ML12234A730
| ML12234A730 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  (DPR-062, DPR-071) |
| Issue date: | 08/15/2012 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Saba F | |
| References | |
| NRC-1810 | |
| Download: ML12234A730 (22) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 RE Brunswick Units 1and 2 Docket Number:
(n/a)
Location:
(teleconference)
Date:
VVednesday,August15,2012 VVork Order No.:
NRC-1810 Pages 1-22 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
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12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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10 CFR 2.206 PETITION REVIEW BOARD (PRB)
CONFERENCE CALL RE BRUNSWICK UNITS 1 AND 2
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WEDNESDAY AUGUST 15, 2012
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The conference call was held, Samson S. Lee, Chairperson of the Petition Review Board, presiding.
PETITIONERS: DAVID LOCHBAUM MARY OLSON JIM WARREN PETITION REVIEW BOARD MEMBERS SAMSON S. LEE, Deputy Division Director, Division of Risk Assessment, Office of Nuclear Reactor Regulation, Chairperson of the Petition Review Board FARIDEH SABA, Petition Manager for 2.206 petition MERRILEE J. BANIC, Petition Coordinator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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NRC HEADQUARTERS STAFF MOLLY L. MARSH, Attorney, Office of General Counsel ROSSNYEV D.
- ALVARADO, Instrumentation and Control Branch, Division of Engineering, Office of Nuclear Reactor Regulation KENT A.L. WOOD, Team Leader, Spent Fuel Team, Reactor Systems Branch, Division of Safety Systems, Office of Nuclear Reactor Regulation EVAN J. DAVIDSON, Balance of Plant Branch, Division of Safety Systems, Office of Nuclear Reactor Regulation HAROLD WALKER, Containment and Ventilation Branch, Division of Safety Systems, Office of Nuclear Reactor Regulation LAUREN R. CASEY, Enforcement Specialist, Office of Enforcement GERALD M. WAIG, Senior Reactor Systems Engineer, Technical Specifications Branch, Office of Nuclear Reactor Regulation KRISTY A. BUCHOLZ, Technical Reviewer, Technical Specifications Branch, Office of Nuclear Reactor Regulation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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RANDALL A. MUSSER, Branch Chief, Division of Reactor Projects, Region II MICHELLE P. CATTS, Senior Resident Inspector DAVID L. PELTON, Chief of the Generic Communications Branch, Office of Nuclear Reactor Regulation ALSO PRESENT CHARLIE DONALDSON, Assistant Attorney General, New York State Attorney General's Office MARK TURKAL, Lead Engineer, Brunswick Licensing at Progress Energy ANNETTE POPE, Manager, Organizational Effectiveness, Brunswick Nuclear Generating Station KATE BARBER NOLAN, Associate General Counsel, Duke Energy Corporation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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PRO C E E DIN G S (9:02 a.m.)
MS. SABA: Good morning. My name is Farideh Saba. I'd like to thank everybody for attending this meeting. Again, my name is Farideh Saba, and I am the Brunswick Project Manager.
We are here today to allow the Petitioners, Mr. David Lochbaum, Mr. Jim Warren l and Ms. Mary Olson to address the Petition Review Board, PRB 1 regarding the 2206 Petition dated July 10~, 2012.
I am the Petition Manager for this petition.
The PRB Chairman is Dr. Samson Lee.
AS part of the PRB's review of this petition l Mr.
David Lochbaum has requested this opportunity to address the PRB.
This meeting is scheduled from 9: 00 to 11: 00 a.m. Eastern time. The meeting is being recorded by the NRC Operations Center, and will be transcribed by a court reporter. The transcript will become a supplement to the petition. The transcript will also be made publicly available.
I'd like to open the meeting with introductions. As we go around the room please be sure to clearly state your name I your position, and the office that you work for within the NRC for the record. I'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W.
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9 11 12 13 14 16 17 18 19 21 22 23 24 start off. My name is Farideh Saba. I'm a Senior project Manager in Division of Operating Reactors Licensing, Office of Nuclear Reactor Regulation, NRR.
DR. LEE: Samson Lee. I'm the Deputy Division Director, Division of Risk Assessment, NRR, and I'm the PRE Chair.
MS.
BANIC:
Merrilee Banic,
- NRR, 2.206 Petition Coordinator.
MS. MARSH: I'm Molly Marsh. I'm an attorney in the Office of General Counsel.
MS. ALVARADO: Rossnyev Alvardo. I'm with NRR, Division of Engineering, I&C Branch.
MR. WOOD: My name is Kent Wood. I'm the team leader for technical team in the Reactor Systems Branch, Division of Safety System in the Office of Nuclear Reactor Regulation.
MR.
PELTON:
David Pelton, Chief of the Generic Communications Branch. I'm responsible for the 2.206 process implementation, the Office of NRR.
MR. DAVIDSON:
Evan Davidson, Balance of plant Branch, NRR.
MR.
WALKER:
I'm Harold Walker from Containment and Ventilation Branch in the Division of Safety Systems, NRR.
MS. CASEY: I'm Lauren Casey, an enforcement NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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specialist in the Office of Enforcement.
2 MS.
SABA:
Okay.
We've completed 3
introductions at the NRC Headquarters. At this time, are there any NRC participants from Headquarters on the 5
phone? Please introduce yourself.
6 MR.
WAIG:
This is Gerald Waig, Senior 7
Reactor Systems Engineer.
I'm with the Technical 8
Speci cations Branch, the Office of NRR.
9 MS. BUCHOLZ: This is Kristy Bucholz. I am 1
in NRR, Technical Specifications Branch, a technical 1
reviewer.
12 MS. SABA: Okay. It looks like we don't have 13 anybody else from Headquarters. Are there any NRC 14 participants from the regional offices on the phone?
15 MR. MUSSER: Good morning. This is Randy 16 Musser, Division of Reactor Projects Branch Chief in 17 Region II.
18 MS. CATTS: Hello, this is Michelle Catts.
19 I'm the NRC Senior Resident Inspector at Brunswick.
2 MS. SABA: Okay, it looks like we are done 21 with the Headquarters and Region. Mr. Lochbaum, Mr.
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- Warren, and Ms.
Olson, would you please introduce 23 yourselves for the record.
24 MR. LOCHBAUM: Go ahead, Mary.
2 MS. OLSON: I'm sorry, I had my phone on mute.
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21 22 23 24 25 I'm Mary Olson. I'm the Southeast Regional Coordinator for Nuclear Information and Resource Service. We are a national educational and advocacy organization with members in all 50 states including North Carolina.
MR.
LOCHBAUM:
This is David Lochbaum, Director of the Nuclear Safety Proj ect with the Union of Concerned Scientists.
MS. SABA: It appears that Mr. Warren has not joined us yet. It is not required for the members of the public to introduce themselves for this call. However, if there are any members of the public on the phone that wish to do so at this time, please state your name for the record.
MR. DONALDSON: Charlie Donaldson, New York State Attorney General's Office. That's Charlie with an I-E, it's not Charles.
MS. SABA: Are there anybody else from the member of public or the licensee on the phone? Please introduce yourself.
MR. TURKAL: This is Mark Turkal. I'm Lead Licensing Engineer at the Brunswick plant.
MS. POPE: Annette Pope, Brunswick Nuclear Plant, Manager of Organizational Effectiveness.
MS. SABA: Okay.
MS. NOLAN: Kate Barber Nolan, Duke Energy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w, (202) 234-4433 WASHINGTON, D,C. 20005-3701 WWIN.nealrgross.com
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15 16 17 18 19 20 21 22 23 24 25 Legal.
MS.
SABA: Are there any other member of public on the phone? Is the court reporter on the line?
COURT REPORTER: Yes, the court reporter is on the line.
MS. SABA: Okay. I'd like to emphasize that we each need to speak clearly and loudly to make sure that the court reporter can accurately transcribe this meeting. If you do have something that you would like to say, please first state your name for the record. For those dialing into the meeting, please remember to mute your phone to minimize any background noise or distractions. If you do not have a mute button, this can be done by pressing the keys *6. To unmute please press the *6 keys again. Thank you.
At this time I'll turn it over to the PRB Chairman, Dr. Samson Lee.
DR.
LEE:
Good morning. Welcome to this meeting regarding the 2.206 petition submitted by Mr.
Lochbaum, Ms. Olson, and Mr. Warren.
I would like to first share some background on our process. Section 2.206 of Title 10 of the Code of Federal Regulations describes the petition process, the primary mechanism for the public to request enforcement action by the NRC in a public process.
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This process permits anyone to petition NRC to take enforcement-type action related to NRC licensees or licensed activities. Depending on the results of this evaluation, NRC could modify, expand, or revoke an NRC issued license or take any other appropriate enforcement actions to resolve a problem.
The NRC Staff Guidance for the disposition of 2.206 petition requests is in Management Directive 8.11 which is publicly available.
The purpose of today's meeting is to give the petitioner an opportunity to provide any additional explanation or support for the petition before the PRB' s initial consideration and recommendation.
This meeting is not a hearing, nor is it an opportunity for the petitioner to question or examine the PRB on the merits of the issues presented in the petition request. No decisions regarding the merits of this petition will be made at this meeting.
Following this meeting, the PRE will conduct its internal deliberations. The outcome of this internal meeting will be discussed wi th the petitioner.
The PRB typically consists of a Chairman, usually a manager at the Senior Executive Service level at the NRC, and a petition manager and a PRB coordinator.
Other members of the Board are determined by the NRC staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 22 23 24 25 based on the content of the information in the petition request.
At this time I would like to introduce the Board. I'm Samson Lee, the PRB Chairman. Farideh Saba is the Petition Manager for the petition under discussion today. Merrilee Banic is the Office PRB Coordinator. Our technical staff includes Randy Musser and Jim Dodson from Region II, Kris Bucholz and Gerry Waig, Office of Nuclear Reactor Regulations, NRR, Division of Safety Systems, DSS, Technical Specifications Branch. Steven Jones and Evan Davidson, NRR, DSS, Balance of Plant Branch, Harold Walker, NRR, DSS, Containment and Ventilation Branch, Kent Wood, NRR, DSS, Reactor System Branch, Rossnyev Alvarado, NRR, Division of Engineering, Instrumentation
& Controls Branch. We also obtain advice from our Office of General Counsel and Office of Enforcement represented by Molly Marsh and Lauren Casey respectively.
As described in our process, the NRC staff may ask clarifying questions in order to better understand the petitioner's presentation, and to reach a reasoned decision whether to accept or reject the petitioner's request for review under the 2.206 process.
I would like to summarize the scope of the petition under consideration and the NRC activities to date. On July 10, 2012, Mr. David Lochbaum submitted to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W.
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16 17 18 19 20 21 22 23 24 25 the NRC a petition under 10 CFR 2.206 process regarding irradiated fill at Brunswick Steam Electric Power Plant, Brunswick on behalf of the North Carolina waste Awareness and Reduction Network, NCWARN, the Nuclear Information and Resource Services, NIRS, and the Union of Concerned Scientists, UCS.
In this petition request, Mr.
Lochbaum requested that the NRC take enforcement action in the form of an order either modifying the Brunswick operating licenses, or obtain or require the licensee to submit amendment request for these licenses.
In summary, Mr. Lochbaum requested that the NRC revise the Brunswick Unit 1 and Unit 2 technical specifications as speci ed in his petition request.
Allow me to discuss the NRC activities to date. On July 12, 2012, the Petition Manager contacted Mr. Lochbaum to acknowledge the receipt of his letter, and discuss the 10 CFR 2.206 process and to offer him an opportunity to address the PRB by phone or in person.
Mr. Lochbaum requested to address the PRB by phone, or if possible in person on August 7th or 8 th prior to its internal meeting to make the initial recommendation to accept or rej ect the petition for review. Due to meeting conflicts, the PRB members were unable to support a meeting in person on August or 7th NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 th August Subsequently, on July 21st, the Petition Manager informed Mr. Lochbaum via email of the planned teleconference on August 15 th By an email dated July 26, 2012, Mr. Lochbaum accepted the date and time of planned teleconference.
As a reminder for the phone participants, please identify yourself if you make any remarks as this will help us in the preparation of the meeting transcript that will be made publicly available. Thank you.
Mr. Lochbaum, I'll turn it over to you to allow you to provide any information you believe the PRB should consider as part of this petition. Mr. Lochbaum.
MR. LOCHBAUM: This is Dave Lochbaum. Thank you and good morning.
On behalf of
- NCWARN, the Nuclear Information and Resource Service, and the Union of Concerned Scientists, I appreciate this opportunity to speak to our recent petition seeking to correct deficiencies in the technical specifications for the two reactors at the Brunswick Nuclear Power Plant in North Carolina.
As described in our petition, the technical specifications contain many requirements intended to protect workers and the public from the irradiated fuel in the spent fuel pools. The table on page 3 of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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16 17 18 19 20 21 22 23 24 25 petition lists these requirements.
The hazard that these requirements seek to protect against is the irradiated fuel. But as the table illustrates, whi the hazard exists any time irradiated fuel is within the spent fuel pool the requirements only apply sometimes.
Our petition seeks to remedy this shortcoming by having these protective measures apply any time irradiated fuel is within the spent fuel pool.
In other words, any time the hazard is present the associated protective measures should be required to be present, also.
I believe our petition is clear on this point, but I would be glad to answer any questions you have to supplement or clarify the information presented in the petition.
My main purpose in asking to speak with you this morning was to cover one point that was not clearly made our petition; namely, the adverse consequences from denying this petition and maintaining the status quo.
On March 12th of this year, the NRC issued three orders to plant owners, including the licensee for the Brunswick Nuclear Power Plant. One of these orders involved water level instrumentation for the spent fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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pools. rrhe specific order is in NRC I S ADAMS library under Accession Number ML12054A679. Attachment 2 to the NRC order defined nine design requirements required and availability and reliability attributes for the spent fuel pool instrumentation.
None of these 12 items explicitly or even implicitly requires that this spent fuel pool water level instrumentation be operable or functional at all times when irradiated fuel is in the spent fuel pool.
Because availability is not specified the order, the defau1 t requirement then becomes defined by standard industry practice and regulatory convention.
When a system, structure, or component is required to be operable all of its associated power
- supplies, instrumentation, and alarms are also required to be operable. Conversely, when a system, structure, or component is not required to be operable neither are its power supplies, instruments, and alarms.
Currently, Brunswick Technical Specification 3.7.7 only requires water level inside the spent fuel pool during operating modes 4 and 5 when an irradiated fuel assembly is being moved in the pool.
Otherwise, this technical specification requirement is not applicable.
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instrumentation to be installed by the NRC's recent order could be intentionally removed from service as long as irradiated fuel is not being moved in the spent fuel pool, or if this instrumentation broke there would be no legal requirement for Brunswick's owner to fix it before the next movement of irradiated fuel inside the spent fuel pool, which could be weeks or months into the future.
Once our petition is granted and the deficiencies the Brunswick technical specifications corrected, the water level instrumentation mandated by the NRC's order would be legally required to be operable and functional any time irradiated fuel was stored in the spent fuel pool, not just when it was being moved. In addition, all other attendant protective measures like power supplies, containment, and ventilation systems would also be legally required.
We're not required under 10 CFR 2.206 to show that the requested actions do not place undue burden on the licensee, but I would like to address that point anyway.
The technical specifications for the Pilgrim Nuclear Power Plant, which are available in the NRC's ADAMS library under Accession Number ML052720275 already contain the requirements we seek in our petition at Brunswick.
For
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12 13 14 15 16 17 18 19 20 21 22 23 24 25 Specification 3.10.C requires adequate water level be maintained in the spent fuel pool at all times when it contains irradiated fuel.
Pilgrim is not operating at an economic disadvantage compared to Brunswick because of this technical specification disparity. There is no undue burden associated with 19rim's technical specifications requiring protective measures to be enforced more broadly than currently at Brunswick.
Hence, it will not be an undue burden for Brunswick owner to implement the actions requested by our petition.
- Instead, the actions requested in our petition once implemented will provide reasonable assurance that workers and members of the public are adequately protected against the hazard associated with irradiated fuel stored in the spent fuel pools at Brunswick. For this reason, the NRC must grant our petition and compel this licensee to rectify deficiencies in the Brunswick technical specifications.
I appreciate this opportunity to address you regarding our petition, and would be glad to answer any questions that you have. Thank you. Mary, do you have anything to add?
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OLSON:
Thank you, Dave.
I really appreciate this opportunity, as well. And I don't have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 anything technical to add, but I do want to point out that part of the inspiration for this concern on our part and catching it at this time is due to the design of this reactor and its similarity to the Fukushima reactors. And while we appreciate the Nuclear Regulatory Commission's efforts to learn from that event, published reports and meetings, and talking is one step. The next step is implementation of actual regulatory diligence and enforcement of those regulations to actually bring a greater level safety.
I don't think this is about popularity or public opinion. I think it is about implementing legal mandate under the Atomic Energy Act. However, I will tell you that in my 22 years in this field I have not seen the ground swell of concern about this federal regulator that has happened since 2011, and this is a stellar opportunity for each individual in this room where you are and on the line in the virtual space to hear and understand that the public is counting on you to actually not only learn from Fukushima, but act on those lessons.
And I think that USC, Union of Concerned Scientists, is doing a wonderful job of providing you with a very simple opportunity to demonstrate your capacity to not only pay attention, not only to learn and discuss, but to actually act.
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21 22 23 24 25 18 DR. LEE: At this point, does the staff here at Headquarters have any questions for Mr. Lochbaum or Ms. Olson?
MR. WOOD: I have one. This is Kent Wood from Office of Nuclear Reactor Regulation. You requested this tech specs being made applicable any time that there is irradiated fuel in the spent fuel pool. And I was wondering if you're considering that, you know, would there be circumstances where these things would not be required even if there is irradiated fuel in the spent fuel pool?
MR.
LOCHBAUM: This is David Lochbaum. I guess at the moment I don't -
when I prepared the petition I didn't envision that, but I guess the licensee in responding to the order, if an order is issued, could always come up with scenarios where they wouldn't be required based on a safety argument. If that's the case, and a sufficient argument is made, then that would be a suitable option.
I didn't envision that coming in, but if that's presented and adequately justified, then that would seem to be okay.
MR. WOOD: Okay.
MS. ALVARADO: I have a question. This is Rossnyev Alvarado to Division of Engineering, f
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21 22 23 24 25 Instrumentation and Control Branch. In the item 3 that you suggest modification to the technical spec, it was 3.3.7.1-1 regarding this high function for control building air intake variations. In the specification that you provide for these you said that this function has to be included in the table, so when the spent fuel is in the pool there is no problem or issues with the control building air intake.
The question that I have why do you consider this required when we have radiation monitors installed in the intake to detect if there is any variation, and that would trigger the activation of the control board.
MR. LOCHBAUM: I guess the reason I -- this Dave Lochbaum. The reason I included it in the petition is that that function is required currently in the technical specifications only when irradiated fuel is being moved. If the configuration as you stated was correct, then it would seem like that requirement would be unnecessary, so I'm assuming the current requirement is necessary. And if so, then it needs to be applicable more broadly than just when irradiated fuel is being moved, so that's why I included it in the table, and in the petition.
MS. ALVARADO: Okay, thank you.
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2 21 22 23 24 25 DR. LEE: Does the staff at the Regions have any questions for Mr. Lochbaum or Ms. Olson?
MR. MUSSER: Randy Musser has no questions for Mr. Lochbaum or Ms. Olson.
DR.
LEE:
Does the licensee have any questions?
MR.
TURKAL:
This is Mark Turkal with Brunswick Licensing. I have no questions.
DR. LEE: Before I conclude the meeting, members of the public may provide comments regarding the petition and ask questions about the 2.206 tion process. However, as stated at the opening, the purpose of this meeting is not to provide an opportunity for the petit or the public to question or examine the PRB regarding the merits of the petition request. Does any public want to make any comments?
MR. DONALDSON: New York has no questions or comments.
DR. LEE: Mr. Lochbaum and Ms. Olson, thank you for your time to provide the NRC staff with clarifying information on the petition you have submitted.
Before we close, does the court reporter need any additional information for the meeting transcript?
COURT REPORTER: This is the court reporter.
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It would be helpful if somebody could email me a list of 2
the participants from the NRC. If you 1
, I could give 3
you my email address.
MS. SABA: Yes. This is Farideh Saba. Please send me an email and I'll respond to you.
COURT REPORTER: Okay. What is your email 7
address?
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SABA: I'm the one who requested the 9
report. Farideh Saba.
1 COURT REPORTER: Can you spell that?
1 MS. SABA: F-A-R-I-D-E-H.S 12 COURT REPORTER: All right, thank you.
13 MS. SABA: Thanks.
1 DR. LEE: With that, the meeting is concluded 1
and we will be terminating the phone connection. Thank 16 you.
17 (Whereupon, the proceedings went off the 18 record at 9:29 a.m.)
19
.gov.
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