ML111520459

G20110221/EDATS: OEDO-2011-0226/2.206 Entergy Nuclear Operations, Inc., Fire Safety Regulations at Indian Point Units 1, 2 and 3--May 9 Meeting Summary

ML111520459
Person / Time
Site:	Indian Point
Issue date:	06/08/2011
From:	Pickett D Plant Licensing Branch 1
To:
Pickett D, NRR/DORL/LPL1-1, 415-1364
Shared Package
ml111520372	List: ML111520410 ML111520459 NRC-2011-0150, G20110221/EDATS: OEDO-2011-0226 2.206 Entergy Nuclear Operations, Inc., Fire Safety Regulations at Indian Point Units 1, 2 and 3--FR Notice
References
2.206, EDATS: OEDO-2011-0226, G20110221, OEDO-2011-0226, TAC ME5932, TAC ME5933, TAC ME5934
Download: ML111520459 (41)

Text

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~o June 8, 2011 LICENSEE:

ENTERGY NUCLEAR OPERATIONS, INC.

ENTERGY NUCLEAR INDIAN POINT 2, LLC ENTERGY NUCLEAR INDIAN POINT 3, LLC FACILITY:

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 1, 2, AND 3

SUMMARY

OF MAY 9, 2011, MEETING WITH THE A TIORNEY GENERAL OF THE STATE OF NEW YORK REGARDING THEIR 2.206 PETITION CONCERNING COMPLIANCE WITH FIRE PROTECTION REGULATIONS (TAC NOS. ME5932, ME5933, AND ME5934)

On May 9, 2011, a Category 3 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), representatives of the Attorney General's Office of the State of New York, and the licensee for the Indian Point Nuclear Generating Unit Nos. 1, 2, and 3 at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The list of attendees is provided as Enclosure 1.

On March 28, 2011, the Attorney General of the State of New York, the petitioner, submitted a petition pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 2.206 regarding compliance with fire protection regulations at Indian Point Nuclear Generating Unit Nos. 1, 2, and 3. The purpose of the meeting was to provide the petitioner with the opportunity to address the NRC Petition Review Board (PRB).

As described in Management Directive 8.11, "Review Process for 10 CFR 2.206 Petitions," the petitioner is provided the opportunity to address the PRB in order to provide any relevant additional explanation and support for the petition in advance of the PRB's evaluation. The meeting was recorded by the NRC's Operations Center and transcribed by a court reporter.

The transcript is provided as Enclosure 2.

Members of the public were in attendance. Public Meeting Feedback forms were not received.

- 2 Please direct any inquiries to me at 301-415-1364, or at Douglas.Pickett@nrc.gov.

Docket Nos. 50-247 and 50-286

Enclosures:

1. List of Attendees

2. Transcript cc w/encls:

Mr. Adam Dobson Assistant Attorney General Office of the Attorney General 120 Broadway, 26th Floor New York, NY 10271 Additional Distribution via Listserv

~Vf~

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Mr. John Sipos Assistant Attorney General Office of the Attorney General 120 Broadway, 26th Floor New York, NY 10271

LIST OF ATTENDEES MAY 9,2011, PUBLIC MEETING THE ATTORNEY GENERAL'S OFFICE OF THE STATE OF NEW YORK ENTERGY NUCLEAR OPERATIONS, INC.

PRESENTATION BEFORE THE NRC PETITION REVIEW BOARD New York Attorney General's Office John Sipos, Assistant Attorney General Jim Ostroff, Platts Nuclear Publications Adam Dobson, Assistant Attorney General Robert Snook, Assistant Attorney General State of Connecticut Richard Webster, Public Justice Anthony Royceman, Consultant to NY AG Entergy Nancy Salgado Bob Walpole Tanya Mensah Bill Glew Gerry Gulla Paul Bessette, Morgan-Lewis Stacey Rosenberg Lee Banic Scott Burnell John Boska Tim McGinty Dan Frumkin Brian Metzger Brett Kulkan Brice Bickett Keith Young John Rogge Doug Pickett

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

10 CFR 2.206 Petition Review Board RE Indian Point Docket Numbers: 05000247,05000286 Location:

Rockville, M D Date:

Monday, May 9, 2011 Edited by Douglas Pickett Work Order No.:

NRC-876 Pages 1-36 NEAL R. GROSS AND CO., INC.

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

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

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3 10 7

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1 11 12 The 13

McGinty, 1

presiding, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+ + + + +

CFR 2.206 PETITION REVIEW BOARD (PRB)

CONFERENCE CALL RE INDIAN POINT ON FIRE PROTECTION

+ + + + +

MONDAY MAY 9, 2011

+ + + + +

conference call was

held, Timothy G.

Chairperson of the Petition Review Board, 1

1 PETITIONER:

NEW YORK STATE ATTORNEY GENERAL PETITION REVIEW BOARD MEMBERS TIMOTHY McGINTY, Director, Division of Policy and Rulemaking TANYA MENSAH, 2.206 Coordinator 2

DOUG PICKETT, Petition Manager 2

NRC HEADQUARTERS STAFF 22 BRIAN METZGER, NRR Fire Protection Branch 23 DAN FRUMKIN, NRR Team Leader, Fire Protection 2

BRICE BICKETT, NRC Region 1 2

(Continued)

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2 NRC HEADQUARTERS STAFF (Continued)

KEITH YOUNG, NRC Region 1 JOHN ROGGE, NRC Region 1 NEIL SHEEHAN, NRC Region 1 NANCY SALGADO, NRR JOHN BOSKA, NRR BRETT KLUKAN, OGC GERRY GULLA, OE SCOTT BURNELL, Office of Public Affairs LEE BANIC, NRR STACY ROSENBERG, NRR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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PRO C E E DIN G S (1:00 p.m.)

MR. PICKETT:

Good afternoon.

I'd like to 6

welcome everyone here that's attending this meeting.

7 My name is Doug Pickett and I am a Senior Proj ect 8

Manager at the Nuclear Regulatory Commission.

9 We are here today to low Peti

oner, 1

Attorney General of State of New

York, 1

represented today by Mr. John Sipos, to address the 12 Peti Review Board, also referred to as the PRB 13 regarding the 2.206 petition submitted on March 28th, 2011.

I am the Petition Manager for the petition.

The Petition Review Board Chairman is Tim 17 McGinty on my right.

18 As part of the PRB's review this 19 petition, John Sipos has requested opportuni to 2

address PRB.

This meeting scheduled for two 2

hours, from one 0' ock to three o'clock.

22 This meeting is being recorded by the NRC 23 Operations Center and will transcribed by a court 24 reporter.

1 1

2 Also I

understand that we have a

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4 2

3 4

5 6

7 8

9 16 17 22 23 2

25 representative the press recording this meeting today.

The transcript will become a supplement to the

petition, and the transcript will also be made publicly-available.

We have public meeting feedback forms that you are welcome to fill out.

These forms are forwarded to our internal communications specialist and you may ther leave them here following the meeting or mail them back.

They are already postage paid.

I would like to open the meeting with the introductions.

As we go around the room, please be sure to early state your name, your position, and the of ce that you work for within the NRC for the record.

I'll start off.

I am Doug Pickett, the Petition Manager.

MR.

McGINTY:

I am Tim

McGinty, the Petition Review Board Chair.

MS. MENSAH:

I am Tanya Mensah.

I am the 2.206 Coordinator.

MR.

METZGER:

Brian Metzger.

I'm a

technical reviewer with NRR.

MR. FRUMKIN:

Dan Frumkin, Fire Protection Team Leader in the Office of NRR.

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5 1

2 3

4 5

6 7

8 9

10 1

12 13 1

1 16 17 18 19 2

2 22 23 2

2 MS.

SALGADO:

I'm Nancy Salgado.

I'm a Branch Chi in Division of Operating Reactor cens MR.

BOSKA:

I'm John

Boska, NRR Project Manager for Indian Point.

MR.

DOBSON:

Adam

Dobson, New York Ass tant Attorney General.

MR. SIPOS:

Hi.

Good ternoon.

This is John Sipos

's S i-p-o-s, Assistant Attorney General for State of New York.

MR.

GULLA:

Gerry Gulla, NRC Office of Enforcement.

MR.

OSTROFF:

I'm Jim Ostroff.

I'm a senior editor with Platts Nuclear Publications.

MS.

ROSENBERG:

Stacy Rosenberg.

I am a Branch Chief, of Generic Communications.

MS.

BANIC:

Merrilee c

of Generic Communications and Power

Uprate, Petitions Coordinator.

MR. BURNELL:

Scott Burnell, NRC Office of Pub1 Affairs.

MR.

BESSETTE:

Paul

Bessette, Morgan, Lewis & Bockius.

MR. GLEW:

Bill Glew, Entergy Legal.

MR.

WALPOLE:

Bob

Walpole, Licensee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW.

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6 1

Manager at Indian Point.

2 MR.

PICKETT:

Okay.

We have completed 3

introductions at the Entergy Headquarters.

At this time are there any NRC participants from Headquarters that are on the phone?

MR.

KLUKAN:

s Brett Klukan 7

from the NRC Office of General Counsel.

I'm the 8

Attorney Advisor to the PRE.

9 MR. PICKETT:

That was Brett Klukan.

1 Are there any NRC participants from the 1

Regional Of ce on the phone?

12 MR. BICKETT:

Yes.

This is Brice Bickett, 13 Senior Project Engineer, NRC Region 1.

MR. PICKETT:

Any others?

1 MR.

YOUNG:

Kei Young, NRC, Inspector, 16 Region 1.

17 MR.

SHEEHAN :

Neil Sheehan, NRC Public 18 Af rs, Region 1.

19 MR. ROGGE:

John Rogge, Branch Chief from 2

Region 1.

21 MR.

PICKETT:

Okay.

And are there any 22 representatives for the licensee on phone?

23 (NO response.)

2 MR. PICKETT:

Okay.

Mr. Sipos, would you 2

please introduce yourself for the record.

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MR.

SIPOS:

Sure.

Good afternoon.

This 2

is John Sipos, S-i-p-o-s, Ass tant Attorney General.

3 MR. PICKETT:

Thank you.

It not required for members of the public to introduce themselves for this call, however 6

if there are any members of the public on the phone 7

who would like to introduce themselves, please state 8

your name for the record.

9 MR.

SNOOK:

This is Robert

Snook, 1

As stant Attorney General for the State of 1

Connecticut.

12 MR. WEBSTER:

And I'm Richard Webster from 13 Public Justice.

1 MR. ROISMAN:

And this is Anthony Roisman.

15 I'm a

consultant to the New York State Attorney 16 General's Office.

17 MR. PICKETT:

Not hearing any more.

18 I'd like to emphasize that we each need to 19 speak clearly and loudly to make sure that the court 2

reporter can accurately transcribe this meeting.

If 21 you do have something that you would like to say, 22 please first state your name for the record.

23 For those dialing into the meeting, please 24 mute your phone to minimize any background noise or 2

distractions.

If you do not have a mute button, this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW, (202) 234*4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com

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2 3

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11 12 13 1

1 16 17 18 19 2

21 22 23 2

25 can be done by pressing the keys "star, 6. II To unmute, press the "star and 6" keys again.

At this time I'll turn it over to the PRB Chairman, Tim McGinty.

MR.

McGINTY:

Thank you, Doug.

Good afternoon.

Welcome to this meeting regarding the 2.206 Petition submitted by the Attorney General of the State of New York.

Representing the Attorney General's Office is Mr. John Sipos.

I would like to first share some background on our process.

Section 2.206 of Title 10 of the Code Federal Regulations describes the tion Process, the primary mechanism for the public to request enforcement by the NRC in a public process.

This process pennits anyone to petition the NRC to take enforcement type action related to NRC licensees or licensed activities.

Depending on the results of this evaluation, NRC could modify, suspend or revoke an NRC-issued license or take any other appropriate enforcement action to resolve a problem.

The NRC staff guidance for the disposition of the 2.206 Petition Request is in Management Directive 8.11, which publicly available.

The purpose of today's meeting is to give NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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9 1

the Petitioner an opportunity to provide any 2

addi tional explanation or support for the petition 3

before the Petition Review Board's initial 4

consideration and recommendation.

This meeting is not a hearing, nor is it 6

an opportunity for the Petitioner to ques on or 7

examine the PRB on the merits or the issues presented 8

the Petition Request.

No decisions regarding the 9

merits of this Petition will be made at this meeting.

1 Following this meeting the Petition Review 1

Board will conduct its internal deliberations.

The 12 outcome of this internal meeting will be discussed 13 with the Petitioner.

1 The Petition Review Board typically 15 consists of a

chairman, usually a manager at the 16 senior executive service level at the NRC.

It has a 17 Petition Manager and a PRB Coordinator.

18 Other members of the Board are determined 19 by the NRC staff based on the content of the 2

information the Petition Request.

2 At this time I'd like to introduce the 22 Board.

We previously went around the room.

I'm Tim 23

McGinty, the Petition Review Board Chair.

Doug 2

ckett is Petition Manager for the Petition under 2

Discussion today.

Tanya Mensah is the Office I s PRB NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1

Coordinator.

2 Our tec~~ical staff includes Brian Metzger 3

from the Office of NRR's re Protection Branch.

Gerry Gulla from the Office of Enforcement.

Brice Bickett and Keith Young you heard from NRC Region 1 on 6

the phone.

They are up King of

Prussia, 7

Pennsylvania.

8 Dan Frumkin, Team Leader for the Office of 9

Nuclear Reactor Regulations, Division of Risk 1

Assessment.

And on the phone also we obtain our legal 1

advice from the Of of General Counsel, represented 12 by Brett Klukan.

13 As described in our process, the NRC staff 1

may ask clarifying questions in order to better 1

understand the Petitioner's presentation and to reach 16 a reasoned decision as to whether to accept or reject 17 the Petitioner's Request for Review under the 2.206 18 process.

19 I would like to summarize the scope of the 2

Petition under consideration and the NRC's activities 21 today.

22 On March

28th, 2011, Mr.

Eric 23 Schneiderman, Attorney General for the State of New 24 York who will be referred to as the Petitioner, 2

submitted a Petition under Title 10 of Code of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 Federal Regulations, Part 2.206, regarding fire 2

protection requirements at the Indian Point Nuclear 3

Generating Unit Number 1, 2 and 3.

The Petitioner cribes the proximity of 5

Indian Point to population centers within a 50-mile 6

radius of the site.

The Petitioner states that the 7

population density within the 10-mile and 50-mile 8

radius the site is greater at Indian Point than any 9

site in the country.

1 Furthermore, the Petitioner states that 1

the site was selected in March 1955 which was before 12 the Atomic Energy Commission, AEC, or NRC established 13 siting criteria.

1 The Petitioner described how approximately lone-half of all core damage risk at operating reactors 1

result from accident sequences that initiate with fire 17 events.

18 The Petitioner described the Browns Ferry 19 f

of 1975 and the subsequent development of fire 2

safety regulations found in 10 CFR 50.48 and Appendix 2

R.

22 The Petitioner describes these 23 prescriptive requirements found in Appendix R.

The 2

Petitioner states that Indian Point is required to 2

comply with the fire safety requirements of Appendix R NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

12 1

because the reactors were licensed to operate prior to 2

January 1st, 1979.

3 The Petitioner describes past 4

investigations by the NRC I s Office of the Inspector General and the Government Accountability Office 6

surrounding fire barriers, most specifically, Thermo 7

Lag and Hemyc.

8 The Petitioner implies that the NRC staff 9

has neither been aggressive resolving fire barrier 1

issues, nor has it taken meaningful enforcement action 1

with regards to Indian Point.

12 The Petitioner focuses on exemptions 13 to Appendix R were submitted by the licensee 1

March 2009.

The exemptions include operator manual 1

actions and a large number f

areas at Indian 16 Point.

17 The Petition states that the regulations 18 do not authorize operator manual actions as a means of 19 protecting a

redundant system from fire.

The 2

Petitioner erences the current situation in Japan 2

and questions whether plant operators would be 22 physically able to perform these duties.

23 In conclusion, the Petitioner states that 2

the exemptions should be reserved for extraordinary 2

circumstances.

The NRC should not approve the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1

exemptions and that Entergy has not made a serious 2

effort to comply Wl Federal regulations.

3 wi regard to enforcement action, the Peti oner requested the following immediate actions.

5 Number one, identi the violations of 10 CFR 50.48, 6

Appendix R, Paragraph III, F and G that exist as of 7

the date this Petition, that is, March 28th, 2011 8

at Indian Point Units 1, 2 3.

9 Number

two, compel Entergy Nuclear 10 Operations and its affiliates to comply on or before 1

September 20th, 2011 with requirements contained 12 in 10 CFR 50.48, Appendix R, Paragraph III, F and G, 13 for all the fire zones in Indian Point Unit 2 and 14 Indian Point Unit 3, and any Indian Point t 1 fire 1

zone or system, structure or component relied on by 16 Indian Point t 2 or Indian Point Unit 3.

17

And, thirdly, convene an evidentiary 18 hearing before commission to udicate the 19 violations by Entergy Nuclear Operations and its 2

affiliates of 10 CFR 50.48, Appendix R, Paragraph III, 2

F and G at Indian Point Unit I, Unit 2 and Indian 22 Point unit 3.

23 Allow me to scuss the NRC activities to 2

date.

On April 1st, the Petition Manager contacted 25 you to discuss 10 CFR 2.206 process and offer you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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14 an opportunity to address the PRE by phone or in 2

person.

3 You requested to address the PRE in person 4

prior to the PRE's internal meeting to make the 5

initial recommendation to accept or reject the 6

Petition for Review.

7 On April 5th the PRB met internally to 8

cuss the request for immediate action.

On April 9

12th you were informed that the PRB denied your 1

request for immediate action because the licensee 1

submitted a request for exemptions in accordance with 12 NRC guidance and enforcement policy as described in 13 Regulatory Issue Summary 2006 10.

1 Enforcement discretion is applicable 15 during the staff review of the exemptions, which are 16 currently being evaluated against the criteria of 17 NUREG 18 entitled "Demonstrating the Feasibility and 18 Reliability of Operator Manual Action in Response to 19 Fire."

2 Also, the licensee evaluated the credited 21 Operator Manual Actions against the acceptance 22 criteria of NRC Inspection Procedures 71111.05T and 23 confirmed them to be feasible and reliable operator 2

actions during the post fire coping scenario.

2 And lastly f the PRB concludes that: one, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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licensee's actions are within an NRC-defined 2

process;

two, enforcement cretion is applicable; 3

and, three, there are no immediate safety concerns.

Therefore, there is no basis to immediate action.

As a reminder for the phone participants, please identi yourselves if you make any remarks, as 7

s will help us in the preparation of the meeting 8

transcript that will be made publicly-available.

9 At this point, Mr. Sipos, I will turn lover to you to allow you to provide any information 1

you believe the PRB should consider.

12 MR.

SIPOS:

Thank you very much, Mr.

13 McGinty.

I appreciate your opening remarks and, on 14 behalf of the Petitioner, the Attorney General of the 1

State of New York, Mr. Eric Schneiderman, I appreciate 1

all the arrangements that have taken place to bring 17 about this meeting, and we're appreciative being 18 able to speak with you today.

19 With me is my colleague, Ass tant 2

Attorney General Adam Dobson, D-o-b-s-o-n, who will be 2

assisting me today at today's hearing.

22 Before I into some of detailed 23 comments that we have for today, I thought it would be 2

good to discuss some procedural

sues, as well.

2 First, that the Attorney General's request to this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" N,W.

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16 Petition Review Board is that this Board accept the 2

Petition for enforcement.

3 As we understand it, that can then result 4

in a

hearing, a

proceeding before the Commissioners, themselves, as was done in case 6

back in 1978 involving some other fire protection 7

matters.

And I refer the Board to 7NRC400, April 13, 8

78 rul in matter of tion for Emergency 9

and Remedial Action which was filed by Union of 1

Concerned Scientists in the wake of Browns Ferry.

1 Secondly, we would like an opportuni to 12 review the transcript just for typographical errors if 13 one is generated from today.

We find that that can 1

often times lead to clarity and resolve some 1

unintended typographical

issues, things of 16 nature.

17 And third, in connection with Management 18 Directive 8.11, Part III B, I guess the tioner 19 would note, since we can't a

question, that 2

there's potentially an issue of whether or not anyone 2

on the Board had, in past, worked on Indian Point 22 specific fire-rel issues.

23 Again, I'm not asking a question because I 24 understand I can't, but I just -

I note that is 2

a reference the Management Directive to that, and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 just wanted you to apply to that.

2 MR. McGINTY:

Thank you.

3 That would turn into a

conflict of interest by working on it?

5 MR. SIPOS:

Not necessarily a conflict of 6

interest in a financial sense or anything 1

that, 7

but there may be 8

MR.

McGINTY :

Maybe employed by Indian 9

Point?

Maybe they worked on 1

MR.

SIPOS:

I hadn't thought of being 1

employed by Indian Point, though I guess that would 12 be that could be an issue.

13 Mr. Pickett:

Where that?

MS.

MENSAH:

[If you re to page 8 of Management Directive 8.11, it states] "In assigning techni staff members to the petition, management will consi any potential conflict from assigning any staff person who was previous involved with the issue gave se to the petition."

MR. SIPOS:

I don't know one.

I'm not 21 asking a

question.

I'm just flagging it as a

22 potential 23 MR.

McGINTY:

Thank you.

We appreciate 2

it.

25 MR.

SIPOS:

I'm sure you've taken that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW.

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into account.

The Attorney General's Petition, simply stated, is a straightforward request for enforcement action by the Nuclear Regulatory Commission.

They are the Federal regulator that responsibility for the fire protection regulation.

The Attorney General, as set forth in the Petition, sees it as a very straightforward regulation that contains speci proscriptive requirements and, furthermore, based on Entergy's regulatory submissions to NRC, it apparent that there are violations of Appendix Paragraph III requirements and that these violations have continued for quite some time.

It appears as long as the plant has owned and operated by Entergy, and likely before that time.

So, it not the type of Petition Enforcement Action where there are some vagaries or there's some question.

It's a straightforward, simple regulat I believe the present Chairman of the NRC has characterized the regulations that manner, and Entergy's filings, which we take at face value, show that there are violations.

I'm sure folks are liar with the regulations.

I'm not going to belabor them.

They are I

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19 1

2 3

5 6

7 8

9 10 11 12 13 1

1 16 17 18 19 2

2 22 23 they were developed the wake 0 f Browns were developed after General Design Criteria 3 had been

around, there was a

decision to promulgate and have specific proscriptive standards for fire protection the wake of Browns Ferry and in the wake of tigations and internal NRC review of risk and fire safety.

That provision uses the mandatory word "shall,"

s 1 1,

which, you

know, requires compliance.

And also that regulation does not use the term "operator manual action."

That term is not used the regulation and does not it's not on the of the regulation, it's not contained in the regulation.

NRC's position, as the Attorney General's Off has able to determine is that not only or not only are OMA' s not mentioned, not only is term OMA not mentioned or the term "operator manual action" not mentioned the regulation, but that Entergy recognized that NRC's position is that OMA's are not explici or implicitly permitted by the regulation.

And I'm referring back to March 2009 exemption request led by Entergy Nuclear Operation.

Moreover, that reliance on operator manual actions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 without specific review and approval is a violation of 2

Appendix R.

Again, that

, as we understand it, the 3

NRC's posi on, and we tand that Entergy 4

tands to be NRC's position.

5 And have discussions 6

that the Attorney General's Off is aware of, of 7

standard called NFPA

805, National Fire Protection Association, Standard Number 805, but that issue or that -- that mechanism is not at issue at Point because as the Attorney General's Office understands 1

1 things, that is, that Indian has elected not to 12 go down the NFPA 805 route and,

fore, the 13 Appendix R, Paragraph III, standards apply.

1 Entergy's 2009 fi with the Commission 15 where sought Commission approval what had been 16 going on in an unauthorized manner at the 17 ified various zones, various fire areas, various 18 fire zones and ous OM.A.'s.

19 By the count -- by our count identified 2

more than a hundred operator manual actions in that 2

filing and it identifi approximately 270-plus 22 zones within Indian Point t 2 and Indian Point 23 unit 3 that rely on operator manual action.

24 Those numbers are objectively high, but 2

that is a high number, and it was there was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW.

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supplemental information provided, and I'm 21 referring 2

3 to a 2010.

document that came in about a year ago, May 4, 4

This was in response to a request for additional information by the NRC s in response to 6

RAI 02.2 which asked for "List the requirements of 7

Paragraph III in G2 that are not met for OMA's in 8

- at issue."

9 Entergy responded on May 4,

2010, and 1

identi ed, by our count, 50 fire zones, 50 separate 1

zones where there was a lack of compliance with 12 Paragraph III G2.

13 In other words, that filing, Entergy 1

identified 50 zones where there were violations of the 1

fire safety regulations that had been in place since 16 1980.

That is NL-I0 042 for Indian Point Unit 2 and 17 NL-I0-043 Indian Point Unit 3.

18 ML on the latter is MLI01320263, and 19 that - the zones are identified in a series tables 2

in back of that document and it starts off, for 2

Indian Point Unit 2, a table, RAI-GEN - G-E-N-l, and 22 it goes through to GEN 27.

23 That would be Indian Point Unit 2 and 2

I believe for Indian Point Unit 3 it's a simi title 25 for the table.

I think it goes from GEN-21 to GEN 23, (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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22 1

ling together, 50 separate zones.

2 The Attorney General's Office believes 3

that it's important to emphasize that e regs were promulgated 30 years ago and that the facility should have in compliance.

6 These 50 zones identi in 7

correspondence a year ago, the more than 100 OMA' s identif two years ago, this should have been this facility, this operator should have been 1

compl and, again, that the term "operator manual 1

action, "

not contained in the Federal Regulation.

12 It probably doesn't need to 13 overemphasized or said too often that e

are 1

important regulations.

I'm sure NRC the view 1

that all its regulations are important, as any 16 regulatory body would.

17 e

regulations go to ensuring 18 safety, the workability cables that operate safety 19 systems at power reactors and ensuring that these 2

cables can operate during the events or the event 2

of a reo They are -- they go to heart of what's 22 going on within the power reactor.

23 Mr.

McGinty summari the Peti on and 2

some of the other some of the components in 25 Petition and I would just like to reiterate or expand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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23 1

on a couple them.

2 Indian Point unique.

It the 3

highest surrounding population by far and away of any power reactor in the country, whether you're looking at it at ten mi or 50 miles, no plant, no reactor 6

site in the country comes close.

7 are more than 17 million people that 8

live with 50 miles.

That number is expected to grow 9

by 2035 and the facility is wi five les of one 1

reservoir of the New York ty watershed, that is the 11 New Croton Reservoir, and 15 miles wi thin another 12 important reservoir, a little further to south 13 Westchester County.

14

Again, that watershed provides the 1

drinking water for the New York for New York City 1

and its tizens.

17 New

York, it not is 18 financial center of

country, provides a

19 transportation hub and it a very critical area 2

wi the States -- wi the ted States.

2 Seismicity has got some attention 22 recently, and in in latter part of March 23 there was a report about ongoing seismic analysis, 24 perhaps consultation with the United States 2

Geologic ce, and there was a report the New NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1

York newspapers and so on television scuss the 2

core damage frequency Indian Point Unit 3 as well 3

as the CDF Unit 2.

Uni t 3 apparently has a very high core damage frequency according to the media reports and o Unit 1, which has around since the late 7

Fifties, came on line the early Sixties, it is not 8

clear that there is a

seismic spectra that 9

ility at all and is seismically more fragile -

1 I don't think there's any dispute as to that --

than 1

the two facilities which are next to it.

12 For sure, that not generating power 13 now.

Unit 1 is not generating power, but it is 1

1 there and there are shared or interconnected systems 1

identified by Con Edison several years back, so there 16 is a seismic concern.

17 Petition did cite a Sandia report that 18 noted that seismic events can a contributor to fire 19 or re initiators, so the Petition would that 2

that be taken account.

2 There's also the issue of security.

I'll 22 keep my remarks on this brief and limited to publicly 23 available material, but NRC, itself, has acknowledged 2

that there is a,

"high-level threat 2

environment," close quote, the wake of 9/11.

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25 1

That's In 67 Federal Register 9792, March 2

4, 2002.

There -

the f'eti on identi es concerns 3

that, if taken that have to come to fore in the wake of 9/11, including what happened on that date.

The 9/11 report goes into additional detail about the 6

plans of the terrorists at that time and we would note 7

that as well Board.

8 The State of the Union, which came a year 9

after that also confirmed publicly the threat 1

situation that exists, there was a reference in that 11 to power plant diagrams.

12 And just t week the Daily News reported 13 and we have a copy of it here, I' be happy to 1

hand it out at the end -- that there appeared to be 1

surveillance at the Sellafield facility in England in 1

which people were arrested for that.

17 It the Attorney

's Office 18 position is that at a time of increased threat, given 1

the design bas threat, given interim compensatory 2

measures and given concerns about aircraft impact 2

analysis and B.5.b issues, that it is certainly 22 appropriate for the fire safety regulations that were 23 promulgated in 1980 to enforced and for Entergy to 2

- to comply with those regulations.

We've talked about remedies that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.

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26 1

2 3

4 5

6 7

8 9

1 1

12 13 1

15 16 17 18 19 2

2 22 23 24 2

Petition seeks.

Again, we would like this Board to accept the Petition for Review.

We think

's a

straightforward Petition tenus of an evidentiary matter, and that there real is there's ly no excuse for the lack of compliance with these regulations.

As we noted earlier, what Entergy now seeks to have authorized at this facili is not specifically mentioned.

Entergy said

's not prohibited, but it's very clear that it's not authorized operator manual action.

It appears that this is a case where Entergy simply disagrees with the application of Appendix R, that it's not to its liking, and that it does not wi to comply with the plain meaning that regulation.

The Petition and the Attorney General's fice believes it's appropriate NRC to compel compliance of those regulations at this facility, that the regulations are on the books.

They've been on books for 30 years, and it's there appears to be widespread noncompliance, widespread violations at the site and it's now time to compel compliance.

One -- one other -- one other fact before NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W (202) 234-4433 WASHINGTON, D,C. 20005-3701 www.nealrgross.com

27 I

conclude.

The Price-Anderson Act provides for 2

taxpayer financed response to a

nuclear incident.

3 That's been around since 1957.

Congress determined that was necessary.

But, in exchange for that arrangement it 6

is es that the Indian Point facility comply 7

with fire saf regulations.

An accident at 8

Indian Point would likely be quite expensive, 9

certainly relative to other facilities in the country 1

given dense population and the highly-developed 11 and built-out infrastructure within the 50-mile area.

12 We understand the existence, and we 13 understand the program behind Price-&~derson, but 1

Entergy should comply with the fire safety regulations 1

which have been around since 1980.

16 I think that concludes my comments.

I'd 17 like to thank you 1

your time and for arranging 18 today' s meeting.

&~d again, we would request that 19 despite Entergy' s request for an exemption, that the 20 Petition Review Board accept the Attorney General's 2

Petition for enforcement action at this area.

22 Thank you very much.

23 MR. PICKETT:

Thank you.

2 At this time, based on what you've hea~d, 2

does the f here at Headquarters have any questions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.

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28 1

for Mr. Sipos regarding 2

Any of the staff on the phone from the 3

Regions, do you have any questions?

MR.

KLUKAN:

This is Brett Klukan, attorney advisor to the PRB.

I have one question, a quick question for the Petitioner.

7 The Petition characterized the violations, 8

but certainly the basis for the Petition as being 9

apparent.

Is that the case and I just want to be 1

able to understand this so that I

can accurately 11 advise the PRE on moving forward on how the 12 disposition or position.

13 If the violations are apparent, what would 1

be the point of requested evidentiary hearing?

1 MR.

SIPOS:

There could be two purposes.

1 One would Are there any further violations?

We 17 have the tables that were referred to before, the RAI 18 GEN, G-E-N tables as well as the 2009 submission.

19 As to those -- as to the zones and OMA 's 2

identified in there, there need not be an evidentiary 2

hearing.

There it is possible that there are 22 additional

zones, given breadth or the shear 23 volume of violations, but I mean, there's also you l

2 know, the potential of civil penalties that could come 25 up at a hearing.

You know, the Attorney General's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W.

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29 1

Off is interested in ensuring compliance and 2

ensuring that this facility complies with these 3

regulations.

4 We recognize

, you know, the licensee might request a hearing although, you know.

We don't 6

know how it could contest the violations are 7

already identified in this, in the filing.

8 MR. KLUKAN:

Thank you.

9 That's all for me.

1 MR. McGINTY:

Thank you, Brett.

1 And once again, I'll ask, any questions 12 from any of the s in Region -- in the Regions?

13 (NO response.)

1 MR. McGINTY:

Also there's

- we have some 1

representatives of the licensee here.

Do you have any 1

does licensee have any questions or comments?

17 MR.

BESSETTE:

We have no comments or 18 questions, thank you.

19 MR. McGINTY:

As I previously stated, the 2

licensee is not part of the PRB's decisionmaking 2

process.

Before I conclude the meeting, members of 22 the publ may provide comments regarding the Petition 23 and ask questions about the 2.206 tion process.

2

However, as stated at

opening, the 25 purpose of this meeting does not include the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.

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30 opportunity for Petitioner or public to 2

ques tion or examine the PRB regarding the meri ts of 3

Petition Request.

4 With that stated, are there any questions from members of the public?

6 MR. SNOOK:

This is Robert Snook from the 7

State of Connecticut, S-n-o-o-k.

We just want to go 8

on record supporting position the Attorney 9

General of New York in this, urging the PRE to accept this tion.

1 1

MR. McGINTY:

Mr. Snook, that is so noted.

12 MR. SNOOK:

Thank you.

13 MR. WEBSTER:

And this is Richard Webster 1

from Publ Justice.

I'd like to ask how long has this lack of compliance existed and has NRC staff 16 taken any moves to correct the lack of compliance.

17 MR.

KLUKAN:

Mr.

Webster, as was just 18 pointed by Petition Chairman, and this, in 19 can echo through the substance of the tion.

1 I f you have any ques ons regarding the 2

2.206 process or the contents of Management Directive 2

22 8.11 which guides the staff execution the process, 23 we'd happy to answer those here.

24 But again, the purpose of this public 2

meet today is not for the s or for members of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 1

the public or the Petitioner to ask any questions, 2

tual or otherwise regarding the substance of the 3

Petition.

But -- so thank you.

MR. WEBSTER:

could I a question 6

about the enforcement process?

7 MR.

KLUKAN:

Yes.

You are more than 8

welcome to a

question about the enforcement 9

process as it relates to 2.206 process.

1 MR.

\\ilJEBSTER:

Well, can I does the 1

NRC have any guidelines correcting noncompliance 12 at nuclear power plants?

13 MR. KLUKAN:

is a very

, broad 1

question, so

's difficult to come to through, and 1

answer is yes.

The licensees are required to have 16 corrective action programs and as part of the NRC 17 enforcement

process, the staff does take into 18 consideration what correct actions licensee has 19 taken in response to identified violations.

2 I mean, that's a very broad answer 2

MR. WEBSTER:

ght.

22 MR.

KLUKAN:

but, it's fficult to 23 summarize it otherwise.

2 MR. WEBSTER:

I, I unders that but 25 I

think the question my question more about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1

timing.

Is there any limit, time limit for how long 2

the corrective action could

occur, or the 3

correction 4

MR.

GULLA:

This is Gerry Gulla with 5

Enforcement.

There are documents publicly-available on our website.

You might want to look into 7

Enforcement Manual the Enforcement Policy and if 8

you read those documents you should be able to get 9

those tions answered.

1 MR.

WEBSTER:

Well, could you possibly 11 answer them me now?

12 MR. McGINTY:

Mr. Webster, pertaining to 13 question this Tim McGinty, the PRB 1

As Brett Klukan mentioned

earlier, 1

questions that are directly applicable to the 2.206 161 tion Reques tare what you. have an opportuni to 17 address the PRB on, and so I think he's then pointed 18 to information that will be helpful to your general 19 curiosity, but we really don't need 20 MR. WEBSTER:

Right.

21 MR. McGINTY:

But we ly don't

, at 22 this point, to the time all the f

23 and the Board to that question.

2 MR.

WEBSTER:

Okay.

Well, can T

ask 25 another question, then, which is just does -

if NEAL R. GROSS (202) 234-4433 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W WASHINGTON, D,C, 20005-3701 www,nealrgross.com

33 1

the PRB finds lack of compliance does have does 2

it then analyze time for which that lack of 3

compliance has ted?

4

MR.

McGINTY:

So that would also so 5

that would be a question if I could rephrase your 6

question.

And again, s is actually what I consider 7

to be more a question about our enforcement process 8

as opposed to this Petition Request.

9 But, within the enforcement process, time 1

lS a factor, yes.

1

MR.

KLUKAN :

And I would point out 12 purpose of the PRB, Mr. Webster, whether to accept 13 or rej ect the Petition.

It's not the purpose of 14 PRE at this stage is not to determine what the 1

outcome would be or even how it would be dispos

ion, 16 were it to be accepted.

17 The ly -

under the 2.206 process the purpose of PRB and this Petition Review Board is to determine whether to accept or rej ect into the

process, 2.206 process the Petition as stated by the Petition the State New 22 So,

's that -- that goes just further on 23 down the 1

, which is not necessarily the purpose of 2

the PRE at this stage in this area.

2

MR. PICKETT:

Okay.

Thanks, Brett.

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34 Are there any other questions?

2 (NO response.)

3 MR.

PICKETT:

Okay.

Thank

you, Mr.

Webster.

Any other questions or any other individuals that are on the 1 listening (No respons e. )

MR. PICKETT:

Okay.

Before we I don't believe that the court report -

I did get a report that the court reporter was having trouble dialing in.

1 Does the court reporter happen to be on 1

the line?

12 THE COURT REPORTER:

Yes, I am on the line 13 now.

14 MR.

PICKETT:

As we discussed prior to 1

your joining us, that NRC's Operations Center has 16 the capability and we confirmed that the 17 Operations Center was recording these this particular scussion.

d you however, not knowing exactly when you

joined, do you have any additional 21 information for meeting transcript that you need 22 repeated or anybody's name to be identified?

Is there 23 any way we can you?

2 THE COURT REPORTER:

I think I'll be able 2

to get most of it from --

Mr. Boska on the line?

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 WW'W.nealrgross.com

35 I've worked with him before.

2 MR. PICKETT:

Yes, Mr. Boska is with 3

us ln the room.

4 THE COURT REPORTER:

Okay.

I can get NRC participants from him and I'm ident that.

6 But if the representatives from the New York Attorney 7

General's Office can identify themselves, I

would 8

appreciate it.

9 MR. SIPOS:

We will do that one more t 1

Would you like us to do that now?

Okay.

We will do 1

that now.

12 Adam, why don't you speak first.

13 MR.

DOBSON:

Adam

Dobson, Assistant 1

Attorney General, State of New York.

And that's D-o 1

b-s-o-n.

16 MR. SIPOS:

And s is John Sipos,

-p 17 o-s, Assistant Attorney General.

18 THE COURT REPORTER:

And who was the 19 leman who was making the presentation when I came 2

in, which was about 1:25?

2 MR. SIPOS:

That was probably me.

It may 22 been Mr. McGinty.

23 THE COURT REPORTER:

No.

It was 24 definitely the New York Attorney General Office's 2

MR. SIPOS:

Okay.

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36 1

THE COURT REPORTER:

presentation on 2

the an factors.

3 MR. SIPOS:

That would be me, John Sipos.

THE COURT REPORTER:

Thank you, Mr. Sipos.

I appreciate that.

MR. McGINTY:

Okay.

This is McGinty 7

again, the PRE Chair.

So, without any further adieu, 8

s meeting will be concluded and we'll be 9

terminating the phone connection.

1 (Whereupon, conference call was 1

concluded at 1:55 p.m.)

12 13 14 22 23 24 2

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- 2 Please direct any inquiries to me at 301-415-1364, or at Douglas.Pickett@nrc.gov.

Ira!

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosures:

1. List of Attendees

2. Transcript cc w/encls:

Mr. Adam Dobson Mr. John Sipos Assistant Attorney General Assistant Attorney General Office of the Attorney General Office of the Attorney General 120 Broadway, 26th Floor 120 Broadway, 26th Floor New York, NY 10271 New York, NY 10271 Additional Distribution via Listserv DISTRIBUTION:

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