ML20151C512
| ML20151C512 | |
| Person / Time | |
|---|---|
| Issue date: | 01/26/1981 |
| From: | Ferguson R Office of Nuclear Reactor Regulation |
| To: | Benaroya V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19284B784 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8103160936 | |
| Download: ML20151C512 (2) | |
Text
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L'... J G IGi' MEMORANDUM FOR:
V.'Benaroya, Chief Chemical Engineering. Branch Division of Cn.;io,; ring F?0M:
R. Fergusen, Section Leader Fire Protecticn Section Chemical Engineering Cranch Division of Engineering
SUBJECT:
DIFFERING PRLFESSIONAL OPIMION - FIRE PROTECTION RULE SUPPLEMENT 1 This memorandum is in response to the request of V. Moonan on January 19, 1981 that I indicate how the ED0's recommendations stated in SECY-S0-525 dated December 23, 1980 affect the subject differing professional opini:n.
Two recenaendations are contained in SECY-80-546. My comn:ents on the. are as follows:
t00 Rect-endation #1:
A fire ;?otection rule,with well defined requirerants for generic its i fplic;ble to most plants, and general requirements.for plant depende-t icatures, should be issued for public c'omment by J;1y 1, 1982.
0 $ 3ator's Opinion I agree with the EDO recommendations regarding technical content and latal however 1.::
of specification (as reflected by Enclosure 2 to SECY-80-546);
Escause 50 has assis: d '."
not agree with the schedule fcr ir.;plementation.
in drafting a revision to SRP 9.5-1 in the foimat of a proposed appendi t ::
10 CFR Part 50, I believe 50 c:uld have a proposed rule issued for pu:'.ic comment within 2 4 months if the Connnission dire:ted the issuance of :ne proposed rule on such a schedule.
At the present time, we are cvaluoling several C'. 1;plications per year.
3cd rule which states current comprehers',e The pro pt issuance of a prep:
require. cants will be helpful to both the applicar.ts and the staff in c: -
pleting these evaluations expeditiously and with a minimum of backfit problems.
EDO Recc-.andation #2:
lhe fire protection rule for future plants should a; ply to nuclear ;:.cr If:.c electric generating stations.:ioso constructicn ;;rc.its ware dockete:
January 1, 1982.
(See Enclos re 2 S.ECY-80-546).
THIS DOCUMENT CONTAINS P00R QUAulY PAGES 8103160036
- . i o.o a cya
-2 Cri.inator's Cainion The fire protection rule should apply to plants licensed to operate after 1:nuary 1,- 1979. These plants are of present ccncern to the staff, ind.st.ry and public. The present Appendix R to 10 CFR Part E0 appli.s to pl;nts licensed to cperate prior to January 1,1979. The C;3's rc: - :ndati:q.uld I.;.c an Appcndix to 10 CFR Part 50 for plants licensed to c;. rate af ter J::a ry 1992 (assuming a 10 year ccnstruction shcedule). Therefore, the many pl.nts to be licensc:d to operate bet.;cen 1979 :nd 1992 uculd not he covered by the re:ulations. This gap would prct:51y give rise to a host cf backfit prcel s.
D ch prcbicms can be avoided by h;ving all plants ccvered by the re;ulatien from January 1, 1979.
SECY-80-546 states that:
The main purpose of issuing a fire protection rule for new plants at this time is to amplify in the regulaticns those fire protection features necessary for plant safety and to codify the NRC policy for the level of fire prctection.
Further, such a rule would standardi e the recuire.:nts, aid applicants early in the design stage, imprcve tne efficiency of r2psistory review and mai.. sin (.nsistency. Th sc facters would lit cly enhance that Ic.01 of s afety prcvided by fire protecticn features.
This purpose is best accc plished by pcc ptly issuing a fire protecticn rule that applies to plants licensed t; cperate after Jan;ary 1, 1979.
\\ 0
- k. '~ 4-vy R. L..-crguson, Se:::cn Lcider Fire Protecticn Section Chemical Engir.eering Branch Civisien of Er.gineering 8
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