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NUCLEAR; REGULATORY COMMISSION I
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o%se CPPEE OF TME' COMMISSIONER!
June 21,.1984!
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MEMORANDUM FOR:.
WilliamiJ. Dircks Executive Director. for Operations.
FROM:
James Xi Asselstine
SUBJECT:
IMPLEMENTATION! 0F PENDIXtR AT CALVERT CLIFFS-On June IB,1984, I visited:the Calvert Cliffs facilities to psin some insight on how Appendix R was bei'ng knplemented.
Fol '. cwi r - t e the impressions I developed based on discussions with the fac' ii.-
management, a tour of the plant and mj understanding of
story of Appendix R.
At the outset, Baltimore Gas and Electric (BG&E) had a cc:. aent from the tcp of the organization.to do the right ' thing on fire ! rcqection.
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BG&E hired three full-time fire protection engineers ': bat
.: e substan-tially involved in carrying out this commitment.
This cornitment was first reflected in the initial design of the plant.
Following the Brcwns Ferry fire, BG&E continually interacted with U:: NRC staff as the Branch Technical Position developed 4 BG&E undertool extensive
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program to upgrade the plant's fire protection capabi'..ies in response to the Branch Technical Position.. When. Appendix R b:
x effective, they appeared to be able to satisf.9 those, requiremen.
vith a minimum of exemptiont.
Where exemptions were. sought because 'of tractical diffi-culties, BG&E was able to prov.ide tho> inforniation needed to support the
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exemption request, and appears to have;been able to provide equivalent protection.
As a result of these efforts, Calvert Cliffs seems to be in very good shape en fire protection; in marked contrast to many, if no most, other plants.
BG&E did not seem to have any difficulty in understanding Appendix R, other than some. initial uncertainty regarding the definition of n u Me" "# ##
"associated circuits".
Generic Letter 83-33 told the BG&E fire ' M"*/**
protection engineers nothing new and did not alter their approach to complying with Appendix R.
BG&E appears not only to have met the requirements of Appendix R, in a timely manner, but also to have gone x
beyond those requirements.
While the. fire-protection measures cost ther.
\\$30 million, BG&E seems to think the expenditures were worthwhile ren the plant protection viewpoint.-
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The SG&E experience scens to contradict irectly those in ind0stry that-claim Appendix R is fraught with uncer:t inty. In reality,: these other_.r-.r.-c em utilities; seem to be arguing the erits of the: requirements"-- arguments Pe/ ***
that they have been making since they unsuccessfully opposed A before ethe Comission and.in the.ccurts-1iterally years ago - pendix.R
'and seem u."a.=r to nwiltling to spend.the money to provide the basic protection, w
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includingihiring. the type of fire protection specialists whc have been
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Are my impressions correct?.
P a r' * 'T cc:
Chairman Palladino Comissioner Gilinsky Cornissioner Roberts Comissioner Eernthal:
SECY OGC OP E-
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J 55 UNITED STATES
-t NUCLEAR REGULATORY COMMISSION p
j WASHINGTON, D. C. 20655 h
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6 1984 MEMORANDUM FOR:
H. R. Denton, Director Office of Nuclear Reactor Regulation FROM:
F. Rosa Chief, Instrumentation & Control Systems Branch Division of Systems Integration
SUBJECT:
DIFFERING PROFESSIONAL OPINION:
INTERPRETATION OF APPENDIX R Your memorandum dated June 15, 1984, assigned me as the Responsible Manager for conducting an independent assessment of the issues raised by the subject Dif-fering Professional Opinion with a due date for completion of July 30, 1984.
The purpose of this memorandum is to request an extension of 15 working days for completion of this assignment.
Based on an assessment of the DP0, I have con-cluded that an extension is necessary because its resolution involves especially complex issues and the participation of several levels of NRC management. My request for an extension is, therefore, in accordance with NRC Manual Chapter 4125, Differing Professional Opinions, Appendix 4125, Section G.e.
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Faust Rosa, Chief Instrumentation & Control Systems Branch Division of Systems Integration cc:
R. Vollmer D. Eisenhut R.W. Houston W. Johnston V. Beneroya R. Ferguson R. Eberly D. Kubicki C. Ramsey (R III)
J. Stang J. 4) lie (R III)
JUL 91984 th
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