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THURSDAY, JUNE 11, 1987
Additional Material Submitted For The Hearing Record
UNITED STATES OF AMERICA
DISCUSSION OF APPENDIX R (FIRE PROTECTION)
Nuclear Regulatory Commission
Wednesday, May 30, 1 984.
2 : 00 p.m .
NUNZIO PALLADINQ "Chairman of the Commission
STAFF AND PRESENTERS SEATED AT COMMISSION TABLE:
E. Ca s e
I 2 3 4
9 10 11 12 13
18 19 20 21 22 23 24 25
MR. VOLLMER: Maybe if we had done this a montl ter Appendix R was issued and hauled everybody in and gc through this routine —
CHAIRMAN PALLADINO: Well, you probably didn't
MR. VOLLMER: That's right. We didn't, that's
COMMISSIONER ASSELSTINE: But even at this poini 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 11 titled, sir, I mean, unfortunately.
A :' The new draft generic letter
CHAIRMAN PALLADINO: Yeah, I think it is.
: Is it going to help? CHAIRMAN PALLADINO: Do you think it's going to .. help? Does the industry think it's going to help? » (CHATTER.)
: The new inter?re-atIon. .MR. EBERLY: Oh, at what point die we jet involved
COMMISSIONER GALIKSKY: Yeah.
MR. EBERLY: We, as the staff fire protection en
gineers, got involved in" it at the point when they started doing the regional workshops. However, jjssui wa9 rfl<*>"g
or less not solicited for this.
COMMISSIONER GALINSKY: And those regional workshops! were around what tine was that?
MR. EBERLY: — when the first one was.
COMMISSIONER GALINSKY: Ok, that gives me an idea.
COMMISSIONER ASSELSTINE: So you weren't real, volved at all In the preparation or —
MR. EBERLY: Not of these interpretations, no.
COMMISSIONER GALINSKY: It is that document with which you are differing?
MR. EBERLY: That's right.
MR. CASE: But that isn't to say that the arguments that they are now making weren't made by their Branch Chief at the time as potential problems. So they were given that consideration. Their Branch Chief's knew their problems.
MR. E3ERLY: That's right. Our Branch Chief was
COMMISSIONER GALINSKY: Is he here today or —
Court'Reporting • Depositions
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 meettrrgj 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 thorough discussion.