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Alternate Fire Protection Rule
Quick Facts
Overview
Frequently Asked Questions
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Frequently Asked Questions About the Alternate Fire Protection Rule

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Index to all Frequently Asked Question Pages

Could the adoption of NFPA 805 impact public health and safety?

The 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.  During the past two decades, the U.S. Nuclear Regulatory Commission (NRC) has recognized that risk assessment science has evolved to the point that it can be increasingly used as a tool in better regulatory decisionmaking to enhance nuclear safety while maintaining safety margin and defense-in-depth.

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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.

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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 deterministic approach, fire protection requirements are prescriptive and are based on accepted national standards and established regulatory requirements.  Fire protection requirements provide an adequate level of protection from potential hazards, as well as protection for systems, structures and components that provide vital functions with respect to nuclear safety.

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.

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What incentive do licensees have to adopt NFPA 805?

National Fire Protection Association (NFPA) Standard 805, “Performance-Based Standard for Fire Protection for Light-Water Reactor Electric Generating Plants” (NFPA 805), should reduce the need for license exemptions and amendments, thereby reducing unnecessary regulatory burden associated with the current deterministic approach.  NFPA 805 will also enhance safety by using risk-informed, performance-based fire protection methods in the fire protection programs.

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How does a licensee transition to NFPA 805?

Transition to an NFPA 805 licensing basis is voluntary.  Once the decision to implement transition has been made, a licensee will submit a letter of intent (LOI) to the staff outlining a transition plan and schedule.  The LOI should include a plan and schedule for a self-assessment period and a schedule for 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 non-compliances with 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 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 — NEI 04-02, “Guidance for Implementing a Risk-Informed, Performance-Based Fire Protection Program under 10 CFR 50.48(c)” — which the NRC has endorsed (with additional guidance) in Regulatory Guide 1.205, “Risk-Informed, Performance-Based Fire Protection for Existing Light-Water Nuclear Power Plants.”  

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How does the NRC determine that a licensee can transition to NFPA 805?

The NRC reviews the transition plan and schedules contained in the LOI.  If the NRC approves the plan and schedules, the licensee then submits to the NRC an LAR that requests use of an NFPA 805 licensing basis.  The staff reviews the licensee’s LAR and writes a safety evaluation report approving or disapproving the license amendment.  Starting with the submittal of the LOI, throughout the transition period, and during the NRC review of the LAR, the NRC grants the licensee enforcement discretion, which means that the licensee will not receive violations for those noncompliances found during the transition that are not of high safety-significance (normally categorized as RED findings in the Reactor Oversight Process).

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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).

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How are plants inspected during the transition?

The NRC continues its regularly scheduled inspections as defined in the ROP.

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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.

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Thursday, July 17, 2008