ML19329G038
| ML19329G038 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1980 |
| From: | Fontecilla H NRC COMMISSION (OCM) |
| To: | Hendrie J NRC COMMISSION (OCM) |
| References | |
| FOIA-80-303, FRN-45FR36082, RULE-PR-50 NUDOCS 8007110496 | |
| Download: ML19329G038 (2) | |
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{*g March 14,1980
.c MEMORANDUM FOR:
Comissioner Hendrie
. M. Fontecilla FROM:
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SUBJECT:
SECY-80 FIRE PROTECTION RULEMAKING 4
This paper requests Commission approval to publish for comment an amendment to 10 CFR Part 50. This would be a new Appendix (R) with fire protection requirements for nuclear power plants in operation prior to January 1,1979.
The staff has been trying to implement BTP 9.5-1 foi some time and has had reasonable success, but they are now left with some recalcitrant licensees objecting to some specific changes.
For this reason the staff has decided to include in the regulations all those generic requirements (as opposed to plant specific concerns) to which at least one licensee is opposed.
These include the requirements for the fire brigades (at least 5 members per shift),
their training and drills, requirements for safe shutdown systems, administration controls to minimize fires, alternate shutdown systems capabilities, fire.
. barriers, etc.
The staff obviously needs a tool that would' allow ther.. to settle these open items with the licensees once and for all.
One way to do this would be by issuing orders to individual licensees, but this would mean further arguing, possibly going to hearings, and consequent further staff *ff-efforts.
The other option is to include the requirements in the regulations as the staff recommends.
'I agree with this recommendation.
s Some paints in the staff's proposal, however, should be carefully considered.
(1)
The staff recommends allowing 30 days for public comments.
One could argue about the need for further comments considering that Reg. Guide 1.120 was issued for comments in 1976, revised acoordingly, and reissued for comments again in 1977.
However, it is hard to make a case for issuing these amendments now effective immediately a
considering the long time elapsed since Browns Ferry, issuance of the BTP, etc.
Commissioners Kennedy and Ahearne have g e along O{
with the 30 day comment period'but have emphasized that^ hould adhere to this schedule.
I agree.
(2)
Although the requirements in the proposed Appendix R are considered necessary by the Staff to satisfy GDC-3, they are by no means sufficient.
This is not clearly indicated in the proposed amendments.
Comissioner Kennedy ~ has also realized this and suggested an additional paragraph on page S/Sa that indicates the need to comply with both this rule and BTP 9.5-1.
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(3)
Implementation of the requirements in Appendix R is to be completed by November 1,1980, "or for good cause shown, the first refueling outage thereafter." The staff's intent is not to require shutdowns solely for the purpose of making fire protection modifications.
. F-The staff has by now pretty much committed itself to the November 1.-
1980 dateline and I see no way out of it.
I recommend concurrence with the proposed rule and Chairman Ahearne's and Comissioner Kennedy's proposed changes.
In view of the implementation date given in thi's rule and that Ahearne's office has indicated that the Chairman will not accept anythi short of the November 1 implementation date, I have indicated our concurrence 3 h the UCS order as revised by Commissioner Kennedy but adding "or the first refueling outage thereafter" for consistency.
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'cc: Mr. Dorie Mr. Hassell'
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