This is in response to your inquiry dated July 31, 1984 regarding the subject meeting. The meeting was held at the request of the Utility Group to inform the staff of the Utility Group's intent to submit a formal response to issues raised during discussions between the staff and the Commission at a briefing on Fire Protection on May 30, 1984. A list of attendees at the subject meeting and their affiliation is enclosed. There were no handouts or briefing materials distributed at the meeting. With regard to your inquiry regarding general matters discussed at the meeting; the Utility Group addressed several points which were raised by Mr. Eberly, NRR, Mr. Ramsey, R-III, and Mr. Trubach, OGC, in presentations to and discussions with the Commission on May 30, 1984. Utility Group believed that several points had not been adequately discussed and the Group believed the Commission should be provided additional information and perspective. Principal among those points were the following: 1. The Utility Group believes that greater emphasis should be given to the potential for reducing significantly the number of exemption requests, which they expect would have to be processed in implementing Appendix R under the current approach. They believe the new guidance proposed by the staff and discussed with the Commission would alleviate this concern. 2. 3. 4. The Utility Group perceives that the Fire Protection competence of utilities in general has been seriously questioned by some of Mr. Eberly's and Mr. Ramsey's remarks at the May 30 meeting. They believe that, in the interest of fairness and balance, those remarks require a response. The Utility Group believes that greater emphasis needs to be given to the potential for speeding the process of implementing Appendix R and verifying compliance by licensees with its requirements. They believe that issuing the guidance proposed by the staff and discussed with the Commission will accomplish this objective. The Utility Group believes that the suggestion by Mr. Trubach that issuance of the guidance proposed by the staff constitutes a change to the regulations without due process needs to be seriously challenged and receive more thorough discussion. - 2 With regard to your question regarding commitments or agreements made at the July 24 meeting, the Utility Group committed to submit their planned formal response sufficiently in advance of the next scheduled Commission meeting on Fire Protection (i.e. within a few weeks) to enable the staff to consider, evaluate and comment on the Utility Group's views in further discussions of these matters with the Commission. The Utility Group intends to include in their submittal (1) discussion of the background and history of development of the Appendix R situation, (2) response to specific points of concern raised by Mr. Eberly and Mr. Ramsey in their oral presentations (and in a written Differing Professional Opinion), and (3) discussion of the questions raised by Mr. Trubach. At the staff's request, the Utility Group will also provide some discussion of why the majority of the Group believe that there is a need for issuance of additional guidance, as proposed by the staff, to facilitate implementation of Appendix R, in view of the fact that one member of the Group (Baltimore Gas and Electric) has been able to implement expeditiously those requirements without such additional formal guidance. No other commitments or agreements were made at the July 24 meeting. The Utility Group also asked if the staff could provide any information or guidance now that might be useful in determining their course of action at this point with respect to implementation of Appendix R. In particular, they inquired as to the staff's judgment regarding whether/how the issues raised at the May 30 meeting might affect the ultimate disposition, and the final form and content, of the proposed Fire Protection guidance package discussed with utilities in the recent Regional Workshops. The staff could provide no firm response in that regard and made clear that the final decisions regarding whether/what additional guidance is to be issued will be made by the Commission. We have read and considered the license condition the staff 2. The licensee may not make changes to the approved |