ML13149A322

Transcript of February 27, 2013 Public Meeting to Discuss Nrc'S Request for Additional Information Regarding Southern California Edison'S Response to the Confirmatory Action Letter for SONGS, Unit 2

ML13149A322
Person / Time
Site:	San Onofre
Issue date:	02/27/2013
From:	Office of Nuclear Reactor Regulation
To:	Southern California Edison Co
Hall J
References
Download: ML13149A322 (62)

Text

UNITED STATES OF AMERICA U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING TO DISCUSS NRC'S REQUESTS FOR ADDITIONAL INFORMATION REGARDING SOUTHERN CALIFORNIA EDISON'S RESPONSE TO THE CONFIRMATORY ACTION LETTER FOR THE SAN ONOFRE NUCLEAR GENERA TING STATION, UNIT 2 FEBRUARY 27, 2013 1:00 P.M.

TRANSCRIPT OF PROCEEDINGS Public Meeting

2 APPEARANCES Southern California Ed ison Participants:

Thomas Palmisano

Richard St. Onge

John Brabec

Michael Short

NRC Staff:

Doug Broaddus

NRR

Randy Hall

NRR

Emmett Murphy

NRR

Ben Parks NRR Dan Dorman

NRR

Rick Daniel

3 P R O C E E D I N G S 1 RICK DANIEL: Well, good afternoon, ladies and gentleman.

2 Today is a SONGS Category 1 public meeti ng, and what that means is, this is a 3 meeting between technical folks from Southern California Edis on and the NRC.

4 There will be a period of time at the end of some of the initial discussion when 5 the public will be able to -- we'll take questions from the public, and we'll be able 6 to answer those questions. While we're talking about the public, do we have 7 members of the public and the media here? Could you please raise your hand?

8 Just one? Two. Where's the other one? Ju st one, right? Ok ay. Thank you for 9 coming. And thank you, ladies and gentlemen that are on phone for joining us 10 today; we very much appreciate you being there.

11 As I said, this is a Category 1 public meeting. My name is Rick 12 Daniel, and I'll be the facilitator today. The purpose of this meeting is to continue 13 where we left off on December 18th.

We had a meeting about request for 14 additional information, and this meeting is to allow additional clarification between 15 -- on the RAIs between the NRC and Southern California Edison. It will also give 16 the opportunity to Southern California Edison to bring the NRC up to speed on 17 the status of answering some of those RAIs.

18 Today's meeting there is going to be -- let me back up a second.

19 Regarding the RAIs, there's been about -- I guess around 60 so far, guys -- 67 to 20 be exact, and some of those RAIs just came out over the mont h of February. I 21 think five went out on February 1st, 15 w ent out on the 20th, and another 15 went 22 out on the 21st. So, some of these RAIs we may not be able to get real in depth 23 with because either Souther n California Edison has just received them or the 24 NRC is just getting responses from them. Now, I'm going to let Doug Broaddus, 25 4 the project manager, the SONGS project manager her e at headquarters talk 1 more about the agenda and the specific RAIs.

But this meeting today is going to 2 be broken up into two parts.

The initial part that we're going to be getting into 3 first has to do with nonproprietary informa tion. In the event that as we have 4 these discussions that pr oprietary information does come up, my assistant, 5 Lynne Finch up there, who is a very capable l ady, is going to make a note of it in 6 the parking lot up there on the flip c hart, and we will get back into those 7 discussions after the break. So, folks on the phone, you're going to be with us up 8 to and including the break. We think this first part of the meeting is going to take 9 about 45 minutes and then we're going to get into about 15 to 20 minutes of 10 questions and comments from you folks on the phone.

11 Additional meetings -- a lot of people want to know or ask about 12 additional meetings. At this point in ti me there is not a m eeting planned, this type 13 of meeting, a technical meeting pl anned and nothing scheduled at this point.

14 That doesn't mean that there won't be one scheduled in the future depending 15 upon how this discussion goes today and additional information flows back and 16 forth. However, there will be a larger public meeting out in California in the 17 April/May time frame, and that will have more to do with the results of the 18 technical inspection and the technical evaluat ion. So, more on that much later in 19 time. There is no date picked out yet, April/May timeframe.

20 So, without further blabbing on my part, I'm going to introduce Dan 21 Dorman. Dan is the Deputy Director of Engineering and Cor porate Support. Go 22 ahead, Dan.

23 DAN DORMAN: Thank you, Rick.

As Rick said, I am Dan Dorman.

24 I'm the deputy director for Engineering and Corporate Support in the Office of 25 5 Nuclear Reactor Regulation, and I also serve with Art Howell, who is off to my 1 left, as co-chairs of the SONGS oversight panel focused on the steam generator 2 issues. The meeting that we're here for today is a step in the substantial 3 process. We have, as Rick indicated, the staff has been deep into the response 4 that Southern Cal Edison provided to the CAL, the response that was provided in 5 October. The staff issued 32 requests for additional information in December of 6 this year and have now received responses to all of those 32 questions, and we 7 appreciate the effort that the licensee has put into being responsive to those 8 inquiries. As Rick indicated, we've i ssued an additional 35 questions here during 9 the last few weeks, and the purpose of this meeting primarily is to make sure that 10 we have clarity between the staff and Southern California Edison on what 11 information the staff is seeking so that we can have the best, clearest responses 12 that we can from the licensee.

13 In addition, we understand the licensee is prepared to speak to 14 several of the responses that we received, in particular, to make sure that the 15 staff clearly understands the responses t hat we have received, and we may have 16 some additional RAI responses that the staff may ask questions about to make 17 sure that we clearly understand the answers that we have rece ived. So, I just 18 want to acknowledge and appreciate the e ffort of both our staff and the SCE staff 19 and support to continue to move this process forward.

20 We are in the middle of a process.

We're not close to the end of it.

21 We need the responses to those 35 questions from the licensee, and the staff will 22 continue its review. This is running in parallel with the staff's efforts to do the 23 CAL closure inspections, the CAL follow-up inspections, and those two efforts will 24 continue in parallel to support an ultima te determination by the NRC. So our 25 6 focus today again is these RAIs, and we appr eciate not only the efforts that have 1 gone into this but also the large team t hat the licensee has brought to help make 2 sure that we have the clarit y that we need here today.

3 Art, anything to add? To m, any opening remarks?

4 THOMAS PALMISANO: I would like to add just on behalf of 5 Southern California Edison, first all, we appr eciate today's meeting. This is an 6 important part of t he regulatory process. Our staff has done a lot of hard work to 7 answer the first 32 questions. Your staff is doing a lot of hard work to review 8 these and pose additional questions, and we look forward to today's discussion.

9 As we get into slides you'll s ee our commitment, just to reiterate it, 10 you know, we are committed to operati ng San Onofre safely and reliably and 11 protecting the health and safety of the public, and additionally we have 12 committed to not restarting Unit 2 and Unit 3 until both we and you are satisfied it 13 is safe, and we see today as an important part of that proc ess and continuing 14 step in the process. So, thank you.

15 DAN DORMAN: Thanks, Tom. And I guess I'll turn it to Doug to go 16 over the agenda and get us started.

17 RICK DANIEL: Doug, before we get into the agenda, how about 18 we go around the table. You gentleman would like to introduce yourselves.

19 Mike, from Edison, why don't you start?

20 MIKE SHORT: Michael Short, supporting Southern California 21 Edison's Steam Generator Return to Service team.

22 THOMAS PALMISANO: I'm Tom Pa lmisano, vice president of 23 Engineering Projects and Site Support for San O nofre Nuclear Station.

24 JOHN BRABEC: I'm John Brabec. I'm a manager of the Steam 25 7 Generator Recovery Pr oject at San Onofre.

1 VICK NAZARETH: I'm Vick Nazare th. I'm the manager of Nuclear 2 Fuel at Southern California Edison SONGS.

3 RICH ST. ONGE: My name is Richar d St. Onge. I'm the director of 4 Nuclear Regulatory Affairs for Southern California Edison.

5 RICK DANIEL: Okay. Now the NRC folks. Emmett, go ahead.

6 EMMETT MURPHY: Emmett Mu rphy, senior materials engineer 7 with Division of E ngineering, NRC.

8 ART HOWELL: Art Howell, manager of the SONGS Special 9 Project Region 4.

10 DAN DORMAN: Dan Dorman, deputy director, NRR.

11 DOUG BROADDUS:

Doug Broaddus. I'm the branch chief in the 12 SONGS Special Projects Branch in the NRR.

13 RANDY HALL: Randy Hall. I'm the senior project Manager in the 14 SONGS Special Project Branch.

15 DOUG BROADDUS: I'd also lik e to recognize that we do have 16 some additional NRC staff that are over her e and that have also been part of the 17 review. They'll be coming up to the tabl e as needed as we get through the -- to 18 the presentations.

19 DOUG BROADDUS: All right. So , now if we can go to the slide, 20 the overview the NRC RAIs. All right. And Dan and Rick have already covered 21 quite a bit of this, but I'll go through a little bit more detail about where we are 22 with the RAIs, what we've issued up to this date.

23 As both Dan and Rick mentioned, we did issue approximately 32 24 RAIs back in December. Some of thos e were -- the first 31 of those were 25 8 discussed during the December 18th meeting, and I'm not going to go over the 1 purpose of those RAIs because we've alr eady had a previous discussion on that, 2 but as we get through the discussions there, some of those RAIs and the 3 responses that you had will come up as well, and we'll talk through what the 4 purpose of those RAIs were at that time.

5 As Rick mentioned, on February 1 st , we also issued an additional 6 five RAIs. These RAIs were more specif ic on the -- an additional report. There 7 were some reports that were submitted to us that were propr ietary reports that 8 were submitted after the Oct ober 3rd submittal. They were requested by us to be 9 submitted and they really -- these RAIs go over the basis for the assumptions, 10 and the assumptions in the AREVA tube-to-tube operational assessment. Then 11 on the 20th of this month, we also issued an additional 15 RAIs. Some of those 12 RAIs were proprietary, again, going back to the proprietary OA assessments, and 13 they were more applicable to the tube-to-tube wear -- the OA s and tube-to-tube 14 wear. They also refer to the MHI tec hnical evaluation report, and they were more 15 specific on the codes, how the codes were used, the assumptions used in the 16 codes, the basis for those codes for t hose assumptions. The third set was 17 issued on the 21st, just a couple of da ys ago, and those, again, were on the 18 operational assessments for the tube-to-tube wear. These were more focused 19 on, again, some of the assumptions but not necessarily with the assumptions in 20 the codes and how the codes were used; th ey were more on the assumptions of 21 how the different aspects of the operational assessments and how they kind of fit 22 within the guidance and your Steam Gener ator Tube Integrity Program. So, 23 that's kind of where those are.

24 Of the 35 additional RAIs, approximat ely eight of those, I believe --

25 9 11 of those were proprietary and the rest were nonproprietary. So, those 11 are 1 the ones specifically that won't be discu ssed during the open sessi on. I just want 2 to, for everybody else's information, both in the webcast and in here, some of 3 those that were nonproprietary also addressed and were specifically referenced 4 on proprietary information that was in your submittal, but the RAI itself was not 5 proprietary. So, we recognize that t here may be a need in those cases also to 6 not have those included in the open session.

7 Of course, as Dan mentioned, the whole purpose for these RAIs is 8 for us to obtain additional information so that we can complete our review and 9 have a complete and technically sound -- we can make a complete and 10 technically sound decision that's legally defensible on whether or not there's 11 reasonable assurance that the plant is safe to operate as we specified in the CAL 12 itself. 13 All right. At this point, what we were planning to do was to have an 14 opportunity both for you to go through the RAI responses you provided at this 15 point and for us to address specific questions on those first set of RAIs, the first 16 32 RAI responses. Emmett Murphy, I believe, may have some specific 17 questions. What we'll do is we'll let you ki nd of go through your presentation first 18 rather than having us go first, then any additional questions we might have as a 19 result of that. We'll have Emmett bring those up or any of the other technical 20 staff. 21 So, Tom, I'll turn it over to you.

22 THOMAS PALMISANO: Can we br ing up the Southern California 23 Edison slides, please? Okay.

So, let me turn it over to John Brabec to introduce 24 the meeting, then I'll have a couple of quick additional comments.

25 10 JOHN BRABEC: All right, thank y ou, Tom. Good afternoon. We're 1 very pleased to have this opportunity to continue our dialogue with the NRC staff 2 regarding your request for additional info rmation related to the information we 3 provided in our confirmatory action letter response on October 3rd of last year.

4 Additionally, we're pleased to have the opportunity to present our planned 5 response methodologies for RAIs 33 through 67 to ensure we understand those 6 questions and provide timely and accurate responses to them. As you can see, 7 we've brought with us today most of the technical experts responsible for 8 development of the operati onal assessments that are par t of our confirmatory 9 action letter response. So, we're prepar ed to have detailed technical discussions 10 as necessary to support answering your questi ons. With that, I'll turn it over to 11 Tom, if you have any additional comments.

12 THOMAS PALMISANO: Just again to reiterate what I said earlier, 13 fundamentally, thank you for this opportunity to come in and continue this 14 technical discussion. I think there's a lot of ground we'll cover today in explaining 15 and clarifying any of our responses and cl arifying your questions, and with that, 16 again, I'd like to now focus on the techni cal aspects of the meeting. So, John.

17 JOHN BRABEC: All right. Thank you, Tom.

18 All right. The purpose -- if you we could go to the purpose slide --

19 the previous slide -- the purpose of today's meeting is to first provide an overview 20 of Southern California Edison's responses in the Confirmatory Action Letter; that 21 would be very brief. Then we'll discuss SC's responses to RAIs one through 32.

22 Specifically RAIs two, th ree, and four were submitted on Friday on last week and 23 then 32 was submitted Monday of this week so, we'll have some discussion of 24 those four RAIs. And then to review S C's plans for responding to the draft RAIs 25 11 33 through 67.

1 All right. We'll start out with our response to the confirmatory action 2 letter. Next slide, please. First, in discussing the power reduction to 70 percent 3 and how that provides safety margin for the restart of Unit 2. What this 4 accomplishes for us is a significant reducti on in fluid velocities in the tube bundle, 5 and this creates a condition where ther e's less energy being imparted to the 6 tubes, causing vibration. Also, significantly reduces void fraction. There is much 7 more moisture in the steam water flui d mixture in the tube bundle, and that 8 provides much better damping at 70 perc ent when compared to 100 percent.

9 This also prevents fluid elastic instability, the mechanistic cause of the tube-to-10 tube wear identified in Unit 2 and Un it 3 steam generator

s. We've also 11 preventively plugged tubes in the steam generators, and those are the tubes that 12 are most susceptible to fluid elastic instability at 100 percent power, and this 13 eliminates the possibility of tube leak age. And then we've identified a short 14 operating interval, that five-month window we've discussed, is significantly 15 shorter than the analysis on our operati onal assessments demons trates the unit 16 is safe to operate. Following that short operating interval we will have a complete 17 inspection -- 100 percent tube inspection during the mid-cycle outage.

18 Now we'd like to move on to a discussion of our responses to those 19 initial RAIs 1 through 32 received in Dece mber of last year, and as I mentioned 20 this will be primarily focused on our RAIs 2, 3, 4, and 32. We've also received 21 some questions about RAIs 18 and 19 that deal with some instrumentation, and 22 we'll provide our clear position relative to those questions.

23 For RAI 32, which we submitted on Monday of this week, and it 24 deals with compliance with technical specification 5.5.2.11, and in that RAI the 25 12 NRC asks several questions, and you see on th is slide that SCE provides clarity 1 how structural integrity and technical spec 5.5.2.11.B.1 is met for operation up to 2 the rated thermal power, RTP; or to provide an operational assessment, an OA, 3 for tube to tube wear at 100 percent rated thermal power. In our RAI response 4 you'll see, or may have seen t hat we have done both of the above.

5 As a compliance with the tech spec 5.5.2.11, we point out in our 6 RAI response that tech spec 5.5.2.11 uses the term "normal full power," quote 7 unquote, not "rated thermal power," and there's an impor tant difference between 8 those two terms. The formal commitment and the confirmatory action letter 9 response to limit power redefines our licensing basis of normal full power to 70 10 percent. Our operational assessments demonstrate the steam generator tube 11 performance criteria are met at 70 perc ent. Therefore, in our October 3 rd 12 submittal we demonstrate that tech spec 5.5.2.11 is satisfied.

13 As requested in the RAI 32, an operational assessment at 100 14 percent rated thermal power will be provided to the NRC.

This is an OA that is 15 being performed using accepted industry guidel ines. This is the Intertek OA.

16 The AREVA and Westinghouse tube-to-tube wear operational assessments 17 continue to provide the basis for operat ion at 70 percent power, and these OAs 18 demonstrate the substantial margin to the onset of fluid elastic instability exists at 19 70 percent power.

20 Now I'd like to discuss some of th e actions that we identify in our 21 RAI 32 response, and these are actions that will be taken subsequent to the next 22 operating interval. As you see, power, as we discussed, will be limited to 70 23 percent unless approval from the NRC is obtained to raise power. The initial 24 operating period will be 150 days, follow ed by our mid-cycle steam generator 25 13 inspection. SCE will then perform steam generator tube inspections in 1 accordance with the tech spec 5.5.2.11 and section 8.3 of the return to service 2 report. Any additional indications of tube-to-tube wear due to fluid elastic 3 instability will be addressed with the NRC staff prior to restart. The operational 4 assessments will determine subsequent operating intervals and power levels, 5 and that's for our steam generator program defined in our technical 6 specifications. And we'll continue to use this approach until long-term 7 operational limits including power level are determined.

8 All right. That's RAI 32. In respons e, at this point in time I'd like to 9 turn it over to Mike Short, and he's going to cover RAIs 2, 3, 4, and any other 10 additional questions perhaps Mr. Murphy mi ght want to bring up about our initial 11 RAI responses in 1 through 32. Mike?

12 MIKE SHORT: Thank you, John. Slide 13 is a summary of RAI 13 number 2 and the response that we provided. It's very similar to the slide that we 14 provided back in December. So, we're just interested at this point if the staff has 15 any questions about our RAI response.

16 EMMETT MURPHY: Yes, and in parti cular, on this particular -- on 17 this RAI. The response to the RAI, I believe, as a general response, is a bit too 18 sketchy. I have lots of questions after having read the response, and I can, you 19 know -- if you want to spend more time on it , I can. I'll have to turn to my notes 20 here. 21 THOMAS PALMISANO: Is this appropriate that we need to 22 schedule the specific call to talk about this in detail?

23 EMMETT MURPHY: My plans are to write up my questions. I 24 don't know whether we'd want to hold off on such a discussion until I write up 25 14 those questions. I just read the material for the first time yesterday, but it's clear 1 that much additional information wil l be needed to support the response.

2 THOMAS PALMISANO: And we recognize these responses, I 3 think, John, you said were submitted on Friday. So, we realize you're just really 4 reviewing them for the first time, and we are more than willin g, whether it's 5 additional phone calls or meetings, to gi ve you a chance to get your questions 6 down in writing, because we want to do a good job in answering your questions.

7 So, really, if it works better for you to put your questions in writing and we can 8 schedule the appropriate mechanism to di scuss them more thoroughly, we'll be 9 glad to do that. So, basically, whatever works best for you.

10 DAN DORMAN: I think that's probably a good idea just to make 11 sure that we get clarity. You know, we can talk to things off the cuff here about 12 things that we've seen for two or three da ys, but I think to let you know now that 13 we do have further questions on the firs t read through the re sponse and then get 14 back later with a better formulated question.

15 EMMETT MURPHY: Yes, I mean the RAI question, you know, it's 16 formally there, is very fundamental to t he overall usefulness of the analysis and, 17 of course, it's going to play an important role in your upcoming response to RAI 18 32, so I understand and you und erstand we'll have to devot e, you know, direct 19 our focus to this particular item in particular.

20 MIKE SHORT: All right. Thank you then. The next sl ide is RAI 3.

21 It pertains to the Intertek OA definition of the wear index.

22 EMMETT MURPHY: Yes, and this likely will have questions on this 23 response as well. This is closely related to RAI 2. Again, we just looked at this 24 information and need to formulate specific questions.

25 15 MIKE SHORT: All right. Thank you. So, it sounds best to treat this 1 in the same fashion that we plan to treat RAI number 2.

2 Next slide, please, is RAI 4. It also pertains to the Intertek 3 Operational Assessment, and, ag ain, on the definition of the wear index used in 4 this assessment.

5 EMMETT MURPHY: I haven't identified any key concerns coming 6 out of your response to this question.

7 MIKE SHORT: All right. Thank y ou. And of course, if questions 8 arise we'll include those in the handling of 2 and 3. All right. All right, thank you, 9 then. Next slide, please.

10 We have received two questions that pertain to RAI 18, which 11 speaks to a system known as the Vibration and Loose Parts Monitoring System; 12 and those same two questions also refer to RAI 19, which speaks to a system 13 known as the Smart Signal System. We've repeated the two questions on this 14 slide and the next slide, and briefly what t he questions go to is in our response to 15 RAI 18 the question indicates that Edison implied they believe this system, the 16 VLPMS system, will be capable of detecting events indicative of tube to tube 17 contact, and the follow-up question requests the basis for this belief. The follow-18 up question also requests the discussion of Smart Signals capability to detect 19 noise events indicative of tube-to-tube or tube to AVB content [spelled 20 phonetically].

21 Next slide, please. The second question requests additional 22 information on SCE's long-term plans for ensuring safe operation and how the 23 Vibration and Loose Parts Monitoring System fits into those plans. The question 24 goes on to request information on how t he data from the VLPMS system will be 25 16 correlated to tube wear mechanisms and how SCE will communicate that 1 information to the NRC.

2 Next slide, please. On this slide we've started to work on our 3 response to these two questions, and right now the response will include the 4 points on this slide. The first point speaks to the long-term plan question for 5 ensuring safe operation of Unit 2, and we have provided information on this 6 subject in our response to RAI 32. The operational assessments that support 7 operation at the return to service power level of 70 percent, as we've spoken of 8 earlier in this meeting, demons trate that fluid elastic instability will not occur.

9 Thus, the real time monitoring of t ube-to-tube contact has not been part of our 10 return to service plan; and we will clarify that in our response.

11 The second point we wish to make is that we did not intend to 12 assert or intend to imply that the upgraded VLPMS system would be able to 13 detect tube-to-tube wear. Our plan is to record data on the system during plant 14 operation and to analyze that data duri ng the next mid-cycle inspection. So 15 that's historically based approach that we ou tlined in our return to service report.

16 That analysis will include a comparison wit h the results of the steam generator 17 inspection itself and, of course, as we indicated in our response to RAI 19, the 18 Smart Signal technology and the capabilities t hat it provides will be used in that 19 analysis.

20 The last point we wanted to make was a review of what was 21 contained in our response of RAI 18, and it's summarized in the third bullet on 22 this slide. The upgraded system, again, will be used as a backward looking 23 analysis tool in subsequent inspection outages, such as the upcoming mid-cycle 24 outage, should unexpected wear be discove red during that inspection. The 25 17 upgraded system will enable Edison to eval uate steam generator site acoustic 1 signal data for events, which may help; and it's important to focus on the "may 2 help" with the understanding of the causes of unexpected tube wear. And then, 3 lastly, we wanted to reiterate that the system in itself is not designed to detect 4 tube to tube contact.

5 That's our intent right now in terms of responding to the two 6 questions that we've received.

7 DAVID RAHN: Okay. Thank you. This is David Rahn. I'm a 8 technical reviewer in the instrumentation and controls branch in the NRR, and the 9 purpose of the first question had to do with determining the appropriate level of 10 confidence you had in the c hanges that are being propos ed for the Vibration and 11 Loose Parts Monitoring System to be able to be used as an investigative tool 12 after the fact, and it didn't appear to me that there was a high confidence, but it 13 didn't say there was no confidence. I m ean, basically it appears that it looks like 14 it's a valid approach to try to improve t he sensitivity of the Loose Parts Monitoring 15 System. So, it looks like what I hear you saying is that provided that the 16 sensitivity is there you could possibly use that system to go back and look at 17 plant operating conditions that occurred at the time acoustic noise was present 18 and then provide some kind of correlation as to the onset of either tube-to-tube 19 wear or tube to anti-vibration wear or any kind of thing that could potentially 20 cause a resultant metallic noise. I think that's what I hear you're saying.

21 THOMAS PALMISANO: Yes, that's consistent.

22 DAVID RAHN: Okay. The other thing is we have been doing a 23 little bit of research on the capabilities of what GE Smart Signal product is 24 capable of doing, and it's kind of like an exception reporting type software that 25 18 looks at, like, deviations from normal. So, what happens if the background -- if a 1 particular signal level starts to exceed background then you might be able to 2 record that event and compare it to what other things are going on in the plant at 3 that time. And so, what we were hoping to do is see what was your intent in 4 using that, you know, that possibility to go back and either support or modify 5 conclusions that are being reached in the operational assessment when it does 6 get performed. We just look and see how are you going to use that information.

7 MIKE SHORT: Yes, the Smart Signal system functions as you 8 have stated. It will be monitoring prim arily process parameters; inputs and 9 outputs from the steam generator. And we believe it will help us understand the 10 behavior of the machine over the operating period of time. So, we intend to use 11 it in that fashion.

12 DAVID RAHN: Okay. And all of th is is all supportive analysis tool; 13 it's not something that's there to help detect leakage. You actually already have 14 a fairly extensive program of primary to secondary tube leak detection system, 15 and that's not changing with the startup of the plant, right?

16 MIKE SHORT: No. Go ahead, John.

17 JOHN BRABEC: Yeah, that's correct. You've correctly 18 characterized our intended use of both of those, what we characterize as 19 additional actions in the return-to-service plan. So, both tools, we anticipate, will 20 make it possible for us should we get unexpected wear in our subsequent 21 inspection window to be able to take t hose two tools, both the VLPMS data, the 22 Smart Signal process data -- and those process signals are things like steam 23 flow, feed flow, steam pre ssure -- and to go back in the cycle and look at perhaps 24 were the perturbations [spelled phonetically] that we could correlate to ongoing 25 19 tube to tube contact or other unexpected tube wear.

1 DAVID RAHN: So, that brings up my final questions which is on, if 2 you do start to sense that there is a leakage over and above that tech spec 3 amount of allowed leakage, are you going to then at that point start going back 4 and analyzing data, or are you going to wait until t he end of the operational 5 cycle? 6 JOHN BRABEC: It's our intent, ac tually, to periodically throughout 7 the cycle take the data and perform some an alysis. So, for example, perhaps on 8 a monthly basis we could take the data, do some analysis. Certainly, and as we 9 stated in our return-to-service plan, w hen we have any confirmed indication of 10 primary or secondary leakage, much less than tech spec allowed, we will be 11 removing the unit from service.

12 DAVID RAHN: Okay. So, you'll be gaining experience in using the 13 analysis tool during the cycle, and that's --

it would help if your response said 14 that. 15 JOHN BRABEC: That is correct, and we'll enhance our response 16 to demonstrate that.

17 DAVID RAHN: Okay. Thank you. That's all I have.

18 DOUG BROADDUS: Before we go on, we should have clarified 19 this ahead of time as to whether we were going to take questions as you're going 20 through it or not, but I th ink there were some questions on RAI 32, and we may 21 have some additional questions on other RAIs as well. So, actually, I'll start from 22 the standpoint of RAI 32. The first questi on, I think, relates to the discussion on 23 RAIs 2, 3, and 4 as well, but the response to RAI 32, you indicate that you're 24 going to do a supplement to the Intertek OA. So, is that going to be using the 25 20 same approach that was used with the supplem ental one? Is it going to be the 1 same approach as used with the existi ng OA -- Intertek OA, and will the 2 questions that Emmett had provided on RAIs 2, 3, and 4 -- will the responses to 3 those also be applicable to that Intertek, supplemental Intertek OA?

4 JOHN BRABEC: I understand the ques tion. Generally, and we do 5 have our operational assessment writer here who can enhance if I don't get this 6 exactly correct. Generally, the methodology is the same as the original Intertek 7 OA, but we have woven in, if you will, t he answers -- the required answers to the 8 RAIs that are relative to the Intertek OA. So, the final 100 percent Intertek OA 9 will have addressed the questions t hat have been asked to date about 10 methodologies for that OA. Would you say that's accurate?

11 DOUG BROADDUS: Emmett, did you have any questions from 12 that perspective? Anything furt her that you needed to clarify?

13 EMMETT MURPHY: No.

14 DOUG BROADDUS: All right.

Second question on the Intertek 15 OA, the commitment for that. You indicated in your response that the OA will 16 demonstrate that that structural integrity performance criteria in the accident-17 induced leakage performance criteria are satisfied for 100 percent rated thermal 18 power. So, I guess what my question is, is that complete already? Do you 19 already have those results?

Is that what you're basi ng that on? What's the basis 20 of that statement?

21 JOHN BRABEC: Well, the operational assessment for 100 percent 22 power is not quite complete; it's ve ry near completion. So we do have 23 preliminary results that dem onstrate that that will give us satisfactory results.

24 DOUG BROADDUS: All right. So, those will be provided to us?

25 21 And you indicated about mid-March?

1 JOHN BRABEC: That's correct.

We've committed to having that to 2 the NRC by March 15th.

3 DOUG BROADDUS: All right.

One other question -- I have a 4 couple of other questions. You indicated in one of your slides that the basis 5 between -- let me go back there and make sure I use the right words -- the 6 terminology that was used in the question and in the tech specs of the full range 7 of normal operating conditions and norma l steady state full power, and that is 8 they have a specific distinct basis from the terminology used, rated thermal 9 power. What is your basis for -- wher e do you believe the basis that they are 10 distinctly different is?

11 JOHN BRABEC: It's essentially t hat the definition of rated thermal 12 power is a maximum number of megawatts we can operate the plant at is a little 13 bit different than what the basis document s that were used or support the actual 14 tech spec change that occurred back in about 2005. There were industry 15 documents, task force number 449 specifically, that do talk to the basis of what 16 the primary parameters of c oncern are when talking about maintaining structural 17 integrity of the tubes during the operating cycle. Ther e are things like differential 18 pressure across [inaudible] to the secondar y side is this differential [inaudible]

19 and primarily for across the tube.

20 DOUG BROADDUS: And you mentioned industry basis 21 documents. Is that something that you could provide?

I mean, I don't know if we 22 will -- our technical staff might have all those industry basis documents, but if 23 there are specific citations to that --

24 EMMETT MURPHY: We have all of them.

25 22 JOHN BRABEC: Certainly, if t here's anything additional that we 1 can provide we will do so.

2 DOUG BROADDUS: Okay. All ri ght. The next question I had --

3 you talk about the future plans after the initial 150-day cycle. I guess my 4 question on that is some of the -- the confirmatory action letter we have right now 5 that's out is based upon t he commitments that you ma de previously. One of 6 those is that you wouldn't start up until you've gotten an approval from us. This 7 also appears to talk about approval beyond that initial 150-day time period. So, I 8 guess -- and also not operating above 70 percent until there's some type of 9 approval as well. Is that an additional commitment beyond the commitment -- it 10 wasn't identified in here as a specif ic commitment, so is that an additional 11 commitment that you're planning to make or...

12 THOMAS PALMISANO: Understand t he question. We've laid out 13 what our current plans ar e, and wanted to propose those to you so that you 14 understand what our current pl ans are. We also recognize that as you complete 15 the CAL inspection activity and the techni cal evaluation report we'll come to the 16 point where you ultimately decide what additional commitments we may need to 17 make. So, if we're proposing the one commi tment here is to supply the Intertek 18 OA, as we resolve RAI 32 with you we are fully prepared to discuss additional 19 commitments that you feel we need to make.

20 DOUG BROADDUS: I guess maybe re word it slightly differently.

21 Are you prepared to make a commitment such as this? Is that what you're 22 indicating to us? I just want to make sure what your --

23 THOMAS PALMISANO: We're pr epared to make commitments 24 along this line once we reach agreement on what would be appropriate that, you 25 23 know, we feel is, you know, this is what we feel is appropriate now. You need 1 time to review this and discuss it with us, and then we'll be prepared to make the 2 appropriate commitments.

3 DOUG BROADDUS: Okay. A ll right. Understood. One last 4 question. As I mentioned before, you indicated that the Intertek OA will indicate 5 that the structural integr ity performance criteria is met 100 percent rated thermal 6 power, but at the end of your RAI response you indicate that SCE will inform the 7 NRC when the determination is made of whether Unit 2 can be returned to 100 8 percent power operation or long-term operation at reduced power as needed. I 9 guess I'm just wondering in that case, it seems that you're saying you have a 10 demonstration that it can be operated at 100 percent, but this seems to indicate 11 that you don't -- that there' s some uncertainty as to whether or not it can be 12 operated at 100 percent. So, if you can clarify what that...

13 THOMAS PALMISANO: Let me clarify the intent of that. We feel it 14 is appropriate to operate San Onofre at 70 percent power to preclude fluid elastic 15 instability from occurring. Okay? As we've all discussed in previous meetings, 16 this is first time phenomena in operat ing U-tube steam generat ors. We need to 17 be appropriately conservative as we approa ch restart of Unit 2, and certainly 18 that's your interest as well. So, we feel operating at 70 percent power is 19 appropriate. There is sufficient or substantial margin to the onset of fluid elastic 20 instability. We're proposing a protocol of five months operating inspection 21 followed by resuming operation, and during those periods of time we will gather 22 more tube performance data allowing us to determine length of operating and 23 possibly higher power levels, subject to your approval, as we've laid out, and 24 ultimately we'll be able to judge whether the plant can return in its current 25 24 condition 100 percent power or some different permanent power level as needed.

1 So, our intent is to go follow the process we've laid out in that part of the 2 response, keeping you adequately informed committing to limited to 70 percent 3 power unless we have justification to raise power level and review that with you.

4 So, that's what our plan is.

5 DOUG BROADDUS: So, just to ma ke sure I understand it. Is this 6 statement saying in any way that you're unc ertain as to whether the plant can be 7 operated at 100 percent power based upon the Intertek OA that you're planning 8 to submit to us?

9 THOMAS PALMISANO: The Intertek OA, again, as John just said, 10 is largely complete but not final. We ar e confident it will de monstrate that steam 11 generator tube integrity is maintained for the initial operat ing period at 100 12 percent power. When we subm it that we will be confident of that. We think it's 13 appropriately conservative to operate at a reduced power level and continue to 14 gather data on the performance of the steam generators.

15 DOUG BROADDUS: Okay. A ll right. Did anyone have any other 16 questions on RAI 32 from the staff?

17 ART HOWELL: No questions, just an observation. As Mr. Dorman 18 indicated, we just received your response

-- and we haven't got all of it yet, we 19 have to wait for the revised Intertek OA

-- but I would note t hat your position on 20 tech spec interpretation is different from the staff's position that was 21 communicated to you on January 29; so we'll have to address that as we go 22 through our review.

23 THOMAS PALMISANO: We underst and that. We appreciate that 24 difference, and we've given you our analysi s of tech spec compliance. We 25 25 understand it's subject to review and we may have some differences, which is 1 why will also deliver the Intertek OA s howing compliance at 100 percent rate of 2 thermal power.

3 DOUG BROADDUS: If there ar e no other questions on RAI 32 --

4 Emmett, did you have any other questions on any of the other responses that 5 you -- to the initial set of RAIs? If you can indicate which RAI and the topic of it 6 that would be helpful.

7 EMMETT MURPHY: Maybe just one clarification. Just one other 8 question. Has to do with RAI 26. In parti cular, I was interest ed in how AVB flaws 9 would be projected to grow during future operation. And as I understand your 10 response, in the context of the AREVA OA for tube-to-tube wear, each individual 11 wear flaw is still in service -- on a tube that

's still in service at BOC 17, that that 12 wear flaw will -- for that t ube at that intersection will be assumed to continue to 13 grow at a rate consistent with what it grew at during the preceding period of 14 operation. Is that a correct interpretation of the response?

15 MIKE SHORT: I'm going to look at Dr. Begley [spelled phonetically]

16 just to be sure, but I believe I know the answer.

17 MALE SPEAKER: Yes.

18 MIKE SHORT: The answer is yes, it does grow at the continued 19 rate -- 20 EMMETT MURPHY: As opposed to , like, for other OAs in your 21 package collecting a set of growth rate distributions and randomly sampling 22 those in a probabilistic assessment, this was done differently.

23 MIKE SHORT: That's correct. Each OA approached the issue in a 24 different fashion.

25 26 EMMETT MURPHY: Okay. Thank you.

1 DOUG BROADDUS: Any other questions? Any other questions 2 from the staff that any reviewers that can be discussed during the nonproprietary 3 portion of it? If not, I don't believe so.

4 I'm going to turn it back to you, Tom. You're looking for 5 clarification, and you're going to talk about your plan for how you're going to 6 respond to the more recent RAIs.

7 THOMAS PALMISANO: Yes, I'll kick it over to John in a minute, 8 but first of all, thank you for the questi ons on RAIs 1 through 32. We appreciate 9 the time you've put in. We recognize on several of them you have just recently 10 received them, and as we stated earlier, we will be able to support you in any 11 mechanism you need to clarify our responses further. So thank you for that. So, 12 John, let's move on to the next group.

13 JOHN BRABEC: All right. In our discussions for our proposed 14 methodology of approaching RAIs, the rec ently received RAIs 33 through 67 I'm 15 going to turn it over to Mike Short to lead that discussion.

16 MIKE SHORT: We'll begin on Slide 20, which is the next slide, 17 thank you. This is RAI 35. It speaks to AREVA's operational assessment, 18 something called the upper bound for contac t force and clarifications on that 19 information. For each of the slides , much like we performed back in the 20 December meeting, we've repeated the RAI and then outlined our planned 21 response. We offered to --

this to the staff and solicit any questions they might 22 have on this planned response.

23 DOUG BROADDUS: Folks on the phone, we just got these slides 24 this morning, so Emmett hasn't had a c hance to look at these yet; so he's 25 27 reading through it.

1 MIKE SHORT: Yeah, Emmett, this is an outline of our proposed 2 response; it's not the entire response.

3 EMMETT MURPHY: Yeah, part of the RAI has to do with the 4 hydrodynamic force bei ng applied to the tube.

5 RICK DANIEL: Emmett, excuse me a second. Now, let's hang on 6 a minute here. Now, licensee, I think you need to go through what the RAI is, 7 give an oral summary of what you're sayi ng here, and then we'll go from there.

8 And I think this puts the NRC kind of on the spot asking them to respond to 9 something that they've only had very limited time to look at. So, really appreciate 10 you taking the time to go through it, maybe summarizing it, and we'll go from 11 there. 12 DOUG BROADDUS: In particula r, if you have -- if there are 13 specific questions that you have, if y ou need a clarification on the RAI or if you 14 could also indicate whether or not you believe you clearly understand what the 15 question is.

16 THOMAS PALMISANO: Okay. We'll be glad to do that. We've got 17 a number of pages here, so what we'll do is we'll st ep through, again, many of 18 these RAIs came out fairly recently, so we are just going through them ourselves.

19 So, we'll explain our understanding of the RAI. We are showing you our 20 response plans; not our detailed response.

So, please understand, we are not 21 going to answer every aspect of the RAI in this meeting. We're talking about how 22 we plan to respond. So, we'll be glad to walk through this. We'll ask clarifying 23 questions on our end. And, again, we ar e not expecting you to say this is an 24 appropriate response. You will need time to see our written response once we 25 28 submit. We're just really looking to clarify it at this point. So, with that, we'll start 1 again. So, Mike, let's summarize the RA I, our understanding, any clarification we 2 need, and then just very quickly summari ze what we will address in our 3 response.

4 RICK DANIEL: Before you start --

5 PAT HILAND: Let me go. I'm Pa t Hiland. I'm the director of the 6 Division of Engineering, and I'd like to si t here and join in on the discussion and 7 I'll hear your outline here. If I have some comments I'll provide them.

8 RICK DANIEL: Thank you, Pat.

9 MIKE SHORT: All right, again, RAI 35 speaks to upper bound 10 contact forces. Clarify what the averages values, how they were determined, 11 what's the upper bound limit, and why only turbulence excitation was considered.

12 Our response plan will explain how the av erages were computed, we'll talk about 13 the fact that small gaps in contact forc e -- excuse me, small gaps without contact 14 force have been show to provide effective s upport historically in the industry, and 15 then we'll speak to how the upper bound contact forces were developed and their 16 applicability.

17 PAT HILAND: That would appe ar to address the question of the 18 RAI. We'll look forward to -- the review will take place.

19 MIKE SHORT: Thank you. Next slide, please, RAI 55. Again, this 20 goes to the AREVA operational assessm ent, with some clar ifications on anti-21 vibration bar wear. Our response is c ontained on this slide and the following 22 slide, and it is a question about the total gap. Does it include wear of the anti-23 vibration bars and how is that wear determined? And it's a follow-up to a 24 previous RAI, number 26. In our response we'll explain that wear was included 25 29 at AVB intersections. We'll speak to the sizes of the wear-induced gaps. We do 1 use the worst case steam generators to complete this task.

2 On the next page -- next slide, we talk about how the wear level 3 was adjusted in the model and then lastly --

the last point we'll make is that the 4 wear lost volumes after restart are the same as those observed at 100 percent 5 power for the -- excuse me , prior cycle of operation.

6 PAT HILAND: Just a quick clar ifying question. You mentioned in 7 the response plan that the worst case in the steam generators are the wear --

8 that you'd taken a look at both Unit 2 and 3.

I'm not the expert in this field, but is 9 the wear -- is this an aver age wear of a number of tube s or is this a specific 10 individual tube in each of those steam generators?

11 MIKE SHORT: Let me ask Dr. Begley for assistance with that 12 question.

13 MALE SPEAKER: Hang on, we're going to grab you a microphone 14 in just a minute.

15 JIM BEGLEY: Jim Begley, consultant to AREVA, performing 16 engineering analysis.

17 JOHN BRABEC: Jim, bring the microphone up a little closer.

18 Thank you.

19 JIM BEGLEY: My name's Jim B egley, a consultant for AREVA.

20 AREVA is performing various engineering analyses on be half of SONGS. The 21 wear that we're talking about here is the wear that occurs in Unit 2, because 22 that's the unit that we've evaluated for return to serv ice at 70 percent power. We 23 used a conservative analysis that says the wear rates at 70 percent power will 24 continue to be the same as those observe d at 100 percent power, which is a very 25 30 conservative assumption as a number of people have pointed out other than 1 AREVA. So, we used those conservative wear rates. We've looked at the wear 2 indications. There's two different generat ors. One generator had their first --

3 actually relatively similar, right, but we have used the wear in the worst quadrant 4 of the generator as inspected, all right, and we've replicated that through all four 5 quadrants which is another element of c onservatism. And so, we're basically 6 saying the wear indications that are there are the worst case wear indications, 7 and they will all continue to grow at a very conservative rate.

8 PAT HILAND: Okay. I think you answered my question just off the 9 top here. It's a quadrant that you're evaluating; it's not an individual tube. So it's 10 the wear of the whole quadrant. You divi ded them into four and you have the two 11 steam generators, you took the worst case, and that's what you've assigned.

12 JOHN BRABEC: Right, but we consider every wear indication in 13 that quadrant. We replicate it four times so it's --

14 PAT HILAND: Understand. Thank you.

15 MIKE SHORT: Next slide, pl ease. RAIs 37 and 56, again, speak 16 to the AREVA operational assessment. It's a discussion of the benchmarking 17 and sensitivity of the probabili ty of fluid elastic instabi lity. We provided a very 18 brief response to this RAI in the public por tion of the meeting. We have a much 19 more substantial response that we'd lik e to include in the closed part of the 20 meeting because it contains proprietary information. My suggestion is that we 21 speak to that in that portion of the meeting.

22 If we can move on to slide 25, RAI 38. Thirty-eight goes to the 23 subject of loading conditions and the influence of hydrodynamic pressure.

24 Specifically, it requests how the AT HOS computer code, which models 25 31 thermohydraulic propert ies of the steam generat or, are converted to 1 hydrodynamic pressure since that conversi on is not a direct output of the ATHOS 2 code. So, our response plan will pr ovide the methods used to calculate 3 hydrodynamic pressure from the ATHOS output, and we will discuss the 4 influence of that pressure on the behav ior of the U-bend portion of the tube 5 bundle. 6 JOHN BRABEC: Mike, if we could just go back to RAIs 37 and 56, 7 Slide 24. Although the bulk of the discussi on on these two RAIs will occur, as 8 much of it is proprietary information, on Slide 24 I'd like to make a couple of 9 points, bullets on that slide that are very important in answering these two RAIs.

10 And essentially the bottom two bullets, that 100 percent power of the SONGS 11 steam generators are outsi de the envelope for past successful performance 12 relative to in-plane fluid elastic instabilit y, and more importantly the final bullet on 13 that page that at 70 percent power the SONGS steam generators are well inside 14 the operating envelope for past successful performance relative to in-plane FEI 15 [spelled phonetically]. So, I thought it was important that we discuss that now 16 before we move on to the proprietary session. Sorry for that --

17 MIKE SHORT: Thank you. I'd lik e to move on to RAI 39 if that's 18 okay. RAI 39 requests information about the definition of the te rm "beta," which 19 is the homogeneous void fraction. We will explain that definition and how it's 20 computed and the relationship between beta and the ATHOS-calculated nodal 21 fraction known as alpha.

22 Next slide, please. RAI 40. S ubject of this RAI is the liquid film 23 condition assumptions in MHI's work for tubes which had been removed from 24 service, also known as plugging. In MHI's work they do assu me that tubes that 25 32 are removed from service are in a wet stat e, and we will provi de the basis for that 1 assumption in our response. There's no heat flux associated with plugged tubes, 2 and that's the fundamental rationale for the assumption, and we will demonstrate 3 that the overall results are not sensitive to this assumption.

4 PAT HILAND: Just, if you could provide me some edification.

5 When you say the term, they're not wet, in a wet condition, is that -- you're talking 6 about the inside of the tubes, they're not wet?

7 MIKE SHORT: Pardon me. Thank y ou for that clarification. We're 8 speaking of the external condi tion of the tube, and it's very important in modeling 9 the tube behavior to understand in a two-phas e environment what that external 10 condition is, and it varies as a function of void fraction along the length of the 11 tube. In the case of plug tubes, our assu mption is the entire external surface of 12 the tube is in a wet state because there's no heat flux associated with that tube.

13 That's the foundation for the assumption.

14 PAT HILAND: Thanks.

15 MIKE SHORT: Next slide, plea se. RAI 42 is a question regarding 16 the preventative plugging pr ogram that we implemented on Unit 2. We went 17 through a process we call the screening process, and the question is a 18 clarification that any t ube that we screened as susceptible to fluid elastic 19 instability wasn't removed from service by plugging, and the answer is -- we'll 20 provide that answer, and the answer is yes, it was. And the question requests a 21 detailed list of all the confirmed plugged t ubes, and we will provide that as a part 22 of our response.

23 PAT HILAND: Yeah, I believe t hat's just -- is that the normal 24 reporting criteria after a st eam generator inspection that -- I've seen my staff 25 33 review is a list of all the tubes inspect ed and which tubes, you know, the number 1 of tubes anyway, that were plugged or corrective actions were taken.

2 MIKE SHORT: That's correct.

It is part of our 180-day --

3 PAT HILAND: I know it's large.

4 MIKE SHORT: Yes, it is part of our 180-day report to provide you 5 that information, but in addition to the 180-day report, which has not yet been 6 filed, we will provide that information as a part of responding.

7 PAT HILAND: Thank you.

8 MIKE SHORT: Next slide, please. RAI 43, discussion of the fluid 9 forces calculating -- used to calculate whether a support is active at AVB support 10 locations, and there are a number of assu mptions cited in the RAI, and there is a 11 request to provide additional informati on regarding the foundation for those 12 assumptions. Our response plan will provide the additional details on why 13 turbulent excitation force was used to ca lculate support effectiveness, and we will 14 -- as requested by the RAI, there's a stat ement in the RAI that has -- which the 15 staff has requested clarification of, and we will provide that clarification as 16 requested.

17 PAT HILAND: Okay. Thank you. That's -- the response plan there 18 is you're going to provide the details on why turbulence excitation forces used to 19 determine support effectiveness.

20 MIKE SHORT: That's correct.

21 PAT HILAND: Good.

22 MIKE SHORT: The next RAI is 44 on Slide 30. This RAI speaks to 23 the small amplitude vibration and its effect on the requ ired contact forces. It 24 requests discussion of our assumptions t hat no in-plane motion occurs if the 25 34 stability ratio is calculated to be less than 1.

0, how is that accounted for, and how 1 would the analysis results be affected if a smaller value was used for the 2 threshold. We will explain our basis for the method used in responding to both 3 this RAI and prior RAI 43 and 44. We believe it's probably best to do that in a 4 combined fashion, and we will discuss that the stability ratio criteria does not 5 affect the contact force.

6 I'd like to move on to RAI 45, wh ich goes to the Intertek Operational 7 Assessment. That assessment includes a discussion of the effect of power 8 reduction on the probability of initiation of tube-to-tube wear indications, and that 9 calculation is based on under standing of dynamic pressure and how that varies 10 with power; and there's a request to provide additional justification for how that 11 particular relationship was chosen, and how that relationship correlates with the 12 tube-to-tube damage patterns experienced at SONGS. Our response plan will 13 go through the basis for selecting dynamic pressure and the sources of the 14 information used in the Intertek OA, and we'll discuss the verification in 15 comparison with the tube instability calculation shown in that OA.

16 DOUG BROADDUS: Mike, I apologize. The individual who wrote 17 these RAIs is not here, but I just wanted to make su re on the previous one on 18 Page 30 that the response is going to fu lly address the question. So, is your 19 response going to address whether or not tube motion can occur at stability 20 ratios below one, less than one, and how that would affect the results in that 21 case? 22 MIKE SHORT: We will make sure that our response addresses 23 that question.

24 DOUG BROADDUS: That was a key part of that as well.

25 35 MIKE SHORT: Thank you. All righ

t. I'd like to move on to slide 32, 1 RAI 46. Forty-six speaks to the Westinghouse operational assessment, and 2 Westinghouse's use of a Connors coefficient, also known as beta value of 5.0, as 3 a threshold value for the fluid elastic inst ability constant. Our response plan does 4 wish to refer you to a reference that we have filed with the st aff that provides 5 substantial detail on the sele ction and basis for the value of the beta coefficient.

6 We will also provide in our response additional test data to demonstrate that the 7 selection of beta used in the operational assessment is appropriately 8 conservative.

9 PAT HILAND: I'm consulting behind me with the experts to see if 10 they are satisfied, and t hat's good. Good response.

11 MIKE SHORT: Thank you. Sli de 33 speaks to RAI 53. Again, on 12 the Intertek operational assessment and t he regression process used to develop 13 the tube-to-tube wear growth model, and wh ether or not approaches similar to 14 those outlined in generic letter 95-05 were used, to what degree this is 15 conservative, how is data scatter modeled, and ultimately a justification for the 16 distribution used. In our response plan we will explain the regression model.

17 We'll discuss the analysis and the basis for the normally distributed distribution 18 used for the tube-to-tube wear growth model, and overall just ification for the 19 approach.

20 Thank you. RAI 54 on the next slide, again, speaks to the Intertek 21 operational assessment. It's an additional question about tube-to-tube wear 22 growth rates and refers to some fi gures contained in that operational 23 assessment, and how they were used to yiel d the growth rates, how the figures 24 worked together, and that also there appears to be some missing data on one of 25 36 the figures. Our response plan is shown on the slide. We will discuss the 1 derivation of the figure 4-13 and how the wear rate was calculated in the 2 operational assessment, and then we will also show that the data is present in 3 the slide. The choice of the axes provided on that particular figure limited the 4 amount of data that we displayed, so we will expand the axes, the range of the 5 axes, so that all the data is displayed.

6 RAI 57, on the next slide, Slide 35 is a question regarding tube 7 support plate holes and their location and, in particular, if the location deviates 8 from the design parameters, and whether or not that was accounted for in MHI's 9 evaluation and if it was used in the evaluat ion, please provide an additional table 10 that includes how it was handled. Our response plan will point out that tube 11 support plate hole mislocation was consi dered in the analysis, and as requested, 12 we will provide an updated table including that information.

13 PAT HILAND: I've got to ask the question. Can you just give me a 14 ballpark for the types of mislocations t hat we're talking about

? Are we talking 15 about mils or fractions, or do you have any idea? I know I'm going to get an 16 exact answer.

17 MIKE SHORT: Yes, let me turn to Dr. Kiguchi.

18 MALE SPEAKER: My name is Kiguchi. This mislocation is just a 19 small mils inside the tolerance of the hole.

20 PAT HILAND: So, this is an internal tolerance of the diameter of 21 the hole, the two holes?

22 MALE SPEAKER: This is just the location of the hole.

23 PAT HILAND: Okay. So, it's tube-to-tube distance in mils?

24 MALE SPEAKER: Yeah.

[unintelligible]

25 37 PAT HILAND: All right. Thanks.

1 MIKE SHORT: Slide 37, RAI 58.

Questions regarding whether the 2 input parameters for the contact force ca lculation were sampled randomly or 3 developed through a functional relationship; and in particular requests 4 parameters such as AVB twist and the assumptions that go into those 5 parameters. So, our response plan will take each parameter and indicate 6 whether it was randomly treated and sampled, therefore, and which parameters 7 had functional relationships, and we'll expl ain the process used to obtain those 8 relationships as shown in a figur e within the MHI r eport, Appendix 9.

9 Next is RAI 59, which requests information about the statistical 10 distributions used for the AVB dimensional inputs and what was their technical 11 justification. Our response plan, as show n on the slide, will include the -- we 12 want to point out that t he data provided in Appendix 9, attachment 9-1, are the 13 results of verification testing prior to the application of the change in the AVB 14 nose press loads, and we'll provide justif ication for the assumed distributions.

15 PAT HILAND: Again, since I have a captive audience here, can 16 you just tell me a little bit about the verification testing? Is this empirical data that 17 you were able to obtain, or what is the te sting that you're referring to? You have 18 results of the verification tests. Can y ou just describe from 10,000 feet what the 19 testing was?

20 MIKE SHORT: In investigating the differences in manufacturing 21 between the Unit 2 steam generators and the Unit 3 steam generators we 22 observed through eddy-current inspection that the Unit 2 steam generators 23 appear to be tighter, if I can use that termi nology, than Unit 3. And we went back 24 into the manufacturing proc ess to ascertain why that might be the case, and MHI 25 38 developed a better understandi ng -- MHI explained that they made a change in 1 the way the AVBs were fabricat ed between Unit 2 and Unit 3.

2 PAT HILAND: If I recall, in t he December 18th meeting they talked 3 about a two to three mil change between manuf acture of Unit 2 and Unit 3 steam 4 generators. Is that the re ference we're talking about?

5 MIKE SHORT: I believe that's co rrect. Those -- two to three mil is 6 a correct parameter. Off the top of my head I'm not sure I can --

7 PAT HILAND: From two to three or vice versa, from three to two.

8 MIKE SHORT: Yes, between Unit 2 and Unit 3.

9 PAT HILAND: Correct. That's what we're talking about? Thank 10 you. 11 MIKE SHORT: And the referenc e to the press load change is on 12 Unit 3 a larger load was used to press the AVB nose into position. Now, in the 13 bending process of an AVB the nose section, which is the U-shaped portion at 14 the AVB, thickens because on one side as you bend the AVB. So, they use a 15 press to flatten that, and if values of the press load used fr om Unit 2 and Unit 3 16 were different -- Unit 3's loads were three times those used in Unit 2. As a result 17 of that, the AVBs and the twist associat ed with them, and the thickness of the 18 nose is different in Unit 3 than Unit 2.

19 PAT HILAND: Okay. Thank you.

20 MIKE SHORT: RAI 60 is straightforward. It's a request for some 21 additional figures, and we will provide those figures for Unit 2. The report only 22 includes figures for Unit 3.

23 RAI 61, on Page 39, points out that in our reports -- in separate 24 reports we provide figures that display that eddy current ding signal information, 25 39 and the two figures are different, and it r equests an understanding as to why they 1 are different. In our response we will poi nt out that the figures are based on the 2 same data. So, it's not an issue of data di fferences that led to the differences in 3 the figure; however, we excluded some information in reference 3 that was 4 included in reference 2, and that's the reason the figures were different. And in 5 reference 3 the figure excluded free-span ding signals but included tube support 6 plate ding signals. And in reference 2 we included the free-span ding signals, but 7 not the tube support plate ding signals.

So, we will straighten that out and 8 provide new figures that clarify and ar e consistent for these two reports.

9 PAT HILAND: I have to do this. Since I see a new engineering 10 term, "ding signals," the ding I presume is your, you know, surveillance machine, 11 when it goes through and has a threshold that indicates -- is that what it --

12 MIKE SHORT: Yes, let me explain what a ding is. Ding is a term 13 used by our eddy current analysts to describe an indication that the eddy current 14 system returns when it does its inspection of a tube, and a ding is a deformation 15 of the tube surface that is detected by eddy current. If it penetrates through the 16 tube wall it becomes a dent, but there is no change in the -- typically there is no 17 change in the inner surface of the tube; there' s a small imperfection on the outer 18 surface. 19 PAT HILAND: So, the eddy current has a threshold that it conjures 20 [spelled phonetically] and it's got a th reshold that sends a signal back.

21 MIKE SHORT: Right. And the threshold -- usually the term voltage 22 is used, which is the signal size, and thes e figures in some cases provide signal 23 size as well as location endings.

24 PAT HILAND: Okay, thank you.

25 40 RICK DANIEL: Mike, before y ou go further we have a question on 1 the phone from an NRC person.

Ben, can you hear us?

2 BEN PARKS: Yes, can you hear me?

3 RICK DANIEL: Yes, we can. Go ahead.

4 BEN PARKS: Okay. My name is Ben Parks. I'm in the Reactor 5 Systems branch, and I had a question about the proposed response to, I believe, 6 it was RAI 40 about the wetted tubes assu mption. I'd like to see if you can 7 explain in a little bi t more detail how you plan to s how that the assumption is 8 insignificant.

9 MIKE SHORT: I think it's probably best that we address that 10 question in our response so we understand that you wish to have a discussion of 11 how we arrive at that assumption and why we -- how that assumption can be 12 show to be not significant.

13 BEN PARKS: That's fair. I w ould encourage you to provide a fairly 14 detailed level of discussion for the purpos e of the reviewer so that he's not 15 encouraged to have to ask more questions.

16 MIKE SHORT: We understand the question. Thank you.

17 RICK DANIEL: Anything else, Ben?

18 BEN PARKS: That's it. Thank you very much.

19 RICK DANIEL: Go ahead, Mike.

20 MIKE SHORT: All right. On to RAI 62. It's a request for -- in the 21 AREVA operational assessment , a discussion of best estima te stability ratios.

22 It's a series of questions regarding the results of the AREVA operational 23 assessment and how those results compare to best estimate values versus the 24 probabilistic values that we used in the operational assessment. We understand 25 41 this question, and we intend to provide a very thorough response.

1 RAI 63 is a request to discuss follow-up on some materials 2 provided in the reference shown that s peak to differences in contact forces 3 between Units 2 and 3 as a result of manufacturing dimensional tolerances and 4 the fact that we excluded the outermost tubes as a boundary condition in our 5 contact force model. In our response we will explain the basis for excluding tube 6 to -- AVB gaps in the outermost tubes as a boundary condition. We will explain 7 that the calculation results indicate t he influence of the outermost tubes is not 8 significant, does not affect the contact forces inside the bundle.

9 EMMETT MURPHY: Have you actually done a calculation to 10 confirm that it's not an import ant player? Measured AVB gaps?

11 MIKE SHORT: Dr. Kiguchi, the question is, have we actually 12 performed the calculation to demonstrate that the outermost tubes and the gaps 13 associated between the tube and the AVBs d oes not influence contact forces 14 within the bundle?

15 MALE SPEAKER: This is Kiguchi again. Our understanding is that 16 we have some calculation actually changing the outside dimensions, and the 17 influences only in a few of those inside. Yeah, so, it's not where we want the 18 dimensions.

19 EMMETT MURPHY: The results of that analysis would be very 20 helpful. Thank you.

21 MIKE SHORT: We understand you'd like to see the results of the 22 calculations that we have performed.

23 All right. Slides 42, 43, and 44 ask a series of questions about the 24 twist factor in any vibrati on bars that results from t he manufacturing differences 25 42 between Unit 2 and Unit 3 steam generator s, how those twist factors were 1 developed and defined, requests for clarific ation of a number of aspects of the 2 twist factor and how it's modeled includi ng how torsional stiffness varies as a 3 function of distance from t he AVB nose, specific variation of torsional stiffness, 4 and how were those variations determined.

So, it's our intent in responding to 5 this RAI -- to actually to respond to this RAI and the next two as a combined 6 response. The RAI 65 requests a very similar discussion in terms of how the 7 function, once it's calculated or determi ned in responding to the previous RAI, 8 how that function was used in the contact force simulation. So, 64 requests the 9 details of how the twist factor was developed, and then 65 is essentially a 10 request for how it was used in the contact force simulation.

11 And then 66 is a request for some clarification on twist and 12 stiffness, how those units work and whether or not they ca n cancel each other 13 out, and, again, it's our intent to respond to these three RAIs as collectively in 14 single response. We'll work through, as I said, how the twist was determined, 15 and then how it's used in the model , and then we'll addr ess the follow-up 16 questions in RAI 66.

17 All right. The last RAI, number 67 , in this portion of the meeting on 18 page 45, is a request for discussion of how any tuning of the contact force model 19 was performed to replicate the ding signals that we discussed earlier. And we 20 will provide a detailed descr iption of the factors used to match the eddy current 21 inspection results. There is some relationship to RAI 59, and we expect to 22 combine the response to this RAI and RAI 59 into a single response.

23 RICK DANIEL: Okay. Any closing questions from NRC folks 24 regarding this portion of the RA Is? All right, Doug and Dan.

25 43 DOUG BROADDUS: Yeah, just one question real quick. I know 1 you'll probably provide this to us as well, and we may have a greater 2 understanding of this after the next portion of the meeting, but overall, when do 3 you expect that you'll be able to get us re sponses for each of -- for all of these 4 RAIs that we've issued at this point?

5 THOMAS PALMISANO: Let us summa rize that at the end of the 6 next portion.

7 DOUG BROADDUS: The reason I'm wondering is because the 8 public will not have an opportunity to hear that at the conclusion of the next 9 portion of it.

10 THOMAS PALMISANO: John, I know we just received some of 11 these and we've laid out our preliminary sc heduled. Can you give us kind of an 12 overview? Just one minute, Doug.

13 JOHN BRABEC: Bear with me just for a moment as I review our 14 schedule; I've got our latest schedule with us.

15 DOUG BROADDUS: I certai nly understand if we ask additional 16 questions and there's additional clarification it may change that, you know, at the 17 end of the meeting, but...

18 JOHN BRABEC: In our current schedule for responding to the 19 most recent group of RAI responses -- or the latest date I see in the schedule is 20 about the 14th of March and many of them before that.

21 DOUG BROADDUS: So, essentially about the same time that we'll 22 be getting the Intertek OA?

23 JOHN BRABEC: That is correct.

24 THOMAS PALMISANO: And let me put the caveat on, we received 25 44 some of these just last week, so this is our initial review of them. That's what our 1 schedule is based on. This discussion has been very helpful. We appreciate the 2 questions and the further comments on those; we'll now factor those into the 3 schedule, and we have periodic phone calls to keep you appraised. So, we'll 4 keep you appraised as our schedule develops.

5 DAN DORMAN: All right. As we wrap up the business portion of 6 the open portion of the meeting, I want to also thank y ou for the effort that you 7 put into putting together an initial take on these RAIs in very short order in 8 coming out here to support this meeting.

I note on your last slide -- you didn't 9 read it out there -- but you had no timeline for safety. We're going to keep at this 10 until we've got it right , and we appreciate the effort that you're putting in to 11 responding to the questions that we have. From here we will continue with our 12 review. As we await the additional responses we'll continue to work on the 32 13 responses we have before us. We are starting to develop our evaluation 14 documentation. In parallel we're continuing with the ins pection closure activities 15 as well. We don't have a set timeline for that, but the timely response to these 16 questions will help us keep moving this toward conclusion. As Rick indicated at 17 the beginning, we don't cu rrently have any further meetings of this type 18 scheduled, but as we continue our review and evaluate the responses you've 19 provided we'll continue to assess t he need, and if we need one we'll have one; 20 and ultimately bring both this techni cal evaluation and the inspection reviews 21 together to our chief of staff's recomm endation regarding the SCE plan. So, with 22 that, I'll turn it back to Rick.

23 RICK DANIEL: Thank you, Dan. Thank you all for the discussion 24 and questions. That concludes the nonproprietary portion of this meeting; so you 25 45 folks on the phone, we're getting ready to go to you to take your questions and 1 comments as well as those in the r oom. And we're going to take about 20 2 minutes for this period of time of questi ons. So, are there any questions in the 3 room right now on these RAIs? And I want to caution you that we're going to 4 stick to the subject of th is meeting, the RAIs that were discussed and you heard 5 about today. So, are there any questions in the room?

6 Kendra, stand up and introduce yourself, please.

7 KENDRA ULRICH: Hi, my name is Kendra Ulrich. I'm with Friends 8 of the Earth. My question pertains to the RAI 32 response. With all due respect, 9 quite frankly, it reads to me like a schoolboy's justification for why they couldn't 10 complete a homework assignment. This response essentially is asserting that 11 they understand what the regul ations are more than the regulators themselves.

12 But they understand what the interpretation of the technical specification is more 13 than the staff who have told them that t hey don't believe that this restart plan 14 complies with that technical specification.

That said, there's a very interesting 15 indication from their choice to try to comply with this by submitting the Intertek 16 OA supplement, and I was very encouraged to hear that Emmett Murphy on the 17 panel here said that he had a number of qu estions related to that; and that's 18 because the Intertek OA relies upon traditi onal measuring data and operational 19 experience. But what we know, what Edison has admitted is that the 20 phenomenon that are experienced within th e replacement steam generators are 21 unique globally. So, what they're sa ying is that by using the operational 22 assessments that actually address what

's actually happening within these 23 replacement steam generators they can't s how that they actually meet the terms 24 of the technical specification. So, what they're actually doing is relying upon tube 25 46 wear mechanisms that are known, which isn't the reality of what's going on here.

1 So, they're asking the NRC to set aside the reality of the situation and accept that 2 this is somehow related to what, you k now, the rest of the industry globally has 3 experienced.

4 Now, my question relates specifically to a public transparency 5 question, because at the end of this the la st two sentences of their response 6 clearly indicate that this is a test or experiment. They say, "We will take this 7 approach until we determine what the operational limits are.

" That says this is an 8 experiment or a test.

9 RICK DANIEL: Okay.

So, what's your question?

10 KENDRA ULRICH: My question is that this reads as a thinly veiled 11 argument for a confirmatory order. W hat I want to know, because we've been 12 hearing that that is the case, is whether or not Edison has been approaching 13 anybody within the NRC with a request for a confirmatory order to address the 14 NRC's concerns.

15 RICK DANIEL: All right. Thank you, Kendra. Dan, would you like 16 to address that?

17 DAN DORMAN: That might be a better question for the licensee. I 18 have not been approached by anyone from the licensee requesting a 19 confirmatory order.

20 DOUG BROADDUS: What I w ould add to that is, you know, 21 throughout this whole process we made it clear to the licensee that all options --

22 all regulatory approaches are on the table for us. You know, when we complete 23 our review we'll make a recommendation to Eric Leeds and Elmo Collins on what 24 is the appropriate approach to take. So, I would say that a confirmatory order, a 25 47 license amendment, everything is on the table right now. There is no 1 determination as to what has to be done in order to be able to restart. We are 2 continuing our review, and we won't be abl e to make that determination until we 3 complete that review.

4 KENDRA ULRICH: So, changing a technical specification, what 5 process does that require? If a lic ensee wants to change a technical 6 specification, what is the appropriate process to do so?

7 DAN DORMAN: If the licensee wants to change a technical 8 specification the process is laid out in 50.90; it's a license amendment.

9 KENDRA ULRICH: That's correct. And in this case NRC staff --

10 thank you for that -- NRC staff had said that this doesn't appear to meet the 11 terms of the license. Edison has come back and said, well, full power means 12 whatever we say it means, whatever we want to limit our operation to; that's 13 different. So, in any event, the public has been demanding a license amendment 14 process. NRC staff has come back, as was indicated by Mr. Howell, and said 15 that that is not the position that was indicated to the licensee, I believe he said on 16 January 29th, 30th. So, in this situat ion it would be wholly inappropriate and 17 completely subvert the demand of the public for a license amendment process in 18 a situation in which the licensee's respons e doesn't comply with the terms of their 19 license. And that is y our position, not ours.

20 RICK DANIEL: All ri ght. Thank you, Kendra.

21 DOUG BROADDUS: I just want to clarify that the RAI does not 22 make any conclusions; all that does is ask for additional information, and in 23 particular it asks for the licensee to demons trate why they believe that they're in 24 compliance with the technical specificati ons, or provide a 100 percent operational 25 48 assessment at 100 percent rated therma l power. It's because we needed that 1 additional information to be able to conti nue our review in part of our overall 2 assessment is -- what they're planning on doing is in compliance with the 3 requirements, with the regulations, with the license and such.

4 KENDRA ULRICH: Even if they set aside the actual [inaudible]

5 phenomenon that experienced with [inaudible].

That's the Intertek delay.

6 RICK DANIEL: All right. Thank you, Kendra. We're going to go to 7 the phone for a minute. Do we have any callers on the phone who would like to 8 ask some questions? Make comments?

9 OPERATOR: If you'd like to ask a question over the phone, please 10 press star one and record your name.

Again, please press star one and record 11 your name to ask a ques tion. One moment.

12 DAN HIRSCH: Dan Hirsch.

13 OPERATOR: Your line is open.

14 RICK DANIEL: Hi, Dan.

15 DAN HIRSCH: Can you folks hear me?

16 RICK DANIEL: We su re can. Go ahead.

17 DAN HIRSCH: Hello all.

I had a couple of questions and a 18 generalized comment. One smaller matter is that you were told by Edison that 19 they assumed the same wear rate, but in fact, what they assumed for that was on 20 volume, and then they reduced it by 70 perc ent in terms of the percent through 21 wall. So I think you may want to take a look at that.

22 The second point I want to ma ke is more important. You asked 23 some questions, as NRC, of Edison as to whether they were proposing on 24 making commitments regarding having to get NRC approval if they either 25 49 operated at higher power than 70 percent or if they wa nted to run for more than 1 the five months. As I read their answer to RAI 32 and what they said in the slide, 2 I am a little concerned that t hey may have slid over thos e two matters. As I see 3 their answer, they're saying that they would not run at higher than 70 percent 4 power without NRC okay, but they're proposing to be able to run for five months, 5 shut down, test their experiment, and then decide to run again and again and 6 again. There's no indication in their stat ement that they're actually asking for 7 permission from NRC for any of that subs equent run. And I think you may want 8 to get that clarified as to whether they are asking you for five months 9 authorization or asking you for unlimited authorization where they shut down and 10 then they decide whether to keep r unning again and again and again.

11 And lastly, this is related to RAI 32, I just think someone has to say 12 very clearly that it really shakes public confidence in the credibility of Edison to 13 have them come in and try to say that 70 percent power is full power. And I was 14 pleased to hear that the NRC staff in its January meetings had rejected that 15 interpretation. But it's also very troub ling to hear them sayi ng that they have now 16 hired someone to try to come up with an ana lysis to try to demonstrate what it's 17 like [spelled phonetically] to run at 100 percent power. Obviously we wouldn't be 18 here if they could run at 100 percent power. If 100 percent power was safe there 19 would be no need to run at 70 percent power. And I think the credibility is 20 beginning to seriously crumble about this ent ire process. And I want to point out 21 that the analysis that they may be doing, if it's just for five months, would be 22 insufficient to prove what you need to have proven, which is that indeed they can 23 run for the long periods of time like they s eem to be contemplatin

g. Thank you.

24 RICK DANIEL: All right. Thank y ou, Dan. I want to take those one 25 50 at a time. Doug, go ahead.

1 DOUG BROADDUS: Well, actua lly, Emmitt, did you have anything 2 on the first part of that? The growth rate -- rates in any way.

3 EMMETT MURPHY: Yes. This is Emmett Murphy. If I heard the 4 gentleman correctly, he basically restat ed what I think we heard earlier in 5 response to RAI 26, namely that it is a look-ahead. They are projecting wear 6 rates based on a constant volume -- constant rate of removal of volume. That's a 7 standard approach to evaluation of problems of this type.

8 DOUG BROADDUS: All right.

If I understood the second part, it 9 was related to the commitments and whether or not the RAI -- the response to 10 RAI 32 was requesting or indicating that

-- a desire to operate at 70 percent for 11 an unlimited period beyond the first 150 days.

What I would say on that is we're 12 definitely going to be looking at the specifics of that RAI 32, and we've only had a 13 couple of days to look at it. And I'm certain that will be something that we're 14 going to want to make sure we underst and what exactly those commitments or 15 those statements mean, and you know, if there's a need for any clarification.

16 And, as Tom mentioned earlier, you know, if there is any need for that we can 17 talk and discuss that and get t hose clarifications made.

18 You know, I -- to the specifics of what it means, you know, I can't 19 comment on that right now, because as I said, we're still reviewing it, you know, 20 unless you wanted them to respond to that in any way as to what the intent -- you 21 know, whether you're -- it actually states what Mr. Hirsch was saying.

22 THOMAS PALMISANO: Well, what we have stated here in our 23 response is that durations of run would be determined by the operational 24 assessment process in accordance with the steam gener ator management 25 51 program, which is required by our tech specs.

Standard program used across 1 the country, and we've said we were limiting operations to 70 percent power, 2 determine the length of the proposed subs equent operating peri od based on that 3 program, and then the operational assessm ents were submitted to the NRC in 4 accordance with t he program.

5 DOUG BROADDUS: Okay. All ri ght. The third part of that --

6 referred to the Intertek supplemental OA , and I'm not sure if I quite heard a 7 question in that. Emmett, did you hear anything that was a question in that?

8 Maybe I misunderstood.

9 EMMETT MURPHY: I did not.

10 RICK DANIEL: Dan, are you still on the phone?

11 DAN HIRSCH: I am.

12 RICK DANIEL: Do you have a specific question about the OA?

13 DAN HIRSCH: No. Well, yes, on the OA, I guess. Are you going 14 to be getting a revised OA that is simply for five months operation whereas 15 Edison is now claiming that the decision as to whether to run longer than that is 16 within their jurisdiction without having to get your approval? Because if that's the 17 case the OA that you should be getting is for far more than five months.

18 DOUG BROADDUS: I believe w hat I heard earlier was that the 19 supplemental OA was going to be addressi ng the 150-day time period, which is 20 consistent with the steam generator tube integrity prog ram in the tech specs, 21 which is you do the operational assessm ents for the planned period that you're 22 going to be operating for, and then once t hat period, as Mr. Palmisano was just 23 mentioning, after the end of that period you would be required to do another 24 operational assessment and projecting forw ard how the additional -- you know, 25 52 any additional wear that would occur beyond that time period. So, without -- and 1 I think to go specifically to the ques tion of whether we should be asking for 2 anything beyond that, and I'll defer to Emmett if he -- if there needs to be 3 anything more on that. I think it would be -- we would not -- you wouldn't be able 4 to project both what's going to happen now, as well as what's going to happen 5 then unless you have a complete cycle, if you start up and shut down, and then 6 start up and shut down again. I mean, t he whole purpose is to look at what 7 occurred during that one cycle and project what goes forward through the 8 program. You know, what the wear is going to be for the next interval. So, 9 providing something for two intervals out I believe is beyond what the 10 requirements specify.

11 EMMETT MURPHY: That's correct.

12 DAN HIRSCH: If I could just re spond to that. I think that it's a 13 really big deal, because the CAL, the c onfirmatory action letter you've issued, 14 says they cannot restart until they get your approval. But they're asking you to 15 give the approval, saying, "Hey, we'll only run for five months."

But once you give 16 them that approval, the position they s eem to be taking is that they can then 17 choose on their own to keep running, in fac t, for years. So if your approval is 18 necessary to determine restart, your approval should be based on what that 19 approval can authorize, and that could be not five months, but years. And I think 20 that's the fundamental problem here, is the five months. You're not even going to 21 be able to tell the difference in terms of the wear on many of these tubes, you 22 know, compared to the 22 months we've al ready seen. So they're coming in and 23 kind of low-balling what they want you to give permission for, but once you give 24 them that permission they're going to be able to use that permission for far more 25 53 than they asked to. And therefore, t he analysis they provided to you should 1 really be for all that they would be permitted to do if indeed you authorized 2 restart.

3 DOUG BROADDUS: Yeah, I apprecia te that input, but I, you know, 4 I can tell you that our assessment is going to be on, you know, what they've 5 provided to us and any decision will also consider longer-term, you know, 6 operation process and how that's going to be addressed going forward.

7 DAN HIRSCH: Then you'd better te ll the Hill, I think, that you're 8 contemplating giving them open-ended approv al for long-term running, but only 9 analyzing what the effects ar e for five months. I thin k there will be a lot of 10 surprise on the Hill about that.

11 DOUG BROADDUS: I don't think I said that. I said -- what I said is 12 that we're reviewing what's been put bef ore us, the plan that's been put before 13 us, and that any decision we make will also consider the longer-term process, 14 and that's one of the reasons why actually we have indicated to the licensee from 15 the very beginning that we need to under stand what their long-term plan is, and I 16 believe that's why they provided that in this RAI 32 response, is to start that 17 dialogue and that under standing of the l ong-term plan.

18 DAN HIRSCH: Well, let me just reiterate. What they told you is 19 they believe they have the power once you st ate it can restart, that they get to 20 choose the long-term plan; and yet you're not analyzing for what the effects are 21 of that long-term operation. I' ve made my point. I just think that this is really very 22 troubling and it's not the way a safety analysis ought to be done. One should be 23 analyzing what the potential effects are of permitting re start if in fact that 24 permission allows them to run for consider ably longer than five months without 25 54 having to get your okay.

1 ARTHUR HOWELL: Mr. Hirsch, this is Art Howell. I would just 2 note that the terms of the confirmatory action letter re main in place until such 3 time it is changed and the staff will decide what mechanism by which to change 4 that. So, no decisions have been made at this point, but we will -- we understand 5 your point and we'll take that into account as we go forward.

6 RICK DANIEL: All right. Thank y ou, Ray. Thank you, Ray. Let's 7 have a question here in the audience.

8 MARK VOSBURGH: Hello. My name is Mark Vosburgh. I'm with 9 CAN, Coalition Against Nukes. And I would like to concur with Kendra Uldrich --

10 Ulrich, excuse me, and the earlier calle r regarding the concerns about RAI 32.

11 Specifically, RAI 32 troubles us greatly. The possibility that is being entertained 12 here today seems to be that the Co mmission will consider possibly changing 13 their own regulations and ignorin g the spirit of the regulat ion itself. It seems to 14 me the regulation was very clear: 100 percent power, full power, that's 100 15 percent of licensee power that was -- that's on record. We know that 70 percent 16 does not equal 100 percent. Okay? Last ti me I checked, 70 does not equal 100.

17 Okay? I want to be very clear on that.

The public that I'm in touch with is very 18 concerned about the possibilit y of changing that regulation to accommodate the 19 licensee.

20 RICK DANIEL: All right. Thank you, Mark. Do you have a 21 question?

22 MARK VOSBURGH: Yes I do.

I have another question as well 23 following. The question is which part of 100 percent do they not understand?

24 Now, the other question that I would have -- I have an RAI of my own here and 25 55 that is -- okay, I'm -- hello? Okay.

I have an RAI of my own, and that is the 1 Mitsubishi memo. Specifically, I'm talking about the me mos that --

2 RICK DANIEL: Mark, excuse me. I'm going to stop you right there 3 for a minute, okay? This is not the foru m to be talking about that. We're here to 4 discuss RAIs. We have the right people in the r oom --

5 MARK VOSBURGH: The public is very concerned about that.

6 RICK DANIEL: I understand.

7 MARK VOSBURGH: May I ask w hen that would be available to us 8 and why it's taking so long for us to get that memo?

9 RICK DANIEL: We'll try to get you an answer, okay?

10 MARK VOSBURGH: Are you taki ng the situation seriously from 11 our lawmakers?

12 RICK DANIEL: We're absolut ely taking all these situations 13 seriously, but what I'm saying is this is not something we can entertain just now, 14 and we're trying to focus our discussion and questions on these RAIs. So, it'll be 15 noted that that's a question and --

16 MARK VOSBURGH: I am requesting that additional information.

17 RICK DANIEL: Okay, and we ap preciate that. Thank you very 18 much. Kendra.

19 KENDRA ULRICH: Rick, I appreciate you recognizing that I wasn't 20 quite done earlier, so thank you. So I appreciate Dan Dorman's insight that he 21 has not been approached for confirmatory or der, but in fact, my question was not 22 answered. My question was whether anybod y at that table or anybody else 23 within the agency, to your knowledge, has been approached by Edison and how 24 often with the request to address the concerns raised on RAI 32 with the 25 56 confirmatory order? Specifically, limi ting power to 70 percent operation.

1 DOUG BROADDUS: If I understand your question, your question 2 is has SCE specifically asked us whether or not we -- to i ssue a confirmatory 3 order. Is that what you're asking?

4 KENDRA ULRICH: Well, what I'm asking is, you know, if you insist 5 on this interpretation, as the regulator, t hat they actually have to comply with the 6 wording of their technical specification, if they have expressed to you that they 7 would be amenable to the confirmatory orde r to address that concern rather than 8 them having to apply for a license amendment, which quite frankly, they 9 should've applied for months ago.

10 DOUG BROADDUS: I think that that, again, I think I would defer 11 that to the licensee whether or not they'r e interested in a confirmatory order or 12 not, not to us whether or not we're --

13 KENDRA ULRICH: I think that this is an issue of public 14 transparency.

15 RICK DANIEL: Oh, Kendra.

16 KENDRA ULRICH: No, let me finish.

17 RICK DANEIL: I think what they're saying is that no one has 18 approached the NRC.

19 KENDRA ULRICH: They haven't sa id that. No one at that table 20 has said that they haven't.

21 RICK DANIEL: Has anyone at the table been approached by 22 Edison about doing a confirmatory action?

23 KENDRA ULRICH: Or that they would be amenable to a 24 confirmatory action?

25 57 RANDY HALL: No one from Southern California Edison has 1 specifically asked me if the NRC would be amenable to a confirmatory order.

2 KENDRA ULRICH: And have t hey, to your knowledge?

3 MALE SPEAKER: Same here.

4 RICK DANIEL: Dan?

5 DAN DORMAN: I already answered that.

6 RICK DANIEL: Art?

7 ARTHUR HOWELL: Only I would just say that there have been 8 discussions as there has been with member s of the public about what paths may 9 be likely or feasible depending on the answers to RAI 32.

10 KENDRA ULRICH: I thin k that was a yes.

11 ARTHUR HOWELL: There have been discussions about all paths 12 and all options. For example, they can -- as you indicated, they maintained their 13 original position on the technical specificat ion, which is that they're compliant. If 14 that were the case and we still disagr ee, there's a process to handle that 15 disagreement; it's the backfit process, confirmatory order, license amendment 16 requests, or revised operational assessmen

t. So all four of those have been 17 asked by various members of the public and also by licensee and us.

18 RICK DANIEL: All righ

t. Thank you, Kendra.

19 KENDRA ULRICH: W hat about Emmett?

20 RICK DANIEL: Emmett, the button, the button.

21 KENDRA ULRICH: I'm sorry. What?

22 EMMETT MURPHY: Negative. I have heard no such inquiry.

23 KENDRA ULRICH: Okay. Thank you.

24 RICK DANIEL: Thank you, Kendra.

All right. Let's go back to the 25 58 phones. Do we have anyone else on the phone that would like to ask a question 1 at this moment?

2 OPERATOR: Yeah. Renald [s pelled phonetically], your line is 3 open. 4 MALE SPEAKER: Hello?

5 RICK DANIEL: Hello. We can hear you loud and cl ear, Renald.

6 MALE SPEAKER: Okay. Hi. Let me first say this. These 7 regulations apply to all the 104 reactors , and affect all Americans, not only 8 Edison. So you cannot change the rules for one utility. The NRC is 9 compromising their reputation and their ob ligations to all Americans and for all 10 the reactors. What I hear is that Edison is saying forget about the mistakes 11 made by SCE and MHI, and forget about what happened to Unit 3. Just give us 12 permission to operate at 70 percent pow er and our operators can handle any 13 kind of an accident scenario, and we'll go on from here.

14 RICK DANIEL: All right. So --

15 MALE SPEAKER: It is the job of the NRC now to be totally there to 16 everybody, enforce regulations equal ly. Thank you very much.

17 RICK DANIEL: Thank you, Renald. Thank you very much.

18 Anyone else on the phone that had a question or make a comment?

19 OPERATOR: Yeah, Bruce Cam pbell, your line is open.

20 BRUCE CAMPBELL: Thank you. So I asked this at an NRC 21 hearing in Orange County but didn't get a re sponse. When was the anti-vibration 22 bar design team formed to evaluate steam generator replacement at San Onofre, 23 and what were the dates of their meetings

? And if you don't have that info with 24 you now, can you get it to me within this week, for instance?

25 59 RICK DANIEL: We might be able to do that, Bruce. Hang on just a 1 minute.

2 DOUG BROADDUS: Could you i ndicate to me which RAI you're 3 referring to in this question so we can try to narrow that down what you're asking 4 about? 5 BRUCE CAMPBELL: I don't have the RAIs in front of me. Also I 6 want it --

7 DOUG BROADDUS: Okay. C ould you narrow down the topic of 8 what it is that -- you're taking about the design team?

9 BRUCE CAMPBELL: Generator r eplacement at San Onofre. They 10 performed an anti-vibration bar design team, and I want to know when it was 11 formed, when they first met --

12 DOUG BROADDUS: And you're --

13 BRUCE CAMPBELL: -- and what dates their meetings were.

14 DOUG BROADDUS: Are you refe rring to a design team that was 15 formed after the CAL was established? Is that what you're -- are you talking 16 about any design team?

17 BRUCE CAMPBELL: I believe Edison and the NRC are well aware 18 which team I'm talking about, and don't try to divert attention just because I don't 19 have all documents in front of me right now.

20 DOUG BROADDUS: Are you ta lking about the design team that 21 was established after March of last year?

22 BRUCE CAMPBELL: I believe it was established in the middle of 23 last decade or somewhere around t here, is what I understand.

24 MALE SPEAKER: Okay.

25 60 BRUCE CAMPBELL: Are ther e two anti-vibration bar design 1 teams? I was particularly asking about t he first one, but I'd like to know all 2 meetings of all anti-vibr ation bar design teams rela ted to steam generator 3 replacement at San Onofre.

4 RICK DANIEL: All right. Hang on.

We're going to try to get you an 5 answer, Bruce. Just a minute.

6 BRUCE CAMPBELL: Thank you.

7 [inaudible conversation]

8 RICK DANIEL: Yeah, Bruce, since this does not pertain to these 9 RAIs, I'm just going to ask you submit this to us in writing and so we can get you 10 a concise answer. If you can just give us that in writing we would really 11 appreciate it and we'll try to get you an answer, because we do want to answer 12 your question. Okay?

13 BRUCE CAMPBELL: And the best place to send the question 14 would be on that sheet handed out --

15 RICK DANIEL: Yes.

16 BRUCE CAMPBELL: -- at the NRC meeting in Orange County at 17 that address?

18 RICK DANIEL: Yes, sir. And don't forget to check the box that 19 you'd like a response and we'll see to it that we get a response for you. Okay?

20 BRUCE CAMPBELL: And this would be in regards to every anti-21 vibration bar design team whether it was last decade or this decade?

22 RICK DANIEL: I don't have a re sponse for that right now, but we 23 will research this and we will try to get you an accurate response. Okay?

24 DOUG BROADDUS: W hat would help us most is if your question 25 61 is specific to what it is you're looking fo r -- that's what I wa s trying to get is to 1 understand, you know, if you're talking about any teams that were developed, 2 you know, years ago or teams that were developed more recently or what, 3 because I'm not exactly sure.

4 BRUCE CAMPBELL: Yeah. When -- I was particularly referring to 5 what was -- the team that met last dec ade, but I'm also interested in the newer 6 teams if they exist.

7 RICK DANIEL: Okay. If you send that in we'll get you an answer.

8 Okay? Thank you, Bruce. Ok ay. Next calle r, operator.

9 OPERATOR: Thank you. Paul Patterson, your line is open.

10 RICK DANIEL: Hi, Paul.

11 PAUL PATTERSON: Hi. Hi.

How are you? Can you hear me?

12 RICK DANIEL: We su re can. Go ahead.

13 PAUL PATTERSON: Just really quickly on the -- just procedurally 14 I'm trying to, you know, just from a non-expert perspective, we're just trying to get 15 a sense as to what the timeframe is here, sort of what the nex t steps are, so the 16 RAI -- you guys have questions about them and, you know, it's going to go back 17 and forth, just sort of w hat the next steps, are and when we think -- when do you 18 think you'd be in a position to make a decision on thes e startups?

19 RICK DANIEL: Go ahead, Dan.

20 DAN DORMAN: Paul, this is Dan Dorman. The -- as I indicated 21 earlier, we don't have a set timefram e because we're going to follow our 22 questioning and we're going to follow our technical evaluation until we get to a 23 conclusion, but the information that the licensee provided here t oday is that they 24 estimate that they'll respond to our late st 35 questions within about the next two 25 62 to three weeks. The staff is continui ng to evaluate the responses that we've 1 received to the first 32, and then we will evaluate the responses to the next 35, 2 and if we don't have any further questions we'll get into development of the 3 documentation and a lot of internal discuss ion of the evaluatio n that we've done.

4 In parallel, we've got some inspection activities that will continue, be ongoing, so 5 I would say that the earliest that we would expect to reach a decision would be 6 probably late April, but I caveat that bec ause as we continue through this there 7 may be additional questions t hat come up that would ca use that to slip out 8 further.

9 PAUL PATTERSON: That's great. I really appreciate it. Thanks 10 so much, and thanks for the call.

11 RICK DANIEL: All right, Paul. Folks on the phone and in the 12 audience here, at this time we said we were going to take 20 minutes. We've 13 taken about 34. I was never that good at telling time. But anyway, we took 34 14 minutes and this concludes our non-proprieta ry portion of the meeting. So we're 15 going to take a break. If you folks on the phone have any additional questions, 16 please feel free to submit them to the NRC via the public websit e, and we'll try to 17 get you some answers, especially if they pertain to these RAIs or this RAI 18 process -- review process. So thank you. We're going to take a 15-minute 19 break, and when we come back we're going to be just dealing with folks that are 20 able to deal with propriety information, so that will discount you folks from the 21 public and the news media. Sorry, Kendra.

Thank you very much. Let's get 22 back together at 3:20.

23 [Whereupon, the proceedings were concluded]

24