ML20133E702
| ML20133E702 | |
| Person / Time | |
|---|---|
| Issue date: | 08/20/1985 |
| From: | Stello V Committee To Review Generic Requirements |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| References | |
| REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR NUDOCS 8510090504 | |
| Download: ML20133E702 (4) | |
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UNITED STATES l'
/,i NUCLEAR REGULATORY COMMISSION p
WASHINGTON. D. C. 20555 AUG 2 01985 e
MEMORANDUM FOR:
William J. Dircks Executive Director for Operations FROM:
Victor Stello, Jr., Chairman Comittee to Review Generic Requirements
SUBJECT:
MINUTES OF CRGR MEETING NUMBER 78 The Comittee to Review Generic Reouirements (CRGR) met on Monday, July 8,1985 from 12-6 p.m.
A list of attendees for this meeting is enclosed (Enclosure 1).
1.
T. Speis /NRR) presented for CRGR review the proposed resolution of A-46,
" Seismic Qualification of Equipment in Operating Plants. Enclosure 2 sumariz's this matter (Category 2 Item).
2.
B. John, ton (NRR) briefed the CRGR concerning updated recomendations on Fire Protection Policy and Program actions. Enclosure 3 sumarizes this matter (Category 2 item).
3.
F. Congel (NRR) briefed the CRGR concerning SRP 12.6 series pertaining to expansion of spent fuel storage pools. Enclosure 4 sumarizes this matter (Category 2 item).
4 C. Serpan (RES) briefed the CRGR concerning agency activities in the development of NDE qualification and performance demonstration criteria. sumarizes this matter (Category 2 item).
5.
G. Arndt (RES) presented for CRGR review the proposed Revision of Appendix J (Primary Reactor Ontainment Leakage Testing for Water-Cooled Power Reactors) of 10 CFR c n. 50 Enclosure 6 sumarizes this matter (Category 2 Item).
'a 6.
J. Zudans (IE) presented for CRGR review, the proposed amendments to 10 CFR 21, " Reporting of Defects and Noncompliance: and20CFR50.55(e),
" Reporting of Defects in Design and Construction." Enclosure 7 sumarizes this matter (Category 2 item).
Enclosures 2 through 7 contain predecisional information and therefore will not be released to the Public Document Room until the NRC has considered (in a public forum) or decided the matters addressed by the enclosures.
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Ouestions concerning these rneeting minutes should be referred to. Walt Schwink (492-8639).
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Enclosures:
As Stated cc: Comission (5)
SECY Office Directors Regional Administrators CRGR Members G. Cunningham T. Speis W. Johnston F. Congel C. Serpan G. Arndt J. Zudans 5
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t to the Minutes of CRGR Meeting No. 78 -
CRGR Briefing on Fire Protection r
The Comittee was briefed by NRR (W. Johnston) on matters addressed in the proposed Fire Protection Guidance Package now scheduled for full review by CRGR at Meeting No. 79 on July 24, 1985. The package being discussed was that submitted by NRR to the EDO by memorandum dated June 24, 1985, Denton to Dircks; that material was in turn distributed to CRGR members by memorandum dated June 25, 1985, Stello to Bernero, et al. No additional briefing material was provided to the Consnittee in connection with this briefing.
l The issues involved in completing implementation of the Appendix R rule regarding Fire Protection programs at operating reactors are long standing; and the Fire Protection Guidance Package that has been submitted for EDO office-level consideration now reflects a complex chronology of evolution over several years. This briefing was scheduled, therefore, in advance of final review by CRGR, to clarify any points or details identified by the Consnittee in its review of that material to date, and hopefully to better focus the presentations and discussions regarding the proposed Fire Protection guidance package at Meeting No. 79.
The principal points developed in the discussions at this briefing were as follows:
1.
The staff's position is that the new Fire Protection Guidance Package addresses procedural changes and clarifications of interpretations of existing requirements that do r.ct result in imposition of new requirements on licensees. Accordingly, NRR believes that the package would not necessarily require CRGR review. It was noted in this context, that the EDO has indicated (in a memo dated 12/10/84, Dircks to Stello/Denton/DeYoung) that the Conenission Paper involved should be reviewed by the Consnittee; but it was also recognized that, with the passage of time and the turn of events since then (including extensive consideration by a senior management review team appointed by E00), review by CRGp may no longer be considered necessary.
2.
The staff emphasized that the proposed Fire Protection Tech Specs, which l
were considered by the Fire Protection Steering Group in their review of the new Fire Protection Guidance documents included in this package, are not now included in the package being considered by CRGR. The proposed Tech Specs involved are being further reviewed / developed in conjunction with the broader Tech Spec review and improvement efforts now underway separately within NRR. They will be submitted for CRGR review later, as appropriate.
3.
NRR has not prepared a cost-benefit analysis in connection with this Fire Protection Guidance Package, because no new requirements are i
proposed / imposed or need justification. The NRR view is that this
2-guidance package only reflects an attempt to expedite implementation of actions already specified or agreed to by the Comission.
.e 4.
Much discussion focused on the proposed Standard (Fire Protect 3on) License Condition. The staff believes that it is necessary to put existing Fire Protection Program comitments into a more binding form for some licensees, as part of an overall effort to better control / monitor changes made to previously approved Fire Protection system features or configurations. The staff also believes that it is appropriate to have all licensees on an equal footing with regard to documentation of plant-specific Fire Protection comitments (i.e., in the license condition format already specified by the Comission for the more recently licensed plants)
The CRGR view was that the proposed Standard License Condition would, in effect, make legal requirements out of what have previously been recognized as comitments to guidance (in effect elevating guidance to the stature of a regulation or other such legal requirement). The proposed license condition does, therefore, involve new requirements (although, as proposed by the staff, the new legal requirements involved would not be imposed, but would be accepted voluntarily in response to " encouragement" by the Comission). The Comittee felt, therefore, that the proposed license condition was inconsistent with the suggestion that CRGR review objectives in proposing the Standard (Fire Protection)g the staff's stated was not really required. Alternative ways of achievin License Condition j
for all licensees were discussed. One alternative mentioned was for staff to identify the Fire Protection Program features over which the staff thought it necessary to exert improved control / monitoring, and to make Tech Spec items of those features. The discussions on this point at this briefing were inconclusive; but this topic area was identified as a principal area for further treatment in CRGR Meeting No. 79 scheduled for July 24, 1985.
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