ML14325A144
| ML14325A144 | |
| Person / Time | |
|---|---|
| Issue date: | 12/08/2014 |
| From: | Gitter J G NRC/NRR/DRA |
| To: | Thomas B E NRC/RES/DE |
| Daniel Frumkin, NRR/DRA | |
| Shared Package | |
| ML14336A663` | List: |
| References | |
| RG-1.189, TAC MF5285, Y020140254 | |
| Download: ML14325A144 (4) | |
Text
December 8, 2014
MEMORANDUM TO: Brian E. Thomas, Director Division of Engineering Office of Nuclear Regulatory Research FROM: Joseph G. Giitter, Director /RA/ Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT: RESULTS OF PERIODIC REVIEW OF REGULATORY GUIDE 1.189
This memorandum documents the US Nuclear Regulatory Commission (NRC) periodic review of Regulatory Guide (RG) 1.189, "Fire Protection for Nuclear Power Plants," most recently published in October 200 The RG provides fire protection guidance that identifies the scope and depth of fire protection that the staff would consider as one acceptable way for nuclear power plants to meet fire protection regulation As discussed in Management Directive 6.6, "Regulatory Guides," the NRC staff reviews RGs approximately every 5 years to ensure that the RGs continue to provide useful guidanc Documentation of the NRC staff review is enclose Based on the results of the periodic review, the staff concludes that no changes to RG 1.189 are warranted at this tim However, the staff identified some technical and regulatory issues that are currently under development and are expected to be fully developed during 201 The NRC staff plans to revisit the updating of RG 1.189 in the fourth quarter of calendar year 201
Enclosure:
As stated CONTACT: Daniel M. Frumkin, NRR/DRA (301) 415-2280 December 8, 2014 MEMORANDUM TO: Brian E. Thomas, Director Division of Engineering Office of Nuclear Regulatory Research FROM: Joseph G. Giitter, Director /RA/ Division of Risk Assessment Office of Nuclear Reactor Regulation
SUBJECT: RESULTS OF PERIODIC REVIEW OF REGULATORY GUIDE 1.189
This memorandum documents the US Nuclear Regulatory Commission (NRC) periodic review of Regulatory Guide (RG) 1.189, "Fire Protection for Nuclear Power Plants," most recently published in October 200 The RG provides fire protection guidance that identifies the scope and depth of fire protection that the staff would consider as one acceptable way for nuclear power plants to meet fire protection regulation As discussed in Management Directive 6.6, "Regulatory Guides," the NRC staff reviews RGs approximately every 5 years to ensure that the RGs continue to provide useful guidanc Documentation of the NRC staff review is enclose Based on the results of the periodic review, the staff concludes that no changes to RG 1.189 are warranted at this tim However, the staff identified some technical and regulatory issues that are currently under development and are expected to be fully developed during 201 The NRC staff plans to revisit the updating of RG 1.189 in the fourth quarter of calendar year 201
Enclosure:
As stated CONTACT: Daniel M. Frumkin, NRR/DRA (301) 415-2280
Distribution: Yellow Ticket: Y020140254 BDean JUhle BHolian NRRMailroom HCruz KRichards ADAMS Accession No: ML14336A663- pkg; ML14325A144-Memo Response OFFICE NRR/DRA/AFPB BC: NRR/DRA/AFPB DD: NRR/DRA NAME DFrumkin AKlein JGiitter DATE 12/03/2014 12/03/2014 12/08/2014 OFFICIAL RECORD COPY Regulatory Guide Periodic Review Regulatory Guide Number: 1.189 Title: Fire Protection for Nuclear Power Plants Office/division/branch: NRR/DRA/AFPB Technical Lead: Daniel M. Frumkin Recommended Staff Action: Reviewed, issues identified for future consideratio . What are the known technical or regulatory issues with the current version of the Regulatory Guide (RG)? Regulatory Guide 1.189, Revision 2 (Rev. 2), "Fire Protection for Nuclear Power Plants," most recently published in October 2009, provides fire protection guidance that identifies the scope and depth of fire protection that the staff would consider as one acceptable way for nuclear power plants to meet fire protection regulation Since 2009 licensees have used the information in RG 1.189 extensively and a number of enhancements have been identifie These enhancements include incorporating staff information that has been discussed in memoranda. One example is the application of the performance goals of 10 CFR 50, Appendix R, Section III.L, see February 10, 2005, memorandum, Agencywide Documents and Management System (ADAMS) Accession No. ML05033041 Another example relates to what systems are considered acceptable as 'redundant' shutdown systems under 10 CFR 50, Appendix R, see November 28, 2000, memorandum, ADAMS Accession No. ML003772256 and December 20, 2000, memorandum, ADAMS Accession No. ML00377682 In addition, information released as part of NUREG/CR-7150, "Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE-FIRE)," is considered applicable to this RG and will be considered for inclusio Some information from NUREG/CR-7150, Volume 3, is not expected to be available until the spring of 2015. Portions of RG 1.189 are based on Nuclear Energy Institute (NEI) 00-01, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," Revision 2 that was last published in 2009. Based on discussions with NEI staff, the next revision of NEI 00-01 will include information from NUREG/CR-7150, Volume While the staff has identified issues that would merit the revision of RG 1.189, Rev. 2, those issues have not related to any currently identified safety concern . What is the impact on internal and external stakeholders of not updating the RG for the known issues, in terms of anticipated numbers of licensing and inspection activities over the next several years? There are no identified safety concerns if the regulatory guide is not update However, there are consistency issues that merit resolving as discussed abov Not having a single reference for fire protection guidance, for example relying on memoranda as described in Question 1, complicates discussions between the NRC inspectors and staff, and licensees regarding the current guidanc Although, improving this consistency would be advantageous there is minimal impact on internal or external stakeholder The benefit of updating would be regulatory endorsement of information included in NEI 00-01, to be developed based on NUREG/CR-7150, but that information is not yet availabl . What is an estimate of the level of effort needed to address identified issues in terms of full-time equivalent (FTE) and contractor resources? NRC staff requires approximately 1-2 FTE to compile the information and develop the changes to the R This activity will require coordination with other NRC Offices (NRR, Office of New Reactors, and Office of Nuclear Regulatory Research), and the NRC Regional Office NRC staff would also need to coordinate with industry stakeholders as part of the development of the next revision of NEI 00-0 The organizations that will be involved are cognizant of the need for updating this RG. Contractor support may be utilized in lieu of staff resources if dictated by resource constraints 4. Based on the answers to the questions above, what is the staff action for this guide (Reviewed with no issues identified, Reviewed with issues identified for future consideration, Revise, or Withdraw)? Reviewed, issues identified for future consideratio . Provide a conceptual plan and timeframe to address the issues identified during the revie A revision to RG 1.189 would be based on the consistency changes above and also the revision based on the NUREG/CR-715 The NUREG is expected to be updated in the fall of 2015, and the expected delivery of a revision to NEI 00-01, is expected to be released later that yea Therefore, the staff plans to revisit the review of RG 1.189 in the fourth calendar quarter of 2015. If both the NUREG and revision of NEI 00-01 are complete, the staff would begin a revision at that tim Such a schedule would result in the development of a draft guide by the fourth quarter of calendar year (CY) 2016, and issue it public comment by the fourth quarter of CY 201 NOTE: This review was conducted in December 2014 and reflects the staff's plans as of that dat These plans are tentative and are subject to change as appropriate.