ML18142A187

Comments on Generic Ltr 85-01 Re NRC Fire Protection Policy Steering Committee Rept.Elimination of Schedular Exemptions & More Aggressive & Expedited Enforcement Actions Fail to Recognize Nature of Fire Protection Issue

ML18142A187
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	02/14/1985
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton NRC OFFICE OF ADMINISTRATION (ADM), Office of Nuclear Reactor Regulation
References
85-113, GL-85-01, GL-85-1, NUDOCS 8502250434
Download: ML18142A187 (2)

Text

WULMM L STEWART Nuclear Operations Department Vice President Post Office Box 26666 Nuclear Operations OneJames River Plaza Richmond, Virginia 23261 Harold R, Denton, Director Office of Nuclear Reactor Regulation February 14, 1985 Serial No.

NO/JDH:pa VIRGINIA POWER 85-113 U. S. Nuclear Regulatory Commission Docket Nos.: 50/280/281 Washington, D. C. 20555 50/338/339 Attn: Document Control Desk License Nos.: DPR-32/37 NPF-4/7

Dear Mr. Denton:

VIRGINIA POWER COMMENTS ON THE NRC FIRE PROTECTION POLICY STEERING COMMITTEE REPORT (GENERIC LETTER 85-01)

Virginia Power appreciates the opportunity to comment on the NRC Fire Protection Policy Steering Committee's report. We have reviewed the policy recommendations and have general comments. Because the comment period was established in a Federal Register notice separate from the generic letter, we have had only limited opportunity to develop detailed comments. However, the comments offered below focus more on the approach we believe the Commission should take in achieving the fire protection goals stated in Mr, Dirck' s September 13, 1984, memorandum - expediting Appendix R compliance and assuring consistent levels of fire protection safety - than on the specific mechanisms for doing so.

We are not insensitive to NRC's resolve in achieving its stated goals; rather, we share them. Virginia Power has expended significant resources in improving fire protection safety at its four operating plants. Since October, 1983, we've spent $22 million on Appendix R and anticipate spending another $6 million. And, we share in the frustration of resolving the complex fire protection issues in a timely manner.

As an example of this frustration, the NRC conducted a series of Regional workshops in early 1984 to help resolve any misunderstandings associated with Appendix R requirements. The latest, and it was hoped, final guidance on the subject was to be issued subsequent to the workshops. This effort was welcomed by industry. Yet nearly a year later, the guidance continues to be revised, and has again been disseminated for comment as part of Generic Letter 85-01.

This example illustrates our primary concern: based on our experience, Appendix R (and fire protection in general) is a living, evolving issue that does not lend itself to definitive guidance nor swift compliance. We are both encouraged and concerned as a result of our review of the Steering Committee 1 *s policy recommendations that the NRC shares this view.

8502250434 850214 PDR ADOCK 05000280 F PDR

e Mr. Harold R. Denton We are encouraged by such recommendations as:

VIRGINIA POWER establishing referees to resolve significant differences that arise during inspections, inspection team workshops, expediting inspections to obtain a clearer understanding of the status of industry in achieving compliance, and designating a central point of contact within NRC to resolve internal conflict. We believe that recommenda-tions such as these reflect not only our experience with fire protection, but indicate that NRC also recognizes that guidance must continue to evolve, that interpretations will change, and that exceptions to the regulations will arise and need to be addressed.

On the other hand, we are concerned by such recommendations as: elimination of schedular exemptions, more aggressive and expedited enforcement actions, and more regulation (i.e. standard license conditions) and apparent new requirements (e.g. meeting GDC-1). We believe that recommendations such as these fail to recognize the nature of the fire protection issue. It is not reasonable to expect that fire protection issues will be resolved and compliance will be achieved solely through mandate. The history of fire protection in the nuclear industry provides ample evidence to support this.

Rather, they will be resolved and achieved through better understanding and continued active communication between NRC and industry. The issuance of the Steering Committee's policy recommendations for comment is a positive step in that direction and we encourage the NRC to continue in this manner.

Virginia Power is committed to assuring that our operating plants are capable of being safely shut down and maintained in a safe condition in the event of a fire. We have maintained active formal and informal communications with the NRC as we strive to resolve any remaining fire protection issues and meet the applicable requirements. We will continue in this manner, and we encourage the NRC to adopt the Steering Committee's policy recommendations that support resolution of fire protection issues through understanding and communications.

Very truly yours, W. L. Stewart cc: Dr. J. Nelson Grace Regional Administrator Region II Mr. Thomas E. Conlon Section Chief Plant Systems Section Region II