ML20235T640

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Forwards Denial of Committee to Bridge Gap Petition for Rulemaking Requesting That Commission Amend Regulations to Require Licensees W/Reactors Using Graphite to Submit Fire Response & Evacuation Plans for Approval for Fr Publication
ML20235T640
Person / Time
Issue date: 09/25/1987
From: Murley T
Office of Nuclear Reactor Regulation
To: Udall M
HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
Shared Package
ML20235T514 List:
References
RULE-PRM-50-44 NUDOCS 8710130158
Download: ML20235T640 (2)


Text

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SEP 2i na7 The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs i United States House of Representatives Washington, DC 20515

Dear Mr. Chairman:

Enclosed for the information of the Subcommittee is a copy of a denial of a I petition for rulemaking that is to be published in the Federal Register. )

The Nuclear Regulatory Commission (NRC) received a petition from the Committee l To Bridge the Gap requesting that the Commission amend its regulations to require licensees whose reactors employ graphite as a neutron moderator or i reflector to formulate and submit for NRC approval fire response and evacuation I plans for combating a reactor fire involving graphite and other constituent parts (e.g., fuel). The petitioner also requested that licensees perform measurements of the "Wigner energy" stored in the graphite at their reactors, )

and submit these measurements to the NRC for review together with a revised l safety analysis that shall address the risk and consequences of a reactor fire. ]

The petition is being denied for the following reasons:

Each licensee of a non-power reactor has submitted an emergency plan that has been approved as meeting the requirements of 10 CFR 50, Appendix E.

The petitioner has not demonstrated that these plans do not provide an 4 appropriate level of protection of the health and safety of the public. 1 i

The licensee for Fort St. Vrain, the only NRC-licensed power reactor using l graphite, has an approved emergency plan that meets the requirements of l l 10 CFR 50, Appendix E, as well as an approved fire protection program that l meets the requirements of 10 CFR 50, Appendix R. In addition, at the

, request of the NRC, the licensee has submitted a report addressing the I implications of the Chernobyl accident for Fort St. Vrain. The report has been reviewed and approved by the staff. The petitioner has not provided a technical basis that would show that an additional fire response plan would enhance the protection provided for the health and safety of the public by the existing emergency plan and fire protection program.

Measurements of maximum stored energy in non-power reactors are not necessary to ascertain the releasable stored energy in graphite components below 650 C. Existing knowledge provides this information which is ad-equate for a safety evaluation of the effect of stored energy on the potential for graphite burning and the associated danger to the health and safety of the public. Additionally, such measurements are contrary to the NRC's as low as is reasonably achievable principle, since unneeded knowledge would be sought at the expense of unnecessary personnel exposure.

8710130158 B70919 PDR PRM 50-44 PDR

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The Honorable Morris K. Udall. E P 2 5 1967 Chairman l

Additional detail with regard to each of these reasons is included in the denial of the petition for rulemaking, which is provided in the enclosed

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Federal Register notice. ]

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Sincerely, l ML Thomas E. Murley, Director Office of Nuclear Reactor Regulation )

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Enclosure:

As stated cc: Rep. Manuel Lujan, Jr.

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