ML20151K518
| ML20151K518 | |
| Person / Time | |
|---|---|
| Issue date: | 11/19/1984 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151H089 | List:
|
| References | |
| FOIA-88-92 NUDOCS 8411290166 | |
| Download: ML20151K518 (2) | |
Text
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NOV 19 7984 MEMORANDUM FOR: Harold R. Denton, Director-Office of Nuclear Reactor Regulation FROM: William V. Johnston, Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
SUBJECT:
COMMENTS ON RECOMMENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS At your request, I have solicited coments on the Fire Protection Policy Steering Comittee Report in order to prepare a response from you to Mr. Stello. Coments were obtained from the fire protection engineers in DE and from DL and DSI.
Coments on the body of the report werp mostly concerned not with policy but with whether sufficient resources %ere available to support the pro-posed inspections, changes to.the Technical Specifications and the imple-( mentation of a standard fire protection condition. One group questioned the need for the expedited inspection program and the referee to resolve differences, mentioning both resource availability and satisfaction trith the current processes. The Division of Licensing recomended that resource impacts be evaluated before a decision is made on this policy. In subsequent discussions with Mr. Vollmer, I learned that resource impacts on DE and DSI will likely be less than the commentators anticipate. A suggested resolution of the DL concerns is provided in the third paragraph of the memo to Mr. Stello.
Coments on the Generic Letter consisted of a question of whether the package truly reflected Comission policy and two suggestions for claritication of portions of the document. The first coment was not incorporated because the Generic Latter will not be issued until it has received Comission review.
The suggestions for clarification are included in the enclosure to the memo to Mr. Stello. 1 Those persons supporting the DP0 continue to express disagreement over the i issuance of pa.rts four and five of the "Interpretations." Sever 0 suggestions I to improve specificity were made and are incorporated in the 4 osure. {
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No substantive coments were received on Enclosures four and five. '
Several suggestions were made to shorten the answers to the questions posed in Enclosure six by deleting quotations from the Branch Techni:a1 Positions.
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Harold R. Denton -2 This suggestion was considered and rejected previously by the Working Group and because it appears to reflect personal preferences more than technical concerns the suggestions are not incorporated. A number of !
suggestions were received which improve consistency with other parts of '
the document and in. prove clarity. Because these suggestions are cl.erical in nature, a marked up copy of the Appendix R Questions and Answers will be given to the Steering Committee for their use prior to issuing the document. '
I In summary, we conclude that, assuming the resolution of the comments dis-cussed above is acceptable, the Report of the Fire Protection Policy Steering Committee should be supported by NRR. A suggested memorandum of support is -
attached.
'Q/jf.je.m [/- bt+3.2.s William V. Johnston, Assistant Director Materials, Chemical & Environmental
,- Technology Division of Engineering J:
Enclosure:
Proposad Memo to V. Stello cc: R. Vollmer -
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MEMORANDUM FOR: Victor Stello, Jr., Deputy Executive Director for .
Regional Operations & Generic Requirements FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
NRR COMMENTS ON RECOMMENDED FIRE PROTECTION POLICY AND ,
PROGRAM ACTIONS This Office has reviewed the report of the Fire Prott: tion' Policy Steering Comittee and supports the conclusions and recommendations contained therein.
We believe that implementation of these recomendations will be helpful in furthering the Comission's objectives of timely and appropriate compliance with Appendix R to 10 CFR 50.
In the course of our review, we received coments fron several individual staff members as well as from NRR Divipions. The most comon divergent opinion concerned not policy but whetHer sufficient resources can be made ~
available to support the proposed inspections and changes to Technical Specifications. Those persons supporting the DP0 continue to express dis-( agreement over the issuance of the "Interpre,tations." Suggestions received to improve the wording of portions of the package to be sent to the licensees are co14ected in the enclosure.
Several of the proposed regu'c cry actions are not included in our FY 84 Operating Plan. After we have further developed the amount of resources required for implementation, we may request an adjustment to the Operating Plan.
/ w Harold R. Denton,~ Director Office of Nuclear Reactor Regulation
Enclosure:
NRR Coments cc: W. Dircks R. Vollmer r
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T..d : .rc A. Gercric Letter Paragraph C: . substitute a fire hazerds analysis for an evaluation in three plese's -- for cieriilcatlur. una consistency. .
Paragraph D: It shculd te pointed out that the fire protection .,
c,uclity acsurancs program is part of the fire protection plan required by 10 CFR 50.48.- The guidance for an acceptable 'QA program should also reference Appar. dix A of BTP APCSB 9.5-1, and the supple-mentary guidance footnoted in 10 CFR 50.48 for plants licensed prior to 1579 - '
B. Interpretations
- 4. Fire Area Boundaries 3rd line: suggest changing important to safe shutdown.
7th line: add specifically before toproved. '
10th line: substitute a fire haveds analysis for an evaluation.
- 5. Automatic Detection and Supdf%ssion Paragraph 2, line 6: Substitute a fire hazards analysis for
( an evaluation.
C. Appendix R Questions and Answers A number of suggestions were received to improve consistency with other parts of the document and te improve clarity. Because:these suggestions are clerical in r.ature, a marked up copy of the Questions and Answers will be given to the Steering Committee for their use prior to issuing the document.
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