Frequently Asked Questions About the Alternate Fire Protection Rule [10 CFR 50.48(c)]
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Could the adoption of NFPA 805 impact public health and safety?
It can absolutely improve an already safe operating environment. Fire risk analysis and fire science has evolved in the last 2 decades and we now know how to make already safe plants safer by using what we learned. 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?
Absolutely. What we have now is safe but the risk-informed method will take safety to a higher level. 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.
What incentive do licensees have to adopt NFPA 805?
It will make the plants safer and at the same time reduce undue regulatory burden. NFPA 805 will also enhance safety by using risk-informed, performance-based fire protection methods in the fire protection programs.
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.
Recently, the NRC updated the triennial fire protection inspection procedures to address the increased scope of fire protection program elements that deal with Explosions and Large Fires (i. e. security-related fires). Will the inspection procedures be updated to address other changes in fire protection program elements, like those for plants that transition to NFPA 805?
Fire protection inspections remain a priority for the NRC and the fire protection inspection procedures have been updated for NFPA 805 plants.