ML20115E448
| ML20115E448 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2020 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML20115E445 | List: |
| References | |
| FOIA, NRC-2020-000129 | |
| Download: ML20115E448 (107) | |
Text
From: Erickson, Alice <IMCEAEX-_0=USNRC_0U=EXCHANGE+20ADMIN1STRATIVE+
20G ROU P+20+28FYDIBOHF23SPDLT+29_CN =RECIPIENTS_CN=AKP1
@usnrc.onmicrosoft.com>
Sent: Monday, December 08, 2014 8:48 AM To: Thormas, George
Subject:
FW: REQUEST: Support needed for PRM 50- 109, ASR Concrete Degradation FYI From: Marshall, Michael Sent: Monday, November 17, 2014 4:48 PM To: Kratchman, Jessica Cc: Diaz-Sanabria, Yolra; Erickson, Allee
Subject:
RE: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Hello Jessie, Alice Erickson will be assigned to support the disposition of the PRM. Alice is a structural engineer that is familiar with the standards listed below and ASR.
Best Regards, Michael L. Marshall, Jr.
Chief Aging Management of Structures, Electrical, and Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation 301-415-2871 Email: michael.marshall@nrc.gov From: Diaz-Sanabria, Yolra Sent: Monday, November 17, 2014 3:46 PM To: Marshall, Michael
Subject:
FW: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Michael, This seems right in your alley. I think they need a technical expert from DLR rather than a PM. What do you think?
Yoira From: Kratchman, Jessica Sent: Monday, November 17, 2014 3:33 PM To: Ott, William; Lupold, Timothy; Colaccino, Joseph; Bladey, Cindy; Diaz-Sanabria, Yoira Cc: Inverso, Tara; Beall, Robert; Philip, Jacob; Fuhrmann, Mark SUbject: REQUEST: Support needed for PRM 50-109, ASR Congrete Degradation Branch Chiefs, 1
I am the NRR PM managing a recent petition issued under 10 CFR 2.802, petition for rulemaking (PRM), regarding the use of visual inspection in the identification of alkali-silica reaction (ASR) concrete degradation. The petitioner is C-10 Research. C-10 has petitioned the NRC to require that all licensees comply with ACI 349.3R, and ASTM C 856-11 . They feel the current reliance on a visual inspection does not adequately identify ASR or provide the current state of ASR damage. While the petitioner refers to Seabrook within the petition, they have identified this as a fleet-wide concern.
I would like to request a member of your staff to be on my working group to resolve this petition. The working group will normally meet once or twice a month, support the Petition Review Board presentation, and write various sections of the FRN to disposition the PRM.
The C-10 petition is attached to this e-mail for your review. We are currently sending out the FRN to formally notice the acceptance and docking of the petition. We are also asking for public comments on the PRM at the same time. Please let me know who you believe should be the lead technical organization for this effort.
Please let me know who from your staff will be participating in the PRM working group by COB December 3, 2014. I have included individuals from RES/DRNETB..NRR/DE/EMCB, NRR/DLR/RPB1, NRO/DARR/NARGB, ADM/RADB.
Let me know if you have any questions.
-Jessie Jessica Kratchman., candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Erickson, Alice <IMCEAEX-_O=USNRC_0U=EXCHANGE+20ADMIN1STRAT1VE+
20GROUP+20+28FYDIB0HF23SPDLT+29_CN=RECIPIENTS_CN: AKP1
@usnrc.onmicrosoft.com >
Sent: Tuesday, December 09, 2014 7:32 AM To: Thomas, George
Subject:
FW: HEADS-UP: Support needed*for PRM 50-109, ASR Concrete Degradation Attachments:
seabrook ASR petition for rulemaking 2.802.pdf Note: The petition is publicly available in ADAMS as ML14281A124.
I shou ld have sent you this email with the PRM attached © From: Marshall, Michael Sent: Monday, November 17, 2014 4:49 PM To: Erickson, Alice
Subject:
HEADS-UP: Support needed for PRM 50-109, ASR Concrete Degradation From: Diaz-Sanabria, Yoira Sent: Monday, November 17, 2014 3:46 PM To: Marshall, Michael
Subject:
FW: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Michael, This seems right in your alley. I think they need a technical expert from DLR rather than a PM. What do you think?
Yoira From: Kratchman, Jessica Sent: Monday, November 17, 2014 3:33 PM To: Ott, William; Lupold, Timothy; Colaccino, Joseph; Bladey, Cindy; Diaz-Sanabria, Yoira Cc: Inverso, Tara; Beall, Robert; Philip, Jacob; Fuhrmann, Mark
Subject:
REQUEST: Support needed for PRM 50-109, ASR Congrete Degradation Branch Chiefs, I am the NRR PM managing a recent petition issued under 10 CFR 2.802, petition for rulemaking (PRM), regarding the use of visual inspection in the identification of alkali-silica reaction (ASR) concrete degradation. The petitioner is C-10 Research. C-10 has petitioned the NRG to require that all licensees comply with ACl *349.3R, and ASTM C 856-11. They feel the current reliance on a visual inspection does not adequately identify ASR or provide the current state of ASR damage. While the petitioner refers to Seabrook within the petition, they have identified this as a fleet-wide concern.
I would like to request a member of your staff to be on my working group to resolve this petition. The working group will normally meet once or twice a month, support the Petition Review Board presentation, and write various sections of the FRN to disposition the PRM.
The C-10 petition is attached to this e-mail for your review. We are currently sending out the FRN to formally notice the acceptance and docking of the petition. We are also asking for publ'ic comments on 1
the PRM at the same time. Please let me know who you believe should be the lead technical organization for this effort.
Please let me know who from your staff will be participating in the PRM working group by COB December 3, 2014. I have included individuals from RES/DRA/ETB, NRR/DE/EMCB, NRR/DLR/RPB1 ,
NRO/DARR/NARGB, ADM/RADB.
Let me know if you have any questions.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Erickson, Alice < IMCEAEX-_O=USN RC_OU= EXCHANGE+20ADMI NISTRATIVE +
20GROUP+ 20+28FYDIBOHF23SPDLT+ 29_CN= RECIPIENTS_CN=AKP1
@usnrc.onmicrosoft.com >
Sent: Monday, January OS, 2015 8:37 AM To: Thomas, George
Subject:
FW: SharePoint Site established: PRM 50-109 ASR Concrete degradation FYI From: Kratchman, Jessica Sent: Friday, January 02, 2015 11:14 AM To: Erickson, Alice; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob Cc: Kratchman, Jessica
Subject:
SharePoint Site established: PRM 50-109 ASR Concrete degradation To anyone still left in the office!
I have established and populated the SharePoint site for PRM 50-109, regarding ASR concrete degradation.
When you have a moment please look over the documents and save this site for our future use.
Thanks and I look forward to working with everyone in the New Year!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-Slli 1
From: Kratchman, Jessica Sent: Monday, January 05, 2015 9:07 AM To: Erickson, Alice cc:* Thomas, George Subjed: RE: UPDATE: Kickoff Meeting: PRM 50-109: ASR Concrete Degradation Thank you. I will make note.
-Jessie
Original Appointment-----
From: Erickson, Alice Sent: Monday, January 05, 2015 8:24 AM To: Kratchman, Jessica Cc: Thomas, George
Subject:
Declined: UPDATE: Kickoff Meeting: PRM 50-109: ASR Concrete Degradation When: Wednesday, January 14, 2015 10:30 AM-11:00 AM (lJTC-05:00) Eastern Time (US & canada).
Where: HQ-OWFN-12B02-12p
- Jessica, I am no longer in DLR, so my role has been reassigned to George Thomas. I have forwarded him the invite, but please include him in future correspondence.
Thank you, Alice 1
From: Kratchman, Jessica Sent: Thursday, January 08, 2015 9:44 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George Cc: Beall, Robert
Subject:
FYI: FRN for PRM 50-109 to be published Attachments: C-10 Petition - Notice of Docketing and Request for Comments.docx Good Morning, Some good news related to PRM 50-109, ASR Concrete Degradation- the Notice of Docketing FRN and request for public comments was delivered to OFR on 01/06. Please review the attached and I look forward to meeting everyone at our upcoming kick-off meeting. You can also find the attached, as well as other background materials, on our SharePoint site.
Thanks.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Craver, Patti Sent: Wednesday, January 07, 2015 10:28 AM To: Couret, Ivonne; Harrington, Holly; Mdntyre, David; Bladey, Cindy; Terry, Leslie; Kratchman, Jessica; Love-Blair, Angella; Barczy, Theresa; I nverso, Tara Cc: Lewis, Antoinette; Remsburg, Kristy; Shea, Pamela; Newell, Brian; Speiser, Herald; Giitter, Rebecca; Julian, Emile; Sola, Clara
Subject:
FRN to be published Happy New Year, Subject FRN:
Petition for rulemaking; notice of docketing, and request for comment - Improved Identification Techniques against Alkali-Silica Reactor Concrete Degradation at Nuclear Power Plants (PRM-50-109)
The attached FRN was delivered to the Office of the Federal Register Tuesday, January 6, 2015 .
It is the staff's responsibility to declare their document (FRN) in ADAMS {ML14317A415) once it has been published in the Federal Register. Staff can verify publication of their document at the following web site: http://www.gpo.gov/ fdsys/ click on Federal Register located at the right hand box.
1
- Thanks, Patti Craver Correspondence and Records Staff Office of the Secretary U.S. Nuclear Regulatory Commission (301) 415-1513 2
[7590-01-P]
NUCLEAR REGULATORY COMMISSION 10 CFR Part 50
[Docket No. PRM-50-109; NRC-2014-0257]
Improved Identification Techniques against Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.
ACTION: Petition for rulemaking; notice of docketing, and request for comment.
SUMMARY
- The U.S. Nuclear Regulatory Commission {NRC) has received a petition for rulemaking (PRM) from Sandra Gavutis on behalf of C-10 Research and Education Foundation (C-10 or the petitioner), dated September 25, 2014, requesting that the NRC amend its regulations to provide improved identification techniques against Alkali-Silica Reaction (ASR) concrete degradation at nuclear power plants. The petition was docketed by the NRC on October 8, 2014, and has been assigned Docket No. PRM-50-109. The NRC is requesting public comments on this petition for rulemaking.
DATES: Submit comments by [INSERT DATE THAT IS 75 DAYS AFTER PUBLICATION].
Comments received after this date will be considered if it is practical to do so, but the NRC is able to assure consideration only for comments received on or before this date.
ADDRESSES: You may submit comments by any of the following methods (unless this document describes a different method for submitting comments on a specific subject):
- Federal rulemaking Web site: Go to http://www.regulations.gov and search for Docket ID NRC-2014-0257. Address questions about NRC dockets to Carol Gallagher; telephone: 301-287-3422; e-mail: Carol.Gallagher@nrc.gov. For technical questions, contact the individual(s) listed in the FOR FURTHER INFORMATION CONTACT section of this document.
- E-mail comments to: Rulemaking.Comments@nrc.gov. If you do not receive an automatic e-mail reply confirming receipt, then contact us at 301-415-1677:
- Fax comments to: Secretary, U.S. Nuclear Regulatory Commission at 301-415-1101.
- Mail comments to: Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Rulemakings and Adjudications Staff.
- Hand deliver comments to: 11555 Rockville Pike, Rockville, Maryland 20852, between 7:30 a.m. and 4:15 p.m. {Eastern Time) Federal workdays; telephone: 301-415-1677.
For additional direction on accessing information and submitting comments, see "Obtaining Information and Submitting Comments" in the SUPPLEMENTARY INFORMATION section of this document.
FOR FURTHER INFORMATION CONTACT: Jessica Kratchman, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; telephone:
301-415-5112, e-mail: Jessica.Kratchman@nrc.gov.
SUPPLEMENTARY INFORMATION:
I.Obtaining Information and Submitting Comments.
2
A. Obtaining Information.
Please refer to Docket ID NRC-2014-0257 when contacting the NRC about the availability of information for this action. You may obtain publicly-available information related to this action by any of the following methods:
- Federal rulemaking Web Site: Go to http://www.regulations.gov and search for Docket ID NRC-2014-0257.
- NRC's Agencywlde Documents Access and Management System (ADAMS):
You may obtain publicly-available documents online in the ADAMS Public Documents collection at http://www.nrc.gov/reading-rm/adams.html. To begin the search, select "ADAMS Public Documents" and then select "Begin Web-based ADAMS Search." For problems with ADAMS, please contact the NRC's Public Document Room (PDR) reference staff at 1-800-397-4209, 301-415-4737, or by e-mail to pdr.resource@nrc.gov. The ADAMS accession number for each document referenced (if it is available in ADAMS} is provided the first time that it is mentioned in the SUPPLEMENTARY INFORMATION section.
- NRC's PDR: You may examine and purchase copies of public documents at the NRC's PDR, Room 01-F21, One White Flint North, 11555 Rockville Pike, Rockville, Maryland, 20852.
B. Submitting Comments.
Please include Docket ID NRC-2014-0257 in the subject line of your comment submission, in order to ensure that the NRC is able to make your comment submission available to the public in this docket.
The NRC cautions you not to include identifying or contact information in comment submissions that you do not want to be publicly disclosed in your comment submission. The NRC will post all comment submissions at http://www.regulations.gov as well as enter the 3
comment submissions into ADAMS, and the NRC does not routinely edit comment submissions to remove identifying or contact information.
If you are requesting or aggregating comments from other persons for submission to the NRC, then you should inform those persons not to include identifying or contact Information that they do not want to be publicly disclosed in their comment submission. Your request should state that the NRC does not routinely edit comment submissions to remove such information before making the comment submissions available to the public or entering the comment into ADAMS.
II.The Petitioner.
The petition states that C-10 is a non-profit organization that "evolved from" Citizens within the Ten-Mile Radius, which C-10 claims is a 5,000 member organization founded in 1986 to challenge evacuation plans for the [NextEra] Seabrook Station reactor. The petition represents that C-10 was established in 1991 to address the health and safety issues related to the [NextEra] Seabrook Station nuclear power plant. The petition further states that ..C-10 has been engaging the NRC about concrete degradation at Seabrook since December 22, 2011,"
and that the Union of Concerned Scientists assisted C-10 in preparing this petition.
Ill.The Petition.
Sandra Gavutis, Executive Director, submitted a PRM on behalf of C-10, dated September 25, 2014 (ADAMS Accession No. ML14281A124), requesting that the NRC amend its regulations to i_mprove identification techniques against ASR concrete degradation at nuclear power plants. The NRC has determined that the petition meets the threshold sufficiency requirements for a PRM under § 2.802 of Title 1O of the Code of Federal Regulations, "Petition 4
for rulemaking," and the petition has been docketed as PRM-50-109. The NRC is requesting public comments on this PRM.
IV.Discussion of the Petition.
At an NRC public meeting at Seabrook Station on June 24, 2014, the petitioner asked the NRC if the agency was investigating the U.S. nuclear fleet for ASR concrete degradation.
The NRC staff responded that ASR concrete degradation could be adequately indicated through visual examination. However, an NRC position paper, "In Situ Monitoring of ASR-affected Concrete," November 2012 (ADAMS Accession No. ML13108A047), states, "ASR can exist in concrete without indications of pattern cracking," and that for " ... structures exposed to ASR.
internal damage occurs through the depth of the section but visible cracking is suppressed by heavy reinforcement. ..." When NextEra determined 131 locations with "assumed" ASR visual signs within multiple power-block structures at Seabrook Station during 2012, further engineering evaluations were not required by the NRC.
The petitioner requests that the NRC amend its regulations to improve identification techniques against ASR concrete degradation at U.S. nuclear power plants. The petitioner suggests* that the reliance on a visual inspection does not "adequately identify Alkali-Silica Reaction (ASR), does not confirm ASR, or p~ovide the current state of ASR damage (if present) without petrographic analysis under current existing code." The petitioner asserts that codes and standards exist that are capable of detecting ASR and determining the key material properties needed to evaluate the degree and severity of ASR damage. American Concrete Institute (ACI) Standard 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures," for instance, has been endorsed by the NRC (ADAMS Accession No. ML112241029) as an acceptable method of protecting against excessive ASR concrete degradation, but is not a regulatory requirement. The petitioner requests that the NRC amend 5
its regulations to require that all licensees comply with industry codes and standards that have "already been endorsed by the agency," and identified two standards for which the NRC's regulations should require compliance: 1) ACI Standard 349.3R; and 2) American Society for Testing & Materials (ASTM) C856-11, "Standard Practice for Petrographic Examination of Hardened Concrete.*
Dated at Rockville, Maryland, this 5th day of January, 2015.
For the Nuclear Regulatory Commission.
IRA/
Annette L. Vietti-Cook, Secretary of the Commission.
6
From: Thomas, George Sent: Thursday, January 08, 2015 5:41 PM To: Kratchman, Jessica
Subject:
RE: Kickoff Meeting: PRM 50- 109: ASR Concrete Degradation Jessica - I have a schedule conflict for this meeting. I will be at NIST for the morning of Jan 14 participating in an ACRS visit of the ASR Research Project at NIST in support of a NRR User Need Request to RES. Thanks.
George
Original Appointment-----
From: Erickson, Allee On Behalf Of Kratchman, Jessica Sent: Monday, January 05, 2015 8:22 AM To: Thomas, George
Subject:
FW: Kickoff Meeting: PRM 50-109: ASR Concrete Degradation When: Wednesday, January 14, 2015 10:30 AM-11:00 AM (lJTC-05:00) Eastern Time (US & Canada).
Where: HQ-0WFN-12B02-12p
Ortglnal Appointment-----
From: Kratchman, Jessica Sent: Wednesday, December 24, 2014 10:57 AM To: Kratchman, Jessica; Erickson, Alice; Fuhrmann, Mark; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; NRR_DPR_PRMB Resource; Mizuno, Geary Cc: Inverso, Tara; Beall, Robert
Subject:
UPDATE: Kickoff Meeting: PRM 50-109: ASR Concrete Degradation When: Wednesday, January 14, 2015 10:30 AM-11 :00 AM (lJTC-05:00) Eastern Time (US & Canada).
Where: HQ-0WFN-12B02-12p Update due to conflict. Thanks!
<< File: PRM-50-109.pdf >> << File: C-10 Petition - Notice of Docketing and Request for Comments.docx >> << File:
KRATCHMAN 09 2014 SUFFICIENY REVIEW ASR concrete PRM revl.docx >>
Bridge line: 888-469-2059
,,/J-Hb....)- - .
Participant passcode: ....
Hello everyone!
Welcome to the PRM 50-109 ASR Concrete Degradation Working Group. You have been identified by your management as an expert in some aspect of this issue and we will be working together to address a recent petition that has come through on this matter. I am requesting this meeting so we can kick-off the Issue, introduce ourselves, and discuss our roles and responsibilities.
Prior to our meeting please review the attached materials. This includes the petition (PRM 50-109) issued by C-10 with support from UCS; note that while the petitioner cites Seabrook, they also identify this as a fleet wide l
issue, and we are treating it as such. I have also included the draft Notice of Docketing FRN (being issued for public comments); hopefully this will be issued soon after the New Year. And finally, for your background, I attached the sufficiency determination that I provided to ADMIN regarding this petition.
Feel free to call-in to the kick off meeting, bridge line information is provided. And if you have any questions prior to the meeting feel free to contact me.
Thanks and I look forward to working with everyone!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Thomas, George Sent: Tuesday, January 13, 2015 6:56 PM To: Marshall, Michael Cc: Plasse, Richard
Subject:
RE: RESPONSE REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Hello Michael - Yes, you did assign it to me. There is a kick-off meeting scheduled for Thurs (1/15).
Thanks.
George From: Marshall, Michael Sent: Tuesday, January 13, 2015 6:13 PM To: Thomas, George Cc: Plasse, Richard
Subject:
RESPONSE REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Hello George, Did I assign support for this PRM to you after Alice left the branch?
- Thanks, Michael L. Marshall, Jr.
Chief Aging Management of Structures, Electrical, and Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation 301-415-2871 Email: michael.marshall@nrc.gov From: Plasse, Richard Sent: Tuesday, January 13, 2015 3:55 PM To: Marshall, Michael
Subject:
RE: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation OK I think you said at the interface that George Thomas was involved, correct?
From: Marshall, Michael Sent: Tuesday, January 13, 2015 3:19 PM To: Plasse, Richard
Subject:
PN: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation FYI From: Diaz-Sanabria, Yoira Sent: Monday, November 17, 2014 3:46 PM To: Marshall, Michael
Subject:
PN: REQUEST: Support needed for PRM 50-109, ASR Concrete Degradation Michael, 1
This seems right in your alley. I think they need a technical expert from DLR rather than a PM.
What do you think?
Yoira From: Kratchman, Jessie.a Sent: Monday, November 17, 2014 3:33 PM To: Ott, William; Lupold, Timothy; Colaccino, Joseph; Bladey, Cindy; Diaz-5anabrla, Yoira Cc: Inverso, Tara; Beall, Robert; Philip, Jacob; Fuhrmann, Mark
Subject:
REQUEST: Support needed for PRM 50-109, ASR Congrete Degradation Branch Chiefs, I am the NRR PM managing a recent petition issued under 10 CFR 2.802, petition for rulemaking (PRM), regarding the use of visual inspection in the identification of alkali-silica reaction (ASR) concrete degradation. The petitioner is C-10 Research. C-10 has petitioned the NRC to require that all licensees comply with ACI 349.3R, and ASTM C 856-11. They feel the current reliance on a visual inspection does not adequately identify ASR or provide the current state of ASR damage. While the petitioner refers to Seabrook within the petition, they have identified this as a fleet-wide concern.
I would like to request a member of your staff to be on my working group to res olve this petition.
The working group will normally meet once or twice a month, support the Petition Review Board presentation, and write various sections of the FRN to disposition the PRM.
The C-10 petition is attached to this e-mail for your review. We are currently sending out the FRN to formally notice the acceptance and docking of the petition. We are also asking for public comments on the PRM at the same time. Please let me know who you believe should be the lead technical organization for this effort.
Please let me know who from your staff will be participating in the PRM working group by COB December 3, 2014. I have included individuals from RES/DRA/ETB, NRR/DE/ EMCB, NRR/DLR/RPB1, NRO/DARR/NARGB, ADM/RADB.
Let me kriow if you have any questions.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5.112 2
From: Kratchman, Jessica Sent: Thursday, January 15, 2015 12:49 PM To: Thomas, George Cc: Marshall, Michael
Subject:
RE: PRM 50-109: ASR Concrete technical lead T hank you. I will make note in toda y's meeting summary.
From: Thomas, George Sent: Thursday, January 15, 2015 12:48 PM To: Kratchman, Jessica Cc: Marshall, Michael subject: RE: PRM 50-109: ASR Concrete technical lead Hello Jessica, As discussed over the phone, you may identify me as the technical lead.
Thanks.
George From: Kratchman, Jessica Sent: Thursday, January 15, 2015 10:52 AM To: Thomas, George
Subject:
PRM 50-109: ASR Concrete technical lead
- George, Per my voicemail, one of my responsibilities is to identify a technical lead for this petition. Would you be amendable to serving in such a capacity?
Thanks so much.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 1
From: Kratchman, Jessica Sent: Thursday, January 15, 2015 12:57 PM To: Phi*lip, Jacob Cc: Thomas, George; Fuhrmann, Mark; Ott, William
Subject:
RE: Rulemaldng re. ACI 349.3R and ASTM C856 Thanks Jake. I am going to send out a meeting summary shortly and I will make sure your comment is reflected.
(h)(:n Looks like we have a lot to think about moving forward!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Phllfp, Jacob Sent: Thursday, January 15, 2015 12: 10 PM To: Kratchman, Jessica Cc: Thomas, George; Fuhrmann, Mark; Ott, William
Subject:
Rulemaking re. ACI 349.3R and ASTM C856
- Jessie, 1b)(b)
Jake 1
From: Kratchman, Jessica Sent: Thursday, January 15, 2015 1:41 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George Cc: Beall, Robert
Subject:
SUMMARY
- PRM 50-109
- HelloWG, Thanks to everyone who was able to attend our kick-off meeting today, to those who were unable to attend I look forward to your future participation. Please find below a summary of today's meeting (I will make this available on our SharePoint Site as well):
- 1. Introductions
- a. Introduced members of the WG.
- b. Discussed an overview of the petition.
- 2. Discussion of schedule
- a. Highlighted areas of importance for the various members of the WG
- i. Admin/ OCG- FRN publication, reviews and concurrences ii. Technical staff- comment adjudication/ briefings
- b. Schedule will ramp up for technical staff once comment period has ended.
- c. Refer to file: "PRM 50-109 working schedule" on the Share Point Site.
- 3. Discussion of roles and responsibilities
- a. Provided general roles and responsibilities for the petition review process (source: Lic-300)
- b. Refer to file: "PRM 50-109 working schedule" on the SharePoint Site.
- 4. General discussion
- a. Questions raised by WG (b)(5)
- 5. Technical lead identified- George Thomas (established after the WG meeting- please let me know if you have comments Please let me know if you have anything to add I 1
Thanks.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Kratchman, Jessica Sent: Thursday, January 22, 2015 10:06 AM To: Thomas, George Cc: Philip, Jacob; Fuhrmann, Mark; Lehman, Bryce; Inverso, Tara; Beall, Robert
Subject:
RESPONSE: Rulemaking re. ACI 349.3R and ASTM C856 Hello Everyone, 5
l<bl( l !Also, as I mentioned at our kickoff meeting, I will send you comments as I receive them but you are not obligated to review until after the comment period ends, at which point we Will start having regular WG meetings.
Thanks everyone.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Kratchman, Jessica Sent: Thursday, January 15, 2015 2:13 PM To: Thomas, George Cc: Kratchman, Jessica; Philip, Jacob; Fuhrmann, Mark; Lehman, Bryce
Subject:
RE: Rulemaklng re. ACT 349.3R and ASTM C856 Understood. I can see there might be some nuances to this that I haven't encountered before, so I'll definitely look into it. Thanks George.
I am on my way to a grad class now but I will get back to everyone as soon as possible- hopefully tomorrow or early next week.
On Thursday, January 15, 2015 at 2:04:33 PM, "Thomas, George" <George.Thomas2@nrc. gov> wrote:
Jessica l ib)i5i r
1
From: Kratchman, Jessica Sent: Thursday, January 15, 2015 1:29 PM To: Thomas, George; Philip, Jacob Cc: Fuhnnann, Mark; Ott, William; Marshall, Michael; Lehman, Bryce r
Subject:
RE: Rulemaking re. ACT 349.3R and ASTM C856 am looking into 1his issuet b)(5)
From: Thomas, George Sent: Thursday, January +S, 2015 1:20 PM To: Phillp, Jacob Cc: Fuhrmann, Mark; Ott, William; Kratchman, Jessica; Marshall, Michael; Lehman, Bryce
Subject:
RE: Rulemaking re. ACI 349.3R and ASTM C856 Jake, (t,)/5)
Thanks.
George From: Phlllp, Jacob Sent: Thursday, January 15, 2015 12:10 PM To: Kratchman, Jessica Cc: Thomas, George; Fuhrmann, Mark; Ott, William
Subject:
Rulemaking re. AO 349.3R and ASTM C856
- Jessie, (11)(~
Jake 2
From: Kratchman, Jessica Sent: Tuesday, January 27, 2015 11:29 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George Subjed: FW: Comment (1) on PRM 109 (NRC-2014-0257)
FYI- our first comment submission for PRM 50-109 is below. This is just for you information, when the comment period ends we will meet to disposition all that we receive.
Thanks!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: RulemakingComments Resource sent: Tuesday, January 27, 2015 10:22 AM To: Gallagher, Carol; Kratchman, Jessica Cc: RulemakingComments Resource
Subject:
Comment (1) on PRM-50-109 (NRC-2014-0257)
View ADAMS P8 Properties ML15026A339 Open ADAMS P8 Document (Comment (1) from Josephine Donovan Regarding PRM-50-109, hnproved Identification Techniques Against Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants.)
Clara (Rica) Sola Rulemakings and Adjudications Staff Office of the Secretary Clara.Sola@nrc.gov 301-415-1668 1
From: Kratchman; Jessica Sent Friday, April 17, 2015 8:40 AM To: Lehman, Bryce Cc: Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 (4-16-2015)
Done! Thanks for letting me know.
From: Lehman, Bryce Sent: Thursday, April 16, 2015 10:22 PM To: Kratchman, Jessica Cc: Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 (4-16-2015)
That is fine with me.
Bryce From: Thomas, George Sent: Thursday, April 16, 2015 8:59 PM To: Kratchman, Jessica Cc: Beall, Robert; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 (4-16-2015)
Thanks, Jessie. Thinking about the comments some more after the meeting, please add Bryce to comments 7 and 8, if it is OK with him.
George From: Kratchman, Jessica Sent: Thursday, April 16, 2015 10:56 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George Cc: Beall, Robert
Subject:
MEETING
SUMMARY
- PRM 50-109 (4-16-2015)
Working Group Meeting (WG): PRM 50-109: Comment/ issue resolution assignments Thank you to everyone who attended today's meeting. We spent the majority of the meeting discussing the Comment Summary Matrix (SharePoint}. If you have been identified as a lead for a comment/ issue response please begin reviewing and working on your comment resolution.
REMINDER: the purpose ofthe petition review Is not to make a decision on whether rulemaking should take place but to determine if this issue should enter the rulemaking process. Please keep this in mind throughout your review.
DISCUSSION:
1
ACTIONS:
- WG members should review their assigned comments/ issues and determine which require a dedicated WG meeting. If the comment response appears to be straightforward, the responses may be circulated to the WG for discussion instead of holding a WG meeting.
o Respond to Jessie COB April 23.
-Jessie will develop a schedule for comment/ issue resolution WG meetings- send to the WG. by COB April 28.
o First comment/ issue resolution working group meeting will take place in early May.
-As WG members identify background documents- send them to Jessie.
o Jessie will post to SharePoint site.
- WG members should regularly check SharePoint site for updates.
o All materials will be updated to reflect today's meeting- please work off the most current versions.
- Jessie will post an example of FRN that includes comment responses to the SharePoint site.
Reminder: SharePoint site link: http://fusion.nrc.gov/ nrr/ team/ dpr/prmb/ rulemaking/PRM 109/ SitePages/Home.aspx This meeting summary will be added to the file: Meeting summary document on SharePoint Site.
Thanks to everyone for your participation and support!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Kratchman, Jessica Sent: Thursday, April 23, 2015 10:54 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George Subject REMINDER: PRM 50-109 working group meetings- your comments REMINDER: please review your assigned comments/ issues and determine which require a dedicated WG meeting. I have*requested your input by COB today. For details see below.
-Jessie From: Kratchman, Jessica Sent: Thursday, April 16, 2015 10:56 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George Cc: Beall, Robert
Subject:
MEffiNG
SUMMARY
- PRM 50-109 (4-16-2015)
Working Grou p Meeting (WG): PRM 50-109: Comment/ issue resolution assignments Thank you to everyone who attended today's meeting. We spent the majority of the meeting discussing the Comment Summary Matrix (SharePoint}. If you have been identified as a lead for a comment/ issue response please begin reviewing and working on your comment resolution.
REMINDER: the purpose of the petition review is not to make a decision on whether rulemaking should take place but to determine ifthis issue should enter the rulemaking process. Please keep this in mind throughout your review.
DISCUSSION:
t.)(:5)
ACTIONS:
1
WG members should review their assigned comments/ issues and determine which require a dedicated WG meeting. If the comment response appears to be straightforward, the responses may be circulated to the WG for discussion instead of holding a WG meeting.
o Respond to Jessie COB April 23.
Jessie will develop a schedule for comment/ issue resolution WG meetings- send to the WG by COB April 28.
o First comment/ issue resolution working group meeting will take place in early May.
As WG members identify background documents- send them to Jessie.
o Jessie will post to SharePoint site.
WG members should regularly check SharePolnt site for updates.
o All materials will be updated to reflect today's meeting- please work off the most current versions.
Jessie will post an example of FRN that includes comment responses to the SharePoint site.
Reminder: SharePoint site link: http://fusion.nrc.gov/ nrr/ team/ dpr/prmb/ rulemaking/PRM 109/ SitePages/ Home.aspx This meeting summary will be added to the file: Meeting summary document on SharePoint Site.
Thanks to everyone for your participation and support I
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Mizuno, Geary <IMCEAEX.-_O=USNRC_OU=FIRST+20ADMIN1STRATIVE+
20GROUP_CN=RECIPIENTS_CN =73E4D2E4-E2312E70-1 D627F61-118EF6DB@usnrc.onmicrosoft.com>
Sent: Thursday, April 23, 2015 2:18 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE:*Comment (10) PRM 109 (NRC-2014-0257)
It is a "me-too" letter, so I do not see any reason why the NRG would say it is impractical to consider the letter
-given that very little additional consideration is needed (as Jessica indicated).
Geary From: Kratchman, Jessica Sent: Thursday, April 23, 2015 2:09 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
FW: Comment (10) PRM-50-109 (NRC-2014-0257)
HelloASRWG:
I received the below referenced comment today, related to PRM 50-109. Note that this comment was submitted outside of the comment period, so it's our job to decide if we would like to consider it. I have added it to the SharePoint Site, as well as the comment summary spreadsheet (also on SharePoint). Please review. My recommendation is that we consider it-- since it is an endorsement of the NEI comment and would not incur additional resources.
I have assigned Thomas as the lead. Please let me know if you have any questions or comments.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: RulemaklngComments Resource Sent: Thursday, April 23, 2015 1:46 PM To: Gallagher, Carol; Kratchman, Jessica Cc: RulemakingComments Resource
Subject:
Comment (10) PRM-50-109 (NRC-2014-0257)
View ADAMS P8 Properties ML15]12A265 1
Open ADAMS P8 Document (Comment {10) from STARS Alliance on PRM-50-109, hnproved Identification Techniques A gainst Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants.)
Clara (Rica) Sola Rulemakings and Adjudications Staff Office of the Secretary Clara.Sola@nrc. gov 301-415-1668 2
From: Kratchman, Jessica Sent: Thursday, May'07, 2015 4:45 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
PRM 50- 109: WG Meeting Schedule/ draft comment response due date WG members, l'n light of the minimal feedback I received regarding the need for comment resolution WG meetings, my assessment is that we only need WG meetings to discuss PRM Issues and the comments submitted by UCS, NEI and NextEra. Everything else can be resolved via email.
As such I have created a WG meeting schedule for every two weeks, with email-resolutions scattered among the schedule. My assumption is that everyone has already started addressing their comments and formulating their responses. For each WG meeting, if you are the lead for a comment resolution please send me your draft comment resolution (and other related topics you want discussed) by COB the day prior to your WG meeting.
Then I can update the scheduler with your draft response so the group can come to our meeting prepared. I will also setup a projector so we can go through and edit during the meeting. If you are the lead for a comment please coordinate your response with the other members of the Working Group as appropriate.
Please review the below table, I have also placed this table in the "Milestone schedule PRM 50-109" file on our SharePoint site.
- Thanks everyone.
Comment# Lead Due Date WG review method Issues 1, 2, 3 Thomas May 26, 2015 WG meetina Comments .1, 2, 3 Kratchman Mav 26, 2015 Email Comment 4 (9) Thomas June 9, 2015 WG meetinq Comment 5, 6 Lehman June *16, 2015 Email Comment 7 (10) Thomas June 23, 2015 WG meetinq Comment 8 Thomas July 7, 2015 WG meetina
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 1
From: Kratchman, Jessica Sent: Friday, May 08, 2015 9:44 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip,,. .,J.;.
ac.;.:o:.:b.:.
- .T..
- h...:o...:m...:a;.:.s,:...G
.:..e:..:o.;,,;
rg::..e;___ _ _ _ _ _ _ _ _- ,
Subject:
CORRECTION: EXAMPLE !(bi 5 Correction: I apparently skim too fast. The example I sent out is a good example for the issue resolution, the one that Geary sent out will work well for comment resolution.
Thanks!
-Jessie From: Kratchman, Jessica Sent: Friday, May 08, 2015 9:30 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Allssa; Philip, Jacob; Thomas, George llH" l SUbject: EXAMPLE L----------------------
See attached for an example comment response FRN. We will use this format for both the comment and issue responses.
I will post this and Geary's guidance to our SharePoint Site.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 1
From: Mizuno, Geary <IMCEAEX-_O=USNRC_OU=FIRST+20ADMIN1STRATIVE+
20GROUP_CN=RECIPIENTS_CN= 73E4D2E4-E2312E70-10627F61 -118EF6DB@usnrc.onmicrosoft.com >
Sent Friday, May 08, 201 5 9:46 AM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Leliman, Bryce; Love Blair, Angella; Neuhausen. Alissa; Phili , Jacob; Thomas, Gear e
Subject:
RE: EXAMPLE,b,i~
(IJ)(5l Colleagues:
However, please do not confuse this with a template for responding to public comments received on a PRM which were provided in an opportunity to submit comments on the PRM.
Geary From: Kratchman, Jessica Sent: Friday, May 08, 2015 9:30 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George Subjed:: EXAMPL~L,r-*J(-:,l- - - - - - - - - - - - - - - - - - - - - - - - - - -
See attached for an example comment response FRN. We will use this format for both the comment and issue responses.
I will post this and Geary's guidance to our SharePoint Site.
-Jessi*e Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 1
From: Thomas, George Sent Wednesday, May 27, 2015 4:14 PM To: Lehman, Bryce
Subject:
REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 Attachments: PRM 50-109 Draft Staff Position Recommending l._
fb-)(ti_l _ _ _ _...,!Rev 0) GT 5-27-15.docx Note: The 18-page draft attachment is withheld in its entirety under FOIA exemption 5 .
Importance: High Hello Bryce - Attached Is my first shot at the draft staff position I developed on the ASR Petition for Rulemaking for a quick review and comment. Please focus on the highlighted sections addressing NRC response to the 3 issues.
Sorry for the delay in sending this to you. Thanks in advance for your help.
George From: Kratchman, Jessie.a Sent: Tuesday, May 26, 2015 9:33 AM To: Thomas, George
Subject:
STATUS: Comment respones for Issues 1, 2, 3 Importance: High
- George, Our PRM 50-109 meeting today is schedule to discuss your comment responses for Issues 1-3. I have reserved a projector so you can walk us through your responses and the group can discuss.
Please send me your responses ASAP so I can attach it to the scheduler.
Thanks.
-Jessie Jessica Kratchman., candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112
From: Lehman, Bryce Sent: Wednesday, May 27, 2015 8:16 PM To: Thomas, George
Subject:
RE: REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, Attachments:
2 and 3 PRM 50-109 Draft Staff Position Recommending lfbl(S) I Rev 0) GT Lehman S-27-15.docx Note: The 19-page draft attachment is w ithheld in its entirety under FOIA exemption 5.
George, I reviewed your draft petition and agree with it completely. I have made multiple edits but they are basically all editorial in nature ... feel free to incorporate I reject as you see fit. As far as technical content I agree with what you have drafted and if I am unable to attend the meeting tomorrow you can tell the group l'blt5, I l(IJ)/:J) I Thanks for going to all the effort of drafting this position now ,.. I think you have saved us all a lot of time later in the process.
Thanks, Bryce From: Thomas, George Sent: Wednesday, May 27, 2015 4:14 PM To: Lehman, Bryce
Subject:
REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 Importance: High Hello Bryce - Attached is my first shot at the draft staff position J developed on the ASR Petition for Rulemaking for a quick review and comment. Please focus on the highlighted sections addressing NRC response to the 3 issues.
Sorry for the delay in sending this to you. Thanks in advance for your help.
George From: Kratchman, Jessica Sent: Tuesday, May 26, 2015 9:33 AM To: Thomas, George
Subject:
STATUS: Comment respones for Issues 1, 2, 3 Importance: High George, Our PRM 50-109 meeting today is schedule to discuss your comment responses for Issues 1-3. I have reserved a projector so you can wal!k us through your responses and the group can discuss.
Please send me your responses ASAP so I can attach it to the scheduler.
Thanks.
-Jessie 1
Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Lehman, Bryce Sent: Wednesday, May 27, 2015 8:19 PM To: Kratchman, )essica
Subject:
RE: UPDATE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Jessica, FYI in case I cannot attend tomorrow. I saw a draft of what George intends to present tomorrow and I agree with it completely.
Thanks, Bryce From: Kratchman, Jessica Sent: Tuesday, May 26, 2015 2:44 PM To: Lehman, Bryce
Subject:
RE: UPDATE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Thank you for letting me know
-Jess
Original Appolntment-----
From: Lehman, Bryce Sent: Tuesday, May 26, 2015 1:01 PM To: Kratchman, Jessica
Subject:
Tentative: UPDATE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 When: Thursday, May 28, 2015 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: HQ-OWFN-04804-12p I am currently scheduledL Jthis day .. . I may be able to call in but cannot guarantee my attendance.
Bryce
From: Thomas, George Sent: Wednesday, May 27, 2015 10:26 PM To: Lehman, Bryce
Subject:
RE: REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 Thanks Bryce for the quick review. I have accepted all the edits you made, which makes it read much better.
George From: Lehman, Bryce Sent: Wednesday, May 27, 2015 8:16 PM To: Thomas, George
Subject:
RE: REQUEST for Review: Draft ASR Petition for Rulemaklng NRC responses to Issues 1, 2 and 3 George, I reviewed *your draft petition and agree with it completely. I have made multiple edits but they are basically all editorial in nature ... feel free to incorporate / reject as you see fit. As far as technical content I agree wit w at YOJI have drafted and if I am 1,oable ta attend the roer ting tomorrow you can tell the group I support (l>J r )(5) - L.....----'
Thanks for going to all the effort of drafting this position now ... I think you have saved us all a lot of time later in the process.
- Thanks, Bryce From: Thomas, George Sent: Wednesday, May 27, 2015 4:14 PM To: Lehman, Bryce
Subject:
REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 Importance: High Hello Bryce - Attached is my first shot at the draft staff position I developed on the ASR Petition for Rulemaking for a quick review and comment. Please focus on the highlighted sections addressing NRC response to the 3 issues.
Sorry for the delay in sending this to you. Thanks in advance for your help.
George From: Kratchman, Jessica Sent: Tuesday, May 26, 2015 9:33 AM To: Thomas, George
Subject:
STATUS: Comment respones for Issues 1, 2, 3 Importance: High
- George, 1
Our PRM 50-109 meeting today is schedule to discuss your comment responses for Issues 1-3. I have reserved a projector so you can walk us through your responses and the group can discuss.
Please send me your responses ASAP so I can attach it to the scheduler.
Thanks.
- Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Thomas, George Sent: Wednesday, May 27, 201 5 10:44 PM To: Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob
Subject:
PRM 50-109 - Draft responses to Issues 1, 2 and ~ fncWG Reyjew r d Discussion Attachments: PRM 50-109 Draft Staff Position Recommending 5 1S.docx r)5) Rev 0) GT Lehman Note: The 18-page draft attachment is withheld in its entirety under FO IA exemption 5.
Hello Jessie and WG Members, Attached is my first shot at a draft NRC responses to Issues 1, 2, 3 and recommended staff position on PRM 50-109 for your review and discussion at tomorrow's meeting. Please focus your review on Section II on pages 6 thru 16 that addresses Issues 1, 2 and 3.
Note that Bryce may not be able to attend or call in to the meeting tomorrow. But he has reviewed my draft and agrees with the recommended position as indicated in the email below_
Thanks.
George From: Lehman, Bryce Sent: Wednesday, May 27, 2015 8:16 PM To: Thomas, George
Subject:
RE: REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 George, I reviewed your draft petition and agree with it completely. I have made multiple edits but they are basically all editorial in nature ... feel free to incorporate I reject as you see fit. As far as technical content I agree with what ou have drafted and if I am unable to attend the meeting tomorrow you can tell the group I supportj/5)(5)
(bX l based on the reasons you have outlined. '-------1 Thanks for going to all the effort of drafting this position now ... I think you have saved us all a lot of time later in the process.
- Thanks, Bryce From: Thomas, George Sent: Wednesday, May 27, 2015 4:14 PM To: Lehman, Bryce
Subject:
REQUEST for Review: Draft ASR Petition for Rulemaking NRC responses to Issues 1, 2 and 3 Importance: High Hello Bryce - Attached is my first shot at the draft staff position I developed on the ASR Petition for Rulemaking for a quick review and comment. Please focus on the highlighted sections addressing NRC response to the 3 issues.
Sorry for the delay in sending this to you. Thanks in advance for your help.
1
George From: Kratchman, Jessica Sent: Tuesday, May 26, 2015 9:33 AM To: Thomas, George
Subject:
STAlUS: Comment respones for Issues 1, 2, 3 Importance: High
- George, Our PRM 50-109 meeting today is schedule to discuss your comment responses for Issues 1-3. I have reserved a projector so you can walk us through your responses and the group can discuss.
Please send me your responses ASAP so I can attach it to the scheduler.
Thanks.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Thomas, George Sent: Friday, May 29, 2015 8:57 AM To: Philip, Jacob; Fuhrmann, Mark Cc: Kratchman, Jessica
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Can you guys take the lead to prepare the response to comments 4 & 9 for the next WG meeting. My work load is currently very demanding.
Thanks.
George From: Kratchman, Jessica Sent: Thursday, May.28, 2015 4:35 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
MEETING
SUMMARY
- PRM 50-109 LINKS: Link to SharePoint Site Link to staff position paper.
MEETING
SUMMARY
- Thanks to everyone for participated in today's meeting and to those of you who provided input prior to the meeting.
DISCUSSION: We spent today's meeting discussing George's input for Issues 1-3. We also discussed action items and the schedule moving forward.
- General discussion: Conform Ian t, \5)
- ssue inpu ACTIONS:
- George: __...
1 o ~odate j~put per today's meeting, refer to comments/ edits tracked during meeting.lt" '"
~ -- 1 . ------
0 repare omment 4 (9) input for June 9 meeting. Provide to PM by June 5.
- Jessie: Comments 1-3 input will be emailed to the group for input by June 5.
- All: review current staff position document (link above).
SCHEDULE: Next meeting we will discuss Issue 3 (RES input) and Comment 4 (9).
Comment# Lead Due Date WG review method Issues 1, 2. 3 Thomas Mav 28, 2015 WGmeetinQ Comments 1, 2, 3 Kratchman June 9, 2015 Email Comment 4 (9) + Issue Thomas/ June 9, 2015 WG meeting 3 (RES input) RES Comment 5, 6 Lehman June 23, 2015 Email Comment 7 (10) Thomas June 23, 2015 WG meetinQ Comment8 Thomas Julv 7, 2015 WGmeetina Thanks again!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Thomas, George <IMCEAEX-_O=USNRC_OU =FIRST +20ADMIN1STRATIVE+
20GROUP_CN=RECIPIENTS_CN =948E1C12-5C1E96B3-5SFE5AB3-C37E2FF7
@usnrc.onmicrosoft.com >
Sent: Friday, May 29, 2015 12:14 PM To: Thomas, George
Subject:
FW: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Attachments: PRM 50-109 Draft Staff Position Recommendingl(b)(5) JRev 0), 5-28-2015 with Angella's comments.docx ~ - - - - - - - - - - - - - - -
Note: The 19-page draft attachment is withheld in its entirety under FOIA exemption 5.
From: Love-Blair, Angella Sent: Thursday, May 28, 2015 12:59 PM To: Kratchman, Jessica; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Here you go. I sign back on at 5 this evening, so please let me know if you have questions.
From: Kratchman, Jessica Sent: Thursday, May 28, 2015 12:26 PM To: Love-Blair, Angella; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 That would be great. T hanks.
From: Love-Blair, Angella Sent: Thursday. May 28, 2015 11:38 AM To: Kratchman, Jessica; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Jessica/George, I leave the office at 2, so I will not be able to participate in the meeting today. However, I have some comments on George's document that I hope to forward in the next 30 minutes or so.
Angella
Original Appointment- -
From: Kratchman, Jessica Sent: Thursday, May 28, 2015 9:05 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George; NRR_DPR_PRMB Resource
Subject:
ATTACHMENT: UPDATE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 When: Thursday, May 28, 2015 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: HQ-OWFN-04B04-12p 1
Please review.
l(b\/5, I
<< File: PRM 50-109 Draft Staff Position Recommendingi..._ _ _ ____. (Rev O) ....docx >>
Rescheduled to accommodate George's schedule. Thanks for understanding!
Passcodes/Pin codes:...,,....,,--__,
Participant passcode: 1...l(IJ-i!b_1_ __.
For security reasons, the passcode will be required to join the conference.
Dial In numbers:
Country Toll Numbers Freephone/
Toll Free Number USA 888-390-1523 Agenda:
General discussion Address scheduled comment resolution draft Briefly discuss any issues with emailed comment resolutions Comment # Lead Due Date WG review method Issues 1, 2, 3 Thomas May 26, 2015 May 28, 2015 WG meeting Comments 1, 2, 3 Kratchman May 26, 2015 Email Comment 4 (9) Thomas June 9, 2015 WG meeting Comment 5, 6 Lehman June 16, 2015 Email Comment 7 (10) Thomas June 23, 2015 WG meeting Comment 8 Thomas July 7, 2015 WG meeting 2
From: Thomas, George Sent: Monday, June 01, 2015 10:13 AM To: Love Blair, Angella Cc: Kratchman, Jessica
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Angella - Thank you for your prompt constructive comments and feedback. I will be incorporating them in future revisions of the document.
Also, just wanted to let you know that there are two George Thomas's at the NRG (both in NRR), and my email address is George.Thomas2@nrc.gov . You had sent your comments to the other George Thomas.
Thanks.
George Thomas Senior Structural Engineer NRR/DLR/RASB; 0-11 E21 301-415-6181 George.Thomas2@nrc.gov
Original Message----*
From: Thomas, George Sent: Friday, May 29, 2015 12:14 PM To: Thomas, George
Subject:
FW: PRM 50-109 Comment Resolution Meeting: Issues 1-3 From: Love-Blair, Angella Sent: Thursday, May 28, 2015 12:59 PM To: Kratchman, Jessica; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 Here you go. I sign back on at 5 this evening, so please let me know if you have questions.
From: Kratchman, Jessica Sent: Thursday, May 28, 2015 12:26 PM To: Love-Blair, Angella; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 That would be great. Thanks.
From: Love-Blair, Angella Sent: Thursday, May 28, 2015 11 :38 AM To: Kratchman, Jessica; Thomas, George
Subject:
RE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 1
Jessica/George, I leave the office at 2, so I will not be able to participate in the meeting today. However, I have some comments on George's document that I hope to forward in the next 30 minutes or so.
Angella
---Original Appointment---
From: Kratchman, Jessica Sent: Thursday, May 28, 2015 9:05 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George; NRR_DPR_PRMB Resource
Subject:
ATIACHMENT: UPDATE: PRM 50-109 Comment Resolution Meeting: Issues 1-3 When: Thursday, May 28, 2015 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: HQ-OWFN-04B04-12p Please review.
<< File: RRM 50-109 Draft Staff Position Recommending!(ti ...-i(o_,'_ _ _ __.! (Rev O) .... docx >>
Rescheduled to accommodate George's schedule. Thanks for understanding!
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Toll Free Number USA 888-390-1523 Agenda :
2
General discussion Address scheduled comment resolution draft Briefly discuss any issues with emailed comment resolutions Comment # Lead Due Date WG review method Issues 1, 2, 3 Thomas May 26, 2015 May 28, 2015 WG meeting Comments 1, 2, 3 Kratchman May 26, 2015 Email Comment 4 (9) Thomas June 9, 2015 WG meeting Comment 5, 6 Lehman June 16, 2015 Email Comment 7 (10) Thomas June 23, 2015 WG meeting Comment 8 Thomas July 7, 2015 WG meeting 3
From: Thomas, George Sent: Monday, June 01, 2015 .10:13 AM To: Kra~chman, Jessica; Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Neuhausen, Alissa; Philip, Jacob
Subject:
RE: MEETING SUMMAR't': PRM 50-109 Hello WG Members, It appears there is some misunderstanding and confusion about the issues raised in the PRM and the initial draft r~sponse. Let's discuss that at the next meeting.
Thanks.
George
Original Message----
From: Kratchman. Jessica Sent: Friday, May 29, 2015 12:04 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 r,,
Geary, Thanks.
Jessie From: Mizuno, Geary Sent: Friday, May 29, 201511:19 AM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 I'~"
Geary From: Kratchman, Jessica Sent: Friday, May 29, 2015 9:17 AM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa:
Philip, Jacob; Thomas, George 1
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 George/ Jake/ Mark- Have I characterized that correctly?
From: Mizuno, Geary Sent: Thursday, May 28, 2015 5:06 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Colleagues:
I am sorrv I was unable to attend this meeting./
(11/(5)
Geary From: Kratchman, Jessica Sent: Thursday, May 28, 2015 4:35 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
MEETING
SUMMARY
- PRM 50-109 LINKS: Link to SharePoint Site<http://fusion.nrc.gov/nrr/team/dpr/prmb/rulemaking/PRM 109/SitePages/Home.aspx> Link to staff position paper.<http://fusion.nrc.gov/nrr/team/dpr/prmb/rulemaking/PRM-50-109/Working%20Documents/PRM%2050-109%20Draft%20Staff%20Position%20Recommending0 (bJ(5, !of r/o20Petition%20(Rev%201 ), %20WG
%20comments.docx>
MEETING
SUMMARY
- Thanks to everyone for participated in today's meeting and to those of you who provided input prior to the meeting.
2
DISCUSSION: We spent today's meeting discussing George's input for Issues 1-3. We also discussed action items and the schedule moving forward .
'H::i.
(l,Ji!>l
- Issue 3: RES to add input ACTIONS:
" RES: Issue 3: provide write up for June 9 meeting. Get to PM by COB June 5.
- G.eorge:
o Update input per today's meeting, refer to comments/ edits tracked during meeting. Link to staff position paper.<http://fusion.nrc.gov/nrr/team/dpr/prmb/rulemakin~ /PRM-50-109/Working%20Documents/PRM%2050-109%20Draft%20Staff%20Position%20Recommending0/c 1JH5) ~/o20(Rev%201 ), %20WG
%20comments.docx>
o Prepare Comment 4 (9) input for June 9 meeting. Provide to PM by June 5.
" Jessie: Comments 1-3 input will be emailed to the group for input by June 5.
All: review current staff position document (link above).
SCHEDULE: Next meeting we will discuss Issue 3 (RES input) and Comment 4 (9).
Comment#
Lead Due Date WG review method Issues 1, 2, 3 Thomas May 28, 2015 WG meeting 3
Comments 1, 2, 3 Kratchman June 9, 2015 Email Comment 4 (9) + Issue 3 (RES input)
Thomas/
RES June 9, 2015 WG meeting Comment 5, 6 Lehman June 23, 2015 Email Comment 7 (10)
Thomas June 23, 2015 WG meeting Comment8 Thomas July 7, 2015 WG meeting Thanks again!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 4
From: Kratchman, Jessica Sent: Thursday, June 11, 2015 8:58 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: ACTION ITEMS: PRM 50-109 Correction, use the link below for your edits.
Please take the time to review and comment by the due dates listed below. The WG will function optimally if everyone in the group is familiar with and has provided input! Thanks.
Link to SharePoint: ISSUE
SUMMARY
DOCUMENT LINK From: Kratchman, Jessica Sent: Wednesday, June 10, 201S 5:22 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
ACTION ITEMS: PRM 50-109 Thanks to everyone for attending today's working group meeting and being flexible with the conference rooms.
Please see the below action items as outcomes from today's discussion:
REMINDER: please revise documents through the SharePoint Site for version control purposes.
- GEARY:
- 1. Provide second draft for issues identified in the petition. Link to Issue Summary Document. Due: June 17
- 2. Read/ provide input to the Issue Summary document.
- JAKE/ MARK: Add your Input into SharePoint (call me if you need some help!). Link to Issue Summary Document. Due: June 23
- GEORGE/ BRYCE:
- 1. Revise each Issue Res onse to reflect Gea (h)(S) ink to Issue Summa Document. Due: une 23
- 2. n input is received (June 17) for the Issue identification, please add technical considerations. Due: June 23
- JESSIE:
- 1. Update overall schedule to provide increased time towards the resolution of Issues. Due: June 23
- 2. Pursue whether allegations have been identified in the petition.
Please let me know If you have any questions.
- Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 1
301-415-5112 2
From: Neuhausen, Alissa Sent Tuesday, June 02, 2015 11:13 AM To: Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Thank you for the response George!
Alissa Neuhausen General Engineer (NSPDP)
NRO/DE/SEB1 301-415-5734
Original Message-----
From: Thomas, George Sent: Tuesday, June 02, 2015 10:54 AM To: Neuhausen, Alissa
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Thanks, Alissa, for your constructive comments.
(b1(ti1 Thanks.
Original Message---
From: Neuhausen, Alissa Sent: Monday, June 01 , 2015 4:22 PM To: Kratchman, Jessica; Mizuno, Geary; Fuhrmann, Marki Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 All, Sorry I was unable to attend the meeting. Based on a read of the position paper. I have a few substantive comments to provide.
(11)(51 1
George, please let me know if you have any questions.
Thanks, Alissa Neuhausen General Engineer (NSPDP}
NRO/DE/SEB1 301-415-5734
---Original Message-From: Kratchman, Jessica Sent: Friday, May 29, 2015 12:04 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Geary,
{b)(5) rnanks.
Jessie From: Mizuno, Geary Sent: Friday, May 29, 201511:19AM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Geary From: Kratchman, Jessica Sent: Friday, May 29, 2015 9:17 AM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 2
(b)(:i)
George/ Jake/ Mark- Have I characterized that correctly?
From: Mizuno. Geary Sent: Thursday, May 28, 2015 5:06 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas, George
Subject:
RE: MEETING
SUMMARY
- PRM 50-109 Colleagues:
I am sorry I was unable to attend this meeting, I (l;){ii)
Geary From: Kratchman, Jessica Sent: Thursday, May 28, 2015 4:35 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Phlllp, Jacob; Thomas, George
Subject:
MEETING
SUMMARY
- PRM 50-109 LINKS: Link to SharePoint Site<http://fusion.nrc.gov/nrr/team/dp:r/prmb/rulemaking/PRM 109/SitePages/Home.aspx> Link to staff position paper. <http://fusion.nrc.gov/nrr/team/dpr/prmb/rulemakinr PRM-50-109/Working%20Documents/PRM%2050-109%20Draft%20Staff%20Position%20Recommending% (t*H5l r/o20(Rev%201 ), %20WG
%20comments.docx>
MEETING
SUMMARY
- Thanks to everyone for participated in today's meeting and to those of you who provided input prior to the meeting.
DISCUSSION: We spent today's meeting discussing George's input for Issues 1-3. We also discussed action items and the schedule moving forward.
3
(h)i5)
(bl{5)
... Issue 3: RES to add input ACTIONS:
RES: Issue 3: provide write up for June 9 meeting. Get to PM by COB June 5 .
- George:
o Update input per today's meeting, refer to comments/ edits tracked during meeting. Link to staff position paper.<http://fusion.nro.gov/nrr/team/dpr/prmb/rulemaking/PRM-50-109Nl/orking%20Documents/PRM%2050-109%20Draft%20Staff%20Positlon%20Recommending, b1(5J r/o20(Rev%201 ),%20WG
%20comments.doox>
o Prepare Comment 4 (9) input for June 9 meeting. Provide to PM by June 5.
- Jessie: Comments 1-3 input will be emailed to the group for input by June 5.
- All: review current staff position document (link above).
SCHEDULE: Next meeting we will discuss Issue 3 (RES input} and Comment 4 (9).
Comment#
Lead Due Date WG review method Issues 1, 2, 3 Thomas May 28, 2015 WG meeting Comments 1, 2, 3 4
Kratchman June 9, 2015 Email Comment 4 (9) + Issue 3 (RES input)
Thomas/
RES June 9, 2015 WG meeting Comment 5, 6 Lehman June 23, 2015 Email Comment 7 (10)
Thomas June 23, 2015 WG meeting Comment a Thomas July 7, 2015 WGmeeting Thanks again!
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 5
From: Kratchman, Jessica Sent: Thursday, June 11. 2015 4:39 PM To: Thomas, George Cc: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
Re: "Issues" for PRM 50-109 WG- please provide all input to George and he will track and consolidate by our next meeting.
George- Please be sure to put the final version in SharePoint one day prior to our next working group meeting.
On: 11 June 2015 14:51, "Thomas, George" <George.Thomas2@nrc.gov> wrote:
- Jessie, I do not agree with your approach that individual WG members go make changes to the document - all you will get is a bigger mess and a poor quality document. As the technical lead, I will take ownership of this document, and WG members can continue to provide comments to me and cc everyone. I will consider all comments (not necessarily accept all) and Input received so far (from Angella, Allssa, Jessica, Bryce, Jake, Mark and Geary) and develop a clean next version of the document for further WG review. Thanks for Gearv's aood inout which (b)(5)
In the mean time, I recommend that WG members develop responses to respective public comments, that have been assigned to them in the proper format and guidance previously provided by Geary.
I will be out-of-the office all of next week, and will try and have the next version to the WG by the next meeting (6/24).
I believe in a focused effort in addressing the petition, rather than reacting to emails and document changes propping up randomly.
Jessie - if you do not like my suggested approach, please let me know, and you may proceed the way you want.
Thanks.
George 1
From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:51 PM To: Mizuno, Gearyj Fuhnnann, Mark; I nverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Please make your changes in SharePoint. That is a living document. The only edits are those supplied by RES and this will keep everything in one location. Thanks so much!
-Jessie From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:47 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 I"'"
Geary From: Kratchman, Jessica sent: Thursday, June 11, 2015 12:42 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 I have no problem with these changes. Thoughts from the Group?
Geary- please update the document in SharePoint (link provided this morning), so that your suggestions have been documented properly.
Group- please provide your input by adding comments/ tracked changes in SharePoint.
From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:08 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues for PRM 50-109 Colleagues:
Now that I have read the PRM in detail, and re-reviewed out PRM response, I have the following observations and suggestions.
(b)(5) 1.
2.
2
Geary (b) 5) 1 2.
3.
3
From: Mizuno, Geary <IMCEAEX-_O=USNRC_OU=FIRST+20ADMIN1STRATIVE+
20GROUP_CN=RECIPIENTS_CN=73E4D2E4-E2312E70-1D627F61-118EF6DB@usnrc.onmicrosoft.com>
Sent: Friday, June 12, 2015 9:18 AM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Great. In developing your draft, please feel free to ~ ~ o-.1.1.1= 1.1.i.... .i..u~............................"""4n of sub-points in my
~trawman,_and definitely__add sLJb-_o_i_n~ddressin raised in the C-1 Q_ petition.
From: Thomas, George Sent: Friday, June 12, 2015 9:14 AM To: Mizuno, Geary; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Phllip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Thanks, Geary. Let me take a shot at developing a revised document taking into account your suggestions.
Georg_~ .* _ _ **-
- _
From: Mizuno, Geary Sent: Thursday, June 11, 2015 4:28 PM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Hi Georae:
(b)(t>)
1
~ry - ---- * - - - - - ~- ----- - - - - - - - -*
From: Thomas, George Sent: Thursday, June 11, 2015 2:52 PM To: Kratchman, Jessica Cc: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Phillp, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109
- Jessie, I do not agree with your approach that individual WG members go make changes to the document - all you will get Is a bigger mess and a poor quality document. As the technical lead, I will take ownership of this document.
and WG members can continue to provide comments to me and cc everyone. I will consider all comments (not necessarily accept all) and input received so far (from Angella, Alissa, Jessica, Bryce, Jake. Mark and Geary) and develo a clean next version of the document for further WG review. Thanks for Gea 's ood in ut which (l1)(5t w1 e ou -o - e o ice a o nex wee , an w1 ry an (6/24).
I believe in a focused effort in addressing the petition, rather than reacting to emails and document changes propping up randomly.
Jessie - If you do not like my suggested approach, please let me know, and you may proceed the way you want.
Thanks.
~!90~~
From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:51 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blarr, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Please make your changes in SharePoint. That is a living document The only edits are those supplied by RES and this will keep everything in one location. Thanks so much!
-Jessie From: Mizuno, Geary Sent: Thursday, June 11, 201512:47 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George bioct* AF* 'Issues" inc PAM 50-109 r
Geary 2
From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:42 PM To: Mlztmo, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 I have no problem with these changes. Thoughts from the Group?
Geary- please update the document in SharePoint (link provided this morning), so that your suggestions have been documented properly.
Group- please provide your input by adding comments/ tracked changes in SharePoint.
From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:08 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wi,ft; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Colleagues:
Now that I have read the PRM in detail. and re-reviewed out PRM response, I have the following observations and suaaestions.
1 (bl(~)
2 Geary
>>>>>>>>>>>>>>>>>'- - . . - ~----
1 (bW'i) 2.
3.
3
From: Tho mas, George Sent: Wednesday, June 24, 2015 9:10 AM To: Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Mizuno, Geary
Subject:
RE: "Issues" for PRM 50- 109
~
Attachments: PRM 50-109 Draft Staff Po~ition Rec,ommendingJ bl(S) ~Rev 2 - In Progress) 6-24-15.docx; UC-300 Rulemaking Procedures.p NoteThe firat attachmeat. a 20-page dra~
is withheld in its entirety under FOIA exemption 5. The second attachment, LIC-Hello All, 300, Rulemaking Procedures, is ML12234A377 is a non-resnonsive record.
I have attached the latest version of the PRM draft document for discussion at today's WG meeting, noting that it is still a work-in-progress since I have been out of the office for over a week. I have also attached FYI the NRR Office Instruction LIC-300 (Appendix I describes the PRM process, and Appendix K provides references to examples of PRM packages).
Please review it in the "Final" view under the review tab so that you do~n./-*~
t s2.ie~e~a 5!....li:!li..!i:!'1L..l.l~uw~i!.U5'larl.lJ.L.Uii: ...-.--.
marku s. I have made chan es to Sections I II Ill and some in I t (b)(5 l (b)( )
Thanks.
George From: Mizuno, Geary Sent: Friday, June 12, 2015 9:18 AM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Great. In developing your draft, please feel free to modif delete- chan strawman, and definitely add sub- oints addressin (t,)(5 ,
From: Thomas, George Sent: Friday, June 12, 2015 9:14 AM To: Mizuno, Geary; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas WIit
Subject:
RE: "Issues" for PRM 50- 109 Thanks, Geary. Let me take a shot at developing a revised document taking into account your suggestions.
George From: Mizuno, Geary Sent: Thursday, June 11, 2015 4:28 PM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109
Hi George:
(t.>)(;:.i)
Geary From: Thomas, George Sent: Thursday, June 11, 2015 2:52 PM To: Kratchman, Jessica Cc: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blalr, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Jessie, I do not agree with your approach that individual WG members go make changes to the document - all you will get is a bigger mess and a poor quality document. As the technical lead, I will take ownership of this document, and WG members can continue to provide comments to me and cc everyone. l will consider a ll comments (not necessarily accept all) and input received so far {from Angella, Alissa, Jessica, Bryce, Jake, Mark and Geary) 2
and develop a clean next version of the document for further WG review. Thanks for Geary's good input which
'b)(::,)
In the mean time, I recommend that WG members develop responses to respective public comments, that have been assigned to them in the proper format and guidance previously provided by Geary.
I will be out-of-the office all of next week, and will try and have the next version to the WG by the next meeting (6/24).
I believe in a focused effort in addressing the petition, rather than reacting to emails and document changes propping up randomly.
Jessie - if you do not like my suggested approach, please let me know, and you may proceed the way you want.
Thanks.
George From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:51 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Please make your changes in SharePoint. T hat is a living document. The only edits are those supplied by RES and this will keep everything in one location. Thanks so muchl
.Jessie From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:47 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 (b)r:,\
Geary 3
From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:42 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 I have no problem with these changes. Thoughts from the Group?
Geary- please update the document in SharePoint (link provided this morning), so that your suggestions have been documented properly.
Group- please provide your input by adding comments/ tracked changes in SharePoint.
From: Mizuno, Geary Sent: Thursday, June 11, 201512:08 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Colleagues:
Now that I have read the PRM in detail, and re-reviewed out PRM response, I have the following observations and suggestions.
- 1. (b)(5i 2.
Geary
>>>>- - - - - - , ,- - ,- - - , , - - , - .... .,- -- ... ~- ........ ~- .... - - .~
- 1. (b)(5) 2.
3.
4
From: Thomas, George Sent: Wednesday, June 24, 2015 9:29 AM To: Kratchman, Jessica Cc: Philip, Jacob; Fuhrmann, Mark
Subject:
RE: "Issues" for PRM 50-109 Jessie - The text in Section VI does incor orate the RES co (b)( )
From: Kratchman, Jessica Sent: Wednesday, June 24, 2015 9:22 AM To: Thomas, George Cc: Philip, Jacob; Fuhrmann, Mark
Subject:
RE: "Issues" for PRM 50-109 George- does this draft incorporate RES comments? I only looked quickly but I don't see Mark's comments anymore .. .
From: Thomas, George Sent: Wednesday, June 24, 2015 9:10 AM To: Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Mizuno, Geary
Subject:
RE: "Issues" for PRM 50-109 Hello A ll, I have attached the latest version of the PRM draft document for discussion at today's WG meeting, noting that it is still a work-in-progress since l have been out of the office for over a week. I have also attached FYI the NRR Office Instruction LIC-300 (Appendix I describes the PRM process, and Appendix K provides references to examples of PRM packages).
Please review it in the "Final" view under the review tab so that you don't see a clean file without redline markups. I have made changes to Sections I II, Ill and some in IV to l(b)(!)) I ibl(S)
Thanks.
George From: Mizuno, Geary Sent: Friday, June 12, 2015 9: 18 AM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: '-'Issues" for PRM 50-109
Great. In developing your draft, please feel free to modify, delete, change the location of sub-points in my strawman, and definitely add sub-points addressing !{6)(5) jralsed in the C-1O petition.
From: Thomas, George Sent: Friday, June 12, 2015 9:14 AM To: Mizuno, Geary; Kratchman, Jessie.a Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50- 109 Thanks, Geary. Let me take a shot at developing a revised document taking into account your suggestions.
George From: Mizuno, Geary Sent: Thursday, June 11, 2015 4:28 PM To: Thomas, George; Kratchman, Jessica Cc: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Hi George:
(b)(5) 2
As a separate matter, it should be obvious that I agree with you that individual WG members making changes to a single document is not the way to go.
Geary From: Thomas, George Sent: Thursday, June 11, 2015 2:52 PM To: Kratchman, Jessica Cc: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt
Subject:
RE: "Issues" for PRM 50-109 Jessie, I do not agree with your approach that individual WG members go make changes to the document - all you will get is a bigger mess and a poor quality document. As the technical lead, I will take ownership of this document, and WG members can continue to provide comments to me and cc everyone. I will consider all comments (not necessarily accept all) and input received so far (from Angella, Alissa, Jessica, Bryce, Jake, Mark and Geary) and develop a clean next version of the document for further WG review. Thanks for Geary's aood inout which (r>)(5)
In the mean time, I recommend that WG members develop responses to respective public comments. that have been assigned to them in the proper format and guidance previously provided by Geary.
I will be out-of-the office all of next week, and will try and have the next version to the WG by the next meeting (6/24).
I believe in a focused effort in addressing the petition, rather than reacting to emails and document changes propping up randomly.
Jessie - if you do not like my suggested approach, please let me know, and you may proceed the way you want.
Thanks.
George From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:51 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 3
Please make your changes in SharePoint. That is a living document. The only edits are those supplied by RES and this will keep everything in one location. Thanks so much!
-Jessie From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:47 PM To: Kratchman1 Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blalr, Angella; Neuhausen, Alissa; Philip, Jacobi Thomas WIit; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Geary From: Kratchman, Jessica Sent: Thursday, June 11, 2015 12:42 PM To: Mizuno, Geary; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blalr, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 I have no problem with these changes. Thoughts from the Group?
Geary- please update the document in SharePoint (link provided this morning), so that your suggestions have been documented properly.
Group- please provide your input by adding comments/ tracked changes in SharePoint.
From: Mizuno, Geary Sent: Thursday, June 11, 2015 12:08 PM To: Kratchman, Jessica; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
RE: "Issues" for PRM 50-109 Colleagues:
Now that I have read the PRM in detail, and re-reviewed out PRM response, I have the following observations and suggestions.
1 (b~5) 2 Geary 4
2.
3.
5
From: Kratchman, Jessica Sent: Wednesday, June 24, 2015 1:25 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
ACTION ITEMS: PRM 50-109 MEETING
SUMMARY
- 1. Discussion of actions from previous meeting.
o*,HS)
ACTIONS:
Jessie- follow up on potential allegations; meeting summary; schedule meeting for 3 weeks from today (-July 15); place binned/ summarized comments into the draft FRN- send to George for incorporation (Due COB July 7).
George/ Bryce- Update FRN draft in light of todays meeting and send to WG (Due COB July 8). Collect/
consolidate group comments (Due next WG meeting).
Working Group- Review next draft of FRN, provide comments to George (Due prior to next WG meeting) and be prepared to discuss at next WG meeting.
Thanks everyone.
-Jessie 1
Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Kratchman, Jessica Sent: Wednesday, June 10, 2015 5:22 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
ACTION ITEMS: PRM 50-109 Thanks to everyone for attending today s working group meeting and being flexible with the conference rooms.
Please see the below action items as outcomes from todays discussion:
REMINDER: please revise documents through the SharePoint Site for version control purposes.
- GEARY:
- 1. Provide second draft for issues identified in the petition. Link to Issue Summary Document. Due: June 17
- 2. Read/ provide input to the Issue Summary document.
- JAKE/ MARK: Add your input into SharePoint (call me if you need some help!). Link to Issue Summary Document. Due: June 23
- GEORGE/ BRYCE:
, b)IS)
- 2. Once Geary s input is received (June 17) for the Issue identification, please add technical considerations.
Due: June 23
- JESSIE:
2
- 1. Update overall schedule to provide increased time towards the resolution of Issues. Due: June 23
- 2. Pursue whether allegations have been identified in the petition.
Please let me know if you have any questions.
-Jessie Jessica Kratchman. candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301 -415-5112 3
From: Marshall, Michael Sent: Wednesday, June 24, 2015 5:07 PM To: Marshall, Jane Cc: Thomas, George; Rogers, Bill Subjed: RE: **POTENTIAL ALLEGATION ***: PRM 50-109 Hello Jane, I have asked George to call you on Thursday to discuss (he is working from home).
We are already involved. George is one of the engineers assigned to*responding to petition for rulemaking concerning ASR. He pointed out to the petition PM that three statements in the petition could be viewed as allegations and suggested that those statements be sent to the allegation coordinator. If the allegation coordinator has questions about regulations and safety, George could have provided a response.
Short answer is to pass George's name along as point-of-contact.
Best Regards, Michael L. Marshall, Jr.
Chief Aging Management of Structures, Electrical, and Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation 301-415-2871 Email: michael.marshall@nrc.gov From: Marshall, Jane Sent: Wednesday, June 24, 2015 3:56 PM To: Marshall, Michael
Subject:
FW: **POTENTIAL ALLEGATION***: PRM 50-109 Your thoughts?
From: Meighan, Sean Sent: Wednesday, June 24, 2015 3:52 PM To: Taylor, Robert; Dennig, Robert; Dean, Jeremy; Jackson, Christopher Cc: Marshall, Jane
Subject:
RE: **POTENTIAL ALLEGATION***: PRM 50-109 Hi all:
I promise I am not tryin to waste time. I a ee this looks like an ASR issues but m lhou ht was this ma be b)(5) ane.
I will stand for Code Review branch and DE' s direction.
Tbank you very much ail!!
1
sean From: Taylor, Robert Sent: Wednesday, June 24, 2015 3:46 PM To: Dennig, Robert; Dean, Jeremy; Meighan, Sean; Jackson, Christopher Cc: Marshall, Jane SUbject: RE: **POTENTIAL ALLEGATION***: PRM 50-109 All, The Seabrook ASR issue is being led out of DLR. I would recommend coordinating with Jane Marshall who can ensure the right folks in her division look at this. DE support may be necessary.
Rob From: Dennig, Robert Sent: Wednesday, June 24, 2015 3:43 PM To: Dean, Jeremy; Meighan, Sean; Jackson, Christopher Cc: Taylor, Robert
Subject:
RE: **POTENTIAL ALLEGATION ***: PRM 50-109 Containment structu ral issues belong to DE - Lupold.
From: Dean, Jeremy Sent: Wednesday, June 24, 2015 3:35 PM To: Meighan, Sean; Jackson, Christopher; Dennig, Robert Cc: Taylor, Robert Subject; Re: **POTENTIAL ALLEGATION ***: PRM 50-109 Sean, I don't think this is a SNPB area of expertise. I think it is more like Reactor Sys or Containment branch.
J~r~l!!Y From: Meighan, Sean Sent: Wednesday, June 24, 2015 03:29 PM To: Dean, Jeremy
Subject:
- POTENTIAL ALLEGATION*** : PRM 50-109 Hi Jeremy:
I work in NRR allegations, and need a little help with the below. My opening question is, are the 3 below issues, issues? Are there regulatory requirements associated with the below concerns.
Let me know when you have a chance to digest (or any staff member you send to). I am free to discuss whenever.
Treat as allegation material until we detennine otherwise. Thank you!
Vcry Respectfully Sean Meighan Allegations Coordinator NRR/DIRS/IPAB U.S. Nuclear Regulatory Commission 2
301-415-1020 From: Kratchman, Jessica Sent: Wednesday, June 24, 2015 2:32 PM To: Willis, Dori Cc: Stuchell, Slheldon; Inverso, Tara; Kokajko, Lawrence; Mohseni, Aby; Banic, Merrilee; Mizuno, Geary
Subject:
POTENTIAL ALLEGATIONS: PRM 50-109 Dori, I am a PM in NRR/ Division of Policy and Rulemaking. I am managing the resolution of PRM 50-109 which was filed under 10 CFR 2.802. We believe that some of the issues raised in the petition might actually be allegations. It was suggested that I contact you to help us determine if these in fact are allegations and what the appropriate path forward is. One of the issues (noted below) may actually be more appropriate for the 2.206 process, so I have included Sheldon Stuchell who's branch manages such petitions.
I have attached the petition to this email and highlighted the areas in question. I have also pasted them below.
- 1. NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements." [Allegation?]
- 2. "Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression." [2.802 or allegation?)
- 3. NextEra did not have composite team. In -fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required.
NextEra failed to test the concrete despite the extent of cracking visibly increasing for years." [Allegation?]
3
Thanks for your help.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 4
From: Gavrilas, Mirela Sent: Friday, June 26, 2015 2:48 PM To: Kratchman, Jessica; Kokajko, Lawrence Cc: Mohseni, Aby; Inverso, Tara; Meighan, Sean; Willis, Dori
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Thanks, Jessica. Please keep us posted and let me know if there is anything that you need from me.
M.
From: Kratchma*n, Jessica Sent: Friday, June 26, 2015 11 :06 AM To: Gavrilas, Mirela; Kokajko, Lawrence Cc: Mohseni, Aby; Inverso, Tara; Meighan, Sean; Willis, Dori
Subject:
POTENTIAL ALLEGATIONS: PRM 50-109 Lawrence/ Mirela, I wanted to bring to your attention some recently identified issues within PRM 50-109 for which I am the PM.
PRM 50-109 is with regards to improved identification techniques of alkali silica reaction (ASR) concrete degradation. On 06-24-15 my working group began discussions on a few issues identified within the petition.
After this discussion we decided that these issues might be better addressed within the allegation process.
After that meeting, and discussions with Tara, I contact Dori Willis and Sean Meighan who are our allegations coordinators. They subsequently contacted the Region 1 where it was decided these issues would reside.
Two of the issues were confirmed by the regional coordinator to be allegations and one was identified not to be an allegation and better addressed either in the PRM or with OIG. As a result, I called the OIG hotline to report this item and they suggested I fill out the online form reporting the issue, and then they can coordinate their efforts with the Region. I have attached the petition to this email and highlighted the areas in question in case you would like some context. I have also attached the Regional Office s assessment of the Issues to this email, as they did a very good analysis of the issues.
Below are the three issues that the WG identified. Please let me know if you have any questions
- 1. NextEra never had a code certified responsible engineer doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements. [CONFIRMED Allegation]
- 2. Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required 1
any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression. [CONFIRMED NOT an Allegation- contacted OIG Hotline]
- 3. NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated responsible engineer conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years.
[CONFIRMED allegation]
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 2
From: Lehman, Bryce Sent: Friday, June 30, 2017 9:13 AM To: Carneal, Jason
Subject:
DRAFT FRN PRM 50-109 Status Jason, Just curious .. what is the status of this rulemaking petition?
Thanks, Bryce From: Lehman, Bryce Sent: Monday, April 17, 2017 4:39 PM To: Ca meal, Jason
Subject:
RE: DRAFT FRN PRM 50-109 EDO and OGC comments resolved.docx Jason,
]
fLh...,,)(S,,,..)- . , . . . - - - - - - - - - - - - - - - - - - 'f veryth1ng else looks good.
Thanks, Bryce From: Carneal, Jason Sent: Monday, April 17, 2017 11:55 AM To: Lehman, Bryce <Bryce.Lehman @nrc.gov>
Cc: Kratchman, Jessica <Jessica.Kratchman @nrc.gov>
Subject:
DRAFT FRN PRM 50-109 EDO and OGC comments resolved.docx Bryce:
Please check the tracked changes i:n the attached and make any necessary changes / corrections, and I think we are good to go!
v/r, Jason Jason Carneal Reactor Operations Engineer NRR/DIRS/IOEB 301-415-1451 1
From: Kratchman, Jessica Sent: Tuesday, June 30, 2015 11 :33 AM To: Mizuno, Geary Cc: Bladey, Cindy; Inverso, Tara; Thomas, George; Kokajko, Lawrence; Mohseni, Aby; Warnek, Nicole
Subject:
FW: POTENTIAL ALLEGATIONS: PRM 50-109 Attachments: RE: POTENTIAL ALLEGATIONS: PRM 50-109 Geary, As you know the PRM 50-109 WG identified some issues within the PRM as potential allegations. I have thus been working with DPR management, the NRR allegations coordinators and Regional counterparts to appropriately handle these issues.
As such, the Regional office confirmed two of the issues as allegations and felt one should be addressed either in the PRM or with OIG (see below}. As a result, I called the OIG hotline/ submitted their online form to report this item.
- 1. " NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements." [CONFIRMED Allegation]
- 2. "Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression." [CONFIRMED NOT an Allegation- contacted OIG Hotline]
- 3. "NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years."
[CONFIRMED allegation]
Out of our discussions, the Regional office has proposed the below highlighted path forward. If we agree with their approach, I will email C-10 and let them know of our need for a call. In the call we can propose the options Nicole outlines below. I will include DPR management, the Regional Coordinator, NRR allegations coordinator and you in the call.
Before I proceed and contact C-10 I wantto make sure you agree with this approach.
Thanks.
-Jessie Jessica Kratchman, candidate DrPH 1
Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Warnek, Nicole Sent: Monday, June 29, 2015 12:50 PM To: Kratchman, Jessica Cc: RlALLEGATION RESOURCE; Vito, David; Willis, Dori; Meighan, Sean
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Jessica, I have never dealt with an allegation derived from a PRM before, but I received guidance from our HQ allegation office on how to handle it. We all agree this should be treated similar to an allegation derived from a 2.206 petition. When an allegation is identified from a 2.206 petition, typically a letter is sent to the petitioner indicating that a particular item is not being processed under 2.206 and is being moved to the allegation process instead.
Can you reach out to C-10 and let them know that the staff has determined that items 1 and 3 (below) would best be handled under the allegation process rather than under the PRM? I imagine a phone call might be the best way to go, In lieu of a letter. If C-10 is against putting the issues into the allegation process. we would likely be okay with that, and you can keep everything under the PRM. (The Region I branch chief with oversight of Seabrook indicated that C-10 may not want these issues separated out and put into the allegation process.}
I am happy to participate on a phone call to C-1 O if that would be helpful to you.
Nicole Warnek Region I Allegation a Enforcement Specialist 610-337-6954 (office) l(h1(61 I(cell)
From: Kratchman, Jessica Sent: Friday, June 26, 2015 10:33 AM To: Warnek, Nicole Cc: Meighan, Sean; Willis, Dori; Inverso, Tara
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Nicole, Also see the attached.
-Jessie 2
From: Kratchman, Jessica Sent: Friday, June 26, 2015 10:32 AM To: Warnek, Nicole Cc: Meighan, Sean; Willis, Dori; Inverso, Tara
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109
- Nicole, Responses to your questions below. Thanks for your help and I look forward to working with you.
The date on the document is September 2014. When did NRR/DPR actually review the document and identify the potential allegations?
-Within the PRM process we have 1 year (approximately) to review the comments/ issues identified in the petition. It was not until I emailed Dori Uune 24, 2015) that the working group had reviewed the issues identified below as potential allegations.
I see the document was submitted by C-10. Do you have ~ specific contact I can work with? (Name, phone number, and mailing address?
- I only have the contact information that was supplied with the PRM (attached).
Was this document ever made publically available in ADAMs?
- Yes, PRMs are generally publically available.
Please let me know how else I can support your effort and what my role is moving forward.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Warnek, Nicole Sent: Thursday, June 25, 2015 1:14 PM To: Kratchman,*Jessica Cc: RlALLEGATION RESOURCE; Meighan, Sean; Willis, Dori
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Jessie, I work in Allegations Office in Region I. Dori and Sean forwarded me your email regarding the C-10 PRM 50-1 09. Our technical staff reviewed the document, as summarized in the below email chain, and we believe 2 of the issues should be treated as allegations. The fourth issue we may take on as well, just to pulse for more information.
l have a few questions for you:
- The date on the document is September 2014. When did NRR/DPR actually review the document and identify the potential allegations?
-I see the document was submitted by C-10. Do you have a specific contact I can work with?
(Name, phone number, and mailing address?)
3
-Was this document ever made publically available in ADAMs?
I've never worked with an allegation that was retrieved from a PRM before, so let me know what you need from me in terms of coordination moving forward.
Nicole Warnek Region I Allegation & Enforcement Specialist
!(b)(t:l I 610-337-6954 (office)
(cell)
From: R1ALLEGATION RESOURCE Sent: Thursday, June 25, 2015 12:48 PM To: Johnson, Sharon; Mclaughlin, Marjorie; Bickett, Brice; Crisden, Cherie; Warnek, Nicole; Urban, Richard SUbject: FW: POTENTIAL ALLEGATIONS: PRM 50*109 From: Meighan, Sean Sent: Thursday, June 25, 2015 12:47:40 PM (UTC-05:00) Eastern lime (US & Canada)
To: Warnek, Nicole Cc: RlALLEGATION RESOURCE; Willis, Dori
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Nicole:
Thank you for response. Now for the big question,,, Since this is Seabrook, are you guys taking this?
V/R s
From: Warnek, Nicole Sent: Thursday, June 25, 2015 11:40 AM To: Willis, Dori; Meighan, Sean Cc: Gray, Mel; Cook, William; Dentel, Glenn; RlALLEGATION RESOURCE
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Dori and Sean, the attachment was reviewed by Mel Gray and Bill Cook (Region I Branch Chief and SRA involved with ASR). Below is a summary of our review:
- 1. NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements.
This appears to be an allegation. Although we have an inspection footprint in this area (re: NextEra's IWL examinations of containment concrete), we (Region I) cannot say with certainty that the NRC verified the specific qualifications of the NextEra contractors/employees who conducted the visual inspections. Note that t he document referenced in the PRM (ML103540534} is a "Response to Request for Additional Information" issued by DLR, so you may want to check with them as well.
- 2. Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm. ASR suspicions or 4
required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression.
This does not appear to be an allegation. It is an assertion against the performance of the NRC. It is true that no core bores have been taken from containment. This either belongs with the petition for rulemaking or, perhaps, with OIG.
- 3. NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to t.ake further action as required. NeKt:efft failea te test the eeaeFete despite the eKteet ef efftekiBg 1,isihly iAeRlasiBg fer years.
This is not really an allegation ... but it's close. The sentence immediately preceding the above sentence references a specific code: ACI 349.3R-02. NextEra was not committed to this code 'in 2009 (they voluntarily committed to it in 2012). As such, they were not required to have a composite team or any of the other items identified in the above assertion. Nonetheless, we would expect that employees who conducted the visual inspections had some level of training or knowledge to carry out that task. If we are accepting #1 as an allegation it wouldn't hurt to include #3 as well.
- 4. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years. (Note: This statement was separated from the end of#3, above)
This appears to be a statement of fact, and something we know the validity of, i.e. not an allegation. We know that NextEra has tested concrete in several buildings, but they have not conducted testing of the concrete in containment. Unless the Cl can provide specific information that indicates NextEra has failed to do required testing, this does not appear to be an allegation.
Please note I have cc'ed some Region I personnel but have NOT included the NRR folks who were further down on the email chain. Feel free to forward as you see fit.
Nicole Warnek Region I Allegation &: Enforcement Specialist 610-337-6954 From: Meighan, Sean Sent: Wednesday, June 24, 2015 3:41 :06 PM To: R1ALLEGATION RESOURCE; Bickett, Brice; Urban, Richard Cc: Willis, Dori
Subject:
FW: POTENTIAL ALLEGATIONS: PRM 50-1 09 Auto forwarded by a Rule Hi All:
Can you guys look at the below and let me know if you have any history (validity known) on below issues?
V/R s
5
From: Kratchman, Jessica Sent: Wednesday, June 24, 2015 2:32 PM To: Willis, Dori Cc: Stuchell, Sheldon; Inverso, Tara; Kokajko, Lawrence; Mohseni, Aby; Banic, Merrilee; Mizuno, Geary
Subject:
POTENTIAL ALLEGATIONS: PRM 50-109
- Dori, I am a PM in NRR/ Division of Policy and Rulemaking. I am managing the resolution of PRM 50-109 which was filed under 10 CFR 2.802. We believe that some of the issues raised in the petition might actually be allegations. It was suggested that I contact you to help us determine if these in fact are allegations and what the appropriate path forward is. One of the issues (noted below) may actually be more appropriate for the 2.206 process, so I have included Sheldon Stuchell who's branch manages such petitions.
I have attached the petition to this email and highlighted the areas in question. I have also pasted them below.
- 1. "NextE!l'a never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements." [Allegation?]
- 2. "Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression." [2.802 or allegation?]
- 3. "NextE!l'a did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required.
NextEra failed to test the concrete despite the extent of cracking visibly increasing for years." [Allegation?]
Thanks for your help.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 6
From: Kratchman, Jessica Sent: Wednesday, July 01, 2015 9:17 AM To: Mizuno, Geary Cc: Bladey, Cindy; Inverso, Tara; Thomas, George; Kokajko, Lawrence; Mohseni, Aby; Warnek, Nicole Subjed: Re: POTENTIAL ALLEGATIONS: PRM 50-109 Thanks Geary. I will contact C-10 and set up a call. I will include those outlined in my below email in the call.
-Jessie On: 01 July 2015 09:00, "Mizuno, Geary" <Geary.Mizuno@nrc.gov> wrote:
This looks good. I would hope that NRR adopts this as a kind of model (perhaps after some internal NRR WG to decide on a "best practice") to show how incoming claims should be summarized and the disposition recorded, for purposes of establishing documentation in PRMs, rulemakings and other situations.
Geary From: Kratchman, Jessica Sent: Tuesday, June 30, 2015 11:33 AM To: Mizuno, Geary Cc: Bladey, Cindy; Inverso, Tara; Thomas, George; Kokajko, Lawrence; Mohseni, Aby; Warnek, Nicole
Subject:
FW: POTENTIAL ALLEGATIONS: PRM 50-109 Geary, As you know the PRM 50-109 WG identified some issues within the PRM as potential allegations.
I have thus been working with DPR management, the NRR allegations coordinators and Regional counterparts to appropriately handle these issues.
As such, the Regional office confirmed two of the issues as allegations and felt one should be addressed either in the PRM or with OIG (see below}. As a result, I called the OIG hotline/
submitted their online form to report this item.
- 1. "NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements." [CONFIRMED Allegation]
- 2. "Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression."
[CONFIRMED NOT an Allegation- contacted OIG Hotline]
- 3. "NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible 1
engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years." (CONFIRMED allegation]
Out of our discussions, the Regional office has proposed the below highlighted path forward. If we agree with their approach, I will email C-10 and let them know of our need for a call. In the call we can propose the options Nicole outlines below. I will include DPR management, the Regional Coordinator, NRR allegations coordinator and you in the call.
Before I proceed and contact C-10 I want to make sure you agree with this approach.
Thanks.
-Jessie Jessica Kratchman, cand;date DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Warnek, Nicole Sent: Monday, June 29, 2015 12:50 PM To: Kratchman, Jessica Cc: RlALLEGATION RESOURCE; Vito, David; Willis, Dori; Meighan, Sean
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Jessica, I have never dealt with an allegation derived from a PRM before, but I received guidance from our HQ alleg*ation office on how to handle it. We all agree this should be treated similar to an allegation derived from a 2.206 petition. When an allegation is identified from a 2.206 petition, typically a letter is sent to the petitioner indicating that a particular item is not being processed under 2.206 and is being moved to the allegation process instead.
Can you reach out to C-10 and let them know that the staff has determined that items 1 and 3 (below) would best be handled under the allegation process rather than under the PRM? I imagine a phone call might be the best way to go, in lieu of a letter. If C-10 is against putting the issues into the allegation process, we would likely be okay with that, and you can keep everything under the PRM. (The Region I branch chief with oversight of Seabrook indicated that C-10 may not want these issues separated out and put into the allegation process.)
I am happy to participate on a phone call to C-10 if that would be helpful to you.
N~
Nkole Warnek Region I Allegation & Enforcement Specialist
, 10-337-6954 (office)
~b)() !(cell)
From: Kratchman, Jessica Sent: Friday, June 26, 2015 10:33 AM To: Warnek, Nicole Cc: Meighan, Sean; Willis, Dori; Inverso, Tara
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Nicole, Also see the attached.
-Jessie From: Kratchman, Jessica Sent: Friday, June 26, 2015 10:32 AM To: Warnek, Nicole 2
Cc: Meighan, Sean; Willis, Dori; Inverso, Tara
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109
- Nicole, Responses to your questions below. Thanks for your help and I look forward to working with you.
The date on the document is September 2014. When did NRRIDPR actually review the document and identify the potential allegations?
-Within the PRM process we have 1 year (approximately) to review the comments/ issues identified in the petition. It was not until I emailed Dori Uune 24, 2015) that the working group had reviewed the issues identified below as potential allegations.
I see the document was submitted by C-10. Do you have a specific contact I can work with?
(Name, phone number, and mailing address?
- I only have the contact information that was supplied with the PRM (attached).
Was this document ever made publica/Jy available in ADAMs?
-Yes, PRMs are genera lly publically available.
Please let me know how else I can support your effort and what my role is moving forward.
-Jessie .
Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: Warnek, Nicole Sent: Thursday, June 25, 2015 1:14 PM To: Kratchman, Jessica Cc: R1ALLEGATION RESOURCE; Meighan, Sean; Willis, Dori
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Jessie, I work in Allegations Office in Region I. Dori and Sean forwarded me your email regarding the C-1 O P RM 50- 109. Our technical staff reviewed the document, as summarized in the below email chain, and we believe 2 of the issues should be treated as allegations. The fourth issue we may take on as well, just to pulse for more information.
I have a few questions for you: ,
-The date on the document is September 2014. When did NRR/DPR actually review the document and identify the potential allegations?
- I see the document was submitted by C-10. Do you have a specific contact I can work with? (Name, phone number, and mailing address?)
-Was this document ever made publlcally ava ilable in ADAMs?
I've never worked with an allegation that was retrieved from a PRM before, so let me know what you need from me in terms of coordination moving forward .
Ni,kJd; Nicole Warnek Region I Allegation El: Enforcement Specialist 610-337-6954 (office )
- ,iti) 11 J(ce_ll).
fom: Rl ALLEGATION RESOURCE Sent: Thursday, June 25, 2015 12:48 PM To: Johnson, Sharon; Mclaughlin, Marjorie; Bickett, Brice; Crisden, Cherie; Wamek, Nicole; Urban, Richard *
Subject:
FW: POTENTIAL ALLEGATIONS: PRM 50-109 From: Meighan, Sean Sent: Thursday, June 25, 2015 12:47:40 PM (UTC-05:00) Eastern Time (US &. canada)
To: Warnek, Nicole 3
Cc: RlALLEGATION RESOURCE; Willis, Dori
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Nicole:
Thank you for response. Now for the big question,,, Since this is Seabrook, arc you guys taking this?
V /R s
From: warnelk, Nicole Sent: Thursday, June 25, 2015 11:40 AM To: Willis, Dori; Meighan, Sean Cc: Gray, Mel; Cook, William; Dentel, Glenn; RlALLEGATION RESOURCE
Subject:
RE: POTENTIAL ALLEGATIONS: PRM 50-109 Hi Dori and Sean, the attachment was reviewed by Mel Gray and Bill Cook (Region I Branch Chief and SRA involved with ASR). Below is a summary of our review:
- 1. NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements.
This appears to be an allegation. Although we have an inspection footprint in this area (re: NextEra's IWL examinations of containment concrete), we (Region I) cannot say with certainty that the NRC verified the specific qualifications of the NextEra contractors/employees who conducted the visual inspections. Note that the document referenced in the PRM (ML103540534) is a "Response to Request for Additional Information" issued by DLR, so you may want to check with them as well.
- 2. Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression.
This does not appear to be an allegation. It is an assertion against the performance of the NRC. It is true that no core bores have been taken from containment. This either belongs with the petition for rulemaking or, perhaps, with OIG.
- 3. NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. Next-Bm iatleEI te test '11e eaeerete Elespite '11e exteet af efaelciBg Yisibly ieereesieg fer years.
This is not really an allegation ... but it's close. The sentence immediately preceding the above sentence references a specific code: ACI 349.3R-02. NextEra was not committed to this code in 2009 (they voluntarily committed to it in 2012). As such, they were not required to have a composite team or any of the other items identified in the above assertion. Nonetheless, we would expect that employees who conducted the visual inspections had some level of training or knowledge to carry out that task. If we are accepting #1 as an allegation it wouldn't hurt to include #3 as well.
- 4. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years. (Note: This statement was separated from the end of#3, above) 4
This appears to be a statement of fact, and something we know the validity of, i.e. not an allegation. We know that NextEra has tested concrete in several buildings, but they have not conducted testing of the concrete in containment. Unless the Cl can provide specific information that indicates NextEra has failed to do required testing, this does not appear to be an allegation.
Please note I lhave cc'ed some Region I personnel but have NOT included the NRR folks who were further down on the email chain. Feel free to forward as you see fit.
Ni,k,k,i, Nicole Warnek Region I Allegation & Enforcement Specialist 610-337-6954 From: Meighan, Sean Sent: Wednesday, June 24, 2015 3:41 :06 PM To: R1ALLEGATION RESOURCE: Bickett, Brice; Urban, Richard Cc: Willis, Dori
Subject:
FW: POTENTIAL ALLEGATIONS: PRM 50-109 Auto forwarded by a Rule Iii All:
Can you guys look at the below and let me know if you have any history (validity known) on below issues?
V/R s
From: Kratchman, Jessica Sent: Wednesday, June 24, 2015 2:32 PM To: Willis, Dori Cc: Stuchell, Sheldon; Inverso, Tara; Kokajko, Lawrence; Mohseni, Aby; Banic, Merrilee; Mizuno, Geary
Subject:
POTENTIAL ALLEGATIONS: PRM 50-109 Dori, I am a PM in NRR/ Division of Policy and Rulemaking. I am managing the resolution of PRM 50-109 which was filed under 10 CFR 2.802. We believe that some of the issues raised in the petition might actually be allegations. It was suggested that I contact you to help us determine if these in fact are allegations and what the appropriate path forward is. One of the issues (noted below) may actually be more appropriate for the 2.206 process, so I have included Sheldon Stuchell who's branch manages such petitions.
I have attached the petition to this email and highlighted the areas in question. I have also pasted them below.
- 1. "NextEra never had a code certified "responsible engineer" doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements." [Allegation?)
- 2. "Since the NRC discovered this situation, the NRC has not required Seabrook to test criteria requiring an engineering evaluation with a single core bore taken from containment to confirm ASR suspicions or required any certified lab testing of key material properties to determine the extent of condition or obtain the data necessary to monitor the rate of progression." [2.802 or allegation?]
s
- 3. "NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated "responsible engineer" conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to talce further action as required. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years." [Allegation?]
Thanks for your help.
-Jessie Jessica Kratchman, candidate DrPH Division of Polley and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 6
From: Mizuno, Geary <Geary.Mizuno@nrc.gov>
Sent: Thursday, July 16, 2015 11 :54 AM To: Warnek, Nicole; Kratchman, Jessica; Inverso, Tara Cc: R1ALLEGATION RESOURCE Subject RE: REQUEST: PRM-50-109; NRC-2014-0257 Ms. Warnek:
Thank you for this information. It will help the WG move forward with the PRM, and properly describe and reflect this information in the documentation for the NRG s consideration of the PRM.
Geary S. Mizuno Special Counsel OGC From: Warnek, Nicole Sent: Thursday, July 16, 2015 11 :46 AM To: Kratchman, Jessica; Inverso, Tara; Mizuno, Geary Cc: R1ALLEGATION RESOURCE
Subject:
FW: REQUEST: PRM-50-109; NRC-2014-0257 Hi Jessica, I spoke with Ms. Gavutis and Ms. Grinnell of C-10 today about the two statements from the PRM that we believed were allegations. At this point, I am no longer considering them to be allegations. Ms. Gavutis stated that the two statements are not two separate issues they are really saying the same thing. Basically, NextEra was not following the ACI guidance (in 2010) and did not have a responsible engineer doing their concrete inspections. She recognizes that NextEra was not required to follow the ACI standard, and was not even committed to it at that time. (In fact, that was the point of the PRM; C-1 O believes NRC should develop a regulation in this area so that NextEra, and other plants, would be be required to follow the industry guidance or some similar standard.)
Most importantly, Ms. Gavutis said she got the information (about NextEra not using a responsible engineer to conduct inspections, and instead using untrained employees) from an NRC inspection report. She said wording is not taken verbatim from the inspection report, and she may have extrapolated it a bit, but the basic underlying information was from the NRC. She believes it was a Region inspection report from the 201 O 1
timeframe. She committed to sending me the ML number. Since the information was taken from an NRG inspection report, it is not an allegation (the validity is known).
At this point I recommend that you/ the PRM review group should keep the two statements with the PRM. C-10 offered them as supporting evidence as to why they believe we need to make a regulation in this area.
Let me know if you have any questions. 111 send along the inspection report when I get it.
Nikki Nicole Warnek Region I Senior Allegation Coordinator 610-337-6954 (office)
,,u,
___iu_ !
> _ _.... (cell)
From: Kratchman, Jessica Sent: Wednesday, July 01 , 20151 :55 PM To: sandra@c-10.org Cc: Mizuno, Geary; Wamek, Nicole; Inverso, Tara
Subject:
REQUEST: PRM-50-109; NRC-2014-0257 Ms. Gavutis, My name is Jessica Kratchman and I am the project manager for the 2.802 petition for rulemaking (PRM) you submitted on September 25, 2014 [Docket No. PRM-50-109; NRC.:2014-0257], titled Improved Identification Techniques against Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants. In evaluating the PRM, the NRC identified two issues that we believe should be addressed in our allegations process. All other issues that you have raised are still being reviewed within the 2.802 PRM process, except the following:
- 1. NextEra never had a code certified responsible engineer doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements.
2
- 2. NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated responsible engineer conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. NextEra failed to test the concrete despite the ~xtent of cracking visibly increasing for years.
Our Regional Allegations Coordinator would like to set up a phone call to explain the allegations process and answer any questions you might have. I will also be on the call to answer any questions about the petition
- process. Please let me know when you would be available for such a call, ideally within the next week.
Thanks so much.
-Jessie Jessica Kratchman, candidate DrPH Project Manager Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuc~ear Regulatory Commission 301-415-5112 3
From: Warnek, Nicole Sent: Monday, July 20, 2015 1:06 PM To: Kratchman, Jessica; Inverso, Tara; Mizuno, Geary Cc: R1ALLEGATION RESOURCE
Subject:
RE: REQUEST: PRM-50-109; NRC-2014-0257 Attachments: [External_Sender] Hello FYI, attached is the email that Debbie Grinnell sent in follow up to my conversation with her last Thursday. It provides background regarding the two statements that we initially believed were allegations. (The inspection report is not included but is referenced on page 3 of the attached letter to Bill Dean.)
Any questions let me know.
Nikki Nicole Warnek Region I Senior Allegation Coordinator 610-337-6954 (office)
L..l
'ti-l(o_-, _ _ __.! (cell}
From: Warnek, Nicole Sent: Thursday, July 16, 2015 11 :46 AM To: Kratchman, Jessica; Inverso, Tara; Mizuno, Geary Cc: R1ALLEGATION RESOURCE
Subject:
FW: REQUEST: PRM-50-109; NRC-2014-0257 Hi Jessica, I spoke with Ms. Gavutis and Ms. Grinnell of C-10 today about the two statements from the PRM that we believed were allegations. At this point, I am no longer considering them to be allegations. Ms. Gavutis stated that the two statements are not two separate issues they are really saying the same thing. Basically, NextEra was not following the ACI guidance (in 2010) and did not have a responsible engineer doing their concrete inspections. She recognizes that NextEra was not required to follow the ACI standard, and was not even committed to it at that time. (In fact, that was the point of the PRM; C-10 believes NRC should develop a 1
regulation in this area so that NextEra, and other plants, would be be required to follow the industry guidance or some similar standard.)
Most importantly, Ms. Gavutis said she .got the information (about NextEra not using a responsible engineer to conduct inspections, and instead using untrained employees) from an NRC inspection report. She said wording is not taken verbatim from the inspection report, and she may have extrapolated it a bit, but the basic underlying information was from the NRC. She believes it was a Region inspection report from the 201 O timeframe. She committed to sending me the ML number. Since the information was taken from an NRC inspection report, it is not an allegation (the validity is known).
At this point I recommend that you J the PRM review group should keep the two statements with the PRM. C-10 offered them as supporting evidence as to why they believe we need to make a regulation in this area.
Let me know if you have any questions. I II send along the inspection report when I get it.
Nikki Nicole Warnek Regio n I Senior Allegation Coordinator 610-337-6954 (office)
- l. .
(o-)\6-) _ ___,! (cell)
From: Kratchman, Jessica Sent: Wednesday, July 01 , 20151:55 PM To: sandra@c-10.org Cc: Mizuno, Geary; Wamek, Nicole; Inverso, Tara
Subject:
REQUEST: PRM-50-109; NRC-2014-0257 Ms. Gavutis, My name is Jessica Kratchman and I am the project manager for the 2.802 petition for rulemaking (PRM) you submitted on September 25, 2014 [Docket No. PRM-50-109; NRC-2014-0257], titled Improved Identification Techniques against Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants. In evaluating the 2
PRM, the NRC identified two issues that we believe should be addressed in our allegations process. All other issues that you have raised are still being reviewed within the 2.802 PRM process, except the following:
- 1. NextEra never had a code certified responsible engineer doing the visual inspections and the NRC was unaware that Seabrook was not following the recommended code inspection requirements.
- 2. NextEra did not have composite team. In fact, since they became the owners of Seabrook, before the ASR discovery in 2009, they did not even have a trained and dedicated responsible engineer conducting the inspections. NextEra had untrained employees conducting the visual examinations of buildings and no one trained engineer conducting the inspections to accurately record the results or trained to take further action as required. NextEra failed to test the concrete despite the extent of cracking visibly increasing for years.
Our Regfonal Allegations Coordinator would like to set up a phone call to explain the allegations process and answer any questions you might have. I will also be on the call to answer any questions about the petition process. Please let me know when you would be available for such a call, ideally within the next week.
Thanks so much.
-Jessie Jessica Kratchman, candidate DrPH Project Manager Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 3
From: Thomas, George Sent: Tuesday, July 21, 2015 1:14 PM To: Kratchman, Jessica Cc: Lehman, Bryce
Subject:
RE: FW: PRM 50-109 Comment Resolution Meeting: Comment 8 Hello Jessie -As indicated by Bryce, I suggest that we postpone this meeting to Aug 6 or 7. I have not made much progress in the preparation of the response due to being very busy with Seabrook and Davis-Besse LRA reviews, and will be on travel tomorrow thru Fri.
Thanks.
George
Original Appointment--*-*
From: Lehman, Bryce Sent: Tuesday, July 21, 2015 12:55 PM To: Kratchman, Jessica Cc: Thomas, George
Subject:
Tentative: FW: PRM 50-109 Comment Resolution Meeting: Comment 8 When: Monday, July 27, 2015 1:00 PM-2:00 PM (UTC-05:00) Eastern Time (US & Canada).
Where: HQ-OWFN-12B02-12p
- Jessica, I am out of town next Monday and will be unable to attend the meeting. Additionally I have been very busy and have not been able to help George with preparation of the response. Would it be possible if we delayed this meeting until August 6 or 7? I would be able to participate at that point and it would give me a bit more time to help fin~lize the response.
- Thanks, Bryce l
From: Thomas, George Sent: Wednesday, July 22, 2015 10:45 AM To: Lehman, Bryce
Subject:
Draft FRN on Recommended NRC response to PRM 50-109 Attachments: PRM 50-109 Draft Staff Position Recommendin \ ( J s) 7-22-1 5.docx Note: The 49-page draft attachment is withheld in its entirety under FOIA exemption 5.
Bryce - Attached is the latest version. Appreciate your help in developing, as much as you can, the NRC response to each of the petitioner's assertions in support of the petition. When working with the file, please use the review format with "no markup" so that you have a clean file when working on it.
Thanks for your help.
G~1~
Senior Structural Engineer NRR/DLR/RASB; 0-11E21 301-415-6181 George.Thomas2@nrc.gov 1
From: Kratchman, Jessica Sent Thursday, July 23, 2015 11:04 AM To: Thomas, George Cc: Lehman, Bryce Subject FW: PRM 50-109: Comment-Response template ,.,.....,,..,.....----,
Attachments: PRM 50- 109 Draft Staff Position Recommendin (IJH~l ith comment-responses j k.docx Note: The 5-page draft attachment is withheld in its entirety under FOIA exemption 5.
As a reminder- for the 08/06 working group meeting please prepare the issue responses and compile my input into your version. Please get it to the group at least a day in advance so people have time to review before the meeting.
- Thanks,
-Jessie From: Kratchman, Jessica Sent: Tuesday, July 14, 2015 10:31 AM To; Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob; Thomas Wilt; Thomas, George
Subject:
PRM 50-109: Comment-Response template Hello Team, As promised, attached is a comment-resolution template for PRM 50-109. It is the same comment summaries and bins from the matrix I provided a while ago (i.e. the Excel spreadsheet we have been working off of in SharePoint) but I have placed everything in the attached template with descriptions, etc. We will probably need to adjust some of the formatting but I wanted to make it easier for everyone to see where the comments and responses go.
George- please compile this in the version you are working on and appropriately adjust the Section numbering, etc.
I will be out of town from July 15-21 but when I return we will have our working group meeting.
Thanks.
-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 1
From: Lehman, Bryce Sent Friday, July 24, 2015 5:01 PM To:
Subjed:
Attachments:
Thomas, George l~
RE: Draft FRN on Recommended NRC response PBM 50-109 5
PRM 50-109 Draft Staff Position Recomrnendin9l.( )( > !(Lehman) 7-24-1 S.docx Note: The 38-page draft attachment is withheld in its entirety under FOIA exemption 5.
George, I did something but I am not sure how helpful you will find it and unfortunately I didn't complete it. As you noted, it is very slow going.
I was having difficulty working with the file you sent me so I accepted all changes and started fresh. The attached file shows everything I changed from the file you sent on Wednesday.
I pasted Jessica's comment response input over what you already had (she sent it in email 7/23). I don't necessarily think her format/ approach is better, but she said she was going to do that section and she grouped the comments ... I suggest leaving it her way and not worrying about it.
(b)(5)
Thanks for taking the lead on this and for putting so much effort in already. Hopefully my edits will help a little bit ... sorry I couldn't do more.
- Thanks, Bryce From: Thomas, George Sent: Wednesday, July 22, 2015 10:45 AM To: Lehman, Bryce
Subject:
Draft FRN on Recommended INRC response to PRM 50-109 Bryce -Attached is the latest version. Appreciate your help in developing, as much as you can, the NRC response to each of the petitioner's assertions in support of the petition. When working with the file, please use the review format with "no markup" so that you have a clean file when working on It.
Thanks for your help.
G~T~
Senior Structural Engineer NRR/DLR/RASB; 0-11E21 301-415-6181 George.Thomas2@nrc.gov 1