ML20115E450

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NRC-2020-000129 - Resp 1 - Interim, Agency Records Subject to the Request Are Enclosed. (Part 3 of 3)
ML20115E450
Person / Time
Issue date: 04/24/2020
From:
NRC/OCIO
To:
Shared Package
ML20115E445 List:
References
FOIA, NRC-2020-000129
Download: ML20115E450 (97)


Text

From; Calal<lo, eaul To: Cook WIIIM2; ~~; Sower fffll; Sal'ldev, Rknard; Sheehan, Nell CC1 Wittids Bnan; Byforrl. Angela; LQCi!lD, Ra,anond; ~ Broaddus Doug; ~.Qla~; \/azQycz Just/a; biXDb, John

Subject:

RE: FW: Press Rel~ from C-10 Date: Friday, June 17, 2016 6:10:38 AM I will get a copy of the last performed test.

From: Cook, WiUlam Sent; Thursday, June 16, 2016 3:41 PM To: Poole, Justin; Bower, Fred; Barkley, Richard; Sheehan, Neil Cc: Wittick, Brian; Buford, Angela; Lorson, Raymond; Gray, Mel; Cataldo, Paul; Broaddus, Doug; Screnci, Diane; Vazquez, Justin; Lamb, John

Subject:

RE: Fw: Press Release from C-10 I would like to remind everyone that NextEra has used the successful completion of the containment ILRT as one of the bases for continued CV operability. in spite of the presence of ASR (reference AR 1804477 available on Certre).

From: Poole, Justin Sent: Thursday, June 16, 2016 3:10 PM To: Bower, Fred <fred.Bowec@occ gov>; Barkley, Richard <Bichard,Barkley@nrc.gov>; Sheehan, Nell

<Nei!.Sheebao@occ gm£>

Cc: Wlttlck, Brian <Brjan,Wittick@nrc rov>; Buford, Angela <An~ela.Buford@nrc gov>; Cook, William

<WlJlia.!llJ:Qok@nrqov>; Lorson, Raymond <Raymond.Lorson@nrc.gov>; Gray, Mel

<Mei.Gray@nrqov>; Cataldo, Paul <Paul Catalda@mc iAY>; Broaddus, Doug

<Doug Broaddus@orc gov>; Screnci, Diane <Diane.Screoci@orc.gov>; Vazquez, Justin

<Justin Yazguez@nrc gov>; Lamb, John <JQhn,tamb@lnrc.eoV>

Subject:

RE: Fw: Press Release from C-10 I'll get something from the staff Justin C. Poole Project Manager NRR/DORL/LPL/-2 U.S. Nuclear Regulatory Commission (301)415-2048 From: Bower, Fred Sent: Thursday, June 16, 2016 3:04 PM To: Barkley, Richard <Richard.Barkle, @nrc.,,ov>; Sheehan, Neil <Nei!,Sheehani@nrc.gov>

Cc: Poole, Justin <Justin Poole@nrc.gov>; Wittick, Brian <Brian Wittick@nrc gov>; Buford, Angela

<Am~ela Buford@nrc iPY>: Cook, William <William~~ nrc.LQ_v>; Lorson, Raymond

<Ra*@ond.Lorson a1 0~>; Gray, Mel <Mel Gray@nrc iAv>; Cataldo, Paul

<PauLCataldo@nrc.gov>; Broaddus, Doug <Doug Broaddus@nrc gov>; Screnci, Diane

<Diane screoci@orq~av>; Vazquez, Justin <Justin Yazquez@nrc.eov>; Lamb, John

<John,Lamb@nrc.gov>

Subject:

RE: Fw: Press Release from C-10 Paul Cataldo - Can you do the prior test research?

Justin/Doug - would you be able to provide info to address the generic question why the change from 1O to 15 years is generally found to be okay by the agency?

Fred From: Barkley, Richard Sent: Thursday, June 16, 2016 2:58 PM To: Bower, Fred <Fred Bower@nrc goy>; Sheehan, Neil <NejLSheehan@nrc goy>

Cc: Poole, Justin <Justin poole@occ gov>; Wittick, Brian <Bciaa Wittick@nrc gov>; Buford, Angela

<Angela.Buford@nrc gov>; Cook, William <William.Cook@nrc.gov>; Lorson, Raymond

<Raymond Lorsoo@nrc.gov>; Gray, Mel <Mel,Gray@nrc gov>; Cataldo, Paul

<Paul Cataldo@nrc.gov>; Broaddus, Doug <Doug.Broaddus@orc gov>; Screnci, Diane

<Diane Screoci@orc gov>; Vazquez, Justin <Justin.Vazauez@nrc,goY>; Lamb, John

<fobo I amb@nrc gov>

Subject:

RE: Fw: Press Release from C-10 One good point from the press release:

NextEra has submitted a request to increase the ILRT frequency from 10 to 15 years. We should be prepared to answer why that amendment has been deemed safe at other sites.

C-10 will insist it should be done sooner versus later given the ASR seen to date.

We should also be ready with past test results - They should have done this test 3 times in their history.

From: Bower, Fred Sent: Thursday, June 16, 7016 2:42 PM To: Sheehan, Neil <Nejl,Sheehan@nrc.gov>

Cc: Barkley, Richard <Bicbard.Bark!ey@nrc.gov>; Poole, Justin <Justin,Poole@occ gov>; Wittick, Brian

<Bciao w;ttjck@ncc eov>; Buford, Angela <Aoeela Buford@nrc iDY>; Cook, William

<William.Cook@nrc gov>; Lorson, Raymond <Baymond.Lorson@nrc iPv>; Gray, Mel

<MeLGray@nrc.gov>; Cataldo, Paul <PauLCataldo@nrc gov>; Broaddus, Doug

<~oaddus@net.,gQY>; Screnci, Diane <Djane,Screnci@nrc gov>; Vazquez, Justin

<Justin YazQuez@nrc eov>; Lamb, John <John.Lamb@nrc gov>

Subject:

RE: Fw: Press Release from C-10

Neil, I would like to consult with Bill and Mel, but I believe that one statement from the PR is factually inaccurate: "Unknown to date is the extent and rate of Alkali Silica Reaction

(ASR) damage which the NRC has confirmed is progressing at a faster rate than expected. "

Beyond that, I would have worded things differently, but I do not see the point in quibbling.

Have we sent Angel our meeting notice, press release and informed her that we have updated our Seabrook webpage?

My reactions are attached.

Cc'ing AAM attendees for info.

Fred From: Sheehan, Neil Sent: Thursday, June 16, 2016 1:57 PM To: Bower, Fred <Fred Bower@nrc,gov>

Subject:

FW: Fw: Press Release from C-10 Your thoughts?

From: AChjarcuuida@newbur)lportnews com Sent: Thursday, June 16, 2016 1:56 PM To: Sheehan, Nell <Nell.S!1eehan21Jrc.pov>

Subject:

[External_Sender] Fw: Press Release from C-10 HI Nell, Wal\t to take a look at 1hls and send me a comment please?

Thanks, AJ Angeljean Chlaramida Staff Wrtter Dally News of Newburyport 23 Liberty Street Newburyport, MA. 01950 Direct line: 978-961-3147 Fax 978-465-8505 achiarami~~is :11ewbury1,,1o~ws.com

- Forwarded b~ Angeljean Chiaramida/ET1 on 06/18/2016 01:61 PM -

Frorn: Sandra Gavutis <sandra@P::10 o(SI>

To: 'AChlaram!da@oewbuNDOrtnews o0m* <ACb1a111mlda@newbuiyportnews.com>

Dale: 06/16/2016 12:23 PM

Subject:

Press Release Sent by* ._!

'b-)(_6)_ _ ___,

Hello Angeljean, Attached is a press release from C-10.

Hopefully you will be covering the NRC meeting re: NextEra's discussion of ASR on Tues.,

June 21.

Sandra Scanned by Trustwave SEG - Trustwave's comprehensive email content security solution. Download a free evaluation of Tru&tw*ave SEG atwww.tr11.rw:wP.cc,rn

From: Bower, Fred Sent: Thursday, June 16, 2016 2:42 PM To: Sheehan, Neil Cc: Bari<ley, Richard; Poole, Justin; Wittick, Brian; Buford, Angela; Cook, William; Lorson, Raymond; Gray, Mel; Cataldo, Paul; Broaddus, Doug; Screnci, Diane; Vazquez, Justin; Lamb, John

Subject:

RE: Fw; Press Release from C-10 Attachments: C*10 Press Release for NRC 6-6-2016 2.206 Meeting_FLB_Reaction.doc>< Note: The one-page draft attachment is withheld in its entirety under FOIA exemption 5 .

Neil, I would like to consult with Bill and Mel, but I believe that one statement from the PR is factually Inaccurate: "Unknown to date is the extent and rate of Alkali Silica Reaction (ASR) damage which the NRC bas confirmed is progressing at .a faster rate than expected. "

Beyond that, I would have worded things differently, but I do not see the point In quibbling.

Have we sent Angel our meeting notice, press release and informed her that we have updated our Seabrook webpage?

My reactions are attached.

Cc'ing AAM attendees for into.

Fred from: Sheehan, Nell Sel\t: Thursday, June 16, 20161:57 PM To: Bower, Fred <fred.Bower@nrc.goV>

Subject:

FW: Fw: Press Release from C-10 Your thoughts?

From: AChiaram ida ~ new bu ryportnews.com Sent: Thursday, June 16, 20161:S6 PM To: Sheehan, Nell <Neil.Sheehan ~ nrc.p.OV>

Subject:

[External_Sender) Fw: Press Release from C-10 Hi Neil, Want to take a look at this and send me a comment, please?

Thanks, Aj Angeljean Chiaramlda Staff Writer Daily News of Newburyport 23 Liberty Street

Newburyport, MA. 01950 Direct line: 978-961-3147 Fax 978-465-8505 ac hiaramida~ newburvoortnews.com

- Forwarded by Angeljean Chiar~untda/ET1 on 06/16/2016 01:51 PM -

From: Sandra Gavu115 <sandra@stJO.org>

To: "AChla,amidai@newburynortQe_y.'.A,!lQ!Jl" <AChtaramlda!<flnewburypprtnew11,i;mn>,

Dale; 06118(2016 12:23 PM Subject. Preff Relea&e Sern by I ,b\(61 Hello Angeljean, Attached is a press release from C-10.

Hopefully you will be covering the NRC meeting re: NextEra's discussion of ASR on Tues., June 21.

Sandra Sc.anned by Trustwave SEG - Trustwave's comprehensive email content security solution. Download a free evaluation of Trustwave SEG at )NWW.trustwave.com 2

From: McNamara, Nancy Sent: Monday, January 12, 2015 3:31 PM To: Becker, Diane (Diane.Becker@dos.nh.gov); 'Giarrusso, John (CDA)'

Cc: Tifft, Doug

Subject:

Federal Register notice on concrete degradation petition Attachments: Sea brookASRPetitio n.1- 12-2015.pdf r:-N,-

ot-e--:

r=h-e-:-N-=-o..,.,

tic_e_a_p_p_

ea-r-s --, 4=7s=-----,

at-=s=o-=F=R--:1:-:-

(Ja nuary 12, 2015).

FYI. Attached is a Federal Register Notice that was published today. It seeks public comment on a C-10 petition for rulemaking re: concrete degradation at Seabrook (and at other plants). We had no heads up on this other than our public affairs seeing it today.

1

From: Trapp, James Sent: Thursday, June 25, 2015 12:56 PM To: Lorson, Raymond

Subject:

FW: POTENTIAL ALLEGATIONS: PRM 50-109 Attachments: Seabrook ASR Petition for Rulemaking POTENTIAL_ALLEGATIONS.docx Note: The 3-page annotated petition that is attached is withheld in its entirety under Petition for rulemaking from C10 regarding ASR at Seabrook. FYI FOIA exemption 5.

From: Gray, Mel Sent: Thursday, June 25, 2015 8:40 AM To: Cook, William Cc: 1rapp, James

Subject:

FW: POTENTIAL ALLEGATIONIS: PRM 50-109

Bill, Can we discuss on these statements this morning and get back to allegations office group?

We should consider whether the statements regarding licensee performance meet the definition of an allegation, and in addition, whether the statements regarding NRC oversight warrant referral to the R1 regional counsel for consideration to forwarding to IG.

ln my preliminary review the source document is a NextEra response to DLR regarding license renewal related RAI from 12/201 O.

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."

Context is SB discussion of results of their IWL examination in 2010.

"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 detennine the extent of condition or obtain the data necessary to monitor the rate of progression." (2.802 or allegation?]

This statement is focused on NRC, and is not an allegation or 2.206 enforcement action request.

"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 ofbuildings 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?)

I do not know what a "composite" team is, perhaps referring to "containment" team? Anyway statement is similar to first, but alleges, prior to IWL exams for containment in 2009, staff were not trained .

1

From: Warnek, Nicole Sent: Thursday, June 25, 2015 6:04 AM To: Gray, Mel Cc: RlALLEGATION RESOURCE; Meighan, Sean

Subject:

FW: POTENTIAL ALLEGATIONS: PRM 50-109 Mel - Can you review the below email and let me know your take on the three statements/issues that HQ has highlighted? Do we already know the validity of these issues, or are they allegations? Feel free to stop by to discuss.

Thank you!

Nicole Warnek Region I Allegation & Enforcement Specialist 610-337 -6954 (office)

! (bHb) j (cell)

From: R1AllEGATION RESOURCE Sent: Wednesday, June 24, 2015 3:41 PM To: Urban, Richard; Johnson, Sharon; McLaughlin, Marjorie; Bickett, Brice; Crisden, Cherie; Wamek, Nicole

Subject:

FW: POTENTIAL ALLEGATIONS: PRM 50~109 From: Meighan, Sean Sent: Wednesday, June 24, 2015 3:41 :06 PM To: R1ALLEGATION RESOURCE; Bickett, Brice; Urban, Richard Cc: Willis, Dorl

Subject:

FW: POTENTIAL ALLEGATIONS: PRM 50-109 Auto forwarded by a Rule lli AU:

Can you guys look at the below and Jet me know if you have any histor y (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, 2

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! have included Sheldon Stuchell who's branch manages such petitions.

I have attached the petiti1on 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 contain.nlent to confinn ASR suspicions or required any certified lab testing of key material properties to detennine 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?J 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 3

From: Lorson, Raymond Sent: Monday, March 05, 2018 1:39 PM To: Lehman, Bryce

Subject:

RE: Questions on PRM 50-109 Bryce - I defer to the wisdom of the rulemaking group; thanks for checking - what got my attention was some inconsistency in the document so you may want to do a search and confirm that the right capitalization is in there.

Thanks Ray From: Lehman, Bryce Sent: Monday, March OS, 2018 1:24 PM To: Lorson, Raymond <Raymond.lorson@nrc.gov>

Subject:

RE: Questions on PRM 50-109

Ray, I was making the changes to the FRN regarding capitalizing "Part 50" and realized that this had been through concurrence in the rulemaking branch and should have been caught already. I double checked with a rulemaking PM (see attached) and he informed me that in an FRN the words should be lowercase b/c it is the OFR style. In the SECY the words should be capitalized. I will apply the guidance that way to the SECY and the FRN and move it forward like that (i.e. lowercase in the FRN and capitalized in the SECY). Please let me know if you have an issue with that approach.
Thanks, Bryce From: Lorson, Raymond Sent: Thursday, March 01, 2018 9:22 AM To: Lehman, Bryce <Bryce.Lehman@nrc.gov>

Subject:

Re: Questions on PRM 50-109 Bryce - pis stop by with a hard copy on Monday - I would like to discuss briefly. I (b)(5}

I thanks ray From: Lehman, Bryce Sent: Wednesday, February 28, 2018 11:16:30 AM 1

To: Lorson, Raymond

Subject:

RE: Questions on PRM 50-109

Ray, The resolution of your comments is in the attached files (pg. 2 in SECY paper, pgs. 8, 16, and 18/19 in FRN).

Once you are OK with the changes I will have Meena incorporate them into official version.

Please let me know if you prefer a hardcopy or if you need anything else from me to concur.

Thanks, Bryce From: Lorson, Raymond Sent: Monday, February 26, 2018 5:15 PM To: Lehman, Bryce <Bryce.Lehman @nrc.gov>

Subject:

RE: Questions on PRM 50-109 Bryce - no problem - we have the eng stand-up from 8-8:30 - perhaps you could stop by at 8:30?

Ray From: Lehman, Bryce Sent: Monday, February 26, 2018 4:14 PM To: Lorson, Raymond <Raymond.Lorson@nrc.gov>

Subject:

Questions on PRM 50-109

Ray, I got your message about PRM 50-109. Unfortunately, I was in training all day and I have to leave the office now to pick up my kids from school. I spoke with your secretary and she suggested giving you a call around 8 AM tomorrow. I will plan on calling you then. Please let me know if there is a better time for me to reach you (I do have training again tomorrow but am free most of Wednesday).

If you have time to summarize your questions via email I can try to respond to them tonight; otherwise, I will call you tomorrow morning.

Thanks.

Bryce Lehman NRR/DE/ESEB (301) 415-1626 2

From: Inverso, Tara Sent: Thursday, October 02, 2014 12:33 PM To: Bladey, Cindy Cc: Colaccino, Joseph; Mizuno, Geary; Kratchman, Jessica; Mohseni, Aby

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation Attachments: KRATCHMAN 09 2014 SUFFICIENY REVIEW ASR concrete PRM rev1 .docx Good afternoon, Cindy, PRMB concludes that C-1 O's petition is sufficient for docketing. Please see attached for the very thorough rationale that Jessica Kratchman provided.

Thank you ,

Tara From: Bladey, Cindy Sent: Monday, September 29, 2014 11:45 AM To: Jones, Bradley; Safford, carrie; OGCMailCenter Resource; Inverso, Tara Cc: Barczy, Theresa; Love-Blair, Angella; Terry, Leslie; Shepherd, Jill; Mizuno, Geary; Colaccino, Joseph

Subject:

ACTION: Sufficiency Determirnation for Petition for Rulemaking submitted by C-10 Foundation NRR and OGC:

I am requesting your view on whether the attached PRM from Sandra Gavutis, Executive Director of the C-10 Foundation, is sufficient for docketing under 10 CFR 2.802. Please respond by COB Monday, October 6.

Thanks, Cindy Cindy Bladey, Chief Rules, Announcements, and Directives Branch 3WFN 06-802 301-287-0949 cindy.bladey@nrc.gov From: RulemakingComments Resource Sent: Friday, September 26, 2014 8:22 AM To: RidsEdoMailCenter Resource Cc: Bladey, Cindy; Giitter, Rebecca; Julian, Emile; Newell, Brian; RulemakingComments Resource; Sola, Clara; Vietti-Cook, Annette

Subject:

EDO ACTION ITEM: FW: C-10 Foundation's 2.802 Petition for Rulemaking to the NRC Attached is a petition for rulemaking submitted by Sandra Gavutis on behalf of the C-10 Foundation regarding revision to applicable regulations to:

1) Require that all licensees comply with ACI 349.3R
2) Require that all licensees comply with ASTM C 856-1 1, Standard Practice for Petrographic Examination of 1

From : Lehman Bryce To: Mizuno Geary; Fuhrmann Mark; Kratchman Jessica Cc: Inverso Tara; Love-Blair Angella; Neuhausen Alissa; Philip Jacob; Thomas George Subject : RE: PRM 50-109 PRB comments Date: Thursday, January 14, 2016 3:17:20 PM Attachments: PRM-50-109 PBB slides 1-13-1 5,ootx All.

Thanks for vour feedback.J b)(5)

Jessica, I will defer to you on George's comment on slide 3.

Thanks, Bryce From: Mizuno, Geary Sent: Tuesday, January 12, 2016 3:01 PM To: Fuhrmann, Mark <Ma1-k.Fuhrma11n@nrc.gov>; Lehman, Bryce <Bryce. Lehma n@nrc.gov::>,

Kratchman, Jessica <Jessica.Kratchman@ nrc.gov>

Cc: Inverso, Tara <Tara.l nverso@nrc.gov>; Love-Blair, Angella <Angella.Love-Blair@nrc.gov>;

Neuhause n, Alissa <Alissa.Neuhausen@nrc.gov>; Philip, Jacob <Jacob.Philip@nrc.gov>; Thomas, George <George.Thomas2@ nrc.gov>

Subject:

RE : PRM 50-109 PRB comments

,b)(5)

Geary From: Fuhrmann, Mark Sent: Tuesday, January 12, 2016 2:38 PM To: Lehman, Bryce <Bryce Lehman@nrc.gov>; Kratchman, Jessica <Jessjca Kratchman@nrc gov>

Cc: Inverso, Tara <Tara .lnverso@nrc.gov>; Love-Blair, Angella <Angella .Love-Blair@nrc.gov>;

Mizuno, Geary <Geary.Mizuno@nrc.gov>; Neuhausen, Alissa <Al issa.Neuhausen@n rc gov>; Philip, Jacob <Jacob.Philip@nrc.gov>; Thomas, George <George.Thomas2@nrc.gov>

Subject:

RE: PRM 50-109 PRB comments HI AII; This is a good presentation .. **, w..!u.1.¥...¥l.li~.....i....u.a~.i.L.1.U-li:L.J.liu;L.¥.l,l,I.J.W,.LliiiJ.Ju.a.i....u..i.J.Ll.lJ..u.i..L.w..JJ..l.:lii;iii.LIJ....i..- - .

into the slides, see attached.

(b)(S)

Mark Mark Fuhrma nn, Ph.D.

Geochemist Office of Nuclear Regulatory Research U.S. Nuclea r Regulatory Commission Mail Stop TWF 10 A-12 11555 Rockville Pike Rockville, MD 20852-2738 mark.fuhrmaoo@nrc.gov Phone:301-415-0879 From: Lehman, Bryce Sent: Tuesday, January 12, 2016 7:58 AM To: Kratchma n, Jessica <Jessjca.Kratchman@nrc.gov>

Cc: Fuhrmann, Mark <Mark.Fuhrmanin@nrc gov>; Inverso, Tara <Tara loverso@nrc gov>; Love-Bla ir, Angella <Angella.Love-Blair@nrc.gov>; Mizuno, Geary <Geary.Mjzuno@nrc.gov>; Neuhausen, Al issa

<Alissa.Neuhausen@nrq~ov>; Philip, Jacob <Jacob.Philip@nrc.iNY>; Thomas, George

<George.Thomas2@nrc.gov>

Subject:

RE: PRM 50-109 PRB Present ation: attached All, Attached are my proposed slides. Please review and provide feedback.

Jessica,

I will be out of the office on 2/1 and will be unable to attend the dry run. I will be in the office the previous week and back in the office Thursday if you can reschedule. Otherwise I will try to support the meeting remotely.

Thanks, Bryce From: Kratchman, Jessica Sent: Monday, January 11, 2016 1:18 PM To: Lehman, Bryce <Bryce.Lehman@nrc.gov>

Cc: Fuhrmann, Mark <Mark.Fuhrmaoo@nrc.gov>; Inverso, Tara <Jara.lnverso@nrc.gov>; Love-Blair, Angella <Ange lla.Love-Blair@nrc.gov>; Mizu no, Geary <Geary.Mjzuno@nrc gov>; Neuhausen, Alissa

<Alissa Neuhauseo@nrc gov>; Philip, Jacob <Jacob Philjp@nrc gov>; Thomas, George

<George.Thomas2@nrc.gov>

Subject:

RE : PRM 50-109 PRB Presentation: attached Working Group- I will be out of the office between 1/13 and 1/15. Please note your action items below (I have also corrected one date to reflect t he holiday on 1/18). Please cont inue to keep your management in the loop and ensure they (or someone they designate) can attend t he Pet ition Review Board (schedu led for 2/11/2016) .

Bryce- per lh e message below pleas!: get rne a dra fl of your slides by 01/19. Thanks so much.

-Jessie From: Kratchman, Jessica Sent: Monday, January 04, 2016 4:19 PM To: Lehman, Bryce <Bryce.Lehman@nrc.gov>

Cc: Fuhrmann, Mark ; Inverso, Tara <Jara loverso@nrc gov>; Love-Blair, Angella <Angella Love-Blair@nrc.gov>; Mizuno, Geary <Geary Mjzuno@nrc.gov>; Neuhausen, Al issa

<Alissa Neuhausen@nrc gov>; Philip, Jacob <Jacob Philip@nrc gov>; Thomas, George

<George Jhomas2@nrc gov>

Subject:

PR M 50-109 PRB Presentation: attached

Bryce, Please find attached the PRB presentation I have developed for the PRM 50-109 upcoming PRB, which takes place on 02/11/2016. You will find blank or partially blank slides that I have left for you to fill in with technical content. Please provide the group a draft by 01/18/2016 so we have time to review and comment. Also note, I have put your name in the notes sections of slides that I believe you should present to the PRB and my name in those slides that pertain to me. Feel free to update you slides if you feel another working group member should present that content.

Also, feel free to add slides in if you need more room or feel another topic should be addressed, but try to avoid making the presentation too lerngthy.

ACTIONS:

O1/194-8/2016: Bryce to provide technical content for presentation and send to the group for review 01/25/2016: Working Group provide any comments on the presentation to Jessie 02/01 /2016: Final Working Group Meeting to run throug h presentation (to be sent out) 02/11 /2016: PRB convenes Thanks everyone .

-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regu latory Comm issio n 301-415-5112

Petition for Rulemaking PRM-50-109 Petition Review Board Meeting February 11, 20150WFN-12802 10:00 am - 11 :00 am Bridge Line: 888-390-1523 Passcode:!(6)(6) !#

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  • Jessica Kratchman- Project Manager, NRR/DPRBryce Lehman- Technical Lead, NRR/DEGeorge Thomas- NRR/DLRAlissa Neuhausen- NRO/DEIAMark Fuhrmann- RES/

DRAJacob Philip-RES/ DRAGeary Mizuno-OGC/GCLRAngella Love-Blair- ADM/DAS 2

  • Pa i poss. Ob tail I Pelitio11Rsvisvv Boa, d (PRB) direction on the working group (WG) recommended resolution of PRM 109.0utcome: PRB understands issues 115 1 raised by the petitioner and !"_ _ _ _ _ __

1 11'...._

~_) ___________ ___.I.Process:

Discuss PRM-50-109 and WG recommendations Rulemaking.

3

Agenda Pe ti Li O11 E) d CkgI Od 11 dSd 11 11 11 d I y Of Pe Li Li O11 e11S RequestsNRC's Interpretation of PRM Argumentlssues for Evaluation by the NRCStaff Technical EvaluationWorking Group RecommendationNext Steps 4

Petition Background September January 12, To 25~2014 2015 Present Notice of docketing review Ms. Sandra Gavutis, C-10 with opportunity for Foundation, submits WG analyzing petiti.o comment published in the petition offer a recommendann11:aa, Federal Register (ADAMS Accession No. ML14281A124)

(80 FR 1476) 5

Summary of Petitioner's Requests

  • Amend regulations to improve identification techniques against alkali silica reaction (ASR) concrete degradation Stating that visual inspection does not "adequately identify Alkali-Silica Reaction (ASR), does not confirm ASR, or provide the current state of ASR damage (if present) without petrographic analysis under current existing code." Requested the NRC amend its regulations to require compliance with:1) American Concrete Institute (ACI) Standard 349.3R, "Evaluation of Existing Nuclear Safety-Related Concrete Structures"2) American Society for Testing & Materials (ASTM)

C856-11, Standard Practice for Petrographic Examination of Hardened Concrete."

6

NRC's Interpretation of PRM Argument

  • Tl ,e 0001ki119 91oap I eo ieooed ti 1e pe~itio11 a11d ide11 tified three issues for evaluation by the NRC:lssue #1: Visual inspections are not adequate to detect and confirm ASRlssue #2: Standards exist that more properly address the detection and evaluation of ASRlssue #3:

Regulations should require compliance with the standards 7

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i Staff Technical Evaluation

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        • Issue 1 Issue #1: Visual Inspections Cannot Detect/ Confirm ASRPetition Points:NRC has stated that ASR can only be confirmed through petrographic examinationVisual indications of cracking may be suppressed by heavy reinforcementVisual inspections cannot identify de radation in inaccessible W rkin Evaluation:

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" .... ~ Issue 2 Issue #2: Codes and Standards Exist to Detect / Evaluate ASR DamagePetition Points:ACI 349.3R provides a means for managing ASR degradation and includes quantitative acceptance criteriaACI 349.3R is endorsed by the NRC in IN 2011-20ASTM C856-11 describes an acceptable means of conductin etro ra hie examinationWorkin Group Evaluation:

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" .... ~ Issue 3 Issue #3: Regulations Should Require ACI 349.3R and ASTM C856-11 Petition Points:NRC endorses both standards but does not require their useSeabrook degradation would have been identified earlier if the N RC reauired complianceWorking Group Evaluation:\

(ti)(5) 10

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..... Summary of Public Comments

  • NRC Received 10 Comments:Five comments in support of the rulemakingTwo comments outside the scope of the rulemakingThree comments saying rulemaking was unnecessaryComments Supporting Rulemaking:Two commenters stated that visual inspection is inadequate with no additional basisThree commenters stated that existing inspection techniques will not adequately detect ASR and the osed solutions are a ro riateStaff Res onse -

(h)(5) 11

Staff Technical Evaluation Summary of Public Comments

  • Comments Against Rulemaking:Two commenters noted that industry is already taking appropriate action to address ASR and that existing regulations properly address degraded concreteSeabrook noted that the referenced documents have been used during the ASR investigation and they also question the validity of claims made in the petitionSeabrook specific issues are outside of the scope of the petition; however, the comments were addressed in the denial documentStaff Resoonse -I (11)(5) 12

(b)(S)

. . . _ _ _ _ _ _ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ _ _ _ _ _ _ _ _ _ _ ,13

Next Steps

  • PRB decision will be documented by the project manager in a non-public meeting summary within 30 days.Finalize SECY paper and draft FRN within 4.5 months and provide to the Commission.Commission vote is needed to lUJ(~) I (b)( 5 )

14

Questions?

15

Backup Slides 16

From: PblllP Jacob To: Kratchman Jessica

Subject:

RE: MEETING SUMMARV: PAM 50-109 Date: Friday, May 29, 2015 2:20:00 PM Gr8 reply !!

.**.*QJ"iginul Message--***

From: Kratchman, Jcssicn Sent: F(iday. May 29. 20t5 12:04 PM To: Mizuno. Geary: Fuhrmann. Mark: Inverso. Tara: Lehman. Bryce: Love-Blair. Angella: Neuhausen. Alissa: Philip. Jacot,:

Thomas. Goorgc

Subject:

RE: MEETING

SUMMARY

PRM 50- 109 Geary, Thanks.

Jessie From: Mizuno. Geary Sent: Friday. May 29, 20 15 lJ :.1 9 AM To: Kratchman, Jessica: Fuhrmann. Mark; Inverso, Tara: Lehman. Bryce; Love-Blatr. Angella: Neuhausen, Alissa: Phibp. Jacob:

Thomas. George Subjecl: RE: MEETING

SUMMARY

PRM 50- !09 I'""'

Geary From: Kratchman. Jessica Sent: Priday. May 29, 20 1S 9: 17 AM To: Mizuno, Geary: Fuhrmann. Mark: Inverso, Tara; Lehnmn. Bryce; Love-Blair, Angella: Neulrnusen, Alissa: Philip. Jacob:

Thomas. George Subjecl'. RE: MEETING

SUMMARY

PRM 50- 109 George/ .lake/ Mark- Have I chL1racten 1.ed that correctly'!

From: Mizuno, Geary Senl : Thursday. May 28. 2015 5:06 PM To: Kratchman, Jessica: Fuhrmann. Mark: In verso, Tara; Lehnmn. Bryce: Lov~-Blair, Angella: Neuhausen. Al issa: Philip, Jacob:

Tho 1rn1s. George Subject.: RE: MEETING

SUMMARY

PRM 50- 109 Colleagues:

(h}(5l l

l am sorry I was unable to attem.l this meeting.'-- - - - - - - - - - - - - - - - - - - - - - - - - - - '

(b)(5)

Geary From: Kratchman. Jessica Sen1: Thursday, May 28. 2015 4:35 PM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair. AngeLla; Mizuno, Geary; Neuhausen, Alissa; Phmp racob; Thomas. George

Subject:

MEETING

SUMMARY

PRM 50- 109 LINKS: Link 10 SharcPoint Sitc<htt~r //fusjon nrc ~oy/nrr/team/dpr/prmh/rulemakioitPRM-50-109/SjtcPa~cs/Home aspx> Link 10 s1aff position paper.<bup*llfusjon nrc i:ov/nrr/te~m/dpr/prmb/ru!emakina/PRM-50-109/Workjng%20Qocumcnt.5/PR M%,20SO-IQ9%?0Draft%20Siaff%,20Posit jon%20Recommendioi:04(bl(5J ~Oof%20Perjrjon%?QCRey% ?QI l o/o?QWG%20commenls docx>

MEETING

SUMMARY

Thanks to everyone for participated in today's meeting am:l to those of you who provided input prior to the meeting.

DISCUSSION: We spent teday's meeting discussing George's inpul for Issues 1-3. We also discussed ac1ion i1ems and 1he schedule moving forward.

  • General discussion: Conform Ian *ua *e 1hroughout: l(b)/S)

( (::>) ---------------------

(b)(">)

Issue 3: RES Lo add inpu1 ACTIONS:

RES: Issue 3: provide 111ri1e up for June 9 mee1ing. Get to PM by COB J une 5.

George:

o Update inpul per today's meeting, refer IO comments/ edi1s tracked during rrwe1ing. Link 10 staff position paper.

<blip*//fw; jon.ore 11ov/nrr/team/dpr/prn1b/ruJemakin11tPRM-SO-J09/Work iu11%20Pocuments/PRM%20S0-109%20Dran%20S1aff%20Posj[ion%20Recommendio1:"/i (b )\S\ joof%20Petition%20<Rev%20 I} %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 I, 2, 3 Thomas May 28, 2015 WG meeting Comments I, 2, 3 Kratchman June 9. 20 15 Email Comment 4 (9) + Issue 3 (RES input)

Thomas/

RES June 9, 20 15 WG meeting Comment 5, 6 Lehman June 23, 201 5 Email Comment 7 ( I 0)

Thomas June 23, 2015 WG meeting Comment 8 Thomas July 7, 20 15 WG meeting

Thanks again!

-Jessie Jessica Kratchman , candidate DrPH Division of Policy and Rulemakin g Office of Nuclear Reactor Regulations U.S. uclear Regu latory Commission 301-4 15-511 2

From: Philip Jacob To : Jessica Kratchman r l(6) h Subject : FW: asr .  ! Note The 6-page draft attachment is withheld in its Date: Monday, June 08, 2015 2:51 :00 PM Attachments: MFl ssue 1 and 2 revised JP 6~ -15.docx entirely under FOIA exemption 5.

Here are Mark's and my revisions to Issue 1 and 2. You can circulate to others as appropriate and we can discuss it tomorrow.

Mark and I will send you our revision this afternoon .

jake From: Fuhrmann, Mark Sent: Monday, June 08, 2015 2:42 PM To: Philip , Jacob

Subject:

asr Mark Fuhrmann, Ph .D.

Geochem ist Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Mail Stop CSB 2C-07m 11555 Rockville Pike Rockville, MD 20852 -2738 mark.fuhrmann@nrc.oY Phone : 301 -251-7472 Fax: 301-251-7410

From: PbiliP Jacob J(b)(a) l To: Jessica Kratchman 1 f Subject : FW: Issue 3 ' - - - - - --;:::~ --=c------,,-------,-----,------,------,----,

Date: Monday, June 08, 2015 3:32:00 PM Note: The 5-page draft attachment is Attachments: MFlssue 3.doc)( withheld in its entirety under FOIA exemption 5.

Here is Mark's and my revisions to Issue 3.

(b)(5)

.__ ___________________________, We can discuss that tomorrow.

Jake From : Fuhrmann, Mark Sent: Monday, June 08, 2015 3:10 PM To: Philip, Jacob Subject : RE: Issue 3 Mark Fuhrmann, Ph.D.

Geochemist Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission M ail Stop CSB 2C-07m 11555 Rockville Pike Rockville, MD 20852-2738 mark.fuhrmaoo@orc.gov Phone: 301-251-7472 Fax: 301-251-7410 From: Philip, Jacob Sent: Monday, June 08, 2015 2:45 PM To: Fuh rmann, M ark

Subject:

Issue 3 Jacob Phi lip Civi l/Geotechnica l Engin eer

From: Kratchman Jess;ca To: Philip Jacob; Fu hrmann Mark Subject : FW: SUFFICIENCY DETERMINATION: C-10 PAM for concrete degradation Dat e: Monday, October 27, 2014 2:32:16 PM Attachments: KRATCHMAN 09 2014 SUFFICIENY REVIEW ASR concrete PRM rv1.docx FYI- attached is my sufficiency determination for PRM 50-109 (ASR concrete degradation).

As I mentioned on the phone, I am awaiting on ADM IN to complete their posting of the FRN for the Notice for Rulemaking. Atter I receive word back from them I will put a working group together.

Thanks for your input! And I will keep you posted.

-Jessie From: Kratchman, Jessica Sent: Thu rsday, October 02, 201 4 10:52 AM To: Inverso, Tara Cc: Beall, Robert Subject : .SUFFICIENCY DETERM INATION : C-10 PRM for concret e degradation Ta ra, I have completed a sufficiency review of C-lO's PR M dated 09/25/2014 and det ermined that the PRM meet s the sufficiency crit eria for docketing u nder 10 CFR 2.802. Attached is a sum mary of my det erminat ion. Please let me know if you have any furt her questions or requi re my assist ance in any way.

Thanks.

-Jessie Jessica Kratchman, candidate DrPH Division of Policy and Rulema king Office of Nuclear Reactor Regulations U.S. Nuclea r Regulatory Commission 301-415-5112

SUFFICIENCY REVIEW: Seabrook ASR concrete degradat ion PRM submitted pursuant to 10 CFR 2.802 on 09/25/2014 PETITIONER: The C-10 Research and Education Foundation (C-10); assistance from Union of Concerned Scientists NRC REVIEWERS: Jessica Kratchman, PM, NRR/ DPR; technical support from Timothy Lupold, Branch Chief, NRR/ DE STATUS: PRM meets the sufficiency criteria for docketing under 10 CFR 2.802. The below table summarizes the review.

10CFR 2.802(c): PRM Criteria (1) Set forth a general solution to the problem or The petitioner requests that the U.S. Nuclear Regulatory Commission (NRC) amend its regulations to provide the substance or text of any proposed better protection against concrete degradation at U.S. nuclear power plants. C-10 suggests that the reliance regulation or amendment, or specify the on a visual inspection does not " adequately identify Alkali-Silica Reaction (ASR), does not confirm ASR, or regulation which is to be revoked or amended; provide the current state of ASR damage (if present) without petrographic analysis under current existing code".

The general solution proposed by the petitioner is to revise applicable regulations to:

1. Require all licensees comply with ACI Standard 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures.
2. Require all licensees comply with ASTM C 856-11, Standard Practice for Petrographic Examination of Hardened Concrete.

(2) State clearly and concisely the petitioner's C-10 addresses healt h and safety issues related to the Seabrook Station. C-10 evolved from Citizens Within grounds for and interest in the action the Ten-Mile Radius, a 5,000 member organization founded in 1986 to challenge evacuation plans for the requested; Seabrook Station. C-10 has been engaging the NRC about concrete degradation at Seabrook since 12/22/2011.

(3) Include a statement in support of the petition NRC public meeting at Seabrook Station on 06/24/2014, C-10 asked if the NRC was investigating the US which shall set forth the specific issues involved, nuclear fleet for ASR concrete degradation. The NRC staff responded that ASR concrete degradation could be the petitioner's views or arguments with adequately indicated through visual examination.

respect to those issues, relevant technical, However, NRC position paper, In situ Monitoring of ASR-affected Concrete, November 2012, states "ASR can scientific or other data involved which is exist in concrete without indications of pattern cracking," and that for" ... structures exposed to ASR, internal reasonably available to the petitioner, and such damage occurs through the depth of the section but visible cracking is suppressed by heavy reinforcement ..."

other pertinent information as the pet;tioner deems necessary to support the action sought. When Next Era determined 131 locations with "assumed" ASR visual signs within multiple power- block In support of its petition, petitioner should note structures at Seabrook Station during 2012, further engineering evaluations were not required by NRC.

any specific cases of which petitioner is aware Codes and standards exist t hat are capable of detecting ASR and determining t he key material properties where the current rule is unduly burdensome, needed to evaluate the degree and severity of ASR damage. ACI Standard 349.3R02, for instance, has been deficient, or needs to be strengthened.

endorsed by the NRC (ADAMS ML112241029) as an acceptable method of protecting against excessive ASR concrete degradation but is not a requirement.

10/02/2014 J. Kratchman, NRR/ DPR/ PRMB

January 7, 2013 (DRAFT)

Memorandum To: ASR Working Group From: William A. Cook, ASR Team Lead, Region I Through: Richard Conte, ASR Project Manager, Region I

Subject:

Position Paper: "ASR Working Group Recommendation to Address the Adequacy of NextEra's Seabrook Station Structures Monitoring Program (SMP)."

IT>,;

Copy to:

James Trapp, William Raymond , Suresh Chaudary, Angela Buford, George Thomas

Position Paper: " Adequacy of NextEra's Revi1sion (2) to the Seabrook Structures Monitoring Program (SMIP) to Address ASR", Revision 1

.b)(fJI

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(b\15)

Hi Bill

  • Hardened Concrete.

ACTION OFFICE: ACTION: APPROPRIATE SECY did confirm receipt of the petition, as requested in the email.

Thank you.

Herald Herald M. Speiser Rulemakings ond AdJudico[1ons Staff Office of the Secretary Nuclear Regulatory Commission (301) 415-1675

~*#*****~*****-~**¥*~***-~'*3~~

2

SUFFICIENCY REVIEW: Seabrook ASR concrete degradation PRM submitted pursuant to 10 CFR 2.802 on 09/25/2014 PETITIONER: The C-10 Research and Education Foundation (C-10); assistance from Union of Concerned Scientists NRC REVIEWERS: Jessica Kratchman, PM, NRR/ DPR; technical support from Timothy Lupold, Branch Chief, NRR/ DE STATUS: PRM meets the sufficiency criteria for docketing under 10 CFR 2.802. The below table summarizes the review.

10CFR 2.802(c): PRM Criteria (1) Set forth a general solution to the problem or The petitioner requests that the U.S. Nuclear Regulatory Commission (NRC) amend its regulations to provide the substance or text of any proposed better protection against concrete degradation at U.S. nuclear power plants. C-10 suggests that the reliance regulation or amendment, or specify the on a visual inspection does not "adequately identify Alkali-Silica Reaction (ASR), does not confirm ASR, or regulation which is to be revoked or amended; provide the current state of ASR damage (if present) without petrographic analysis under current existing code".

The general solution proposed by the petitioner is to revise applicable regulations to:

1. Require all licensees comply with ACI Standard 349.3R, Evaluation of Existing Nuclear Safety-Related Concrete Structures.
2. Require all licensees comply with ASTM C 856-11, Standard Practice for Petrographic Examination of Hardened Concrete.

(2) State clearly and concisely the petitioner's C-10 addresses health and safety issues related to the Seabrook Station. C-10 evolved from Citizens Within grounds for and interest in the action the Ten-Mile Radius, a 5,000 member organization founded in 1986 to challenge evacuation plans for the requested; Seabrook Station. C-10 has been engaging the NRC about concrete degradation at Seabrook since 12/22/2011.

(3) Include a statement in support of the petition NRC public meeting at Seabrook Station on 06/24/2014, C-10 asked if the NRC was investigating the US which shall set forth the specific issues involved, nuclear fleet for ASR concrete degradation. The NRC staff responded that ASR concrete degradation could be the petitioner's views or arguments with adequately indicated through visual examination.

respect to those issues, relevant technical, However, NRC position paper, In situ Monitoring of ASR-offected Concrete, November 2012, states "ASR can scientific or other data involved which is exist in concrete without indications of pattern cracking," and that for" ... structures exposed to ASR, internal reasonably available to the petitioner, and such damage occurs through the depth of the section but visible cracking is suppressed by heavy reinforcement ..."

other pertinent information as the petitioner deems necessary to support the action sought. When NextEra determined 131 locations with "assumed" ASR visual signs within multiple power-block In support of its petition, petitioner should note structures at Seabrook Station during 2012, further engineering evaluations were not required by NRC.

any specific cases of which petitioner is aware Codes and standards exist that are capable of detecting ASR and determining the key material properties where the current rule is unduly burdensome, needed to evaluate the degree and severity of ASR damage. ACI Standard 349.3R02, for instance, has been deficient, or needs to be strengthened.

endorsed by the NRC (ADAMS ML112241029) as an acceptable method of protecting against excessive ASR concrete de_g_radation but is not a requirement.

10/02/2014 J. Kratchman, NRR/ DPR/ PRMB

From: Bladey, Cindy Sent: Friday, October 03, 2014 10:47 AM To: Kratchman, Jessica; Mizuno, Geary; Inverso, Tara Cc: Colaccino, Joseph; Mohseni, Aby; Beall, Robert; Jones, Bradley; Biggins, James; Love-Blair, Angella; Terry, Leslie; Barczy, Theresa

Subject:

Cindy Bladey response on public commetn request Jessica, ADM will draft the NOR to include a comment request, but I suggest technical staff consider formulating a few questions to include in the notice. The intent is not to restrict the scope of the petition open for comment. Rather, staff (and the public) may find it useful if we include questions that direct public comment toward those particular areas where focused discussion and directed comment responses can assist staff to disposition the petition. If you agree with this approach, but need some time to develop questions, ADM will send you the notice for your input before we send for concurrence review. Thanks, Cindy From: Kratchman, Jessica Sent: Friday, October 03, 2014 8:42 AM To: Mizuno, Geary; Bladey, Cindy; Inverso, Tara Cc: Colaccino, Joseph; Mohseni, Aby; Beall, Robert; Jones, Bradley; Biggins, James

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation {OGC Ticket 2014-3965)

Importance: High Cindy.

Please let me know If that is an issue Thanks.

-Jessie From: Mizuno, Geary Sent: Thursday, October 02, 2014 3:05 PM To: Bladey, Cindy; Kratchman, Jessica; I nverso, Tara Cc: Colaccino, Joseph; Mohseni, Aby; Beall, Robert; Jones, Bradley; Biggins, James

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C- 10 Foundation (OGC Ticket 2014-3965)

Cindy (h)(5) 1

Geary From: Bladey, Cindy Sent: Thursday, October 02, 2014 1:25 PM To: Kratchman, Jessica; Mizuno, Geary; Inverso, Tara Cc: Colaccino, Joseph; Mohseni, Aby; Beall, Robert

Subject:

RE: ACTION : Sufficiency Determination for Petition for Rulemaklng submitted by C-10 Foundation Thanks Jessica. I included NRO on cc for information only at this point. RES is not a rulemaking office, and so normally does not participate in sufficiency determinations.

From: Kratchman, Jessica Sent: Thursday, October 02, 2014 1:23 PM To: Mizuno, Geary; Bladey, Cindy; Inverso, Tara Cc: Colaccino, Joseph; Mohseni, Aby; Beall, Robert

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation RES and NRO will weigh-in when we establish a working group. For now I consulted technical staff only to the extent necessary to aid in establishing enough understanding to make a cursory determination.

-Jessie From: Mizuno, Geary Sent: Thursday, October 02, 2014 1:18 PM To: Bladey, Cindyi Inverso, Tara Cc: Colaccino, Joseph; Kratchman, Jessica; Mohseni, Aby

Subject:

RE: ACTION : Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation Did we hear from NRO? Is RES also supposed to weigh in (or are they typically excluded?)

From: Bladey, Cindy Sent:' Thursday, October 02, 2014 1:15 PM To: Inverso, Tara Cc: Colaccino, Joseph; Mizuno, Geary; Kratchman, Jessica; Mohseni, Aby

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation Thanks , very nice assessment.

Geary and Tara, barring any objections, I plan to docket this PRM later today, and have my staff draft a notice of receipt that requests public comment on the petition. Please let me know if you have any objections or concerns with this approach, and/or any specific questions you would like to have included in the NOR.

Cindy From: Inverso, Tara Sent: Thursday, October 02, 2014 12:33 PM To: Bladey, Cindy Cc: Colaccino, Joseph; Mizuno, Geary; Kratchman, Jessica; Mohseni, Aby

Subject:

RE: ACTION: Sufficiency Determination for Petition for Rulermaking submitted by C-10 Foundation Good afternoon. Cindy, 2

PRMB concludes that C-10's petition is sufficient for docketing. Please see attached for the very thorough rationale that Jessica Kratchman provided.

Thank you, Tara From: Bladey, Cindy Sent: Monday, September 29, 2014 11 :45 AM To: Jones, Bradley; Safford, carrie; OGCMailCenter Resource; Inverso, Tara Cc: Barczy, Theresa; Love-Blair, Angella; Terry, Leslie; Shepherd, Jill; Mizuno, Geary; Colaccino, Joseph

Subject:

ACTION: Sufficiency Determination for Petition for Rulemaking submitted by C-10 Foundation NRR and OGC:

I am requesting your view on whether the attached PRM from Sandra Gavutis, Executive Director of the C-10 Foundation, is sufficient for docketing under 10 CFR 2.802. Please respond by COB Monday, October 6.

Thanks, Cindy Cindy Bladey, Chief Rules, Announcements, and Directives Branch 3WFN 06-802 301-287-0949 cindy.bladey@nrc.gov From: RulemakingComments Resource Sent: Friday, September 26, 2014 8:22 AM To: RidsEdoMailCenter Resource Cc: Bladey, Cindy; Giitter, Rebecca; Julian, Emile; Newell, Brian; RulemakingComments Resource; Sola, Clara; Vietti-Cook, Annette

Subject:

EDO ACTION ITEM: FW: C-10 Foundation's 2.802 Petition for Rulemaking to the NRC Attached is a petition for rulemaking submitted by Sandra Gavutis on behalf of the C-10 Foundation regarding revision to applicable regulations to:

1) Require that all licensees comply with ACI 349.3R
2) Require that all licensees comply with ASTM C 856-11, Standard Practice for Petrographic Examination of Hardened Concrete.

ACTION OFFICE: ACTION: APPROPRIATE SECY did confirm receipt of the petition, as requested in the email.

Thank you.

Herald 3

Herald M. Speiser Rulemakings and Adjudications Staff Office of the Secretary Nuclear Regulatory Commission

{301) 415-1675

                    • ~*************~******

4

From: Kratchman, Jessica Sent: Thursday, April 23, 2015 12:17 PM To: Mizuno, Geary Cc: Inverso, Tara; Spencer, Mary; Biggins, James

Subject:

RE: REMINDER: PRM 50-109 working group meetings- your comments Follow Up Flag: Follow up Flag Status: Flagged It's not a problem- you are not a lead on any comment, I mainly included you as support for particular issues.

Please j ust keep an eye on which comments you support and their associated meetings (or lack of meetings).

Thanks.

-Jessie From: Mizuno, Geary Sent: Thursday, April 23, 2015 12:11 PM To: Kratchman, Jessica Cc: Inverso, Tara; Spencer, Mary; Biggins, James

Subject:

RE: REMINDER: PRM 50-109 working group meetings- your comments Jesica:

I am not going to be able to provide my input, due to higher priorit y items. As I have told the staff, someone is going to be unhappy that I cannot do everything.

Geary From: Kratchman, Jessica Sent: Thursday, April 23, 2015 10:54 AM To: Fuhrmann, Mark; Inverso, Tara; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Al1issa; 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:

MEmNG

SUMMARY

PRM 50-109 (4-16-2015)

Working Group Meeting (WG): PRM 50-109: Comment/ issue resolution assignments 15

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 rulemak,i ng should take place but to determine if this issue should enter the rulemaking process. Please keep this in mind throughout your review.

DISCUSSION:

IIJ)(S)

ACTIONS; WG members should review their assigned comments/ i,ssues 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 Sit e.

Thanks to everyone for your participation and support I

-Jessie Jessica Kratchman, candidate DrPH 16

Division of Policy and Rulemaking Office of Nuclear Reactor Regulations U.S. Nt1clear Regulatory Commission 301-415-5112 17

From: Kratchman, Jessica Sent: Monday, October 05, 2015 11 :02 AM To: Mizuno, Geary Cc: Inverso, Tara; England, Christina; Spencer, Mary; Biggins, James

Subject:

RE: Re: Status of the C-10 Petition for Rulemaking Follow Up Flag: Follow up Flag Status: Flagged Thank you. I appreciate your quick response and I will make the recommended modifications.

-Jessie From: Mizuno, Geary Sent: Monday, October 05, 2015 10:39 AM To: Kratchman, Jessica Cc: Inverso, Tara; England, Christina; Spencer, Mary; Biggins, James

Subject:

RE: Re: Status of the C-10 Petition for Rulemaking (b)(51 Geary From: Kratchman, Jessica Sent: Monday, October 05, 2015 10:29 AM To: Mizuno, Geary <Geary.Mizuno@nrcgov>

Cc: Inverso, Tara <Tara.lnverso@nrc.gov>

Subject:

RE: Re: Status of the C-10 Petition for Rulemaking 1(0)(:::,)

0

-Jessie Jessica Kratchman, candidate DrPH Division of Policy a11d Rulemaking Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission 301-415-5112 From: McIntyre, David Sent: Monday1 Oct ober 05, 2015 8:46 AM To: Inverso, Tara Cc: Kratchman, Jessica; Mohseni, Aby Subject : RE: Re: Status of the C-10 Petition for Rulemaking Indeed , I was confusing them . So many processes, so little time ...

From: Inverso, Tara Sent: Monday, October 05, 2015 8:08 AM To: McIntyre, David Cc: Kratchman, Jessica; Mohseni, Aby

Subject:

RE: Re: Status of the C- 10 Petition for Rulemaking Hi David, I think you are thinking of the 2.206 petition process. For 2.802s, we have a petition review board, but the petitioner isn't involved nor are the results provided publicly.

Jessie - Please draft something up about how you are the PM, we're evaluating the requests, will provide a recommendation to the Commission, etc. Please also provide to me and Aby before you send back to OPA.

Thanks!

Tara From: McIntyre, David Sent: M onday, Oct ober 05, 2015 7:53 AM To: Inverso, Tara <Tara.lnverso@nrc.gov>

Subje ct: FW: Re: Status of the C-10 Pet it ion for Rulemaking Tara - I sense some frustration here. Anything more we can tell her? Didn't they have a PRB meeting, and wouldn't she know the contact from that? Or has it been so long that she's forgotten who it was?

Dave From: Debbie Grinnell [1]

Se nt: Sunday, October 04, 2015 10:21 AM 9

To: McIntyre, David

Subject:

[External_Sender) Re: Status of the C-10 Petition for Rulemaking

Dave, Out of curiosity, is anyone reading it and who is assigned by the NRC to the petition?

Thank you, Debbie Sent from my iPhone On Oct 3, 2015, at 10:34 PM, McIntyre, David <David.Mclntyre@nrc.gov> wrote:

I'm afraid there really isn't a timetable.

Regards, Dave On: 03 October 2015 12:13, "Debbie Grinnell" <grinnelldebbie2@gmail.com > wrote:

Hello David, Thank you for relying. Do you know approximately when you might know the current status of our Petition.

Thank you, Debbie C-10 Foundation Sent from my iPhone On Sep 29, 2015, at 4;58 PM, McIntyre, David <David.Mclntyre@nrc.gov> wrote:

Ms Grinnell-Staff is still reviewing your petition and preparing a recommendat1on for the Commission Regards, David M cfntyre Ofjtce of Public Affo,rs U.S. Nuclear Regulatory Commission 301-415-8200 From: Debbie Grinnell [maillo:debbie@c-10 org]

Se nt: Tuesday, September 29, 2015 1:36 PM To: OPA Resource <OPA.Resource@nrc.gov>

10

Subject:

[External_Sender] Status of the C-10 Petition for Rulemaking

Hello, I am with the C-10 Foundation and we submitted a Petition for Rulemaking in September 2014. What is the current status of the petition.

Thank you, Debbie Grinnell Research staff C-10 Foundation 11

Subject:

MATERIALS: PETITION REVIEW BOARD: PRM 50-109 Location: HQ-OWFN-12B02-12p Start: Thu 02/11/201610:00 AM End; Thu 02/11/2016 11:00 AM Show Time As: Tentative Recurrence: (none)

Meeting Status: Not yet responded Organizer: Kratchman, Jessica Required Attendees: Bladey, Cindy; DeJesus, Anthony; Ross-lee, MaryJane; Spencer, Mary; Mohseni, Aby; Correia, Richard; Miller, Chris; Tappert, John; Inverso, Tara; Fuhrmann, Mark; Lehman, Bryce; Love-Blair, Angella; Mizuno, Geary; Neuhausen, Alissa; Philip, Jacob: Marshall, Jane; Thomas, George Optional Attendees: Caldwell, Robert; Mayfield, Michael; DE_Calendar Resoufce; Doyle, Daniel; Wittick, Brian Note: These three attachments are the same as the attachments to J. Kratchman's 2/12/16 3:03 pm email.

Seabrook ASR seabrook ASR PRM-50-109 PRB Petition for Rule... petition for rule... FINAL slides 2-...

Link to ADAMS to review the final package: LINK to PRM 50-109 Package Meeting

Subject:

Petition (PRM) 50-109: Improved Identification Techniques against Alkali-Silica Reaction Concrete Degradation at Nuclear Power Plants Meeting

Purpose:

To obtain management approval for the Working Group's proposed closure of Petition (PRM) 50-109.

Role of the Petition Review Board (PRB): PRB is composed of division directors/ deputy division directors from each technical area affected by the petition and represented on the working group. The Chair pf the PRB will by the NRR/ DPR Deputy Division Director. The PRB may decide to:

1. Approve the recommended closure approach
2. Specify a different closure
3. Request additional information or further briefing.

PRB Materials: to be provided no later than 1 week before the PRB convenes. Please try and review materials in advance to expedite the meeting and resolution of comments.

If you have any questions please feel free to ask me or the working group member which represents your division.

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 Passcodes/Pin codes:

II Participant passcode!(IJH6 II For security reasons, the passcode will bo required to Joli, the conference.

Dial in numbers:

Freephone/

Country Toll Numbers Toll Free Number

!USA / 888-390-1523 2

From: Campbell. Jjspn To: Carneal, Jason Cc: Spencer. Mary; segarnjck Maxjne

Subject:

FW: ADM comments on PRM-50-109. Denial of Petition for Rulemaking Submitted by C-10 Date: Monday, October 24. 2016 2:01 :33 PM Attachments: EBN with ADM comments c10 PBM denlal.docx Note: A ll four draft attachments. totalling 49 Letter to petitioner with ADM comments docx pages, are withheld in their entirety under FOIA SECY c10 denial with ADM comments.docx exemption 5.

Congressional letters with ADM comments.docx Jason:

Molly is on a rotation right now and will be unable to review these documents. I've asked Maxine Segarnick (an ITLG in our division) to review these changes and Molly"s previous comments. I am going to have our mailroom create a ticket and we will get back to you in no more than IObusiness days.

Thanks, Tison Tison Campbell Deputy Assistant General Counsel US Nuclear Regulatory Commission Office of the General Counsel (30 I) 287-9290

Original Message-----


Original Message-----

From: Carneal, Jason Sent: Monday, October 24, 2016 12:43 PM To: Marsh, Molly <Molly.Marsh@nrc.gov>

Subject:

ADM comments on PRM-50-109, Denial of Petition for Rulemaking Submitted by C- I 0 Molly:

We received comments from ADM on the 50-109 package. Your comments were incorporated in the fi le that ADM reviewed.

Could you review the tracked changes in the attached fi les and let me know if you disagree with any of the changes proposed by ADM?

v/r, Jason Jason Carneal Project Manager NRR/DPR/PRMB 301-415-145 I

From: Spencer, Mary Sent: Tuesday, October 25, 2016 12:56 PM To: Khanna, Meena Cc: Campbell, Tison; Segarnick, Maxine

Subject:

RE: ADM comments on PRM 109~(1JJl 5J jPetition for Rulemaking Submitted by C-10 ,.__ _..

Meena, (b)(5)

We'll do this as quick was we can.

Mary


Original Message----

From: Khanna, Meena Sent: Tuesday, October 25, 2016 12:39 PM T o: Spencer, Mary <Mary.Spencer@nrc.gov>

Subject:

FW: ADM comments on PRM-50-109 ..... r_*H5_' ___! Petition for Rulemaking Submitted by C-10 Here you go ...thanks!


Original Message-----

From: Carneal, Jason Sent: Monday, October 24, 2016 2:07 PM To: Khanna, Meena <Meena.Khanna@nrc.gov> .

Subject:

FW: ADM comments on PRM-50-109, ~ Petition for Rulemaking Submitted by C-10 Meena:

FYI - another 1O day delay to 50-109 since our original lawyer went on rotation.

v/r, Jason


Original Message-----

From: Campbell, Tison Sent: Monday, October 24, 2016 2:02 PM To: Carneal, Jason <Jason.Carneal@nrc.gov>

Cc: Spencer, Mary <Mary.Spencer@nrc.gov>; Se arnick, Maxine <Maxine.Segarnick@nrc.gov>

Subject:

FW: ADM comments on PRM-50-109, ibl(5 > Petition for Rulemaking Submitted by C-10 Jason:

Molly is on a rotation right now and will be unable to review these documents. I've asked Maxine Segarnick (an HLG in our division) to review these changes and Molly's previous comments. I am going to have our mailroom create a ticket and we will get back to you in no more than 10 business days.

s

Thanks, Tison Tison Campbell Deputy Assistant General Counsel US Nuclear Regulatory Commission Office of the General Counsel (301) 287-9290

- -Original Message---


Original Message----

From: Carneal, Jason Sent: Monday, October 24, 2016 12:43 PM To: Marsh, Molly <Molly.Marsh@nrc.gov>

Subject:

ADM comments on PRM-50-109,l.(b"""

.,,..l(5.,...

l --., Petition for Rulemaking Submitted by C-10 Molly:

We received comments from ADM on the 50-109 package. Your comments were incorporated in the file that ADM reviewed .

Could you review the tracked changes in the attached files and let me know if you disagree with any of the changes proposed by ADM?

v/r, Jason Jason Carneal Project Manager NRR/DPR/PRMB 301-415-1451 6

From: Carneal, Jason To: Segamick Maxine Cc: Khanna. Meena

Subject:

RE: ADM comments on PRM-50-109,~ Petition for Rulemaking Submitted by C-10 Date: Friday, October 28, 2016 11 :05:03 AM Attachments: 50*109 letter. Chances made in response to OGC comments.docx Note: All three draft attachments, totalling 94 50-109 FRN - Changes made Jo resppnse to DGC comments dPQ. pages , are withheld in their entirety under FOIA so-109 SECY - Changes made io response to OGC comments,docx exemption 5.

Maxine:

I do Dot bave a hardcopy of Molly's comments. The best I can do is the attached, which compares the September 15.

201 6 version that went to OGC to the September 30, 201 6 version that l updated after we received Mo11y's comments.

Not.c: The attached files do not contain th<.\ comments from ADM that we asked OGC to review.

v/r, Jason


Original Mcssagc-----

From: Segamick, Maxine Sent: Friday, October 28, 20.16 9:24 AM To: Carneal, Jason <Jason.Carneal@nre.gov>

Co: Campbell, Tison <Tison.Campbell@nrc.go~

Subject:

RE: ADM comments on PRM 109,~ Petition for Rulemaking Submitted by C- 10 Hi Jason, Do you have the hardcopy of comments that Molly Marsh previously provided? l just left you a voiccmaif requesting the same.

Thanks, Maxine

Or.iginal Mcssagc-----

f rom: Campbell, Tison Sot1t: Monday, October 24, 201 6 2:02 PM To: Carneal, Jason <Jason.Carneaf@nrc.gov>

Cc: Spencer, Mary <Mary.Spenccr@nrc.gov>; Segarnick, Max.inc <Maxi1ie.Segarnick@nrc.gov>

Subject:

FW : ADM comments on PRM-50-109,,lll)(~*) rPetition for Rulemaking Submitted by C-10 Jason:

Molly is on a rotation right now and will be unable to review these docwnents. l've asked Maxine Segarnick (an HLG in our division) to review those changes imd Molly's previous comments. I am going to have our mailroom create a ticket and we wi II get back to you in no more than l Obusiness days.

Thanks, Tison Tison Campbell

Deputy Assistant General Counsel US N11clear Regulatory Commission Office of the General Counsel (30 1) 287-9290

---Original Message---


Origina l Message-----

From: ameal, Jason Sent: Monday, October 24, 2016 12:43 PM To: Mar h, Molly <Molly. Marsh@nrc .gov~

Subject:

ADM comments on PRM 109.E _ _ J Petition for Rul emaking Submitted by C-10 Molly:

We recei ved comments from ADM on the 50-109 package. Your comments were incorporated in the fil e that ADM reviewed.

Could you review the tracked changes in the attached fi les and let me know if you disagree with any of the changes proposed by ADM?

v/r, Jason Jason Carn eal Project Manager NRR/DPR/PRMB 301-415-1451

From: Seaarnick, Maxine To: Houseman Esther Cc: Campbell Tison

Subject:

FW: PRM 50-109 FRN - EDD comments addressed Date: Tuesday, January 31, 2017 10:08:00 AM Note The two draft attachments, totalling 88 pages, Attachments: DRAFT FRN PRM 50-109 EDO Comments Addressed Clean.docx DRAFT FRN PRM 50-109

  • EDO Comments RLSO.docx are withheld in their entirety under FOIA exemption 5 Hi Esther and Tison, I just received an NLO request on a revised PRM I reviewed around November. Should I sent a ticket request? l"m not sure if the email cc-ed below will result in a ticket (to RidsOgcMaHCenter Resource@nrc.gov).
Thanks, Maxine From: Carneal, Jason Sent: Tuesday, January 31, 2017 9:58 AM To: Segarnick, Maxin e <Maxine.Segarn ick@nrc.gov>

Cc: RidsOgcMa ilCenter Resource <RidsOgcMailCenter.Resource@nrc .gov>

Subject:

PRM 50-109 FR N - EDO comme nts addressed Maxine:

Attached is a copy of the updated PRM 50-109 that addresses comments that we received from the DEDO. The changes were substantial, so I am resubmitting the attached for NLO review.

For your convenience, I have attached a RSLO version that shows the DEDO comments, and a clean version. We are requesting NLO review on the clean version , which has been placed in ADAMS as well.

Please let me know if you have any additional questions.

v/r, Jason Jason Carneal Project Manager NRR/DPR/PRMB 301-415 -1451

From: QGC RMR Tickets Resource To: Segamick Maxine Cc: OGC RMB Tickets Resource

Subject:

FW: OGC 2017- 0368--- PRM 50-109 FRN - EDO comments addressed Date: Tuesday, January 31, 2017 4:11:11 PM The first two draft attachments, Attachments: DRAFT fBN PRM so-109 EDO comments Addressed c1ean.docx totalling 88 pages, are withheld in their DRAFT FRN PRM 50-109 - EDO Comments Rl,50.docx entirety under FOIA exemption 5.

OGC 2017-0368- -- SUBJECI -- PRM 50-109 FRN EDO comments addressed pdf Assigned to Maxine.

Best, Esther Houseman From: RidsOgcMa ilCenter Resource Sent: Tuesday, Ja nuary 31, 2017 2:14 PM To: OGC_KMR Tickets Resou rce <OGCRMRTickets.Resource@nrc.gov>

Subject:

OGC 2017- 0368--- PRM 50-109 FRN - EDO comments addressed Paperless t icket for RMR Division Ellen From: Carneal, Jason Sent: Tuesday, January 31, 2017 9:58 AM To: Segarn ick, Maxine <Maxine Segarnjck@nrc gov>

Cc: RidsOgcMailCenter Resource <RidsOgcMailCenter.Resource@nrc.gov>

Subject:

PRM 50-109 FRN - EDO comments addressed Maxine:

Attached is a copy of the updated PRM 50-109 that addresses comments that we received from the DEDO. The changes were substantial, so I am resubmitting the attached for NLO review.

For your convenience, I have attached a RSLO version that shows the DEDO comments, and a cle,an version. We are requesting NLO review on the clean version, which has been placed in ADAMS as well.

Please let me know if you have any additional questions.

v/r, Jason Jason Carneal Project Manager NRR/DPR/PRMB 301-415-1451

Ticket Tracking EDATS Number: OGC-2017-0368 Ticket Type: Rulemak.ing Cross Reference Numbers:

Originator: Carneal, Jason Document Date: 1/31/2017 12:00:00 AM Originator Organization: NRR Received Date: 1/31 /2017 12:00:00 AM Incoming Accession #: Response/Package #:

Addressee: Recurring Item: No Office Due Date: 2/14/20 17 12:00:00 AM EDO Due Date:

Subject:

PRM 50-109 FRN EDO comments addressed

==

Description:==

Special Instructions: review: electronic maiJ plus attachments forwarded to RMR tickets Assignees G roup : OGC/GCLR/RMR Contact : Houseman, Esther Orig Due Date: 2/ 14/2017 12:00:00 AM Last Due Date : 2/ 14/2017 L2:00:00 AM Status: Open Group: OGC/GCLR/RMR Contact : Campbell, Tison Orig Due Date : 2/ l4/2017 12:00:00 AM Last Due Date : 2/14/20 17 12:00:00 AM Status: Ope n Emails Closed By Office:

Closed By EDO:

Close Notes:

From: Segarnick, Maxine Sent: Monday, April 17, 2017 10:18 AM To: Carneal, Jason Cc: Lehman, Bryce; Campbell, Tison; Spencer, Mary; Khanna, Meena

Subject:

RE: DRAFT FRN PRM 50-109 EDO Comments Addressed Clean_OGC rev 2 - JBC BCL 2.docx Hi Jason, I reviewed the comment responses. The clean copy you sent is blank, so I looked over the marked up version (D){5)

Maxine Segarnick Attorney Reactor and Materials Rulemaking Office o'f the General Counsel 301-287-9117 Off,cia I t,sc O: d9 ,At1 tett :ey Eli@At Pri,cili8i From: Carneal, Jason Sent: Tuesday, April 04, 2017 2:59 PM To: Segarnick, Maxine <Maxine.Segarnick@nrc.gov>

Cc: Lehman, Bryce <Bryce.Lehman@nrc.gov>; OGCMailCenter Resource <OGCMailCenter.Resource@nrc.gov>

Subject:

DRAFT FRN PRM 50-109 EDO Comments Addressed Clean_OGC rev 2 - JBC BCL 2.docx Maxine:

Attached are a markup and clean copy of our responses to your comments on the FRN for PRM 50-109.

Please let us know if the changes address your comments. If not, we can meet to discuss any additional changes.

v/r, Jason 3

Jason Carneal Reactor Operations Engineer NRR/DIRS/IOEB 301*415* 1451 4

From: Khanna, Meena Sent: Monday, April 17, 2017 10:55 AM To: Campbell, Tison Cc: Lund, Louise; Casto, Greg; Spencer, Mary; Segarnick, Maxine; Benner, Eric; Ammon, Bernice; Safford, Carrie; Barczy, Theresa; Carneal. Jason; Kratchman, Jessica

Subject:

RE: STATUS: PRM 50-109 Thanks Tison, we just received the comments on the PRM from Maxine.

(b)(~*)

Thanl-.s for the continued support, Meena From: Campbell, Tison Sent: Monday, April 17, 201710:14 AM To: Khanna, Meena <Meen.:i.Kharrna@nrc.gov>

Cc: Spencer, Mary <Mary.Spencer@nrc.gov>

Subject:

RE: STATUS: PRM 50-109 Hi Meena:

You should see something later today.

-Tison From: Khanna, Meena Sent: Friday, April 14, 2017 9:31 PM To: Cam pbell, Tison <llson.Campbell@nrc.gov>

Subject:

FW: STATUS: PRM 50-109 Hi Tison, i hate to be a pest ... but, if you could pis help me to determine the status of OGC's review of the revised PRM 50-109 package is, I'd appreciate it. The EDO's office (T.Clark) has been asking me where this package is, as she provided her and Mike J's comments to my branch back in December... i know that my branch sat on it for a while due to the decomm rule draft RB, etc, and i fully respect that you all are busy, just wanted to touch base to check on status .. thanks so much.

Meena From: Kratchman, Jessica Sent: Thursday, April 13, 2017 10:31 AM To: Khanna, Meena <M eena .Khanna@nrc.gov>

Subject:

STATUS: PRM 50-109

Meena,

Here is the status of PRM 50-109:

The package is with OGC and we are awaiting tbe re-coofumation of their NLO. I do not think OGC has prioritized this work as high, which contributes to the lengthy review time. I have up-to-date electronic files from Jason that reflect all comments to date. Jason is going lo confinn that these are the files in ADAMS.

We do not know where the pieces of the hardcopy package have gone (maybe either Theresa Clark or OGC?). So we recommend giving the package back to DPR admin and having them re-print the missing pieces of the package. As we recover the old hardcopy pieces we wiU add that to the back.

Please advise.

Jessica Kratchman, Dr.PH Project Manager/ Reactor Systems Engineer U.S. Nuclear Regulatory Commission 2

From: OGCMailCenter Resource To: OGC RMB Tickets Resource; Seqarnjck, Maxine

Subject:

OGC-2017-1539 - PRM 50-109 draft SECY paper with EDO comments Date: Monday, April 17, 2017 5:33:04 PM Note : The first two draft attachments ,

Attachments: 50-109 SECY Paper with EDO comments - CLEAN.docx 50-109 SECY Paper with EDO comments.docx consisting of 10 pages , are with held in 0Gc-201z-1539 - PBM so-109 draft SECY paper with EDD commeots.odf their entirety under FOIA exemption 5.

Leslie From: Carneal, Jason Sent: Monday, April 17, 20171:56 PM To: Segarnick, Maxine <Maxine .Segarnick@nrc.gov>

Cc: OGCMailCenter Resource <OGCMai lCente r.Resource@nrc .gov>; Kratchman, Jessica

<Jessica.Kratchman@nrc.gov>; Campbe ll, Tison <Tison.Campbe ll@nrc.gov>

Subject:

PRM 50-109 SECY paper with EDO comments Maxine:

I just realized that OEDO had made several changes in ADAMS to the SECY paper that supports our evaluation of PRM 50-109.

I have attached a tracked change and clean version for NLO review, since the changes were substantial. Hopefully the attached clean version comes through this time.

v/r, Jason Jason Carneal Reactor Operations Engineer NRR/DIRS/IOEB 301-415-1451

Ticket Tracking EDATS Number: OGC-20 17- 1539 Ticket Type: Rulemaking Cross Referenee Numbers:

Originator: Carneal, Jason Document Date: 4/ 17/2017 12:00:00 AM Originator Organization: NRR Received Date: 4/ 17/2017 12:00:00 AM Incoming Accession # : Response/Package #:

Addressee: Recurring Item: N o Office Due Date: 5/1/20 17 12:00:00 AM EDO Due Date:

Subject:

PRM 50- 109 latest draft SECY paper with EDO comments - SECY paper o n staff's denial

==

Description:==

Special Instructions: Carneal emailed Segarnick .. LEV emailed OGCRMRTICKETS/Segamick w/ticket..LEV emailed Scott/B.Mizuno/Harris/ Joyce (paper tickets)

Assignees Group : OGC/GCHEA/OR Contact : Harris, Brian Orig Due Date: 5/ 1/2017 12:00:00 AM Last Due Date: 5/1 /20 17 12:00:00 AM Status: Ope n Group : OGC/GCHEA/OR Contact : Mizuno, Beth Orig Due Date : 5/ L/2017 12:00:00 AM Last Due Date: 5/1 /2017 12:00:00 AM Status: Open Group: OGC/GCHEA/OR Contact : Scott, Catherine Orig Due Date: 5/ L/2017 12:00:00 AM Last Due Date: 5/1/2017 12:00:00 AM Status: Open Group: OGC/GCLR/RMR Contact : Segamick, Maxine Orig Due Date : 5/1/20 l 7 12:00:00 AM Last Due Date: 5/1/2017 12:00:00 AM Status: Open Group: OGC/GCLR/RMR Contact : Campbell, Tison Orig Due Date: 5/ 1/2017 12:00:00 AM Last Due Date: 5/1/2017 12:00:00 AM Status: Open Group : OGC/GCLR/RMR Contact : Spencer, Mary Orig Due Date: 5/ l/2017 12:00:00 AM Last Due Date: 5/1/2017 12:00:00 AM Status: Open Emails

From: OGCMailCenter Resource To: OGC RMB Tickets Resource; Segarnjck, Maxine

Subject:

OGC-2017-1540 - PRM 50-109 Letterto Petitioner Date: Monday, April 17, 2017 5:40:31 PM Note : Th e first tw o draft attachments, Attachments: 50-109 Letter to Petitioner - EDO Comments Clean.dog 50-109 Letter to Petitioner - EDO Comments tracked changes.docx consistin g of fo ur pages , are withh eld in th eir OGC-2017-1540 - PRM 50-109 Letter to Petitioner pdf entirety un de r FOIA exemption 5.

Leslie From: Carneal, Jason Sent: Monday, April 17, 2017 2:03 PM To: Segarnick, Maxine <Maxine.Segarn ick@nrc .gov>

Cc: Kratchma n, Jessica <Jessica.Kratchman@nrc.gov>; Campbel l, Tison <Tison .Campbel l@nrc.gov>;

OGCMa ilCenter Resource <OGCMai lCenter.Reso urce@nrc .gov>

Subject:

PRM 50-109 Letter to Petitioner Maxine:

The same goes for the PRM 50-109 letter. Additional changes were made in ADAMS that we need to run by OGC to reconfirm NLO.

Attached are the tracked change and clean versions for your review.

Thanks, Jason Jason Carneal Reactor Operations Engineer N RR/DI RS/IOEB 301-415 -1451

O}!t Ticket Tracking EDATS Number: OGC-2017- 1540 Ticket Type: Rulemak.ing Cross Reference Numbers:

Originator: Carneal, Jason Document Date: 4/ 17/2017 12:00:00 AM Originator Organization: NRR Received Date: 4/ 17/2017 12:00:00 AM Incoming Accession #: Response/Package #:

Addressee: Recurring Item: No Office Due Date: 5/1 /2017 12:00:00 AM EDO Due Date:

Subject:

PRM 50-109 Letter to Petitioner

==

Description:==

Special Instructions: Carneal emailed Campbell/Segarn ick ..LEV emailed OGCRMRTICKETS/Segamick w/ticket Assignees Group : OGC/GCLR/RMR Contact : Segamick, Maxine Orig Due Date : 5/1 /20 17 12:00:00 AM Last Due Date: 5/1/20 17 12:00:00 AM Status: Open Group: OGC/GCLR/RMR Contact : Campbell, Tison Orig Due Date : 5/ 1/2017 12:00:00 AM Last Due Date: 5/1/20 17 12:00:00 AM Status: Open Group: OGC/GCLR/RMR

Contact:

Spencer, Mary Orig Due Date : 5/ 1/2017 12:00:00 AM Last Due Date : 5/1/2017 12:00:00 AM Status: Ope n Emails Closed By Otlice:

Closed By EDO:

Close Notes:

From: Campbell. Tison To: seoamick. Maxine

Subject:

PRM-50-109 Date: Monday, April 17, 2017 6: 12:41 PM Attachments: OGC-2017-1540 - PRM 50-109 Letter to Petitioner.msg OGC-2017-1539 - PRM 50-109 draft SECY paper with EDO comments.msg Maxine:

Sorry to bother you with an RMR item now that you 've moved on . Can you clarify whether you provided NLO on one or both of these? I believe that you 've closed out the SECY for RMR, so I just need to add OR and close us out there. Can you provide the status of the "letter"?

Thanks, Tison

From: OGCMailCenter Resource To : OGG RMR Tickets Resource ; Segarnick Maxine Subject : OGC-2017- 1540 - PRM 50-109 Letter to Petitioner Date: Monday, Apri l 17, 20 17 5:40 :3 1 PM Attachments : 50-109 LeUeL IO Petitil;lner - EDO Comments Clean.docx.

50* 109 Lelter toJ'etitione.r - EDD Comments tracked chanaes.docx

!J..GC.:2.01J-=.1MlL:...e.BM.5.0.c10.9-.Le.tte.L.l.o..E.itlo.oer.!).df Leslie From: Carnea l, Jason Sent: Monday, April 17, 2017 2:03 PM To: Segarnick, Maxine <Maxine .Segarnick@nrc.gov>

Cc: Kratchman, Jessica <Jessica .Kratchman@nrc.gov>; Campbell, Tison <Tison. Campbell@nrc.gov>;

OGCMailCenter Resource <0GCMai1Center.Resource@nrc.gov>

Subject:

PRM 50-109 Letter to Petitioner Maxine:

The same goes for the PRM 50-109 letter. Additional changes were made in ADAMS that we need to run by OGG to reconfirm NLO.

Attached are the tracked change and clean versions for your review.

Thanks, Jason Jason Carnea l Reacto r Opera tions Engineer NRR/DI RS/IOEB 301-415-1451

From: OGCMailCenter Resource To : OGG AMA Tickets Resource ; Segamick Maxine Subject : OGC-2017- 1539 - PRM 50-109 draft SECY paper with EDO comments Date: Monday, April 17, 20 17 5:33 :06 PM Attachments : 50-109 SECY Paper with EDO cQmments - CLEAN.doc><:

50* 109 Sl:CY Paoer with EDO commenJs.doc11 o..GC.:2fil7..:.1.5.3.LeBM--5.0.c.1..D.9-draf.l.SfC.Y_p.a!lflDY.i11LED.0...co.mments..pdf Leslie From: Carneal, Jason Sent: Monday, April 17, 20171:56 PM To: Segarnick, Maxine <Maxine .Segarnick@nrc.gov>

Cc: OGCMailCenter Resource <OGCMailCenter.Resource@nrc.gov>; Kratchma n, Jessica

<Jessica.Kratchman@nrc.gov>; Campbell, Tison <Tison .Campbe ll @nrc.gov>

Subject:

PRM 50- 109 SECY paper with EDO comments Maxine:

I just realized that OEDO had made several changes in ADAMS to the SECY paper that supports our evaluation of PRM 50-109.

I have attached a tracked change and clean version for NLO review, since the changes were substantial. Hopefully the attached clean version comes through this time.

v/r, Jason Jason Carnea l Reacto r Operations Engin eer NRR/D IRS/IOEB 301-415 -1451

From : Ghosh Anita To: Seoarnjck Maxine Note: This is the same 6-page draft attachment, Cc: Harris Brian withheld in its entirety under FOIA exemption 5,

Subject:

FW: PRM 50-109 SECY paper with EDO comments as the attachment to Ms. Ghosh's 4119117 6:51 Date: Tuesday, April 18, 2017 11:59:00 AM pm email.

Attachments: 50- J09 SECY Paoer with EDO comments OGG-RMB comments.docx Hi Maxine, I am reviewing this for Brian Harris since he is at the Hill today. In your email to Beth below, (b)(5) 1 nanks!

Anita From: M izuno, Beth Sent: Monday, April 17, 2017 3:42 PM To: Harris, Brian <Brian .Harris@nrc.gov>; Segarnick, Maxine <M axine.Segarnick@nrc.gov>; Ghosh, An ita <Anita.Ghosh@nrc.gov>; Wachutka, Jeremy <Jeremy.Wachutka@nrc.gov>

Cc: Scott, Catheri ne <Catheri ri e.Scott@nrc.gov>

Subject:

FW: PRM 50-109 SECY paper with EDO comme nts Brian, please review the attached and give your comments to Maxine. Thanks.

Maxine, Brian is the lead attorney on the current Seabrook litigation. Anita and Jeremy are his co-counsels on that case.

Anita and Jeremy, I am cc'ing you for information purposes.

From: Segarnick, Maxine Sent: Monday, April 17, 2017 2:36 PM To: Mizu no, Beth <Beth Mizuno@nrc gov>

Cc: Campbell, Tison <Tison Campbell @nrc.gov>

Subject:

FW: PRM 50-109 SECY paper with EDO comments Hi Beth, l(bJ(S) I,._

Could you please take a look at this SECY paper on staff's v Specifically, see the paragraph on page 3 that discusses a Seabrook 2.206 request and contention.

I've attached the latest draft, which AMR previously NLO'd, but OEDO revised to add this new language. I re-reviewed it, so my markup is also in track changes.

Tison will add you to the ticket.

Maxine From: Campbell, Tison Sent: Monday, April 17, 20171:59 PM To: Segarnick, Maxine <Maxjne.Segarnick@nrc.gov>

Subject:

FW: PRM 50-109 SECY paper with EDO comments If you have time to look at this, the new discussion of the 2.206 petition and contention will need to go to OGC/OR (Beth Mizuno) for review. I'm not sure how much time they'll need.

From: Carneal, Jason Sent: Monday, April 17, 2017 1:56 PM To: Segarnick, Maxine <Maxine,Segarnjck@nrc.gov>

Cc: OGCMailCenter Resource <0GCMai1Center.Resource@nrc.gov>; Kratchman, Je ssica

<Jessica .Kratchman@nrc.gov>; Campbell, Tison <Tison .Carnpbell@nrc .gov>

Subject:

PRM 50-109 SECY paper with EDO comments Maxine:

I just realized that OEDO had made several changes in ADAMS to the SECY paper that supports our evaluation of PRM 50-1 09.

I have attached a tracked change and clean version for NLO review, since the changes were substantial. Hopefully the attached clean version comes through this time.

v/r, Jason Jason Carnea l Reactor Operations Eng ineer NRR/DIRS/IOEB 301-415-1451

From: segarnjck Max;ne To: Ghosh Anita Cc: Harris Brian; Campbell Ji~oo

Subject:

RE: PRM 50-109 SECY paper with EDO comments Date: Tuesday, April 18, 2017 3:35:50 PM Hi Anita, That's the latest version.

b)(5)

'm copying Tison, who

"":h_a_s-;b:-e-e_n_i:n-:-

- t-o-uc-;h- w":":'it-:-

h.M 7e

_e_n_a-.- - - - - - - - - - - - - . J Maxine From: Ghosh, Anita Sent: Tuesday, Apri l 18, 2017 11:59 AM To: Sega rn ick, Maxine <Maxine.Segarnick@nrc.gov>

Cc: Harris. Brian <Brian.Harris@nrc.gov>

Subject:

FW: PR M 50-109 SECY paper with EDO comme nts Hi Maxine, I am reviewing this for Brian Harris since he is at the Hill today. In your email to Beth below, (b)(5)

Thanks!

Anita From: Mizuno, Beth Sent: Monday, April 17, 2017 3:42 PM To: Harris, Brian <Brjan.Harrjs@nrc.gov>; Sega rnick, Maxine <Maxine Segarnick@nrc.gov>; Ghosh, An ita <Anita.Ghosh@nrc.gov>; Wachutka, Jeremy <Jeremy.Wachutka@nrc.gov>

Cc: Scott, Catheri ne <Catherioe.Scott@nrc.gov>

Subject:

FW: PR M 50-109 SECY paper with EDO comme nts Brian, please review the attached and give your comments to Maxine. Thanks.

Maxine, Brian is the lead attorney on the current Seabrook litigation. Anita and Jeremy are his co-counsels on that case.

Anita and Jeremy, I am cc'ing you for information purposes.

From: Segarnick, Maxine Sent: Monday, April 17, 2017 2:36 PM To: Mizuno, Beth <Beth Mizuno@nrc gov>

Cc: Campbel l, Tison <Jjson.Campbell @orc.gov>

Subject:

FW: PR M 50-109 SECY paper with EDO comments Hi Beth, Could you please take a look at this SECY paper on staff's (

bb)<~ b f

Specifically, see the paragraph on page 3 that discusses a e OrooK 2.206 request and contention.

I've attached the latest draft, which RMR previously NLO"d, but OEDO revised to add this new language. I re-reviewed it, so my markup is also in track changes.

Tison will add you to the ticket.

Maxine From: Campbe ll, Tison Sent: Monday, April 17, 20171:59 PM To: Sega rni ck, Maxine <Maxine Segarnick@nrc.gov>

Subject:

FW: PRM 50-109 SECY paper with EDO comments If you have time to look at this, the new discussion of the 2.206 petition and contention will need to go to OGC/OR (Beth Mizuno) for review. I'm not sure how much time they'll need.

From: Carneal, Jason Sent: Monday, April 17, 20171:56 PM To: Sega rni ck, M axine <Maxlne.Segarnjck@nrc.gov>

Cc: OGCMa ilCenter Resou rce <OGCMailCenter.Resource@nrc.gov>; Kratchman, Jessica

<Jessica. Kratchman@nrc .gov>; Campbell, Tison <Tison .Campbe ll @nrc.gov>

Subject:

PRM 50-109 SECY paper wi t h EDO comme nts Maxine:

I just realized that OEDO had made several changes in ADAMS to the SECY paper that supports our evaluation of PRM 50-109.

I have attached a tracked change and clean version for NLO review, since the changes were substantial. Hopefully the attached clean version comes through this time.

v/r, Jason Jason Carnea l Reacto r Ope rat ions Engineer NRR/DIRS/IOEB 301-415-1451

From: Lehman Bryce To : Ghosh Anita ; Harris Brian ; wachutka Jeremy Cc: Thomas George; Buford Angela ; Oujchocho Jessie; Poole Justin Note: The two draft attachments, 3 and Subject : Attorney Work Product - Seabrook Contention 35 pages respectively, have been Date: Tuesday, April 18, 20 17 5:03 :22 PM withheld under FOIA exemption 5 Attachments: Contention Response 2.doox DRAFT FRNPRM50-109 EDO Comments Addressed Clean OGG rev 2 - JBC BCL 2.... .docx All ,

Attached is the document we discussed today along with the referenced DRAFT FRN .

(b)(:>l

Thanks, Bryce Lehman NRR/DE/ EMCB (301 ) 415-1626

From: Ghosh Anita To: Harris Brian Note: The two attachments, 6 and 35 pages,

Subject:

ASR PRM comments respectively, have been withheld under FOIA Date: Wednesday, April 19, 2017 6:57:00 PM exemption 5.

Attachments: 50* 109 SECY Paoer with EDO comments OGC-RMR OR comments.doc~

DRAFT FRN PRM 50-109,doc)I Hi Brian, I have reviewed the FRN for the PRM and the SECY related to the PRM.I (b)(5)

IMy comments are attached.

Please let me know what you think (bJ(tiJ Anita Ghosh Sen ior Attorney Office of the General Counsel U.S. Nuclear Regulatory Commission (301) 287-9175 anita.ghosh@nrc gov IQOI ICE. 1IIIS @liidil diitJ di 19 dlldtl 11 11@1 \CS 111ay LOI ildifi tdlilid@htldi Alt bf r1ey .. c11@t1t bf Allbffiey VVOf k*Pfddbtl material ~ .. Rllt r.liliGil11c1111::tcir.111 ~lii'C 111itl..*1t 'eii"H~iaaiiiR ii!i!i~ii"iil

From: Harris Brian To: Ghosh Anita Subject : RE: ASA PAM comments Date: Thursday. April 20, 2017 7: 15:14 AM Thanks. I would go ahead and send it.

Best regards, Brian G. Harris Senior Auorney Office of the General Counsel Nuclear Regulatory Commission 301.287.9 120 bri an.hmJis@nrc.gov Note: New Phone Number Qffiri*111 1,e Only= A1toroey Client Pcivilu~'i*/\b/Qr~ Prftl<<l11cEQwreltM-1.i From: Ghosh, Anita Sent: Wednesday, April 19, 20 17 6:57 PM To: Harris, Brian <Brian.Harris@nrc.gov>

Subject:

ASR PRM comments Hi Brian, I have reviewed the FRN for the PRM and the SECY related to the PRM. I (b)(5)

J My comments

~a;::ri-e:-:

a::1m~a::-::c:i::
n:-:::e~a. - - - - - - - - - - - - - - - - - - - - - - - '

Please let me know what ou think (o)i 5 )

hanks, Anita Anita Ghosh Sen ior Attorney Office of the General Counsel U.S. Nuclear Regulatory Commission (301) 287-9175 anita.ghosh@nrc.gov P49flCE. Tl:iJ c;;;ail C11eJ 0119 attad 1111c11ts 11109 cs1:toi11 co11fidc11tiol ;Ottto111c9 Clic 11t 01 ,,tto; 11c 9 \¥0:lc P1oeJuct material Do oat disclose 011tside NBCwithout Commission approval.

From: Ghosh Anita To: Khanna Meena; Carneal Jason Cc: Lund Louise; Bowman Gregory; Harris Brian; Clark Theresa; filil:l&Ill!IWL~~~------------~

Subject : RE: STATUS: PRM 50-109 Note : These two draft attachments , withheld in Date: Thursday, April 20, 2017 9:02:00 AM their entirety under FOIA exemption 5, are the Attachments : 50-109 SECY Paoer with EDO comments OGC-RMR OR comments docx same as the attachments to Ms. Ghosh's DRAFT FANPBM 50-109 OGC OR cmts docx 4/1 9/1 7 6:51 pm email.

Meena and Jason, I have reviewed the SECY and FRN related to PRM-50-109 (li)(5)

My comments on o

....d

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: "e

.:::-:n::.t-:::-

s-:::a~re~ affa

".c= e:-::r-._______________J Please let me know if you have any questions.

Thanks, Anita From: Khanna, Meena Sent: Tuesday, April 18, 2017 6:31 PM To: Ghosh, An ita <Anita.Ghosh@nrc.gov>

Cc: Lund, Louise <Louise.Lund@nrc.gov>; Bowman, Gregory <Gregory.Bowman@nrc.gov>; Harris, Brian <Brian .Harris@nrc.gov>; Clark, Theresa <Theresa.Clark@n rc.gov>; Kratchman, Jessica

<Jessica.Kratchman@nrc.gov>; Carnea l, Jason <Jason.Carnea l@n rc.gov>

Subject:

RE : STATUS: PR M 50-109 Great, thanks so much, Anita. We appreciate your and Brian's support.

Meena From: Ghosh, Anita Sent: Tuesday, April 18, 2017 6:29 PM To: Khan na, Meena <Meena.Khanna@nrc.gov>

Cc: Harris, Brian <Brian Harris@nrc gov>

Subject:

FW: STATUS: PRM 50-109 Meena, I am working with Brian Harris on the Seabrook litigation, so this is with me right now. We will try to get you feedback on this in the next day or so.

Thanks, Anita From: Harris, Brian Sent: Tuesday, April 18, 2017 4:12 PM To: Ghosh, Anita <Anita.Ghosh@nrc,gov>

Subject:

FW: STATUS: PRM 50-109 Best regards, Brian G. Harris

Senior Attorney Office of the General Counsel Nuclear Regulatory Commission 30 1.287.9 120 brian.haffis@nrc.gov Note: New Phone Number Officizd Use Olil) ,4ett6rfl@)' Cli @Rt Privili8i/U/Qrlc Prgduct Doctrine From: Harris, Brian Sent: Tuesday, April 18, 2017 2:08 PM To: Harris, Brian <Brian.Harris@nrc.gov>

Subject:

FW: STATUS: PRM 50-109 Brian K. Harris P roject :rvlanager 301.415.2277 NRR/DPR/PGCB U.S. Nuclear Regulatory Commission Washington, D.C. 20555 From: Campbell, Tison Sent: Tuesday, April 18, 2017 2:07 PM To: Khan na, Meena <Meena.Khanna@nrc gov>; Safford, Carrie <Carrje.Safford@nrc.gov>

Cc: Lund, Louise <Louise.Lund @nrc.gov>; Casto, Greg <Greg Casto@nrc.gov>; Spencer, Mary

<Mary.Soencer@nrc.gov>; Segarnick, Maxine <Maxine.Segarnick@nrc.gov>; Benner, Eric

<Eric Benner@nrc gov>; Ammon, Bernice <Bernjce Ammon@nrc gov>; Barczy, Theresa

<Theresa.Barczy@nrc gov>; Carnea l, Jason <Jason.Carneal@nrc gov>; Kratchman, Jessica

<Jessica.Kratchman@nrc,goy>; Mizuno, Beth <Beth.Mizuno@nrc.gov>; Harris, Bria n

<Brian.Harris2@nrc.gov>

Subject:

RE: STATUS: PR M 50-109 Meena:

We provided the SECY on the PRM to OGG/OR yesterday. Beth Mizuno and Brian Harris are the points of contact for that division on this item.

-Tison Tison Campbell Deputy Ass,stant General Counsel Reactor and Materials Rulemaking US Nuclear Regulatory Commission Office of the General Counsel (301) 287-S290

~

AUORMFY "PIT PRll:'lbEGEEl IPJFBRfo1Al'1614 LIMITE9 l9 MRS 'e'~II iU COW41SSIODI DEIEPD41'>1ES OIHEP\O'ISE.

From: Khanna, Meena Sent: Tuesday, April 18, 2017 2:05 PM To: Safford, Carrie <Carrle.Safford@nrc.gov>

Cc: Lund, Lou ise <Louise,Lund@nrc.gov>; Casto, Greg <Greg Casto@nrc.gov>; Spencer, Mary

<Mary.Spencer@orc.gov>; Segarnick, Maxi ne <Maxjne.Segarnick@nrc.gov>; Benner, Eric

<Eric.Benner@nrc gov>; Am mon, Bernice <Bernice Ammon@nrc gov>; Barczy, Theresa

<Theresa.Barczy@nrc gov>; Carnea l, Jason <Jason Carnea l@nrc.gov>; Kratchman, Jessica

<Jessica.Kratchman@nrc.gov>; Campbell, Tison <Tison.Campbell@nrc.gov>

Subject:

RE : STATUS: PR M 50-109 Thanks Carrie ... l will touch base with Cathy to obtain any insights/path forward.

From: Khanna, Meena Sent: Monday, Apri l 17, 2017 10:55 AM To: Campbel l, Tison <Tison.Campbell@nrc.gov>

Cc: Lund, Louise <Louise Lund@nrc gov>; Casto, Greg <Greg Casto@nrc gov>; Spence r, Mary

<Mary.Spencer@nrc gov>; Segarnick, Maxine <Maxjne.Segarnjck@nrc.gov>; Benner, Eric

<Eric.Benner@nrc.gov>; Ammon, Bernice <Bernice.Ammon@nrc.gov>; Safford, Carrie

<Carrie.Safford@nrc.gov>; Barczy, Theresa <Theresa.Barczy@nrc.gov>; Carneal, Jason

<Jason.Carneal@orc gov>; Kratchman, Jessica <Jessica.Kratcbm20@orc gov>

Subject:

RE: STATUS: PR M 50-109 Thanks Tison. we iust received the comments on the PRM from Maxine.

(b)(S)

Thanks for the continued support, Meena From: Campbell, Tison Sent: Monday, April 17, 2017 10:14 AM To: Khanna, Meena <Meena Khanna@nrc gov>

Cc: Spencer, Mary <Mary.Spencer@rre.gov>

Subject:

RE: STATUS: PR M 50-109 Hi Meena:

You should see something later today.

-Tison From: Khanna, Meena Sent: Friday, April 14, 2017 9:31 PM To: Campbel l, Tison <Tison Campbell@orc gov>

Subject:

FW: STATUS: PRM 50-109 Hi Tison, i hate to be a pest. .. but, if you could pis help me to determine the status of OGC's review of the revised PRM 50-109 package is, I'd appreciate it. The EDO"s office (T.Clark) has been asking me where this package is, as she provided her and Mike J's comments to my branch back in December ... i know that my branch sat on it for a while due to the decomm rule draft RB , etc , and i fully respect that you all are busy, just wanted to touch base to check on status ..thanks so much.

Meena From: Kratchman, Jessica Sent: Thursday, April 13, 2017 10:31 AM To: Khanna, Meena <Meena.Khanna@nrc.gov>

Subject:

STATUS: PRM 50-109

Meena, Here is the status of PRM 50- 109:

The package is with OGC and we are awaiting the re-confirmation of their NLO. I do not think OGC has prioritized this work as high, which contributes to the lengthy review time. I have up-to-date electronic files from Jason that reflect all comments to date. Jason is going to confirm that these are the files in ADAMS.

We do not know where the pieces of the hardcopy package have gone (maybe either Theresa Clark or OGC?). So we recommend giving the package back to DPR admin and having them re-print the missing pieces of the package. As we recover the old hardcopy pieces we will add that to the back.

Please advise.

-jess Jessica Kra tchma n, Dr .PH Proj ect Ma nager/ Reactor Systems Engineer U.S. Nuclear Regu lato ry Comm ission

From: Lappert Glenna To: Ghosh Naber Anjta

Subject:

PRM-50-109 Date: Tuesday, January 30 , 2018 3 :03:24 AM

Anita, Meena wanted me to send you the package number for the 50-109. It is ML15301AOQ __

The hearing for Seabrook is addressed on page 2 of the SECY paper.

Please let me know if you need anything else.

Thanks, Glenna Lap pert

From : Ghosh Anita To : Lappert Glenna Cc: Khanna Meena Subject : RE: PRM-50-109 Note: The 4-page draft attachment is Date: Tuesday, January 30, 2018 11 :23:00 AM withheld in its entirety under FOIA exemption Attachments : FINAL 50-109 SECY Paper 01262018 OGC cmts.docx 5.

Glenna, Thanks for sendin this m wa . I have some minor suggestions to the languagq(b)(:,/

(b)(S) Please let me know if you have any qu""'e"""" st"1o

"""'n"""s-. __,

From: Lappe rt, Glenna Sent: Tuesday, January 30, 2018 3:03 AM To: Ghosh, Anita <Anita .Ghosh@nrc.gov>

Subject:

PRM 109

Anita, Meena wanted me to send you the package number for the 50-109. It is ML15301A002.

The hearing for Seabrook is addressed on page 2 of the SECY paper.

Please let me know if you need anything else.

Thanks, Glenna Lappert