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
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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
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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
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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
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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
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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
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