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MR. VOLLMER: };aybe if we had done this a mont;

ter Appendix R was issued and hauled everybody in and go

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through this routine --
CHAIRMAN PALLADINO: Well, you probably didn't

enough.

MR. VOLLMER: That's right. We didn't, that's

COMMISSIONER ASSELSTINE: But even at this point why aren't we better off by just saying, you have 8333, that's it? - * *

MR. CASE: That's certainly an approach.

MR. : That's a good possibility.

CHAIRMAN PALLADINO: But, do you think that thes interpretation documents - we should give some other name

COMMISSIONER ASSELSTINE: Well, that's the way it

titled, sir, I mean, unfortunately.

A

:: The new draft generie lette: right? cHAIRMAN PALLADIN0: Yeah, I think it is. Is it going to help? CHAIRMAN PALLADIN0: Do you think it's going to help? Does the industry think it's going to help?

... (CHATTER.) /MR. . : —— helped write it, obviously $Hey-are

going to like it.

FREE STATE REFORTING INC.

* ----- P -------' We Deree: *** -

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The new intero retation,
:F. EBEF.I.Y Ch., at what point did we set involved

in it?

COMMISSIONEF GALINSKY: Yean.
MR. EBERL?: We, as the staff fire protection en-

sineers, sot involved in it at the point when they started

doing the regional workshops. However —-a-more

COMMISSICNER GALINSKY: And those regional workshops

were arcund what time was that?

3.

-- when the first one was . COMMISSIONER GALINSKY: ok, that gives me an idea.

COMMISSIONER ASSELSTINE: So you weren't really-to

volved at all in the preparation or -- - Q_T

MR. EBEFL?: Not of these interpretations, no. CCMMISSIONER CALINS: Y: It is that document with which you are differing?

MR. EEERLY: That's right.

MR. CASE: But that isn't to say that the arguments that they are now making weren't rade cy their 3ra

at the time as potential problems. So they were given that

consideration. Their Branch Chief's knew their problems.
MR. EBE5-?: That's right. Our Branch Chief was
-

involved.

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UNITED STATES
NUCLEAR REGULATORY COMMISSION

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. - Se...so WASHINGTON, D. c. 20555 %3||||3 o, o, AUG 1 3 S84 MEMORANDUM FOR: Commissioner Assel Stine FROM: William J. Dircks

Executive Director for Operations

SUBJECT: NRC STAFF MEETING WITH UTILITY FIRE PROTECTION GROUP,

JULY 24, 1984

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. 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.

3. 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.

4. 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-tROFOUGHTaTscussian:

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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.

lliam J. Dircks "To cutive Director for Operations Enclosure

Attendee List

cc: Chairman Palladino
Commissioner Roberts
Commissioner Bernthal
Commissioner lech
OPE
0GC
SECY

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NRC Utility Group
W. Stello M. McGarry Bishop, Lieberman, Cook
R. Wollmer Purcell, Reynolds
J. Taylor D. Stenger Bishop, Lieberman, etc.
J. Sniezek R. Oates Carolina Power & Light
P. McKee T. Pickens Northern States Power
W. Kane L. Parscale Arkansas Power & Light
J. Conran R. Kacich Northeast Utilities
S. Maloney Engineering Planning &
Management
J. Haverly Impell (Formerly with Toledo

Edison)

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