereas Guidance in regulatory guide (RG)
RG 1.232 is a guidance document. The staff is 1.232, Developing Principal Design confusing requirements versus suggestions. 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 6
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document (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.
NRC-2022- Design Regulatory Delete reference to RG 1.189. The NRC staff disagrees with this 0082-DRAFT- Basis, 2nd comment.
0003 - 8 paragraph, item Fundamentally discusses design features as 4 opposed to plant operational programs and as RG 1.189, Fire Protection for such is not particularly relevant. Introduces the Nuclear Power Plants, provides staff likely potential to create unnecessary accepted guidance regarding how an requirements, contrary to Modernization Act. 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- Quality (a) Application (a) Only list key topic areas; delete explanatory a) The NRC staff disagrees with this 0082-DRAFT- assurance Guidance - Fire text. Applicant to generally identify how comment. The purpose of the ISG 0003 - 9 Protection implementation occurs and what industry is to provide guidance to Program codes/standards apply. How implementation applicants regarding the (Administrative occurs is the subject of applicable industry development of their fire Programs codes/standards. The staff is attempting to add protection programs. Listing the during specific implementation requirements that are elements to be addressed in the Operations), P6 not justified considering that fire protection is fire protection program thru 13, items 1 not Safety-Related. The staff requirements are description is useful guidance. As thru 16. at odds with the risk informed considerations of stated in this ISG, the fire (b) Item 7 the Modernization Act. protection program description 7
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document (c) Item 8 (b) Delete all references to QA. See comment should identify what industry
- 4 and above item (a). There are no CFR codes and standards related to fire requirements for fire protection QA. Item #7 is protection the applicant used to clear regulatory overreach. develop the program. Regarding (c) Delete this item in its entirety. See comment the NEIMA, refer to the response
- 4 and item (a) above. There are no fire to comments NRC-2022-0082-protection V&V CFR requirements. Item #8 is DRAFT-0003 - 1 and - 2.
clear regulatory overreach.
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- RG 1.189 Staff Review Delete all items and replace with list of key The NRC staff disagrees with this 0082-DRAFT- Guidance - topic areas (see comment #9 (a)) and statement comment.
0003 - 10 Acceptance that the staff reviews are to use the applicants Criteria, items specifically identified industry codes/standards The staff acceptance criteria listed in 1 thru 9 elements as the basis for review and acceptance. Section C of this ISG reflect the guidance described in Sections A and The Acceptance Criteria are open ended while B. While this guidance does reference RG1.189 is regulatory overreach on a vast scale elements described in codes/standards 8
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document in the light of the Modernizations Acts (e.g., NFPA 805) there are other requirements concerning risk informed elements that the staff needs to considerations and the priority of industry evaluate to determine fire protection codes/standards. program adequacy.
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- Backfitting Backfitting Delete all requirements in the ISG that rely on The NRC staff disagrees with this 0082-DRAFT- And Issue speculation of prospective elements in the comment.
0003 - 11 Finality proposed and unapproved 10CFR53 and Discussion planned amendments to 10CFR50 and 52. The guidance in the ISG is based on the requirements in existing Appears the staff is attempting to use the ISG regulations (i.e., 10 CFR Parts 50 and for back fitting, considering that a number of 52). The references to future Part 53 new requirements are apparently being are only for general background proposed that are outside the existing Code of information. The ISG does not address Federal Regulations and industry any proposed Part 53 requirements.
codes/standards. Citing the unapproved 10CFR53 or intended amendments to Regarding the NEIMA, refer to the 10CFR50/52 as a justification for new response to comment NRC-2022-requirements, even on an interim basis, is of 0082-DRAFT-0003 - 2.
doubtful validity. If simplifications (i.e. fewer requirement) are intended, then state reason for No change has been made to this ISG.
such simplifications (e.g. refer to Nuclear Modernization Act).
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document NRC-2022 General General Please rephrase to indicate the guidance is The NRC staff disagrees with this 0074- DRAFT- technology-inclusive and is equally applicable comment. The NRC staff is 0006-1 to both LWR and non-LWR designs. considering expanding the applicability of ARCAP guidance Throughout all the documents of the package, documents beyond non-light water there are statements that this guidance is reactors (non-LWRs). However, applicable to nonLight Water Reactors expansion of the guidance beyond (LWRs). However, all the guidance is non-LWRs at this time is premature.
technology-inclusive and is equally applicable to LWRs. ARCAP is supposed to be applicable The final ISG continues to note that for any technology (non-LWR and LWR), any the NRC is developing an optional licensing approach (LMP, classical, etc.), and performance-based, technology-any licensing path (CP, COL, DC etc.). inclusive regulatory framework for licensing nuclear power plants For the ARCAP guidance, industry specifically designated as 10 CFR Part 53, requested the NRC develop guidance applicable Licensing and Regulation of to both non-LWRs and LWR SMRs, and we Advanced Nuclear Reactors, (RIN were informed in various meetings that this 3150-AK31). It is envisioned that the would be the NRCs approach. While NEI 18- 10 CFR Part 53 guidance would be 04 and NEI 21-07 were developed specifically applicable to both LWR and non-for advanced non-LWRs, applicants with LWR LWRs. Should the 10 CFR Part 53 designs should also be able to use the Licensing rulemaking include requirements for Modernization Project (LMP) methodology if both LWR and non-LWRs the NRC they elect to do so (e.g., NEI 18-04 and NEI 21- staff envisions that the concepts found 07). It would be up to the applicants to justify in the ARCAP ISGs guidance would the use of the guidance documents and be expanded beyond non-LWRs. In associated regulatory guides. 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 General General Please provide a statement of what is expected The NRC staff disagrees with this 0074- DRAFT- for the CPA. comment.
0006-2 10
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document This guidance describes the advanced reactor As stated in the Applicability fire protection program as an operational section, this ISG is (only) applicable program. What is the NRC expecting to see, if to applicants submitting risk-anything, in regards to plant fire protection for informed, performance-based the Construction Permit Application (CPA)? applications for an OL under 10 CFR Part 50.
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 DG-1404, Chapters 3 through 7, and the ARCAP Roadmap document.
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 11
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document requirements with its CP application (in accordance with 10 CFR 50.31, Combining applications) or separately from the CP application.
No changes have been made to this ISG.
NRC-2022 NFPA 804 p. 5 No change required, just further engagements to At the present time, NRC has no plans 0074- DRAFT- explore the possibility of endorsing NFPA 804 to formally endorse NFPA 804 in the 0006-3 for advanced reactors. near term. Note that this ISG does state the following regarding this Is the NRC willing to consider endorsing NFPA NFPA standard: provides useful 804? 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 p. 6-11 Provide updated guidance or relaxation for fire The NRC staff disagrees with this 0074- DRAFT- brigades at advanced reactors that demonstrate a comment.
0006-4 fire cannot impact safe shutdown and cannot violate offsite dose releases in 50.34. This ISG references RG 1.189, which is a comprehensive fire protection The guidance that a plant should have a five- guidance document and identifies the man fire brigade is based on the design basis scope and depth of fire protection that fire causing a radioactive release to the public, the NRC staff would consider and the manual suppression from the fire acceptable for nuclear power plants.
brigade mitigates the consequences of the This ISG also refers to elements and design basis fire. The new ARCAP guidance concepts in NFPA 805, Performance-12
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document continues to mention fire brigade should be Based Standard for Fire Protection for addressed in the fire protection program. Light Water Reactor Electric Advanced reactors following the NEI 18-04 Generating Plants, 2001 Edition, as process may demonstrate the fire design basis well as the guidance in NFPA 804, hazard levels (DBHLs) do not cause a radiation Standard for Fire Protection for release to the public and environment that Advanced Light Water Reactor exceed the limits of 50.34. Therefore, is the Electric Generating Plants, that can NRC staff considering relaxing or rewording be used by non-LWR applicants to fire brigade requirements if manual suppression develop their fire protection programs.
is not required for nuclear safety, in order to The NRC staff has no near-term plans prevent exemption requests? Is the NRC to revise RG 1.189 to specifically considering adding to the guidance in RG 1.189 address advanced reactors beyond the or revising the guidance in RG 1.189 to relax references to these NFPA standards.
fire brigade requirements for advanced reactor technologies that do not require manual The fire protection program suppression? 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. It should justify exceptions to RG 1.189.
No changes have been made to this ISG.
NRC-2022 p. 6 in B.2.iii Replace as noted. The NRC staff disagrees with this 0074- DRAFT- comment.
0006-5 The document calls for identification of Authority Having Jurisdiction (AHJ). The term This ISG references RG 1.189, AHJ is specific to NFPA codes, and should not Regulatory Position C.1.1, and NFPA be used in this document as alternative codes 805, Section 3.2.2, which contain and standards could be used, meaning that this additional guidance on this topic. The term would not be relevant. A generic term such term Authority Having Jurisdiction as parties with responsibilities should be used is an industry standard term used in instead. these guidance documents. If an applicant chooses to deviate from this 13
Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document guidance or chooses to use alternate codes and standards, then the applicant should provide a basis in their application.
No changes have been made to this ISG.
NRC-2022 p. 8-9 Please consider including guidance related to The NRC staff disagrees with this 0074- DRAFT- these regulatory requirements, including the comment.
0006-6 kind of information NRC would be looking for to meet the intent of the regulations or in This ISG is applicable to non-LWRs exemption requests. (refer to the response to comment NRC-2022-0074- DRAFT-0006-1).
There are several fire protection related This ISG notes that elements and regulatory requirements that may be less concepts in standards developed for relevant and/or less important to smaller SMRs LWRs, such as NFPA 805, or microreactors. Such requirements include: Performance-Based Standard for Fire (1) Fire protection staff training and Protection for Light Water Reactor qualification requirements. Electric Generating Plants, 2001 (2) Manual fire fighting capabilities that do not Edition, as well as the guidance in rely on having a fire brigade. Having some RG 1.205, Risk-Informed, generic guidance related to how smaller SMRs Performance-Based Fire Protection or microreactors can meet the intent of these for Existing Light-Water Nuclear regulations, or the type of information NRC Power Plants, can be used by non-would be looking for in an exemption request to LWR applicants to develop their fire these requirements, would be helpful to protection programs (i.e., in lieu of the industry. Especially as demonstrating why some more prescriptive guidance in RG of these things may not be needed would 1.189). Given the wide range of require a developer/potential licensee to prove possible advanced reactor designs it is a negative. not practical for the NRC to provide more specific guidance for each reactor type.
No changes have been made to this ISG.
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document NRC-2022 p. 9 in B.11 Section should be removed. The NRC staff disagrees with this 0074- DRAFT- comment.
0006-7 The document describes a monitoring program similar to that performed for NFPA 805 and for This ISG provides guidance for maintenance rule. The purpose of such a applicants submitting a risk-informed, program is to ensure that the risk-informed performance-based application for an inputs to the fire protection program remain operating license (OL) under 10 CFR valid; such a monitoring program is not Part 50 or for a combined license applicable to a non-NFPA 805 plant. (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- General Please provide guidance for 10 CFR 50 Refer to the response to Comment 0075-DRAFT- Construction Permit applicants who are not NRC-2022-0074- DRAFT-0006-2.
0004-37 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?
NRC-2022- Page 5 of 13 No change suggested, however, X-energy is Refer to the response to Comment 0075-DRAFT- interested in further engagements to explore the NRC-2022-0074- DRAFT-0006-3.
0004-38 possibility of endorsing NFPA 804 for advanced reactors.
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Commenter Topics Section of Specific Comment NRC Staff Response Identifier Document Is the NRC considering endorsing NFPA 804?
NRC-2022- Pages 6-11 of Please provide updated guidance or relaxation Refer to the response to Comment 0075-DRAFT- 13 for fire brigades at advanced reactors that NRC-2022-0074- DRAFT-0006-4.
0004-39 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?
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