ML20236H511
| ML20236H511 | |
| Person / Time | |
|---|---|
| Issue date: | 05/28/1998 |
| From: | Mcgaffigan E NRC COMMISSION (OCM) |
| To: | Hoyle J NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20236H475 | List: |
| References | |
| SECY-98-058-C, SECY-98-58-C, NUDOCS 9807070241 | |
| Download: ML20236H511 (2) | |
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NOT ATION VOTE RESPONSE SHEET TO: John C. Hoyle, Secretary FROM: COMMISSIONER MCGAFFIGAN
SUBJECT:
SECY-98-058 - DEVELOPMENT OF A RISK-INFORMED, PERFORMANCE-BASED REGULATION FOR FIRE PROTECTION AT NUCLEAR POWER PLANTS (WITS 9200197)
Approved I Disapproved Abstain Not Participating Request Discussion COMMENTS:
See attached comments.
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Entered on."AS" Yes No W B"e 2?! "
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Commissioner McGaffigan's Comments on SECY-98-058 I approve Opbon 2. The staff should work with the NFPA and other stakeholder to develop a more risk-informed, more performance-based consensus standard for fire protection and then endorse the standard to the fullest extent possible.' I agree with Commissioner Dicus that the staff should pursue rulemaking to make a minor change to Section Ill.M of Appendix R to
- eliminate the requirement for non-combustible penetration seal material. I also agree with Commissioner Diaz that RES should prepare a report on completed fire protection studies and
- seek Commission approval before initiating any further research in the area of fire protection.
As I noted in my vote on SECY-98-077 (Respiratory Protection), I feel that there is a policy issue
, as to what constitutes endorsing a consensus standard, as advocated in DSI-13 and the L Technology Transfer Act of 1996 (Public Law 104-113). In the case of fire protection, any endorsed standard must, due to backfit considerations, be a voluntary alte native to current fire protection rules (e.g.,10 CFR 50.48, or 10 CFR 50 Appendix R). For this reason, the method .
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that the Commission would use to endorse any consensus standard developed by NFPA will be of particular importance if there is to be any chance that large numbers of licensees will elect to shift to the new standard. ' The most cited success in voluntary licensee adoption of a
. performance-based rule is Option B to Appendix J. The question will be whether this success
. can be replicated in fire protection as the staff proceeds.
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- @ VEC L UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON D C 205 % 0001 g
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, \> # June 30, 1998 OFFICE OF THE SECRETARY 3
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' MEMORANDUM TO: L. Joseph Callan - gM e
Executivfirector for Operations 9k d
FROM:
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John C. Hoyle, Secretary g'
SUBJECT:
STAFF REQUIREMENTS: SECY 98-058 - DEVELOPMENT OF A RISK-INFORMED, PERFORMANCE-BASED REGULATION FOR FIRE PROTECTION AT NUCLEAR POWER PLANTS l
The Commission approved the staffs proposal to defer development of a risk-informed,
- performance-based fire protection rule at this time and, instead, to pursue with the National Fire Protection Association (NFPA) and the nuclear industry the development of a risk-informed, and
- ultimately performance-based consensus' standard for fire protection at nuclear power plants (Option 2 of SECY-98-058). Under this approach, the NRC staff would endorse the consensus
- standard, if successfully developed, in a rulemaking to serve as an altemative method for licensees to meet NRC fire protection requirements. In implementing Option 2, the staffis directed to take the following actions:
- 1. Work closely with the NFPA so that the consensus standard is developed on an expedited basis and to ensure that the proper risk-informed, performance-based
^ approach is maintained, The staff is directed to update the Commission on the status of L
NFPA activities, providing an assessment of progress and direction.-
(EDO) (SECY Suspense: 11/1/98) 2.- . Pursue rulemaking to amend section Ill-M of Appendix R to 10 CFR Part 50 to eliminate the requirement f:r non-combustible penetration seal material and make other minor changes to fire protection regulations.
(EDO) (SECY Suspense: 11/1/98)-
- 3. . Closely examine plants whose individual plant examinations for external events
. (IPEEEs) show fire protection vulnerabilities to gain a thorough understanding of the particular risk contributors. In evaluating those facilities, consideration is'to be given to j the cumulative effects of exemptions to current regulations to ensure that an adequate I
l SECY NOTE: This SRM and the Commission Voting Record for SECY-98-058 will be-made publicly available 5 working days from the date of the final SRM.
SECY 98-058 was made publicly available at a Commission meeting on March 31,1998.
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~ level of fire protection is maintained. The staff is directed to report to the Commission the results of lessons leamed from the IPEEE efforts.
(EDO) L (SECY Suspense: 5/30/99).
- 4. . Continue to consolidate existing regulatory positions to generate a comprehensive fire
. : protection regulatory guide to be used in meeting the existing fire protection regulations.-
' 9/30/99);
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L(EDO) (SECY Suspense:
' 5. . l Summarize NRC's fire protection-related research activities conducted to date and seek Commission approval before initiating further research.-
- :(SECY Suspense: 10/1/98):
. (EDO) i
- 6. f Inform the Commission on how and when the fire protection issues as listed in SECY-97-127 will be cle ed.. 1 (EDO) (SECY Suspense: 10/1/98). -!
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cc:' . Chairman Jackson I ~ -
~ Commissioner Dicus
- Commissioner Diaz -
! Commissioner McGaffigan OGC 1
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l Office directors, regions,' ACRS, ACNW,'ASLBP (by E-Mail) .
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