Fire Protection Policy Steering Committee Report (Generic Letter 85-01)

                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                           WASHINGTON, D. C. 20555

                               January 9, 1985

TO ALL POWER REACTOR LICENSEES AND ALL APPLICANTS FOR POWER REACTOR LICENSES

Gentlemen: 

SUBJECT:  FIRE PROTECTION POLICY STEERING COMMITTEE REPORT (Generic Letter 
          85-01) 

     Enclosed is a copy of the NRC Fire Protection Policy Steering Committee
Report, dated October 26, 1984. The background and purpose of the Steering 
Committee is described in the report. A notice will be published in the 
Federal Register in the near future that will provide an opportunity for 
public comments on this report. No response to this letter is required. 


                         Darrell G. Eisenhut, Director 
                         Division of Licensing 

Enclosure: 
As stated  


.

                                                                  ENCLOSURE 

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                           WASHINGTON, D.C. 20555 

                              October 26, 1984 

MEMORANDUM FOR:     William J. Dircks 
                    Executive Director for Operations 

FROM:               Fire Protection Policy Steering Committee 

SUBJECT:            RECOMMENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS 

Introduction 

At an August 27, 1984 meeting on fire protection, you directed that a review
of current fire protection issues be conducted and that recommendations for 
resolution of these issues be made within two months. This effort was to 
examine all current licensing, inspection, and technical issues to develop 
policy recommendations aimed at expediting Appendix R compliance for older 
plants and assuring consistent levels of fire protection safety at all 
plants. 

By your memorandum dated September 13, 1984 (Enclosure 1) to the NRR and IE 
Office Directors and the Regional Administrators, you confirmed this 
direction and approved a Steering Committee to provide appropriate 
recommendations. You indicated that, among the issues to be considered, 
were: 

     o    adequacy of current guidance to industry; 

     o    interpretation of Appendix R requirements; 

     o    treatment of technical. and schedular exemptions; 

     o    comparison of Appendix R and current NTOL plants for fire 
          protection safety; 

     o    adequacy of current inspection practices; and 

     o    identification and resolution plan for any outstanding technical 
          issues. 

In response to this direction, the Fire Protection Policy Steering Committee
(SC) has considered the broad range of fire protection issues necessary to 
arrive at policy recommendations. The SC has reviewed documents which 
provide the basis for current fire protection policies and which discuss 
many of the issues that could significantly delay Appendix R compliance and 
question consistency in fire protection safety at all plants. The SC held 
six meetings. These included meetings with the Senior NRC Managers, the NRR 
and IE Office Directors, and the fire protection engineers from NRR, IE, and 
the Regions. At the latter meeting, the candid views of the individuals 
intimately involved in the fire protection issues were solicited and 
received. A record of the SC meetings is included as 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                 - 2 -                        OCT 26 1984 

Enclosure 7. Finally, the SC received significant input from Thomas Wambach,
who acted as Secretary to the SC, and the Working Group, headed by Faust 
Rosa, NRR, and composed of V. Benaroya, C. Grimes, and V. Moore of NRR; S. 
Richardson, IE; W. Shields, OELD; and C. Anderson, T. Conlon, and W. Little 
of Regions I, II and III respectively. 

The recommendations of the SC are provided below. We believe that this 
responds to your direction, and when fully implemented, represent actions 
that will indeed expedite Appendix R compliance and assure consistent levels
of fire protection safety at all plants. The SC is aware that not all 
parties will be fully satisfied with these actions. Nor have our 
recommendations been reviewed by the cognizant Offices or Regions. However, 
we believe that they represent sound judgments balanced with other competing 
safety priorities, and that with your approval the plan can and should be 
initiated promptly. 

Recommendations 

To expedite Appendix R compliance and assure consistent levels of fire 
protection safety at all plants, the Fire Protection Steering Committee 
recommends that the following actions be taken: 

     1.   Promptly issue the enclosed Generic Letter (Enclosure 2) informing
          all licensees that: 
          
          (a)  Extensions to the 50.48(c) schedules will no longer be 
               granted; 

          (b)  An expedited fire protection inspection program will be 
               instituted; 

          (c)  Documentation of valid analyses supporting fire protection 
               features must be available for inspection; 

          (d)  Quality assurance applicable to fire protection systems is 
               that required by GDC-1 of Appendix A to 10 CFR Part 50; and 
               

          (e)  The interpretations of Appendix R, (Enclosure 3) which should
               facilitate industry implementation of Appendix R and the 
               responses to industry questions (Enclosure 6) represent the 
               official agency position on all issues covered. (It should be
               noted that The Commission requested these documents for their
               review prior to issuance to industry.) 

Enclosure to GL 85-01, Re: Fire Protection Policy  
.

William J. Dircks                 - 3 -                         OCT 26 1984 

     2.   Conduct fire protection inspections within CY 1985 at ORs and 
          NTOLs to include at least one site per licensee not subject to a 
          previous Appendix R fire protection inspection. These inspections 
          will assess the degree of fire safety, steer and promote licensee 
          compliance, and, take enforcement action where appropriate. A 
          Temporary Instruction for this program will be issued by 11/15/84.
          To make this program of inspection most effective: 

          (a)  A workshop for the inspection teams will be conducted in mid 
               December with SC, NRR, IE and Regional participation to 
               assure common understanding of the objectives, scope and 
               technical issues. Followup workshops will be held as needed; 

          (b)  The fire protection inspections will utilize new guidance for
               enforcement actions (Enclosure 4); 

          (c)  The processing of current fire protection enforcement actions
               will be expedited; and 

          (d)  A referee will be established to promptly resolve significant
               differences between the inspection teams and licensees. 

     3.   Upgrade regulatory documents and procedures to achieve an 
          appropriate level of fire protection safety while maintaining 
          consistency among plants. In particular: 

          (a)  Impose a standard fire protection condition (Enclosure 5) in 
               each operating license (already being implemented); 

          (b)  Reevaluate all fire protection guidance for consistency with 
               the SC recommendations and compare fire protection 
               requirements for ORs and NTOLs, both under the auspices of 
               the Working Group; 

          (c)  Develop appropriate revisions to the Standard Review Plan and
               Standard Technical Specifications by March 31, 1985; and 

          (d)  Designate the Director, Division of Engineering, NRR as the 
               central point of contact for interoffice/region fire 
               protection issues. 

     4.   To assure timely and on-track completion of these recommended 
          actions, the SC will review progress at least quarterly, make 
          mid-course corrections if appropriate, and report to the EDO. 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                 - 4 -                        OCT 26 1984 

Discussion 

The recommended actions are grouped into three main areas dealing with (1) 
guidance to industry, (2) an expedited program of fire protection 
inspections, and (3) a general upgrading of regulatory documents to reach 
and maintain consistent fire protection safety. This discussion section will
focus broadly on what the SC found during its deliberations to warrant the 
focus of these recommendations and will indicate how this satisfies the 
agenda of issues cited in your memo of September 13. Details on these issues
are provided in the record of the SC deliberations contained in Enclosure 7.

With regard to guidance to industry, the SC concludes that adequate 
technical guidance had been issued but that there were areas where confusion 
could arise. It was not clear where exemptions were needed, for example. 
However, a diligent reading of Appendix R and other staff documents did 
provide the basis for the satisfactory implementation of Appendix R at 
Calvert Cliffs. The SC concluded that it was neither needed nor appropriate 
to develop new guidance, rather, bringing current technical and 
implementation guidance together in one Generic Letter and make the SRP, 
Tech Specs, and licenses consistent would suffice. The Generic Letter makes 
clear (1) that extensions to the 50.48(c) schedules will no longer be 
granted, (2) that an expedited inspection program will be instituted to see 
what fire protection fixes are in place and give licensees the inspection 
team judgements on the acceptability of future modifications, and (3) that 
the licensee judgements must be backed by documented and valid analyses. The 
SC believes that this will demonstrate to the licensee what action he must 
take and what our inspections will look for. The Generic Letter notes that, 
although the 50.48(c) schedules will not be extended, the relative safety 
priorities of fire protection modifications need to be considered in the 
development of "living schedules." One item of guidance in the Generic 
Letter that had not been uniformly disseminated is that the QA applicable to 
fire protection features is that required by GDC-1. This would not attempt 
to backfit any QA requirements. Rather it would assure that future design, 
procurement, installation, testing and maintenance of fire protection 
features would receive high industrial quality attention. The SC believes 
that this initiative fully responds to the first three issues in your memo 
of September 13. 

Turning now to the inspection program, the SC found that the current 
inspections are generally satisfactory but that steps must be taken to 
indicate NRC's view of the importance of expediting implementation of 
Appendix R. These steps are to (1) speed up the inspection process, (2) 
develop a sound policy for fire protection enforcement actions, and (3) 
issue enforcement actions currently pending. These steps, in our view, would 
help expedite licensee compliance because it would raise industry's 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                 - 5 -                        OCT 26 1984 

awareness to NRC's resolve in this area and, more importantly, would allow 
the teams to judge the current direction (for licensees still designing or 
installing fixes) and advise the licensee on its acceptability. This should 
save both industry and staff resources in the long run. In the short run, 
that is 1985, the SC believes that adequate resources exist for the 
inspection teams (one for R-I, R-II and R-III, and one for R-IV/V) to be 
taken from regional staff, augmented by contractor, NRR, and IE assistance. 
While this would take a modest amount of reprogramming in the regional 
inspection program, we suggest that it's worth the effort to get Appendix R 
implementation behind us. 

Prior to the 1985 inspection, a several-day inspection team workshop would 
be held to discuss the inspection program, the technical issues, and reach a 
common understanding on acceptability of various configurations and required 
documentation. Since this workshop cannot solve all potential problems the 
inspection teams will encounter, a team at HQ would be set up to promptly 
resolve significant differences between the inspection personnel and the 
licensee. This referee team would be headed by NRR (SES level) and would 
have an NRR, an IE and a regional technical member. Their decision would be 
issued in one week and would be sent to all teams for their information. 

The SC believes that this program of expedited inspections, aimed at 
reaching ORs and NTOLs and to include at least one site from each licensee 
not previously subject to a fire protection inspection, coupled with denial 
of future schedular exemptions and a fire enforcement policy will result in 
a fair and uniform speed up of Appendix R compliance. Further, since the 
resource cost is believed to be modestly above the already-programed fire 
protection inspections, we believe the cost is well worth it and will even 
benefit industry by correcting false starts in Appendix R implementation 
where they are found. Although we found the current inspections adequate 
(fifth item in your memo of September 13), this program will continue to be 
focussed on safe shutdown, will be implemented more expeditiously, and will 
build on the resolution of other initiatives considered by the SC. A 
Temporary Instruction for this inspection program has been drafted and is 
undergoing final revisions It will be in final form by November 15, 1984 and
will include the elements discussed above, for example, the team set up to 
resolve inspection differences with the licensee. 

Finally, the SC considered means to assure and maintain consistent levels of
fire protection safety at all plants. The Working Group researched the 
guidance documents currently available and how these are applied to old and 
new plants. The SC discussed findings of the reviewers and inspectors who 
are close to the issues. As a result of this work, the SC found that the 
requirements for old and new plants were generally the same but that 
discrepancies do exist. The application of guidelines, both in the review 
process and the inspection process, leaves room for interpretation. The SC 
concluded that several steps needed to be taken in addition to those 
described above some of which were to assure and maintain consistency. 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                 - 6 -                        OCT 26 1984 

These steps are to develop and implement standard fire protection license 
conditions, Standard Review Plan, and Standard Tech Specs for all plants. 
The license condition developed for this is along the lines of the security 
plan and QA program (Enclosure 5). The Standard Review Plan should need 
minimum revision to assure that Appendix R is fully included. The Tech 
Specs, however, will require more research and development by the Working 
Group. We need to assure that the Tech Specs are soundly based to assure 
functioning of fire protection features but which require only those 
activities which are commensurate with other Tech Spec items in terms of 
importance to safety. As part of the above tasks, all fire protection 
guidance needs review and culling to assure that only a consistent and 
appropriate set remains. This complete set of guidance will be referenced in 
the Standard Review Plan revision. A last step in achieving uniform 
technical requirements is the SC recommendation to designate an office as 
responsible for awareness and resolution of interoffice/region fire 
protection issues. This is felt to be needed since current fire protection 
review is conducted within three divisions within NRR and one in IE. 
Although there is a lead branch responsibility, it is not always kept 
informed and involved. Therefore, the SC believes that the Director, 
Division of Engineering in NRR should be designated as the central point of 
contact. 

Conclusion 

The Fire Protection Policy Steering Committee concludes that the actions 
described above will accomplish the goals set forth in your memo of 
"expediting Appendix R compliance for older plants and assuring consistent 
levels of fire protection safety at all plants." We believe that these 
actions will facilitate industry implementation of Appendix R through the 
use of the "interpretations" and a consistent set of guidance yet will 
provide the necessary regulatory tools to guide, monitor, and, where 
appropriate, enforce this implementation process. We feel strongly that the 
actions we propose are synergistic and therefore all need to be completed to 
be most effective. 

The Fire Protection Policy Steering Committee has found the assignment to be
challenging and rewarding. We would be pleased to brief you on our efforts 
at your earliest convenience. 

                Fire Protection Policy Steering Committee 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                - 7 -                         OCT 26 1984 

     FIRE PROTECTION POLICY STEERING COMMITTEE 


          J. Nelson Grace, Director 
          Quality Assurance, Safeguards & Inspection 
          Programs 
          Office of Inspection and Enforcement 


          Thomas T. Martin, Director 
          Division of Engineering and Technical Programs 
          Region I 


          William J. Olmstead, Director and Chief Counsel 
          Regulations Division 
          Office of the Executive Legal Director  


          John A. Olshinski, Director 
          Division of Reactor Safety 
          Region III 


          Richard L. Spessard, Director 
          Division of Reactor Safety 
          Region III 


          Richard H. Vollmer, Director 
          Division of Engineering 
          Office of Nuclear Reactor Regulation (Chairman) 

Enclosure to GL 85-01, Re: Fire Protection Policy 
.

William J. Dircks                 - 8 -                        OCT 26 1984 

Enclosures: 
1. Memo to H. Denton et al on Review of 
     NRC Fire Protection Policy and Programs.
2. Generic Letter on Fire Protection 
3. Interpretations of Appendix R 
4. Guidance for Enforcement Actions Concerning 
     Fire Protection Requirements 
5. Fire Protection License Condition 
6. Appendix R Questions and Answers 
7. Steering Committee Memoranda 

Enclosure to GL 85-01, Re: Fire Protection Policy