ML22005A078
| ML22005A078 | |
| Person / Time | |
|---|---|
| Issue date: | 12/28/2021 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML22005A076 | List: |
| References | |
| FOIA, NRC-2022-000026 | |
| Download: ML22005A078 (75) | |
Text
From:
Suber, Gregory Sent:
Fri, 19 Nov 202118:48:33 +0000 To:
Shoop, U ndine;Wrona, David;Carusone, Caroline;Pham, Bo;Screnci, Diane;Burnell, Scott;Sheehan, Neil
Subject:
RE: 10 CFR 2.206 meeting summary
- Everyone, I went through the extracted comments from the transcripts and came away with a few major themes from Blanch:
- 1. NRC needs to ensure statements in the petition response are not, incomplete, misleading, or inaccurate. (We addressed this through the independence, peer review, and contractor option)
- 2. A petitioner does not have appeal rights if a petition is rejected. (This is a part if the program we did not change)
- 3. Petitioners cannot ask the staff questions about the review. They can only present information where as the licensee can ask questions. (This practice is designed not to make the 2.206 process a de facto adjudicatory process. These types of questions should be addressed as a Petition for Hearing, Petition for Rulemaking, or through an Allegation is wrong doing is suspected)
- 4. General criticism regarding the handling of the San Onofre Petition and the staff's inability to explain how it reaches a determination of what is and is not credible.
This is just a high level read of the comments. In addition, his presentation at the first meeting which was not transcribed, focuses on the methods that can be employed by the public to question regulations and a specific staff analysis. In some cases, the 2.206 process is not the appropriate mechanism to address these types of concerns. Maybe petition for hearing or rulemaking is not in order. Conversely, the Allegations Process or OIG referral works best.
Would like to hear your feedback or perspective.
From: Shoop, Undine <Undine.Shoop@nrc.gov>
Sent: Friday, November 19, 202112:14 PM To: Wrona, David <David.Wrona@nrc.gov>; Carusone, Caroline <caroline.carusone@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>; Screnci, Diane
<Diane.Screnci@nrc.gov>; Burnell, Scott <Scott.Burnell@nrc.gov>; Sheehan, Neil
<Neil.Sheehan@nrc.gov>
Subject:
FW: 10 CFR 2.206 meeting summary FYI - Paul Blanch was the individual who made a presentation at the first 2.206 meeting. Attached are his slides
From:
To:
Subject:
Date:
Burnell Scott Screod Diane RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From:
WIRELESS CALLER, 8609223119 Wednesday, November 17, 2021 8:35:00 AM That's the focus of the email.
From: Screnci, Diane <Diane.Screnci@nrc.gov>
Sent: Wednesday, November 17, 2021 8:34 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 Just FYI, he also asked Neil for the new public meeting policy (again) recently.
Diane Screnci (she/her)
Sr. Public Affairs Officer USNRC, Region I 610-337-5330 From: Burnell, Scott <Scott Burnell@nrc gov>
Sent: Wednesday, November 17, 20218:32 AM To: Russell, Andrea <Andrea Russell@nrc gov>; McIntyre, Dave <David Mclntyre@nrc gov>; Screnci, Diane <Diane Screnci@nrc gov>
Cc: Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 After checking with the EDO's office, I'll reach out to Blanch on what he wants to discuss. If it aligns with the email he sent the EDO, we'll work on a single reply.
From: Burnell, Scott Sent: Tuesday, November 16, 2021 9:31 AM To: Russell, Andrea <Andrea Russell@nrc,gov>; McIntyre, Dave <David Mclntyre@nrc gov>; Screnci, Diane <Diane,Screnci@nrc,gov>
Cc: Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 Hi Andrea; He's also emailed the EDO. We're working on how best to wrangle all this into one task, so don't reply just yet. Thanks.
Scott
From: Russell, Andrea <Andrea RusseH@nrc.gov>
Sent: Monday, November 15, 202110:05 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>; McIntyre, Dave <Davjd.Mclntyre@nrc.gov>; Screnci, Diane <Diaoe.Screnci@nrc gov>
Cc: Evans, Jonathan <Jonathan.Evans@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 I just missed another phone call from him. I didn"t answer as l"d like some instruction on how to respond to him if I must interact with him.
From: Russell, Andrea Sent: Monday, November 15, 2021 9:30 AM To: Burnell, Scott <Scott Burnell@nrc gov>; McIntyre, Dave <David Mclntvre@nrc gov>; Screnci, Diane <Diane Screnci@nrc gov>
Cc: Evans, Jonathan <Jonathan.Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc.gov>
Subject:
10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 Good morning.
Both Jonathan and I received the same voicemail from Mr. Blanche Friday afternoon.
have forwarded Jonathan's e-mail below. He wanted to talk about the SECY related to the revisions to the 10 CFR 2.206 process.
I believe all 3 of you were at some point involved in our public meetings regarding the 10 CFR 2.206 process revisions related to the OIG report on Indian Point. Please let me know if you all can address or if Jonathan and I should respond to Mr. Blanche.
- Thanks, Andrea From: Suber, Gregory <Gregory Suber@nrc gov>
Sent: Friday, November 12, 20211:39 PM To: Russell, Andrea <Andrea Russell@orc gov>; Evans, Jonathan <Jonathan Evans@nrc gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 So it is a general request. You can call him if you like or refer it to OPA. They are accustomed to dealing with him and can answer any high level question he may have.
Just want to be considerate of your time and do not want you to get distracted by a side dialogue.
From: Russell, Andrea <Andrea Russell@orc gov>
Sent: Friday, November 12, 20211:12 PM To: Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119
Yep... he left same voicemail on mine.
From: Evans, Jonathan <Jonathan.Evans@nrc gov>
Sent: Friday, November 12, 20211:11 PM To: Russell, Andrea <Andrea Russell@nrc.gov>; Suber, Gregory <Gregory,Suber@nrc.gov>
Subject:
FW: Voice Message From: WIRELESS CALLER, 8609223119 Message from paul blanche Jonathan E. Evans Acting Branch Ch ief Reactor Inspection Branch Division of Nuclear Materials Safety United States Nuclear Regulatory Commission Arlington, Texas 76011 Phone: 817-200-1249 From: WIRELESS CALLER <tel=8609223119@ofljcelinx.nrc.goy>
Sent: Friday, November 12, 202111:23 AM To: Evans, Jonathan <Jonathan.Evans@nrc.gov>
Subject:
Voice Message From: WIRELESS CALLER, 8609223119
From:
Burnell Scott To:
Screnci Piaoe; McIntyre Pave
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From:
WIRELESS CALLER, 8609223119 Date:
Attachments:
Tuesday, November 16, 2021 9:14:00 AM 20211112 PMB to EDO for oublic dialoa.odf Given that he's pinged the EDO asking for another meeting on San Onofre (where he continues to abuse the 2.206 process), I'd suggest letting him know he'll get one response from the agency.
From: Screnci, Diane <Diane.Screnci@nrc.gov>
Sent: Monday, November 15, 202110:49 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>; McIntyre, Dave <David.Mclntyre@nrc.gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 If you ask for a list of questions, you're going to get pages of questions. Why don't you just call him back to see what he wants and if it's responses to a list of questions, then ask for the list. (His name is Blanch, by the way. No "e")
Diane Screnci (she/ her)
Sr. Public Affairs Officer USNRC, Region I 610-337-5330 From: Burnell, Scott <Scott Burnell@orc gov>
Sent: Monday, November 15, 202110:43 AM To: McIntyre, Dave <David Mclntyre@nrc gov>; Screnci, Diane <Diane Screncj@nrc gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 I agree, I was thinking emailing him to ask for a list of Qs.
From: McIntyre, Dave <David Mclntyre@nrc gov>
Sent: Monday, November 15, 202110:42 AM To: Burnell, Scott <Scott.Burnell@orc gov>; Screnci, Diane <Diane Screoci@orc gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 It's going to be a never-ending monologue....
From: Burnell, Scott <Scott Burnell@nrc gov>
Sent: Monday, November 15, 202110:20 AM To: Screnci, Diane <Diane Screoci@nrc gov>; McIntyre, Dave <David Mclntyre@nrc gov>
Subject:
FW: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt):
Voice Message From: WIRELESS CALLER, 8609223119
How would you suggest we proceed? Get specific questions from him to pass on to the staff?
From: Russell, Andrea <Andrea Russell@nrc gov>
Sent: Monday, November 15, 202110:05 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>; McIntyre, Dave <David.Mclntyre@nrc.gov>;
Screnci, Diane <Diane Screncj@nrc !NY>
Cc: Evans, Jonathan <Jonathan Eyans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
RE: 10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt):
Voice Message From: WIRELESS CALLER, 8609223119 I just missed another phone call from him. I didn't answer as I'd like some instruction on how to respond to him if I must interact with him.
From: Russell, Andrea Sent: Monday, November 15, 2021 9:30 AM To: Burnell, Scott <Scott Burnell@occ gov>; McIntyre, Dave <David Mclntyre@nrc gov>;
Screnci, Diane <Diane Screncj@nrc gov>
Cc: Evans, Jonathan <Jonathan.Eyans@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>
Subject:
10 CFR 2.206 revisions detailed in SECY (related to OIG Report for Indian Pt): Voice Message From: WIRELESS CALLER, 8609223119 Good morning, Both Jonathan and I received the same voicemail from Mr. Blanche Friday afternoon. I have forwarded Jonathan's e-mail below. He wanted to talk about the SECY related to the revisions to the 10 CFR 2.206 process.
I believe all 3 of you were at some point involved in our public meetings regarding the 10 CFR 2.206 process revisions related to the OIG report on Indian Point.
Please let me know if you all can address or if Jonathan and I should respond to Mr.
Blanche.
- Thanks, Andrea From: Suber, Gregory <Gregory Suber@nrc gov>
Sent: Friday, November 12, 20211:39 PM To: Russell, Andrea <Andrea Russell@nrc goy>: Evans, Jonathan <Jonathan Eyans@nrc gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 So it is a general request. You can call him if you like or refer it to OPA. They are accustomed to dealing with him and can answer any high level question he may have. Just want to be considerate of your time and do not want you to get distracted by a side dialogue.
From: Russell, Andrea <Andrea Russell@nrc.gov>
Sent: Friday, November 12, 20211:12 PM To: Evans, Jonathan <Jonathan Eyans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 Yep... he left same voicemail on mine.
From: Evans, Jonathan <Jonathan Eyans@nrc gov>
Sent: Friday, November 12, 20211:11 PM To: Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>
Subject:
FW: Voice Message From: WIRELESS CALLER, 8609223119 Message from paul blanche Jonathan E. Evans Acting Branch Chief Reactor Inspection Branch Division of Nuclear Materials Safety United States Nuclear Regulatory Commission Arlington, Texas 76011 Phone: 817-200-1249 From: WIRELESS CALLER <tel-8609223119@office!inx ore gov>
Sent: Friday, November 12, 202111 :23 AM To: Evans, Jonathan <Jonathan Evans@nrc gov>
Subject:
Voice Message From: WIRELESS CALLER, 8609223119
Paul M Blanch PE Energy Consultant Friday, November 12, 2021 Mr Daniel Dorman Executive Director for Operations Nuclear Regulation Commission Washington DC 20001
SUBJECT:
Request for Public Dialog Communicating with Public Watchdog and the General Public.
REFERENCE:
Letter from Kevin Williams to Public Watchdogs dated August 30, 2021.
Dear Mr. Dorman:
For almost more than two years I, and others have been exchanging communications with the NRC related to our safety issues and the storage of spent fuel at San Onofre Nuclear Generating Station (SONGS).
The most recent communication is from the NRC's Mr. Kevin Williams to Public Watchdogs dated August 30, 2021. Public Watchdogs has formally responded to this letter expressing its total disagreement. We appear to have reached a stalemate.
Our respective opinions related to the safe operation of SONGS are clearly in disagreement. Our strongest belief is that Adequate Protection to the Public is not being provided. The differences of opinions are clearly articulated in numerous letters and meetings betw,een us and the NRC.
We believe that the time has come to consider a different approach to resolve our conflict, seeking resolution with a more open means of communicating. We believe the full Commission is amenable with a different approach as reflected in both the NRC's recently issued policy "Enhancing Participation in NRC Public Meetings,"
that emphasized the need to improve the consistency of the NRC's public meetings
and help participants better prepare for NRC meetings1and its basic Principles of Good Regulation. The NRC espouses principles of good regulation on its "Values" public web page.
"These principles focus us on ensuring safety and security while appropriately balaticin,: the interests of the NRC's stakeholders, includin,:
thepublic and licensees."
"Independence: Nothing but the highest possible standards of ethical performance and professionalism should influence regulation. However, independence does not imply isolation. All available facts and opinions must be sou,:ht openly from licensees and other interested members of the public. The many andpossih!J, conflictin,:puhlic interests involved must be considered. Final decisions must be based on objective, unbiased assessments of all information, and must be documented with reasons explicitly stated.
Openness: Nuclear re,:ulation is the public's business, and it must be transacted publiclv and candidly. The public must be informed about and have the OJWOrtunity to participate in the re~ulatory processes as reguired by law. [ emphasis added) Open channels of communication must be maintained with Congress, other government agencies, licensees, and tlte public, [emphasis added] as well as with the international nuclear community."
The recent GAO report on Commercial Spent FueF noted that involving the public and restoring public confidence is a key to the resolll.ltion of the Commercial Spent Fuel dilemma.
This GAO report encouraged dialog between the NRC and the Public as a means to restore faith and trust in the NRC as a foundation for the resolution of the commercial fuel issue. The GAO report goes so far as to state that "public trust and confidence in the commercial spent nuclear fuel management program" and "The Blue Ribbon Commission's recommendations focused on ways to sustain the public trust and confidence necessary to see controversial facilities, such as geologic repositories, through to completion." The GAO noted that "Canada's Nuclear Waste Management Organization completed a 3-year-long dialo1:ue with the public [ emphasis added] to develop a path forward for spent nuclear fuel 1 https://www.federalregister.gov/documents/2021 /03/19/2021 -05787 /enhancing-participation-in-nrc-public-meetings 2 chrome-extension://efaidnbmnnnibpcajpcglclefindmkaj/viewer.html?
pdfurl=https %3A %2F%2 Fwww.gao.gov%2Fassets %2 Fgao-21-603.pdf&clen=3084930&chunk
=true
management... " is the foundation to any resolution of the Spent Fuel issues."
An open dialog and meeting between the NRC and the Public discussing the public's safety concerns with SONGS would be a great starting point.
History has clearly demonstrated that conflict is never resolved in an equitable manner without face to face meetings and dialog.
Prior to making a final decision to outright reject our safety concerns, I formally request a public dialog and a meeting with the NRC, in the vicinity of San Onofre and following the guidance the NRC's Principles of Good Regulation and its Policy of Enhancing Participation.
We suggest that this meeting be conducted prior to the end of the comment period on the Decommissioning Rule such that the outcome of the meeting can be incorporated into our comments on the Decommissioning Rule.
An extract from the NRC 's Policy is provided as Attachment 1 and describes the type of meeting we are seeking.
Please contact Mr. Langley to discuss panel format and participants, meeting location, proposed moderator, time and proposed topics to be discussed.
I am looking forward to your positive response.
Very truly yours, Sincerely, Paul Blanch PE This request has been reviewed by Public Watchdogs and the Samual Lawrence Foundation and has received their full support and concurrence.
Cc:
Chainnan Hanson Commissioner Baran Commissioner Wright Inspector General Feitel Kevin Williams Extract from NRC's Policy of Enhancing Participation in NRC Public Meetings Information Meeting With a Question and Answer Session Meeting Purpose-The purpose of this type of meeting is for the N RC to share information and discuss applicable regulatory issues and NRC actions with meeting attendees. The meeting will inform the public by providing information to help them understand the applicable regulatory issues and NRC actions through NRC presentations and discussions with NRC staff. These are organized, yet infonnal opportunities to interact with and ask questions of the NRC staff not associated with a more traditional public meeting format.
Level of Participation-This type of meeting is tailored to inform attendees and allow them to ask questions. The NRC staff should strive to ensure sufficient time is allotted for an Information Meeting with a Question and Answer Session to ensure that members of the public can pose their questions and have them answered during the meeting. Whether all questions are addressed or not, the NRC should emphasize ways members of the public can ask questions outside the meeting.
Description-Meetings in this category are held with interested parties, including representatives of non-government organizations, private citizens, or various businesses or industries, to engage them in a discussion of regulatory issues.
The following description will be included in the notice for an Information Meeting with a Question and Answer Session:
The purpose of this meeting is for the NRC staff to meet directly with individuals to discuss regulatory and technical issues. Attendees will have an opportunity to a k question of the NRC taff or make comments about the issue di cu ed throughout the meeting, however the RC is not actively soliciting comments towards regulatory decisions at this meeting.
From:
Sent:
To:
Subject:
Bruce/Tony, Sheehan, Neil Friday, May 28, 2021 2:17 PM Watson, Bruce; 'Dimitriadis, Anthony' FW: Decommissioning and Rubbleization You two definitely work in one of the most active in the agency. Can I get your thoughts on this early next week?
- Thanks, Neil From: Paul Blanch Sent: Friday, May 28, 202112:19 PM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>
Cc: Paul M. Blanch <pmblanch@comcast.net>
Subject:
[External_Sender) Decommissioning and Rubbleization Neil:
I have worked at some decommissioning nuclear plants where "rubbleization"(sp) was employed as a means to "cover up" remaining radioactive material on site after decommissioning. I have searched various sections of 10 CFR and can't locate any discussion of limits, specific or total activity allowed to remain buried and depth requirements.
The only discussion I can find is related to the dose at the surface (25 or 10 mr) of the site. I believe this measurement is a few feet above the ground.
Could you direct me to the location of the NRC regulation that discusses the permitted buried residual activity (not dose) prior to site release by the NRC.
Are the requirements for site disposal similar to those discussed in 10 CFR PART 61-LICENSING REQUIREMENTS FOR LAND DISPOSAL OF RADIOACTIVE WASTE If a licensee can't meet the required surface dose rate is it permissible to bury the activity deeper or cover it with more uncontaminated soil?
What regulations are in place to preclude another "Love Canal" type of situation?
Are there any building, farming or other restrictions imposed on the land vacated by Maine or Connecticut Yankee depicted below?
Sign in to download full-size image F,g 4 MJ,nc Ywkcc S.,tc,n :xlls '11111th a I plantstructurcs rcmO\\'cJ, ISfSI rrm.i n ng (Planet Forw:ml, 1014).
CT Yankee Nuclear Power Plant...
Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast.net Cell 860-922-3119 2
From:
To:
Cc:
Subject:
Date:
Attachments:
Shoop UQdioe Burnell Scott: Suber Greg91Y: Rus:;eu Andrea: Eyans Jonathan* earusone caroUne: Wrona David: ~
fmy: fllilm.JI!!
Screnci pjane: McIntyre Dave: Sheehan Neil FW: ACTION: FOIA NRC-2022-00020
- Fi!!! Estimate Due Nov 23rd Wednesday, November 17, 2021 9:04:48 AM FOIA Assjanment foe NRC-2022-000020 pd{
FYI - from Bia nch From: Kauffman, Lisa <Lisa.Kauffman@nrc.gov>
Sent: Wednesday, November 17, 20218:03 AM To: Shoop, Undine <Undine.Shoop@nrc.gov>
Subject:
ACTION: FOIA NRC-2022-00020 - Fee Estimate Due Nov 23rd Hi Undine, Would you have summaries or transcripts of the meetings described in this FOIA? Or, can you direct me to who would have them? Right now this FOIA is just in the estimate phase asking for (1 ) search time, (2) review time, and (3) approx. page count The estimate is due back to me by 11/23.
Let me know if I should send this to someone else.
- Thanks, L~ ~
, FOIA CctrY~
Reactor Program Services Branch II Division of Resource Management and Administration Office of Nuclear Reactor Regulation FOIA CAC: ZF0000 From: Ellis, Stephan <Stephan Elljs@nrc gov>
Sent: Wednesday, November 17, 2021 7:36 AM To: NRR FOIA Resource <NBBEOIA Resource@nrc ~ov>
Cc: Kauffman, Lisa <Lisa Kauffmao@nrc iPv>; Stevens, Margo <Mamo Steyens@nrc 11ov>
Subject:
RE: NRC-2022-00020 - Fee Estimate Due Nov 23rd Good morning, This requester has been placed in the "non-excepted" fee category, being responsible only for search fees in excess of two (2) hours and duplication costs after receiving 100 pages free of charge. Therefore, your initial fee estimate of search fees and duplication costs is required on or before Tuesday November 23, 2021.
- Please note - The Requester is seeking transcripts or summaries for public meetings held on August 18, 2020, October 20, 2020, and June 8, 2021 relating to the 10 CFR 2.206 process and revisions to MD 8.11. We assume the requester prefers
transcripts, if the meetings were transcribed. So please provide us an estimate to for the transcripts, if they exist. If any of the meetings were not transcribed, please let us know the estimate for the summaries. Of course, if you have both, please let us know that, and include the estimates for each.
Sometimes, we task you for a fee estimate, but your office does nQ1 have responsibility for, or involvement in, the subject matter of the request. If we have misdirected our tasking, please tell us that instead of responding "no records." But, if you (or your staff) actually searched and found no responsive records, please tell us that you searched and found no records. Remember to include the amount of time spent searching (and at what level).
The FOIA request should be processed in accordance with the standard instructions ("How to Respond to an Initial FOIA Request") at ML060590485.
To ensure that search time is calculated appropriately and consistently, ~
is the time spent looking for material subject to a request, either manually or by automated means, including time spent in page-by-page or line-by-line identification of responsive material within records. Searches should identify all paper and electronic records maintained by your office, including records in any file centers or other remote locations, all versions in ADAMS, SharePoint, Nuclepedia, or other shared drives, as well as individual staff members' Outlook, Office, and other computer files, audio and video tapes, and any other media. If you or your staff believes that a Capstone official (in general, Office Directors or above}, may have had records responsive to the request, please remember to include an estimate for a search to CapstoneResource@nrc gov.
Please be sure to distinguish the search time based on the three levels:
SES/Commissioner, professional (technical/managerial}, or clerical. In addition, if any of the search time is expected to be performed by a contractor, please provide a fee estimate for the contractor's search, using the hourly rate the NRC is billed for the contractor's services.
You are encouraged to ask for a scoping discussion with the requester when you believe it would be beneficial.
In addition to tasking any subject matter experts within your office, please ensure that your fee estimates take into account searches of shared platforms, such as ADAMS, SharePoint, shared network drives, and Nuclepedia. You are encouraged to ask for assistance in performing adequate ADAMS searches if you have any difficulty doing a search.
NRC Form 496, "Report of Staff Resources for Processing FOIA Requests," is attached for your use.
Please remember to charge time spent on this FOIA to CAC ZF0000.
Please contact me if you have any questions.
Thank you.
- Regards,
Stephan M. Ellis FOlA Analyst (Pathfinder Consultants Co11tracto1~
OC/0/GEMS/FllC U.S.
uc/ear Regit!ato1J1 Co111111issio11 Mail Stop: TWFN-06A-60M Office Location: TWFN-06-A00 Rockville, Maryland 20555-0001 (301) 415-3655
From:
admio@ro1aon11oe coy Ems. Stephan To:
Subject:
[Extemal_5ender) FOIA Assignment for NRC-2022-000020 Wednesday, November 10, 2021 11: 12:32 AM Date:
You ba e been a ign d to the FOL r que t - NRC-2022-000020. Once logged into FO!Aonlin, you can na igale to this ase by following Lhi link: Y.ie..w_. Additional d tail for thi item are as follows:
- Tracking umber:
R -2022-000020
- Requester: Paul M Blanch
- Reque t Track: imple ubmitted Date: 11 /10/2021
- Due Date:
/ A
- De cription:
hort De cription:
I
- De cription: Three meeting were held with the Public and the NRC related to the 19 CFR 2.206 proce and revi ion to D.1 1. The e meeting took place on Augu I I,
2020* October 20, 2020. r participated in the June, 2021 meeting. Plea e provide a transcript of all three of these meeting or a written summary of the same.
From:
To:
Cc:
Subject:
Date:
Burnell Scott Shoop, Undjne: Suber, Greaorv: Bussen Andrea; Evans Jonatllan: Carusone Caeolioe: Wrona Dayjd: ~
felrt; fllam...Bg Serene; Piaoe: McIntyre Pave: Sheehan Neil RE: ACTION: FOIA NRC-2022-00020
- Fee Estimate Due Nov 23rd Wednesday, November 17, 2021 9:06:00 AM Well, if that's what he wants to talk about, now we know how to answer.
From: Shoop, Undine <Undine.Shoop@nrc.gov>
Sent: Wednesday, November 17, 20219:05 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Carusone, Caroline
<caroline.carusone@nrc.gov>; Wrona, David <David.Wrona@nrc.gov>; Buckberg, Perry
<Perry.Buckberg@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>
Cc: Screnci, Diane <Diane.Screnci@nrc.gov>; McIntyre, Dave <David.Mclntyre@nrc.gov>; Sheehan, Neil <Neil.Sheehan@nrc.gov>
Subject:
FW: ACTION: FOIA NRC-2022-00020 - Fee Estimate Due Nov 23rd FYI - from Blanch From: Kauffman, Lisa <Lisa,Kauffman@nrc.gov>
Sent: Wednesday, November 17, 2021 8:03 AM To: Shoop, Undine <Undjne Shoop@nrc gov>
Subject:
ACTION: FOIA NRC-2022-00020 - Fee Estimate Due Nov 23rd Hi Undine, Would you have summaries or transcripts of the meetings described in this FOIA? Or, can you direct me to who would have them? Right now this FOIA is just in the estimate phase asking for (1) search time, (2) review time, and (3) approx. page count The estimate is due back to me by 11/23.
Let me know if I should send this to someone else.
- Thanks, LlMJ-, K~, FOIA Coor~
Reactor Program Services Branch II Division of Resource Management and Administration Office of Nuclear Reactor Regulation FOIA CAC: ZFOOOO From: Ellis, Stephan <Stephan.Ellis@nrqmv>
Sent: Wednesday, November 17, 2021 7:36 AM To: NRR FOIA Resource <NRRFOIA Resource@occ.iov>
Cc: Kauffman, Lisa <Lisa Kauffman@nrc gov>; Stevens, Margo <Margo,Stevens@nrc gov>
Subject:
RE: NRC-2022-00020 - Fee Estimate Due Nov 23rd Good morning, This requester has been placed in the "non-excepted" fee category, being responsible only for search fees in excess of two (2) hours and duplication costs after receiving 100 pages free of charge. Therefore, your initial fee estimate of search fees and duplication costs is required on or before Tuesday November 23, 2021.
- Please note - The Requester is seeking transcripts or summaries for public meetings held on August 18, 2020, October 20, 2020, and June 8, 2021 relating to the 10 CFR 2.206 process and revisions to MD 8.11. We assume the requester prefers transcripts, if the meetings were transcribed. So please provide us an estimate to for the transcripts, if they exist. If any of the meetings were not transcribed, please let us know the estimate for the summaries. Of course, if you have both, please let us know that, and include the estimates for each.
Sometimes, we task you for a fee estimate, but your office does OQt have responsibility for, or involvement in, the subject matter of the request. If we have misdirected our tasking, please tell us that instead of responding "no records." But, if you (or your staff) actually searched and found no responsive records, please tell us that you searched and found no records. Remember to include the amount of time spent searching (and at what level).
The FOIA request should be processed in accordance with the standard instructions ("How to Respond to an Initial FOIA Request") at ML060590485.
To ensure that search time is calculated appropriately and consistently, ~
is the time spent looking for material subject to a request, either manually or by automated means, including time spent in page-by-page or line-by-line identification of responsive material within records. Searches should identify all paper and electronic records maintained by your office, including records in any file centers or other remote locations, all versions in ADAMS, SharePoint, Nuclepedia, or other shared drives, as well as individual staff members' Outlook, Office, and other computer files, audio and video tapes, and any other media. If you or your staff believes that a Capstone official (in general, Office Directors or above), may have had recoirds responsive to the request, please remember to include an estimate for a search to CapstoneResource@nrc gov.
Please be sure to distinguish the search time based on the three levels:
SES/Commissioner, professional (technical/managerial), or clerical. In addition, if any of the search time is expected to be performed by a contractor, please provide a fee estimate for the contractor's search, using the hourly rate the NRC is billed for the contractor's services.
You are encouraged to ask for a scoping discussion with the requester when you believe it would be beneficial.
In addition to tasking any subject matter experts within your office, please ensure that your fee estimates take into account searches of shared platforms, such as ADAMS, SharePoint, shared network drives, and Nuclepedia. You are encouraged to ask for assistance in performing adequate ADAMS searches if you have any difficulty doing a search.
NRC Form 496, "Report of Staff Resources for Processing FOIA Requests," is attached for your use.
Please remember to charge time spent on this FOIA to CAC ZF0000.
Please contact me if you have any questions.
Thank you.
- Regards, Stephan M. Ellis FOIA Analy t (Pat~f,nder Con ultant Contractor)
OCIOIGEMSIFLIC U.S. Nuclear Regulatoty Commission Mail Stop: TWFN-06A-60M Office Location: TWFN-06-A00 Rockville, Maryland 20555-0001 (301) 415-3655
From:
Sent:
To:
Sheehan, Neil Wednesday, August 25, 2021 1:03 PM Watson, Bruce; Sturzebecher, Karl
Subject:
FW: Re: Indian Point PSDAR Meeting FYI It's not clear to me why he thinks I misinterpreted his request.
From: Paul <pmblanch@comcast.net>
Sent: Wednesday, August 25, 202111:57 AM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>
cd (b)(6) f b......
)(6.,...
) _
___.~
Bartley, Mallon <Malion.Bartley@nrc.gov>
Subject:
[External_Sender] Re: Indian Point PSDAR Meeting Neil Thank you and I will be responding to your note below. It appears you have misinterpreted my request. We will be making a formal request to either directly to the commission or the executive Director for operations for a question and answer round table type of meeting Described in the recent revised NRC policy Paul Sent fr,om my iPad On Aug 25, 2021, at 10:39 AM, Sheehan, Neil <neil.sheehan@nrc.gov> wrote:
- Paul, The Commission Policy Statement on Enhancing Participation on NRC Public Meetings, published on March 19th in the Federal Register, redefines the three categories of public meetings offered by the agency. It also identifies the level of public participation offered at each category of meeting. Your request indicates that you are interested in another session that would fall under the category of "Comment-Gathering Meeting". The Federal Register notice cites as examples of such meetings town hall and roundtable discussions, environmental impact statement scoping meetings and workshops.
We would like to point out that both our public meeting on July 29th in Tarrytown, N.Y., and our virtual meeting on Aug. 18th were conducted specifically to solicit public comments on the Post-Shutdown Decommissioning Activities Report, or PSDAR, for the Indian Point nuclear power plant. We received dozens of public comments at these meetings, as well as during a government-to-government meeting held on July 29th* As part of our review of PSDARs, we have a mandate to hold public comment-gathering meetings and we have conducted these for each and every plant entering the decommissioning process. In addition, we held a public webinar in the spring of 2020 to educate the public about the decommissioning of Indian Point and our inspections and reviews associated with those activities.
Your request for a roundtable or town hall meeting regarding the Indian Point decommissioning plans would go above and beyond those interactions and we currently have no plans for such a session. Your request will be considered by NRC senior management and we will inform you of any changes. However, as of now, our focus will be on considering the large number of public comments already provided. And we would note that the window to submit written comments on the Indian Point PSDAR will remain open until Oct. 22nd*
Neil Sheehan NRC Public Affairs (610) 337-5331 From: Paul Blanch <pmblanch@comcast.net>
Sent: Friday, August 13, 202110:15 AM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>
Cc: Paul M. Blanch <pmblanch@comcast.net>
Subject:
[External_Sender] Indian Point PSDAR Meeting Neil I heard a rumor there is going to be another meeting due to techinical problems with the last one. Any truth to this rumor?
When can I expect a response to my questions on the new NRC Policy on open meetings with the public?
Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast.net Cell 860-922-3119 2
From:
Sent:
To:
Subject:
8609223119 Attachments:
Hi, Shoop, Undine Thu, 18 Nov 2021 21:38:37 +0000 Burnell, Scott;Screnci, Diane;Sheehan, Neil Info on for Mr. Blanch meeting - FW: Voice Message From: WIRELESS CALLER, Public Meeting Transcripts.docx I wanted to forward the attached in case it helps with our discussions with Mr. Blanch. Andrea went through the two transcripts (only the 2 and 3 meeting were transcribed) and extracted Mr. Blanch's comments.
- Cheers, Undine From: Russell, Andrea <Andrea.Russell@nrc.gov>
Sent: Tuesday, November 16, 202111:03 AM To: Buckberg, Perry <Perry.Buckberg@nrc.gov>; Carusone, Caroline <caroline.carusone@nrc.gov>;
Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine
<Undine.Shoop@nrc.gov>
Cc: Wrona, David <David.Wrona@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 So I found the October 20, 2020 and June 8, 2021 transcripts and extracted Paul's comments (including a few responses we provided him at the meeting). I could not find the other transcript to the first meeting. Forgive any formatting issues.
From: Buckberg, Perry <Perry.Buckberg@nrc.gov>
Sent: Tuesday, November 16, 2021 9:32 AM To: Carusone, Caroline <caroline.carusone@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine
<Undine.Shoop@nrc.gov>
Cc: Wrona, David <David.Wrona@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119
- Folks, To help show the bigger picture of Paul Blanch's agency interactions, attached is a letter dated November 12, 2021, from Paul Blanch to the EDO regarding his dissatisfaction with recent SONGS related interactions (petitions and letters).
- Thanks, Perry
From: Carusone, Caroline <caroline.carusone@nrc.gov>
Sent: Tuesday, November 16, 2021 9:17 AM To: Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>
Cc: Wrona, David <David.Wrona@nrc.gov>; Buckberg, Perry <Perry.Buckberg@nrc.gov>; Pham, Bo
<Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 I'm just throwing this out there for consideration... and I'm hesitate to provide additional "escalation channels,* but-would there be any benefit in either Dave Wrona or I reaching out to him? We would be "new* to this discussion and perhaps having someone that he perceives is less biased might help? On the other hand, he might find it frustrating that there are new players. Thoughts?
From: Russell, Andrea <Andrea.Russell@nrc.gov>
Sent: Tuesday, November 16, 2021 9:02 AM To: Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undlne.Shoop@nrc.gov>
Cc: Carusone, Caroline <caroline.carusone@nrc.gov>; Wrona, David <David.Wrona@nrc.gov>; Buckberg, Perry <Perry.Buckberg@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 So Jonathan got another call this morning. I truly think someone (Gregory or Undine?) needs to reach out to Paul sooner than later. As for the transcripts, I don't see how we could ask Perry to go through the transcripts since Perry wasn't part of the WG. I can go through the transcripts if needed.
From: Suber, Gregory <Gregory.Suber@nrc.gov>
Sent: Monday, November 15, 2021 5:46 PM To: Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>
Cc: Carusone, Caroline <caroline.carusone@nrc.gov>; Wrona, David <David.Wrona@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119
- Jonathan, I believe Undine or I should call Mr. Blanch. He has contacted Senator Gillibrand and we have a briefing with her staffers tentatively scheduled for December 2nd. I need someone - hopefully the current 2.206 PM - to extract Mr. Blanch's comments from the transcripts of our public meeting. He has informed the Senator that we were not responsive to his questions and comments.
I do not think you or Andrea should engage him since we have permanent staff work on 2.206.
We should handle this within DORL.
- Thanks,
From: Evans, Jonathan <Jonathan.Evans@nrc.gov>
Sent: Monday, November 15, 2021 5:07 PM To: Suber, Gregory <Gregory.Suber@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>
Subject:
Fwd: Voice Message From: WIRELESS CALLER, 8609223119 Hey all, I am on travel right now. Are any of you able to respond to Paul?
Get Outlook for iOS From: WIRELESS CALLER <tel=8609223119@officelinx.nrc.gov>
Sent: Monday, November 15, 2021 7:04:00 AM To: Evans, Jonathan <Jonathan.Evans@nrc.gov>
Subject:
Voice Message From: WIRELESS CALLER, 8609223119
October 20, 2020 Meeting Paul Blanch: Good afternoon David and all those other people. I've got no questions, but I have very significant comments. Being that I was the initiator of this whole thing with the Inspector General and the author of the 2.206 petition, I probably have significant knowledge. At the beginning of the meeting, the words "public confidence in the process" were mentioned. From my relationship with those people that have submitted 2.206 petitions, I think if you want to improve public confidence you should find out what public confidence those people over the past number of years have in this process. I know if you asked me, my confidence is zero.
Now, let me first of all get to an issue that has not been properly resolved. If we look at the OIG Event Inquiry, I think it's16-024 whatever. I was working on it this morning and this is something everyone's got to take to heart. In that OIG Event Report or Inquiry, there were 14 times it mentioned that inaccurate information was provided by the NRC, primarily to me. There was also one or two statements that talked about how the NRC misrepresented information. Now I would have thought after my discussions with Dave Skeen and everything, that that would have raised a flag, and we, the NRG, would have really determined a way to make sure that anything that is sent to the petitioner is accurate, complete, so on, and so forth. Now a petition was filed on February 4th by Public Watchdogs and, of course, I was the author of that. That petition had to do with flooding of the FSC system with 73 canisters being potentially flooded. We received a letter from Kevin Williams, dated September 1st of this year, that contained incredible amounts of inaccurate and incomplete information. Totally, totally bogus. Regarding that letter, as you have previously discussed before it went out, I would have expected some type of interest independent review to assure that the rejection of the petition was properly justified by the references provided in the rejection letters. We will have a response to that. However, again, after all of this and everything I have been through with Indian Point, the Inspector General, and everyone that's been involved here, we're still getting inaccurate, incomplete, and in some cases, intentionally misleading information. That's a serious accusation that I'm making, and I'll deal with that. When the NRC is either rejecting or proposing to reject a petition, which is my case here on that September 1stletter, or the final director's decision, what assurance do we have that the information provided in these documents is in fact complete and accurate? As of September 1st, the NRC continues to intentionally mislead members of the public and the millions of residents, especially around the San Onofre Plant. We had ii with the Indian Point Plant, but it's just Deja vu and the NRC needs to look at that. I will be outlining all the false information that was provided by the NRC in a response within the next week. It's incredible. We have technical specifications that are obsolete, and these are referenced in the response that absolutely cannot be met. These are legal licensing documents whereby the NRC is misleading us, the public, myself, and my client and nothing has improved. I apologize for sounding so negative, but I've been working on my response to Mr. Williams' letter for the past few days and interfacing with other federal agencies. That's all (unintelligible).
Scott Burnell: Paul. Thank you, Paul. Again, Scott Burnell from Public Affairs. Whenever you submit your letter, the staff will review it. They did take a great deal of lime in putting together an extensive letter closing out the petition and the staff does stand by that. Do you have any specific?
Paul Blanch: (Unintelligible).
Scott Burnell: Was it a question regarding the recommendations that we're discussing today?
Paul Blanch: Absolutely, the petition was not closed out. It was just rejected. So, it was never even accepted.
Scott Burnell: That is one of the potential outcomes of the process. The staff can determine that a petition is not suitable for review. So again, do you have any questions or comments on the recommendations that we're discussing today?
Paul Blanch: My comments are the NRC has got to look very carefully. I think David Skeen mentioned it. They have to look, very carefully, at the proposed response to a petitioner to assure its accuracy. This has not been done and it's got to be done.
Scott Burnell: We'll take that as a comment. Thank you, Paul.
June 8, 2021 Meeting Coordinator:
Thank you. Our first question comes from Paul Blanch. Your line is open.
Paul Blanch: Well, thanks very much for this opportunity. This is the first meeting that I've heard about on the 2.206 process. I think in some respects you are missing the boat.
I was obviously the one who initiated the OIG investigation and numerous meetings with them as I'm sure the NRC staff has had with them.
Subsequent to the report that came out in February of last year, I spent quite a bit of time working with David Skeen and his executive management team on recommendations, primarily on technical issues. I've also had a few meetings with Petition Review Boards.
And again, I don't think that what is being proposed here is going to address the questions I have and certainly some other people have who are not on this particular phone call.
One or two of the issues that were clearly identified in the Inspector General report but never addressed in any of your slides. Our statements in the IG repont, such as the NRC provided an inaccurate description of the work the NRC conducted to assess the stakeholders' concern.
Inaccurate information, you know, as a licensee we have either 50.5 or 50.9. And when a licensee submits inaccurate information to the NRC, there are sanctions and civil penalties and criminal penalties that could be imposed on the licensee.
Now here we have the NRC providing what I call a politically correct name, inaccurate, incomplete information to the public that the NRC serves.
And here we have a meeting to address some of the issues, or the major issues, in the OIG report. To me, this is one of the major issues and how do we stop the NRC from putting out inaccurate information which, if it went the other way, sanctions and criminal penalties could occur?
The other statement that the OIG report said, NRC misrepresented the assumptions using the follow-up bounding analysis. Again, we're talking NRC putting out bad information to the petitioner.
Something needs to be done. It needs to be done and sanctions need to be imposed on those people that are responsible. This is not acceptable to me as a member of the public.
Now, moving on to some of the other issues I have. And I received - well I have two Petitions essentially open. One has to do with the flooding analysis San Onofre Nuclear Power Station in California.
That Petition was rejected because the NRC determined it was a previously analyzed event.
Nothing could be further from the truth. How do we prevent the NRC from making these false statements, and I do mean false statements, and incomplete information to the petitioner?
I mean, the BS that was put out in the Kevin Williams September 1st letter was just absolutely incredible, inaccurate, incomplete. We need to stop that.
The second Petition was submitted in October of 2020. This Petition is also being rejected on the same basis. We've had a preliminary rejection already by email.
And the other thing this group rnally, really needs to take a careful look at, 2.206 clearly stated, whether I agree with it, but it is a rule, that for a petitioner once there is a director's decision, there Is no appeal by the petitioner.
The NRC in some of their communication with me has inferred that the non-acceptance of a Petition cannot be overruled, appealed, reconsidered or anything else. That is not stated in the rule itself, 10 CFR 2.206.
Another problem we have, when we have a problem, a safety problem, regulatory compliance or any problem, be it a family problem, a problem with our children or whatever, we always find that a dialogue works best.
Now we went through within the past two months a two hour presentation with the NRC and the Petition Review Board on the issue of credible events and not credible. And I believe it was 18 times I was told I am not allowed to ask any questions.
That just shuts off any dialogue. That has got to be resolved. In your Management Directive 8.11, it allows the licensees to ask questions as well as other participants in the meeting. But the petitioner who has the concern, and I was told emphatically eight times, we have a video of it, that we cannot ask questions.
How can we solve a problem, and we do have outstanding two major problems, the one on the flooding of San Onofre and the one on the definition and how is it used for credible events?
I have a simple question that I want to ask and that has to do with a dry cask. I talked to Andrea Kock and asked her what is the impact should the canister that contains the spent fuel should it lose its helium overpressure. And she said, I can't answer that because it's in the 2.206 process.
Now, here we have a Catch-22. Directors can't answer my question. They tell me go through the 2.206 process. I go through the 2.206 process, and what am I told? We can't answer any questions.
So the resolution, I believe, that if a Petition either, well, is not accepted for consideration because it has been whatever the reasons are given in Management Directive 8.11, analysis has already been conducted.
If that is going to be the NRC's position that the analysis has already been conducted, that analysis, or at least the summary - now I agree or admit that on the flooding analysis Holpak has determined it not to be proprietary, that doesn't prohibit the NRC attesting to the fact that
here are the results. Here's a summary of the results of the analysis and this is why your Petition is rejected.
All I get in the rejection is that analysis has already been conducted. That is not the right way to do business. We both have problems, both the NRC and us members of the public. And if we can't have an open dialogue to discuss the problems, all we're going to do is lock horns and bang heads. And that's what we've been doing.
And it was the OIG report that alluded to some of these facts that are not being addressed. And I just read some of them to you. Go back to the OIG Report 16-024. And don't cherry pick the easy problems. Go to the big problems where the NRC is putting out misinformation, inaccurate and incomplete information and in my words absolute lies.
What is being done as far as sanctions to those people that are causing this and what is being done to prevent that from recurring? Again, those are the major issues I have.
It's Just that every time, and I've probably in my life over the last 30 years submitted maybe 8 or 10 Petitions, some of them accepted and some rejected, but all of them obviously have been rejected by the director. We as the public just don't stand a chance.
Look at the statistics that I presented. Back in 1993 based on an Inspector General's report and my testimony before the U.S. Senate, only two Petitions out of 400 plus were ever accepted.
And the numbers have gotten worse since that time.
We need to change the process. Don't pick the low hanging fruit that you're doing right now. Get to the root cause of the process and the problem. Get the NRC to tell the truth.
And if they're going to say an analysis has already been conducted then provide a copy of the analysis or a summary of the analysis if it happens to be security related or proprietary information but just don't tell us. We put a lot of time and trouble into these Petitions, believe me.
And I know we cause a lot of heartaches and headaches with the NRC. But when we get to this stonewalling each other - and I think I've been open as indicated by my communication with the OIG and Dave Skeen's team and the PRBs and so on and so forth, I've been more than cooperative. I've been open.
And I get Mr. Williams up there telling me in a somewhat controversial manner, Mr. Blanch.
You're not allowed to ask any questions, that's not part of2.206. That's part of the 8.11 process that was developed. And I know this to be a fact in conjunction. by - well first of all by the NRC and in conjunction with NEI, which at the time might have been NUMARC.
So the public is blocked, totally blocked in public meetings. This is the only time I've had a chance to fully vent. And if I sounded too harsh, I apologize. BUJt I think I've got good points. I've got valid points. And I hope that the NRC will take these points very seriously.
They are being transcribed. This transcription will be circulated. And I thank you for your time.
And I'd like to hear what the other commenter has to say. And I am done. And again, thanks again for your time.
Brett Klukan: Thank you very much, Mr. Blanch. I'm going to turn it over to Greg for a response. So with that, Greg or Gregory.
Gregory Suber: Hey, so I will kind of respond at the end. And I'm just willing to forego that for right now and listen to the comments from the other commenter. But I have taken some notes and I am going to address some of Mr. Blanch's points, which I really appreciate.
Gregory Suber: Okay. Yes. So thanks, Brett, and I appreciate the question. And, you know, so I'll just kindly remind everyone what this meeting designed for is to address the proposed changes that we have set forward for the 2.206 process.
And I understand that there is some curiosity regarding specific 2.206 Petitions in the way the technical staff has dispositioned those Petitions. But this just isn't the forum for us to address those specific questions.
What we're really talking about today, and the input that we were looking for today, was on the proposed changes that we are making to this process, some of which were changes in response to the IG report and the subsequent evaluation from the task force and others were changes in response to the other two public meetings that we held.
And so that's the focus of this particular meeting and that's what I would like to respond to. So Mr. Blanch raised a couple of really good points when he was talking about the IG inquiry and the resultant evaluation report from the expert staff, from the expert panel.
And one of the things that we did in response to that is we looked at the information and how it was being communicated in the process. And we did find some disparities. We found some information that was reported that wasn't properly documented.
And so we looked at our process and we made two pretty significant changes to what we are doing for 2.206 Petitions. And one of those changes is explicit direction to the staff in providing documentation during a 2.206 process.
And what the core team Is designed to do is to make sure that that's going to be done consistently moving forward for every 2.206 Petition that the agency receives so that proper documentation is being addressed under the auspices of revising this process.
And the other thing that we're doing is Incorporating where practicable and appropriate peer reviews so that people who were not connected to the original assessment can take a fresh look at what was done in that Petition to give it a second peer review or a second check.
And in addition to that, if the expertise doesn't exist within the staff to verify that, meaning if the experts from the staff were used to generate the report, we've opened the option for ourselves to decide if it would be appropriate for us to elicit the help from contractors, which we do throughout the agency, throughout every technical division within the NRC and to give us that qualified second look.
So there were a number of changes that we made to address the OIG's concern on document accuracy and inconsistency. And so I wanted to make sure I made those clarifications.
And I know that there is a lot of interest in SONGS and there is a lot of interest in other technical portions of what we do. But this is not the meeting for us to address those concerns. So we'll have to table that for another time and maybe go back and look and decide as a staff what would be the proper forum for us to discuss, you know, particular technical issues.
And it will probably be in the disposition of those specific concerns with the Petition Review Board. But it's not in this meeting, which is laser focused on just the process. That's it.
Paul Blanch: Thank you very much, Greg. I just have some comments on what you just said.
You referred to peer review. I'm not sure what a peer review is. But I have followed nuclear safety culture and, you know, all the stuff on nuclear safety culture, both within the NRC and outside the NRC.
And we can, you know, look at NRC people that have been persecuted. Having a peer review by NRC personnel with the culture that exists, almost everyone, at least at a high level, if they ever want to progress, will ever disagree with management's desires. The culture is horrible.
And that peer review should actually be done by someone independent of the NRC.
The other thing, Greg, that yoUJ mentioned is, here we go on a Catch-22. You said something along the lines this is not a forum to answer questions. Well, I think I talked about that before.
The PRB Is not a forum of answer questions. This session, which is at a higher level, revising 8.11, this is not a forum to ask a question. Something needs to be in 8.11 which will facilitate or allow a dialogue between the petitioners.
Now someone just - Greg, I think it was you that made a statement that everyone was in agreement that the pipeline is safe, the pipeline interaction with the nuclear plant at Indian Point.
Once the plant has been shut down, I believe that the probability of a major catastrophic accident is acceptable where we are right now. Prior to its shut down a little over a month ago, that plant was not safe. And it was not safe, as I've told the NRC, and again could never have a dialogue was if there was an explosion of the lines go through tfhe site 400 feet from the NR3 control room that unignited gas going into the control room could ignite in the control room and that would be catastrophic.
In response I get from the NRC well, the operators would smell the gas and take some action.
That didn't go over well with me. But the other even more important thing is the switch gear room was located right below the control room and should unignited gas get in there and be ignited by sparks and motors a,nd switchgear and so on and take out the switch gear room, we have a disaster. There is no doubt about it.
And I think that someone now making a statement that the OIG or whomever determined that the Indian Point interaction demonstrated it was safe is just another misleading statement and how do we prevent those types of statements?
And my last comment is Geri and I, Geri Shapiro and I have known one another for a long time.
And I wanted to thank Geri Shapiro and the Senator for their interest in this very, very important topic. And whatever the Senator could do to allow open communication between concerned members of the public and the NRC would certainly be of help to all of us and for public safety.
And with that I'll shut my long winded mouth. Thank you very much.
From:
To:
Cc:
Subject:
Date:
Russell. Andrea Suber Gregory: Shoop und,ne Evans Jonathan RE: Just got phone call and voicemail from Paul Blanche Friday, November 12, 2021 12:09: 57 PM He apparently left one for Jonathan as well. Let me see if I can figure out how to forward it since it is on my cell phone (went to my cell voicemail instead of work).
From: Suber, Gregory <Gregory.Suber@nrc.gov>
Sent: Friday, November 12, 202112:44 PM To: Russell, Andrea <Andrea.Russell@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>
Subject:
RE: Just got phone call and voicemail from Paul Blanche
- Andrea, I have not. You can forward the call to me. Not sure what actionable task will come out of it.
From: Russell, Andrea <Andrea Russell@occ gov>
Sent: Friday, November 12, 202112:25 PM To: Shoop, Undine <Uodioe Shoop@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Subject:
Just got phone call and voicemail from Paul Blanche Regarding the SECY that was issued. I'm off this afternoon. Have you all received any phone calls from him? Should I call him back?
Andrea Russell Safety and Plant Systems Engineer ticlear Regulatory Commission RR/DSS/STSB 301-415-8553
From:
Burnell Scott To:
Morris Scott: Williams Keyin
Subject:
FVV: Fwd: Letter to David Victor Chair San Onofre CEP Thursday, April 01, 2021 3:39:00 PM Date:
Attachments:
Final Slaned letter to David Victor CEP.odf oastedGraohic.onQ pastedGra!)hk: 1.png DastedGraohic 2.1mo Hi Scott; FYI -- Blanch has also submitted the questions (not the discussion of the conduct of the meeting) to the 2.206 petition review board.
Scott From: Paul Blanch <pmblanch@comcast.net>
Sent: Thursday, April 01, 2021 2:08 PM To: Burnell, Scott <Scott.Burnell@nrc.gov>; Morris, Scott <Scott.Morris@nrc.gov>
Cc: Paul M. Blanch <pmblanch@comcast.net>; Charles Langley <langley@publicwatchdogs.org>;
(b)(6)
Subject:
[External_Sender) Fwd: Letter to David Victor Chair San Onofre CEP
Dear Scotts:
FYI Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblaocb@comcast net Cell 860-922-3119 Begin forwarded message:
From: Paul Blanch <pmblanch@comcast.net>
Subject:
Letter to David Victor Chair San Onofre CEP Date: March 31, 2021 at 6:01:32 PM EDT To: dayid yictor@ucsd edu Cc: "Paul M. Blanch" <pmblaocb@comcast net>, l._(b_)(_6) ____ ____.l mmcnicholas@capousd org. Lisa Bartlett@ocgov com, garry@coastkeeper org.
Jim Desmond@sdcounty ca goy, DuncanC@sao-clemente org.
Rob Howard@uwua246 com,!"'"(b...;.)('-'6) ______________
!(b)(6)
~ jtaylor@sanjuancapistrano org. info@slrmjssjonindlans ore.
m11illar@danapoint org
Mr. Victor:
Per your invite to write to you during the recent CEP meeting. please see enclosed letter to you as Chair of the San Onofre CEP. Please feel to share with other panel members.
Wednesday, March 31, 2021 Dr. David G. Victor Paul M. Blanch PE Energy Consultant Chair, SONGS Community Engagement Panel UC San Diego School of Global Policy & Strategy RBC #1405, 9500 Gilman Dr. #0519 La Jolla, California 92093-0519
Dear Dr. Victor and the SONGS Community Engagement Panel (CEP) members:
I am responding to your kind invitation to write you regarding basic unanswered safety questions on behalf Public Watchdogs.
You will recall that prior to the SONGS Community Engagement Panel meeting on March 18, 2021, I sent three questions in advance using the posted links in the slide shown at left below. My understanding was that these questions and comments would be addressed first. The questions were passed on to SCE and then conveniently "ducked" without any truthful response.
Opffl."11 Commet1t:1 DmlVlclOt
===--=--=-~ --
(View the this slide oo page 4. at MPrJJbo fy{JlQEUliOJ Statement ill ht!m/&il IY{3cyr1YP, mOJte 1:10:52 of Mal rmcfm.
Near the end of the meeting, at Minute 1:10:52 of the proceedings. you stated:
"I sow a bunch of comments about Poul Blanch not being able to speak. When he submitted his questions in advance, he said he didn't want to speak, so I would urge Mr. Blanch ta send me a letter about his concerns, I'll make sure that gets addressed. And I'll also make sure that he's on the list far ihe next meeting."
I would appreciate your source of what I believe is the false information you stated in this video. At no time did I request that I not be asked to speak. My hand was raised during the public comment period. In addition, I pleaded in the "chat room" that I wanted to speak. During the meeting I also called Charles Langley and asked him to alert the CEP in the "chat room" that I was anxious to correct the false information being put forward by Edison.
Mr. Langley's chat room requests were Ignored, along with the requests of at least four other members of the public who were asking that I be allowed to address the CEP.
Equally troubling, John Dobken, Southern California Edison's media relations officer, posted a link to derogatory article that he has written about Public Watchdogs and myself in the comments section. In my opinion, this was an intentional effort by Mr. Dobken to conceal the large number of chat room requests to the Community Engagement Panel. This action alone by Mr. Dobken, confirmed that Edison was fully aware of my requests and failed to inform the CEP of my desperate desire to correct the false information communicated to the CEP and the public.
I am alerting you to these events, because in addition to Edison's established practice of lying to the public.
These are the sort of shameless public relations shenanigans that have deepened public mistrust of Southern California Edison, and the dedicated public servants who serve on the CEP.
Understandably, the Community Engagement Panel deflected my questions to Southern California Edison, which failed to provide a logical, coherent response. For example, when Mr. Bauder passed Question B to his staff, the staff's answer had nothing to do with the question. Further, in response to questions A and B, Mr. Bauder simply stated that canister failure was not credible.
For the record, these are the questions I asked prior to the CEP meeting:
Question A: The words "not credible" appear in numerous SCE docketed communication with the NRC and now with the CEC. How does SCE define "not credible" and for what time period is this claim valid?
Question 8: The Technical Specifications require equipment to be readily available to recover from a flooding event within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. I have a copy of the ISFSI Emergency Plan for SONGS (FOIA 2021-000114) but it does not mention any flooding recovery equipment such as pumps, water supplies, high temperature hoses, radioactive liquid disposal and training to recover from the potential flooding of 73 canisters.
Question C: If thP 1JnrlPfinPrl "nnt uPrlihlP"flnorling PVPnt n~rnr~. ;irp ~()N(;S pPr~nnnPI trained to respond to a criticality event?
The reason for these questions: The licensee has submitted its Final Safety Analysis Report (FSAR) and its Certificate of Compliance (Coe) for the ISFSI. The NRC approved these documents. Within these documents the licensee has stated numerous times that failure of the Holtec canisters is "Not Credible." This "not credible" determination is in response to the integrity requirement of 10 CFR 72.236(1), which allows Southern California Edison to dodge any and all of the requirements needed to assure integrity. Further, the NRC has formally declined to answer these questions.
Accordingly, I request that the Community Engagement panel secure competent answers to the following questions.
QUESTION 1: How does the licensee define "Not Credible" and what analysis has been conducted to support this statement?
Reason for this question: The devious use of the term "not credible" without any regulatory definition allows Ed1son/Holtec and the NRC to avoid addressing the design requirements of 10 CFR 72.122 and 10 CFR 72.236 and all requirements for Aging Management.
QUESTION 2: Does the licensee have equipment such as pumps, special high temperature hoses and disposal provisions for radioactive water and pure water supplies, readily available? Is there also sufficient time to prevent fuel damage that will occur within either 8 or 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> according to the Final Safety Analysis Report (FSAR)?
Reason for this question: In the FSAR Technical Specifications (TS), Southern California Edison discusses recovery from an analyzed flooding event as involving the insertion of some type of suction device to remove water and debris. This procedure is allegedly discussed in the site emergency plan.
QUESTION 3: What is the radiological impact of an inadvertent criticality in the event of flooding and loss of canister integrity due to this flooding event?
Reason for this question: In an official email from the NRC to Tom Palmisano RE: "Criticality impact of thin-wall dry storage canisters" sent Thursday, December 21, 2017, at 2:15:00 PM the NRC stated:
"the criticality safety control during storage does rely on the exclusion of water from the canister, and that is what led the NRC staff to ask Ho/tee to evaluate how criticality will be prevented." (emphasis ours)
After a detailed review of the published video and the deceptive information being conveyed to the public, you should be very concerned about your continued leadership of the panel that "is intended to serve as a conduit for public information and encourage community involvement and communication with the SONGS Co-owners on matters related to SONGS decommissioning." My concern is your independence from Edison is questionable.
I have been a member of decommissioning panels and/or conducted formal presentations before these panels. None of these panels were financed by the utility. All of them in contrast to the CEP, had some type of formal oversight from State Regulatory bodies.
I am concerned that the CEP is not truly "independent." The Community Engagement Panel is 100"/o funded by Southern California Edison. Aside from a handful of elected officials, the panel members are hand-selected by Edison using a charter written by Edison. This structure makes it impossible for the CEP to exercise truly independent oversight of decommissioning activities at San Onofre.
My goal is similar to the of the CEP charter. I want to assure that the San Onofre spent fuel is consistent in meeting the NRC's stated goal of "Protecting the Public and the Environment."
I believe it to be reasonable to inform members of the risks presented by the spent fuel and regulatory compliance identified in 10 CFR 72 and 10 CFR 71.
I am more than willing to make a presentation to the CEP at any time to provide my perspective of the risks associated with the storage of the spent fuel at San Onofre. On March 18, 2021, I along with Public Watchdogs, made a formal presentation to the NRC about San Onofre risks. I am also willing to present this vita I information to the CEP should there be any Interest.
I am formally requesting finally an apology from you and some assurance the CEP will commence operating as an independent panel.
I look forward to your prompt response.
Sincerely, Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 omblaocb@comcast net 860-922-3119 CC: Daniel T. Stetson President and Chief Executive Officer, Ocean Institute Martha McNicholas, Capistrano Unified School District Board of Trustees Michelle Anderson, Orange County Sheriff's Department The Honorable Lisa Bartlett, Fifth District Supervisor, County of Orange Garry Brown, President and CEO, Orange County Coastkeeper The Honorable Jim Desmond, San Diego County Board of Supervisors The Honorable Chris Duncan, City of San Clemente
Rob Howard, President, Utility Workers Union of America, Local 246, AFL-CIO Sam Jammal, community liaison officer Marine Corps Installation West Valentine "Val" Macedo, Laborers Intl. Union of North America - Local 89 Marni Magda Community College Professor, ret.
Edward "Ted" Quinn, President, Technology Resources, Consu lting and Nuclear Industry Mgmt.
Mark Riddlebarger, Emergency Manager, California State Parks, Orange Coast District The Honorable John Taylor, former Mayor of San Juan Capistrano Captain Mel Vernon San Luis Rey Band of Mission Indians The Honorable Michael Villar. Council Member City of Dana Point Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast net Cell 860-922-3119
From:
To:
Burnell Scott Williams Keyin
Subject:
FW: Fwd: List of attendees for 3/9/2021 PRB meeting with Public Watchdogs Thursday, March 11, 20211:58:00 PM Date:
Attachments:
Attendee List fOf 3-9-2021 PRB Meetino.od1'.
I'll resist the urge to suggest he review the YouTube video, where we introduced ourselves.
From: Paul Blanch <pmblanch@comcast.net>
Sent: Thursday, March 11, 20211:44 PM To: (b)(6)
!(b)(6)
Cc: Paul M. Blanch <pmblanch@comcast.net>; Burnell, Scott <Scott.Burnell@nrc.gov>; Charles Langley <langley@publicwatchdogs.org>
Subject:
[External_Sender) Fwd: List of attendees for 3/9/2021 PRB meeting with Public Watchdogs How would I find the titles of these NRC personnel?
Paul Blanch pmblanch@comcast net 860-922-3119 Begin forwarded message:
From: Charles Langley <lang!ey@publicwatchdogs.org>
Subject:
Fwd: List of attendees for 3/9/2021 PRB meeting with Public Watchdogs Date: March 11, 2021 at 11:58:17 AM EST To: Paul <pmblanch@comcast net>, "Stuart Scott {Stuart Scott)"
l(b)(6)
Forgive me if I have sent this list twice. - Charles
Forwarded message ---------
From: Liu, Tilda <Tilda Lju@nrc gov>
Date: Wed, Mar 10, 2021, 10:44 AM
Subject:
List of attendees for 3/9/2021 PRB meeting with Public Watchdogs To: Charles Langley <langley@publicwatchdogs org>
Cc: Burnell, Scott <Scott Burnell@orc gov>
Mr. Langley.
I learned from Mr. Scott Burnell that you were looking for a list of attendees of
the PRB meeting with Public Watchdogs, held on 3/9/2021.
Attached contains the names of those who were in attendance.
Tilda Liu, Petition Manaaer Division of Fuel Manaaement (DFM)
OHice of uclear Material Salety and Saleauaids 181 R-II I ii 404-997-4730 I Lido I.iunrc,13ov
v Pirtioplnt:1(174)
Q """'
v hnckt;22 Hl O ~ln1WIJ'..
T'o Q Tidal.&I 0
CM () Ch!tles Momsol'I j
AA Q Ailoflfllytq M Q Ar$N!Coci CW Q Ow18PubkW.lchdogl D
UI O ci.*OIJln'I~
00 /) 0-,,".i!OuM OM00...1<<1nty1e c.~ /)Q,goryS....
JMi I).klhfl~
KW I) Ke.in WillltM 0
lH O t&Lf Hltndiln ttll)lnct,a~
NII'- N!n.841oitr P8 I') Pei;l&n:h D
- PII I) ~k.kberg MCltoblrfturpffll"'
kSltobtirt.SUn SB I) Scon &mel ss StiatSron VD/)YoifiOilril:
Attt nde, Lu,t
- 0 I) --
~W.tdt AC....
--Ult I)....,...,_n NIA I)....,..,,,..
NIA I) _,.,.,..
NIA Attend~Ltst
'-t1*H
.. 0 I) t.rt...-11~...
I)... blriljily I)
... blf,1'welrf!lll Ob.t.""5' lnvlron, I) --
lodt* Jt"'tyl
'-:~Nofth#llt I)
MlnWf'9't CINfllghl l!~t I) -*-
Ol.~+1,~...
Benj Clarke Berton Moldow Anendee ltSl
- 0
., -,~
I) c.d51.11*
E<0Ac!MI01 I),__
NIA 0 """'""""'
NIA I) c....w.....
0 --
Siln.-i Cl.lb fNC G.
I) Ullo"""
NIA I)
ChtrtHCi19()1rt NIA Chuck Anders - Strategic Initiatives
AttMdffllst
/) =-
() Ch*....,._,
I)
Craig $hNmin o,,,.........
()
O.A.Zlm:liW oo.1o-..
I) 0.,,,0,,W)lo Attende, IJst NIA NIA
~nr<<bl.ol NIA NIA faclngfuture.
- c:,
~ "
- c..... 1.iv
/) """'-
NIA a
D.nlllrr#lto NIA
/) -~-
NIA 0......
~
/) -**
/)
l'Mwlrtl*II N,1CN{N19'J'l'1 Attendee List S.foct *=
~.,
N,* I t7I
" C,
I 0
Debbie-Klnsinget N/A OebbloS.i.h, N/A 0
Oelise Konigsbadl N/A 0
Oefek 81k*
N/A 0
oi.ne,.len N/A
... mane~y N/A 0
dlaoe sc,ond N/A 1h
I Atttndtt List
- C Q
NIA Q
Ow_,Wilde, Q
fl,f1rtfl~
Q,.,_......
NIA IV.t>>lh\\t*"
NIA Attendee List Stk-t14!1
.. C
~-,77}
- C "' '
(... _
NIA NIA fritShilhlln NIA htMf,,f,r NIA f...;,nS.to NIA flllDnllCfll IOG&l Glor.. (,11/riWll*
NIA I Att*ndtt LtSt
- 0
- (Cfflf>l 'f Q
{,Hg'illafra.k NM:*li!g,onlV Q
t4tMylM ilWM'C~
0 -~
.. A Q
i.tror,'"'
SCI g
jkq~*tc:"4Mf NIA 0 """'"'
.. A Q
~tor~,
Q 1.-1.-~rt -
James Swenson Q
~....
llttbld Q -*~
NIA Q...... -
NIA Q
NIA Q
.ltflystfPMl'ISIC)n
>Cl Q..........
NIA Q....,,....,
f)
>cNn Holt N/A
- ot.'lmihf N/A
()
judthcvmbfef NIA
( ~ly
..,c.........
-~M'huto (ylfk\\c:l'ldi t.anw5'ow Nof,.,.
loll~INN:W Mttt"4'ng l,11"'"'Hffdnrlli..,.
lDisHilf1iness NIA Kay Cumbow Keith Schue Kristopher Cummings Linda Seeley SallyG Angel Moreno M,,yrll"ll1fl".n.,.
Q.................,.
Q M---.,.
Q
,._,,htll..
t OVl'ltllo,,k'll~t Q.........,.,.,..,.
0 Nc*v~.,.
0.........
l'QT,.,
I)..,.,_
HIA I)...,,.cw,,,, Sie<<io.lblll'ld~
I)
PNGunl.,.
I)..,_,,....
t,lffictloi(ft.
I)
Ptterlutibut'9.,.
I)..........
kw'8.,.w.t,...,,.
I).....
N/A I) lwrld(ll(",t..,..,.,..
SOUthelt'ICitlilOI,...
M>ecc*Sc~ s.ndi* JrutJOMI l.txlrilL ltkMdGf't
~jou,lii!isi 1iobt,lhu,v._.
N/A N/A 1onflOONOT NIA I}
SANW bowl'I PO lox2*<J 0
S..aAltn@IJ 0
~IHOlnt
~II+.
I)..,.....,~ N/A I) ~MM'ffA PNNl I) --
0pt~ltf,,lllh6 I)
SiKa,I HilolShlpifO N/A I) SusanV_,...Clolwn N/A I)
NIA 0
Suz...-Oenre...
I) 1.,.cu,,111 I) 10,,l~ WtmontP 199 in attendance 33 in teleconference
From:
To:
Subject:
Date:
Burnell Scott West Stephanie RE: Meeting gone horrible wrong, IT-wise Thursday, February 11. 2021 3:34:00 PM That should work fine.
From: West. Stephanie <Stephanie.West@nrc.gov>
Sent: Thursday, February 11, 2021 3:29 PM To: Burnell, Scott <Scott.Burnell@nrc.gov>
Subject:
RE: Meeting gone horrible wrong, IT-wise Trying to come up with a graphic. Don't know if there's a new meeting date.
From: Burnell, Scott <Scott Burnell@nrc gov>
Sent: Thursday, February 11, 2021 3:05 PM To: Harrington, Holly <Hollv.Harrjngton@nrc gov>; Castelveter, David <Davjd.Castelveter@nrc gov>;
McIntyre, David <David Mclotyre@nrc gov>; w est, Stephanie <Stephanie west@nrc gov>
Subject:
RE: Meeting gone horrible wrong, IT-wise OK, I'll start drafting something.
From: Harrington, Holly <Holly Harrjngton@nrc gov>
Sent: Thursday, February 11, 2021 3:03 PM To: Burnell, Scott <Scott Burnell@nrc goy>; Castelveter, David <David Castelveter@nrc gov>:
McIntyre, David <David Mclntyre@nrc gov>; West, Stephanie <Stephanie west@nrc gov>
Subject:
RE: Meeting gone horrible wrong, IT-wise No objection. We are trying to get the Commission/Hanson Facebook post up today, but only when the video link goes live.
Holly From: Burnell, Scott <Scott BurneH@nrc gov>
Sent: Thursday, February 11, 2021 2:55 PM To: Castelveter, David <David Casteiveter@nrc gov>; Harrington, Holly <Holly.Harrington@nrc gov>;
McIntyre, David <David.Mclntyre@nrc.gov>; West, Stephanie <Stephanje.West@nrc.gov>
Subject:
Meeting gone horrible wrong, IT-wise Importance: High Hello all; As Dave will attest, NOTHING went properly in trying to have a virtual petition review board meeting with Public Watchdogs and Paul Blanch. Multiple phone lines, wrong passcodes, WebEx issues, everything was screwy.
After half an hour with minimal progress towards even starting, the PRB chair, Kevin Williams, decided to call it off and reschedule, with Public Watchdogs and Blanch agreeing.
Williams tried to apologize to the crowd on the public bridgeline, but apparently the operator cut the line and no one heard.
I suggested that we do a quick-turnaround Facebook post and Tweet to apologize and announce we're rescheduling. Kevin and the PRB are OK with that, I wanted to run that past you all before we dive into drafting something.
Please let me know what you think, thanks.
Scott
From:
Sent:
To:
Sheehan, Neil Tuesday, February 16, 20211 1:03 AM Buckberg, Perry
Subject:
FW: Fwd: Not credible Good morning, Perry Mr. Blanch is asking this same question again.
Neil Public Affairs, Region I From: Paul <pmblanch@comcast.net>
Sent: Monday, February 15, 20213:34 PM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>
Subject:
[External_Sender] Fwd: Not credible Neil I would like to know how many petitions were filed and how many were found not to meet the criteria for acceptance by the PRB Number of petitions not accepted seems ambiguous.
I think you are interested in how many were filed, and how many were found not to meet the criteria From: Paul <pmblanch@comcast.net>
Sent: Monday, February 15, 20211:08 PM To: Neil Sheehan <neil.sheehan@nrc.gov>
Cc: Paul M. Blanch <pmblanch@comcast.net>; James Lampert <james.lampert@comcast.net>; Charles Langley <langley@publicwatchdogs.org>; (b)(6)
- Liu, Tilda <tilda.liu@nrc.gov>; Williams, Kevin <Kevin.Williams@nrc.gov> (b)(6)
!(b)(6)
Subject:
Not credible Neil:
I need your help. I have a presentation coming up with the NRC petition review board (PRB) about the NRC's phrase "not credible" for dry cask loss of integrity. This phrase is used by most manufactures of dry casks.
I have searched everywhere anc!I can't find a definition in 10 CFR.
Does this phrase mean impossible, less than 1 minus 6 and how long is this assumption valid?
I need this information before the PRB meeting I expect next week.
I would also appreciate answers to my questions posed to you on February 81 2021 related to the number of 2.206 petitions not accepted.
See email below:
Neil:
The ASLB enclosed order discusses 387 petitions where there was a Director's Decision.
How many additional petitions were submitted and rejected without a Director's Decision? More than 80% ofmy petitions were rejected by the PRB (including the Indian Point gas line), although I may be a special case. There must be some place where these rejected petitions are tracked.
The second question relates to the chart below where licensee requested some type of licensing actions or relief from the regulations. It appears to be about 900 per year. How many of these provided substantive relief?
I don't need an exact number and a percent estimate will do.
<image00l.png>
Paul Blanch 135 Hyde Rd.
West Hartford, CT 061 17 pm blanch@comcast.net 860-236-0326 Cell 860-922-3 119 2
From:
Sent:
To:
Subject:
Attachments:
Importance:
norepliesplease@mymeetings.com Wed, 9 Jun 202101:40:56 -0500 Shoop, Undine
[External_Sender] Participant List r 2164544 VC-2164544 EIS-US NUCLEAR REGULATORY COM Shoop.xis Normal Pica c find atta bed to lhi e-mail, the participant Ii t from your recent confi rcn c.
If you have any questions or concerns, ith thi list, plea e feel free to contact the ustomer Relations team in your region. 800-4 5-0600 Or 210-795-0354 and E
- +44-20-7950-9949 Hong Kong anJ A ia Paci lie - +852-2 02-515 Japan 3-" 39-6595 We look forward to a i ting you and your company again in the near future.
Regard,
ustomcr Relations onferenciag & ollaboration ervice
1 2
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 EIS-US NUCLEAR REGULATORY COM Conference Call CONFERENCE DETAILS:
LEADER:
Ms Undine Shoop Blank Fields = Indecipherable lnfc DATE/TIME:
Jun 8 2021 @ 12:30 PM ET CONARMATION #:
2164544 ATTENDEE PROVIDED SYSTEM CAPTURED First & Last Name Affiliation CALLED FROM SPEAKERS Andrea Russell (b)(6)
Brett Klukan David McIntyre David Wrona Diane Screnci Dori Willis Gregory Suber 3014151680 Jonathan Evans Ladif Hamdan (b)(6)
Nikki Gilanshai Robert carpenter Undine Shoop PARTICIPANTS Baleu NRC (b)(6)
Billie Garde Clifford & Garde 2022806116 Brian (b)(6)
Caroline carusone US NRC Charles Langley Public Watchdogs 8587524600 David Skeen NRC (b)(6)
Denise Hannigan NRC Office of the Inspector General Geri Shapiro Senator Kirsten Gillibrand Senior Advisor Jenny Weil US NRC Logan Martens US NRC Neil Sheehan NRC Nilda Rivera US NRC Nina Babiarz Public Watchdogs Paul Blanch Energy Consultant 8609223119 Perry Buckberg NRC (b)(6)
Peter Snyder NRC Theresa Clark NRC William Gott NRC NRC NO DECIPHERABLE INFORMATION IN ANY CATEGORY PROVIDED BY PARTICIPA
~~
l (b-)(6_) __
-...ea1
,w:111t,..**n-io.-n.
Dwte:
llJl!Ch::id8¥,.Morl:Pll~~lf:~M Givtft BlanchkffPi ~IIKl*n1 tht 1G*, office In h6 cont,nutd 1Mus.t ofth*oe1,11on prou" (atld my,-,c,l!iiyrolt), I felt 1he nttd to tmurt 101MOMC0<1\\lnuM to 001111 Oiil 1ht rt.:illt1 or what h,pp,ned I J'l~I w*sh 1
!'Yd acc@ll to h11 BCC g1oup. whic:h a tht llut! audifflt* a fur d.
Scou from: 8ufr.t-l. Scoct <Scon B,,.mt'IOm:.fOV>
5tnl: Wfdntldt'(, M*<h 10, 2021 ~ 11 PM To; Pau I Blanch <ombl.lneP,@<<)mtaSI ~t>
~~~=:~:
1:::~;;u~:=~.:;n(<<~n W,ll~Mlfnr< a~>'ll.li..W:.i..-----------------------------...J SW)e<t: ~: lte'.,-....111anc:h w,nt you SOl'M Mes Helo Paul:
To reeap rec:entevenls My oontri;lu1100 U:> yesterday's meeting was an offer to the audiefteeto answer questions not rel.iited to the pelition process. The distinction should be obVIOUsbetweeo YQU, an acti~ petitioner who has EW'I nlobllthed c:ommunlcetlon link lo !he pol#on rovilw board, and en audlOnoe mefNMlr not Included In the polllboo YH\\etday you Cleat1y Mated a H1 of quelCJOnl during a wan1Ctlbed meeting, !TIMIW'lg lhe quea.bon1 wilt be part of the offlali record Despite ltlal exlMll'lg documenlMlon, you lnduded me in an email to l'le
~
board chair wllh ao addelooal oopy of those queAOns As a courtesy I adnowtedged receipt for 1he staff (meaning lhe review board chalf) As lhequesllons were dncted to the review board as part of IN m6tllng mt quteNon, lllt OUlttdt Of my offer IO lht... Oler'!Ct, IV. nO P~I did I,t.tt a,.v'ltw ~
Pol llion,.liJWdlng tl'ION <1111,t1on1. *Inc* lnal.. a lkhOU, matlltf ou,.... my rt1ponM)ll1Cy H,a put)k affaln officer.
I provided
- furthef counety In rescult1g )'O\\ll Orop80J1 ernt1ii tom m, jl.M\\k m,il folder end ensuring the petition review board WH tliWtlrt of your COfflf'!'IJnQt lon. I continued i'I the splri1 of counesy by wgoetting POF1 04 lhl p,.. eoiauon llldM WOUid be N MO&t &CCHllblll format. Tht-NR.C-. IT tttOurc.. h.t'tt thllf ~nllll, 10 pllAM rtcorwlellt ~f.. IU!'rlptlOr'I {MMII lrt I...
,....,,.,.,.,~
by M'Ory,o,'11 01'1 di:JtributlOn hefe) th3t ii fall$ to lhe $Ullf to $001ehow lnln$10te Keyno(e fies k>r )'tM.I The clearest ~lh ~ ensuring those $1ide$ are induded in the recoro i5 for Mr. Scoct or you 10 convet1 them to POF5 Thank you.
ScottBurnel PublicAfl'&QOfllct, Nuclear RegulalOry Commiulon f,om: Paut 81.mct, <prr,b!Mlch@tomt.iSt ~ t>
S4fll:Wtdn.s<111v. M¥(h 10, 2021 4 41 PM To: lkirMII, Scot! -cScotl &Jrrwll.nrctov>
Cc; PAIi M Blaneh <l)n'lblilll\\(l'l@l~t l'ltt>;l1u. Jildli <Tildauu,h'U'Cgov>; W11llilln'IS, KMi <<~.... Wffi.3"1$i!lm'C,CO
'¥2t\\:(lf!'naiJe-ndett Rt P:U ellnl ;e-::~=~=llf'v*l)f,lt)lltwal\\hdoCS or*
S<OII I bchcvc to su1cd dwmg the mcc1iog anyone can Sffl(! you qucstt0ns? Are YOII SJt)1,-gyou are 1101 a<.Upt1ng my ques11ons as a followup to the meeting.,.,! Because I am pan of1he pe1111on j)R)CU!J. 1ndappan:ntly not JI nw.:mbtt o (thc, public. I C'lltl nf>l i11bmit qtk'Miom 10 )'o.110 you 11a-.:d l l the ("flftCIU~i()ft Mtht n1ix1in1')
I (..-l'l,c,y pltl&M\\J 1o be m 1,cry l'M:l1mvc-d11w rxnbl mcb" cmncast arr 1!6(M22*l119 OnMu 10, 2021.113:14 PM. llwneU, SM11<$rn1g Utunc:11 //QI£ i'OY> wrMe:
Helo Pauk;
~
a rvn1nd1N', I.,, noi P9rt of the l)tllbon re\\11, "'N boef'd I 11111Wlf9d )'Ollr,aroer em11 I -
- CCMtesy. I PfO\\'tdad my erna* to l,t aJdllOOI fOI' thw 91neral QUnltona tol~ing yesterday I IT'lffltng.
Your 811efflll lo use Oropbo" ended up ri my junk mail folde~ as 1UCh, ifs foounate 1ha1 I saw ii befofe rt was aulomMC8t;" dete1ed Also. the peohon review board lad:s the atMhty 10 open KeyncNe MN M> I IU~M 1umi11glho.. 111<1M lr,10 POr, fa, ttltwktfft poM!l>it oo,np.ilit, 111~
Sctltl Bumtll From: OfQpOQ1 Transfer <m-cei'/lY!droctxu cw>
s.nt:1 WednHcUy, MM ch 10, 1011 l 05 PM To: Burne( Sc:011 <:xo*r 8 'Cf p)r,r Crnt>
SUbj<<t: il:xtt-l'NI_S.nOtr} P1i.A 8!11r,c:ft1en1 Yo"',~ fii,e, l~nload them b) JI 11:2021 ll Paul Blanch sent you Actual NRG Presentation.key "Please assure this is placed iu A DA MS" You cnn download 1hcsc files now or umil 3117/202 1.
Queslions'/ Ask Paul (pm11roodiablaarb@groail com)
Here's what they sent you I i1cm
- 44 MB
B,:masoflnmtxu
From:
To:
Subject:
Date:
Attachments:
Hello again; Burnell Scott DeJesus. Anthony: Dennis Suzanne Per my Teams note Tuesday, November 16, 2021 11:04:00 AM 20211112 PMB to EOO for oublic dialoa.odf This is the 11/12/21 letter from Mr. Blanch to the EDO (a copy of which was furnished earlier in this released set).
My understanding is that NMSS is already starting to work on a reply. Blanch is also calling NRR staff who worked on the SECY for the 2.206 process revisions, and in my view that"s all related. l"m hoping we can figure out how to have one single response to Blanch.
Thanks.
Scott
From:
Sent:
To:
Cc:
Subject:
Suber, Gregory Wed, 9 Jun 202111:26:51 +0000 Williams, Kevin;liu, Tilda Skeen, David;Clark, Theresa;Shoop, Undine Public Meeting on 2.206 Petition Process Kevin and Tilda, Hope all is well. Just wanted to give you heads up on part of the discussion we had at the third public meeting we conducted (June 8th) on revising the 2.206 Petition Process. I do not believe there is any action or follow up required on your behalf. Just want to make you aware that Paul Blanch and Charles Langley were in attendance and made several comments regarding the SONGS petition. Specifically, Mr. Langley repeated concerns about how the staff used risk in evaluating the petition and how the determination was made that certain events/failure mechanism were not credible. I am sure none of this is new to you. However, the meeting was moderately well attended and there were some congressional staffers on the line (not sure if an from CA listened in.) As the focus of the meeting was the proposed process revisions, we did not attempt to answer technical questions and only provided information that the staff had already previously committed to responding in writing. The meeting was transcribed and we can forward you the transcription when it becomes available if you like.
Hope this helps. Please reach out to me or Undine Shoop if you have any questions. Latif Hamdan can also provide you with information as he was in attendance.
Best regards, Gregory F. Suber Deputy Director, Operating Reactor Licensing HOWARD UNIVERSITY
From:
Sent:
To:
Subject:
- Bruce, Sheehan, Neil Tuesday, August 24, 2021 8:59 AM Watson, Bruce RE: Re: Request for a public meeting I should respond to Mr. Blanch on this. Are you good with this response?
Neil From: Sheehan, Neil Sent: Thursday, August 12, 20211:26 PM To: Guzman, Richard <Richard.Guzman@nrc.gov>; Watson, Bruce <Bruce.Watson@nrc.gov>
Cc: Sturzebecher, Karl <Karl.Sturzebecher@nrc.gov>; Klukan, Brett <Brett.Klukan@nrc.gov>
Subject:
RE: Re: Request for a public meeting Here is my proposed response. Our options would be me sending this to Mr. Blanch in advance of the meeting or having Bruce, Brett or someone else speak to it during the virtual meeting.
Please advise how a member of the public could make a request for a "round table or town meeting" type of public meeting as described in the Commission Policy (enclosed).
Proposed response: The Commission Policy Statement on Enhancing Participation on NRC Public Meetings, published on March 19th in the Federal Register, redefines the three categories of public meetings offered by the agency. It also identifies the level of public participation offered at each category of meeting. Your request indicates that you are interested in another session that would fall under the category of "Comment-Gathering Meeting". The Federal Register nofoe cites as examples of such meetings town hall and roundtable discussions, environmental impact statement scoping meetings and workshops.
We would like to point out that both our public meeting on July 29th in Tarrytown, N.Y., and our virtual meeting on Aug. 18th were conducted specifically to solicit public comments on the Post-Shutdown Decommissioning Activit1ies Report, or PSDAR, for the Indian Point nuclear power plant. We received dozens of public comments at these meetings, as well as during a government-to-government meeting held on July 29th* As part of our review of PSDARs, we have a mandate to hold public comment-gathering meetings and we have conducted these for each and every plant entering the decommissioning process. In addition, we held a public webinar in the spring of 2020 to educate the public about the decommissioning of Indian Point and our inspections and reviews associated with those activities.
Your request for a roundtable or town hall meeting regarding the Indian Point decommissioning plans would go above and beyond those interactions and we currently have no plans for such a session. Your request will be considered by NRC senior management and we will inform you of any changes. However, as of now, our focus will be on considering the large number of public comments already provided. And we would note that the window to submit written comments on the Indian Point PSDAR will remain open until Oct. 22nd.
From: Guzman, Richard <Richard.Guzman@nrc.gov>
Sent: Tuesday, August 10, 2021 8:01 AM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>; Watson, Bruce <Bruce.Watson@nrc.gov>
Cc: Stu rzebecher, Karl <Karl.Sturzebecher@nrc.gov>
Subject:
RE: Re: Request for a public meeting Bruce / Neil, NRR/DORL suggests that we address Blanch's decommissioning related questions during the webinar - either in the presentation or during the comment gathering/Q&A period as the easiest path forward. We can then point him to the webinar transcript rather than take up additional time/resources for what he's requesting in a separate roundtable Q&A meeting wi the NRC. DORL also suggesied to check w/HQ OPA on what was the intended meaning of "roundtable.. " in the Mar 2021 policy statement.
-Rich From: Guzman, Richard Sent: Monday, August 09, 20215:23 PM To: Sheehan, Neil <Neil.Sheehan@nrc.gov>
Cc: Watson, Bruce <Bruce.Watson@nrc.gov>; Sturzebecher, Karl <Karl.Sturzebecher@nrc.gov>
Subject:
RE: Re: Request for a public meeting Hi Neil - sorry for my late reply. Did you already respond to Blanch? I would agree with Bruce that he is misinterpreting the revised policy statement and that it was not intended to convey that members of the public may now request the NRC staff to arrange a round table Q&A. Did HQ OPA provide any language for these type of requests? I suppose he can send a formal request letter to the Commission requesting a meeting (as he's done before w/one of his 2.206s) and we can assess the need for one (or the Commission direct us to have a meeting, if warranted).
From: Sheehan, Neil <Neil.Sheehan@nrc.gov>
Sent: Friday, August 06, 202110:37 AM To: Watson, Bruce <Bruce.Watson@nrc.gov>; Sturzebecher, Karl <Karl.St urzebecher@nrc.gov>; Guzman, Richard
<Richard.Guzman@nrc.gov>
Subject:
Fwd: Re: Request for a public meeting Thoughts?
From: " Paul Blanch" <pmblanch@comcast.net>
Subject:
[External_Sender] Re: Request for a public meeting Date: 06 August 202110:18 To: "Sheehan, Neil" <Neil.Sheehan@nrc.gov>
Cc: "Paul M. Blanch" <omblanch(a)comcast.net> l(b)(6)
(b)(6) 2
, "Richard "Screnci, Diane" nrc. ov>
Neil:
I may have missed your response. Please resend.
Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast.net Cell 860-922-3119 On Jul 30, 2021, at 5:29 PM, Paul Blanch <pmblanch@comcast.net> wrote:
Neil:
I transmitted to you and also distributed to the NRC a presentation that contained my assumptions of the technical issues related to tihe Indian Point decommissioning and site remediation.
I also mentioned during my presentation the revised "Commission Policy Statement on Enhancing Participation in NRC Public Meetings" was published on March 19, 2021.
Please advise how a member of the public could make a request for a " round table or town meeting" type of public meeting as described in the Commission Policy (enclosed).
As you should have noted by a show of hands, most public members indicated endorsement of such a meeting however when I asked for a show of hands from NRC members present, not one NRC hand was raised in support of this Commission Policy.
Your prompt response, including the NRC's concurrence or my misunderstanding of site remediation will be appreciated.
<Untitled.pdf>
Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast.net Cell 860-922-3119 3
From:
Sent:
To:
Sheehan, Neil Thursday, September 02, 2021 9:39 AM Lorson, Raymond
Subject:
FW: Responses to your questions re: Indian Point decommissioning
- Ray, As an FYI, I sent these responses to Mr. Blanch and have not received a response to date. Of course, he may be on vacation or tied up with something else.
Neil From: Sheehan, Neil Sent: Thursday, August 26, 202111:16 AM To: Paul Blanch <pmblanch@comcast.net>
Subject:
Responses to your questions re: Indian Point decommissioning
- Paul, Apologies for it taking a while to get back to you on these. Here are our responses to questions you asked of us in conjunction with the July 29th Indian Point PSDAR public meeting:
- 1.
According to the Indian Point PSDAR, the entire site, with the exception of the ISFSI area, will be released for unrestricted use as defined by 10 CFR 20.1402. However, the surface dose rates may be reduced by state and localrequirements and agreements.
NRC Response: States may establish unrestricted dose criteria that are less than the 25 millirems per year plus A LARA (As Low As Reasonably Achievable) requirement in 10 CFR 20. The unrestricted release criteria is not just a surface dose rate. The unrestricted release criteria follows the 25 mrem/y and ALARA principle. The release criteria is typically determined by the final residual activity based on site-specific dose modeling, using an all-pathways analysis. NUREG 1757 Volume 2 provides guidance for scenarios, dose modeling and methodologies acceptable to the NRC staff to determine the residual radioactivity concentrations used to determine the annual dose.
- 2.
There is no discussion in the Indian Point PSDAR of release under restricted conditions as described in 10 CFR 20.1403 and appears to have been common practice at both Maine and Connecticut Yankee. I assume partial release is not anoption. These are no present plans for restricted use release as defined in 10 CFR20.1403.
NRC Response: On page 2 in the Introduction section of the PSDAR, Holtec states the intent is to release the site, with the exception of the Independent Spent Fuel Storage Installation (ISFSI) for unrestricted use. The term "unrestricted use" is used 12 more times in the PSDAR. Therefore, there is no discussion on restricted use per 10 CFR 20.1403.
- 3.
Unrestricted use, as discussed by NEI and the NRC during the NRC workshop, will include the unrestricted residential use, industrial use, and possible power generationincluding potential new nuclear facilities.
NRC Response: Holtec, the company and landowner will determine the future use of the site and this will be provided in the license termination plan. As noted in an e-mail from staff to you dated July 24, 2021 on a similar question, the following response paraphrased below was provided:
[It is not known at this time,] what scenarios are being considered for Indian Point; however, as we discussed... unrestricted release means the licensee cannot take credit for any restrictions on land use. As I mentioned in the public workshop, NUREG-1757, Volume 2, Chapter 5 contains additional details on exposure scenarios. The licensee can use screening or bounding exposure scenarios such as the resident farmer scenario or more realistic, reasonably foreseeable future land use site-specific exposure scenarios. If they consider more realistic scenarios, they need to consider less likely but plausible exposure scenarios as well.
- 4.
There are no present plans for engineered barriers to facilitate unrestricted release asdiscussed in NUREG 1757.
NRC Response: Engineering barriers are not used to facilitate unrestricted use. By definition, unrestricted means no restrictions. Engineered barriers are typically used only for restricted use.
However, to date, no NRG-licensed facilities have chosen the restricted-use option.
- 5.
The screening values or isotopic concentrations remaining at the site will be less thanthe values stated in NUREG 1757, Table H.2 "Screening Values (pCi/g) of CommonRadionuclides." It is assumed that any soil containing radioactive concentrations in excess of these values will be removed prior to release for unrestricted use.
NRC Response: In the July 24 email response to your previous inquiry on a similar matter, NRC staff provided you with the following response:
With regard to screening values, NUREG-1757, Volume 2, Chapter 5 discusses use of screening values found in Appendix H of the same NU REG that can be used as long as the assumptions inherent in the modeling to derive screening values are met. Licensees also have the option to perform site-specific dose modeling to derive clean-up levels, which is also discussed in Chapter 5.
It is additionally noted that most complex site's develop site specific Derived Concentration Guideline Levels (DCGLs) as part of the license termination plan. The OCGLs are the levels by which the licensee demonstrates the site meets the unrestricted dose criteria.
2
APPF.NOIX fl Table H.2 Scrffnlng Yalu*** (pCl/g) ot Common R*dlonuclldea for Soll Surface Contamina11on Level ltadk>nwcllde SvmboJ S wrrace Solt Screc11lfu1: Valuu*
I lydroaon-3
' 11 110 Carb<>n* 14
C 12 Sodiu_m.22 UN*
4.J Sulf\\ar-3j
" S 270 Chloth-.o-16 "Cl 036 Calcium--4S "Ca 57 Scandlum6 "So IS M a1111,,mct10-!i4
- ~Mn IS lron-SS Hfc 10000 Cob111t,..57 nco 150 Cobllll-60 "Cu J.8 Nlckcl-59
Ni ssoo Nlckel-63 UNI 2100 S1ron1\\um.-90 "S,
1.7 Nloblum-94
~ Nb 5.8 Techneiium-99 "Tc 19 lodinc-129
'"I o.s Ccaium-134
'"C, S.7 Cesium-137 l>*c.
11 -
europluin-1.52 u:eu 8.7 f':uropium-1.54 l'M6U lrid lum--192
'" Ir 4 1 Lcad-210 f l-Vb 0.9 R1Hl1un\\--:Zl6 JN.Ra 0.1 Radlum-226-+-C'
"'Ra+C 0.6 Actinium--227 n'Ac 0.$
At.1 1111um*:Z:Z1 C u'Ac*C o.s Thorium-228 U>fh 4.7 hV REQ*l757. Vol. 2. Rev. I
- 6.
According to the PSDAR, "During demolition, above-ground structures will be removed to a nominal depth of three (3) feet below the surrounding grade level",however remaining concrete may contain highly contaminated piping with unspecified levels of radioactive contamination.
NRC Response: All residual components and surfaces must meet the OCGLs or otherwise be removed. Radioactive materials, including piping, will be decontaminated or will be removed that are above the DCGLs. It is industry practice for buildings to be demolished down to 3 feet or more based on applicable state requirements.
- 7.
Radioactive surface and internal pipe contamination (no limits specified) will remainburied within the containing concrete structures. This will be consistent with the practices of Maine and Connecticut Yankee sites.
NRC Response: All radioactive components, including those below the surface, were removed from Maine Yankee and Connecticut Yankee. As noted in response #6, the site must meet the DCGL criteria approved in the license termination plan, which has not yet been submitted for Indian Point.
- 8.
Twenty five years after shutdown of Maine and Connecticut Yankee, the sites havenot been released for "unrestricted" use. This is in addition to the ISFSI portion ofthe site licensed under 10 CFR 72.
NRC Response: Both Maine Yankee and Connecticut Yankee land areas were released for unrestricted use except for the ISFSls, which remain under NRC licenses.
- 9.
"Rubblization" as proposed at Maine Yankee will not be considered.
NRC Response: Rubblization can be used in many contexts. Maine Yankee decided to rubblize much of the site concrete to remove the rebar from the concrete and transport it offsite for disposal. Detailed plans for Indian Point should be addressed in the license termination plan.
3
4
Neil Sheehan NRC Public Affairs Officer Region I (610) 337-5331 cell: l(b)(6) 5
From:
Sent:
To:
Subject:
Suber, Gregory Tue, 16 Nov 2021 12:51:27 +0000 Shoop, Undine;Wrona, David;Carusone, Caroline Senator Gillibrand Briefing Strategy Develop strategy to address concerns raised by Senator Gillibrand regarding Paul Blanch concerns.
Microsoft Teams meeting Join on your computer or mobile app Click here to join the meeting Or call in (audio onl
+ 1 301 576 2978, (b)(B)
United States, Silver Spring Phone Conference ID: (b)(6) -----
Find a local number I Reset PIN
- U.S. Nuclear Regulatory Commission **
Learn More I Help I Meeting options
From:
Sent:
To:
Jonathan Cc:
Subject:
Shoop, Undine Tue, 16 Nov 2021 21:44:48 +0000 Carusone, Caroline;Wrona, David;Russell, Andrea;Suber, Gregory;Evans, Buckberg, Perry;Pham, Bo RE: Voice Message From: WIRELESS CALLER, 8609223119 When Gregory and I discussed this last night, he recommended that Dave and Caroline return the call since they could be seen as neutral. But I also see Dave's point. Therefore I will call him back to understand his concerns and see if it is an any aligned with his concerns expressed to his Senator's staffer.
From: Carusone, Caroline <caroline.carusone@nrc.gov>
Sent: Tuesday, November 16, 202111:14 AM To: Wrona, David <David.Wrona@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory
<Gregory.Suber@nrc.gov>; Evans., Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine
<Undine.Shoop@nrc.gov>
Cc: Buckberg, Perry <Perry.Buckberg@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 Fair point.
From: Wrona, David <David.Wrona@nrc.gov>
Sent: Tuesday, November 16, 2021 9:30 AM To: Carusone, Caroline <caroline.carusone@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine
<Undine.Shoop@nrc.gov>
Cc: Buckberg, Perry <Perry.Buckberg@nrc.gov>; Pham, Bo <Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 I'm guessing that the content of his calls is that he doesn't see any changes based on his comments. I think he would find it frustrating to deal with new NRC staff, especially-at least based on my lack of knowledge of the history, not being able to help him see where we did or why we didn't accept his items. Just my 2 cents.
From: Carusone, Caroline <caroline.carusone@nrc.gov>
Sent: Tuesday, November 16, 2021 9:17 AM To: Russell, Andrea <Andrea.Russell@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undlne.Shoop@nrc.gov>
Cc: Wrona, David <David.Wrona@nrc.gov>; Buckberg, Perry <Perry.Buckberg@nrc.gov>; Pham, Bo
<Bo.Pham@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 I'm just throwing this out there for consideration... and I'm hesitate to provide additional "escalation channels," but - would there be any benefit in either Dave Wrona or I reaching out to him? We would be "new" to this discussion and perhaps having someone that he perceives is
less biased might help? On the other hand, he might find it frustrating that there are new players. Thoughts?
From: Russell, Andrea <Andrea.Russell@nrc.gov>
Sent: Tuesday, November 16, 2021 9:02 AM To: Suber, Gregory <Gregory.Suber@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undlne.Shoop@nrc.gov>
Cc: Carusone, Caroline <caroline.carusone@nrc.gov>; Wrona, David <David.Wrona@nrc.gov>; Buckberg, Perry <Perry.Buckberg@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119 So Jonathan got another call this morning. I truly think someone (Gregory or Undine?} needs to reach out to Paul sooner than later. As for the transcripts, I don't see how we could ask Perry to go through the transcripts since Perry wasn't part of the WG. I can go through the transcripts if needed.
From: Suber, Gregory <Gregory.Suber@nrc.gov>
Sent: Monday, November 15, 2021 5:46 PM To: Evans, Jonathan <Jonathan.Evans@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>
Cc: Carusone, Caroline <caroline.carusone@nrc.gov>; Wrona, David <David.Wrona@nrc.gov>
Subject:
RE: Voice Message From: WIRELESS CALLER, 8609223119
- Jonathan, I believe Undine or I should call Mr. Blanch. He has contacted Senator Gillibrand and we have a briefing with her staffers tentatively scheduled for December 2nd. I need someone - hopefully the current 2.206 PM - to extract Mr. Blanch's comments from the transcripts of our public meeting. He has informed the Senator that we were not responsive to his questions and comments.
I do not think you or Andrea should engage him since we have permanent staff work on 2.206.
We should handle this within DORL.
- Thanks, From: Evans, Jonathan <Jonathan.Evans@nrc.gov>
Sent: Monday, November 15, 2021 5:07 PM To: Suber, Gregory <Gregory.Suber@nrc.gov>; Shoop, Undine <Undine.Shoop@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>
Subject:
Fwd: Voice Message From: WIRELESS CALLER, 8609223119 Hey all, I am on travel right now. Are any,of you able to respond to Paul?
Get Outlook for iOS
From: WIRELESS CALLER <tel=8609223119@officelinx.nrc.gov>
Sent: Monday, November 15, 2021 7:04:00 AM To: Evans, Jonathan <Jonathan.Evans@nrc.gov>
Subject:
Voice Message From: WIRELESS CALLER, 8609223119
From:
To:
Cc:
Subject:
Date:
Attachments:
Burnell Scott Screnci Piaoe McIntyre Pave RE: Re: your voicemails to the staff Wednesday, November 17, 202111:20:00 AM 1maae001.cna My thinking is that he's chosen the FOIA process, so that takes precedence. If he still has questions after that, we'll cross that bridge then.
From: Screnci, Diane <Diane.Screnci@nrc.gov>
Sent: Wednesday, November 17, 202111:18 AM To: Burnell, Scott <Scott.Burnell@nrc.gov>
Cc: McIntyre, Dave <David.Mclntyre@nrc.gov>
Subject:
RE: Re: your voicemails to the staff Since we don't know what his questions are I don't think we can assume the FOIA response will have the answers. It might be the FOIA will have the answers, but we just don't know at this point. Since Undine already left a message for him. The ball's in his court.
I suggest that all calls are during work hours at our convenience.
Diane Screnci (she/her)
Sr. Public Affairs Officer USNRC, Region I 610-337-5330 From: Burnell, Scott <Scott Burnell@orc gov>
Sent: Wednesday, November 17, 202111:07 AM To: Russell, Andrea <Andrea Russell@nrc gov>; Shoop, Undine <Undjne Shoop@nrc gov>; Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Cc: Screnci, Diane <Diane Screnci@orc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>; McIntyre, Dave <David Mclntyre@nrc gov>
Subject:
RE: Re: your voicemails to the staff Does anyone else have input on the proposed reply? Thanks.
From: Russell, Andrea <Andrea RusseH@nrc gov>
Sent: Wednesday, November 17, 2021 9:53 AM To: Burnell, Scott <Scott Burnell@orc gov>; Shoop, Undine <Uodine Shoop@nrc gov>; Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Cc: Screnci, Diane <Diane Screnci@orc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>; McIntyre, Dave <David Mdntyre@nrc gov>
Subject:
RE: Re: your voicemails to the staff Sounds good to me.
From: Burnell, Scott <Scott BurneH@nrc gov>
Sent: Wednesday, November 17, 2021 9:51 AM To: Shoop, Undine <Undjne Shoop@nrc gov>; Russell, Andrea <Andrea RusseH@nrc gov>; Evans, Jonathan <Jonathan Evans@nrc gov>; Suber, Gregory <Gregory Suber@nrc gov>
Cc: Screnci, Diane <Diane Screncj@nrc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>; McIntyre, Dave <David Mclotyre@nrc gov>
Subject:
FW: Re: your voicemails to the staff Hello all; Given he's submitted a FOIA on the public meetings for the 2.206 revision process, I plan to tell him our reply will come through that process.
I welcome your suggestions. Thanks.
Scott From: Paul Blanch <pmbianch@comcast net>
Sent: Wednesday, November 17, 2021 9:34 AM To: Burnell, Scott <Scott Burnell@orc gov>
Cc: Paul M. Blanch <pmbianch@comcast net>; Screnci, Diane <Piaoe Screncj@nrc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>; Charles Langley <langiey@publjcwatchdogs org>
Subject:
[External_Sender) Re: your voicemails to the staff Scott:
This is a technical issue and there is no need to involve OPA. I think if you look at the transcript of the 2.206 meeting, you will see why I called Is this a new unwritten NRC Policy that a member of the public can't talk about a formal meeting with the NRC's staff?
I am pursuing different routes seeking answers to my questions My letter to the EDO was not related to the unreturned calls from the NRC Staff Has OPA now directed the Staff not to talk to me?
I am well aware of how to contact OPA if I need its assistance Apparently, OPA now screening all my calls as in "1984"?
Paul Blanch 135 Hyde Rd.
West Hartford, CT 06117 pmblanch@comcast.net Cell 860-922-3119 On Nov 17, 2021, at 8:49 AM, Burnell, Scott <Scott Burnell@orc gov> wrote:
Good morning, Paul; I understand you've left voicemails for several staff in NRR, regarding the recent SECY on revisions to the 2.206 process. Given that you've also just emailed the EDO on matters related to your 2.206 on San Onofre spent fuel, we'd like to understand what about the SECY you wanted to discuss. Thank you.
Scott Burnell Public Affairs Officer Nuclear Regulatory Commission
From:
To:
Cc:
Subject:
Date:
Hi Scott, Shoop Undjne Bumen Scott: Russeu. Andrea: Evans. Jonathan: Suber. Gregory McIntyre Daye; Screnci Qiane; Sheehan Neil RE: RE: your voicemails to the staff Wednesday, November 17, 2021 8:59:03 AM This is consistent with what I said as well. I got his voice-mail so I told him I was returning his call and asked him to e-mail me so we could determine a mutually agreeable time to discuss his interests.
Thanks u
From: Burnell, Scott <Scott.Burnell@nrc.gov>
Sent: Wednesday, November 17, 2021 8:51 AM To: Shoop, Undine <Undine.Shoop@nrc.gov>; Russell, Andrea <Andrea.Russell@nrc.gov>; Evans, Jonathan <Jonathan.Evans@nrc.gov>; Suber, Gregory <Gregory.Suber@nrc.gov>
Cc: McIntyre, Dave <David.Mclntyre@nrc.gov>; Screnci, Diane <Diane.Screnci@nrc.gov>; Sheehan, Neil <Neil.Sheehan@nrc.gov>
Subject:
FW: RE: your voicemails to the staff FYI From: Burnell, Scott Sent: Wednesday, November 17, 20218:50 AM To: pmblanch@comcast net Cc: Screnci, Diane <Diane Screnci@orc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>
Subject:
RE: your voicemails to the staff Good morning. Paul; I understand you've left voicemails for several staff in NRIR, regarding the recent SECY on revisions to the 2.206 process. Given that you"ve also just emailed the EDO on matters related to your 2.206 on San Onofre spent fuel, we"d like to understand what about the SECY you wanted to discuss. Thank you.
Scott Burnell Public Affairs Officer Nuclear Regulatory Commission
From:
To:
Subject:
Date:
Thanks!
Dennis Suzanne Bume\\L Scott RE: RE: your voicemails to the staff Wednesday, November 17, 2021 8:56:06 AM From: Burnell, Scott <Scott.Burnell@nrc.gov>
Sent: Wednesday, November 17, 20218:55 AM To: Dennis, Suzanne <Suzanne.Dennis@nrc.gov>
Subject:
FW: RE: your voicemails to the staff FYI, we'll see how he responds.
From: Burnell, Scott Sent: Wednesday, November 17, 2021 8:50 AM To: pmb!anch@comcast net Cc: Screnci, Diane <Diane Screncj@nrc gov>; Sheehan, Neil <Neil Sheehan@nrc gov>
Subject:
RE: your voicemails to the staff Good morning, Paul; I understand you've left voicemails for several staff in NRR, regarding the recent SECY on revisions to the 2.206 process. Given that you've also just emailed the EDO on matters related to your 2.206 on San Onofre spent fuel, we'd like to understand what about the SECY you wanted to discuss. Thank you.
Scott Burnell Public Affairs Officer Nuclear Regulatory Commission