ML20151C527
| ML20151C527 | |
| Person / Time | |
|---|---|
| Issue date: | 02/06/1981 |
| From: | Ferguson R Office of Nuclear Reactor Regulation |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19284B784 | List: |
| References | |
| REF-10CFR9.7 NUDOCS 8103160951 | |
| Download: ML20151C527 (4) | |
Text
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A FEB D 61551 MEMORANDUM FOR: Richard H. Vollmer, Director Division of Engineering FROM:
Robert Ferguson, Section Leader Fire Protection Section Chemical Engineering Branch Division Engineering
SUBJECT:
DIFFERING PROFESSIONAL OPINION - FIRE PROTECTION RULE 1
SUFPLEMENT 2 Ycur memorandum to me, dated February 4, 1981, on this subject requested my
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concurrence or comments on the following proposals:
All plants now scheduled to be licensed to operate after September 30, 1.
1981 would be required to identify deviations from NRC fire protection acceptance criteria. Such deviations would be specifically evaluated in the staff SER prior to licensing.
All plants licensed to operate between January.1, 1979 and September 30, 2.
1981 would not be required to identify such deviations as long as the staff can conclude that the acceptance criteria have been met.
All plants licensed to operate would be required to meet a new rule which 1
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we plan to issue for coment on or about July 1982. This rule would contain the assemblage of present accep ince criteria in the form of requirements. The requirements would be applied to new CP applications and to OL applications on a reasonable schedule. Consideration would be given to backfitting on all operating plants.
To identify the issues, I propose a course of action to achir$e the same goal, i.e., a rule which states NRC fire protection requirements (Jr all operating plants, as follows:
All plants licensed to operate after January 1, 1979 would be required to A.
rest the requirements of Appendix R to 10 CFR Part 50 on the same basis as those licensed before that date.
All plants licensed to operate would be required to meet a new rule B.
(Appendix d) which we plan to issue for coment on or about July 1981.
This rule would contain the asse.blage of present acceptance criteria in the form of requirements. The requirements would be applied to new CP Further ap,lications and to OL applications on a reasonable schedule.
t,ackfitting would not be necessary because it has already been accomp-lished under A above.
8103160951
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Richard H. Vc11mer If the flRC determines that o t
h would be added to. Appendix R,ther requiremen s are necessary, t ey C.-
to 10 CFR 50 annually or as they are-developed, whichever is longer.
From the above, it appears'that there is concurrence on the end goal.
I recon =end rey The issue concerns the method used to achieve the goal.
method because:
I All licensees and applicants are given early notice of our requirements l
with a minimum of staff effort.
This early notice allows applicants to meet the requirements with a minimum of effort because they know the requirements early in the design.
By providing better separation.at this time,they can reduce the need for some automatic suppression systems and extra barriers and also assure the survival of more shutdown systems for any fire.
Fewer modifications will be required late in construction when they are more costly and usually do not provide as much margin as original design features.
The burden of providing adequate fire protection is placed on the licensees and can be readily checked and assured by the f;RC Inspectors with a minir:
Jm of effer.t.
It is easier for the staff to accomplish since we still have the personnel that are familiar with our fire protection requirements and the rulemaking If we wait until July 1982, we cay have new personnel. Using procedures.
new personnel.with little or.no experience in dealing with the pr:blems encountered over the past.several years, I doubt that the proposed schedule of July 1982 could be met.
M w,.d s
Robert L. F g ason, Section Leader Fire Prote tic i Section Chemical EngV eering Branch Division of Engineering cc:
H. Denton E. Case
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ENCLOSURE 2 SAMPLE RULE ON FIRE PROTECTION FOR FUTL':.E PLANTS
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INTRODUCTION AND SCOPE all CP and OL applications for
_ This Appendix applies to nuclear power electric generating g
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stations on a schedule yet to be determined.
With respect to certain generic issues fcr su:5 facilities, it sets forth fire protection features required to satisfy Criterion 3 of Appendix A to this part.
Criterion 3 of Appendix A to this part spe:if'es that "Stru::gres, systems, and components important to safety shall be designed and iccated to minimize, consistant with other safety requirteents, the ;rota:ility and effect of fires and explosions."
When considering the effects of fire, these systems ass::iated with achieving and maintaining safe shutdewn conditi:.s ass.::e za.'or #r :rtance to safety be:ause damage to them can lead to core ca: age resulti.; frem
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loss of coolant through hoiloff.
The phrases "important to safety," or " safety-eiated," will :s used throughout this Appendix R as applying to all safety f.netions. T e phrase
" safe shutdown" will be used throughout this A;;ar:ix R as a;;1yir; to both hot and cold shutdcwn functions.
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