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c9 UNITED STATES 4 .! ,, j NUCLEAR REGULATORY COMMISSION
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'.....' DEC 2 81934 MEMORANDUM FOR: Victor Stello, Deputy Executive Director for Regional ;
Operations and Generic Requirements Richard DeYoung, Director )
Office of Inspection and Enforcement 1 FROM: Richard H. Vollmer, Director ;
Division of Engineering l
SUBJECT:
COMMISSION PAPER ON FIRE PROTECTION By niemo dated December 10, 1984 Mr. Dircks made certain assignrents leading to the preparation of a Comission paper which would (1) address fire protection activities to date; (2) address the specific questions in that memo; and (3) provide specific fire protection recomendations for Comission approval. Although NRR has the lead for preparation of the Com-mission paper, your input is needed. In particular, your answers to questions 1 7 on page one and IE's response to item 3 on page two is requested by February 15, 1985 to meet the revised target of March 15 for sending the paper to CRGR. .
NRR will take the lead on items 1, 2 and 4 with assistance from IE and ELD. The Steering Committee report is being sent to the PDR and interested parties for a 30-day coment period. We are aiming at February 15 for analysis of public coments and evaluation of risk associated with fire from operating plants. We will keep you infomed as these activities progress.
1 Please identify, by January 7, 1985, your contact for this work. l l
ichard H. Vollmer, Director Division of Engineering Office of Nuclear Reactor Regulation ec: See r. ext page
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! Q NUCLE AR REGULATORY COMMISSION wasmorow, o. c. nsas O
(*****/ NOVI9 nyy MEMORANDUM FOR: Victor Stello, Jr., Deputy Executive Director for Regional Operations & Generic Requirefnents FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
NRR COMMENTS ON REC 0m ENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS This Office has reviewed the report of the Fire Protection Policy Steering Comittee and supports the conclusions and recomendations 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 free several individual staff members as well as from NRR Divisions. The most common 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 "Interpretations." Suggestions received to improve the wording of portions of the package to be sent to the licensees are collected in the enclosure.
Several of the proposed regulatory 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.
/ n Harold R. Denton, Director Office of Nuclear Reactor Regulation
Enclosure:
NRR Coments cc: W. Dircks R. Vollmer I
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Enclosure l A. Generic Letter Paragraph C: substitute a fire hazards analysis for an evaluation in three places -- for clarification and consistency.
Paragraph D: It should be pointed out that the fire protection quality assurance program is part of the fire protection plan required by 10 CFR 50.48. The guidance for an acceptable QA program should also reference Appendix A of BTP APCSB 9.5-1, and the supple-mentary guidance footnoted in 20 CFR 50.48 for plants licensed prior to 1979.
1 B. Interpretations
- 4. Fire Area Boundaries 3hdline: suggest changing important to safe shutdown.
7th line: add specifically before approved.
10th line: substitute a fire hazards analysis for an evaluation.
- 5. Automatic Detection and Suppression
. Paragraph 2, line 6i Substitute a fire hazards analysis for an evaluation.
C. Appendix R Questions and Answers A number of suggestiuns were received to improve consistency with other parts of the document and to improve clarity. Because these suggestions are clerical in nature, 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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