ML16225A768

Lr Hearing - Status of Ucs 2.206 Petition Indian Point Reactor Vessel Baffle-Former Bolts

ML16225A768
Person / Time
Site:	Indian Point
Issue date:	08/04/2016
From:	NRC
To:	Division of License Renewal
References
Download: ML16225A768 (26)

Text

IPRenewal NPEmails From: Pickett, Douglas Sent: Thursday, August 04, 2016 4:46 PM To: Dave Lochbaum (dlochbaum@ucsusa.org); Prussman, Stephen G (SPrussm@entergy.com); Walpole, Robert W (rwalpol@entergy.com)

Cc: Benner, Eric; Dentel, Glenn; Banic, Merrilee; Hair, Christopher

Subject:

Status of UCS 2.206 Petition RE: Indian Point Reactor Vessel Baffle-Former Bolts Attachments: Transcript of UCS Presentation July 28 2016.pdf Gentlemen -

Attached for your information is the publicly available transcript of the Union of Concerned Scientists presentation of July 28, 2016, before the Petition Review Board concerning their 10 CFR 2.206 petition regarding the Indian Point reactor vessel baffle-former bolts. The transcript can be found in ADAMS at ML16215A391.

In accordance with NRCs Management Directive 8.11, Review Process for 10 CFR 2.206 Petitions, the petition review board met internally this afternoon to make its initial recommendation regarding accepting or rejecting the petition for further review under 10 CFR 2.206. The PRBs initial recommendation, which has been concurred on by the NRR front office, is to accept the petition for review.

Mr. Lochbaum - Our Management Directive stipulates that the petitioner be offered an opportunity to comment on the PRBs initial recommendation. This would be done via a public meeting or telephone conference call similar to what we did for your presentation on July 28. If you decide to decline the opportunity to comment on the initial recommendation, it will become final. At that point, I will prepare an acknowledgement letter, that will be publicly available, that characterizes your petition and informs you that your petition has been accepted for review.

Please let me know of your decision.

Doug Douglas V. Pickett, Senior Project Manager Indian Point Nuclear Generating Unit Nos. 2 & 3 Douglas.Pickett@nrc.gov 301-415-1364 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 7595 Mail Envelope Properties (6cf330b8b6a5416bb7c0e8f805436051)

Subject:

Status of UCS 2.206 Petition RE: Indian Point Reactor Vessel Baffle-Former Bolts Sent Date: 8/4/2016 4:45:32 PM Received Date: 8/4/2016 4:45:34 PM From: Pickett, Douglas Created By: Douglas.Pickett@nrc.gov Recipients:

"Benner, Eric" <Eric.Benner@nrc.gov>

Tracking Status: None "Dentel, Glenn" <Glenn.Dentel@nrc.gov>

Tracking Status: None "Banic, Merrilee" <Merrilee.Banic@nrc.gov>

Tracking Status: None "Hair, Christopher" <Christopher.Hair@nrc.gov>

Tracking Status: None "Dave Lochbaum (dlochbaum@ucsusa.org)" <dlochbaum@ucsusa.org>

Tracking Status: None "Prussman, Stephen G (SPrussm@entergy.com)" <SPrussm@entergy.com>

Tracking Status: None "Walpole, Robert W (rwalpol@entergy.com)" <rwalpol@entergy.com>

Tracking Status: None Post Office: HQPWMSMRS06.nrc.gov Files Size Date & Time MESSAGE 1529 8/4/2016 4:45:34 PM Transcript of UCS Presentation July 28 2016.pdf 201827 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

10 CFR 2.206 Petition Review Board RE Union of Concerned Scientists Docket Numbers: Indian Point Nuclear Generating Unit Nos. 2 and 3. 50-247 and 50-286 Location: teleconference Date: Thursday, July 28, 2016 Edited by Douglas Pickett, August 2, 2016 Work Order No.: NRC-2504 Pages 1-22 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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10 CFR 2.206 PETITION REVIEW BOARD (PRB)

CONFERENCE CALL RE UNION OF CONCERNED SCIENTIST'S PETITION DATED JUNE 30, 2016

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THURSDAY JULY 28, 2016

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The conference call was held, Eric Benner, Chairperson of the Petition Review Board, presiding.

PETITIONER: DAVID LOCHBAUM PETITION REVIEW BOARD MEMBERS ERIC BENNER, Deputy Director, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation DOUGLAS PICKETT, Petition Manager for 2.206 petition RUSS ARRIGHI, Senior Enforcement Specialist, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 Office of Enforcement CHRISTOPHER HAIR, Attorney, Office of General Counsel ALLEN HISER, Senior Technical Advisor, Division of License Renewal JACK MCHALE, Branch Chief, Division of Engineering NRC HEADQUARTERS STAFF GANESH CHERUVENKI, Mechanical Engineer, Vessels and Internal Integrity Branch NIKLAS FLOYD, Acting Senior Project Engineer, Division of Reactor Projects, Region 1 MICHAEL MODES, Senior Reactor Inspector, Engineering Branch, Region 1 GARRETT NEWMAN, Resident Inspector, Indian Point SERITA SANDERS, Petition Coordinator, Office of Nuclear Reactor Regulation DIANE SCRENCI, Sr. Public Affairs Officer, Office of Public Affairs, Region 1 NEIL SHEEHAN, Public Affairs Officer, Office of Public Affairs, Region 1 TRAVIS TATE, Branch Chief, Division of Operating Reactor Licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 P R O C E E D I N G S 2 1:33 p.m.

3 MR. PICKETT: Good afternoon. I would like 4 to thank everybody for attending this meeting. My 5 name is Doug Pickett, and I am an Indian Point Project 6 Manager for the NRC's Office of Nuclear Reactor 7 Regulation.

8 We are here today to allow the 9 Petitioner, Mr. David Lochbaum of the Union of 10 Concerned Scientists, to address the Petition Review 11 Board, also referred to as PRB, regarding their 12 petition submitted on June 30th, 2016.

13 I am the Project Manager for this 14 petition and the PRB Chairman is Mr. Eric Benner. As 15 part of the PRB's review of this petition, the Union 16 of Concerned Scientists requested this opportunity to 17 address the PRB.

18 This meeting is scheduled from 1:30 to 19 approximately 3:00 Eastern Time. The meeting is being 20 recorded by the NRC Operations Center and will be 21 transcribed by a court reporter. The transcript will 22 be treated as a supplement to the petition and will 23 be made publicly available.

24 I'd like to open this meeting with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 1 introductions. As we go around the room please be 2 sure to clearly state your name, your position, and 3 the office that you work for within the NRC. I'll 4 start off with myself, Douglas Pickett. As previously 5 stated, I am serving as the Petition Manager.

6 MS. SANDERS: Hi, I'm Serita Sanders. I am 7 the backup for Ms. Banic as the Petition Coordinator 8 in the Office of NRR.

9 MR. BENNER: Eric Benner. As Doug said, 10 I'm the PRB Chair, and I'm a Deputy Director in the 11 Division of Operating Reactor Licensing in the Office 12 of NRR.

13 MR. HISER: I'm Allen Hiser, Senior-Level 14 Advisor in the Division of License Renewal, and I'm 15 a member of the PRB.

16 MR. CHERUVENKI: Ganesh Cheruvenki, 17 Materials Engineer, Vessels and Integrity Branch, 18 NRR.

19 MR. McHALE: I'm Jack McHale. I'm a Branch 20 Chief in NRR, Division of Engineering, and I'm a PRB 21 member.

22 MR. TATE: I'm Travis Tate. I'm a Branch 23 Chief in the Division of Operator Reactor Licensing 24 in NRR.

25 MR. HAIR: Hi, this is Chris Hair. I'm an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 attorney with the Office of the General Counsel.

2 MR. PICKETT: We've completed 3 introductions at NRC Headquarters in this room. At 4 this time, are there any NRC participants elsewhere 5 on the phone?

6 MR. MODES: Michael Modes, Senior Reactor 7 Inspector, Region I.

8 MR. PICKETT: That was Michael Modes, and 9 I think Russ?

10 MR. ARRIGHI: Yes, Russ Arrighi, Senior 11 Enforcement Specialist, Office of Enforcement. I'm a 12 PRB member.

13 MR. PICKETT: Are there any 14 representatives for the licensee on the phone?

15 MR. WALPOLE: Yes, Doug. It's Bob Walpole 16 and Dave Mannai, both from Entergy.

17 MR. PICKETT: Okay. Would the 18 representatives of the Union of Concerned Scientists 19 please introduce yourselves along with anyone else 20 assisting you for the record.

21 MR. LOCHBAUM: David Lochbaum, Director of 22 the Nuclear Safety Project from Union of Concerned 23 Scientists, and it's just me.

24 MR. PICKETT: All right. It is not 25 required for members of the public to introduce NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 themselves for this call; however, if there are any 2 members of the public on the phone that wish to do so 3 at this time, please state your name for the record.

4 Hearing nothing, is there anyone else on the phone 5 that we missed?

6 MS. SCRENCI: Doug, it's Diane Screnci in 7 Region I, Public Affairs.

8 MR. PICKETT: Okay.

9 MR. NEWMAN: Garrett Newman, Resident 10 Inspector.

11 MR. PICKETT: So we have the Resident 12 Inspector here?

13 MR. NEWMAN: Correct.

14 MR. PICKETT: Who was it?

15 MR. NEWMAN: Garrett Newman.

16 MR. PICKETT: Okay. Garrett Newman, 17 Resident Inspector, Office of -- somebody else spoke 18 at the same time?

19 MR. SHEEHAN: Neil Sheehan, Region I, 20 Public Affairs.

21 MR. PICKETT: Okay. Is there anybody else 22 on the phone with us?

23 MR. FLOYD: Lastly, this is Niklas Floyd, 24 Acting Senior Project Engineer, Division of Reactor 25 Projects, Region I.

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7 1 MR. PICKETT: Okay. I'd like to emphasize 2 that we each need to speak clearly and loudly to make 3 sure that the court reporter can accurately 4 transcribe this meeting. If you do have something 5 that you would like to say, please state your name 6 first. For those dialing into the meeting, please 7 remember to mute your phones to minimize any 8 background noise or distractions. If you do not have 9 a mute button, this can be done by pressing *6 key; 10 to unmute press *6 key again.

11 At this time, I'll turn it over to the 12 PRB Chairman, Eric Benner.

13 MR. BENNER: Thank you, Doug, and thank 14 you, Dave for scheduling this with us.

15 So good afternoon, welcome to the meeting 16 regarding the petition submitted by the Union of 17 Concerned Scientists. I'd like to first share some 18 background information on our process.

19 Section 2.206 of Title 10 of the Code of 20 Federal Regulations describes the petition process, 21 the primary mechanism for the public to request 22 enforcement action by the NRC in a public process.

23 This process permits anyone to petition the NRC to 24 take enforcement-type action related to NRC licensees 25 or licensed activities.

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8 1 Depending on the results of this 2 evaluation the NRC could modify, suspend, or revoke 3 an NRC-issued license, or take any other appropriate 4 enforcement action to resolve a problem. The NRC 5 Staff Guidance for the disposition of 2.206 petition 6 requests is in Management Directive 8.11 which is 7 publicly available.

8 The purpose of today's meeting is to 9 provide the Petitioner an opportunity to provide any 10 additional explanation or support for the petition 11 before the PRB's initial consideration and 12 recommendation. The meeting is not a hearing, nor is 13 it an opportunity for the Petitioner to question or 14 examine the PRB on the merits or issues presented in 15 the petition request. No decisions regarding the 16 merits of this petition will be made at this meeting.

17 And following this meeting, the PRB will conduct its 18 internal deliberations. The outcome of this internal 19 meeting will be discussed with the Petitioner, 20 though.

21 The PRB typically consists of a Chairman, 22 usually a Manager at the Senior Executive Service 23 Level at the NRC, which I do fulfill that; a 24 Petitioner Manager, who is Doug Pickett, and a PRB 25 Coordinator, normally Lee Banic but for today it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 Serita Sanders. We are not -- a number of members of 2 the Board here are basically based on their technical 3 and regulatory expertise to help, you know, derive an 4 effective evaluation of the petition.

5 As described in our process, the NRC 6 Staff may ask clarifying questions in order to better 7 understand the Petitioner's presentation and to reach 8 a reasoned decision whether to accept or reject the 9 Petitioner's request for review under the 2.206 10 process.

11 I'd like to summarize the scope of the 12 petition as we understand it under consideration and 13 the NRC activities to date. On June 30th, 2016, 14 sighting discovery of an unexpected degradation of 15 the baffle-former bolts at the Indian Point Nuclear 16 Generating Station Unit 2, the Union of Concerned 17 Scientists submitted a petition pursuant to 10 CFR 18 2.206 requesting the following enforcement actions.

19 One, NRC should issue an order requiring the Indian 20 Point licensee to inspect the baffle bolts and to 21 install the downflow to upflow modifications on Unit 22 2 during its refueling outage.

23 Two, NRC should issue a demand for 24 information requiring the Indian Point licensee to 25 submit an operability determination to the Agency NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 regarding continued operation of Unit 3 until its 2 baffle bolts can be inspected per the Materials 3 Reliability Project, 227A.

4 And lastly, three, NRC issue a demand for 5 information requiring the Indian Point licensee to 6 submit an evaluation of the performance goal and 7 operating experience of the Metal Impact Monitoring 8 System detecting and responding to indications of 9 loose parts such as broken baffle bolts within the 10 reactor coolant system.

11 On July 7, 2016, the NRC Staff contacted 12 the Petitioner by email to offer him the opportunity 13 to make a presentation before the PRB, and the 14 Petitioner was also reminded that the 2.206 process 15 is a public process. On July 12th the Petitioner and 16 the NRC Staff reached agreement to schedule the PRB 17 presentation for today.

18 As a reminder to the phone participants, 19 please identify yourself if you make any remarks as 20 this will help us in the preparation of the meeting 21 transcript that will be made publicly available.

22 Thank you.

23 At this point, I'll turn it over to Mr.

24 Lochbaum of UCS to provide any information he 25 believes the PRB should consider as part of this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 petition.

2 MR. LOCHBAUM: Thank you. This is Dave 3 Lochbaum with the Union of Concerned Scientists.

4 Thank you, Doug and Eric for that tee up, for setting 5 it up.

6 As indicated, the reason UCS requested 7 this opportunity to present to the PRB was to 8 basically highlight or summarize the request made in 9 our petition, and also to answer any clarifying 10 questions the PRB members or Staff may have for us.

11 With that, I'd like to start by pointing 12 out that by letter dated May 18th, 2016, which is in 13 ADAMS under ML16144A789, EPRI submitted to the NRC 14 summaries of the reactor vessel internals inspections 15 conducted at nine reactors during 2014 and 2015 under 16 MRP-227-A, the same procedure that identified the 17 degraded baffle bolts at Indian Point Unit 2. These 18 reactors had operated for 26.1 to 35.5 effective full 19 power years at the time these inspections were 20 conducted, with most having more operating time than 21 Indian Point Unit 2 did at the time of its discovery.

22 According to Table 4-2 in another EPRI 23 report, MRP-191 dated November 2006, which is in 24 ADAMS under ML12335A503, five of these reactors, or 25 five of these inspections were at reactors having the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 downflow configuration that Entergy identified as 2 contributing to the degradation at Indian Point Unit 3 2.

4 All things being equal then it would be, 5 therefore, expected that these reactors would have 6 more extensive baffle bolt degradation than was 7 experienced at Indian Point Unit 2, but that was from 8 the case and things are far from being equal. Only 9 one of the 864 bolts examined at Palisades had 10 indications. Only one of the 864 baffle-former bolts 11 examined at Oconee Unit 3 had an indication. Only 40 12 of 688 baffle-former bolts examined at Prairie Island 13 Unit 1 had indications. Only 15 of the 727 baffle 14 bolts examined at Point Beach Unit 2 had indications.

15 None of the 305 baffle bolts examined at Turkey Point 16 Unit 3 had indications. There were more degraded 17 baffle bolts identified at Indian Point Unit 2 than 18 at these five as old or older reactors combined. For 19 reasons not yet identified and confirmed, the baffle 20 bolts at Indian Point Unit 2 experienced more 21 degradation than the bolts at reactors with more 22 operating time.

23 Because of this unexplained 24 vulnerability, UCS requested in our petition that the 25 NRC order Entergy to take two corrective actions the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 company committed to take in its licensee event 2 report dated May 31st, 2016, which is in ADAMS under 3 ML16159A219; namely, to reinspect the bolts and to 4 install the downflow to upflow conversion during the 5 next Unit 2 refueling outage. We explained in our 6 petition why commitments alone aren't sufficient.

7 Between now and the next scheduled Unit 8 2 refueling outage, Indian Point Unit 3 is scheduled 9 to have its next refueling outage. Entergy separately 10 has committed to volumetrically inspecting the baffle 11 bolts on Unit 3 for the first time during that outage.

12 Consider for a moment the possible 13 outcomes from the Unit 3 bolt inspections. Few 14 indications of degradation could be found comparable 15 to the results from inspections at other reactors 16 during 2014 and 2015. That outcome would make Indian 17 Point Unit 2 an even more unexplainable outlier.

18 Alternatively, the Unit 3 bolt 19 inspections could reveal degradation approaching or 20 even surpassing that found on Unit 2. That outcome 21 would not help answer the question of why degradation 22 is so extensive on Unit 2, but it would reinforce the 23 need for the baffle bolts on Unit 2 to be reinspected 24 at the next convenient opportunity.

25 Our petition did not request that the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 issue an order compelling Entergy to conduct the 2 inspections of the baffle bolts on Unit 3 during the 3 refueling outage planned during 2017. Our request in 4 the petition to back commitments for the bolt issues 5 on Unit 2 with an order seems contradictory to our 6 request not seeking an order to back a commitment for 7 bolt issues on Unit 3, but that's only because it is 8 contradictory. Let me attempt to explain this 9 contradiction.

10 Our petition requested that the NRC issue 11 a Demand for Information requiring Entergy to conduct 12 an operability determination for Unit 3 continuing to 13 safely operate until the bolt inspections are 14 performed. We also requested that Entergy make its 15 operability determination publicly available by 16 placing it on the docket.

17 From our perspective, this operability 18 determination would answer the timing of the initial 19 inspection question. It is highly likely that an 20 operability determination would rely in part on time 21 until the bolt inspections are performed. In other 22 words, the operability determination would very 23 likely articulate reasons why it's acceptable to 24 safely operate Unit 3 until some future refueling 25 outage when the inspections of baffle bolts will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 performed. Such an operability determination would 2 establish boundaries and conditions for continued 3 safe reactor operation like an order would do.

4 The UCS feels the operability 5 determination to be the more appropriate vehicle in 6 the case of Unit 3, much more applicable or 7 appropriate than an order.

8 There is ample evidence indicating that 9 the baffle bolts are needed to affirm the 10 degradation; thus, Entergy's plan to reinspect the 11 bolts and implement the downflow to upflow conversion 12 during the next refueling outage on Unit 2 is sound, 13 so sound safety-wise that backing up that great 14 intention with a regulatory requirement is most 15 prudent. But there is enough evidence indicating that 16 the baffle bolts on Unit 3 are also degraded. Maybe 17 they are as degraded as the bolts on Unit 2, or maybe 18 they have little to no degradation like the bolts 19 inspected at several other reactors in 2014 and 2015.

20 Absent more compelling evidence, UCS does 21 not feel that requesting that the NRC issue an order 22 for baffle bolt inspections on Unit 3 or for letting 23 Entergy implement the downflow to upflow conversion 24 during its next refueling outage was justified.

25 UCS does feel that Entergy should be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 required to assemble and evaluate the scant evidence 2 that is available, and justify operating Unit 3 until 3 some future date when the bolt inspections are 4 performed.

5 Operability determinations for 6 situations like this one are standard industry 7 practice and are entirely consistent with the NRC's 8 longstanding expectations. Thus, in operability 9 determinations, the tried and true way to handle 10 situations like on Unit 3 at the moment.

11 Our third and final request in the 12 petition was for the NRC to issue a Demand for 13 Information to Entergy regarding the performance of 14 the Metal Impact Monitoring System at Indian Point.

15 There is no evidence publicly available indicating or 16 even suggesting that this system detected the loose 17 parts from the degraded and broken bolts on Unit 2.

18 That's the sole purpose of this system and yet it 19 seems to have utterly failed to perform this role.

20 This system, if it functions as intended, 21 could from part of the safety net for continued safe 22 operation of Unit 2 until someone figures out why its 23 bolts are so prone to degradation, and for the 24 continued safe operation of Unit 3 until someone 25 figures out whether its bolts are Unit 2-like, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 more like bolts elsewhere in the industry. But this 2 safety system seems to be nothing but a hunk of junk 3 occupying space without any redeeming value 4 whatsoever. Consequently, UCS feels that Entergy 5 should evaluate this system that's described in the 6 FSAR to determine whether it should play or can play 7 a useful role in proactively detecting baffle bolt 8 degradation.

9 Thank you for your consideration of our 10 issues, and I'll be glad to answer any questions from 11 the NRC Staff.

12 MR. BENNER: Okay, thank you, Dave.

13 I'm going to offer the opportunity for 14 the Staff here at Headquarters to ask any questions 15 of the Petitioner. I have some questions, but I'll 16 hold mine until everyone else speaks. So I'll start 17 here with the Staff in the room; do any of the Staff 18 in the room have questions for Dave?

19 MR. HISER: This is Allen Hiser of License 20 Renewal. Page 5 of your petition cites the Unit 3 21 UFSAR description of the loose parts monitoring. Is 22 that -- are similar provisions in the Unit 2 FSAR?

23 It's curious to me that you're citing Unit 3 but yet 24 you're concern was with the function of Unit 2.

25 MR. LOCHBAUM: This is Dave Lochbaum. For NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 the past decade, the NRC has been blanket withholding 2 FSAR updates, and only recently restarted putting 3 UFSAR updates in the public domain, so it's been very 4 challenging for the public to obtain access to FSAR 5 information. I assume that similar to Unit 2, but the 6 limited access that the NRC has afforded the public 7 to these documents makes me uncertain. So I chose the 8 documents I could find, and those that the NRC chose 9 to make available.

10 MR. HISER: Thank you.

11 MR. McHALE: This is Jack McHale from the 12 Division of Engineering. Just have a minor question; 13 on the petition on the top of page 4 it makes a 14 reference to Manual Chapter 0305 which is the 15 Operating Reactor Assessment Program. Is that a -- I 16 know there's an earlier reference to 0326 for 17 Operability. Does the 0305 come into play here, or is 18 that just a typo?

19 MR. LOCHBAUM: That's a typo; my mistake.

20 Yes, it went back to the middle -- the previous page 21 where I cited some criteria, and I just noticed it on 22 the next page.

23 MR. McHALE: Okay, so we're still talking 24 about the same areas. Okay, thank you.

25 MR. LOCHBAUM: That was the intention, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 it was mistake to get the number wrong.

2 MR. BENNER: Questions for Dave? Okay, it 3 seems we have no other questions in the room, so are 4 there any other questions from the Headquarters folks 5 on the phone? Hearing none, I'll turn it over to -

6 - are there any questions from our Regional 7 participants? Does the licensee have any questions or 8 comments?

9 MR. WALPOLE: This is Bob Walpole; no 10 comments, no questions.

11 MR. BENNER: Okay. Thank you, Bob.

12 So, Dave, my -- this is Eric Benner 13 again. Mine are less questions that just sort of 14 confirm kind of where -- our understanding of your 15 request. So for your -- so your request regarding the 16 order for Unit 2, is it safe to conclude that you 17 essentially find the Corrective Actions that have 18 been proposed by the licensee to appear to be 19 sufficient. What you're looking for is a stronger 20 regulatory footprint by the NRC to insure those 21 corrective actions actually get implemented.

22 MR. LOCHBAUM: That is correct. This is 23 Dave Lochbaum. That is correct. As we espoused in the 24 petition, we're a little concerned that that's -- the 25 current MRP 227-A guidance would allow that to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 deferred for up to 10 years.

2 MR. BENNER: Okay.

3 MR. LOCHBAUM: We think, as I said, the 4 corrective actions that Entergy provided a good ---

5 MR. BENNER: Okay. And then regarding your 6 request for the Demand for Information on Unit 3, 7 your logic there is, you know, in the absence of some 8 sort of publicly available information on the 9 applicability of this degradation mechanism to Unit 10 3, you don't feel you have enough information to 11 warrant, you know, proposing to the NRC anything that 12 would fall within the 2.206 process like, you know, 13 ordering inspections or ordering some other activity.

14 MR. LOCHBAUM: That's correct. We think 15 the operability determination when it can be done 16 would answer those kind of questions and would show 17 why waiting until the next refueling outage is a good 18 thing.

19 MR. BENNER: Okay.

20 MR. LOCHBAUM: What we've heard today is 21 that the reason Unit 3 is okay is because it doesn't 22 have as much operating time as Unit 2 did and, 23 therefore, it's less -- is likely to have experienced 24 less bolt degradation. That's why the information I 25 provided earlier in this call with even older NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 reactors with more operating time having less bolt 2 degradation seems to suggest that operating time is 3 not the primary factor in determining extended bolt 4 degradation. Where the operability determination once 5 performed would more fully address issues like that 6 and explain why Unit 2 is different.

7 MR. BENNER: But for me these two parts to 8 this, because typically we would -- the NRC would 9 look at operability determinations and the inspection 10 realm and, you know, as you well know, you know, the 11 inspection report when issued, you know, may not have 12 a sufficient level of detail that would allow you to 13 feel you could, you know, render judgments over the 14 underlying technical issues. So part of the issue 15 here is you're looking for a level of, you know, 16 public availability of this information.

17 MR. LOCHBAUM: That's a good point. It is 18 that second aspect, because this issue has attracted 19 so much attention, making an operability 20 determination is atypical but it seems appropriate 21 given the environment or the context that it's in.

22 MR. BENNER: Okay. Those were the only two 23 clarifications I had, so with that, before I conclude 24 the meeting, no members of the public identified 25 themselves, but members of the public may provide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 comments regarding the petition and ask questions 2 about the 2.206 petition process. However, as stated 3 in the opening, the purpose of this meeting is not to 4 provide an opportunity for the Petitioner and the 5 public to question or examine the PRB regarding the 6 merits of the petition request, so you certainly can 7 provide any comments, as desired.

8 Hearing none, I'd like to thank Mr.

9 Lochbaum for taking the time to provide the NRC Staff 10 with clarifying information on the petition you 11 submitted. And before we close does the court 12 reporter need any additional information for the 13 meeting transcript?

14 COURT REPORTER: Hi, this is the court 15 reporter. If I could get the representatives of the 16 licensee to please state their names for me, that 17 would be great.

18 MR. WALPOLE: Sure, I'll speak. My name is 19 Bob Walpole, W-A-L-P-O-L-E, and I'm the Regulatory 20 Assurance Manager for Entergy. And the other person 21 that was listening in on the call, his name is David 22 Mannai, M-A-N-N-A-I, and he also -- he's a Senior 23 Manager of Regulatory Assurance for Entergy.

24 COURT REPORTER: Okay. Thank you very 25 much.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 MR. BENNER: And with that this meeting is 2 concluded, and we'll be terminating the phone 3 connection. Thank you very much, all.

4 MR. LOCHBAUM: Thank you.

5 (Whereupon, the proceedings went off the 6 record at 1:59 p.m.)

7 8

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433