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% ,',Y, FEB 2 81985 b-riiT4 MEMORANDUM FOR: Thomas E. Murley, Regional Administrator, Region I 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 RCM: James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
SAFE SHUTDOWN INSPECTION PROGRAM One of the recommendations to the Executive Director for Operations of the Fire Protection Steering Committee is to conduct expedited inspections of safe shutdown aspects of various licensees in order to give the staff additional inferination on the status of implementation of fire protection features. These expedited inspections would require a substantial reprogramming of resources from the planned inspection program. While I support limited planning and
. preparation for these inspections, implementation of the expedited inspection l recommendation should not proceed in advance of approval by the EDO of the '
Steering Com.ittee recommendation in this area. Until further guidance is )
given on this matter, fire protection inspections should continue to focus on !
safe shutdown requirement compliance at HT0L plants and plants that have completed modifications in accordance with 10 CFR 50, Appendix R.
. , L-- l am s M. aylor. Director ice o Inspection and Enforcement
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Enclosure 3 MAR 0 $ tgg5 HEMORANDUM FOR: James Knight Acting Director Division of Engineering Office of Nuclear Reactor Regulation FROM: James M. Taylor, Director Office of Inspection and Enforcement
SUBJECT:
RESOURCE EST! MATES FOR PROPOSED EXPEDITED FIRE PROTECTION INSPECTIONS By a memorandum dated December 10, 1984, the EDO requested that IE provide information on resource impacts associated with the expedited fire protection 4 inspection as proposed by the Fire Protection Steering Comittee. I The !! staff has evaluatec the resources associated with the proposed expedited" l inspection and notes the following: i
- a. The total estimated resources required to perform the expedited inspections would be approximately 10 staff years of regional resources. Based on already planned fire protection inspections, this represents approximately 8 staff years additional resources. The staff also estimates that contractor assistance would be increased by approximately 5500K to support the expedited inspection program. Using the $500K for the expected inspection effort would exhaust all routine technical support funds for the regions, as well as significantly deplete funding set aside to deal j with problem facilities.
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- b. Approximately 4 stcff years of the additional resources can be reprogramed from routine fire protection inspection effort. This effort is primarily associated with fire protection inspection of features other than. safe shutdown such as fire brigade training, and fire protection program review.
It is important to note that this reprograming will direct programatic fire protection reviews away from a large number of plants in order to focus on safe shutdown inspections at a fewer number of plants.
- c. The remaining 4 staff years of resources can be reprogramed from engineering and project inspections. Inspections impacted would primarily be enhanced efforts directed at poor overall licensee performers and efforts directed at licensee functional areas identified by the region during SALP
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- 4 James Knight As discussed above, the impact on IE inspection programs would be significant.
I therefore do not support implementing the Steering Comittee's recomendation for expedited inspection effort and instead recommend that the safe shutdown inspections be conducted as previously planned.
tk: W SI!ned W Iaiht d'aIager James M. Taylor Director Office of Inspection and Enforcement Distribution:
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4 Attachment C NRR Comnents on the Steering Committee Report This office has reviewed the report of the Fire Protection Policy Steering Committee and supports with one minor difference the conclusions and recom-dations contained therein. We believe that implementation of these recom-mendatier.s will be helpful in furthering the Commission's objectives of timely ,
and appropriate compliance with Appendix R to 10 CFR 50.
Recommendation d. of the May 3rd letter to me suggests the use of the proposed technical specifications in future operating licenses as appropriate (in addition to providing them to the NRR Technical Specifications Improvement Project). We have not included this clause in the Commission paper recon-mendations because several proposed tech specs will probably be backfit iters and can be better resolved in the context of technical specification improve-ments.
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