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UNITED STATES g
NUCLEAR REGULATORY COMMISSION 3
l WASHINGTON, D. C. 70%5 JUL 171986 EGM 86-04 MEMORANDUM FOR:
Thomas E. Murley, Regional Administrator, Region !
J. Nelson Grace, Regional Administrator, Region II James G. Keppler, Regional Administrator, Region III Robert D. Martin, Regional Administrator, Region IV John B. Martin, Regional Administrator, Region V i
FROM: James M. Taylor, Director I Office of Inspection and Enforcement {
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SUBJECT:
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ENFORCEMENT GUIDANCE ON FIRE PROTECTION j
l By memorandum dated March 7,1986 from S. J. Chilk to V. Stello the staff was directed to revise its proposed fire protection Severity Level guidelines so they are consistent with 10 CFR Part 2.
The Commission was concerned that the proposed guidelines required an actual fire for Severity Levels I and II. i After receiving regiohal coments on proposed revisions dated April 17, 1986, the staff has further revised the guidance and is now issuing it for implementation.
You should now begin to process any fire protection cases you have pendin using this enclosed guidance, and submit the cases to IE .for concurrence.g Fire protection cases that have already been submitted should be reevaluated in accordance with the guidance and resubmitted.
n a s M. Tay w -
r, Director
' ice of Inspection and Enforcement 1
Enclosure:
As stated R. Vollmer, NRR i
i pg 4. ?? -4I O G//6 8712310065 871224 PDR FOIA GUILDB7-450 PDR
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Fire Pettection Enforcement Guidance
- 1. General Guidance A.
l Fire protection requirements are delineated by 10 CFR 50 Appendix A General Design 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 De issued for violation of requirements.
However, failure to meet fire protection commitments other than requirements will be designated as deviations.
B.
Failures to meet regulatory 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 detennine 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 wnich require the application of fire protection features as described in the licensee's fire hazards analysis report and NRC's safety evaluation report.
C.
Fire protect' ion 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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Severity Categories-A. Severity I. 1 Violations of fire prctection requirements established to protect or enable operation of safe shutdown equipment concurrent {
with an actual fire which damages that equipment such that safe shutdown 'l could not be achieved or maintained.
B. Severity 11.
Violations 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 safe 1 snutdown would not have been achieved and maintained, i
C.
Severity 111. Violations of fire protection requirements established to protect or enable operation of safe shutdown equipment such that a fire in the area, in the absence of additional evaluation, could danage that equipment to the extent that safe shutdown could not have been achieved and maintained using the equipment identified ir. the fire hazards analyses for this purpose in accordance with applicable requirements. Failure to have an adequate written evaluation available for an area where compliance with Appendix R 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 Severity Level.
D. Severity IV.
Violations of one or nore fire protection requirements that do not resuit 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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