ML20128B598
| ML20128B598 | |
| Person / Time | |
|---|---|
| Issue date: | 11/27/1992 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Morris B NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| References | |
| RTR-REGGD-XX.XXX, TASK-DG-3006, TASK-RE NUDOCS 9212040027 | |
| Download: ML20128B598 (6) | |
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NUCLEAR REGULATORY COMbilSSION
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0 Ngs y 611 RY AN PL AZA DRIVE, $Ulf L 400 AHLING N, E, AS 118(Mia MEMORANDUM FOR: Bill M. Morris, Director Division of Regulatory Applications Office of Nuclear Regulatory Research FROM: L. J. Callan, Director Division of Radiation Safety and Safeguards
SUBJECT:
REVIEW Of DRAFT REGULATORY GUIDE Attached are our brief comments on draft Regulatory Guide DG-3006, " Standard format and Content for fire Protection Sections of License Applications for fuel Cycle facilities." Please direct any questions to Charles Cain (817-860-8186) or Mike Vasquez (817-860-8121) of my staf f.
,. / .t l tII L. J. 'allan, Director Divis on of Radiation Safety and Safeguards Enclosure I
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Bill M. Morris t bec:
DMB - Original (IE-07)
JLMilhoan LJCallan JPJaudon WLFisher CLCain GMVasquez NMls MIS System RIV Files (2)
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Region IV Comments on DRAF1 REGULATORY GUIDE DG-3036 STANDARD FORMAT AND CON?ENT FOR FIRE PROTECTION SECTIONS Of LICENSE APPLICATIONS FOR FUEL CYCLE TAClllTIES This guide is written in rather general termr, with little substantive guidance to licensees. Essential elements discussed in the BIP (54 fR 11590-88) dated August 10, 1992, should be included in the regulatory guide.
Also, some of the information in Inspection Procedure 88055, " Fire Protection," should be discussed in the regulatory guide. The regulatory guide could be the single document that describes the minimum information that NRC expects its licensees to submit and/or address, without being overly prescriptive. The inf ormation contained in the inspection procedure should be similarly discussed in the regulatory guide so that there is no discontinuity between what NRC inspectors review and what licensees understand to be required.
for exampla, licensee facilities were built to various National fire Protection Association (NFPA) codes and standards. The licensees should submit information regarding which NFPA codes the licensee will implement.
Therefore, the Reg Guide should discuss this.
The regulatory guide should contain more substantive information regarding the minimum information NRC would like to see in license applications for topics such as:
- NFPA codes and standards,
- program management and documentation,
- licensees should be asked to commit to the latest NFPA codes and standards when modifying processes or constructing new buildings,
- precautions for flar.;mable and corrbustible liquids and gases,
- precautions for machining operations of combustible metals,
- precautions for incinerators, boilers, boiler furnaces, and stationary combustion engines,
- precautions for storage and handling of flammable and combustible liquids and gases,
- hot cells and glove boxes,
- acceptable fire detection and alarm systems, and maintenance.
- acceptable fire suppression equipment, and maintenance,
- fire protection water systems, and maintenance
- elements of a fire hazard analysis,
- minimum requirements for a fire brigade (NfPA 600)
- personnel egress,
- laboratories, During the past two years, NRC inspections have discovered numerous problems in certain licensee programs. Some of these problems have shown that licensee programs did not contain certain minimum elements, and no guidance existed
4 that discussed minimum program elements. Therefore, it is recommended that more substantive information be included in the regulatory guide.
Additionally, the cover memorandum from Mr. Morris noted that he was interested in our viewpoint on whether this guide is necessary at this time, given the publication of the BTP in the federal Register on August 10, 1992.
In our view, the regulatory guide is not essential at this time, since the BTP has been issued. Licensees should be asked to address the BTP during the licensing process. This process would allow NRC time to develop a quality regulatory guide,
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Bill M. Morris bec:
DMB - Original (IE-07)
JLHilh. n LJCallan JPJaudon WLFisher CLCain GMVasquez NMIS MIS System RIV Files (2)
RSTS Operator REHall, URF0 -
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RIV:NMISilAE_ C:NMIS be D:DRSkk' GMVasquez CLCain LJCallan II /r7/92 ll /77/92 11/d/92
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