ML20203F223
| ML20203F223 | |
| Person / Time | |
|---|---|
| Issue date: | 10/25/1985 |
| From: | Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Davis A, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20203F188 | List: |
| References | |
| NUDOCS 8604250085 | |
| Download: ML20203F223 (3) | |
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ass UNITED STATES
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, , p *,, NUCLEAR CECULATORY COMMissi;N 3 , S- CE2 TON lli O j m noosevett mono y cor~ ruva. itu~ois .om OCT25 585 MEMORANDUM FOR: James G. Keppler, Regional Administrator A. Bert Davis, Deputy Regional Administrator THRU: { Carl J. Paperiello, Director Division of Reactor Safety, Luis A. Reyes, Chief, Operations Branch, Division of Reactor Safety William G. Guldemond, Chief Operational Programs Section, Operations Branch, Division of Reactor Safety FROM: Joseph M. Ulie, Reactor Inspector Operational Programs Section. Operations Branch, Division of Reactor Safety
SUBJECT:
REQUEST BY THE COMMISSIONERS FOR THE DP0 ORIGINATORS TO WRITE A
SUMMARY
STATEMENT REGARDING THEIR POSITION ON THE FIRE PROTECTION POLICY STEERING COMMITTEE'S PROPOSED RESOLUTION TO THE DP0 f, During the Comission Meeting of October 3,1985, held to discuss the " Staff Recomendations Covering the Implementation of Appendix R to 10 CFR 50,"
y the Comissioner's requested the DP0 originators to write a sumary statement regarding their position on the Fire Protection Policy Steering Comittee's proposed resolution to the DPO.
The staff DP0 is primarily concerned with Section 4. Fire Area Boundaries and Section 5, Automatic Detection and Suppression, of the Interpretations of Appendix R.
In being a co-signor of the DP0, my intentions were to bring to NRC management attention that the Interpretations (allowing penetrations in fire area boundaries; allowing partial area coverage for fire suppression and detection based on an analysis; and not requiring submitting of this analysis for prior staff review including the filing of exemption requests prior to the time of the inspection) was a significant change to NRC policy.
As stated at the Comission meeting of October 3,1985, the staff indicated that the " Interpretations" are a change to NRC policy practice in that Generic Letter 83-33 would no longer be in effect.
Based on NRC management's understanding of this change in operating philosophy relative to 10 CFR Part 50, Appendix R and its possibTe resulting affect on already approved fire protection programs including pending" enforcement actions. I believe my concerns regarding the DP0 are croplete.
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James G. Keppler 2 2 5 1335 Regarding Section 5 of the Interpretations document, as identified in Section 8.9 of Enclosure 6 of the Steering Comittee's "Recomended Fire Protection Policy and Program Actions", dated October 26, 1984, those plants who state that their design " meets the NFPA Codes" or " meets the intent of the NFPA Codes" are expected to have their system designs confom to the code if deviations from the code are not identified in the FSAR or FHA. This interpretation, which .-
relates specifically to the DPO, provides guidance for the NRC and licensee staff (s) to follow in meeting 10 CFR Part 50.48(a) in addition to meeting 10 CFR Part 50. Appendix R requirements (in accordance with the Interpretations partial area coverage for fire suppression and detection systems is allowed for specific protection against hazards of safety related equipment based on an adequate analyses). Based on my interpretation of the Steering Comittee's Interpretations if a plant comitted to the particular NFPA codes during the Appendix A to the Branch Technical Position 9.5-1 reviews, and this was accepted by NRC-NRR reviewers as identified in the plant Safety Evaluation Report, then area wide detection and suppression is required in order to confom to the
! NFPA code.
Regarding the staff's recomendation of allowing licensee's to have valid
_^- analyses supporting fire protection features and having this documentation j available for inspection, I offer the following coments:
- 1. Consistent reviews will be more difficult to achieve due to the increased number (each regional staff) of individuals given review responsibilities in detemining adequate licensee analyses.
- 2. In the " Staff's Recomendations Regarding the Implementation of Appendix R to 10 CFR 50", not dated, the staff indicated that the Interpretations j allowing penetrations in fire area boundaries and partial area coverage for fire suppression and detection were positions previously approved by l
the staff as exemptions. It is the inspector's hope that these previously 4
approved exemptions will be consolidated into a guidance package for use by the regional inspection teams, since NRR fire protection reviewers no longer accompany Regional inspection teams due to travel fund restrictions; or preferably that travel funds be made available so that the fire protection reviewers can again participatc in the Appendix R team I inspections which would also maintain consistency in NRC fire protection reviews (reference 1. above).
- 3. A considerable and currently unplanned for increase in regional man-hours will be required to perform the analysis review when licensets choose the option of having valid analyses to support fire protection featurgs.
l Since previously these reviews were performed by NRR, having the same regional manpower available will decrease the Region's direct inspection effort.
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- .1 James G. Keppler 3 03 0 f " - )
In response to Comissioner Asselstine's request of what the DP0 originators believe the answer is to get fire protection resolved at the plants as expeditiously as possible, I support the belief that the NRC should no longer grant any further extensions to the 50.48(c) schedules as discussed in Section A of Enclosure 2 of the Interpretations.
Reactor Inspector cc: W. J. Dircks, EDO W. J. Olmstead, ELD R. H. Vollmer, IE R. L. Spessard IE T. T. Martin, RI J. N. Grace, Rll J. A. 01shinski, RII
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