ML20151C519

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Forwards Info Re Differing Prof Opinion on Fire Protection Rule.Nrc Should Request That Licensee Submit,In Writing, Deviations from Branch Technical Position & App R.W/O Encl
ML20151C519
Person / Time
Issue date: 02/02/1981
From: Noonan V
Office of Nuclear Reactor Regulation
To: Vollmer R
Office of Nuclear Reactor Regulation
Shared Package
ML19284B784 List:
References
REF-10CFR9.7 NUDOCS 8103160943
Download: ML20151C519 (1)


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MEMORANDUM FOR:

Richard H. Vollmer, Director Division of Engineering FROM:

Vincent S. Noonan, Assistant Director Materials & Qualifications Engineering SUBJECTi DIFFERING PROFESSIONAL OPINION ON FIRE PROTECTION RULE By this memorandum I am forwarding to you three enclosures on the abe.e c

subject.

Enclosures'1 and 2, dated January 5 and January 26, are Robert Ferguson's differing professional opinion on fire protection rule and, dated January 26, is Victor Benaraya's response to Mr. Ferguson'as required by the NRC policy on differing professional opinions.

Mr.-Benaroya is Mr. Ferguson's immediate supervisor.

j I personally met with Mr. Ferguson and Mr. Benaroya on this subject :: nelp me better understand the exact nature of Mr. Ferguson's concerns and to offer a proposal. addressing his' concerns which I felt would satisfy his objections.

At the present time all. safety evaluations on fire protection are re. iring the ifcensee to be in full compliance with the General Criterion 3 of Appen'Jix A to 10 CFR Part 50, the Branch Technical Position (BTP) and Appendix R.

In addition, I would also propose that we request from re licensu, in' writing, any deviations from the BTP and Appendix R for v.eir-This list of deviations could also be made as a cc-:ition particular plant.

that, prior to full power operation, the licensee would state that n: cevi-ations exist or submit to the staff the list of deviations for the stdf's review and concurrence.

In sumary, I do not believe Mr. Ferguson or myself are really in disa;ree-ment but we probably do not fully agree on the method of implementati:- cf

- the new fire protection rule which is scheduled for completion July 1,1932.

Until the rule is drafted and published I believe my proposal on har.d'ing the plants that we license prior to issuance of the rule would give :.e staff reasonable assurance regarding the licensee's pliance to tt:e fire protection issue.

O se N nan, Assistant Directer

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Materials & Qualifications Engineering Division of Engineering

Enclosures:

As stated "t

P00R ORIGINM V. Benaroya R. Ferguson 81031609.43

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