Frequently Asked Questions About Risk-Informed, Performance-Based Fire Protection [10 CFR 50.48(c)]
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Could the adoption of NFPA 805 impact public health and safety?
NFPA 805 allows licensees to use risk informed approaches to fire safety, and either improve fire safety for specific fire prone areas, and/or address regulatory challenging issues in a different approved manner than their old fire protection licensing bases. Early fire protection regulations were developed without the benefit of quantitative estimates of risk and before recent advances in performance-based methods such as fire modeling.
What is probabilistic risk assessment?
Probabilistic risk assessment (PRA) is a mature technology that can provide a quantitative assessment of the risk from accidents in nuclear power plants. The NRC and the nuclear industry use PRA as one way to evaluate overall risk.
Does a risk-informed, performance-based fire protection program provide an acceptable level of protection of public health and safety compared to deterministic requirements?
In a risk-informed approach, risk insights are considered with other factors to establish requirements that better focus licensee and regulatory attention on design and operational issues according to their importance to public health and safety.
In a deterministic approach, fire protection requirements are based on accepted national standards and established prescriptive regulatory requirements.
Both approaches are considered acceptable, provided a licensee complies appropriately to the applicable requirements.
What incentive do licensees have to adopt NFPA 805?
Where licensees experienced difficulties in meeting deterministic fire protection requirements, or where licensees voluntarily determined that a risk informed approach to fire protection licensing bases provided better risk analysis based consideration to fire protection licensing bases, the NRC provided enforcement discretion for implementation of NFPA 805. Generally, risk informed/performance based approaches to fire protection programs provide better focus to specific analysis and resolution of design and operational issues in accordance to their importance to public health and safety.
How does a licensee transition to NFPA 805?
The transition is voluntary. Once the decision has been made to transition a licensee will submit a letter of intent (LOI) to the staff outlining a transition plan and a schedule including a schedule for a self-assessment period and submittal of a license amendment request (LAR). During the self-assessment period, a licensee is expected to evaluate its existing fire protection program, review fire protection exemptions in effect at the time of the application to determine continued validity, and resolve potential non-compliances with existing prescriptive fire protection regulatory requirements by either performing physical plant modifications that meet the regulatory requirements or perform engineering analyses that verify that the risk of the potential non-conformance is acceptably low. The NRC allows a licensee up to 3 years after the submittal of the LOI to perform its self-assessment. In order to assist licensees in performing their self-assessments, the Nuclear Energy Institute (NEI) developed a guidance document which the NRC has endorsed with additional guidance.
How does the NRC determine that a licensee can transition to NFPA 805?
The NRC reviews the transition plan and schedules. If the plans and schedules are approved, the licensee then submits a license amendment request (LAR) that requests use of an NFPA 805 licensing basis. The staff reviews the LAR and writes a safety evaluation report approving or disapproving the license amendment. Throughout the transition period, the NRC grants the licensee enforcement discretion, which means that the licensee will not receive violations for those potential noncompliances found during the transition that are not of high safety-significance.
How long does it take to transition to NFPA 805?
The NRC allows a licensee up to 3 years to submit the LAR to transition to NFPA 805. During the transition and subsequent LAR review period, the NRC continues to monitor individual licensee actions to address plant-specific fire protection technical issues through its Reactor Oversight Process (ROP).
How are plants inspected during the transition?
The NRC continues its regularly scheduled inspections as defined in the ROP.
How are plants inspected after the transition?
After the transition, the regional inspectors perform the fire protection inspections on the schedule outlined in the ROP. The inspection procedure will be amended to reflect specific inspection modules applying only to plants that have transitioned to NFPA 805.