ML20247K369
| ML20247K369 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/29/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247K346 | List: |
| References | |
| NUDOCS 8909210139 | |
| Download: ML20247K369 (153) | |
Text
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.UNITED STATES ,
NUCLEAR REGULATORY COMMISSION
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I j 3 OFFICE OF NDCLEAR REACTOR REGULATION In the Matter of: )
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Status Briefing with Sacramento ) Municipal Utility District (SMUD) on ) Rancho Seco Nuclear Generating Station )
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. s Pages: 1 through 104 Place: Rockville, Maryland Date: August 29, 1989
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L ia a _ 1 UNITED' STATES NUCLEAR REGULATORY COMMISSION
! OFFICE OF NUCLEAR REACTOR REGULATION
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In the' Matter of: )
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Status Briefing with Sacramento ) Municipal Utility District (SMUD) on ) i
' Rancho Seco Nuclear Generating Station ) I Tuesday, August 29, 1989 0 Room 12-B-11 One White. Flint North 11555.Rockville Pike Rockville, Maryland The meeting convened, pursuant to notice, h .at 9:02 a.m.
P' RESENT: On bahalf of the Nuclear Reculatorv Commission: THOMAS MURLEY, Director, NRR-STEVEN-A. REYNOLDS. Project Manager, NRR GEORGE KALMAN, Senior-Project Manager, NRR ~ MARTY VIRGILIO,. Assistant Director, NRR-JAMES PARTLOW, Associate Director, NRR GARY HOLAMAN, Acting Director, NRR On behalf of the Utility: DAVID BOGGS, General Manager DANIEL KEUTER, Assistant General Manager, Nuclear STEVEN CRUNK, License Manager
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2 1 P_ B Q C E E I. H G A 2 HR. REYNOLDS: We will go ahead and get started. 3 Today's meeting is between the NRC and the Sacramento 4 Municipal Utility District,or SMUD. Other people are here 5 today. I ask that they hold any questions or comments that 6- they may have until the end at which time they can address 7 those questions to the NRC. In addition to the people in 8 this room, we have members from Region V out in California 9 with us via our video conferencing equipment. 10 To start this meeting, I would like to rute a few 11 introductions. I am Steve Reynolds and I am the project 12 manager for Rancho Seco. Sitting next to me is 13 George Kalman, the senior project manager for (. j) 14 Rancho Seco. From SMUD we have Mr. David Boggs, and he is 15 the general manager. Mr. Dan Keuter, who is the assistant 16 -general manager of nuclear. And Mr. Steve Crunk, the 17 licensing manager. 18 From the NRC we have Dr. Tom Murley, the i 19 director of NRR. Sitting next to me is Marty Virgilio, the ] 20 assistant director of Reactor Projects III and V. 1 21 DR. MURLEY: Why do we not go around the room and i 22 introduce ourselves. 23 MR. REYNOLDS: Okay. 24 DR. MURLEY: You have got Marty and me, ; 25 Tom Murley.
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'l MR. PARTLOW: Jim Partlow, associate director of 2 NRR.- '
3' MR. HOLAHAN: Gary Holahan' acting director for , 4 Regions III, IV, and V'. , 5 MS. ALMOND:- Amy Almond.
-6 MR. SCINTO: I am Joe Scinto.
7 "MR. PODOLAK: Ed Podolak, emergency planning 8 -branch,-NRR. 9 MR. TRIMBLE: Dave Trimble, Commissioner 10- Curtis' office.
'11 MR. BROWN: Greg Brown, Stone & Webster.
12 MR. REIS: Ed Reis, Office of' General Counsel. 13 MR. T77 LOR: Jim Taylor,.B&W. h 14. MR. HAROLD: Jeff Harold, NRR. 15 MR. WOOD: Bob Wood, NRR. 16 MR. LEWIS: Steve Lewis, OGC. 17 MR. PITTIGLIO: Larry, Pittiglio, low level waste 18 . management / decommissioning. 19 MR. LEWIS: David Lewis from Shaw Pittman. 20 MR. ZOEPLL: Fred Zoepil from ABZ, Inc. 21 MR. CUTCMIN: Mack Cutchin from 22 Commissioner Roberts' office. 23 MR. HAYES: Ben Hayes, Office of Investigations.
~24 MR. CONNOR: Lynn Connor, the NRC Calendar.
25 MR. HALE: Eric Hale, SERCH/Bechtel. Heritage Reporting Corporation ("gh- (202) 628-4888
c.n l' MR. CLAYTON: Brent Clayton from the office of
.2 the' director of operations.
- 3. MR. RICHARDS:- 'Stuart Richards from the 4 Region V office. ,
5 MR. KNIGHTON: . George Knighton, PDV. _6 MR. LAMBE: Bill Lambe, NRR. 7 MS. LEE: Jean Lee, NRR. 8 MR. BANGART: Rick Bangart, low level waste 9 management / decommissioning, NMSS. + 10 MR. KARMAK: Myron Karmak from 11 Commissioner Rogers' office. 12 MR. JOHNSON: Jim Johnson, low level waste. 13 MR. REYNOLDS: And would the people from t 14 Region V identify.themselves, please. 15 MR. ChiAFEE: Al Chafee, safety and projects, and 16 Ross Scarano. 17 MR. REYNOLDS: This meeting was called by the 18 NRC. The purpose of this meeting is to discuss the present 19 plant status of Rancho Seco and to discuss the future plans 20 for plant closure and decommissioning. Also SMUD will 21 provide a brief summary of their status for divestiture. At 22 .this time, I would like to have Dr. Murley make some opening 23 remarks. 24 DR. MURLEY: Thank you, Steve. I would say to 25 amplify that there are two purposes that we would like to Heritage Reporting Corporation (202) 628-4888
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. h* 1 get out of today's meeting. First is to understand your 2 intentions with regard to the Rancho Seco plant. And second 3 we need to assure that we have mutual understanding of how 4 these activities at th'e plant are going to be conducted.
5 We are reminded that SMUD holds a valid operating 6 license. That allows you to operEte Rancho Seco at full 7 power provided that you meet all of the. pertinent NRC 8 requirements. A license carries with it certain obligations 9 of course. There are many license conditions that have to 10 be met as long as you hold that license. 11 My staff informs me for example that there are 12 several surveillance tests and inspections that are due in 13 the coming months. If you want relaxation from some of I ) 14 these license conditions, you must obtain NRC approval. And 15 our regulations specify procedures for making amendments to 16 that license. 17 We the NRC of course have certain obligations 18 ourselves. We have to know the condition of the plant at 19 all times. We have to make sure that the plant license is 20 respected, that the plant in this case is not allowed to 21 deteriorate. We intend to monitor the activities of the 22 plant to ensure compliance with the license conditions and 23 to ensure a safe disciplined approach to all license 24 activities at the plant. 25 MR. REYNOLDS: Would the Region like to make any Heritage Reporting Corporation
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h 1 opening comments? l 2 MR. CHAFEE: No, not at this time. 3 MR.'REYNOLDS: If there are no other opening 4 commentB from the NRC,*I wo,uld like to turn it over to 5 Mr. Boggs and you may proceed. 6 MR. BOGGS: Thank you very much. Just a brief 7 look at our agenda. It is slightly different than the 8 printed agenda that you have before you. We were be 9 covering all of the items that will be on that agenda, but 10 this is the format that we would like to follow which is 11 indicated in your booklet. I will be giving a very brief 12 introduction and then we will get into the more detailed 13 closure status, a number of elements of that, with I' d) 14 Dan Keuter and Steve Crunkr as we go through the 15 presentation. 16 You have already met members of my staff who will 17 be providing updates to you today. As you are well aware 18 and as has already been indicated that due to the 19 June 6th vote that we have taken a two pronged approach to 20 how we are dealing with Rancho Seco. One is closure and the 21 other is divestiture, and I will give a very brief update on 22 that in such a moment. 23 One of the very first items and always an 24 important element is what about the Rancho Seco budget. l 25 First I would like to talk about the 1989 budget. The vtg Heritage Reporting Corporation l (se (202) 628-4888
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%e 1 original budget which is shown at the top of 2 $200.5 million includes both capital and operations expenses
'3 and operations and maintenance expenses. And our current 4 projection for shutdowh is,$147 million.
5 Of that $110 million is operations expenses, and 6 that was originally budgeted at $116 million. So there has 7 been just a slight decrease in that number towards closure, 8 and the balance is in the capital area. And as you can see, 9 there obviously has been some impact on the capital side. 10 , When we go our budget, Dan Keuter as AGM nuclear 11 has full respons:.oility for that budget reporting directly 12 to me. And in my experience at SMUD as general manager 13 which goes back to June of 1988 and prior to that time I was , '), 14 in a different position, both our board and our senior 15 management have always supported the Rancho Seco budget. I 16 do not see that in any way diminishing over time. 17 We expect in 1990, we have a current projection 18 of a $50 million budget including decommissioning costs. I 19 will be reviewing that budget in detail with Dan. We do not 20 expect that any rate actions or any other actions at the 21 district would prevent us from having adequate resources 22 available to meet the Rancho Seco needs for closure. 23 MR. PARTLOW: Would you give that split again 24 before operations and capital? 25 MR. BOGGS: Yes. Basich11y, Jim, on the current Heritage Reporting Corporation ffh Ju/ (202) 628-4888
c,s 8 L ( j, 1 ' projection which is the dotted line off to the right, the 2 $147 million, the current year end pr6jection is L '2h $110Lmillion for cperations and $37 million'for capital. 4 The next it'm e which is obviously of concern to 5 all'of us is the overall staffing situation ht Rancho Seco. 6 I'believe that you are familiar with the top line which was
.7- submitted to the NRC previously by-letter indicating on the 8 left-hand side at the top where at June 1 of 1989 we were 9 at 1600 total employees, and we expect by the end of 10 December or January 1, 1990 to be at approximately 400.
11 There are several items that I would like to 12 mention here. The dotted line below shows our current 13 staffing level. We are currently at approximately roughly
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. 14 750 positions with people in those positions. We have
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15 expedited our defueling by approximately four to six weeks. 16 We are projected now for mid-october for defueling. 17 One of the things that happened immediately upon 18 the vote being taken on June 6th was that Dan and his staff 19 moved in very quickly and began dealing with a retention 20 program to keep key people. And cut of current management, 21 20 of the 25 senior managers have been retained, and 87 out 22 of 89 retention agreements were accepted. So we went 23 immediately to retain key people. 24 Now obviously over time we could lose some of our 25 other people, and we expect that by keeping the ones that we [, - Heritage Reporting Corporation (202) 628-4888 O i
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1 have and augmenting the others by contract if necessary that 2 we can continue to keep staffing at an appropriate level.
.3 I would also liko to add that our senior 4 management including myselt has been in place for quite some 5- time at least on SMUD standards which is anywhere over six
'6 mor.ths . But the fact is that we are there and it is the
- 7. same. team, and I think that is important as we move through 8 closuro.
9 MR. PARTLOW: You say that you are at 750 now? 10 MR. BOGGS: Approximately. 11 MR. PARTLOW: SMUD? 12 MR. BOGGS: SMUD only, that is correct. 13 .MR. REYNOLDS: That includes the security staff?
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- 14. MP. KEUTER: 750 SMUD employees. We have 150 15 contractsecurithrpeople.
16 MR. PARTLOW: That brings you up to about 900 on 17 this line? 18 MR. BOGGS: Right. 19 MR. KEUTER: And we also have currently 20 approximately 62 contractor. 21 MR. REYNOLDS: Do you plan to go into more the 22 key personnel? 23 MR. KEUTER: I am going to talk a little bit more 24 about that. 25 MR. BOGGS: We will cover that in depth. 6" Heritage Reporting Corporation (202) 628-4888 _ _ . _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _._________
_ _ _ _ _ _ .- _ _ - _ _ - _ _ = _ - _ _ _ _ _ _ __ ____ _ _ _ _ 10 ni I 1 MR." KALMAN: Your charts here indicate that 2- ' dotted line includes the security folks.
.3 MR. KEUTER: Yes,'it does.
4- MR. KALMAN: So.that is the 900 line? ) 5 MR. KEUTER: It is about 950. 6 MR. KALMAN: Okay.. 7 MR. KEUTER: SMUD only is approximately 750. 8 MR. REYNOLDS: Thank you. 9 MR. BOGGS: And we will cover that in more detail 10 by classification. 11 MR. REYNOLDS: Thank you. 12- MR. BOGGS: Again-this is just a very brief 13 overview. On the. closure, one of the items that I would 63) 4 14 like to mention.is that we again moved in very quickly after 15- ,the vote and put a team together to not only protect 16 Rancho Seco and what was happening with closure but also 17 taking into consideration the SMUD district objectives as 18 well. 19 As the general manager, I appointed 20 Dan Keuter following Joe Firlit's resignation as the 21 assistant general manager of nuclear. Dan and I meet at 22 least weekly to go over the closure status. That is a 23 process that we have been using since the day that the vote 24 was taken, and we will continue to do that. So I am updated 25 on a very regular basis on the status of closure. We brief f} Heritage Reporting Corporation (202) 628-4888 L L. . _ - ________ _ _________ -
V - 11 1 our board of directors at least monthly on the same basis 2 which deals with closure budgets and staffing levels, so 3 that they are aware at all times cf what is happening. 4 We. put together aus executive management team 5 which is made up of Dan Keuter, his deputy Jim Shetler, 6 Paul Turner of the nuclear staff, and then John Rivera who 7 works directly for me as part of corporate services to make 8 sure that our district objectives are met. And we have 9 basically an overall task force that has a number of 10L elements assigned to it. One specific item at the bottom 11 under plant closure Dan will cover in more detail.
'12 I would like to make one other comment which does
.13 not show on this chart. But one of the things that we have
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h 14 done and just have begun recently is one key elements like
- LS - the emergency preparedness plan, we are bringing in what we 16 call peer reviews which is basically industry people as well 17 as other knowledgeable management staff to take a look at 18 what we are doing to make sure that we have not forgotten 19 something or that we can do something better.
20 So that is an ongoing program that we will be 21 using as we move through closure to make sure that we are as 22 fine tuned as we can be on the kind of approach that we are 23 taking on particular issues. We had our first review about 24 a week ago and I feel that it was very productive. So we 25 will be using that throughout this entire process. I sc L Heritage Reporting Corporation W (202) 628-4888
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- 1. I would like to spend just a moment on v 2 divestiture since that is an issue that you obviously are 3 aware of and that we have to deal with. Fundamentally our 4 position and very clea'ly r stated in the board resolution is 5 that I have the responsibility for ensuring that the plant 6 is closed safely.
7 Up until last week, we continued in that closure 8 mode. And as a result of a recommendation by Golden State 9 Energy formerly called Quadrex, we have delayed until 10 September 8th further closure activities, specifically 1:L detention at the head. That was done after a check was 12 received by Golden State Energy to provide reimbursement to 13 SMUD for any loss dollars during that period of time to
/TS ti,j 14 allow for further possible-divestiture action and in order 15 to avoid having any cost to our rate payers of a delay.
16 The bottom line at this point in time is that we 17 basically have until this Friday to negotiate with Golden 18 -State Energy for two agreements. One is a power sales 19 contract which would obviously determine how much power and 20 at what price SMUD is going to pay, as well as an asset 21 transfer agreement or an asset sale agreement which would 22 actually be the sale of the Ranch. 23 The reason for that timing is that we have been 24 advised by Golden State that they do not feel that they can 25 continue on at least at this point in time if they do not Heritage Reporting Corporation (^) (202) 628-4688
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. t 13 A 1 'have the vote of the people by December. So we are using g
2- this next Friday as that target date because the board 3 . meeting would be the following Thursday on September 7th and 4: all-of our documents have to be out by Friday. 5 So as you can tell, we are on a very aggressive 6 schedule on divestiture and we will keep you posted'as time 7 goes on that particular issue. Right now we do not plan to 8 go beyond September 8th as far as any delay in closure 9 unless'there is another specific action by our board of 10 directors and funds provided by Golden State Energy. 11 DR. MURLEY: Let me see if I understand this, the 12 board has to decide by Friday whether to call a special 13 election.in December?
*7) 14 MR. BOGGS: Actually they do not have to. The
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15 feeling was, as we understand it from Golden State, we 16 originally were targeting for a November election and we 1 17 have missed those deadlines. There is a timing requirement 18 of getting the registration of votes. Golden State had 19 indicated that if we go beyond roughly December 12th that it 20 will be very difficult for them to proceed with this 21 process. In order to meet that time line, we feel that 22 Friday is really -- it is actually September 7th but Friday ] 23 is when we have to send the material to the board. So 24 Friday would be the target date to wrap up the draft 25 memoranda of understanding with Golden State. 1 Heritage Reporting Corporation
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"" Now the board has indicated that really we are 1_
2 not on any timing situation whatsoever. They have allowed 3 staff to take as much time as necessary. But in order to 4 try to cooperate with Golde,n State, they feel that we need 5 to obviously get those agreements agreed to as quickly as 6 possible. So September 1st is really a key date followed by 7 a board action on September 7th. 8 I might also add, Dr. Murley, that there is 9 actually no requirement that we could find that the voters 10 would in fact have to approve this action. However, our 11 board of directors has clearly stated that they will not in 12 any way divest this plant without a further vote of the 13 people, whatever that vote might be. rm
' '! 14 DR. MURLEY: In the meantime, you are maintaining 15 the plant in a certain condition you are saying being 16 reimbursed I gather by Golden State?
17 MR. BOGGS: That is correct. The first action ~ V< 18 was last Thursday which ended up in a payment to us for 19 delay in the detention of the head which we planned to 20 proceed between August 28th and the 30th. That is now 21 delayed until at least September 8th. 22 DR. MURLEY: Now do I understand that the board 23 is willing to proceed on this kind of a basis for awhile, 24 but that of course Golden State has I guess certain limits. 25 I am just trying to understand how long this can go on or l Heritage Reporting Corporation ({} (202) 628-4888 e A- - _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l l 15 - CN q ;+' 1 might go on. 2 MR. BOGGS: My personal view is not very long. 3 And the reason for that as the board has made very clear in 4 discussion at the board meeting when they actually delayed 5 the action last week until September 8th is that they wanted 6 to get on with the program and that Golden State had the 7 responsibility to come forward very quickly to get this 8 issue dealt with. So I do,not believe that this will be a 9 prolonged situation. I think that it will be handled very 10 quickly. 11 MR. KEUTER: I think that the longest it would be 12 would be September 21st which is when the agreement with 13 Golden State runs out to negotiate with them. 14 MR. BOGGS: Right. We are basically on an 15 exclusive negotiation path only with Golden State at this 16 point in time, but we do expect the issue to be resolved 17 either positively or negatively fairly quickly. 18 DR. MURLEY: Okay. 19 MR. BOGGS: And again without a further action by 20 our board on September 7th, we would then begin detention of 21 the head shortly after September 8th without some definitive 22 action by the board. 23 The next slight that I really will not even spend 24 any time on basically lays out some divestiture projections, 25 and obviously the bottom line is February 1, 1990 receipt of
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16 I 1 license transfer is obviously an item. I' am concerned that 2 date is probably overly optimistic. But on this particular 3 chart, it does indicate the December 12th potential of a 4 public vote. , 5 Now there is no requirement again for that to be 6 on December 12th, but I believe that it is really an 7 economic issue rather than a timing issue. So on Golden 8 State's part, they would like to have it done by 9 December 12th. 10 MR. KEUTER: I would like to point out'that in 11 the second to the last line is an error. It should be after 12 12/13 after the election results. 13 MR. REYNOLDS: Could you define a little more 14 what you mean by assume responsibilities for the o eratione
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15 under that same line? 16 MR. BOGGS: Well, quite frankly that is exactly 17 what is being negotiated while we sit here. There was 18 discussion held with the board on whether or not that meant 19 that Golden State would assume operating under our license 20 which obvious ~f we would have to work out the arrangements 21 with you. And frankly that is not clearly defined at this 22 point in time. That is still one of a number of the issues 23 that have to be negotiated obviously subject to NRC 24 approval. So we are really not prepared to deal with that 25 until we have completed the negotiations, again subject to 7 Heritage Reporting Corporation 3 (202) 628-4888
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1 your approval. 2 So we are moving on the parallel tracks of both l l
- 3. closure and divestiture. And I feel very confident that 4 staff is handling it e'tremely x well. We do view at this 5 point in time that it has caused us any difficulty 6 whatsoever. But we have from the beginning until last week 7 very clearly headed towards closure and;we have now delayed 8 that "wo weeks.
9 Regardless of the option whether it be closure or 10 divestiture we as we have in the past and I think that our 11 track record clearly speaks for itself do intend to have a 12 very safe operation regardless again of whichever we pursue 13 whether it be closure of divestiture.
? 14 In summary on the introduction, the bottom line
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15 is that I am absolutely confident both for myself and for 16 the board of directors that an adequate budget dill be . 17 provided for closure or adjusted as divestiture may take 18 place. All licensing and regulatory requirements will be 19 met whether those are current requirements or whether they 20 are modified through the process that we proceed with you 21 on. 22 We will maintain trained and qualified staff. We 23 will obviously supplement that with contract staff if that 24 is what it takes to do that, but I am confident that we will 25 keep most of our key people. There may be some issue with 4% Heritage Reporting Corporation
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i 18 0 1 that, but we think that the retention program has helped us 2 with that, and we will close the staff safely. 3 And with that, I would like to turn it over to
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4 Dan Keuter to get into more detail on plant closure. Yes. 5 DR MURLEY: A few questions on this, Dave. 6 When do you expect to develop your 1990 budget? 7 MR. BOGGS: Dr. Murley, the current estimate of 8 the 1990 budget which has already been submitted to our 9 budget staff is $50 million and the preliminary numbers are 10 in right now. We will begin within about two weeks the 11 detailed review which will be with Dan and myself, and then 12 about two weeks after that near the end of September we will 13 be going over those budgets with the board of directors. O0
'1 14 I might add that just recently as a district I 15 made a presentation to the board at their request regarding 16 where we are as far as finances within the district. And 17 one of the things that I am obviously cautious about is not 18 cutting nuclear or any other expenditures beyond where they 19 should be cut.
20 We have had an extensive cost containment program 21 going into every department within the organization 22 excluding nuclear to determine exactly what we feel our 23 right size staffing should be in those departments. And the 24 only reason that I mention that is we have in my opinion 25 done an excellent job in coming up with what we think the Heritage Reporting Corporation (f) (202) 628-4888
19 Ibh 1 organization should be. And while we will look in depth at 2 nuclear, I cannot guarantee that there will be any changes 3 to.the budget, but 't will Le done in a very professional 4 manner and with the inhent.of meeting all requirements. 5 And I do not see just an arbitrary reduction of 6 that budget just to handle rate situations which perhaps has 7 been done in the past, although I believe that our board has 8 always met all commitments on the nuclear side. But.we have 9 a full cost containment program on the nori-nuclear side. 10 And basically those numbers amount to a significant 11 reduction from 1987, so we are already doing some other 12 actions that are budgetary kinds of actions that do not 13 affect nuclear but that help the district which is my h
! 14 message.
15 DR. MURLEY: Okay. Were you going to talk later 16 on at all about possible plans for decommissioning? 17 MR. BOGGS: Yes, I believe we are going to cover 18 that. 19 DR. MURLEY: Okay. 20 MR. BOGGS: Is there anything else that you would 21 like to cover before we move on? 22 MR. KALMAN: I wanted to ask about some of your 23 long term modifications that are in progress, I do not know 24 whether Dan will cover that later, but things like your 25 simulator building, and you were putting in a, third feed Heritage Reporting Corporation f}c
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- 20 1 pump,)and you had some upgrades on your main feed pumps.
2 . I would imagine that you are not doing those 3 things right now, but is it possible that you have lost a 4 window'to complete tho'e s things to meet future requirements 5 in anticipation of' continued operations? 6 MR..KEUTER: Obviously if we go through closure 7 and decommissioning, we do not need to make the 8 modificat' ions to the main feed pumps and auxiliary feed 9 pumps, those modifications. And those modifications have 10 been put on hold. We have gone through a very stringent 11 process of taking those designs that were in progress and 12 putting them in what I will say is a layup condition. We 13 have made sure that all of the documentation was there and 14 all of the two day current' engineering work was put together () : 15 in a package and stored. 16 That way if there is a divestiture in the future 17 then we can pull those designs off the shelf, complete the 18 designs, and therefore complete the modifications. But the 19 majority of the design work that was in progress has been 20 put on hold, but there is still some design work going on 21 namely in effluents, security, and radioactive waste which 22 will continue through the decommissioning procesa. 23 But things as far as reactor vessel level 24 indication, reactor pump modifications, ox feed pump 25 modifications, main feed pump modifications, they have all c; Heritage Reporting Corporation l gj) (202) 628-4888 _____. ______._m _ _ _ _ . _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ . _ _ . . _ _ _ _ _ _ _ - _
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*q . ;- 1 been put on hold.
2 MR. KALMAN: How about the simulator building, is 3 there a deadline that you have to meet? 4 MR. KEUTER: The simulator building we have gone 5 back to the contractor in charge of that building and we 6 have negotiated a closure where they come in and completely 7 close up the building, make it weatherproof, and put all of 8 the excavation on the exterior in place. .But bhsically on 9 the inside they are going to take power up to the main 10 terminal boxes and complete the work on the equipment that 11 they have already bought. But other than that, they are 12 going to seal it up and mothball that building. 13 MR. KALMAN: In case that divestiture is not
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14 successful, istherenota~requirementthat#founeedtohave
.s 15 a simulator by 1991 sometime?
16 MR. KEUTER: That is correct. 17 MR. KALMAN: Laying it up now, are you precluding 18 completion on time? 19 MR. KEUTER: We have the simulator contract too 20 with CAE which we have recently negotiated a contract on 21 that where CAE has taken the simulator and put it on hold 22 until the end of the year where SMUD will recoup 23 $2 million for putting it on hold if we never complete that 24 simulator. Whoever buys the plant has an option of going 25 back to CAE and renegotiating that contract and completing Heritage Reporting Corporation ([ (202) 628-4888
___ _ _ _ _ _ _ = - _ __ _. -- . _ - _ _ _ _ _ _ - _ - - _ k 22 1 the simulator. There is nothing that is going to be done on 2 the simulator that is irreversible. It will be maintained 3 as is until December. 4 I will be h'o nest with you. That if we do go 5 through divestiture to complete the simulator within the
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6 proposed original time frame that it would be extremely 7 difficult, not impossible but difficult-.
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8 MR. KALMAN: But on the schedule that you were on 9 before it would have possible to finish it on time? 10 MR. KEUTER: It would have been possible? 11 MR. KALMAN: Yes, on the previous schedule. 12 MR. KEUTER: Yes. 13 MR. BOGGS: Until closure took place, that is 14 right. 15 MR. KEUTER: Until the election took place, we 16 were on schedule and we were going to meet that original 17 commitment date. 18 MR. KALMAN: I am sorry if I broke it. 19 MR. BOGGS: That is fine. 20 MR. KEUTER: No, that is fine. 21 MR. BOGGS: With that I could like to turn it 22 over to Dan Keuter, our assistant general manager for 23 nuclear, who will give a more detailed update on the closure 24 of the plant. 25 MR. KEUTER: The main areas I am going to be Heritage Reporting Corporation p) u (202) 628-4888
23 (-)3 covering is the Rancho Seco closure process, an overview'of-1 2 that; 'and our long range schedule, an overview of that; and 3 some of the action plans that we are going to be going 4 through'after closure.' . 5 We have seen this slide before. You see.this 6 first box here where it says plant closure, that is where 7 most of I will say the closure action plans feed into our i 8 closure process. This is a corporate overview that Dave is 9 in charge of, and on site we feed into here.in the box 10 called plant closure. 11 On site we have a closure process. The tcp box 12 is where we feed into the corporate closure. But down in 13 the y-UN 14 left-hand corner we have developed action plans for some of 15 the majority activities that we have to do. For example, to 16 request a defueling mode is an action plan. Most of these
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17- action plans are listed here. But it goes into great detail 18 of the activities that we have to complete to complete our 19 closure process. 20 These are reviewed on site by a plant closure 21 task team. These are the main managers' operations, 22 maintenance, radiation protection, chemistry. They go 23 through these closure plans and approve those closure plans. 24 Then they are put into our integrated plant schedule so that 25 we make sure that we track these actions and put them right () Heritage Reporting Corporation (202) 628-4888
9 24 g
' 1 into our day to day activities.
2 So the process here is that we identify the 3 action plans that we need, develop the action plans with 4 schedules, and then turn that into our day to day plant 5 schedule for implementation. 6 This is a somewhat complicated looking long range 7 schedule. Mainly I want to make the point here that we have 8 taken these action plans, and have integrated them together 9 into a Icng range schedule. The top shows a shutdown layup 10 which we have completed. The next major activity under that 11 is a possession only license amendment which we are in the 12 process of developing. We are also going to be 13 renegotiating our commitments that we have. Obviously some
!-) 14 of the commitments are not'needed any more if we truly go 15 through a complete closure of such things as reactor vessel 16 level indication.
17 Below that is a cold shutdown which has been 18 completed. We are almost completed our fuel handling 19 equipment. Before the election we had shipped off our main 20 fuel handling equipment to B&W for refurbishment and 21 upgrade. That upgrade is almost complete. In September we 22 will be going through a testing program testing that fuel 23 handling equipment. And in parallel with that, we will go 24 through and start detention in the head. 25 In October we will go through a core offload. We Heritage Reporting Corporation I c}- (202) 628-4888 1 l
25
.(b)
In 1 will complete' core' offload by the end of October. 2 parallel'with that also we are performing a long term layup 3 analysis of our systems. Currently our systems are in what j 4 I will say are refueling mode operations. When we went 5 through shutdown, we just followed our procedures for 6 shutdown, and laid up our systems per refueling mode 7 operations, and that is where the systems are currently. 8 And they are all being maintained in a refueling outage type 9 shutdown. These long term layups -- 10 MR. PARTLOW: Excuse me, that means they are 11 being maintained as though you are anticipating restarting 12 in the short term, is that right? 13 MR. KEUTER: That is correct. Like I said, we
) 14 have a current license and'we are following that current 15 license, and we are following our current procedures. It is 16 just like we are in a refueling mode. Some of the things 17 that we have not been doing is our long range surveillance, 18 our refueling interval surveillance. That if we do not 19 start up, it would not be required. But all of our day to 20 day procedures and our day to day operations we are 21 conducting those just like we are in a refueling mode.
22 These layup plans here for example some of our 23 systems are being maintained in a wet layup condition, for 24 example steam generators. We are going through an analysis 25 of what we do for a twenty year period and how we would lay Heritage Reporting Corporation f' ) (202) 628-4888
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26 h # 1 them up for twenty years. And most of those layup: vould be ) 1 2 a dry layup condition, and we are going through an a.nalysis 3 now of how we would lay them up 1cng term versus refueling 4 term intervals. . ;
)
5 MR. REYNOLDS: Dan, just to jump'in here, some of 6 your requirements, your ISI requirements, that require 7 detensioning the head, what are your plans for those, 8 because I know that they are due in just a matter of a 9 couple of weeks, or do you plan on addressing that later on? 10 MR. KEUTER: Well, for example, the one that you 11 may be referring to is our internal vent valve? 12 MR. REYNOLDS: We have the reactor vessel vent 13 valve. I guess that is due the end of October. But you r, i 14 have seven ISI inspections that will be due on 15 September 18th I believe. 16 MR. KEUTER: Right now we have an action plan for 17 in service inspection and in service testing. But our in 18 vessel reactoi vessel inspections, we are looking at those 19 to see which ones if we.do go through closure we would have 20 to complete versus the ones that if se restart obviously we 21 would have to go through and complete those or request some 22 type of waiver. 23 MR. REYNOLDS: If you are not going to do them, 24 are you planning to request before the 18th? 25 MR. KEUTER: Pardon me.
<$)
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4 y , < 1.1 27 c .eg l \ I kb$ - ll MR. REYNOLDS: If you are not going to do them,- 2' are you. planning to get some request into the NRC before the 3 lath? - 1 MR. KEUTER:" Well, right now we are geared for l S. closure. And if it looks like we-are going to go through a
- 6. restart, yes, we would have to.-
7 MR. KALMAN: At this stage you would have;to talk 8 to us and get relief no. matter what because you still have a 9 license and the requirements. You would have to take some , 10 kind of action to get relief. 11 MR. CRUNK: We intend to submit.that request, 12 yes. 13 MR. REYNOLDS: Thanks.
' i 14 MR. KEUTER: Down before that, we get into our 15 decommissioning plan. Right now we are looking at'possibly 16 submitting the decommissioning plan to'the NRC for approval 17 next year. And then this shows where we actually go through 18 a decommissioning which is a disassembly of.the plant. -And 19 that starts somewhere around the year 2008 and 2009.
20 The next slide gives you an idea of the action 21 plans that we have developed and the variety of things that 22 we are looking at to ensure that we comply with all 23 regulations. The ones with the asterisks are the ones that 24 we are planning on talking a little bit more in detail on. 25 If there are any questions about the other ones, we can
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I 28 f ug # 1 raddres's those too. But for right now, the ones with the-2 asterisks are the ones that we are going to give you 3 somewhat of a briefing today on. 4 Some of the' action plans that I was going to 5 discuss today is give an overview of the organization of the-6 staffing, where we currently are on our offload of the 7 reactor core and our system layup and operability that we 8 are currently in. 9' The first thing after.the election that we had to 10 address, like Mr. Boggs said, was our organization to ensure 11 that we had adequate resources and staffing to maintain the
-12 plant and go through a decommissioning process. This is'our 13 organization before the election. Joe Firlit was the CEO r% Coming down he had four main reports to him. The
/ 14 nuclear.
15 AGM technical services, the AGM nuclear quality and 16 industrial safety, myself nuclear plant manager, and 17 Paul Caudill who is nuclear plant support. Also he had an 18 AGM special projects which was Jim Shetler who had human 19 resources. 20 We were already working on a contingency plan in 21 case the election did shut down the plant. That contingency 22 plan was fully developed and that is probably why we are 23 really where we are today in the transition very smoothly. , 24 It is because we had that contingency plan and just i 25 implemented that the day after the election. What we have *
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ________________.________ _ ___ 1 ________
1 9{\ M L 29 h~ > l' triedLto maintain is a very similar organization. We did 2 not go through a-major reorganization or a major transition 3' of managers.- 4 MR. REYNOLDS: Before you go'on, could you.just 5 for everybody's benefit say:who-is'still at Rancho and who 6 is gone? 7 MR. KEUTER: Okay. If.you lock at the asterisks, 8 those are all of the managers that were here before the 9' election that are still here. As you can see from this, 10 there are only four people who have left. Like Dave said, 11 of our 25 what I will call management team, 20 are still
.12 here. And for the most part other than filling in for the 13 people who have left, the five people who have left, they sh Q.! 14 are in the same positions. So essentially we have the same 15 management team that we had before with the exception of 16 Joe Firlit, Bob Croley, John Vinquist, and Paul Caudill.
17 The other person who left was Lee Fosom who was my assistant 18 plant manager. 19 MR. REYNOLDS: Okay. 20 MR. KEUTER: So we pretty much have the same 21 management team in place. 22 MR. REYNOLDS: Thank you. 23 MR. KEUTER: And pretty much the same 24 organization. The current organization is very similar to 25 the previous organization. What we have done is instead of Heritage Reporting Corporation
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Y I? 30 () , 1 having the CEO nuclear, we have gone down one tier and we 2 have an AGM nuclear. Instead of AGM nuclear plant, we have 3 manager nuclear plant. So we have just taken everything 4 down one level. The AGM nuclear fulfills the te'ch spec 5 functions of both the CEO nuclear and the AGM nuclear power 6 production, fulfilling both roles per our tech specs. 7 The previous nuclear plant manager duties which I 8 have filled have been split between two people, the manager 9 nuclear plant and the manager nuclear maintenance. So to 10 even out the work load we have split those two. 11 And the next slide shows our current 12 organization. As you can see, it is very similar with the 13 differences that I just mentioned. Some of the other 14 differences where I have an engineering group under the 15 plant manager, we have combined all engineering functions 16 into one area under management of technical service Warren Plant performance which was our system engineering 17 Peabody. 18 group which was under the plant manager before is now 19 combined. One of the main reasons is that we are not doing 20 a lot of design changes right now and we want to combine 21 resources there. 22 MR. REYNOLDS: And all of these people on this j 23 chart here were previous employees prior to the 24 June 6th vote, correct? 25 MR. KEUTER: That is correct. In fact they were Heritage Reporting Corporation () (202) 628-4888
h 4 b -.:. . 31.
- , k , 1 .all'in management positions before the. vote I'believe also.
GL Some of the other minor changes-are materials 3 which'is in'the warehouse function which'used'to be under 4- technical services. It'haa moved over to' nuclear 5- maintenance.- And licensing. and environmental monitoring, 6 unnd emergency ~ preparedness which.used t'o be under technical 7 now is under the deputy AGM. But.as you can see, it is a 8 very similar organization with almost'all'of the same 9 people. 10 You had some questions' earlier about our 11 . staffing. The black'line was an original what I will say 12 estimate as far as staffing. requirements. This pretty much 13 came out of contingency. plan that we had developed before C), 14 the election. The lower line is what we are projecting are a: . 15 our resources.- The main reason that the bottom line is 16 lower is that we have improved our schedule on defueling 17 from four to six weeks. If you slide that line over about 18 four to six weeks, it would match up pretty good. So we 19 pretty much maintain our staffing. We have not had a 20 problem on retaining staff currently. 21 DR. MURLEY: Excuse me a second. If the level 22 that you show at the beginning of 1990 anticipated to remain 23 relatively level? 24 MR. KEUTER: That shows 600 people. The blue 25 line is SMUD employees. But it comes down to about 450 SMUD
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H 32 1 employees. What I am anticipating in 1990 is we will start 2 the year.off somewhere around 400 people. and end the year 3 between 200 and 300 people. It depends on where'our 4 decommissioning plan takes us as far as resources. 5 DR. MURLEY: Okay. So you'are cutting roughly in 6 half say from 450 at the end of the year cn: the beginning of' 7 1990 to 250 or.something like that? 8 MR. KEUTER: To the end of 1990, yes, that is 9 correct. 10 MR. BOGGS: We are still working on that 1 11 obviously, but we do not have the details of that yet. 12 MR. KEUTER: What I am saying is just our feeling 13 right now and we have not fully developed it. I will be f% N ? 14 honest with you, some of the things that affect our staff is 15 how readily they can get the decommissioning plan approved, 1 16- our security plan approved, or E plan approved. All of 17 those things affect resources. If for any reason we are 18 held up, we will maintain whatever staff it is to maintain 19 the current requirements. But I would say that at the end 20 of 1990 that we are looking at between 200 and 300 people. 21 DR. MURLEY: I looked at one schedule which 22 showed that you are not anticipating a license change for 23 about two years, is that right? 24 MR. KEUTER: That is true. One of the main 25 things that is driving our resources right now would be our Heritage Reporting Corporation
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33 1 security plan approval which we are hoping to get approved , 2 next year, and our emergency plan for defuel plant approval l i 3 are the two main things that would affect staff next year. 4 DR. MURLEY: The tech specs changed and 5 possession only you are contemplating June of 1992, is that 6 correct? 7 MR. CRUNK: No, that is a late approval date. 8 That is what we are looking at there. 9 DR. MURLEY: I am just looking at your calendar. 10 MR. CRUNK: I understand. We have got a little 11 more detail in terms of when we expect these submittals to 12 come. But in terms of possession only supposing that the 13 divestiture effort does not go through that will come out ( 14 early in the year, probably around the January time frame. 15 So we will be ready to submit that application if 16 divestiture fails. This long line here is just the process 17 actually. Maybe more clearly worded it should be 18 application and receipt of possession only. It includes the 19 review time. 20 MR. PARTLOW: You are paying that the ball is l 21 going to be in our court for that whole period, is that what 22 you are saying? 23 MR. CRUNK: We are just giving you that much 24 time. We do not know how long it is going to take you, I 25 guess is what it boils down to, to approve that. And I know Heritage Reporting Corporation (. ) (202) 628-4888 l
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"'G 1 that a lot of it is contingent on the review of the '
- 2. decommissioning plan as well. So we just put a long time 3- frame in for that particular item.
.4 MR. BOGGS: 'This was intended as a level of 5 magnitude just to show ball park.
6 MR. REYNOLDS: And your staffing reductions would 7 be based on if we grant you any relief from some of the 8 requirements?. 9 MR. CRUNK: Absolutely. 10 MR. REYNOLDS: It would not be prior to any of 11 that stuff? 12 MR. CRUNK: Absolutely. 13 MR. KEUTER: That is correct.
') 14 MR. CRUNK: There is an intermediate license 15 changes that we are going to talk about a little bit later 16 when we get into the regulatory part of our discussions that 17 I think will answer some of that question as well too.
18 MR. REYNOLDS: All right. 19 MR. KEUTER: Some of our success in retaining 20 staff is mainly two things. One of the first things I did 21 was implement a retention program where I went through and 22 identified the resource requirements for the future. And 23 the criteria that I used is if we got into a real problem as 24 far as staffing that my two fall back areas in my i 25 contingency plan is to utilize contractors which would be Heritage Reporting Corporation
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i 4 35 1- more expensive and utilize overtime. )i 2 So I went through and identified those areas 3 where it would be very difficult to use contractors and/or
.- i 4 overtime. Those areas'were mainly management where I have 5 contracts or retention agreements with practically a whole 6 management team. That includes approximately twenty people.
7 Additionally the operations department,_anybody in the B operations department that has a RO license, SO license, or 9 STA qualified, we have retention agreements with those. 10 And then we have approximately ten to twenty 11 retention agreements with what I will call technical people 12 which includes engineering personnel, radiation protection, 13 and chemistry who have expertise that would be very q }'; 14 difficult to get a contractor person in, and we have set up 15 retention agreements with those. 16 These retention agreements what they are for 17 management personnel is a contract that they will stay for a 10 period of time, and those periods of time depend on how long 19 we need them. For example, we need a licensing manager for 20 a long period of time, and the licensing manager signed a 21 contract for three years because that is about how long it 22 is going to take us to get through our decommissioning plan, 23 our license changes and those types of requirements. And 24 for that period of time, it would be very difficult to 25 utilize contractors. So we have contracts with most of the g Heritage Reporting Corporation t.ty (202) 628-4888
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- l 36 1 management personnel.
2 The operations personnel, the retention agreement 3 that we have with them is that if they are laid off they get 4 six months of pay. Th'refore e if they resign, they do not 5 get that. So what we are guaranteeing them is if they are 6 laid off that they get six months of salary, plus when they 7 are at the plant they maintain their current salary and any 8 what I will call cost of living increases. So they are 9 guaranteed a job. If they laid off, they do get a sizable 10 severance package. - 11 For most of our technical people it varies, but 12 what we have guaranteed them is at least a voluntary program 13 which I will get into and to maintain their current r.
) 14 salaries. We have been very successful in this program.
15 Almost everybody has with one exception accepted the program 16 and still is with us. 17 MR. PARTLOW: Give me it again, what is the 18 incentive for the operators to stay? 19 MR. KEUTER: Basically the licensed operators are 20 guaranteed a job at their current salaries. If they are 21 laid off, they get six months salary. So basically they get 22 a severance, a six months severance package. So their main 23 concern right now as far as leaving would be job security. 24 And what we are saying is we will guarantee you a job, and 25 is worse comes to worse you will get a sizable severance fg3 Heritage Reporting Corporation
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4 37 1 package, and that has been acceptable to most of the 2 licensed operators. I will get into where we are with 3 technical people and key personnel here and where we would 4 get to what I would' consider a problem. 5 The other thing is the voluntary separation 6 package. It.is a doubla-edged sword here. It is a r 7 severance package to our employees who will be leaving, so 8 it will make it easier for them to find a job. But it has 9 also had the benefit that it guarantees that I maintain 10 people at the site as long as I need them. 11 For example # if I need an engineer to stay at the 12 plant to maintain his system, that he is a system expert on 13 say the decay heat system, and I want him to stay at the
') 14 plant until the decay heat' system is no longer required, 15 then what I have done is that I have set up a voluntary 16 separation package saying I will give you twelve weeks of 17 pay plus one week for every year that you have been here if 18 you stay at the plant until you are laid off.
19 So what this does is that it motivates the people 20 to stay at the plant as long as they are required, because 21 if they leave before their separation date then they do not 22 get the severance package. So that has been very 23 successful. The positions that have been identified for 24 future layoffs have been like 400 people at the site. And 25 we are down to say nine people who have not accepted that Heritage Reporting Corporation
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38 ($) < 1 program. 2 And therefore what it does is that it guarantees 3 that I have staff as long as I need them. Plus when they l 4 are not needed any more, it gives them a nice severance 5 package. And that has been a very successful program. l 6 On the next page, I was going to go into a little 7 bit more detail in what I call the key positions. And I 8 will give you the current status as of where we are going to 9 be around September 1st. Like I said, senior management 10 before the vote, we had twenty-five people. Currently we 11 have twenty, and we do have agreements with those twenty 12 people. And I did review the people that we have lost. 13 MR. KALMAN: But those are not the twenty cf the 14 twenty-five that you had originally? 15 MR. KEUTER: Yes, they are. 16 MR. KALMAN: The same individuals? 17 MR. KEUTER: The same individuals. 16 In operations, we have broken this down. We 19 had twenty-nine senior reactor operators before the 20 election, and currently we have twenty-three, plus we have 21 seven coming out of SRO class in September. Reactor 22 operators, we had twenty-four before the election, and we 23 have nineteen currently, plus we have another seven coming 24 out in September. 25 Non-licensed operators, we had twenty-seven and g3 Heritage Reporting Corporation
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I c i . 39 O 1 we have thirty-one now. Some operators had been hired 2 before the election that showed up on site after the l 3 election. So we are actually increased in that area. l 4 The other thing as far as tech spec requirements, 5 our tech spec requirements are far as licenses on shift are < 6 two ROs and two SROs for an operating plant, and we have 7 five crews and so that is twenty people, and that is for 8 operating mode. And what I call the refueling mode or cold 9 shutdown mode, we require one RO and one SRO times five is l 10 ten. So you can see that we have approximately fifty some 11 licenses, and before we really get closed we would have to 12 get down to ten. 13 I would probably implement some type of
? %.
J 14 contingency plan when we get to the range of less than 15 thirty, twenty to thirty people. If we got down that close 16 at that point, I would probably come through with some other 17 type of' retention program to retain licenses. But as you 18 can see, we were doing very well on retaining our people. 19 MR. REYNOLDS: The two operators who just quit, 20 did they accept the retention package or they did not accept 21 it? 22 MR. KEUTER: If they quit now, they do not get 23 any type of severance packege. 24 MR. REYNOLDS: I just wondered if they had 25 accepted it and then decided not to accept it and quit, do Heritage Reporting Corporation l}' (202) 628-4888 e
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'N# 1 you know of the'two who just quit that you notified us of? s
-2 MR. KEUTER: The two that we notified you they.
l 3 did not leave voluntarily. 4 MR. REYNOLDS: O) cay. - 5 MR. BOGGS: So they did not get the package. 6 MR. REYNOLDS: Okay.
.7 MR. KEUTER: It was at our request.
8 MR. REYNOLDS: Okay. 9 MR. KEUTER: So, we did lose two, but that was at 10 our request. 11 MR. REYNOLDS: Okay. 12 MR. KEUTER: Radiation protection technicians, 13 before the election we had 29; currently, we have 25. Our 14 contingency plan there is if we did lose too many, that we
}
15 could utilize contract radiation protection technicians, or 16 overtime. 17 Our current overtime is very low.' It's in the 18 range of 2 to 3 percent, and that includes our built-in 19 overtime on our shift schedules of 5 percent. So basically, 20 currently we are not working any overtime except for some 21 critical path work. 22 Chemistry technicians, we've gone from eight to 23 five.
.24 In maintenance, basically you can see the numbers there, but 25 we have laid off approximately one-third of our maintenance g; Heritage Reporting Corporation i (202) 628-4888 e
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'O. 1. personnel; mainly due to the fact that there is just less 2 maintenance to do, less work to do.
3 These people that we did lay off were people we 4 offered packages to, ekeept that there wasn't enough work to 5 keep them busy. So this is more -- where we didn't need 6 them other than -- they didn't actually leave before we 7 wanted them to. 8 Engineers, we've gone from 91 to 60. The main 9 reason there is we're just not doing much design work at 10 this time. The 60 are mainly working.on layup plans, 11 putting the design packages that were in the process, 12 putting those them into a condition that we can store those 13 so that they could be retrievable. 14 But the main reason we're down there is our own
~J 15 design, because we're just not doing any design work.
16 Quality and safety, that is still very intense, 17 and we're maintaining almost our whole current staff there. 18 Licensing, most of the work right now is in 19 licensing, so we've retained a staff there. 20 Environmental monitoring and emergency 21 preparedness, we have gone down to nine people there. We 22 are anticipating some type of waiver as far as our December 23 drill. If divestiture did go through, we'd probably have to 24 do some restaffing in that area before start up. 25 Security department is pretty much the same. 4 Heritage Reporting Corporation 1 (202) 628-4888
42 m EON 1 So, as you can see as far as key personnel, we've 2 been very, very successful in retaining our koy personnel.
-3 The people that have left are people where we just didn't 4 have the work to keep them busy.
'S MR. .KALMAN: Dan, in your liquid effluent 6 program, we went through many years of negotiations with you 7 to' upgrade that whole -- the hardware and your procedures.
8 Are you still proceeding with those upgrades? 9 MR. KEUTER: Yes. Almost all of our capital-10 expenditures are in two afsac: security and liquid 11 effluents. All of our -- I could pretty much say that all 12 of the effluent-commitments we will need unless -- there are 13 some that we may not, we might ask to meet. For example,_we 14 had a lot of design work to make the tank farm, to go out rC.)h 15 there, pave that, put in new drain systems. 16 The way it looks now is most of those systems, if 17 not all of those systems out in the tank farm, are going to 18 be' drained. Therefore, it doesn't make sense to go out and 19 put in a whole new draining system to collect leakage of 20 systems that are going to be dry. 21 So those types of things we probably will request 22 that we do not meet those commitments. 23 But as far as the other, any systems that we are 24 going to be using, we will meet those commitments. But we 25 will be negotiating back and forth. 753 Heritage Reporting Corporation tE/ (202) 628-4888
r . -_- _-. _ . _ - _ _ - _ _ _ _ - _ - _ _ _ - _ - _ - - - __ 1- *y 43 0 1 MR. KALMAN: I guess we'11 talk about it later. 2 MR. KEUTER: Yes. 3 ~But, yes, some of those commitments, if it l-4 doesn't make sense to comp 1.ete, we won't, and we'll be , .5 talking to you about them. But right now most of our 6 effluents, we are planning on doing most of that work. And 7 we do.have capital money to. complete that work. 8 MR. PARTLOW: Other than the tech spec for 9 control room manning, in what way are you committed to the 10 NRC in terms of minimum staffing? 11 Does your FSAR include commitments? 12 MR. KEUTER: Well, it's mainly our E plan, our 13 security plan are two big commitments, and we do have a lot (D
"\ ! 14- of resource committed in them. Our USAR, I'm sure, 15 addressessomethlings.
16 MR. CRUNK: Yes. The real driving force is the 17 emergency plan. 18 MR. PARTLOW: Are STAS in here some place? 19 MR. KEUTER: Most of our STAS are licensed, and 20 they are included in the licensed group. And our STAS are 21 in a retention program, the same as the operators. So I 22 have grouped them in with the operators. 23 In your book there is some resumes, which I'm not 24 planning on covering, of some of our key management 25 personnel, and that's mainly for your information. You can Heritage Reporting Corporation th N (202) 628-4888
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1 review it, but I wasn't planning on covering them in detail. 2 MR. VIRGILIO: Dan, in your summary.of key staff, 3 you did not. touch on training. 4 Would you pleasa' discuss the training staff and b 5 the role of training in this phase of the operation? 6' . MR . KEUTER: Right now we are maintaining our 7 accreditation through the end.of the year. One of the 8 things that we are, if we go through closure, is get out of 9 a centralized training group, and put the training back into 10 the departments. 11 For example, there will.be some trainers in the 12 ~ maintenance department. There will be trainers in the 13 operations department. In fact, the trainers in the 14 operations department do have retention agreements, because 15 they do have licensed certificates. Training in the 16 radiation protection is going to be given back to the - 17 radiation protection department. Training in chemistry is 18 going to be done in the chemistry department. 19 So we are looking at a decentralized training 20 department, but that won't be implemented until next year 21 some time. 22 But, no, we have gone away from a centralized
'23 training department, or planning to. We haven't yet.
24 MR. VIRGILIO: How has the size of the training 25 department changed since the vote? Heritage Reporting Corporation [i} . (202) 628-4888
4 ( ^) 1 MR. KEUTER: It has gone down mainly because the 2 training department had a large percent -- it was our last 3 department -- did have a large percent of contractors in it, 4 in the training. , 5 We have retained all contract, you know, I said 6 something like 62 contractors still on site. I think 7 something like 10 to 15 of those are in. training that we 8 have maintained. So I would say our total training 9 department, we probably lost a third of those personnel. 10 If we did go to a divestiture, definitely that is 11 another area that we would have to go through some 12 restaffing on is in our training department. 13 MR. VIRGILIO: How many of your programs are
- 14 currently accredited?
15 MR. KEUTER: All of our programs are accredited. 16 MR. VIRGILIO: And do you intend to maintain that 17 through the end of the year? Is that what you said? 18 MR. BOGGS: Through the end of the year, yes. 19 MR. KEUTER: Yes. 20 One of the people I'm going to be talking to this 21 week is INPO, and that's one of the things we will be 22 talking to them about this week is our future training and 23 also accreditation, where we want accreditation. 24 But that plan is still being firmed up. But 25 right now it looks like we will next year, beginning of next
$3) Heritage Reporting Corporation (202) 628-4888 w__-______________
46 (h- 1 year possibly, not have accredited programs. We will go 1 2 back to a regulatory-based training program. So the 3 accreditation process is very, very labor intense, and I 4 think wherever the plant will be at that time, it's probably 5 better to take the training back into the departments. 6 MR. VIRGILIO: Thank you. 7 MR. KEUTER: The next area I,was going to cover 8 is our offload reactor core. I was mainly going to talk 9 about some of the major milestones. 10 The election was on the 6th. We shut down the 11 plant on June 7th; reached cold shutdown June 10th. July 12 12th, we had received back from B&W our main fuel bridge 13 trolley, and that was set inside the containment in July.
'} 14 We completed the main fuel bridge mechanical modifications 15 in August. There were several of the modifications that we
( 16 had to deal onsite. 17 We were originally, when we made this slide up, 18 going to begin detensioning the head on August 30th, and 19 remove the head on September lat. That's been delayed due 20 to last week's board meeting, until September 8th. 21 Reactor vessel offload will happen some time in 22 October, and reinstall the head probably some time the 23 beginning of November. 24 MR. REYNOLDS: Are you going to use extra 25 contractors to help you do the offload, or just use your rg Heritage Reporting Corporation QJ/ (202) 628-4888
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(Ih: 9 1 present staff? 2 MR. KEUTER: Head detensioning,'we have a 3 contract with B&W. They are going to come in and actually l 4 do the head detensioning. . 5 As far as fuel movement, it will be a combination 6 of B&W and SMUD. 7 MR. REYNOLDS: Thank you. 8 MR. KEUTER: But, up until last week, we were 9 probably four to six weeks ahead of schedule on core 10 offloads. 11 MR. REYNOLDS: Okay. 12 MR. KEUTER: Long-term layup, this was another 13 major area I was very concerned about. Where we're going
.' )% 14 with long-term layup, like I said, our systems are all 15 currently in a refueling mode layup. We follow the same 16 procedures we would if we went into refueling. Laid those 17 systems up in accordance with existing procedures.
18 Long-term layup is the next step. Where we go in 19 long term, it's a lot more difficult to maintain systems in 20 wet layup for 20 years than dry layup. So we are looking to 21 layup a lot of systems in a dry layup condition. 22 But we have identified systems required to be 23 operable. That's been completed. We identified PMs and 24 surveillance that will have to be maintained. We are 25 identifying systems for long-term layup. We developed Heritage Reporting Corporation (k) (202) 628-4888
! )
48 l' system layup plans which I'll show you an example in a 2 minute, which kind of integrates the layup, the PMs, the
'3 surveillance, how we're going to maintain those systems.
4 And those are being developed by the system engineers. 5 Develop and revise procedures, implement -- we'll 6 start implementing our long-term layup requirements around 7 the first of January. So'at that point.is when we start 8 getting out of what I'll call a refueling mode layup 9 condition into a long-term layup conditions. 10 MR. REYNOLDS: Are those systems you have 11 identified be operable, the one that when your -- your June 12 30th closure plan that you. submitted to us? 13 MR. KEUTER: I believe so. rq' E;' 14 MR. REYNOLDS: In there you had a memo signed by 15 Joe Firlit that identified systems you would maintain, a 16 cold setdown, and then the second part was where you were 17 . going to maintain after you defueled. 18 MR. KEUTER: That's correct. 19 MR. REYNOLDS: Is that still current? 20 MR. KEUTER: Yes, and that was the first one 21 here, identify systems prior to -- 22 MR. REYNOLDS: That's the systems? 23 MR. KEUTER: Yes. 24 MR. REYNOLDS: Okay, thank you. 25 MR. KEUTER: And then periodic inspection of [ I) Heritage Reporting Corporation * (202) 628-4888
I 49 1 systems on layup. These include visual checks, dewpoint 2 monitoring, chemistry evaluations. So those are still 3 maintainable, wet layup conditions.
-4 This slide here Aind of gives you what -- this H 5 isn't an actual example, or sample of one of the conditions.
6 As you can see, the cold shutdown and defueling is, however, 7 maintained in our main condensate makeup system. That's 8 what MCM stands for. It shows here how we maintain this 9 system, both operations and maintenance. 10 After we get into the defueling mode, and this 11 shows what we are going to do at that: point. And this will 12 be continued into a long-term layup. Probably in this 13 system most of it will be drained.
') 14 Some of the things that won't be drained are the 15 polishers, because they do have some seals, neoprene lining 16 inside that if they dry out, they will destroy those seals.
17 The vessels themselves will be in wet layup. Most of the 18 remaining systems will be in dry layup. 19 And this is just a sign off for every system. As 20 we design the plan, it's reviewed and approved by 21 operations, chemistry, licensing, technical service and 22 maintenance. So this is basically an integrated plan to 23 layup our systems, both in the short term and in the long 24 term. 25 MR. HOLAHAN: How would you describe the basic Heritage Reporting Corporation JN) u- (202) 628-4888
50 1 goal of the long-term layup program?- Laying them up with 2 what objective in mind? 3 That they could be used again, or what? 4 MR. KEUTER: Both. We're laying them up so they 5 could be used again, or could be sold. We are rotating the 6 major rotating elements to make sure they don't sit too long 7 in one spot. You can see that -- by hand rotating. 8 So if we get into a situation that we could 9 restart the plant, even under a long-term dry layup, or sell 10 the equipment again. So we are maintaining -- we are not 11 letting the equipment deteriorate. 12 MR. TAYLOR: Gary, you may recall that this was 13 one of the things that Miller's group has expressed an
- 14 interest in this issue. They also have that noted, to see 15 that the stuff is laid up right.
16 MR. HOLAHAN: Okay. 17 MR. KEUTER: We do have some experience in this 18 during our 27-month layup. 19 MR. KALMAN: Would you at this time pursue l i 20 selling some of the equipment to potential buyers? 21 MR. KEUTER: We have. One of our corporate l 22 action plan is asset recovery action plan, which looks at 23 doing that. Currently, we have not implemented that plan, 24 because we are still in negotiations for divestiture and 25 looking to sell the whole plant as a package.
' ?=
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'h - 1 If it doesn't look like divestiture is going to 2 work, we do havu an action plan being developed for asset 1
3 recovery, which would mean selling.off plant equipment both 4 in the-warehouse and in'the plant. 5 MR. KALMAN: And how soon would that possibly 6 take place? 7 HR. KEUTER: Some time next year when divestiture 8 is pretty much gone one way or the other. But there is an 9 actual plan to do that. 10 That concludes my part of the presentation. I 11 was going to let Steve go into some of the major licensing-12 closure action plans, unless there'is any other questions. 13 And if any questions come up, we can answer them at the end
#eml 14 also.
15 MR. CRUNK: Okay. What I'm going to talk about 16 are some of the, as Dan mentioned, the major licensing 17 action plans. We're going to talk about what we are calling 18 defueled mode tech specs, which is our interim step between 19 the existing tech specs and a possession-only amendment. 20 I'm going to talk about our decommissioning plan, the 21 emergency plan, security plan, how we're handling our review 22 of commitments and retrievability of those commitments. 23 Then finally I'm going to summarize what the various major 24 regulatory interplay between the district and the NRC is 25 going to be. l {$) Heritage Reporting Corporation (202) 628-4888
() " 1 VOICE: Are you going to talk about any financial 2 aspects to decommissioning? 3 MR. CRUNK: No. In reality, the financial 4 program is under review for submittal in July, I believe it 5 is, of next year, and those details are actually still being 6 worked on as to what the final description is going to be 7 that will be submitted. So I won't be discussing that 8 portion. 9 (Slide presentation.) 10 First of all, I'm going to talk about defuel mode 11 tech specs, and these are being developed to better 12 characterize the plant with all of the fuel located in the 13 spent fuel pool. 4 9 14 The scope of these particular specs are going to 15 be those systems then that are required to maintain the 16 integrity of the fuel in the pool. The reason for this 17 approach is actually twofold. 18 Number one, we believe by putting in one place 19 all of the technical specifications that deal with the fuel 20 in this condition, which if you were to go now into the 21 existing tech specs are kind of scattered out through 22 various sections, and is actually kind of an unclear state 23 in many respects since having all the fuel out of the vessel 24 is something that's only contemplated as a step perhaps in a 25 full vessel inspection or some other evolution involved in a
~)) Heritage Reporting Corporation (202) 628-4888
l 1 : 53
': refueling process.
1 2 We wanted to clarify that and make it possible 3 for operators to have all of those specs in one place, 4 easily referred to and' clearly describe the condition or 5 mode that we're talking about here as defueled. So we are, 6 in effect, proposing to add another operating mode to the 7 technical specifications and calling it.defuel. 8 The second benefit that this gives us is since by 9 our schedule, as we will see in a moment, we intend to 10 submit this about the middle of October. The cecond benefit
- 13. to this is that changing modes then is no different than 12 changing from say a regular refueling mode into our cold 13 shutdown, hot shutdown, et cetera, and into our startup 14 modes.
15 So there would be no surrendering of the license 16 to operate, but rather, a redefinition of an operating mode. 17 So we see that as a benefit both for clarity as well as the 18 flexibility to go back to an operating condition should that 19 be possible. 20 MR. REYNOLDS: So what you propose, Steve, is 21 just to add a separate mode. 22 MR. CRUNK: Yes. 23 MR. REYNOLDS: Not to change tech specs. 24 MR. CRUNK: That's right. 25 MR. REYNOLDS: Not to get rid of the old ones. Heritage Reporting Corporation e4 ' (202) 62 8 -4 F) 8 8
r, t'
- 54 2 .
'A 1 MR. CRUNK: That's right.
2 MR. REYNOLDS: Just to add. 3 So the difference between defuel mode and refuel 4 mode, you would have less aystems tech specs operable. 5 MR. CRUNK: Yes. 6 MR. REYNOLDS: But then if you decided to start 7 backup, you could go through whatever process in the tech 8 specs to start back up. 9 MR. CRUNK: Exactly. No different than you'd-
- 10. have to do from refueling to cold shutdown. There is a 11 difference in systems that are required betwaen cold 12 shutdown and refueling as well.
13 MR. REYNOLDS: Right. 14 MR. CRUNK: So, you would follow the natural 15 succession then of operating modes, having to redo whatever 16 surveillance are required and whatever testing to get you 17 back to'the next mode. We would simply do the same thing 18 from this mode back up. 19 MR. REYNOLDS: So this would be totally separate 20 then in your possession-only license application. 21 MR. CRUNK: Yes, yes. 22 It's intended that we submit this as an appendix 23 since we are kind of lumping everything in one spot. So 24 it's going to be like a new appendix as we envision it at 25 this time. Heritage Reporting Corporation
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.2 55' 1 MR. KEUTER: Yes. REYNOLDS: We want to get 2 closer to what the standard tech specs are. The standard 3 tech specs have a refueling mode, Mode 6, and they also have
-4 a mode called "at all times,", and our tech specs aren't that.
5 clear, and I think this will give us the same flexibility as 6 a lot of the standard tech specs. 7 MR. REYNOLDS: Okay. 8 MR. KALMAN: I think realistically this is 9 probably somewhat man-hour intensive for our review, and I 10 think before this kind of amendment is approved, we would 11 most likely have already submitted your possession-only 12 license if you are still planning to do that by January. 13 MR. CRUNK: Well, as far as the time table goes, "m,)- 14 we were looking at possession-only being submitted later, 15 you know, as in January. 16 Do you mean that we would submit it before you 17 approved, you mean? 18 MR. KALMAN: Yes. I think if you submit this, as 19 you plan to in October, by the time we finish our review and 20 approve this kind of a tech spec, you would already have 21 submitted to possession-only license. 22 MR. CRUNK: Well, there is a good chance that 23 that may not be necessary, you see. 24 MR. KALMAN: If we approve this? 25 MR. CRUNK: Well, if the concept of divestiture
* '[') Heritage Reporting Corporation (202) 628-4888 L. _ _ . _ . . _ . _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___.__
56
- -. I 1 is acceptable.
2 You see, we are kind of--- this amendment process 3 also carries us down both paths as well.
'4 'MR. KALMAN:* .I s,ee. .I see.
5 MR. CRUNK: So it's advantageous to go ahead and 6 have the techs. But we would want this mmendment anyway. 7 MR..KEUTER: We were planning on doing it anyway. 8 It gives us a lot more flexibility during'the refueling to 9 go into - you know, if we have to do -- 10 MR. CRUNK: If we have to do an in-vessel 11 inspection'or extensive types of work on the inside where we 12 would have to remove the core, this gives.us that 13 flexibility.
~jj 14 DR. MURLEY: George, I'm not sure you were --
15 there was some problem you were alluding to. That doesn't 16 strike me as a problem 17 MR. KALMAN: It's not a problem, but it would be 18 somewhat man-hour intensive, because we have to review all 19 the tech specs which are very cumbersome in Rancho's case 20 because of the long time period that they have accumulated. 21 There is a lot of changes. And I just don't see that 22 happening quickly. It wouldn't happen by January unless we 23 really focus a lot of resources on this issue. 24 MR. CRUNK: It's also our intent that the 25 ' possession-only application would build on this, too. So it
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.h\- 1 wouldn't really be time lost in the sense of your review. j 2 You would more than likely, if we had to go into a 3 possession-only submittal, you would be able to transfer the 4 effort.of that review direqtly to the possession-only.
5 I don't think it's time lost'for either party in 6 that regard. 7- DR. MURLEY: Now, is there something that's 8 timing sensitive to this? 9 Suppose it does take awhile as George suggested. 10 MR. CRUNK: Well, no. There's really nothing 11 ~that's timing sensitive other than the amount of resources 12 it takes the district to maintain -- 13 DR. MURLEY: I see.
^% -- any additional tech spec systems.
c1 14 MR. CRUNK: 15 DR. MURLEY: Okay. 16 MR. CRUNK: So it's strictly a resource problem, 17 the way we look at it, at this point. 18 VOICE: Well, that suggest that you're thinking 19 in terms of reducing staff when you get approval for this. 20 MR. CRUNK: Not necessarily staff. It's just 21 reducing effort in that sense which can be equated to staff. 22 VOICE: One and the same thing? 23 MR. CRUNK: I suppose that is true. 24 VOICE: That's a concern I think to give. 25 MR. CRUNK: I understand. ()c Heritage Reporting Corporation (202) 628-4888
E i.
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58 1 But bear in mind, we're still operating under'the 2 overall license at that point, too. So we could never 3 reduce below what the overall license requirements are. 4 MR. PARTLOWi What does that "no significant 5 hazards" mean? 6 MR. CRUNK: Oh. Well, what that is is we believe 7 that we would likely be able to put this through under an 8 ' affirmative no significant hazards, based on the fact that 9 it's an extension of existing tech specs. We are not 10 modifying systems or changing anything to do with the 11 accident analysis of the facility whatsoever, so that it's a 12 very straight-forward type of amendment process. 13 You would have to ascertain that, of course,
/"0) 14 after we submitted it. But we believe at this time that the 15 amendment would certainly qualify under the no significant 16 hazards.
17 Okay, the next point that I wanted to talk about 18 was the decommissioning plan. And as Mr. Keuter indicated, 19 we have been working within a task force that's been 20 established onsite to develop a decommissioning plan. And 21 as an effort that is directed towards that, one of the 22 things we have to do is put together what the plan looks 23 like, its contents as well as the various actions or 24 activities that might be required to get us to that point. 25 And what you see up there is a proposed table of () Heritage Reporting Corporation (202) 628-4888 1 i
s-- -. l v .
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i
!1' contents that would make up the plan itself, and just I i
2 briefly let me describe what we envision those encompassing. 3 Simply, the introduction is going to include what 4 the regulatory basis for th,e decommissioning plan is, and 5 define a revision process that we would envision the 6 . changing of the plan over a period of time might be 7- required, and therefore we wanted to define a process.- 8 The operating history, we want to characterize 9 the site, the systems, the radiological conditions that we 10 anticipate as well as the hazardous materials. 11 We want to talk about the alternatives that are 12 available and then why we selected the alternatives we did, 13 which in fact at this point in time appear to be safe. store-3 14 or delay decon. 15 We want to talk about the program itself. We'll 16 include there a discussion of scope, the organization that 17 will do that, the administration, the controls there. We 18 will talk about quality assurance, training. As you 19 mentioned, Mr. Virgilio, that is an aspect that will be 20 defined under the decommissioning plan. QA, industrial 21 safety, those kinds of elements will be all included under 22 that particular part. 23 The steps then in six and seven, of course, lead 24 up to what we need to get: the safe store, the operations 25 and how we conduct that during safe store. And then eight Heritage Reporting Corporation f (202) 628-4888 e
60-w m.
'Ud. 1 and nine will be a little bit nebulous since -- I shouldn't.
2- say nebulous, will be a little less defined since the decon 3 is at the tail end of the process. We'll give you the best' 4 description at this point that we can give you, recognizing J. that there may be some changes to that as we get a few years 6 down the road. But nonetheless, we will describe what our 7 decon process is at this point in time.- 8 And then, finally, the steps leading to the 9 ultimate site release and the request for termination of 10 license. 11 So that's what we have laid out with regards to 12 the plan. We have already put certain pieces of this 13 together in terms of the paper work, what we need and so
') 14 forth from a regulatory standpoint. So we are making 15 pyogress along that line.
16 The next -- 17 MR. HOLAHAN: The budget financial resources for 18 this are included somewhere in this? 19 MR. CRUNK: The financial plan for 20 decommissioning will be a separate submittal, but will go in 21 at virtually the same time. 22 MR. KALMAN: So this is just part of the 23 submittal that is required within two years of shutdown? 24 MR. CRUNK: Yes. 25 MR. KALMAN: For safe store.
.3 Heritage Reporting Corporation (M) (202) 628-4888
c 61 1 MR. CRUNK: Yes.
'2 MR. KALMAN: Which'also.has to'have the budget 3 information.
4 MR. CRUNK: '. Right , . right . 5 . VOICE: There is another plan'that's-called a-
'6 preliminary decommissioning plan that'was intended to update 7 the-cost estimate for decommissioning, and'that, by the 8 regulation anyway, would be submitted five years before 9 shutdown.
10 Is this supposed'to be included in here or 11 somewhere else? 12 MR. CRUNK: . We'11 roll up the preliminary 13 information there, but the actual detailed plan, the vg
'V 14 regulation required submittal that was for the middle of 15 next' year, is going to carry the lion's share of the 16: definition of that.
l 17 VOICE: I think the preliminary plant was 18 intended to update the cost estimate applicable to your real 19 site. 20 MR. CRUNK: Right. 21 VOICE: It maybe indicated change in the default 22 value that was set out in the rule. 23 Is that going to be submitted separately, or'how 24 are you going to deal with that? 25 MR. CRUNK: Well, if I understand what you are {} Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ _ _ - _ _ = -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ __ _ __- _ _ _- -
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$3' ' I saying, 'it's a ' separate submittal.
2 MR. KEUTER: Yes. Even if the plant ran, we were 3 . going to submit that June of next year. 4 MR. CRUNK:
- Ye s .,
5 MR. KEUTER: Since the election -- well, let's 6 try to meet that submittal, and we'll met that either way. 7 But it doesn't make any sense to wait another year and then 8 submit our detail plan. 9 Our goal right now is to submit both our L lLO financial and our detail plan at the same time, which we're 11' shooting for June of next year. So we want to try to bring 12 those two plans together. 13 MR. SANDUTO: Let me interject at this point.
;g } 14 I'm Bill Sanduto.
15 The rule does, of course, provide that you submit 16 your financing plan by June 1990. 17 MR. CRUNK: Yes. 18 MR. SANDUTO: And as you recognize, that rule 19 anticipated an operating nuclear power plant. 20 MR. CRUNK: Yes. 21 MR. SANDUTO: The conditions are somewhat ' 22 different perhaps, maybe somewhat different, and I just 23 wanted to indicated it may be that the staff will think they 24 will need to do some moving up of that time frame. We will 25 discuss that, and I am not suggesting it right now that we Heritage Reporting Corporation (.m[] (202) 628-4888
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^7 63 O-w But the reliance on the plan date
~1 will come in with that.
2 may not be fully applicable for condition Rancho S'eco will 3 be in. 4 MR. CRUNK: 'I see. - l 5 Are you saying that you feel that -- 6 MR. SANDUTO: I think that's something we will 7 need to discuss a little but further. 8 MR. CRUNK: Okay. 9 MR. SANDUTO: Today's meeting is not that. 10 MR. CRUNK: Okay. 11 MR. SANDUTO: I just wanted to give you an 12 indication that that sounds like something we -- if you plan 13 to decommission, in fact you will have a decommission, we n?
'd 14 need to discuss the question of timing.
15 MR. CRUNK: Okay, very good. 16 Let's see. So let's look at the next slide here 17 which -- we'll talk about the major milestones as we see 18 them. This first milestone is our internal approval of the 19 action plan, and I stress the difference there between the 20 decommissioning plan and our action plan to obtain that. l 21 The next milestone that we expect is the l 22 completion of these individual task plans that result from l: 23 the action plan. That is, the individual plans, pieces of 24 the overall decommissioning that each department or area 25 would be responsible for. The completion of the task Heritage Reporting Corporation
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64 7; 2d 1 deliverables, the prep work and so forth then would occur in 2 January, and the final draft decommissioning plan internally 3 would be completed about May of ' 90. It would be 4 distributed internally, rev.iewed internally and approved 5 internally, with a final submission to the Commission on or 6 about July 1st of 1990. 7 MR. REYNOLDS: Have you approved your action 8 plan? 9 MR. CRUNK: Yes, the action plan is approved. 10 MR. REYNOLDS: Okay. 11 MR. CRUNK: There are several of the task plans, 12 of course, that are obviously still in the process. 13 Do you have any questions on the decommissioning j 14 plan? 15 Okay, the next document of interest is the 16 emergency plan. And again, this is another area that we've 17 put together an action plan to determine what would be the 18 actions that we would take. 19 First of all, we recognize that the defuel mode l 20 reduces the types of possible accidents that we can l l 21 experience as well as the severity of those accidents. And 22 those things have to be taken into consideration into any 23 kind of an emergency plan dealing with that particular 24 program. 25 We would then revise the implementing procedures C?g Heritage Reporting Corporation NJi (202) 628-4888 _-.______-____m_____ . _ _ . _ _ _ _ _
65 0 1 as well as the plan to reflect those new limiting accidents 2 as well as the severities of those types of things. 3 We anticipate, as noted there, a reduction in the 4 EPZ. That would likely follow a calculation of what the 5 release would be capable of that type of an accident given 6 totally defuel spent, spent fuel pool. 7 Additionally, we anticipate downsizing the 8 emergency response organization. That's really a step that 9 is a logical outcome of decreasing all these other 10 requirements. 11 We expect to implement pieces of this, as it 12 points out here, on December the 1st. Part of that is our 13 initial reduction in the ERO that is just down to the I 14 regulatory limits. You recognize now we are in excess of 15 what the regulatory requirements are, and we expect to 16 downsize and meet the regulatory requirements still at that 17 point in time as well, and then redtfine the plan, have that 18 submitted and reviewed, as we'll cover in our summary in 19 terms of the documents that we are going to submit to the 20 Commission for review. 21 MR. KALMAN: The significance of that December 22 date is that you will have your emergency exercise scheduled 23 in December? , 24 MR. CRUNK: Right. And we will request, or we 25 have requested a waiver or delay, if you will, of that [) Heritage Reporting Corporation (202) 628-4888
66 Q(cy 1- particular exercise. 2 DR. MURLEY: Does that come up against your two-3 year deadline? 4 MR. CRUNK: *I'm Jiot sure. 5 DR. MURLEY: When did you have your last full-6 scale exercise? 7 MR.'KEUTER: Last year. 8 MR. CRUNK: Last year. Yes, we had an annual 9 exercise, full-scale. 10 MR. ROLAHAN: Is December onsite or offsite? 11 MR. KEUTER: It must be an onsite. 12 MR. CRUNK: Yes. 13 MR. KEUTER: This is onsite. 14 MR. CRUNK: Onsite. 15 HR. HOLAHAN: Just onsite. 16 MR. CRUNK: Yes. 17 MR. REYNOLDS: Again, your revision to FD plan is 18 just an amendment. It's not a total change. You're not
.19 going to get rid of the existing and replace it with this 20 one, similar to like your tech specs?
21 MR. CRUNK: Yes. 22 MR. REYNOLDS: You are going to have a defoel 23 mode. 24 MR. CRUNK: Yes. 25 MR. REYNOLDS: And so that you still plan, if you Heritage Reporting Corporation k (202) 628-4888
l . U 1 1 l ': I 67 m D) 1 sell the plant, this would still be in effect for defueling 2 mode. l 3 MR. CRUNK: That's right. i 4 MR. REYNOLDS: How would you work'the downsize, l 5 'which is a response organization? Would that stay the same? j l 6 MR. CRUNK: Well, you can -- what we're looking 7 lat now'is the required staffing of the. plan, in terms of 8 the number of people that are required for each position, or 9 the redundancy in the numbers of positions. i 10 And so by looking at that aspect, we're still ! 11 manning the organization, but with effectively less people. 12 We're looking at those types of methods of reducing the 13 organization size while still maintaining the organization i, 14 as defined. l 3 .2 15 In some cases, we had four or five people defined 16 for a given ERO position. You clearly don't need four or 17 five people for a given position. So by reducing those 18 numbers down to a reasonable number, then we are able to 19 maintain the staff. 20 MR. KEUTER: The amount of credible accidents in 21 a defueled mode has dropped significantly. You can't have a 22 LOCA. You can't have all your major accidents, especially 23 if you -- the major accidents you could have is a fuel- l l 24 handling accident. And we're even looking restricting all 25 fuel handling to day shift when you do have the E plan type l l r; Heritage Reporting Corporation - f" (202) 628-4888 l
t' 68 QQ wv' 1 resources available, those types of things. 2 You know, even a waste gas K tank rupture, whe.a 3 you don't have any gas, isn't - your' source term is greatly. 4 reduced. So the types'of s.everity of accidents in this mode 5 has gone down significantly, and we're lcoking at our EPZ 6 greatly reduced, too. In fact, it's down to the point that 7 it probably only include'one county instead of three 8 counties.- And right there you save resources in trying to 9 handle all three counties when it's not credible that you 10 can have an accident that will affect the other two 11 counties. 12 MR. HOLAHAN: I don't quite understand the 13 relationship between implementing this plan and changing the 14 license, or terminating the license. It looks like you want 15 to implement this plan as a separate license amendment, but 16 based on the existing full-power license? 17 MR. CRUNK: Basically, that's correct. 18 You know, again, this is not intended to be a 19 replacement of the existing emergency plan, but rather, a 20 modification to it. 21 MR. HOLAHAN: For some things I understand that, 22 but you don't change your EPZ every time you change the 23 modes at the plant. 24 MR. CRUNK: Oh, yes. 25 MR. HOLAHAN: I don't think that's how that gTg Heritage Reporting Corporation b.9 , (202) 628-4888 l I
k ' 9. 69
. !?)
.1 works.
.2 MR. CRUNK: Yes, right, right. This is really 3 twofold.
4 This action' plan covers two steps: short term, 5 immediate fixes, if you will, that we would anticipate 6' giving some reduction in required staff. Long term, down 7 the road dealing with the plant.as a license amendment where 8 we would have to change EPZ. This is all based on accident 9 analysis and everything else that has to be done to justify 10 changing your EPZ as well as the license amendment itself. 11 So it's really twofold. 12 This is an action plan that covers different 13 steps.
. ..g
?J 14 DR. MURLEY: There is a logical problem here that 15 Gary is getting at, I think, that we haven't thought 16 through. I'm not sure that you have. But if you reduce the 17 EPZ and if you cut out some certain counties and cut out 18 certain people that participate, that strikes me as nearly 19 irreversible. You can't go back and change modes and then 20 suddenly expand the EPZ and expand the number of counties 21 who can participate.
22 MR. .CRUNK: We agree. 23 DR. MURLEY: So, this time line involves pretty 24 much an irreversible kind of a change, and we would have to 25 think about this pretty carefully. Heritage Reporting Corporation (() (202) 628-4888 e
70 b~" 1 MR. CRUNK: Some of those steps indeed are that 2 kind of irreversible change. Those would be the later 3 actions taken under the action plan. 4 MR. KEUTER:' We',re planning on two submittals: 5 One September of this year for a defuel mode, and then a 6 second submittal emergency plan for a safe store in 7 September of next year. 8 MR. CRUNK: Yes. 9 MR. KEUTER: So that's what we are trying to say. 10 We're looking for an interim E plan change. And then when 11 we are truly out of divestiture, what our ultimate E plan 12 changes are. 13 DR. MURLEY: You keep, and there is kind of an ( ,. 14 undercurrent that runs through the discussion her, that you 15 may be in divestiture discussions for the next year or so. 16 Is that contemplated? 17 MR. BOGGS: Let me clarify that. 18 No, I don't believe that is the case. I think 19 that once -- we have exclusive negotiating rights right now 20 only with Golden State, and that's the only entertainment of 21 a nuclear option. Obviously, there is repowering and other 22 options that have been discussed, but even those I don't see 23 coming to light. 24 So I do not view that it will be -- I personally 25 believe, as the head of the organization, that it will be
$$) Heritage Reporting Corporation (202) 628-4888
'i 1 71 i% u 1 resolved fairly quickly.
2 DR. MURLEY:: Fairly quickly. That's right. 3 MR. BOGGS: And I think that's to staff's benefit. 4 :and to yours as well tb get,that issue either_ divested, and
- 5. then we start through'that process, or to continue on with 6 plant closure. And I look, based on board direction, I look 7 for that.to be resolved relatively soon.. And I think that's 8 in everybody's best interest to get that issue resolved, and
, 9 that's the way we are headed.
10 DR. MURLEY: Yes. Because it does make it 11 awfully awkward, I think, to keep carrying these options for 12 a long period of time. I don't know that we have in our 13 regulations allowances for emergency plan reductions and EPZ 7, 14 reductions and that sort of thing, do we, for this kind of a 15 mode? 16 Now, we would entertain it, I think. 17 MR. CRUNK: Let me just about three or four 18 slides ahead. I think we have gotten into a conflict of 19 concept here as to the schedule, and I think it's the last 20 side in that section. And this would, I think, clarify a 21 little bit of wha' s going on here. 22 What we anticipate very promptly is a defuel 23 emergency plan. It's going to give us some relief in 24 staffing, some relief in organization. We don't anticipate 25' necessarily an EPZ change in that. This is strictly an
.g Heritage Reporting Corporation L;y (202) 628-4888
,c 1 .
72 l' additional recognition of a defueled mode. And we're
- 2. looking at different staffing requirements and so on and so ~
3 forth. 4 MR. PARTLOW': Yo.u're going to submit that to us 5 about -- 6 MR. CRUNK: And that will be submitted. 7 MR. PARTLOW:. -- the time that the path becomes 8 clear -- 9 MR. CRUNK: Yes. 10 MR. PARTLOW: -- as to whether you are going 11 divestiture or closure. 12 MR. CRUNK: Yes. 13 MR. PARTLOW: The only outstanding matter is the
.i '
14 December public input. 15 MR. CRUNV.: Election, exactly. 16 MR. BOGGS: If in fact we've got a divestiture 17 out. 18 MR. CRUNK: Yes. 19 MR. PARTLOW: So given that, you want us to go 20 ahead and work on that emergency plan change and have it 21 ready for you in November. 22 MR. KEUTER: As you see by our asterisks here, 1 23 these dates may change. 24 MR. PARTLOW: Oh. 25 MR. KEUTER: Depending on where we're going with Heritage Reporting Corporation th' (202) 628-4888
" 73
'l divestiture.
2 MR. PARTLOW: Oh. 3 MR. CRUNK: To be honest with you, I wouldn't 4 anticipate, even if thb clo,sure in December, the vote was 5 absolutely negative, we would still not anticipate giving 6 you another emergency plan revision until later in 1990, 7 .perhaps close to the end of the year. 8 So it makes a difference to us both of,these 9 stages of review.- You know, if we get this particular 10 initial amendment review and approved by the end of the 11 year, then that's advantageous to us as well, as well as, I 12 would think, advantageous to you because it characterizes 13 the condition of the plant.
"n 14 Then later, in 1990, you know, a year later, we v
15 would be giving you another amendment which would at that 16 time include the EPZ reductions. 17 MR. PARTLOW: But for the first one, if by 9-15 18 you realize you're probably got a growing concern here, 19 you're going to hold this thing until after the -- 20 MR. CRUNK: That's correct. 21 MR. BOGGS: There's a series of those kinds of l 22 things that could happen. 23 I would like to clarify that if in fact we are 24 unable to reach a divestiture agreement with Golden State, I 25 do not see anyone else coming forward at this point in time.
. -3 Heritage Reporting Corporation
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1 I would continue on requesting board direction. In fact, I 2 don't even have to have board direction. It's already set 3 for closure, and I do not -- if there is any concern, I do 4 not see a half a dozen'othe,r people coming forward that will 5 continue this process. It's really strictly with Golden 6 State Energy. And our board has made it extremely clear 7 that let's get on with it and either divest or let's close, 8 let's get this resolved. And I expect that to happen very, 9 very shortly. 10 That makes it a little bit difficult through this 11 presentation, but I do believe that is in fact going to 12 happen, that specifically. Our direction at this point is 13 to solve that divestiture one way or the other. r) " 14 DR. MURLEY: Yes. Now, let us, for the purposes 15 of this discussion, assume that divestiture does not happen, 16 and so you are on a closure path. 17 MR. CRUNK: Yes. 18 DR. MURLEY: Why do you feel the need for a 19 revised emergency plan? 20 MR. CRUNK: The initial revision will actually 21 reduce really the resources that have to be committed to the 22 emergency plan organization. It is clearly the major 23 factor. It's far in excess of the tech spec numbers of 24 people required. The E plan really drives the size of the j 25 organization at this point.
, 7,) Heritage Reporting Corporation (202) 628-4888
75 +
,9
'O 1 MR. PARTLOW: Even if the plant were running,-you 2 would' submit this, wouldn't you think?-
3 MR. CRUNK: Yes. 4 MR. ' KEUTER:
- Probably.
5 What we have is 400 people in our E plan. This l 6 includes'-- we've gone to the detail of communicators, which 7 are secretaries that talk from one person to E xther. 7 8 MR. CRUNK: Yes. 9 MR. KEUTER: Runner, duplicator, copymakers. You 10 know, we have gone far in excess'of regulatory requirements. 11 MR. CRUNK: We've overstated it. 12 MR. KEUTER: And we want some -- we would request 13 some relief on that, because -- DR. MURLEY: So-it would not necessarily reduce 1[ 14 15 the capability of the plan, but it would reduce what's 16 called the specificity that's in there -- 17 MR. CRUNK: Yes. 18 MR. KEUTER: That's correct. 19 DR. MURLEY: -- in terms of people. 20 MR. CRUNK: Exactly. 21 DR. MURLEY: Where it gives you a little more 22 latitude in staffing. 23 MR. CRUNK: Yes. 24 DR. MURLEY: But does it degrade from the plan at 25 all? f .., Heritage Reporting Corporation 9 (202) 628-4888
- 76 1 MR. CRUNK:. We wouldn't see it. degrading the plan 2 at all.
3 DR. MURLEY: Emergency plan.
.4 MR. KEUTER:' Okgy. Our first amendment is 5 basically looking, you know, at the requirements of the 6 existing plan. It's based on an amendment to the existing 7 plan.
8 It isn't until we get down to a. safe store on the 9 bottom of the page, emergency plans for safe store next year 10 that we actually will be looking at reducing our EPZ. 11 One of the other things I'll be doing, you know, 12 even an EOF at that point. And if we don't, we'll probably 1 13 make a submittal there. At this point we don't need an EOF, l ez l 14 those types of things. 15 DR. MURLEY: Well, yes. When you are in the safe 16 store mode, I can understand it. 17 MR. KEUTER: Yes. 18 MR. CRUNK: Exactly. 19 DR. MURLEY: But you've got me a little confused 20 with your discussion as to when the fuel was in the spent 21 fuel pool, you can't have LOCAs and you can't have this and 22 you can't have that. But you've still got something like 23 millions of curies of -- 24 MR. CRUNK: Yes. 25 MR. KEUTER: Oh, absolutely. () Heritage Reporting Corporation (202) 628-4888 9 um._--________.____.m_._ m_ta.__..
~
I- a* l 77. I
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1 MR. CRUNK: Absolutely. That's correct. 2 DR.'MURLEY: And if you were going to expect us 3~ to review a different set of accidents, that's going to take 4 us a lot of time. 'I chn te,11 you that. 5 MR. CRUNK: And that's the 1990 submittal. 6 DR. MURLEY: Okay. Good. 7 MR. KEUTER: That's why we. dropped back to here. 8 MR. CRUNK: That's why we dropped back to here, 9 because I could see that I was getting into some trouble 10 there trying to make that clear that there is two separate 11 submittals. The action plan has to clearly address both of 12 them. 13 DR. MURLEY: Yes. i 14 HR. CRUNK: But there is clearly two-separate 15 submittals. 16 MR. HOLAHAN: I think I still have a problem. 17 The actual license termination, or conversion to 18 a possession-only license really goes along with the line 19 called " decommissioning plan", doesn't it? 20 When does their license change here? It looks 21 like that is to be determined. 22 MR. CRUNK: To be -- you mean the possession-only 23 tech spec submittal or what? I don't understand. 24 MR. I:OLAHAN: Possession-only license. 25 When do you loso your operating license for this? [h Heritage Reporting Corporation
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.I f-1 MR. CRUNK: 'Okay. -That we anticipate, based on 2 again the failure of the divestiture' process, submitting 3 that to you about the first of the year. December 1st may 4 be a little bit early.' But about the January time frame of 5 the year, that's when the application will be submitted to 6 you.
7 MR. KALMAN: Typically, in previously 8 decommissioning, that was the first step for reducing both 9 the tech spec requirements and also the emergency i' 10 preparedness. 11 MR. CRUNK: Yes. i 12' MR. KALMAN: Usually after we receive the 13 possession-only license, we acted on reducing the 14 requirements for those items. j 15 MR. CRUNK: And in reality, that goes along with 16 what we're saying. If we are in agreement that the initial , i 17 submittal of the emergency plan is not intended to reduce l l 18 the effectiveness of the plant, but merely to reduce some of 19 the specificity that's in there in terms of runners and 20 communicators -- not communicators, but interface people ! 21 between different groups and so forth. So that's really 22 what the first submittal does. I 23 MR. KALMAN: In reality, what I think will happen ; i 24 we'll receive those, say on those particular dates before l l 25 the end of the year, the emergency plan reduction, and also If') Heritage Reporting Corporation (202) 628-4888 _--_m--___ . _ _ . _ _ _ _ . _ _ _ . _ _ .m__.
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2 MR. CRUNK: Yes. 3
~
MR. KALMAN: But before we finish our review,. 4 according to your' schedule,,you should have also submitted-5 the possession-only license. So we'll be pretty much in-6- sync with previous plans that have. decommissioned. 7 MR. S. LEWIS: Steve Lewis from the General 8' Counsel's Office. 9 There should be an understanding that.even though 10 you've submitted your possession-only application in advance m 11 of various other things that will be submitted, which are l 12 laid out there, including decommissioning plan some eight 1 13 months later, it may well be that we can't act on your
~;,,
f 14 possession-only application until'we decide on your 15 decommissioning plan. 16 And I'm not sure I see a recognition on your part 17 that that's the case. But based on previous experiences 18 we've had in this organization, that'may well be the way it 19 would have to be analyzed. 20 MR. CRUNK: That's acceptable. 21 We hadn't ignored that as a possibility. But 22 clearly, what we did was we put out what the best of what we 23 could dig out at different plants and what other licensees 24 had done in the past that looked like a rational pattern for 25 us doing these things. E] Heritage Reporting Corporation (202) 628-4888
h- 4
- 4 80
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1 We' know the possession-only is 'really the first 2 step in the process, and that's why it appears that way. 3- The other. things that occur in front of that are steps that'
'4 are intended to not degrade,anything with respect to'the 5 license or the commitments made under the existing license.
6 MR. HOLAHAN: But the pieces that concern me are 7 those where implementation occurs before the possession-only 8 license is approved. 9 MR.- CRUNK: Yes. 10 MR. HOLAHAN: It isn't clear to me what pieces we 11 could or should approve before that step. Certainly when'we 12 start talking about big steps like EPZ, I I m not sure that 13 that step should come before the possession-only license.
- 14 MR. CRUNK: It does. That's under the last EPZ 15 submittal.
16 MR. HOLAHAN: No. No, because I think the message 17 we are giving you is that approval of a possession-only 18 license may include accepting the decommissioning plan. 19 MR. CRUNK: Okay. 20 MR. HOLAHAN: Okay. And that's your "to be 21 determined date" on here. 22 MR. CRUNK: All right. 23 Well, certainly those are only assumed dates in l 24 terms of the NRC review and approval there. We recognize 25 that you will review and approve them as you are able to.
#j
$-7. Heritage Reporting Corporation (202) 628-4888
81 h- 1 MR. HOLARAN: It's not clear to me those two last
'2 steps will be done.in.that order.
3 MR. CRUNK: Yes, okay, and they may not be. They 4 may-not'be. . . 5 MR. PODOLAK: I'm in the Emergency Planning 6 Branch of NRR.. 7 Earlier in the presentation you talked about 8 assuming that yo wnre going-to get an exemption on this 9 year's exercise. You mentioned that. 10 MR. CRUNK: Yes. 11 MR. PODOLAK: You haven't got any indication from 12 us that you would, have you?
' 13 MR. CRUNK: We've had the request in, and we
.~.,
. 14 understand that it's being-looked e,t. And that's 15 certainly --
16 DR. MURLEY: It's an onsite exercise. 17 MR. PODOLAK: Yes, the onsite exercise. So you 18 are planning -- until you get that, you are planning to have 19 it, I assume. 20 MR. CRUNK: That's right. 21 MR. PODOLAK: Okay. We'll schedule that for you. 22 And this plan submittal that's coming in 9-15-89 23 would be to support your existing plan, but with fewer 24 people, but you're still just reiterating, you're still 25 going to meet the requirements -- Heritage Reporting Corporation Sh') (202) 628-4888
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- 2. MR. CRUNK: Yes.
2 HR. PODOLAK: --.for emergency plan. 3 MR. CRUNK: Yes. 4 MR. PODOLAK) Ju,st less people.
' I 5- MR. CRUNK: Exactly.
6 MR. PODOLAK: Okay. i
'I
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MR. CRUNK: As Day said, this submittal would 8 have occurred if we had been operating. 3 .MR. PODOLAK: Understand. 10 MR. CRUNK: Yes? 11 VOICE: You talk about this, and I realize that 12 you can't do certain things unless you know whether you are 13 going to transfer the plant.
, 14 At which point do you think you are. going to have 15 to start thinking about environmental submittals, and 16 looking at whatever you might have to submit under the Part 17 51 of our regulations in order to get these authorizations?
18 MR. CRUNK: You're talking about environmental 19 impact -- 20 VOICE: Appraisals, statements, what have you. 21 MR. CRUNK: Those actually come as part of the 22 decommissioning plan as far as we're concerned. 23 VOICE: The question that you might have to look L. 24 at is whether you are taking steps that will lead to an 25 inevitable decommissioning before then, and therefore have Heritage Reporting Corporation fy()s
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- h-1 to have an environmental review before'then. 1
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2 .MR. CRUNK:. We appreciate that question. And at \ 3 .this point-the intent is to,not have taken any.de facto: decommissioning steps.'
~
4 . 5 VOICE: I was waiting-for.that term to be used. L 6 3GR. CRUNK:' I thought I'd just go ahead and say 7 it since everybody was' waiting for it. 8 That's the intent. And clearly, we recognize: 9 that.for us it's kind of a difficult circumstance.- We 10 : recognize that the decommissioning plan typically, according
- 11 to the way the regulations and the. reg guides are 12 structured,.you submit five years before you are at the 13 point of actually ceasing operation of the facility. And we rm 0 14 appreciate that it's, and I'm sure you do, that it's a 15 different circumstance than most folks go through.
16 VOICE: I'm not sure that,.i: loo? ting at some of 17 the' actions that you are taking ahead of time and asking us
- 18. to approve, we would not be bifurcating our approval process 19 within the terms of the environmental statutes to work cui 20 the knowledge of where you are heading, and wait that long 21 to get an environmental report.
22 MR. CRUNK: Well, if that's the case, certainly 23 we can adjust our schedule to suit whatever the regulations 24 require, or your interpretation of them. 25 VOICE: Regulations, statutes, case law. kf Heritage Reporting Corporation (202) 628-4888 G .
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- j. .
84-k 1 MR. CRUNK: Statutes or whatever, yes. 2 So, no, these things are actually put up there as 3 projected, and we're here to show you what our bestl guess is 14 that this process is gbing,to work, and-we are certainly
. 5 here to work with the NRC, the staff. members, general 6 counsel, or whoever might provide insight to us as to the 7 best=way to go on this.
8 We have been working, of course, with our legal 9 folk as well as other industry groups. B&W has provided 10 assistance as well as other industry groups. So it's kind-11 of a little bit of unchartered waters for us, being out here , 12 in a condition that is not clearly charted by regulations at 13 this point.
'^ 14 And so we will work with the Commission in that 15 regard, and satisfy all the requirements.
16 MR. KEUTER: We do have a separate action plan on 17 our environmental impact. 18 MR. CRUNK: Yes. 19 MR. KEUTER: We are trying'to move that up a 20 little. Currently, we are trying to make this part of our 21 decommissioning plan. What we don't want to do is submit 22 everything in pieces and then have the pieces get mixed up. 23 But our target, you know, is earlier than our 24 decommissioning plan. 25 MR. CRUNK: Yes.
<> Heritage Reporting Corporation U/ (202) 628-4888
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l ' l I() 1 MR. KEUTER: 'But we haven't worked out if we're 2 going to make it part of the decommission plan, try to 3 submit it early. The bottom line is we'll work with you in 4 trying to figure out when to actually submit it. 5 MR. CRUNK: It looks like, if you look at just 6 the bare regulation, the statement on the first bullet is, I 7 think, about the way it's worded: Either submit it with the 8 decommissioning plan or no later than two years following 9 permanent cessation of operation. 10 And to meet that, we're looking at targeting it 11 at, as Dan says, early in the year, but it could be as late 12 as the report, the way we see things at this time. 13 VOICE: I think the next issue that Ed Reis is W 14 raising is that that is still after the time that you would 15 be seeking an interim amendment to put into effect another 16 mode. And for any amendment, we have to look at what has to ' 17 be done underneath NEPA. 18 And so there may, you know, acknowledging the way 19 you are approaching it and from your point of view, the 20 logic of not doing it piecemeal, nevertheless, we're going 21 to have to look at what type of environmental review we have 22 to do in connection with the amendment, the interim 23 amendment that you are seeking to have this additional mode 24 permitted under your current license. 25 MR. CRUNK: Well, let's go back here and just j Heritage Reporting Corporation (202) 628-4888
p 86 t 1 briefly address that. 2 What we're talking about there, I assume, is the 3 defuel condition, tech specs. ! 4' VOICE: Yes'. , 5 MR. CRUNK: They are the ones that's going to 6 come out? 7 VOICE: Yes. Which precedes,the submittal of the 8 environmental report. 9 MR.-CRUNK: That's correct. We do not see that 10 as being a step toward -- any kind of irrevocable step 11 toward decommissioning the facility. 12 In fact, we had anticipated submitting something , 13 like this anyway, because of the fact we were going to be
- ' p~.9 14 for a period of time with no fuel in the vessel, and we 15 wanted to make it very clear for our operators via an
- 16. amendment process, what they were accountable for under 17 those conditions.
18 MR. KEUTER: It's been a big question. Even at 19 an operating plant when they get into a defuel mode whero 20 they take the fuc' out, do the in-service inspections, or 21 whatever, you know, what systems do they maintain or don't 22 they maintain. 23 This tech spec that we're requesting here is 24 probably one that we would request no matter -- well, we 25 would request it even if we went into restart; that we feel () Heritage Reporting Corporation (202) 628-4888
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k 1 this would give us a lot more flexibility and a lot-more 1 2 clear guidance when we do take the fuel out of the core out L 3 during our refueling outage, and it's one that we would 4 request either way. , 5 MR. HOLAHAN: It sounds like there are two 6 aspects to the defuel mode aspect. One has to do with 7 systems and surveillance. This piece talks about emergency ,
- 8. plan. I guess it's not clear to me how you change your 9 emergency plan for.the --
10 MR. CRUNK: The only thing that the emergency 11 plan maybe is made unclear because it says "defueled" after 12 it. But we were tying it to the time frame that we were 13 going to defuel, in a sense the implementation of it. 14 But basically that emergency plan amendment is 15 foreseen as nothing more than we would change anyway at this 16 point in time knowing what we know about our existing 17 emergency plan. 18 It is very prescriptive. It's very excessive in 19 the amount of definition and control at places over the way 20 we implement the plan. It's clearly in excess of regulatory 21 requirements, and therefore we intended to modify that plan 22 to conform to the regulatory requirements without the intent 23 of changing anything, of reducing the effectiveness of the I 24 plan or any significant changes of that nature. ) 25 MR. REYNOLDS: And it'll be applicable in all
. .y Heritage Reporting Corporation
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88 7) 1 modes and cperations through refueling a.d defueled mode. 2 MR. KEUTER: That's correct. 3 MR. CRUNK: Yes. Yes. 4 So, perhaps' the parenthetical expression there 5 has caused that perception. But the intent is that that's 6 the time frame that we intend to have it implemented. but 7 basically the effectiveness of the plan.is not intended to 8 be reduced at all. 9 Okay? 10 MR. HOLAHAN: Okay. 11 MR. CRUNK: The one that's down there under safe 12 store is the one that's intended to implement a whole new 13 set of conditions, a whole new set of accident analyses, and 14 the one we recognize is going to take substantial review by 15 the Commission. 16 Let's just leave this up there then as we talk 17 through the other points, kind of to keep our thoughts 18 focused there. 19 We talkel about a security action plan, and that 20 is intended to bo a vital area analysis, a radiation area 21 review, a revision of the physical security plan, and any 22 sev rity mods that are required at that point in time, and 23 any staff and area reductions that are appropriate. 24 We're already working with the Commission to 25 define what's allowable and what's acceptable, and we intend , ~~') Heritage Reporting Corporation
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t 89 i'") 1 to work with you before we even submit the plan, in order to i 1 2 make sure nothing comes in that's unacceptable at that ) 3 point. 4 There is reh11y,no change in the current security I 5 itself anticipated until next year some time. And by then 6 we'll know whether we're on the road to decommissioning or 7 not for sure. 8 I would like to talk, if there are not questions 9 about that aspect, I would like to talk about commitment 10 review and discuss how we're attacking that issue. 11 We recognize that there are a great body of 12 commitments out there if you include those items that sprang 13 form our restart effort. And as I'm sure you recognize, a
;j 14 great number of those are commitments that don't make sense l l
15 if the plant is truly to be decommissioned. 16 obviously, we're not going to go out and want to 17 replace reactor coolant pump seals, or do some major 18 remodification to the operating system if the plant is never 19 to be operated again. The system won't be pressurized, l 20 won't be running. It doesn't make any sense. 21 What we're doing is we're reviewing each 22 commitment, not only to the NRC, but also the commitments we l 23 have made to other agencies or organizations, I should say, 24 that might be interested in them such as ANI and INPO, to 25 see which of those commitments makes sense in a defueled,
~ (; Heritage Reporting Corporation (202) 628-4888
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- 1 decommissioned direction type of a facility.
2 And although the side says in the past tense, was 1 3 reviewed and justified, actually we are still -- we are 1 4 anticipating being done wit,h that, but we're not. l 5 In fact, that process is kind of -- we've 6 discovered an iteration process that we've had to re-review 7 certain items because we as a licensing organization didn't L 8 agree that they should be done or should not be done. So, 9 we've kept that process going. 10 What we're doing by this, then, is defining what 11 amounts to three categories of commitments for our records. 12 One is an open commitment that we intend to accomplish 13 regardless of the direction the facility goes, em
- / 14 Second, is a commitment that we feel is only 15 applicable if divestiture is successful. Those are items 16 that we are calling deferred, because in reality we're not 17 going to' proceed on them until it becomes clear that 18 divestiture is successful, i.e., after the December vote.
19 So we're calling those deferred or achieved. 20 And for those elements, we're putting all 21 documentation, all the references, all the paper work into 22 files that we can retain and resurrect if we need to upon O 23 the success of divestiture. 24 Then we have items that -- there are some that 25 we're going to be coming back with that we think are closed (]) ' Heritage Reporting Corporation (202) 628-4888 e
t 91
,73 nj 1 in the process, or that we've identified alternative actions 2 that have completed them, other than what was originally 3 committed. So we will be coming back to the NRC with those 4 items as well. ,
5 So we will have all of those things provided for 6 review by at least the region folks and if NRR is interested 7 in that, we will provide the same review for your benefit as 8 well. And all that is a documented process, so that it's 9 retrievable. 10 MR. PARTLOW: Bulletins and generic letters. We 11 issued some, we've issued them recently. Some are sort of 12 long term. 13 MR. CRUNK: Yes. s 14 MR. PARTLOW: Some are sort of short term. 15 MR. CRUNK: Yes. 16 MR. PARTLOW: What are you doing with the short-17 term one that says, go out and look and see whether you've 18 bought any of these kind of circuit breakers or not? 19 MR. CRUNK: Okay, let's flip the page, and let me 20 explain by looking at -- this is sort of an answer to your 21 question. 22 Oh, wait a minute. Maybe it isn't in there. Let 23 me see. Here we go. 24 We took a look to see what the status was of 25 those kinds of elements, and of those things -- this is by
.; Heritage Reporting Corporation l
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9 t-92 I 1 way of introduction to an answer to your question -- we 2 looked at different categories of things that are 3 outstanding in terms of LERs, NOVs, NODS, Notices of l 4 Deviations and Violati'ons, pulletins, generic letters. l 5 Of those outstanding items, the ones we had,'we l l 6 have deferred a total of 15 elements from bulletins, 16 from 7 NOVs, NODS, and 18 from LERs. Those are the things that 8 deal with operating plant physical modifications and so 9 forth. 10 And what we still have open are the elements 11 we're going to continue. Those are the kinds of things I 12 think you are interested in, the ones that are still open; 13 the ones that say what have you got in the warehouse of XYZ 14 breakers, and what have you installed in.your plant that are 15 of a fail type or something like that. 16 MR. PARTLOW: You wouldn't defer that? 17 MR. CRUNK: Those would not be deferred. Those 18 would be provided in terms of information. 19 We recognize there are different types of 20 regulatory things that you require. Some of them involve 21 plant modifications, some involve information for the 22 industry in the sense of where is the industry, is there a 23 safety problem, how many of these things are out there. And 24 those kinds of things, we're answering. 25 MR. REYNOLDS: To my knowledge, you haven't told Heritage Reporting Corporation l r)[ (202) 628-4888 _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ )
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'us all the ones that you plan on. deferring like the LERs.
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2 'MR . CRUNK: You are right, a 3 NR. REYNOLDS: And generic. And you'have, I know 4 on at least one, you h've a Asked.us to-allow you not to 5 respond to generic letters.
, 6 MR. CRUNK: Yes.
7 MR. REYNOLDS: Do you plan on notifying.us of all 8 the ones you've deferred? 9 MR. CRUNK: Yes, yes. L 10 This is preliminary data in terms of our review. 11 MR. REYNOLDS: Okay. 12 MR. CRUNK: And we are going to specifically 13- identify each and every one, r ?' . se 14 MR. KEUTER: And justify every one.- 15 MR. CRUNK: And justify each and every one. 16 MR. KEUTER: And review it with -- 17- MR. CRUNK: And review it with both, if NRR
.18 desires and the region.
19 VOICE: Okay. What does it mean when you say 16 20 deferred actions in responses to notices of violations and 21 notices of deficiencies? 22' Is that something you have advised the region 23 that you are -- 24 MR. CRL Gt: Those are ones, if you look at it a 25 different way for juat a second. We have 26 of them open j[]3 Heritage Reporting Corporation (202) 628-4888
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i 94 L- A: q) 1 .that are somewhere in the process of our working on them, 2 not necessarily overdue,-but that are open', okay? 3 So there is 26 of them. Of that, our review of-4 those 26 has identified'tha,t 16.of them can be put into a 5 category of deferred, that we haven't told you about yet, 6 but we will. 7 VO. ICE: Good. 8 HR. CRUNK: And 10 of them that we have
'9 identified as open and reviewed.
10 So of those, that's our estimation of them. 11 Certainly if, in our review with your staff you disagree gag ,, 12 with that, you know, then we will take care of them. 13 MR. KEUTER: Then it goes back to the open a L; 14 column. 15 MR. CRUNK: Then it goes back to the open column, 16 the numbers change rapidly. . 17 MR. KEUTER: The reason we didn't put it in your 18 book is this is preliminary. It's just a status to show you 19 where we are and give you some feel of the open versus 20 deferred. 21 MR. PARTLOW: Yes, I guess we won't dwell on 22 them. 23 MR. CRUNK: Yes. 24 MR. PARTLOW: The LERs are an operating 25 experience, something that has happened. (fh Heritage Reporting Corporation
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t 95 1 MR. KEUTER: Well, it happened when they were 2 operating. 3 MR. PARTLOW: I think it's across the industry. 4' Why would you defer thb sub.mittal of LERs? 5 MR. CRUNK: No. That's not the submittal of 6 LERs. It's the corrective actions called for -- 7 MR. PARTI OW: Okay. 8 MR. CRUNK: -- from LERs, which may have 9 involved, you knou, a commitment we made to modify a plant 10 system. 11 MR. PARTLOW: Okay. 12 MR. CRUNK: And what we're saying is these are 13 the corrective actions for LERs. 14 MR. KEUTER: For example, on the ox feedwater 15 pressurization of that, that was an LER. There were 16 several, a large magnitude of actions that came out of 17 there. But if you are never ever going to use that system 18 again, it doesn't make sense to make those modifications. 19 MR. CRUNK: Yes. 20 So, just to clarify that, that's not -- 21 MR. PARTLOW: I realize the situation. 22 You know, next year there are going to be more 23 bulletins and generic letters. 24 MR. CRUNK: Yes. 25 MR. PARTLOW: You are going to have a hell of a []7#1 heritage Reporting Corporation (202) 628-4888
, t 96 1 : time catching up. 2 MR. CRUNK: And each one will have to be reviewed 3 and we'll respond to the ones -- 4- -MR. KEUTER:' Wel,1, they will~still be reviewed. 5 MR. CRUNK: Yes. Oh, yes. i'
- 6. MR. .KEUTER: And determined if they are- -
7 applicable to us.- 8 MR. CRUNK: In either event, we'will respond to 9 them. 10 MR. PARTLOW: I understand. 11 MR. CRUNK: Either we will tell you that, yes, 12 here is the answer to your question; or, no, we're not in a 13 position to do that modification that you have indicted
,3 i jf 14 there is appropriate.
15 VOICE: Let me follow up for a moment. I notice L 16 the violation of the Notice of Deficiencies. There is a
- 17. regulatory requirement. You have to respond within 30 days l 18 under regulation. It's 20 days.
19 MR. CRUNK: We've already responded. 20 VOICE: Okay. 21 MR. CRUNK: These are the corrective actions -- 22 VOICE: All right. 23 MR. CRUNK: -- that we have committed to in the 24 re:sponses . 25 VOICE: None of these indicate that you have
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'i' failed to meet the regulatory required time for response to 2 this violation.
3 MR. CRUNK: That's correct. 4 These are ohly t,he actions springing from LERs, 5 NOVs, bulletins, generic letters, which ones are still open. 6 Several of these we have already done in terms of actions in 7 the past months. 8 The point being that what we wanted to profile by 9 this was not that it was -- there was not a blanket effort 10 to wipe out the commitment base. The intent is to go 11 through those commitments, see which ones make sense and , 12 which ones don't, and then inform you as to that 13 determination, and show you what our justification is for
~
14 doing or not doing those items. 15 And even as such, even without the regulatory 16 prod, we wanted you to see that we were in good conscious 17 doing many commitments that we made on these items. 18 MR. PARTLOW: I just want to point out that 19 required by Appendix C is immediate corrective action. So 20 11 you are going to defer ar.ything, you need to let us know 21 as quickly as possible to see if we agree with you or not. 22 MR. CRUNK: Yes. 23 MR. PARTLOW: Because you are required to take l 24 immediate corrective action for all identified deficiencies. 25 MR. HOLAHAN: I think the word is " prompt". Heritage Reporting Corporation L [5) (202) 628-4888
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1 MR. CRUNK: Prompt, or whatever, yes. 2 MR. PARTLOW: Prompt. 3 MR. CRUNK: In any case, these are the ones that 4 have had dates assigned to.them already, you know, so that 5 they are somewhere down the path. It's not like we've let 6 these things all roll by and said, oh, by the way, we're not 7 going to do them. 8 MR. REYNOLDS: I just see a large number up there 9 and between the region and NRR, I don't think we're aware of 10 only one you plan on deferring. 11 MR. CRUNK: Yes. 12 MR. REYNOLDS: So you have a number up there that 13 we're not aware of. m J 14 MR. CRUNK: Yes,' and we recognize that it's taken 15 some time to get to this point. But you recognize that it's 16 a big job to do that review and the justification as well. 17 MR. REYNOLDS: Right. 18 MR. HOLAHAN: How are these commitments and 19 probably hundreds of others that you've made to the NRC 20 being treated in the divestiture decision?s 21 MR. KEUTER: They would all move back to an open 22 column. 23 MR. CRUNK: Yes. 24 MR. KEUTER: We're assuming that if we operate, 25 you know, that all these commitments will be met. rs i;r.,1) Heritage Reporting Corporation
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99 h 1 ' MR . CRUNK: Anything that changes with regard to 2 any commitments that have.been made to the Commission will 3 have to be separately addressed with the Commission.
- 4. There is no*inte,nt to say, it's a new ball game; i 5 you know, the players have changed and everything is gone.
6 The intent is that we've captured everything. And the 7 intent is to come back to you and say, these are the ones 8 that we are either doing or not doing. And if the 9 divestiture process goes, then GSE has a responsibility to 10 meet those commitments or come back and separately negotiate 11 each one of them. 12 MR. KALMAN: And there are many, I think, would 13 be impossible to instigate on the dates that have been C') 14 committed to, so that would have to be negotiated.
%j 15 MR. CRUNK: Yes.
16 MR. KEUTER: You brought up the example of the 17 simulator. 18 MR. CRUNK: The simulator is one that's going to 19 be tough. 20 MR. KEUTER: Is a very good example. 21 MR. CRUNK: Tough or impossible, right. 22 MR. KALMAN: I don't know of any method that's 23 been identified for you to by-pass the regulatory 24 requirements to have it submitted. 25 How do you propose to address that if divestiture
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k\ d 1 goes through? 2 MR. HOLAHAN: The question is-who is going to 3 address it if it goes through. 4 Is it part of yo.ur arrangement in the divestiture 1 5 process, or is someone -- 6 MR. KALMAN: Let's face that problem when we get 7 to it. 8 VOICE: That's going to be the licensee, whoever 9 that is. 10 DR. MURLEY: I was going to say, I think that we 11 probably -- that's a topic of another meeting really. 12 MR. CRUNK: I agree. 13 DR. MURLEY: The progress and what we do about
)) 14 divestiture and how we treat the license. It's going to be 15 very, very complicated as you know, and I would propose that 16 we not spend a lot of time here today on that.
17 I would only remind you that if divestiture does 18 go ahead, Dave, SMUD would still be the licensee or some 19 time. 20 MR. CRUNK: Yes, we understand that. 21 DR. MURLEY: Right. So you would still have to 22 deal with all these requirements and regulations and so 23 forth. 24 MR. BOGGS: I would like to make just one more 25 sentence on divestiture, if I could. l
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f:. L 101 r? 1 DR. MURLEY: Sure. 2 MR. BOGGS: We've mentioned several times about a 3 l~ 3 December date. I do want to make'it clear that the board-4 has mad it clear that if we, do not have an agreed to 5 package, there.will be no vote period. There will not be a 6 generic vote that says, you know, divest the plant. So it 7 has to be based on a package. And again, that ties back to 8 Gold-State only. 9 So if there is not an agreed to memorandum of 10 understanding for the power sales and one for the transfer, 1.1 there will be no vote unless the board for some reason 12 changes the policy direction. But there will not be a vote 13 unless there is a specific package upon which we are acting.
) 14 And obviously, that's all subject to NRC review.
15 DR. MURLEY: Okay. 16 MR. CRUNK: Just one final thing there just to 17 close out the discussion on the inventory items. lo Again let me stress that these were put down as 19 dates that look reasonable to us based on what we knew. And 20 certainly we are welcome to input from your staff, Dr.
.21 Murley, and if they have additional insights that can help 22 us better tune this schedule, we would appreciate that, too.
23 DR. MURLEY: Fine. We recognize that we're 24 moving in unchartered waters here, and I think you have done 25 a good job in trying to identify the issues. And I think we Heritage Reporting Corporation (I) (202) 628-4888
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' lid? 1 have picked up probably some uncertainties here today: .one 2 in the emergency plan area, the other is in the 3 environmental report area. I think we need to probably 4 communicate a'little bit mo,re. .
5 MR. CRUNK: Good. 6 DR. MURLEY: But by and large,.I think you have 7 identified the issues pretty well. 8 MR. CRUNK: Okay. 9 MR. KEUTER: I would like to conclude, summarize 10 'where we-are, where we are going. 11 I definitely have adequate resources, both budget 12 and staff, to complete an orderly and very. comprehensive 13 closure plan that will result in a decommissioning plan for
~ {], 14 long-term safe store and eventual disassembly of the plant.
15 Budget and staff is adequate. We have laid out 16 detailed plans that are resource-loaded, and we are right on 17 our plan. In some respects, we are ahead of schedule in our 18 defueling, and in a few areas, we are a little bit behind 19 schedule. But we are proceeding in a very orderly, well l 20 planned out and well documented. 21 We are implementing detailed closure plans. This 22 is the book that has our closure plans in them. Where we 23 are on our closure plans right'now is they all have been 24 reviewed and approved through a Plant Clo'sure Committee, and 25 now we are in the process of taking, although we have a big
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" I picture of schedule, taking all the individual actions out 2 of these action plans and make sure that they mesh together.
3 We will complete all applicable corumitments. We 4 are in the middle of that review process as you've seen, and 5 we will meet those that are still applicable to us. 6 And in closing, I would just like to say we are 7 committed to a safe plant, and that we will meet all 8 federal, state, county and ANI regulatory requirements and 9 recommendations. And we want to make this an orderly and 10 well planned out closure process. 11 DR. MURLEY: Okay. I think this meeting has been 12 very useful for us, the staff. I think, however, there is, 13 as I understand it, Dave, a decision that is imminent in the 14 next month that's going to take you on one path or another. 15 MR. BOGGS: Right. 16 DR. MURLEY: So, my guess is that probably we 17 ought to get together again some time maybe in October. 18 Whatever path you are on then, we need to have an early 19 meeting to make sure that we and you understand that path. 20 And this was more of a discussion of the decommissioning 21 path, and I think there are some questions that we will want C2 to discuss again in about October. 23 MR. BOGGS: We would b3 glad to do that. And I 24 think, frankly, it will become much easier as the path i 25 becomes clearer. (h Heritage Reporting Corporation
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N) W' 1 DR. MURLEY: .Yes. Yes,ait.will. 2' Anything think else or comments?.
'3 (No. response.)
- 4. DR.'MURLEY:* Tha,nk you very much, and that 5 terminates-the meeting.
6 (Whereupon, at-11:16 a.m.,.the meeting was 7 concluded.)' , 8
.9 10-11 12 13
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74 15 16 17 18 19 20' 21 22 23 24 25
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-1 1 CERTIFICATE 2
3 This is to certify that the attached proceedings before the 4 United States Nuclear Regulatory C m ission in the matter 5 of: Status Briefing with Sacramento Municipal Utility District (SMUD) on 6 Name: 7 8 Docket Number: n/a 9 Place: 10 Date: August 29, 1989 11 were-held as herein appears, and that this is the original 12 transcript thereof for the file of the United States Nuclear 13 Regulatory Commission taken stenographically by me and,
': 14 thereafter reduced to typewriting by me or under the 15 direction of the court. reporting company, and that the 16 transcript is a true and accurate record of the foregoing-17 proceedings.
18 /s/ a ko m Ur b am o 19 (Signature typed) : Alan Friedman 20 Official Reporter 21 Heritage Reporting Corporation 22 23 i 24 25 Oi k l.2 Heritage Reporting Corporation (202) 628-4888
s ENCLOSURE 2 ATTENDEES l Public Meeting on Status of Rancho Seco Closure NAME ORGANIZATION Tom Murley NRC/NRR'- Steve Reynolds NRC/NRR/PDV George Kalman NRC/NRR/PDV Jim Partlow NRC/NRR/ADP Gary Holahan NRC/NRR/DRSP Marty Virgilio NRC/NRR/DRSP Stuart Richards NRC/ REGION Y David Boggs SMUD Dan Keuter SMUD Steve Crunk SMUD Mack Cutchin NRC/0CM Ben Hayes NRC/01 Brent Clayton NRC/0ED0 George Knighton NRC/NRR/PDV Jean Lee NRC/NRR/PDV Bill Lambe NRC/NRR/PTSB Richard Bangart NRC/NMSS Myron'Karman NRC/0CM Tim Johnson NRC/NMSS Aqy Almond NRC/NRR/PDV Joe Scinto NRC/0GC Ed Podolak NRC/NRR/EPB David Trimble NRC/0CM Edwin Reis NRC/0GC J. Harold NRC/NRR Robert Wood NRC/NRR/PTSB Dan Martin NRC/NMSS/LLRB Clayton Pittiglio NRC/NMSS/LWMD Steve Lewis hRC/0GC Fred Zoedl ABZ, Inc. David Lewis Shaw Pittman Potts & Trowbridge Lynn Connor The NRC Calendar Eric Hale SERCH/Bechtel Michael Doyle Sacramento Bee Greg Brown Stone & Webster Jim Taylor B&W Elaine Hiruo McGraw-Hill
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