ML19295F842
| ML19295F842 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1980 |
| From: | Notley D NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML19295E769 | List: |
| References | |
| FOIA-81-80, TASK-EM-915-1, TASK-OS NUDOCS 8012170221 | |
| Download: ML19295F842 (6) | |
Text
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.TtCo": dot FCR:
Steve Scott, Chief, Dccument Manageaent Branch, TIDC FRG1:
David P. Notley, EMSS
SUBJECT:
JUSTIFICATICri Ali/1YSIS FOR REPCRTIhG REQUIRE 4EhTS IN APPENDIX R TO 10 CFR PART 50 Attached is a ecoy of the Recert Justificaticn Analysis for Ap;:endix R -
Fire Protaction Fregram for Nuclear Power Facilities Cperating Price to January 1, 1973.
Please arrange fcr appropriate SAC clearanca.
Original 31 FM 27 D.P.SoGe7 David P. Notley Fire Protection Engineer Engineering "ethodology Standards Branch Office of Standards Development
Enclosure:
Repcrt Justification Analysis bcc:
- 0.. Smith G. Arlotto W. "orrisen J. Ncrberg D. Notley DISTRIEUT!CN CENTAAL FILE SD RD SD RF E4SB SUBJ EMSB READ E1SB C
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_AttacFrent JUSTIFICATICN At:ALYSIS FOR E0 REPORTING REQUIRE"ENTS CCNTAINED IN APPEt. DIX R TO 10 CFR PART 50 Appendix R - Fire Protection Progra,n fo'r "oclear Pc,er Facilities Cperating Prior to January 1,1979 - rakes requircments of certain itars of fire protec-tien guid3nce that h3ve been used by the staf f since the Erc. ns Farry fire of
- arch 22, 1975, to avaluate the adequacy of fire protection programs at cperat-ing nuclear pr..er plants.
The notice of prcpcsed rule.aking in.iting public ccr ents was published in the Federil 3;gister (45 FR 35032) on "3y 29, IF30, allcuing 30 days for public ccaments.
Fifty-one cc: ent letters (50 frca irdus-try) '..ere received regarding the proposed amend:ents.
The letters contained numerous specific cca ents, rest of them pertaining to the individual require-
. rents in the proposed Appendix R.
None of the 50 industry letters contained any adverse corcents relative to these reporting requirements.
There..ere, however, three substantive cer ents common to many of the cor: enters that can be su :arized as folicws:
1.
!iost co,T. renters stated that the 30-day comment period was too short to permit adequate detailed response and that the comment period should be extended.
2.
Most co. :anters stated that the provision of the proposed rule to require backfitting of all the requirei.ents of the prcpesed Appen-dix R to all operating plants was both unnecessary and unjustified.
They added that most operating plants have already corplied with 1
Enclosure I
st 3f f fir e prot &ticn ;::cc ~ Matiens in " g d 3;th" ud !
,2 ali c idy ccmT,itted to or cc.:pleted odi ficaticns accept ible to e
- staff, 3.
!'ost ccr, enters stated that they could not meet the irplementation schedule centaired in the propose rule.
Tha first of those three cc:T.ents was rejected and the public ccr ent period
'as not exteN ad.
The seccad and third issues were adopted in part sad neces-sary 7 dificatiens made in the final rule.
With respect to the 30-day public ccTTent period, note that the rule is based on fire protection guidelines which the f.RC has been developing since 1975.
The f.RC staff has evaluated each licensce's fire protection program against these guidelines during the course of our fire protection reviews conducted over the past four years.
Licensees have discussed with the staff in detail the results of these fire protection reviews and have complete understanding of there !!RC guidelines.
Therefore, the Commission believes that a 30-day public cer.ent period was adequate.
With respect to the provision for backfitting the requirements of Appendix R to all plants, only three of the 15 specific requirements will be imposed on all cperating plants regardless of prior ccImitments to and approval by the staff of specific fire protection nodifications.
In each case, heaever, the Comnission has advised the licensees that careful consideration will be given to requests for exemption if they furnish substantial technical justification 2
Enclosure I
1.
" 4ct',;n III.I.3.d.
At 3 s tar intervais, a rir d ly se -ct~d inc.cunced drill shall be critigwed by qualified individu11s independent of the licensce's staff.
A cepy of the written report frca such individuals shall be available for NRC review."
'le esticate that total time required by such qualified individuals to participite in planning, witnessing, critiquing and preparing a written report of such drills should not exccad 24 man-hcurs.
This esticate d:es not include travel time or overhead time involved by the licensee or the other ceganizations in producing the r? port.
2.
"Section III.I.4.
Individual records of training provided to each fire brigsde macber, including drill critiques, shall be maintained for at least 3 years to ensure that each member receives training in all parts of the training program.
These records of training shall be available for NRC review.
Retraining or broadened train-ing for fire fighting within buildings shall be scheduled for all those brigade members whose performance records shcw deficiencies."
We estimate that most plants will train about 40 persons for fire brigade responsibilities.
The licensee would likely keep records of drills and training conducted so as to determine the effective-ness of the program from the perspective of costs incurred vs.
learned capabilities of the individual members and fire brigade operating as teams.
Such record keeping would be independent of any requirements by NRC, and would be a small percentage of costs 4
Enclosure I
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v i r ? d t o t '.e a f f a r t s r ' p i t e d f x p h.a i n g, ad,inistering,
.2.d evaluating th2 training ind drill sessions.
The a.iditicnal i pict of this requirem20t on the licensee will be minimal since t!.e require 2nt is cnly to hire the records avail 3ble fcr eximination by NRC for 3 years; the recceds will not have to be processed in any p articul ar.3y or sut :.itted to NRC.
- 'e estirate that a maxi
_m of 3 in-hours per bri 32de stter per year will be required to d3seicp and.aintain their it, divi > nl training records.
Thus, for a 40-m :ber fire brigade,. e esti-rate approxinately 120 man-hours par year will be required to develop and,aintain these records.
These tv.c requirements will af fect only those nuclear po. er plants that. sere licensed to operate prior to Janusry 1, 1979, and that have these requirements as contested issues in their safety evaluation reports.
40st plants have already ccamitted to these reporting require. Tents in their approved fire pro-tection programs.
Since the entire Section III.I " Fire Brigade Training,"
of Appendix R constitutes an open issue at only 10 plants, this is the maximum nu.'ber of plants that could be af fected.
No special requirements for format or form are being imposed with this' rule.
Each licensee is free to d2velop the method and forms that best suit its individual operations.
5 Encicsure I sp