ML20134G429

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Notation Vote Approving w/comments,SECY-96-134, Options for Pursuing Regulatory Improvement in Fire Protection Regulations for Nuclear Power Plants
ML20134G429
Person / Time
Issue date: 09/09/1996
From: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
To: Hoyle J
NRC OFFICE OF THE SECRETARY (SECY)
References
SECY-96-134-C, NUDOCS 9611130195
Download: ML20134G429 (2)


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RESPONSE SHEET

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'TO: John C. Hoyle, Secretary FROM: CHAIRMAN JACKSON

SUBJECT:

SECY-96-134 - OPTIONS FOR PURSUING REGULATORY IMPROVEMENT IN FIRE PROTECTION REGULATIONS FOR NUCLEAR POWER PLANTS Approved X Disapproved Abstain Not Participating Request Discussion COMMENTS:

Subject to comments attached.

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/ SIGNATURE Release Vote / X / September 9, 1996 DATE l

Withhold vote / /

Entered on "AS" Yes X No C'h I 0S0025

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9611130195 960909 PDR COMMS NRCC I CORRESPONDENCE PDR .

i CHAIRMAN'S COMMENTS ON SECY 96-134 I approve Option 2, Revise 10 CFR 50.48 and modify, or remove, App. R. This l option removes the inherent inconsistency, set up by the promulgation of App.

l l R, whereby licensees have different regulatory approaches in maintaining their  ;

fire protection programs. This option creates consistency, eliminates future

! exemptions, enhances flexibility, and allows latitude for future efforts concentrating on risk significant activities.

In the area of fire protection regulation, the staff should develop a plan (including milestones and schedules) for transitioning to a more risk-informed and performance-based regulatory structure. The plan should identify the key elements of a transition strategy as well as the obstacles that must be overcome to make progress in this area. Weaknesses in PRA methods and  ;

operational data should be identified along with ongoing research activities j to address the weaknesses identified (if any). Since " uncertainty" is likely to be a major issue in any risk-informed and performance-based approach, the l staff should explicitly address plans for dealing with this issue.

Additionally, I encourage continued staff interaction with industry regarding the transition toward risk-informed performance-based regulation.

Further, the staff should factor preliminary IPEEE insights-gained into

. rulemaking in this area. Finally, the staff should address the legal status of l the existing exemptions granted to licensees should new rulemaking be adopted.

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