ML19323B387
| ML19323B387 | |
| Person / Time | |
|---|---|
| Issue date: | 10/09/1979 |
| From: | Harold Denton Office of Nuclear Reactor Regulation |
| To: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| Shared Package | |
| ML19323B372 | List: |
| References | |
| SECY-80-088, SECY-80-88, NUDOCS 8005120309 | |
| Download: ML19323B387 (4) | |
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f.INITED STATES 8005120 ]QQ NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D. C. 20555 OCT 9 1979 MEMORANDUM FOR:
R. Minogue, Director, Office of Standards Development FROM:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation
SUBJECT:
RULE MAKING REQUEST - FIVE MAN FIRE BRIGADE FOR OPERATING REACTORS In the NRC Staff P9 port on the Union of Concerned Scientists' Petition for Emergency and Remeo al Action dated December 15, 1977, we stated to the Commission that fire brigade strength and training was part of our basis for allowing continued operation of nuclear plants while modifications to the fire protection programs are being implemented.
In late 1978, we completed our evaluations of the fire brigade strength and training at all operating plants and concluded that our interim position, i.e., a minimum fire brigade shift size of five persons, was both necessary and adequate for all plants.
At that time, there were about 20 plants which did not meet the staff position and which indicated that they would not meet it unless they received our detailed evaluation. A few indicated that they would have to be Ordered to do so. We initiated letters to those licensees informing i
them of our position and indicating that we were considering issuing Show Cause Orders (10 CFR 2.202) if they did not comit to meet our fire brigade shift size requirements.
During our discussions requiring the use of Show Cause Orders, OELD advised us that they believe that such an approach is undesirable. They believe that this approach could expose the NRC to several separate adjudicatory hearings and that this issue is applicable to all plants rather than being plant specific. They expressed the belief that a rule on this subject could be promulgated within a few months.
In view of this advice, on August 9, 1979, NRR requested SD to expeditiously promulgate such a rule. By memo dated August 20, 1979, SD indicated that such a rule could not be issued for coment until late February 1980.
Subsequently, NRR indicated that we would like to implement this rule within 90 days; however, by memo dated September 5, 1979, SD indicated that their "most optimistic" schedule would have the proposed rule published for public coment and for interim guidance by the middle of December 1979.
Enclosure "F"
OCT S we It appears to us that it is desirable to resolve the fire brigade shift size issue, and perhaps several other issues, by rulemaking.
- However, to be useful the procedure should take no longer than a single Show Cause Order proceeding. NRR, SD and OELD representatives are meeting to establish whether additional requirements should be included.
During such meetings, OELD has advised that publishing the rule for interim guidance will have no practical value in resolving these issues. We need an effective rule.
Therefore, we request that SD give consideration of having ACRS review this rule concurrent with the NRC review or during the public coment period and having a review group formed which represents the cognizant offices.
In this way perhaps the time required should be significantly reduced.
The approved Task Initiation Form and the Network are enclosed.
NRR personnel will support the shortest schedule you can develop. As you are aware, the Commission plans such an expedited schedule for Appendix E emergency planning changes.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation
Contact:
R. Ferguson X-27096 cc:
E. Case E. Sylvester D. Eisenhut C. Heit F. Schroeder G. Arlotto B. Grimes W. Morrison R. Vollmer J. Norberg W. Gamill D. Notley V. Moore D. Skovholt G. Lainas S. Varga V. Benaroya A. Schwencer D. Ziemann T. Ippolito T. Wambach R. Reid R. Ferguso '
Enclosure "F"
NRC CONSIDERS CHANGES TO REGULATIONS ON FIRE PROTECTION REQUIREMENTS FOR NUCLEAR POWER PLANTS The Nuclear Regulatory Commission is considering amending its regulations to strengthen fire protection requirements for operating nuclear power plants.
The amendments would reflect the upgraded minimum level of fire protection required for operating plants as a result of the NRC's evaluation of the March 22, 1975, fire at the Tennessee Valley Authority's Browns Ferry Nuclear Power Plant near Decatur, Alabama.
This fire--the worst to date in an operat-ing commercial nuclear power plant--was eventually controlled, there was no release of radioactive material to the environment and the reactor was safely shut down.
However, many of the systems relied on for shutdown under normal and emergency conditions were not available because the fire caused extensive damage to the electrical cables controlling backup safety systems.
NRC Branch Technical Positions issued in 1976 provided a range of alterna-tives that would, in the NRC staff's opinion, provide an adequate minimum level of fire protection for nuclear power plants.
Most licensees have accepted the majority of the staff's positions.
However, several disagreements exist between i
the staff and licensees on interpretation of these guidelines.
Consequently, the Commission is considering amending its regulations to j
state definitively what the minimum fire protection requirements are in each of these contested areas of concern.
The proposed amendments would describe the general requirements for an acceptable fire protection program and set out specific requirements in 17 areas, as contained in a Federal Register notice published on 1
Enclosure "H" 1
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The specific requirements include:
1)
Two fresh water supplies capable of supplying the maximum expected water demands for a period of two hours of fire fighting; 2)
Special protective features (such as physical separation and partial fire barriers) for electrical cables or equipment relating to backup safety systems important to achieving safe shutdown of the reactor, and 3)
A fire brigade consisting of at least five persons on each shift at the plant who are trained and equipped for manual fire fighting.
Interested persons are invited to submit written comments on the pro-posed amendments, which are to Part 50 of the Commission's regulations, to the Secretary, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Attention:
Docketing and Service Branch, by (30 days after publication in the Federal Register).
Copies of the NRC Branch Technical Positions are available from David P.
Notley, Office of Standards Development, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, telephone: 301-443-5921.
2 Enclosure "H"
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UNITED STATES NUCLEAR REGULATORY COMMISSION y i)
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WASHINGTON, D. C. 20555 3.g' 2
. c gv+....f AUG 9 1979 MEMORANDUM FOR:
G. Arlotto, Director, Division of Engineering Standards FROM:
D. Eisenhut, Acting Director Division of Operating Reactors
SUBJECT:
RULEMAKING REQUEST - FIVE MAN FIRE BRIGADE FOR OPERATING REACTORS During our evaluation of fire protection programs at operating plants and on the advice of our fire fighting consultants, we have concluded that the minimum fire brigade shift size at all operating reactor sites should consist of five trained members.
This position is an NRR position and carries the concurrence of other effected Divisions in NRR.
Further, we have established a minimum acceptable level of fire brigade training in cases where licensee's do not train all members in conformance to staff guidelines. We have enclosed our evaluation to support these conclusions.
We request that you t
i initiate actions to expeditiously develop an amendment to the regulations which will state this requirement for all operating plant sites. We are available to consult with, and otherwise assist your staff as you feel necessary.
The majority of licensees of operating reactors have committed to provide a trained five man fire brigade, however, there are a number who have not made such a commitment.
OELD has advised me that a rulemaking procedure is the moit appropriate method to resolve this issue.
Licensees have been advised that this procedure is being initiated.
We, therefore, request that you proceed on the most expeditious course possible so that we may resolve the matter of fire brigade size and training on all operating reactors as we believe this is a rather urgently needed action.
Would you please advise us of your schedule for proceeding with this rulemaking so that we can decide whether another ourse of action, e.g., Orders is warranted.
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1 DUPLICATE DOCUMENT
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.l UNITED STATES g
NUC1. EAR REGULATORY COMMISSION i
r,, 4 WASHINGTON. D. C. 20555 August 17, 1979 Docket No. 50-305 l
Mr. Eugene R. Mathews, Vice President Power Supply and Engineering Wisconsin Public Service Corport'. ion Post Office Box 1200 Green Bay, Wisconsin 54305
Dear Mr. Mathews:
In May 1976, we issued guidelines reflecting the NRC's policy regarding the implementation of General Design Criterion 3 - Fire Protection.
Since that time, you have performed a fire hazards analysis for your facility and have compared its fire protection program with the NRC guidelines.
In late 1976, we set October 1920 as the date for completing the implementation of all modifications associated with this program.
This implementation schedule recognized that such modifications should be completed as soon as practical, with due consideration of the nature of the modifications.
For example, minor modifications, adoption of
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administrative controls and additional portable equipmeliFwould be completed w' thin six months; however, major modifications would require a year or more to complete and some modifications would be coordinated with refueling outages.
By their Memorandum and Order in the matter of the Union of Concerned Scientists' Petition for Emergency and Remedial Action, dated April 13, 1978, the Commission directed the staff to use their best efforts to maintain this schedule, and also directed that the Commission be advised 3
if any slippage is anticipated, along with suggested corrective actions.
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We urge you to apply your best efforts to maintain your schedules for
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completion of all of the fire protection modifications at your facility and to submit, on an expedited basis, any inforTnation that is still
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outstanding with regard to open items and required design details.
j L/ a s Sincerely,
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Darrell G. Eisenhut, Actine Cirector Division of Operating Reactors Office of Nuclear Reactor Reculation cc:
See next page Enclosure G