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C. J. Anderson, RI V. Benaroya, NRR T. E. Conlon, RII C. I. Grimes, NRR W. S. Little, RIII V. A. Moore, NRR S. D. Richardson, IE W. M. Shields, ELD FROM:
F. Rosa, Chairman Fire Protection Policy Working Group
SUBJECT:
FIRE PROTECTION POLICY WORKING GROUP - REMAINING TASKS The purpose of this memorandum is to provide the W.G. with: 1) A status summary of the Fire Protection Policy effort and related W.G. tasks, 2) The schedule and proposed agenda for the next W.G. meeting, and 3) A copy of recent documents related to this effort.
The Steering Committee report is being placed in the PDR and a request for public comments was published in the Federal Register on January 15, 1985.
Concurrently, a copy of the report is being sent to the nuclear utilities via Generic Letter 85-01 dated January 9,1985.
It is expected that this G.L.
will be dispatched this week. The comment period is 30 days. Comments on the report from the NRC Offices and Regions have already been received. directs NRR, with assistance from IE and ELD, to prepare a Conmission paper on fire protection addressing activities tn date and the specific questions raised, and including recommendations for Commission approval. The proposed Commission paper will be submitted for CRGR review.
In support of the Commission paper effort, the Working Group has been assigned (see Enclosure 2) the task of, "---revising the generic letter and its attach-ments, if appropriate, received from the Offices and Regions and after evalua-ting any comments received,from the public." A commentary on disposition of unused comments is also required.
The target date for completion of this task is February 15.
(We are unlikely to meet this date since the public comment period expiration date is February 14.)
The W.G. (as a group) remains uninvolved with the Temporary Instruction being prepared by IE.
Steve Richardson is interacting directly with the Steering Committee on this.
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Var. Addressees The status o( our previously assigned task, the revision of the STS on fire protection, is as follows~: Comments on the STS draft transmitted to the W.G.
by my memorandum dated December 7, 1984 have been received. These comments are being incorporated into the draft by Chris Grimes, in consultation with Don Brinkman (SSPB) in regard to STS format and policy.
Chris is also pre-paring the rationale for re,iected comments.
I am scheduling a meeting of the W.G. for January 24 (and 25 if necessary),
1985, at 9:00 A.M. in P-204 in Bethesda with the following agenda.
1.
Review and approval of a final draft of the STS.
2.
Discussion of Office and Region comments on the Steering Committee report.
3.
Determination of specific task assignments and schedule for completing the new W.G. assignment cited above.
The W.G. objectives at this meeting should be the completion of the STS task, and the establishmert of assignments for the new task that will result in a proposed draft revision of the G.L. and its attachments to incorporate the Office and Region comments prior to receipt of the public comments (expected about 2/22/85). The evaluation and incorporation of public comments can then be accomplished during the week of February 25, 1985 with a target date for submission of a final package to the S.C. of March 4,1985.
I believe that the Bethesda based members of the W.G. (V. Benaroya, C. Grimes, W. Shields, and F. Rosa - V. Moore is retiring from the NRC at the erd of this month) assisted by Tom Wambach can accomplish the remaining W.G. tasks.
How-ever, the Regional members of the W.G. (C. Anderson, T. Conlon, W. Little) are welcome to continue full participation; in any event, you will be kept fully informed and consulted prior to any final W.G. action.
Your comments on this arrangement are invited. lists the memoranda and other documents contained in the attached package. These documents are relevant to the material to be addressed at the upcoming meeting.
(You may already have most of them.) Please review them prior to the meeting, r
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Faust Rosa, Chairman Fire Protection Policy Working Group
Enclosures:
As stated cc: See attached list
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Enclosures:
R. H. Vollmer R. M. Bernero R. W. Houston cc w/
Enclosures:
T. Wanbach
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MEMORANDUM FOR:
Victor Stello, Jr., DEDROGR Harold R. Denton, Director, NRR Richard C. DeYoung, Director, IE FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
FIRE PROTECTION POLICY STEERING COMITTEE RECOMMENDATIONS In a memorandum dated October 26, 1984, the Fire Protection Policy Steering Comittee provided me with their recomended actions on the fire protection policy and program. Coments on these recomendations have been received from the appropriate program and regional offices. The individual coments are enclosed.
These coments, although generally supportive of the Steering Comittee's work, raise a nunber of serious, questions which need to be answered before we can proceed to the Comission on this matter. They are:
1.
Are all the recomendations technically justified from the safety standpoint?
2.
Are the resource estimates correct?
3.
How will the inspection program be impacted to the extent that resources will be diverted from other activities?
4.
Considering the current status of fire protection capability at, operating plants, does the current risk dictate the reprograming of inspection resources for fire protection inspection?
5.
Is the magnitude of the safety problem comensurate with the proposed actions; e.g., no further schedular exemptions?
6.
Should the revised interpretations and questions and answers be issued and what impact will they have on the overall program?
7.
Do the recommendations go beyond what the Comission intended in promulgating Appendix R?
In light of the above, I have decided to proceed in the following way:
1.
The Director, NRR, should release the report of, the Steering Comittee to the PDR and invite somment by interested parties.- Comments should be analyzed by NRR with assistance from IE and ELD as needed. This analysis should be provided as part of a Commission paper.
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The Director, NRR, should provide a quantitative estimate of the public risk associated with fire from operating plants based on their current status; i.e., incomplete compliance with Appendix R.'
This estimate should be based on your review of pertinent existing PRAs that have been reviewed by NRC. The ROGR staff should be kept informed of progress in 'this area. This estimate and associated basis should be provided in the Commission paper.
3.
The Director IE, should provide an evaluation of the reprogramming of inspection activities that will be necessary in order to implement the Steering Committee's reconnendations regarding inspection.
Inspection activities to be reprogrammed shall be identified and a basis provided.
This report shall be prcvided to NRR for the Commission paper and shall be consistent with the results of Task 2.
4.
The Director, NRR, with assistance from the Directors of IE and ELD should prepare a Commission paper that addresses the activities to date and provides specific recommendations for Connission approval. Thht paper
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should address the specific questions identified above. Target date for providing the paper to the CRGR for review is February 1,1985.
5.
CRGR should review the proposed Commission paper, address each.of the above questions, and nake specific reconmendations to me not.later than
. 30 days after receipt from NRR.
I expect appropriate management representatives from NRR, IE and the Steering Committee to attend the CRGR meetings on this issue to respond to CRGR questions.
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dD William rcks Executive Director for Operations
Enclosures:
As stated cc:
R. Minogue G. Cunningham Regional Administrators e
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