ML20209D794

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Confirms B Kane Conversation That Stello Will Not Provide Input to NRR Re Commission Paper on Fire Protection,In Response to 841228 Memo.Crgr Will Review Issue.J Conran Should Be Informed of Progress & Meetings.Fr Notice Encl
ML20209D794
Person / Time
Issue date: 01/03/1985
From: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Vollmer R
Office of Nuclear Reactor Regulation
Shared Package
ML20209D558 List:
References
FOIA-86-274 NUDOCS 8501280129
Download: ML20209D794 (3)
v • d • e


Text

d'pareg#g UNITED STATES

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[,g NUCLEAR REGULATORY COMMISSION

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MEMORANDUM FOR:

Richard H. Vollmar, Director Division of Engineering, NRR FROM:

Victor Stello, Jr.

Deputy Executive Director Regional Operations and Generic Requirements

SUBJECT:

COMMISSION PAPER ON FIRE PROTECTION (YOUR t1EMORANDUti DATED DECEMBER 28,1984)

This is to confirm Bill Kane's conversation with you.

I do not plan to provide input to NRR on the subject Comission paper at this time since it is a matter that will be reviewed by CRGR.

It is important, however,'that the ROGR staff contact (J. Conran) be kept informed of progress and any significant meetings that may occur between now and the CRGR meeting.

(", -[

  • ictor Stello& k. 'sf/h i V

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Deputy Executive Director 3

Regional Operations and Generic Requirements cc:

J. Conran o

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2056

- Fcdsral Registtr / Vol. 50. No.10 / Tursdsy. Jrnutry 15. 1985 / Propos:d Rules A

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proposed to be corrected hereby.This is Insurance Policy fcr the 1985 cnd b.The doll;r animat"ofins ranciper acre

Amendment No. 2.

succeeding crop years are as follows:

for each crop year is determined by reference to the ro!! wing table:

' )

The changes herein proposed for the Peach Crop Insurance Regulations.

4,+

+ +

1. * '.

).. ' 4 effective for the 1983 and succeeding crop years. involve the clarification of

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the heading of the Amopnt ofInsurance

, c, Table illustrating the dollar amount of

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.c=a===nsas.===

s.ra 3-insurance per acre based on the amount cr of fruit remaining on the trees.De T

^ '. ' " " " * * " " " ' " * " ' ~A"'1""*' " ***. ".E' 5" 'W"*"' " "1,$@

amended language now defines when y:s.-

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ce s cec-ce cm.

on cm. n-a icm, ws

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- the amount is applicable as being the enA-a.ome n ap ma om t.-ias e-se s.-ee a.m.

m or 5

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=.ue.-. = e.e.-.m e.em.e.s..-.; I earlier of (a) the time of harvest. or (b).

~. nu -

m m

m the date of inspection when damage is.

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8# = *** * ; '

due to. hail.This change allows FCIC -

sufficient time ia inspect for. ball:

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a damage.These changes also define * '.-

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. ano 3 $

-J;s.. production to count. for purposes of - * *g'.,. -

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,,,, yfgyaag w.,,.,,p.;g 4. appraisal, when the crop is not 9 m u.m

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. harvested before the harvesting of-rW

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O. ' peaches becomes generalin.the county: ' '" *J.ma'="-

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ano ss. ).e.4es4 ses m1 9 sus 3 d

, and delete Appendix B... n::.M

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3.59'E b" -

FCICis soliciting commentsin this m%...........E,,

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3.% rf 8

.2.1" I soi Casii 7 37s

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' proposed rule for 60 days after.,,,

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ars m

- 37s dm' y see

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publication in the Federal Register. All

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. suo.x aso.a.candwt.nso G " action will be available for publicI Men

.. au. ~ in Woo, "'M i.-

u.,).iss..

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written comments made pursuant to this ico.o-t.e

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'ses #. ines..-y inspection in the D!Iice of the

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Federal Crop Insurance Corpo_Mada~ger.:

7 ration.

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]1 Room 4096. U.S. Department of '. ',;'.'.

"r **"** m n o.umes em o s.a -.,;

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-u..-- Wt.W1erx-.ec...p.c;. f;'.g,'hg (j;

.1 Agriculture. Washington D.C 20'50. ~

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.,.4aMyA@DinteIesirakkpal during regular business hours. Monday (

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a my thmugh Frid,ay.,,,.,,,,4

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g,... 7 e...: m.,g

n. r, wHl vary wiW rek amonced by A, j

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  • idbM5 - h ocutary oN%.Intemst wHlv -

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.".0.<~List of Subjects in 7 CF"R P,ht 40&.:#

, f(3) + loth'a$veNiie~fo$ yk. be paid in'accordance esith.this sec

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+ +.

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(a)Is

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beginning withDesses cropyear,a gr Cropinsurance. Peach,.

fe. gin

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c., :.-J..:.. 2

.3 fio..kJ " of peaches becomes generalin ths'Q. :

- PART 403-AMENDED W A.s '

. country; or;....t.f[q%.'y$J.' ^5" pp'en'dii1ItMyolih cont'ilne'd1.4 m';

Accordingly, pursuant to the auS5ty .We have a policWorpaying your.Wc'M*"'$Ukr.in,7 g403J(dg,_ mme gy

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I -4 ' ;

e Done in Washington Dr.on Noveinbert.,'. - D

~.. ~ - contained in the Federal Crop'Insu'rance Act. as amended (7 U.S.C.4501 et seg')'

indemnity within 30 days of ourn.4.G.h-19e4..-

'7 ~ ? -

. T'?

N the Federal Crop Insurance Corporation approval of your claim. or. entry of a @ %es, yfCele'*'"

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p'mposes to amend the peach Crop'. ; - final judgment against us. We will. in no., Seiretary.Fedein/CWp'h" *' "'". N

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~ Insurance Regulations (7 CFR Part 403).. Instance, be liable for the payment of v f corpomtioni'--'*c~ a... - 'I "

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effective for the 1985 and succeeding damages attorney's fee orother Approved by?-N W'C J.

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crop years,in the following instances:

charges in connection with any claim for. Merritt W.spME

/.

1.The Authority citation for 7 CFR indemnity, whether we approve.or -.

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disapprove such claim. We will pay.. e'.-

a part 403 is'

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simple interest. however. compiated on Deteddenuary7. ass % u.

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Authority: Sees 2. s'e. Pub.1.75-430. 52 the net indemnity ultimately found to be (R Doc. 85-1,1,47 Ned,1,y 245 m),

Stat. 73.n. esamended i U.ssc.150s.1516).

due to you by us or by a final Judgment. sums ooos se*ews.;,... -

2.7 CFR 403.7 is amet ded by revising from and including the elst day after the the introductory test of paragraph (d)-

date the insured signs, dates and and revising the following parts of th' submits to us the properly completed -

NUCLEAR REGULAiORY :

Peach Crop Insurance Policy; the table claim for indemnity form, if the reason COMMISSION. r.

In 4.(b); 9.(e)(3)(a); and 9.h. to rea d:~

for non-payment is not due toyour 3....

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failure to provide informationer other,

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material necessary for the computation I 403J h ePP5coh emipo8cy..- '

or payment of the indemnity."Ihe

% Availability of MRC Fire Protection l

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interest rate will be that established by Policy Steering Committee Report For r

(d)The application for the 1985 and the Secretary of the Treasury under Comment Nuclear Nt[gulatory succeeding crop years is found at section1:of the Contract Disputes Act Aossocy:

~

Subpart D of Part 400-<,eaeral (41 U.S.C. 811) a.nd published.in the Commission.

Administrative Regulations (7 CFR Federal Register.This rate is referred to a

400.37. 400.38) and may be amended as the " Renegotiation' Board laterest Actioec Notice of' availability of and iest for annwnts on fim protectin -

nficy neomnwndations.

from time to time for subsequent crop Rate" and is pub!!shed semi-annually.on po years.The provisions of the Peach or about January 1 s'nd July 1.*Ihe

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, 1 Fedical Register / Vol. 50. No.10 / TundIy. Jr.nuary 15. 1985 / Proposed Ruhs 2057 suuuany:ne staff of the Nucleat FEDERAL. RESERVE SYSTEM constrained to approve the application Regulatory Commission is requesting 4

based on the literal definition of the

~

N public comment on the 12 CFR Part 225 term " bank"in the Bank Holding recommendations made by the Fire I'

Company Act. De Board -r. M lts.

Protection Policy Steering Committee for.

concern that the ese of these limited -

expediting compliaqce with fire Regulation Y;Permissado purpose banks to avoid the objectives of 1

protection requirements.

Transactiona Between Bank Hohnne the Bank Holding Company Act is DATE: Comment period expires February Companies and Dek N: M b

~

Co se and t t the liferation of 4

14.1985. Commen5 received after this 8"D*3dI*'I'*

d date will be considered ifit is aosucv: Board of Governors of the..

simi transactions would seriously undermine the policies of the Bank -

1 practicable to do so but assurance for Federal Reserve System (HtB).

Holding Company Act.The Board found,

consideration cannot given except as to-AcTioec Solicitation of public comments. that use of this devia presents the -

I commen'ts received before this date.

potential for a signiacant, haphazard.

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~

. sunessany:%e Federal Reserve Board is and possibly dangerous alteration of the.

W Anonass: Mail comments to: Harold R-soliciting comment on whether the nation's banking structum without-.*

P Denton. Director. Office of Nuclear Board should permit bank holding Congressional action on the underlying i

Reactor Regulation. U.S. Nuclear companies that own nonbank banks policy issues. In view of these concerns, j

Regulatory Commission. Washington.

(institutions that are chartered as banks.the Board approved the application D.C. 20555. ATIM Document Control but which either do not accept demand subject to the following conditions:

f Desk. "~

deposits or tio not make commercial

' (1) Applicant would not operate the N

loans) to engage in certain transactions nonbank bank's demand deposit taking 1

FOR PURTMsR pdPOResaTION CONTACT:

or establish or continue certain activities in tandem with any other f

Romas V. Wambach. Imad Project j

Manager. Fire Protection. Nuclear arrangements with their nonbank bank subsidiary or other financial institutions:.

subsidiaries. SpeciBcally, such (2) Applicant would not link in any Regulatory Commission. Washington.-

transactions orarrange==nts would wgy the demand deposit and D.C. 20555. Phone:(301)492-7072-include: -

.C

. commercial lending services that define

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smaasswmmeronesamene ?

1.ne provision of certain internal a bank under the Act: and

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Nuclear Regulatory Commission is :..

administrative services to a nonbank s (3) ne nonbank bank would not- "-

intending to review and approve a,

kk sabidarg

v..

engage in any transacdone with + -

I 2.Condnuadonof trustserviceand affiliates, other than the payment of-l policy for expedidng consplation of. -

investinent arrangements that existed dividends to Applicant or the infusion of compliance with the $re protectionJr.6 between a bank holding m=p=ny and. capital by Appucent into the nonbank l mquirementa fornuclear power planta t.

Its trust company subsidiary prior to the bank, without the Board's approval.

including Appendix R to to CPR Part 50.

trust com

's conversion to a '

Dese conditions were established to A Steering Committee was appolnied by nonbank and -.

ensure that a nonbank bank would be i the Executive Director for Operations...

- 3. Officer and director interlocks.

Independent of its afEliates and that its and the Stee' ring Committee issuedl

'j.,

~

- recommendations for the policy to be.:;

by the Board by February 14.1985.

Integrated with those ofits affiliates -

caTE:Allcomments should be received banking activities would not be...

adopted by the (*a==i== tan. In a report such that the lastitution would be a dated October 28.1984.%e OfEce of,,.

' Acoassa All ns===mata w%should.

~-

    • bank" under 'he Act. Dese conditions t

refer to Docket No. Rres38.should be Nuclear Reactor Regulation (ONRR) is,, mailed to Wilham W. Wiles. Secretary. - were intended to prevent evasion of the seeking comments on the proposed.

Board of Governors of the Federal '. -

f basic poHey of me Act to sepamte -

policy. Copies of the Steenng f'r==Enee Reserve S' ~

Wa=Magean D.C.

banking and commerce and to maintain J Report are available for inspection and '.' 20551.or esed to Room B-,2223. 20th compliance with the Act's limitations on copying at the NRC Public Document.

& Consititution Avenue.NW.,

interstatWn% %us. ee hamewd e

Room.1717 H Street,NW Washington.

Washington. D.C between 845 a.m. and was intended to establish a set of.

D.C. and at each of the Local Public.. 5:15 p.m. weekdays. Comments may be requirernents applicable to the,

f..

Document Rooms loca inspected in Room 8-1122 between 8:45

[c

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.... of each nuclearpowerted in theNicinity'.

e; sidon osi no yg

, gon nking plant licensed or a.m. and 5:15 p.m. r

--s j.

l under construction.[%e Steering pon puuvien usponesafiose coerracT:.. J.

these institutions would remain u

organizations that would assure that Committee Report is an enclosure to ~

Virgil Mattingly. Associate General t

Generic Letter 85-01, dated January 9. -

Counsel (202/4SH430).CarlHoward, independent and not integrated into the i

1985.) Information regarding the location Senior Counsel (202/4sM7e8), or.

parent's operations in such a manner as i

of Local Public Document Rooms can be Melanie L Fein. Senior Attorney (202/

to effect a combination of banking and y

obtained by calling the Incal Public _. 452-3504). Insel Division.

commerce or otherwise prohibited interstate deposit taking and e

Document Room Branch's toll free suretansestranymeronesafioet On

'8 commerdallending.

y numben 800.ess-e0s1.

March 23.1 sed. the Board approved the Following the Board's approval of the Dated at Bethesda.4 land this eth day 8pplication by U.S.TrustCorporation to U.S. Trust application. a number of bank J

convert its state chartered Florida trust holding companies applied to acquire

  • gI*""*'Y 3885' company int 6 a nationally chartered similar nonbank b&nks.He Board has

,For the Nuclear Rptory Commission.

    • nonbank bank" that would accept approved several of these applications demand deposits and make consurner, to date, subject to the same conditions it Harold R. Desses.

/ -

Director. Office o/NuclearReactor but not copunerdal, loans as defined by established in its U.S. Trust order.8 Regulation.

the Board' U.S.1>ust Corporotton. 70 Federal Reserve Bulletin 371 (1984). In

[FR Doc. s5-1157 Filed 1-14-45: s:45 am) its order approving the U.S. Trust

, g,,, 7mem rd wuon, n l

rederal Reserve sulietin si itsask sonA e/8ostoa esimes coot reso es.e application, the Board stated that it was co w l

d e

,___.____-____-_____.-~.__-._..__-_-m_

  • /

UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON. D. C. 20555

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TO ALL POWER REACTOR LICENSEES AND ALL APPLICANTS FOR POWERlREACTOR LICENSES Gentlemen:

SUBJECT:

FIRE PROTECTION POLICY STEERING COMMITTEE REP' ORT (Generic Letter 85-01)

Enclosed is a copy of the NRC Fire Protection Policy Steering Committee Report, dated October 26, 1984.

The background and purpose of the Steering Committee is described in the report.

A notice will be published in the Federal Reaister in the near future that will provide an opportunity for public comments on this report.

No response to this letter is required.

e Ei

nhut, Division of LWeensing

Enclosure:

As stated 4

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TECHNICAL ASSIGNMENT CONTROL 1 M @ Id I / lb

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HARTFORD. CONNECTICUT 06141-0270 a C'7% C,*."'C','O""

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(2mj ses-sm0 March 1,1985 Docket Nos. 50-213 50-245 50-336 50-423 A04606 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

References:

(1)

D. G. Eisenhut letter to All Power Reactor Licensees and All Applicants for Power Reactor Licensees, dated January 9, 1985 (Generic Letter 85-01).

(2)

3. M. McGarry III letter to H. R. Denton, dated February 14, 1985.

(3)

E. L. Jordan letter to All Holders of Operating Licenses or Construction Permits, dated June 22,1983 (IE Information Notice 83-41).

Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos.1,2 and 3 Comments on Fire Protection Policy Steering Committee Report On January 15,1985, the NRC published in the Federal Register (50FR2056) a notice of availability of and request for comments on the NRC Fire Protection Steering Committee report.

This report was forwarded to power reactor licensees via Reference (1).

Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO), on behalf of the Haddam Neck Plant and Millstone Nuclear Power Station, Unit Nos.1, 2 and 3, respectively, have participated in the Nuclear Utility Fire Protection Group (NUFPG) via Northeast Utilities Service Company (NUSCO) and strongly endorse the Group's comments (see Reference (2)). CYAPCO and NNECO also hereby submit comments in response to the Federal Register notice.

~

In general, we applaud the Commission for its attempt to issue a final regulatory guidance document governing fire protection and Appendix R issues. It is clear that a significant and sincere attempt was made by the Staff to produce a document which would lead to closure on Appendix R issues as rapidly as possible. In many respects, the draft guidance document accomplishes this and would serve to facilitate resolution.

. e e cWG ? ! 'i+

Foi*%N c' -"C I

, However, we disagree with some portions of the report, and these are dealt with below.

1.

Proposed License Condition Our most significant disagreement is with the proposed license condition provided as Enclosure 5 to the report.

Apparently, this draf t was prepared from the perspective of recently licensed plants, and introduces some confusion regarding its potential application to older operating facilities.

We believe this proposed license condition should be withdrawn. In support of this view, we invite your attention to page 4 of the draft policy in program guidance document discussed in a Commission meeting on January 31, 1985. A relevant excerpt from Section II Regulatory Philosophy, is as follows:

"The Commission intends to shif t its regulatory emphasis away from detailed, prescriptive requirements toward general design and performance criteria."

While much of the fire protection policy steering committee report runs contrary to the above quoted Commission policy, the proposed licensed condition is the most significant one.

Paragraph 2 of the proposed licensed condition is apparently, and, in our view, inappropriately patterned af ter similar approaches taken with emergency plans and security plans. As worded, the proposed licensed condition produces the undesirable result of subjecting to the license amendment process technically acceptable changes which would otherwise be implemented at the discretion of the licensee. Specifically, changes which would decrease the level of fire protection in the plant, but not below the acceptable threshold of continued overall fire protection safety, would consume significantly more resources than necessary on the part of both the NRC and licensees. Our operating plants already have fire protection license conditions which were issued in 1978, in addition to the governing regulation, 10CFR50.48 and Appendix R.

What an additional license condition would accomplish is not clear.

Paragraph 3 of the proposed license condition would apparently elevate fire protection issues and reviews to a level greater than that associated with other elements of operating a nuclear facility. The NRC currently requires submittal of annual updates to the FSAR and the 50.59 annual report; when changes are made to the plants, fire protection is but one of many aspects which must be investigated as part of the design change process. We believe that the additional resource expenditures required by this proposed license condition would not result in a commensurate increase in public safety, and we urge that this proposal be eliminated.

We also refer to the rationale presented by the NUFPG in support of the view that this proposal be withdrawn.

I f

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.W*.

.y: 2.

Schedular Relief The committee report and the proposed generic letter indicate that extensions to the 10CFR50.48(c) schedules will no longer be granted. It is possible to infer from the language of the generic letter that no further schedular exemptions may be filed. The generic letter should state specifically that schedule exemption requests may still be filed under 10CFR50.12.

3.

Quality Assurance Requirements We wholeheartedly agree with the NUFPG position (see Reference (2))

that the current wording of Section D of the proposed generic letter introduces an unnecessary complication with respect to the "important-to-safety / safety-related" issue.

We strongly recommend that the suggested NUFPG modification to this Section be adopted.

4.

Documentation Required to Demonstrate Compliance This portion of the proposed generic letter addresses engineering evaluations performed to demonstrate compliance with NRC requirements, citing references for use as guidance in preparing such evaluations.

Although we agree that any necessary engineering evaluations should be complete, the level of detail that the selection of references imply is necessary may not be needed in all cases.

5.

Questions and Answers a.

Question 3.2.3 (fire door modifications)

The second paragraph of the response, which states: "An exemption is required if fire doors installed in a fire barrier used to satisfy Section III.G.2 are modified such that the labeled rating no longer applies" seems to be inconsistent with the first paragraph of the response. Since any modification of a fire door will invalidate UL and FM labeling an exemption should be required only when the analysis described in the first paragraph shows that adequate margin will not exist fo!!owing the modification.

b.

Question 3.1.1 (fire area definition)

The response for this question, referring to 10CFR50 Appendix R Section III.G.3.b, indicates that, for safety-related equipment and associated cabling the licensee must "(p)rovide the design criteria for protection of such equipment against inadvertent operation, careless operation or rupture of extinguishing systems." In contrast the regulation itself addresses " rupture or inadvertent operation of fire suppression systems."

Reference (3) quoting, 10CFR50 Appendix A General Design Criterion 3 (GDC) states "(f)tre fighting systems shall be designed to ensure that their rupture or inadvertent operation does not significantly impair the safety capability" of

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_4 safety-related equipment.

We believe that the inclusion of the additional criterion of " careless operation," is inappropriate. It is not clear what additional concern the NRC intends for licensees to address by inclusion of this term.

~

We appreciate the opportunity to offer our comments on the committee report, and request that our comments be considered although the requested response date has already passed.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY L 'fb)

W. 'G. Counsil Senior Vice President

. h;. ; ;

,

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