ML20209D691

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Comments on Recommended Fire Protection Policy & Program Actions in Response to 841102 Memo.Proposal for Conducting Fire Protection Insps Supported.Resource Impact Underestimated
ML20209D691
Person / Time
Issue date: 11/14/1984
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Stello V
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20209D558 List:
References
FOIA-86-274 NUDOCS 8412190355
Download: ML20209D691 (1)


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, November 14, 1984 MEMORANDUM FOR: Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements. E00 FROM: James G. Keppler, Regional Administrator, Region III

SUBJECT:

RECOMMENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS In response to Mr. Dircks' memorandum of November 2,1984, I have the following coments on the recomendations provided by the Fire Protection Steering Comittee in their memorandum to Mr. Dircks dated October 26, 1984:

1. I believe the Stearing Comittee did a comendable job in dealing with the myriad of view on fire protection and recomending a course of action. The recomendations, in my view, are generally reasonable and ones which should provide a logical approach to bring about a consistent response by industry to the fire protection problem.
2. One area that does trouble me is the enforcement guidance which suggests that violations of fire protection requirements will only be Severity Level III or above when the ability to proceed to safe shutdown is impaired. If we had a major fire (e.g., cable spreading room), would we only classify the violations as Severity Level IV if we could shutdown g the plant from outside the control roorn?
3. Since the Steering Comittee recomendations represent a compromise of sorts, I would not expect total support within the agency staff for the recomendations. Since the Comission is aware of differing staff views on fire protection I think it would be beneficial to seek the views of all staff members involved in fire protection on the Steering Comittee's report --- and then provide in our report to the Comission, as appropriate, the rationale for not endorsing these views.
4. I support the proposal for conducting fire protection inspections; however, I am concerned that the resource impact may have been underestimated. If so, we may have to r.odify this effort.

wA fJamesG.Keppler Regional Administrator cc: See' attached distribution.

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