ML20209D679

Comments on Recommendations of Fire Protection Policy Steering Committee in Response to 841102 Request.Documents Should Be Carefully Edited to Ensure That Terms Are Defined & Consistently Used

ML20209D679
Person / Time
Issue date:	11/27/1984
From:	Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20209D558	List: IA-86-274, Advises That Listed Secys Will Be Forwarded to J Curtiss, Associate Counsel,Senate Subcommittee on Nuclear Regulation, Committee on Environ & Public Works,On 860210 Under Encl Cover Ltrs.W/O Encls ML20209D553 ML20209D568 ML20209D679 ML20209D686 ML20209D691 ML20209D771 ML20209D775 ML20209D781 ML20209D784 ML20209D788 ML20209D794 ML20211J190 ML20211J203 ML20211J248 ML20211J261 ML20211J281 ML20211J299 ML20211J320 ML20211J350 ML20211J362 ML20211J373 ML20211J378
References
FOIA-86-274 NUDOCS 8412190344
Download: ML20209D679 (2)

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' November 27, 1984 HEMORANDUM FOR: Victor Stello, Deputy Executive Director for Regional Operations and Generic Requirements FROM: Thomas E. Murley, Regional Administrator, RI

SUBJECT:

RECOMMENDED FIRE PROTECTION POLICY AND PROGRAM ACTIONS We have reviewed the recommendations of the Fire Protection Policy Steering Committee as requested in Mr. Dircks' memorandum of November 2,1984. We believe the Steering Committee's three main recommendations dealing with (1) guidance to the industry, (2) expedited inspections, and (3) upgrading of regulatory documents to ensure consistency provide a sound basis for moving forward in the fire protection area. I believe the benefits from moving quickly to clear up the cloud of uncertainty that hangs over the fire protection area outweigh any gains to be made by delaying while we attempt to resolve remaining disagreements. In that spirit we have the following comments:

1. In the task to develop and implement standard fire protection Tech Specs for all plants, the staff must be careful that they don't make the current problems with Tech Specs even worse. For instance, the Tech Specs for Susquehanna 1&2 specify the surveillance frequency for each of the hundreds of fire detectors in the plant. If a surveillance test is missed, an LER is initiated and plant management up to the.. Station Superintendent have to get involved. If NRC proceeds to clutte'r up all plants' Tech Specs in this manner, I believe that would bhohtfary to improving safety.

2. We believe it would be more efficient if all fire rotection review activities were consolidated in the Division of En ineering in NRR.

3. The Steering Committee documents should be carefully edited to be sure the terms are defined and consistently used and to be sure the Interpretation and Q&A documents are internally consistent.

4. The Region II concern, as stated in their November 15, 1984 letter from James P. O'Reilly to Victor Stello in item 8.11, that the BTP CMEB 9.5-1 does not include the requirements of Appendix R for NTOL plants should be resolved and the response to 8.11 modified before Enclosure 3 is sent to the licensees.

h j Thomas E. Murley Regional Administrator cc: See next page _-

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VictorsStello cc: W. J. Dircks, EDO H. R. Denton, NRR R. C. DeYoung, IE G. H. Cunningham, ELD R. H. Vollmer, NRR J. P. O'Reilly, RII J. G. keppler, RIII R. D. Martin, RIV J. B. Martin, RV D

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