ML20236V956
| ML20236V956 | |
| Person / Time | |
|---|---|
| Issue date: | 07/27/1998 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Ralph Beedle NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9808040310 | |
| Download: ML20236V956 (7) | |
Text
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4 UNITED STATES j
NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 2055M001
- ,o July 27, 1998 Mr. Ralph E. Beedle Senior Vice President and Chief Nuclear Officer Nuclear Energy institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708
Dear Mr. Beedle:
I am responding to your letter of May 5,1998, to Chairman Jackson of the U.S. Nuclear Regulatory Commission (NRC) regarding the development of a new fire protection rule and fire protection requirements. In your letter, you reaffirm the industry's position that a new rule for fire protection offers no safety benefits, suggest specific areas that w0t!d benefit from increased attention if the ru!emaking is canceled, and summarize the actions that could lead to more effective and efficient fire protection programs if the rulemaking proceeds.
In a staff requirements memorendum dated September 11,1997, the Commission directed the staff to brief the Commission on industry feedback regarding the proposed rulemaking. On November 5,1997, representatives of the Nuclear Energy Institute (NEI) met with the NRC staff and 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 submitted the results of this survey in a letter dated December 11,1997, to the Executive Director for Operations.
In SECY-98-058, "Developmr :t of a Risk-informed, Performance-Based Regulation for Fire Protection at Nuclear Power Plants," the staff submitted the results of the survey to the
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Commission and, on the basis of the feedback received, proposed three options related to the i
fire protection rulemaking effort for the Commission's consideration. These options incorporated the industry position, which you reiterate in your May 5 letter. Specifically, SECY-98-058 stated that the industry opposed any rulemaking, and that if the rulemaking proceeded, industry preferred an approach that retains the option of continued compliance with existing regulations, including approved exemptions. It further stated that new or revised guidance would be provided in areas that the public, the staff, and the industry determined need clarification and also indicated that the staff would work with the National Fire Protection Association and the industry to develop a performance-based, risk-informed consensus j
l standard for fire protection for nuclear power plants. SECY-98-058 also addressed the other points you made about fire protection rulemaking and about consolidating and clarifying existing staff guidance.
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2 The Commission, in voting on the subject, directed the staff to continue to work with the industry toward the development of a risk-informed, performance-based, consensus standctd for fire protection which could be endorsed by the NRC. In doing so, the Commission anticipated i
endorsement of the consensus standard through a rulemaking, which would provide a voluntary alternative to existing regulations. Additionally, the Commission directed the staff to continue its current effort to develop comprehensive regulatory guidance for existng fire protection requirements.
Therefore, the Commission is fully aware of the industry's position on the fire protection rulemaking. Your May 5 letter further reinforces the industry's position. The staff has worked in l
cooperation with the public and the industry in its proposed fire protection activities and is committed to continuing this cooperation in the future.
In your letter to the Chairman you also raised the issue of firc-induced circuit failures. In a letter to you dated March 17,1997, I provided the staff positions regarding such failures and informed you that the staff would consider the need to take further action to ensure that licensees understand and comply with the applicable regulatory requirements. Since then, the staff has developed the " Circuit Analysis Resolution Plan" (CARP) to track and manage its actions to resolve this issue. Under the CARP, which the NRC staff has provided to your staff, the staff will alert licensees to potential problems associated with fire-induced circuit failures and spurious actuations. This will be done through an information notice that will be issued in the near term.
As a longer term action the staff will clarify the regulatory requirements and consolidate existing staff positions. This may be done through a generic letter. The staff will continue to interact with NEl and the licensees on this issue.
Sincerely, s
ctor Office of Nuclear Reactor Regulation l
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2 Tha Commission, in voting on th] subj:ct, dircct:d the staff to continua to work with ths industry tow rd tha dev;lopm:nt of a risk-inform:d, performance-bas d, consansus standard for firs protection which could be endorsed by the NRC. In doing so, the Commission anticipated endorsement of the consensus standard through a rulemaking which would provide a voluntary l
alternative to existing regulations. Additionally, the Commission directed the staff to continue its current effort to develop comprehensive regulatory guidance for existing fire protection requirements.
Therefore, the Commission is fully aware of the industry's position on the fire protection rulemaking. Your May 5 letter further reinforces the industry's position. The staff has worked in l
cooperation with the public and the industry in its proposed fire protection activities and is committed to continuing this cooperation in the future.
In your letter to the Chairman you also raised the issue of fire-induced circuit failures. In a letter to you dated March 17,1997, I provided the staff positions regarding such failures and informed you that the staff would consider the need to take further action to ensure that licensees understand and comply with the applicable regulatory requirements. Since then, the staff has developed the " Circuit Analysis Resolution Plan" (CARP) to track and manage its actions to resolve this issue. Under the CARP, which the NRC staff has provided to your staff, the staff will alert licensees to potential problems associated with fire-induced circuit failures and spurious actuations. This will be done through an information notice that will be issued in the near term.
As a longer term action the staff will clarify the regulatory requirements and consolidate existing staff positions. This may be done through a generic letter. The staff will continue to interact with NEl and the licensees on this issue as appropriate.
Sincerely, 5
Samuel J. Collins, Director Office of Nuclear Reactor Regulation DISTRIBUTION Public Central File SPLB R/F TJCarter (G980314)
LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinot LWhitney JHolmes CBajwa PQualls MSalley PMagnanelli (G980314)
SECY OGC EDO OCA OPA CFO CIO JCallan AThadani HThompson PNorry JBlaha SBurns MKnapp FMiraglia LTCallan BBoger BTravers JRoe RZimmerman Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\\BEEDLE.WPD *See previous concurrence SPLB:DSSA SPLB:DSSA SPLB:DSSA D:DSSA DOudinot:lk:rmc*
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5/15/98 5/15/98 5/15/98 5/18/98 l
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Therefore, the Commission is fully aware of the industry's position on the fire protection rulemaking. Your May 5 letter further reinforces the industry's position. The, staff has worked in i
cooperation with the public and the industry on the proposed fire protection rulemaking and is committed to continuing this cooperation in the future in your letter t the Chairman you also raised the i ue of fire-induced circuit failures. In a letter to you dated M ch 17,1997, I provided the sta positions regarding such failures and informed you that the staff uld consider the need to t e further action to ensure that licensees understand and com with the applicable, regulatory requirements. Since then, the staff has developed the " Circuit alysis ResolutioryPlan" (CARP) to track and manage its actions to l
resolve this issue. Unde he CARP, w h the NRC staff has provided to your staff, the staff will l
alert licensees to potential oblems sociated with fire-induced circuit failures and spurious actuations. This will be done rou an information notice that will be issued in the near term.
As a longer term action the sta I clarify the regulatory requirements and consolidate existing staft positions. This may be do rough a generic letter. The staff will continue to interact with NEl and the licensees on this ' sue s appropriate.
Sincerely, n;uel J. Collins, Director O
e of Nuclear Reactor Regulation DISTRIBUTION:
Public Central File SPLB R/F TJCarter (G980314)
LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinot LWhitney JHolmes CBajwa PQualls MSalley PMagnanelli (G98G314)
SECY OGC EDO OCA PA CFO ClO JCallan A adani HThompson PNorry JBlaha SBu s MKnapp FMiraglia LTCallan BBoge BTravers JRoe RZimmerman Chairma Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan DOCUMENT NAME: A:\\BEEDLE.WPD *See previous concurrence SPLB:DSSA SPLB:DSSA SPLB:DSSA D:DSSA DOudinot:lk:rmc*
KSWest*
LBMarsh*
GMHolahan*
5/15/98 5/15/98 5/15/98 5/18/98 TECH AADT:NRR
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SCollins*
5/15/98 5/19/98 5 /9 5/27/98 Chairman Jackson 5 @8
} /27/9 8 OFFICIAL RECORD COPY i
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i Mr. Ralph E. Beedle 2
l Therefore, the Commission is fully aware of the industry's position on the fire pr ion rulemaking. Your May 5 letter further reinforces the industry's position. The has worked in cooperation with the public and the industry on the proposed fire protection emaking and is committed to continuing this cooperation in the future.
Sincerely, l
l Samuel J. Copins, Director Office of Nuclear Reactor Regulation
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DISTRIBUTION:
Public Central File
/SPLB R/F TJCarter (G980314)
LMarsh GHolahan
/ SNewberry BSheron SWest PMadden
/
EConnell DOudinot LWhitney JHolmes
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JCallan AThadani HThompson PNorry JBlaha SBurns MKnapp F,Miraglia LTCallan BBoger BTravers dRoe RZimmerman Chairman Jackson j
Commissioner Dicus Commissioner Diaz Commissioner McGaffigan
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DOCUMENT AME: A:\\BEEDLE.WPD *See previous concurrence
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Therefore, the Commission it fully aware of the industry's position on the fire protection rulemaking. Your May 5 letter further reinforces the industry's position. The staff has worked in cooperation with the public and the industry on the proposed fire protection rulemaking and is l
committed to' continuing this cooperation in the future.
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Sincerely, N
x Samuel J. Collins, Director l
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Office of Nuclear Reactor Regulation
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DISTRIBUTION; Public Central File \\
SPLB R/F TJCarter (G980314)
LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinnt LWhitney JHolmes N
CBajwa PQualls MSalley PMagnanelli(G980314)
\\OCA OPA CFO C;O JCallan AThadani HThompson PNorry JBlaha SBurns MKnapp FMiraglia LTCallan BBoger BTravers JRoe RZimrnerman Chairman Jackson Commissioner Dieus Commissioner Diaz Commiss ner McGaffigan DOCUMENT NAME: A:\\BEEDLE.WPD *See previous concurrence SPLB:DSSA SPLB:DSSA SPLB:DSSg 4 D:DSSA DOudinot:lk:rmc' KSWest LBMarsh //f GMHolahan 5/15/98 5//i/98 5/6/98 5/ /98 TECH AADT:NRR DD:NRR D:NRR EDITOR
- BSheron FJMiraglia SCollins 5/15/98 5/ /98 5/ /98 5/ /98 EDO Chairman Jackson j
5/ /98 5/ /98 OFFICIAL RECORD COPY l
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Mr. Ralph E. Beedle 2
N iherefore, the Commission is fully aware of the industry's position on the fire protection rulem,aking. Your May 5 letter further reinforces the industry's position. The staff has worked in cooperation with the public and the industry on the proposed fire protection rulemaking and is commitled to continuing this cooperation in the future.
Sincerely, j
L. Joseph Ca n Executive Director for Operations DISTRIBUTION:
Public Central File.
SPLB R/F TJCarter (G980314)
LMarsh GHolahan SNewberry BSheron SWest PMadden EConnell DOudinot LWhitney JHolmes CBajwa PQualls MSalley PMagynelli(G980314)
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