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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.
We have read and considered the license condition the staff recommends be made available to licensees and included in licenses issued in the future. We would recommend only that the wording of the second paragraph of the condition be made permissive. It is the intent of the second paragraph to make clear that licensees may make use of the flexibility available under 50.59, a flexibility which the first paragraph, standing alone, would take away. However, the negative wording of the second paragraph obscures its intent. We therefore propose the following changes:
2. The licensee may not make changes to the approved
TO: Samuel J. Chilk, Secretary Of The Commission
SUBJECT: SECY-85-306 - STAFF Recommendations Regarding The
SECRETARIAT NOTE: Please Also Respond To And/or Comment On Ogc/ope Memorandum If One Has Been Issued On This Paper.
NRr-SFfY Form Dec. 80
I have several concerns about the staff's recommendations for implementation of Appendix R. These Include concerns about the procedures 1n the staff's Interpretation document, technical concerns, problems with the proposed enforcement policy and the staff's backflttlng analysis.
I heUeve that the staff's approach will make 1t harder for our fire
What this new procedure does 1s to, 1n effect, shift the burden from the
The staff argues that Its procedure 1s acceptable becn.se, in the areas in