ML20206P380

Fire Protection Enforcement Guidance

ML20206P380
Person / Time
Issue date:	07/17/1986
From:	NRC
To:
References
PROC-860717, NUDOCS 8608270189
Download: ML20206P380 (2)

Text

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f July 17, 1986

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EG!! 86-04 Fire Protection Enforcement Guidance Qgg

1. General Guidance A. Fire protection requirements are delineated by 10 CFR 50 Appendix '

A General Des.ign Criterion 3,10 CFR 50.48,10 CFR :50 Appendix R, Facility License Conditions, facility technical specifications and other legally binding requirements, as applicable. A Notice of Violation will be issued for violation of reqatirements. ~

However, failure to meet fire protection commitments other than requirements will be designated as deviations.

8. Failures to meet reg'ulatory requirements for ' protecting trains of equipment required for achieving and maintaining safe. shutdown are serious violations. The specific violations should be~ reviewed individually and as a group to determine their root cause(s).

This guidance gives examples of violations at various severity levels and should be used to determine the appropriate enforcement action.

For purposes of this guidance, required structures, systems, and components are those which are necessary to achieve and maintain safe shutdown and which require the application of fire protection -

features as destribed in the licensee's fire hazards analysis

- report and NRC's safety evaluation report.

C. Fire protection violations may involve inoperable or inadequate:

fire barriers, separation, suppression or detection systems, repair parts, procedures or other conditions or items required to prevent fires, protect safe shutdown equipment during a fire or to restore safe shutdown equipment to service following an actual fire.

D. Numerous violations of fire protection requirements which individually may be classified at lower severity levels may cumulatively be classified at a higher severity level due to inadequate implementation of the fire protection program.

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g 82 g 9 860727

, 8608270189 PDR

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l Severity Categories A. Severity I. Violations of fire protection requirements established

' to protect or enable operation of safe shutdown equipment concurrent with an actual f4rs which damages that equipment such that safe shutdown could not be achieved or maintained.

B. Severity II. folations of fire protection requirements established to protect or enable operation of safe shutdown equipment such that a fire in the area would damage that equipment to the , extent that s_a.fe shutdown would not have been achieved and maintained.

C. Severity III. Violations.of fire protection requirements established to prctect or enable operation of safe shutdown equipment such that a fire in the area, in the absence of additional evaluation; could damage that equipment to the extent that safe shutdown could not have been achieved and maintained using the equipment identified in the fire hazards analyses for thfs purpose in accordance with applicable requirements. Failure to have an adequate written evaluation available for an area where compliance with Appendix R q

' is not apparent will be taken as an indication that the area does not comply with NRC requirements and may result in enforcement -

action at this Sever *ity Level.

D. Severity IV. Violations of one or more fire protection requirements that do not result in a Severity Level I, II, or III violation and which have more than minor safety or environmental significance.

E. Severity V. Violations of one or more fire protection requirements that have minor safety or environmental significance.

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