ML19338F354
| ML19338F354 | |
| Person / Time | |
|---|---|
| Issue date: | 07/09/1980 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| Shared Package | |
| ML19338F355 | List: |
| References | |
| FRN-45FR42431, RULE-PR-50 ACRS-1767, NUDOCS 8010200192 | |
| Download: ML19338F354 (8) | |
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m MINUTES OF THE ACRS SUBCOMMITTEE MEETING ON FIRE PROTECTION 9
WASHINGTON, D. C.
July 9, 1980 The ACRS Subcommittee on Fire Protection held a meeting on July 9,1980 in Room _ll30, 1717 H St., N.W. Washington, D.C.
The purpose of the meeting was to discuss the proposed 10 CFR 50 Rule on fire protection for nuclear plants operating prior to January 1,1979 (SECY-80-88). The proposed rule includes a new Section 50.48 and Appendix R to 10 CFR 50. The Subcommittee was pre-paring comments for the ACRS concerning the proposed rule.
Notice of this meeting was published in the Federal Register on Tuesday, June 24, 1980. A copy of this notice is included as Attachment A.
A list of attendees for this meeting is included as Attachment B, and the schedule for the meeting is included as Attachment C.
A complete set of handouts has been included in the ACRS files. There was one written statement from Duke Power Company (Attachment D) and two. requests for time to make oral statements from KMC Inc.
and Edison Electric Institute. The designated Federal Employee for this meeting was Peter Tam.
NRC Staff Views on the Propose'd Fire Protection Rule Mr.. R. Ferguson of the NRC Staff briefly described the history of the fire protection issue from the Browns Ferry fire until the writing of the proposed rule. The rule was written to address 17 issues where there was disagreement between the NRC. Staff and the licensees ~ on a minimum requirement to meet General Design Criteria 3.
The NRC. legal staff recommended that a rule be issued on the 17 items because too much time would be spent if individual orders were sent to each licensee on each issue.
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The central' issue in the decision to write a rule was the disagreement on the need for a 5-man fire brigade. Mr. Ferguson stated that only two utilities l
(Florida Power and Light and Northeast Utilities) have not yet comitted to having a 5-man fire brigade.
Mr. Ebersole stated.that a recent Sequoyah report leo him to believe that the fire protection crew was not trained to use discretion when using fire water
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hoses in certain vital plant areas.
He suggested that the NRC Staff investi-gate this. Mr. Benaroya of the NRC Staff stated that he was shocked that such.
a situation might exist at Sequoyah.
Mr. Bender ques,tioned whether some items in the proposed rule might force the NRC Staff to re-review all fire protection programs rather than just the ones in' dispute. Mr. Ferguson explained that some wording added by the Commissioner will require such a re-review. Mr; Benaroya stated that the NRC Sta f pla to I
ask that re-reviews be written out of the rule since, in the Staff's opinion, such re-reviews are not necessary or cost-effective.
I Dr. Siess asked if.the proposed rule would make BTP 9.5-1 a legally binding document :ince it is referenced in the text of the rule. Mr. Benaroya said that the -lawyers told him that by simply referencing the BTP that it is not a legally-binding part of the rule..Ftrther, hr. Benaroya said that the BTP l
could be changed by the NRC Staff at any time without going through rulemaking.
However, the legal staff has not given a formal written position on this question. Dr. Siess expressed concern.that licensees may be held accountable
- to the rule. Additionally, the BTP can be changed without ACRS or NRC Com-missioners' review.
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- Dr. Siess"q'u'estioned the 30-day comment period and the implementation sc.. dule in the rule.
Mr. Ferguson said that the NRC Staff recommended the 30-day comment period and that the implementation schedule was based on an original staff recum)endation.
However, the Commissioners removed the NRC Staff wording which would have allowed the implementation schedule to slip until the first refueling or maint? nance outage following the implementation dates. Mr. Ferguson stated that the NRf, Staff expected public comments on the implementation dates t,ecause they negate previous agreements between the NRC Staff and the licensees.
Mr. Bender asked if the requirements and implementation dates in the rule might be grounds to shut down a plant until the requirement was met.
Mr. Ferguson stated that he did not know.
However, Mr. M. Stearne of Wisconsin Public Ser-vice Corp. explained that the first I&E Inspector that finds a particular re-quirement of a rule, any rule, is not met by an operating plant, he is duty bound to enforce the rule.
Mr. Ebersole questioned the basis for the 50 foot separation criteria in the rule.
Mr. Benaroya said that it was based on a consultant's report and that he would be glad to send Mr. Ebersole a copy of the rerort.
K,MC Representatives Views on the Rule Mr. John Roncaioli of Northeast Utilities representing the KMC owners group of thirteen utilities made-a presentation concerning the rule. He described the history of the rule, the impact of the iule, and recommended changes 'to the rule. He expressed the opinion that the new rule achieves an extremely small benefit _ to safety which cannot be justified on a cost-benefit basis.
He stated that the rule would cost up to $50 million per operating plant for implementation of the changes.
The cost estimate did not include replacement power costs.
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s Edison Electric Int Representatives Views on the Rule Mr. Edward Sawyer of Yankee Atomic Co. represented the EEI group on fire pro-tection and he expres;ed great concern over the fact that the proposed rule abrogates the terms of SER's negotiated in good faith between the NRC Staff and licensees.
Further, he stated that the implementation dates in the rule are unrealistic.
Subcommittee Comments on the Rule Mr. Bender polled the Subcommittee members concerning their comments on the proposed rule. Mr. Ebersole said that he could not recommend the rule at present because it was an impasse breaker, and he wants to review the crucial issues of the' impasse to see if a rule is necessary. Mr. Ray said he could not recommend the rule because a chan.ge to the BTP should be sufficient for the problem at hand. Mr. Bender was also not in favor of the rule, and he suggested that more emphasis should be placed on having a good qualified fire protection team rather than getting a rule on fire protection out on the street. Mr. Bender said that the rule would be discussed at the 243rd (July 1980) ACRS meeting.
The meeting was adjourned at 4:34 P. M.
NOTE: For additional details, a complete transcript of the meeting is available in the NRC Public Document Room,1717 H St. N.W., Washington, D. C. 20555 or from Alderson Reporters, 300 7th St., S.W. Washington, D. C. (202-554-2345).
f rednal Register / Vd. 45. No.123 / Tuesd:y. June 60.19uu i m-
_ NUCLEAR REGULATORY
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June 30. Anyone wcnting the specific COMMISSIOi!
a enda should c:nt:ct the Commissen Applications for Uc:nses TO Export
__ Sign:d at Weshinton.D C. this teth day Since the Commission has concluded Nuclear Facilitics or Mater {sds CIICt.
oflane.19eo.
Adminisuntor. Pension ond We !!anr Benefit its hearings,no testimony willbe Pursuant to 10 CFR 110.70(b) **Public tasD t.nooff Receipt of an Application",
received at this meeting.
prgroms. 4obor. Management ScrvicesAdmLeisucron. U.S Department of Labor, Notice please t ke notice that tha NuclearReg Telephone inquiries and communications concerning th. meetint is fouowing applications for export ps rmsm ru.e us am eu ;
should be directed to: James hL Rosbrow. Executive Director. National,'" licenses. A copy of each application is a coag,m on file in the Nucleat Regulatory Commission on Unemployment Compensation.1815 N. Lynn Street.
Commission's Public Document Room NATIONAL. COMMISSION ON UNEMPl.OYMENT COMPENSATION Room 440. Rosslyn. Virginia 22209. (703) located at1717 H St N.W., Wash'ington.
D.C.
235-2782-N Signed at Washicgton D C. this 19th day Dated this day. June ta,1980, at Bethesda...
L.
Meetin9
%) Twenty.Seventhmeetingof theof June 1990.
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For the Nuclear Regulatory Commission..
National Commission on UnemploymentCompensation is scheduled to be held i James M.Rosbrow.
James R. Shea' 4-the Ravensworth WesiRoom of the unempicyment Compensation.
pff,ctof, ogjce of tntemationo/ Pagroms.
e-Arlington Hyatt.Roulyn. Virginia onune 28.29.3D 1980.The meeting will p oac.s-rw om su.aq sw.,o coot uso.rt.as egin at 9.00 AAf. on Saturday, June 28.
D&me est4 mete Ccuey W and conclude at 3:00PM on Monday.
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p p.e.e>nrere.m wsaeu.=t room 1167.1717.H St., NW.
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Duringtheinitialportionof the Washington. DC to discuss a proposed. e 1980 supeocoot new as
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fire protection rule for nuclear power Advisory Committee on Reactor meeting, the Sube,mmittee, along with Safeguards. Subcommittee on any of its consultants whc may be facilities operating prior to January 1.
present,will exchange preliminary 1979 (SECY-80-88). Notice of this Advanced Reactors; Meeting views regarding matters to be meeting was published June 20.
Advanced Reactors wiU hold a meeting considered during the balance of the In accordance with the procedures
%e ACRS Subcommittee on outlined in the Federal Register on October 1.1979. [44 FR 56408). oral or on July 9,1980 in room 1167.1717 H St
%e Subcommittee will then hear meeting.
written statements may be presented by NW. Washington, DC to continue its presentations by and hold discussions with representatives of the NRC Staff.members of the public, recordings will review of the NRC funding and p ogram be permitted only during those portions their consultants, and other interested am termination, as of the meeting when a transcript is being direction or e annual ACRS persons.Further information regarding topics kept, and quest!ons may be asked only appropriate, reports to NRC and Congress. Notice of by members of the Subcommittee,its to be discussed, whether the meeting this meeting was published June 20.
consultants, and Staff. Pe sons desiring has been cancelled or rescheduled, the In accordance with the procedures Chairman's ruling on requests for the to make oral statements should notify M
i outlined in the Federal Register on opportunity ?.n present oral statements the Desigaated Federal Employee as far
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October t.1979. (44 FR 56408), oral or and the time allotted therefor can be in advance as practicable so that written statements may be presented by i
l members of the ublic, recordings willobtained by a prepaid telephone call to appropriate arrangements can be made i
to allow the necessary time during the. m 3f during those portions the cognizant Designated Federal 1
a-be ermittedo e meeting when a transcript is being Employee, hir. Paul Boehnert (telephone I meeting for such statements..
kept, and questions may be asked only 202/634-3267) between 8:15 a.m. and He entire meeting willbe open to of 1
.s by members of the Subcommittee.itsconsultants. and Staff. Persons desiring Public attendance.He agenda for subject m 5:00 p.m EDT.
Dated: June 19.198o.
to make oral statements should notify be as follows:
Wednesday.fuly 9.1960.1:00p.m.
John C.Itoyle.
the Designated Federal Employee as far pgyg,,,, comm;gg,,, yanag,,,,g og;cer, untilthe conclusion of business.
i in advance as practicable so that Duringtheinitialportionof theittee, along with l
appropriate arrangements can be made
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~l to a!!ow the necessary time during the
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b meeting.the Su comm any ofits consultants who may be meeting for such statements..
- Advisory Committee on Reactor Present,will exchange preliminary We entire meeting will be open to views regarding matters to be Sateguards. Subcommittee on Fire n.
public attendance.ne agenda for subject meeting el.a Protection; Meeting be as follows:
ne ACRC Subcommittee on Fire
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Wednesdoy.fuly 9.1980. 8.3C o.m.
. Protection willhold a meeting on u y.
anti / the conclusion of business
[qpyroximotely U.07 noon).
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y-Fcdcral Regist:r / V:1. 45. I 1::3 / Tuesday, June 24, 1900 12432
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Building. Comm:nweilth and Walnut'.
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Duringtheinitialporti:ncf the
.on'sidered during the balance of the m:eting, the Subcommittic, clong with Streets, liarrisburg. Pennsylvenia 17128
- ne: ting.
any of its consultants who may be and the York Co!!cge of Pennsylvania.
C.
I l esentations by and hold discussions present, will exchange preliminary Country Club Road. York. Pennsylvania
'ne Subcommittee will then hear rith representatives of the NRC Staff, views regarding matters to be 17405. A copy will also be filed with the considered during the balsnee of the Secretary for the Commission's review S
. tacir consultants. and etber interested in accordance witp to CFR 2.206(c). As D
meeting.
De Subcommittee will then hear provided in 10 CFR 2.20G(c) this decision 1
persons.
m bu ther information regarding topics presentations by and hold discussions will become the final action of the
[ to be discussed. whether the meeting witn representatives of the NRC Staff.
Commission twenty days after issuance ac Dr 1 his been cancelled or rescheduled. the the Tennessee Valley Authority (TVA).
unless the Commission elects to review
{ Chairm:n's ruling on requests for the their consultants, and other interested the decision on its own motion within AC j cpportunity to present oralstatements that time' su i
Persons.
cnd the time allotted therefor can be Further information regarding topics Dared at Bethesda. Maryland. this 13th day g
c,bt:ined by a prepaid telephone call to to be discussed, whether the meeting the cognizant Designated Federal has been cancelled or rescheduled. the offune,1980.
ani Er-pl yer.Mr.PeterTam(telephone Chairman's ruling on requests for the For the Nuclear Regulatory Commission.
sur J
Em 202/634-1413) between 8.15 a.m. and opportunity to resent oral statements r2 son G. case.
500 p.m EDT.
h#fj, refi et a
Daudd eu.noa o ain d b a p pa d e honec to las C He e, the cognizant Designated Federal
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ma l AddsoryCommittee.ManagementOfficer.
Employee, Dr. Richard Savio (telephone snmo coce tsnaw og(
202/C34-32G7) between 8:15 a.m. aq Act fa tu swam m e-:Sm us **t 520 p.m EST or EDT.
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I have determined. In accordance with Subsection 10(d)of the Federal DEPARTMENT OF TRANSPORTATION stat 4
mai Advisory Committee on Reactor Advisory Committee Act, that it may be FederalRailroad Administration 3
(Put I
Ref.
Safego:rds, Subcommittee on the necessary la close some portions of this Sequoyah Nuclear Plant; Meeting meeting to protect proprietary Public Meeting To Out!!ne and Discues 1 Oct information.The authority for such Proposed Guidelines and Procedures g
na ACRS Subcommittee on the closure is Exemption (4) to the Sunshine Regarding Rock isfand Railroad and bon I
Sequoyah Nuclear Plant will hold a Act. 5 U.S.C. 552b(c)(4).
Employee Assistance Act and mietL.g on july 9.1980, in Room 1046.
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Mllwaukee Railroad Restructuring Act g
1717 !! St., NW Washington. DC to Dated: June sa. usa tview the Tennessee Valley Authority John C.Ho3 e.
On Wednesday. June 25,1980. at 10:00 1
re2 Advisory Committee. Management Officer.
a.m the FederalRailread 7
ivi thI ant.ho ce of this me ting as (nuk mm M s-u us ant Administration (FRA) will hold a published June 201980 namo o oc rswaw Wing 6 Room m of b Nassa p
In accordance with the procedures sur,,
outlined in the Federal Register on (Docket No. 50-321 Bdiding. 400 7th Street. Southwest,
, Bac!
Washington, D.C. to outline and discusa Oct:ber 1.1979. (44 FR 56408), cral or Metropolitan Edison Co.(Three MIIe the proposed guidelines and procedures
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written statements may be presented by Island Nuclear Station, Unit 2);
to be issued by the Department of J
members of the public. recording will issuance of Director's Decision Under Transportation (DOT). under which the be permitted only during those pcrtions to CFR 2.206 public may submit applications for ofm en of the meeting when a transcript is being On September 14.1979.a notice was dirrcted service under section 104 of the
,. that kept, and questions may be asked only published in the Federal Register that a RockIsland Railroad Transition and satis by members of the Subcommittee.its consultants. and Staff. Persons desiring petiton by the Anti. Nuclear Group Employee Assistance Act(Pub.L 96-bonc to make oral statements should notify Representing York (ANGRY) was being 254) and section 18 of the Milwaukee Met 4
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the Designated Federal Employee as far considered under to CFR 2.206.
Railroad Restructuring Act (45 U.S.C.
into in cdvance as practicable so that ANCRTs petition requested that the.
916). and the proposed criteria which the warc f
rppropriate arrangements can be made Commission prepare an environmental Department will use to evaluate those dutic to allow the necessary time during the impact statement concerning the venting ref'm c:eting for such statements.
of radioactive gases from the reactor applications.
bear The entire meeting will be open to buildng of the Three Mile Island Nuclear ne meeting is open to the public.
Ofi8h I public attendance except for those Station. Unit 2. Because this action will including interested states and as ar j sesslins during which the Subcommittee not cause any significant environmentalorganizations who are considering wher I finds it necessary to discuss propnetary impact.it has been determined not to applying for directed service under Pub.
auth<
inf;rmation.One or more closed prepare an environmentalImpact
- g.96-254.
of the sessiens may be necessary to discusa statement. Accordingly. ANGRTs Issued in Washington, D.C., on June 2o, is au t
the T suchinformation.(Sunshine Act petition is denied.
usa A copy of the formal decision denying MkhaelT.Haley cond Enmption 4.)To the extent practicable.
the petition is available for inspection in form i thesi closed sessions will be held so as to *ninimize inconvenience to members the Commission's Public Document Acting ChiefCounsel and of th2 publicin attendance.
Room at 1717 H Street NW ps ow. mms ra.o.m m est presc,
The agenda for subject meeting shall Washington, D.C. 20555 and in the local on m o coes es, ews Deci: l public document rocms at the State 1972. I l
be ce follows:
Wednesday. July 9. wao. 320 a.m.
l.ibtery of Pennsylvan!e (Government Th l provi smtil the conclusion ofbusiness.
Publications Section). Education D**D
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ATTACHMENT B MINUTES OF THE ACRS' SUBCOMMITTEE' MEETING ON FIRE PROTECTION WASHINGTON, D. C.
July 9,1980
-ATTENDEE LIST-ACRS NRC STAFF M. Bender, Chairman :
J. Ray R. Ferguson J. Ebersole D. Notley C. Siess-(Part time)
V. Benaroya P. Tam, Designated Federal Employee T. Wambach G. Young, AGRS Staff G. Harrison J. McKinley, (Part time) ACRS Staff S. Hudson P.~ Sears Edison Electric Institute R. Anand J. Evans Consolidated Edison Co. of N.Y.
P. Kelsey D. Rosh Yankee Atomic Co.
KMC,'Inc.
E. Sawyer R. Schaffstall
. Duke Power Co.
Arkansas Power & Light Co.
J. Hendricks-D. James American Nuclear-Insurers Wisconsin Public Service P. Giaccaglia M. Stern Northeast-Nuclear Co.
EPRJ J. Summa R. Leyse Northeast Utilities Boston Edison Co.
'f.
Venkatonaman -
J. Roncaioli A. Capato
' Baltimore Gas &~ Electric Co.
Debevoise & Liberman K. Armstrong G.'Powell L. Wenger jDoub & Muntzing J. Shoemaker Florida Power '& Light Co.
Nixon, Hargrave, et. al.
~T.'Grozan.
J. Balcerak
.G. Patrissi H. Paduano,- Jr.
ATTACHMENT C l
. REVISED 7/3/80L ACRS SUBCOMMITTEE MEETlHG ON FIRE.P.10TECTION.
. JULY 9,'1980 WASHINGTON, DC ROOM 1167 SCHEDULE APPR0XIt%TE TIME 1:00 p.m.
Opening Remarks, M. Bencer, Chainnan 1:15 p.m.
NRC Staff Presentation and Discussion Background for Proposed Rule, Comparison with BTP 9.5-1 Guidelines, and Impact of Rule en Present SER Commitments (R. Ferguson - 15 mins.)
Discussion (1 hr.)
2:30 p.m.
Public and Licensee Comments
(
KMC Representative (15 mins.)
}'
(Mr. ~ John Roncaioli, Northeast Utilities)
EEI Representative. (10 mins.)
(Mr.Ed' Sawyer,YankeeAtomic)
- Discussion (1 hr.)
4:00 p.m.
ACRS Discussion Session 5:00 p.m.
Adjournment I
k ATiecHMENT k
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