ML20236U013
| ML20236U013 | |
| Person / Time | |
|---|---|
| Issue date: | 07/24/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 9807290253 | |
| Download: ML20236U013 (3) | |
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UNITED STATES l, ',
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NUCLEAP REGULATORY COMMISSION I
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July 24 1998 l
Mr. G.R. Mc n Senior Vica thesident. Energy Supply Nebraska Public Pov'er Distuct 141415th Street P.O. Box 499 Columbus, NE 68602-0499 Dear Mr. Horn-(
l am responding to your ietter of June 25,1998, to Chairman Jackson of the U.S. Nuclear Regulatory Commission (NRC) regarding the development of a new risk-informed i nd performancobased hre piotection rule. In your letter, you stated that risk information can effectively be ussd in the exemption and deviation process, that a new rule for fire protection has the potential for creating an unstable regulatory environment, and that a new rule would require extensive plant resources to rebaseline plant programs to the new regulation.
In a staff requirements memorandum (SRM) dated September 11,1997, the Commission directed the staff to brief the Commission on industry feedback regarding the proposed rulemaking. During a public meeting on November 5,1997, representatives of the Nuclear Energy Institute (NEl) presented the preliminary results of a survey of all Chief Nuclear Officers of operating reactors regarding the proposed rulemaking. Representatives of NEl also presented these preliminary results at a meeting of the Advisory Committee on Reactor Safeguards on November 7,1997, and formally provided the results of this survey to the NRC Executive Director for Operations in a letter dated December 11,1997.
In SECY-98-058, the staff provided the results of NEl's industry survey to the Commission and, on the basis of feedback received, proposed three options for fire protection rulemaking for consideration by the Commission. These options incorporated the ir'dustry position, which was reiterated in a letter dated May 5,1998, to Chairman Jackson from Ralph Beedle of NEl.
Specifically, SECY-98-058 stated that the industry opposed any rulemaking and that if the rulemaking proceeds, industry pr(fers an approach that retains the option of continued
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compliance with existing regulations, including approved exemptions. SECY-98-058 futther stated that new or revised guidance would be provided in those areas in which the public, the staff, and the industry determine that clarification is needed, and that the staff would work with the National Fire Protection Association (NFPA) and the industry to develop a performance-based, risk-informed consensus standard for fire protection for nuclear power plants.
k The Commission has been fully aware of and has considered the industry's position regarding fire protection rulemaking while it has deliberated the options proposed by the staff. In an SRM dated June 30,1998 (copy enclosed), the Commission approved the staff's proposal to defer l
development of a risk-informed, performance-based fire protection rule at this time and, insteed, to pursue with the NFPA and the nuclear industry the development of a risk-informed, t
and ultimately performance-based consera.us standard for fire protection at nuclear power plants (Option 2 of SECY-98-058). Under this approach, the NRC staff would endorse the 9807290253 980724 PDR ORG NRRA pqq 6y?h r-r- (T"w{~ m
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July 24, 1998 Mr. G.R. Horn 2
consensus standard, if successfully developed, in a rulemaking to serve as an alternative method for licensees to meet NRC fire protection requirements. The Commission also directed the staff to continue to consolidate existing regulatory positions to generate a comprehensive fire protection regulatory guide to be used in meeting the existing fire protection regulations.
Any new fire protection rule would serve as an alternative method for licensees to meet NRC l
fire protection requirements. Therefore, it would not create an unstable regulatory environment, nor would it require plant resources to rebaseline plant programs unless a licensee voluntarily chooses to do so.
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l appreciate your willingness to share your concerns with the Commission.
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The staff is committed to continue to work with the public and the industry during the proposed fire protection rulemaking. If you have any further questions, please do not hesitate to contact me.
glh' signed $
SamuelJ. Collins Samuel J. Collins, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated "This correspondence addresses policy issues previously resolved by the Commission, transmits factual information, DISTRIBUTION:
or restates Commission policy."
Public w Central File-SPLB R/F TJCarter (G980419)
LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinot LWhitney JHolmes CBajwa PQualls MSaliey SPLB Ticket Filo PMagnanelli (G980419)
SECY OGC EDO r/f OCA OPA CFO CIO JCallan AThadani HThompson PNorry JBlaha SBurns MKnapp FMiraglia SCollins BBoger BTravers JRoe RZimmerman Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\\ HORN.WPD
- See previous concurrence To receive e copy of this wcument, indicate in the box:
"C" = Copy without attachment / enclosure "E" = Copy with attachment! enclosure
- N* = No copy i
0FFICE NRR:SPLB NRR:SPLB NRR:SPLB l
NRR:D:DSSA Tech Editor l
NAME_
CBajwa*
SWest*
LMarsh*
GHolahan*
BCalure*
DATE 07/09/98 07/09/94 07/10!98 07/13/98 07/8/98 OFFICE NRR:AADT l
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NAME BSheron*
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DATE 07/14/98 07(D8
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.i July 24, 1998
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Mr. G.R. Horn 2
consensus standard, if successfully developed, in a ruiemaking to serve as an alternative method for licensees to meet NRC fire protection requirements. The Commission also directed the staff to continue to consolidate existing regulatory positions to generate a comprehensive fire protection regulatory guide to be used in meeting the existing fire protection regulations.
Any new fire protection rule would serve as an alternative method for licensess to meet NRC fire protection requirements. Therefore, it would not create an unstable regulatory environment, nor would it require plant resources to rebaseline plant programs unless a licensee voluntarily chooses to do so.
I appreciate your willingness to share your concerns with the Commission.
The staff is committed to continue to work v.ith the public and the industry during the proposed fire protection rulemaking. If you have any further questions, please do nct hesitate to contact me.
N g$ 8lp ed $
SamuelJ.Colks Samuel J. Collins, Director Offse of Nuclear Reactor Regulation
Enclosure:
As stated "This correspondence addresses policy issues previously resolved by the Commission, transmits factual information, DISTRIBUTION.
or restates Commission policy."
Public Central File SPLB R/F TJCarter (G980419)
LMarsh GHolahan SNewbeHy BSheron
.SWest PMadden EConnell DOudinot LWhitney JHolmes CBajwa PQualls MSalley SPLB Ticket File PMagnanelli(G980419)
SECY OGC EDO r/f OCA OPA CFO CIO JCallan AThadani HThompson PNorry JBlaha SBums MKnapp FMiraglia SCollins BBoger BTravers JRoe RZimmerman Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\\ HORN.WPD
'See previous concurrence To receive e copy of this document, Indicate in te9 box: "C" = Copy without attochment/ enclosure
- E' = Copy with attachment / enc (08ure T = Fiucopy 5FFICE lNRR:SPLBl NRR:SPLB l NRR:SPLB l
NRR:D:DSSA l Tech Editor l
NAME CBajwa*
SWest*
LMarsh*
GHolahan*
BCalure*
DATE 07/09/98 07/09/94 07/10/98 07/1Ls8 07/8/98 OFFICE NRRAADT' NR6 L f6 l
EQb.D Chairman
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NAME BSheron*
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ENCLOSURE
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June 30, 1998 OFFICE OF THE l
S E C RE TA R Y l
MEMORANDUM TO:
L. Joseph Callan Execu}ive irecpr for Operations Wv N-- -
FROM:
Jo C.. Hoyle, ecretary
SUBJECT:
STAFF REQUIREMENTS: SECY 98-058 - DEVELOPMENT OF 'A RISK-INFORMED, PERFORMANCE-BASED REGULATION FOR FIRE PROTECTION AT NUCLEAR POWER PLANTS The Commission approved the staff's proposal to defer development of a risk-informed, performance-based fire protection rule at this time and, instead, to pursue with the t 'ational Fire Protection Association (NFPA) and the nuclear industry the development of a risk-informed, and ultimately performance-based consensus standard for fire protection at nucidar power plants (Option 2 of SEGY-98-058). Under this approach, the NRC staff would endorse the consensus standard, if successfully developed, in a rukmaking to serve as an attemative method for licensees to meet NRC fire protection requirements. In implementing Option 2, the staff is directed to take the following actions-1 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, perfonnanoe-based approach is maintained. The staff is directed to update the Commission on the status of NFPA activities, providing an assessment of progress and direction (EDO)
(SECY Suspense:
11/1/96) 2.
Pursue rulemakin; to amend section ill-M mf Appendix R to 10 CFP Part 50 to eliminate the requirement for non-combustible penetration wal material and make othc..ainor changes to fire protectio.. regulations (EDO)
(SECY Suspense 11/1/98) i 3.
Closely examine plants whose individual plant examinatens for extemal events (IPEEEs) show fire ghi vulnerabilities to gain a tiiorough understandag of the parbcular risk contnbutors. In evaluatmg those facelshes, considersbon is to be given to the cumulative effects of exemptions to current regulations to ensure that an adequate 1
SECY NOTE-This SRM and the Commission Voting Record for SECY-g8-058 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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s Py level of fire protection is maintained Tne staff is directed to report to the Commission the resu'ts oflessons fearned from the IPEEE efforts.
(EDO)
(SECY Suspense:
5/30/99) 4.
Continue to consolidate existing regulatory positions to generate a comprehensive fire J
l protection regulatory guide to be used in meeting the existing fire protection regulations.
(EDO)
(SECY Suspense:
9/30/99) 5.
Summarize NRC's fire protection-related research sctivities conducted to date and seek Commission approval before initiating further research.
(EDO)
(SECY Suspense:
10/1/98) l l
6.
Inform the Commission on how and when the fire protection issues as listed in SECY-i 97-127 will be closed.
(EDO)
(SECY Suspense:
10/1/98)
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cc:
Chairman Jackson l
Commissioner Dicus Commissioner Diaz l
Commissioner McGaffigan OGC-l ClO l
CFO l
NA OPA OlG Office directors, regions, ACRS, ACNW, ASLBP (by E-Mail)
POR l
DCS l
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