ML042870477
| ML042870477 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 08/26/2004 |
| From: | NRC/EDO, Office of Nuclear Reactor Regulation, NRC/SECY |
| To: | |
| Ennis R, NRR/DLPM, 415-1420 | |
| Shared Package | |
| ML042870431 | List: |
| References | |
| G20040511 | |
| Download: ML042870477 (23) | |
Text
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 MEETING OF 5 PETITION REVIEW BOARD 6 + + + + +
7 THURSDAY 8 AUGUST 26, 2004 9 + + + + +
10 DOCKET NO. 50-271 11 + + + + +
12 The meeting met via teleconference, Rick 13 Ennis presiding.
14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 P R O C E E D I N G S 2 MR. ENNIS: Paul Blanche (phonetic) and 3 Arnie Gunderson (phonetic) are you on the line yet?
4 MR. GUNDERSON: Yes, we are.
5 MR. ENNIS: Are both of you in the same 6 location?
7 MR. GUNDERSON: No.
8 MR. ENNIS: Okay. Who from Entergy is on 9 the line?
10 MS. DeFLUCUS: You have Rhonda DeFlucus 11 from Vermont Yankee.
12 MR. ELMERS: John Elmers (phonetic) from 13 the White Plaines office.
14 (Inaudible.)
15 MR. ENNIS: Paul and Arnie do you have 16 everybody you need?
17 MR. GUNDERSON: Paul and Arnie only need 18 Paul and Arnie.
19 MR. BLANCHE: We are the participants.
20 There might be other people listening.
21 MR. ENNIS: Okay. Entergy, is everybody 22 on the line that youre expecting?
23 MS. DeFLUCUS: Yes, thank you.
24 MR. ENNIS: Okay, I guess at this point 25 well get started. My name is Rick Ennis (phonetic).
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3 1 Im the Project Manager at NRC Headquarters in 2 Rockville, Maryland, for Vermont Yankee.
3 Today Im acting as the Petition Manager 4 since Donna Skay, the Petition Manager for this 5 specific 2.206 petition is out of the office.
6 At this point, Id like to turn it over to 7 Jim Lyons (phonetic), who is the Petition Review Board 8 Chairman.
9 (Inaudible.)
10 MR. LYONS: Im Jim Lyons. Im the Deputy 11 Director of the Division of Licensing Project 12 Management in the Office of NRR.
13 MR. WALKER: Chavone Walker (phonetic),
14 just sitting in.
15 (Inaudible.)
16 MR. BURKE: Gary Burke (phonetic), Project 17 Director, NRR.
18 MR. PETTIS: Bob Pettis (phonetic), Plant 19 Support Branch.
20 MR. HOLDEN: Cornelius Holden (phonetic),
21 Project Director, NRR.
22 MR. ROLAND: Bill Roland (phonetic),
23 Project Director, NRR, power up rate process only.
24 MR. ENNIS: NRC in Region I?
25 MR. ANDERSON: Its Cliff Anderson NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 (phonetic), Branch Chief, Branch 5, with 2 responsibility for Vermont.
3 MR. SHAND: Leo Shand (phonetic), NRC 4 Region I, Public Affairs.
5 MR. ZELLIS: Ed Zellis (phonetic), NRC, 6 Region I, Branch 5.
7 MR. ENNIS: Once more, Entergy, could you 8 list everybody thats there?
9 MS. DeFLUCUS: Entergy, Rhonda DeFlucus at 10 Vermont Yankee.
11 MR. McCULLOUGH: Travis McCullough 12 (phonetic), in Pipeline.
13 MR. ELMERS: Chad Elmers (phonetic), White 14 Plaines.
15 MR. ENNIS: Okay. And Paul and Arnold?
16 MR. GUNDERSON: Right. Im on.
17 MR. BLANCHE: And Paul is here.
18 MR. ENNIS: Okay. Are there any other 19 interested parties that are on beside either Entergy, 20 the NRC, or the petitioners?
21 MR. ROCKBAUM: Dave Rockbaum (phonetic) 22 with the Union of Concerned Scientists.
23 MR. BLOCK: Jonathan Block (phonetic),
24 attorney for a number of the different organizations 25 that might be involved here.
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5 1 MR. ALEXANDER: Peter Alexander (phonetic) 2 with New England Coalition.
3 MR. WEI: Orlick Wei (phonetic), just a 4 private party.
5 MS. LAURI: Carolyn Lauri (phonetic) from 6 the Battleboro Reformer (phonetic).
7 MS. SMALL: Susan Small (phonetic) here 8 from the Rutland Herald (phonetic).
9 MR. SHADOWS: Ren Shadows (phonetic) with 10 the New England Coalition.
11 MR. ENNIS: Anyone else?
12 (No response.)
13 MR. ENNIS: Okay, at this point Id like 14 to turn it over to Jim Lyons.
15 MR. LYONS: Thank you, Rick.
16 The subject of this conference call is a 17 10 CFR 2.206 petition submitted by Mr. Paul Blanche 18 and Mr. Arnold Gunderson dated July 29th, 2004 19 pertaining to the Vermont Yankee Nuclear Power 20 Station.
21 Petitioners have requested that the NRC 22 take enforcement action against Entergy, the licensee 23 for Vermont Yankee.
24 Specifically the petitioners requested 25 that the NRC issue a demand for information requiring NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 Entergy to provide information that clearly and 2 unambiguously describes how Vermont Yankee complies 3 with the general design criteria in 10 CFR 50, 4 Appendix A, and Ill refer to the general design 5 criteria from now on as just GDC, it just makes it a 6 lot easier, or the draft GDC as published in the 7 Atomic Energy Commission in 1967.
8 The petition indicated that this 9 information was essential to the NRCs review of the 10 proposed Vermont Yankee power up rate and the NRCs 11 engineering inspection at Vermont Yankee. Both of 12 these efforts are presently in progress.
13 The NRC issued a letter to the petitioners 14 that the NRC will not treat this request under 10 CFR 15 2.206 process because these issues can be addressed 16 through the ongoing licensing proceeding for the 17 proposed power up rate.
18 This decision was based on the guidance in 19 the NRC Management Directive 8.11 review process for 20 10 CFR 2.206 petitions and its found in the Handbook, 21 Part 3, in Sections 2.1.a.iii.
22 In addition, as discussed in our letter to 23 the petitioners, its clear that Vermont Yankee was 24 licensed to the draft GDC published by the Atomic 25 Energy Commission in 1967.
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7 1 With respect to the Vermont Yankee power 2 up rate license amendment request, the licensee has 3 provided the information the NRC needs with respect to 4 which GDC is applied to each of the specific technical 5 review areas covered by the NRC review.
6 With respect to the engineering inspection 7 that is currently being performed, there are methods 8 available to the inspection team to obtain additional 9 information regarding the plant design and licensing 10 basis if we need it.
11 Therefore, that renders a demand for 12 information unnecessary.
13 This teleconference is being held in 14 response to a request from the petitioners to address 15 the Petition Review Board. The purpose of this call 16 is to allow the petitioners to provide any additional 17 or clarifying information that could effect the NRCs 18 decision not to treat this request under the 10 CFR 19 2.206 process.
20 This is also an opportunity for the NRC 21 staff and the licensee to ask any clarifying 22 questions.
23 The purpose of this teleconference is not 24 to debate the merits of the NRCs decision.
25 Following this phone call, the Petition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 Review Board will meet to discuss the comments 2 provided during this call. A letter will be sent to 3 the petitioners documenting our review and 4 dispositioning their comments.
5 The teleconference is being transcribed so 6 it will help if anyone making a statement first state 7 their name clearly. The transcript will be made 8 publically available.
9 Only the petitioners, the licensee, and 10 the NRC may participate during this call. Other 11 interested parties are invited to listen in, however 12 they may not provide any comments or questions.
13 We request that the petitioners keep their 14 remarks to about 30 minutes. And so at point, Id 15 like to turn it over to Mr. Blanche and Mr. Gunderson.
16 MR. BLANCHE: Im going to -- at this 17 point, Im going to let Arnie start off. And then Im 18 going to pick up. And then Arnie will summarize at 19 the end.
20 MR. GUNDERSON: Okay. Thank you.
21 This is Arnie Gunderson calling. The 22 issue is not which GDC applies, whether its the draft 23 70 or the final 64. It really doesnt matter to us 24 and we understand that the draft GDCs do apply. So 25 thats really not on the table. And I think all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 parties are in agreement on that.
2 We have received a rejection letter 3 already and its really broken into two parts. And 4 Ill address mainly one and Paul the other.
5 It is -- you suggest that we have the 6 right and the opportunity to file as part of the 7 hearing process on the up rate, which is open for 8 another week approximately. Its our position that 9 the compliance with the GDCs applies to the plant as 10 it exists today.
11 And its exacerbated by the up rate but, 12 in fact, the issues dont go away with an up rate. We 13 simply, after a review of voluminous information, 14 cannot determine whether or not Vermont Yankee is in 15 compliance with the draft general design criteria.
16 So its a problem now, which is 17 exacerbated by the 400,000 extra horsepower that the 18 plant will be cranking out. But its clearly a 19 problem of the existing license.
20 So we will not be availing ourselves of 21 the hearing process.
22 On top of that, the hearing process for 23 individuals is costly and incredibly burdensome. And 24 to the best of my knowledge, theres been no 25 individual who has ever successfully intervened in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 hearing process. So that, you know, neither Paul nor 2 I will be filing as interveners in the -- before 3 August 30th on this matter.
4 And again our position is pretty clear 5 that the general design criteria are vague, ambiguous 6 -- the compliance with the general design criteria are 7 vague and ambiguous right now. And are just 8 exacerbated by the up rate.
9 This is -- we really requested something 10 that I consider to be quite simple. And basically if 11 the NRCs right and that Vermont Yankee has clearly 12 and unambiguously addressed all the 70 of the draft 13 general design criteria, it should be simple for all 14 parties to clarify this situation.
15 You know a 15-minute letter from the NRC 16 to Vermont Yankee saying do you or do you not meet the 17 70 design criteria that applied when the plant was 18 built. And if Vermont Yankee, in fact, does have it, 19 a simple letter back saying yes we do and heres proof 20 that we meet the 70 draft design criteria or we take 21 exemption to certain ones for certain issues.
22 The best example we have of a plant, a 23 pre-GDC plant doing just that is Prairie Island.
24 Prairie Island has a very good matrix of what the GDCs 25 were -- what the draft GDCs were and their compliance.
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11 1 And we just cant find anything similar to that on the 2 docket.
3 So, again, Im going to hand it over to 4 Paul now to talk about the -- whether or not we view 5 the information as clear and unambiguous. But we 6 certainly saw this as a simple request and certainly 7 not something that should have taken all of the man 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> that have already been put in.
9 And if Vermont Yankee in fact did meet the 10 general design criteria, it would be simple for 11 Vermont to verify that as well.
12 And, you know, Im sorry this is becoming 13 a monstrous issue but, in fact, its a simple question 14 with a simple solution.
15 Okay, Im going to turn it over to Paul 16 now who is going to talk about clear and unambiguous.
17 MR. BLANCHE: Yes, okay. This is Paul 18 Blanche. And Im going to be talking about a little 19 more than clear and unambiguous.
20 But just to clarify what Arnie just stated 21 as far as the response, what we are really looking for 22 is how does the plant comply with the 70 GDC and how 23 does it deviate? Or does it deviate from any of the 24 general design criteria, and especially General Design 25 Criteria 41, which deals with the net positive suction NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 head.
2 The NRC rejected our petition by stating 3 compliance with the GDCs is clear and unambiguous.
4 We, both Arnie and I, contend that this is an 5 inaccurate statement. Therefore, there is no basis 6 for the rejection. And we are requesting that you 7 substantiate this statement.
8 All we are requesting is that the NRC 9 identify to us where compliance and deviations from 10 the GDCs are addressed within the licensing basis.
11 So far the NRC has refused to provide us 12 with this vital information and has sent us around in 13 circles all leading to dead ends.
14 How I got into this, I initially 15 identified problems with compliance with draft GDC 41 16 and Safety Guide 1 dealing with the net positive 17 suction head. Ive searched through the entire FSAR, 18 2,229 pages, and could not locate where this was 19 addressed.
20 I asked Mr. Ennis where I could find 21 compliance with the general design criteria. Mr.
22 Ennis, in an e-mail, told me that compliance is 23 addressed in Appendix F to the UFSAR.
24 Appendix F, when you read it carefully, 25 states that "design conformance statements to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 current facility design has not be evaluated." And 2 also that its only in there for historic purposes.
3 Appendix F has no meaning whatsoever.
4 Both Arnie and I submitted the 2.206 as 5 the only means of obtaining this vital information.
6 Last week or the week before, I received a phone call 7 from Rick Ennis stating that the petition was going to 8 be rejected.
9 Mr. Ennis also stated to me that Donna 10 Skay had offered us an opportunity to participate in 11 a Petition Review Board and that we declined this 12 invite. I do not recall ever having a conversation 13 with Ms. Skay.
14 So 2.206 Petition impacts the present 15 compliance with the regulation and is not necessarily 16 impacted by the EPU or extended power up rate.
17 However, the extended power up rate should not be 18 considered until the NRC and the public are made aware 19 of Vermont Yankees regulatory compliance.
20 The NRC rejected our petition by stating 21 that compliance with the GDCs is clear and 22 unambiguous. I contend that this is an inaccurate 23 statement. Therefore, there is no basis for the 24 rejection. And Im requesting that you substantiate 25 this statement.
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14 1 All we are requesting that the NRC 2 identify to us where compliance and deviations from 3 the general design criteria are addressed. So far, 4 the NRC has refused to provide us with this vital 5 information.
6 Ive reviewed the entire FSAR and I 7 believe it to be Revision 18, the latest proposed 8 revision, and only found discussions related to two of 9 the GDCs. And these discussions related to the final 10 GDCs and not the draft even though the final is 11 supposedly not applicable to the present design.
12 I have copied the FSAR electronically and 13 I am reasonably sure of the results of my search. I 14 have reviewed many other FSARs, including the Prairie 15 Island, the Millstone, and many others, and find that 16 each and every one of them that Ive reviewed contain 17 a section addressing compliance and deviations from 18 the GDCs and regulatory compliance.
19 We formally request the NRC grant our 20 petition and if rejected, provide us with accurate 21 information as to where the regulatory compliance is 22 addressed.
23 Unless Vermont Yankee can clearly 24 demonstrate compliance with the most basic safety 25 criteria, there is little assurance that the residents NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 around Vermont Yankee are protected by anything more 2 than the intentionally misleading NRCs statements 3 provided to us.
4 I firmly believe that the NRC has a 5 statutory responsibility to provide assurance to the 6 public that Vermont Yankee is in compliance with all 7 regulations. And by rejecting this petition, it is 8 failing to fulfil this vital responsibility.
9 If you believe compliance with the GDCs is 10 clear and unambiguous, I would like you now to provide 11 me an example of where I could locate where compliance 12 with GDC, for example, GDC 45, 47, and 48 could be 13 located. I am not able to locate it in any of the 14 searches of ATOMS (phonetic) or any of the other 15 documents that I have.
16 And we just need some clear and 17 unambiguous answers to our questions. And thats all 18 I have to say right now.
19 MR. GUNDERSON: This is Arnie Gunderson 20 again.
21 I think the one last item that needs to be 22 mentioned is that in the text of your rejection 23 letter, you pin your hopes on Appendix 4, Attachment 24 4 to the January 23rd letter from Vermont Yankee. And 25 its got a BDY number and Im on Acrobat now trying to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 find it.
2 But on January 31st, Attachment 4, Vermont 3 Yankee re-filed for the up rate. And they put -- they 4 gave you -- its called Attachment 4. And theres an 5 Insert 1, which is the BWR Template Safety Evaluation.
6 And they modified the BWR Template Safety Evaluation 7 to address not the GDC but the draft GDC. And thats 8 all well and good.
9 However, what that attachment is is an NRC 10 document which has been fed back to the NRC with a 11 different GDC number in it. There is no statement on 12 the record that states that Vermont Yankee meets that 13 GDC.
14 So whats happening in Attachment 4 is 15 that -- to the January 31st letter, is that Vermont 16 Yankee has fed back to the NRC the NRCs very own 17 document. And is expecting now for the NRC to pour 18 holy water on an NRC document.
19 Theres no statement in Attachment 4 to 20 the January 31st letter which states that Vermont 21 Yankee complies with the GDC. And, in fact, again, if 22 you go back to the appendix in the UFSAR, they state 23 that the GDCs have not been evaluated. I needed to 24 close the loop on that.
25 MR. BLANCHE: Yes, and I want to just add NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 one more comment. What Entergy is doing, or Vermont 2 Yankee is doing, is they want the NRC to state that 3 they are in compliance with the GDCs without them ever 4 stating that they are in compliance.
5 And Id like to hear from Entergy and the 6 NRC as to the statements with respect to compliance 7 with the general design criteria.
8 MR. GUNDERSON: So Insert 1 and Insert 2 9 are an NRC template safety evaluation. And what 10 Entergy has done as been to revise an NRC template and 11 put different GDCs in to reflect the draft versus the 12 final.
13 And, again, it really doesnt matter to 14 either Paul or I which GDC is in there. The fact of 15 the matter is that we can find nothing in the UFSAR or 16 in the January 31st letter which says that they comply 17 with the 70 general design criteria.
18 And, again, if you go to a perfect example 19 of one that we feel works is Prairie Island, which 20 specifically in their UFSAR, they specifically say 21 they comply. And when they dont comply, they note 22 what the exception is.
23 There is nothing on this entire docket 24 which allows us -- you know were not exactly lay 25 people here guys -- to review it to see if the plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 meets the draft GDCs. And, in fact, when we do review 2 what is on the docket, we come to exactly the opposite 3 conclusion.
4 That, in fact -- and Ill use Vermont 5 Yankees last few words here as Im pretty much done, 6 in the UFSAR, Vermont Yankee says -- and we had this 7 in the text of our letter, too, which surprises us 8 that you guys would say its clear and unambiguous 9 when Vermont Yankee is telling you, "the applicability 10 of historic design criteria conformance statements to 11 the current facility design has not been evaluated."
12 Vermont Yankee has not evaluated its 13 existing design -- forget the up rate -- its existing 14 design to see if it meets the GDCs. And yet you are 15 allowing them to leverage that onto the up rate, which 16 is certainly going to exacerbate any problems which 17 may have occurred earlier.
18 MR. BLANCHE: And again this is Paul 19 Blanche. I dont have the verbatim words but 20 somewhere in Appendix F it states that compliance with 21 the general design criteria is addressed in the body 22 of the UFSAR. I was unable to locate anywhere in that 23 document where compliance with other than two new GDCs 24 is even addressed.
25 MR. GUNDERSON: And again, its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 fascinating. Even the ones that Vermont Yankee does 2 address, they dont compare to the old draft GDCs but 3 therein discussing how they comply with the new GDCs.
4 So in the two examples weve been able to 5 find where Vermont Yankee addresses compliance with 6 GDCs, they talk about the new GDCs. In all of the 7 other -- we have 2,200 pages in the computer and we 8 searched for the GDCs. And we cannot find, you know, 9 I guess 68 of the 70 GDCs being specifically addressed 10 to see if they meet them.
11 MR. BLANCHE: The only GDCs that are 12 addressed in the body are Criteria 19, which is 13 control room habitability, and General Design Criteria 14 12, and Im not sure what that is. But thats all 15 Ive been able to find.
16 MR. GUNDERSON: I really have nothing to 17 summarize. You know weve got -- I think our petition 18 was pretty clear. And I think weve certainly been 19 able to expand on that by speaking to you guys for 20 about 20 minutes.
21 But, again, just to summarize, its a 22 simple problem. Its a letter from the NRC. It takes 23 15 minutes to write. Do you guys comply with the 24 GDCs? Yes? No? Tell us where.
25 And given that the NRC feels that its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 clear and unambiguous that Vermont Yankee does comply, 2 it should be a 15-minute letter back from Vermont 3 Yankee saying yes we comply with the 70 general design 4 criteria.
5 But after a thorough review by two 6 relatively competent guys here, we cant prove that 7 the existing design, let alone the up rate, complies 8 with the general design criteria.
9 MR. BLANCHE: And this engineering 10 inspection, I dont know how meaningful that could be 11 if the NRC itself doesnt know how the plant was 12 designed, which is clear from the misinformation Ive 13 been getting from the NRC.
14 So any meaningful inspection of the 15 facility would have to know what its design basis is.
16 And the general design criteria is the foundation of 17 all the regulations.
18 MR. GUNDERSON: Okay, Im off. Paul, I 19 have nothing else to say. Do you?
20 MR. BLANCHE: No, Id like to hear a 21 response from Entergy and the NRC.
22 MR. ENNIS: This is Rick Ennis. Does 23 Entergy have any questions or comments they would like 24 to make?
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21 1 Davidson (phonetic) at Entergy Nuclear Operations. We 2 have no comments.
3 (Inaudible.)
4 MR. GUNDERSON: So I guess now, as I 5 understood your opening -- this is Arnie Gunderson --
6 as I understood your opening remarks, I guess you will 7 respond, either reopening our 2.206 or rejecting our 8 2.206 based on this conversation?
9 PARTICIPANT: Yes, thats what we will do.
10 MR. ENNIS: This is Rick Ennis and Id 11 like to ask a question from petitioners. How do your 12 concerns relate to specific regulatory requirements 13 for a licensee to provide information in the FSAR or 14 to provide information to the NRC with respect to a 15 license amendment request?
16 MR. BLANCHE: Okay. I believe, I could be 17 wrong, but 50.71E requires accurate information to be 18 provided in periodic updates to the FSAR, and NEI 9803 19 and Regulatory Guide 1.81.
20 MR. GUNDERSON: No, Paul, its Regulatory 21 Guide 1.181.
22 MR. BLANCHE: Right.
23 MR. GUNDERSON: It was issued in September 24 of 99. And the objective on the top of the second 25 page of Regulatory Guide 1.81 states:
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22 1 "The objectives of 10 CFR 50.51E are to 2 ensure that licensees maintain the information in the 3 UFSAR to reflect the current status of the facility,"
4 the current status of the facility, "and address new 5 issues as they arise so that the UFSAR can be used as 6 a reference document in safety analysis."
7 And its our position that based on that 8 reg guide, we cant use the UFSAR as a reference 9 document in a safety analysis. And were pretty smart 10 dudes. And it looks to us like Entergy, the existing 11 UFSAR -- forget the up rate -- the existing UFSAR as 12 well as any new issues which theyre attempting to 13 install, the up rate on the plant, have not been 14 addressed in the UFSAR. So we cannot use it as a 15 reference document in safety analysis.
16 MR. BLANCHE: And Id like to state 17 something for the record that the laughter that was 18 heard in the background did not come from myself and 19 I dont believe it came from Mr. Gunderson either.
20 MR. GUNDERSON: No, it wasnt me either.
21 MR. LEWIS: This is Steve Lewis. We 22 really didnt -- were not influenced by any laughter 23 that was taking place. So dont be concerned about 24 that.
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23 1 that were not laughing. This is not a joking matter 2 to me.
3 MR. LEWIS: No, were not laughing here 4 either.
5 MR. GUNDERSON: Okay, Paul, I have nothing 6 else to say. Are you clear?
7 MR. BLANCHE: I have nothing else to say.
8 NRC? Anything else?
9 MR. ENNIS: We have nothing else. Thank 10 you very much --
11 MR. BLANCHE: Are we going to get a call 12 or a letter on this?
13 MR. ENNIS: -- for the information that 14 you provided today. And the Petition Review Board 15 will consider that as we continue to deliberate.
16 MR. BLANCHE: Okay. Thats all I have.
17 I thank you very much for your time.
18 MR. GUNDERSON: Thank you.
19 MR. ENNIS: Thank you.
20 (Whereupon, the foregoing matter was 21 concluded.)
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