ML13149A117

Transcript of April 3, 2013 Public Meeting to Discuss Southern California Edison'S Proposed License Amendment Request

ML13149A117
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Site:	San Onofre
Issue date:	04/03/2013
From:	Division of Operating Reactor Licensing
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Hall J R
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Download: ML13149A117 (85)

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UNITED STATES OF AMERICA U.S. NUCLEAR REGULATORY COMMISSION PUBLIC MEETING TO DISCUSS SOUTHERN CA EDISON'S PROPOSED LICENSE AMENDMENT REQUEST April 3, 2013 1:00 P.M.

TRANSCRIPT OF PROCEEDINGS Public Meeting

2 APPEARANCES Southern California Edison:

Richard St. Onge

Director of Nuclear Regulatory Affairs, San Onofre Station

Vic Nazareth

Manager of Nuclear Fuel, S outhern California Edison

Ryan Treadway

Regulatory Affairs Manager , Southern California Edison

Michael Short

Steam Generator Recovery Team

NRC Staff:

Randy Hall Senior Project Manager, SONGS Special Projects Branch, NRR

Doug Broaddus Branch Chief, SONGS Special Projects Branch, NRR

Michele Evans Director, Division of Operating Reactor Licensing, NRR

Ken Karwoski

Senior Level Advisor, Steam Generators, Division of Engineering, NRR

Rob Elliott

Branch Chief, Technical Specifications Branch, Division of Systems safety, NRR

Rick Daniel, Facilitator, Office of Enforcement

3

P R O C E E D I N G S 1 RICK DANIEL: Good afternoon ladies and gentlemen. My name is 2 Rick Daniel. This is the Nuclear Regulatory Commission's Category 1 public 3 meeting. This meeting will be between the regulator, the Nuclear Regulatory 4 Commission, and the licensee, Southern California Edison. Southern California 5 Edison requested this meeting because this meeting is a pre-application meeting.

6 It's going to be about the license -- draft license amendment request which they 7 provided the NRC on this past Friday. It's on the NRC website and the 8 presentation that you're going to see t oday is also on the website that was 9 provided on Monday. There's some minor changes between the presentation 10 that was sent to us on Monday and t he one you're going to see; very minor 11 changes, so I don't think it will make that much difference.

12 This is a meeting where we're not going to get deeply into the RAIs, 13 request for additional in formation -- we've had other meetings on those --

14 however, there will be some RAI discussion pertaining to this draft license 15 amendment request. So, but for the most part I'm going to keep the discussion 16 on the topic of this meeting.

Now we're not going to get out in left field, right field, 17 or whatever. So this is part of the normal pre-application licensing process. So 18 we're just going to have brief introductions and then I'm going to talk a little bit 19 about the format. Before we get into intr oductions I'm going to -- Michele Evans, 20 director of operating reactor license -- director of operating reactor licensing is 21 4 going to address us. I knew I' d fumble over that one.

1 MICHELE EVANS: Afte r the introduction --

2 RICK DANIEL: Okay. Why don't you guys introduce -- Southern 3 California Edison, why don't you introduce yourselves first?

4 RICHARD ST. ONGE: Okay, good a fternoon I'm Richard St. Onge.

5 I'm the director of Nuclear Regulator y Affairs at the S an Onofre Nuclear 6 Generating Station.

7 RICK DANIEL: Vic?

8 VIC NAZARETH [spelled phonetica lly]: I'm Vic Naza reth. I'm the 9 manager of Nuclear Fuel at S outhern California Edison.

10 RICK DANIEL: Ryan?

11 RYAN TREADWAY: I'm Ryan Treadway. I'm the reg affairs 12 manager at Southern California Edison.

13 MICHAEL SHORT: Michael Short, member of the Steam 14 Generator Recovery Team at Sentinel [spelled phonetically].

15 RICK DANIEL: Okay , now the NRC folks.

16 RANDY HALL: I'm Randy Hall, the senior project manager at the 17 SONGS Special Projects Branch.

18 DOUG BROADDUS:

Doug Broaddus, I'm the branch chief for the 19 SONGS Special Projects Branch.

20 MICHELE EVANS: Yes, and I'm Michele Evans, director of the 21 Division of Operating Reactor Licensing in NRR.

22 KEN KARWOSKI: Ken Karwoski, Senior Level Advisor for Steam 23 Generators.

24 ROB ELLIOTT: I'm Rob Elliott. I'm the tech spec branch chief.

25 5 RICK DANIEL: All right, thank you very much. See that was even 1 a mouthful title for yourself, right? I should've let you do it in the first place. So, 2 Michele, why don't you start us off with an introduction there?

3 MICHELE EVANS: First of all I'd like to welcome everybody in 4 attendance today, especially Southern California Edison, the NRC staff, 5 interested stakeholders, and members of the public who are here in person and 6 on the telephone. I believe this is also being web-streamed, correct? So thanks 7 for coming in everyone's interest in this topic. As Rick, our facilitator, has 8 indicated, this is a pre-submittal meeting to discuss Southern California Edison's 9 draft license amendment request. The draft license amendment request 10 addresses proposed technical specification and license condition changes for 11 SONGS Unit 2. The licensee intends to provide a presentation and details of 12 their draft license amendment request. T he nature of a pre-submittal meeting 13 allows for discussion, and questions, and clarifications to occur between 14 Southern California Edison and the NRC staff. Because open exchange of 15 information is the purpose of today's meet ing, I encourage both parties to actively 16 engage in the dialogue as needed. As a pre-submittal meeting, no decisions will 17 be made at today's meeting and we can discuss next steps in the schedules at 18 the end of the meeting, as appr opriate. I think at this po int we're ready to turn it 19 over to Rich St. Onge to begi n their presentation.

20 RICK DANIEL: Rich before you start, I want to let Doug's --

21 DOUG BROADDUS: Actually I wa s just -- did you have any other -

22 - you wanted to go over --

23 RICK DANIEL: Just format --

24 DOUG BROADDUS: Forma t? Why don't you go ahead.

25 6 RICK DANIEL: Okay --

1 MICHELE EVANS: Yeah.

2 RICK DANIEL: Let me talk a little bit about the format of this 3 meeting. And ladies and gentlemen on the phone we also want to welcome you.

4 We're really glad you're here with us somewhere we can't see you, but you can 5 see us, but we're very -- we're happy you're here.

6 Let me go over the format a littl e bit. Southern Ca lifornia Edison's 7 going to give a brief presentation, and the first part of this meeting is going to be 8 between the licensee and the regulator. T hey're going to give a presentation and 9 as we go through their slides the NRC may make comments, it may make 10 questions, you'll hear some discussion back and forth. At the c onclusion of that, 11 when we get through that presentation, and all the technical discussion back and 12 forth, we're going to open up the phone lines and we're going to take questions 13 from those of you of the public that might be her e with us today and folks on the 14 phone. Okay? So that's how things ar e going to go. Doug? Why don't you go 15 ahead -- 16 DOUG BROADDUS: Actually, we're going to go ahead and --

17 MICHELE EVANS: Yeah.

18 RICK DANIELS: Okay.

19 DOUG BROADDUS: Come on over here, Rich.

20 RICK DANIEL: Okay. Go ahead, Rich.

21 RICHARD ST. ONGE: Okay. Thank you very much. Again, 22 Richard St. Onge, director of Reg Affairs at San Onofre. I really appreciate you 23 all coming and spending time with us th is afternoon on this very important 24 subject. I'm here, as you can see, with a small team of folks from San Onofre to 25 7 go over questions and just have a discussion about the license amendment. Can 1 I have the next slide please?

2 So we've got an agenda there broadly laid out for you where I'll 3 provide just a few moments of comment s and then I'll turn it over to Mr.

4 Treadway. We will go through the details of the license amendment request 5 having dialogue as we go. And then we hav e some questions at the end that we 6 would like to present to the stuff jus t, again, for discussion purposes. And then, 7 again, I'll end with just a few closing remark

s. So that's where we intend to go 8 today. Next slide, please.

9 So the purpose the meeting, again -- we'll have a discussion for 10 why Edison's making the submittal. That

's part of why we're here. We also 11 really look forward to technical discussion on procedural matters as they relate to 12 the proposed amendment. We've got a few questions as I indicated that we'd 13 like to talk to you about. Also talk about the scope and content of proposal.

14 That'll be the bulk of the discussion. Next slide, please.

15 Little background information: I thin k most of the folks in the room 16 know, but on January 31 st , 2012, after 11 months of operation, our SONGS Unit 17 3 experienced a small steam generator tube leak. Subsequent inspections 18 revealed extensive tube-to-tube wear in a small concentrated part of both of the 19 Unit 3 steam generators. Ou t of an abundance of caution, our Unit 2, which was 20 preparing a return to service after a 21 month run in a successful refueling 21 outage, Unit 2 was held offline while t he problems at Unit 3 were better 22 understood. SCE gathered the best indus try experts and formed a technical 23 team that examined both Unit 3 phenomena and the potential impact of the 24 problem to the Unit 2 generat ors. As most of us k now, Unit 3 had experienced 25 8 Fluid-Elastic Instability. This was a previously unseen phenomenon in 1 commercial u-tube steam generators. A nd again that was in the in-plane 2 direction. After several months of examination and preventative actions to 3 ensure Unit 2 would not experience FEI, SCE submitted its CAL response letter 4 on October 3 rd , 2012. That letter provided the in sights of what actually occurred 5 in Unit 3 which caused the FEI condition and it proposed corrective actions that 6 would prevent FEI from occurring in Unit

2. These actions are outlined in the 7 return to service report which was included in the October 3 rd CAL response, and 8 in that response is when we first propos ed running the unit at 70 percent power, 9 which of course is a subject of this license amendment request.

10 Currently NRC has issued 72 requests for additional information 11 regarding the return to service re port. Of the 72, 68 have been formally 12 responded to. We expect to have the other four out in about a week's time. Of 13 particular interest today is RAI number 32, we'll spend a little bit of time on that 14 and have again some questions there we'd like to go over with the st aff. It is our 15 intention to return Unit 2 to service at 70 percent power in time for the Southern 16 California peak electrical usage peri od. This traditionally starts June 1 st, so that's 17 the date that we're looking for a potentia l restart of the unit. This is needed to 18 ensure good reliability and stability in the Southern California ar ea. Next slide, 19 please. 20 So a little recap on RAI 32: In our response to RAI 32 there really 21 were two questions we answered. First was the question around compliance 22 with Tech Spec 5.5.2.11 Bravo 1. This we answered in a manner that provided 23 for the operational assessment determining what the power level needed to be to 24 operate safely for the next operating period. The second part of that was the 25 9 operational assessment tool -- I'm sorry. The second part of that was providing 1 an operational assessment at a 100 percent power whereas the other OAs were 2 at 70 percent power, so t hat has been provided to the NRC staff and, of course, 3 remains under review with the staff right now. In order to ensure the appropriate 4 regulatory actions are underway to support retu rn to service of our Unit 2 facility 5 for that peak summer demand period, we are considering today a license 6 amendment request to be a parallel path to ge tting the unit returned to service. I 7 think you all understand that it's a proposed submittal at this point. If the NRC 8 determines that the previous supply of 100 percent OA is sufficient to 9 demonstrate compliance for that tech s pec 5.5.2.11 Bravo dash 1, then this 10 amendment would be withdrawn by SCE. And with that I'd like to transition to 11 Mr. Ryan Treadway, again, who's our m anager of regulatory licensing at San 12 Onofre. 13 RYAN TREADWAY: Okay, thanks Rich. The next couple of slides 14 that you'll see here provide an outline of the proposed license amendment. For 15 several months, as you know, a team of experts has worked with SCE's 16 engineering team and determi ned that operation at 70 per cent power will prevent 17 loss of tube integrity due to fluid-elastic instability. Very simply put, the lowering 18 power has a direct effect on the thermo-hydraulic conditions affecting the tube-to-19 tube wear in the steam gener ators. And we have dete rmined that operation at 70 20 percent power will ensure the steam generators operate safely. Also we 21 understand to address this change associ ated with operation at 70 percent 22 power a license amendment is required. Next slide.

23 So SCE has proposed a license amendment for operation at 70 24 percent power which allows consistency for the submittal that we provided on 25 10 October 3 rd: the CAL response letter and the retu rn to service report. And the 1 changes made to the license and the associat ed tech specs are also consistent 2 with this submittal. Because this proposed license amendment is a temporary 3 amendment for cycle 17 only, we have propo sed a footnote change to both tech 4 spec 5.5.2.11 and the license condition for maximum power level. Next slide.

5 So what we've put together her e in our proposal, in our license 6 amendment, its changes to both that tech spec 5.5.2.11 for the steam generator 7 program and the license condition. We feel that this was conservatively done in 8 the event that NRC's review of the 100 percent OA is not complete to support the 9 June 1 st restart date. At this point, we understand that both our success path, 10 either completion of the 100 percent OAs reviewed and approved by the NRC 11 staff or a license amendment to address both the conditions in tech spec 12 5.5.2.11, are complete. This proposed license amendment to both 5.5.2.11 and 13 the license are for cycle 17 only and we've also incorporated PRA comparative 14 analysis for operation at 70 percent power and 100 percent power and have 15 concluded that the steam generators in t he plants are safe to operate. Next 16 slide. 17 The specific changes to the tech specs is what this slide provides 18 an overview for. This is the steam gener ator program technica l specification and 19 it clarifies that normal, full power operat ion is limited to 70 percent power; again, 20 which is consistent with our CAL respons e and our return to service report.

21 Again, we have determined that the license amendment is temporary until the 22 final power level at which Unit 2 can oper ate is determined. Therefore the final 23 power level that we will be determining will be addressed in cycle 17. Next slide.

24 Now that I've covered the specific changes addressed in the 25 11 proposed license amendment, I w ould like to provide an overview of this LAR.

1 Specifically for the license condition consistent with the tech spec, we propose 2 not to operate in excess of 70 percent power for cycle 17. The changes to the 3 license condition are, again, consistent with what was outlined in the change to 4 tech spec 5.5.2.11. The basis for our conclusion and the proposed license 5 amendment is supported by, it is safe to operate at 70 percent power. The basis 6 for the conclusion is that operation at 70 percent power reduces the thermo-7 hydraulic conditions in t he steam generator and prevents fluid-elastic instability, 8 which is supported by our CAL response and return to service report. The 9 technical basis for both these conclusions has been provided, as discussed 10 previously, in the CAL response letter and the return to service report.

11 Okay so going on to the -- on slide 11, the changes to tech spec 12 5.5.2.11 address the questions that were raised in RAI 32. In addition, these 13 changes align with the proposed changes to our tech spec and our license 14 condition. As discussed before, the analysis and the evaluations we have 15 completed in the CAL response and the re turn to service report demonstrate we 16 are safe to operate at 70 percent power. The CAL and return to service report 17 specifically address the acti ons that are necessary to ensure tube integrity and 18 the steam generator tube integrity requirements are met. We have completed a 19 comparative PRA analysis for operation at 70 percent power and 100 percent 20 power and these conclusions support the license amendment. Next slide.

21 So you can see here in the no signi ficant hazards consideration, we 22 have concluded that there is no significant increase in the probability of a 23 consequence previously analyzed. Specif ically, we have evaluated the steam 24 generator tube rupture and the main st eam line break-induc ed tube rupture 25 12 event, as well as other design basis accidents and determined there is no 1 significant increase in the probability of a previously analyzed event. We have 2 also concluded that there is no possibility of a new or different kind of accident 3 introduced because of this amendment. Based on our analysis, we have 4 determined that the thermo-hydraulic conditions that caused fluid-elastic 5 instability do not exist at 70 percent power.

And lastly, we concluded that there is 6 no change within this license amendment that's proposed that involves a 7 significant reduction in margins of safety. The proposed license amendment 8 incorporates changes for operation at 70 percent including plant safety system 9 changes and procedure changes necessary to operate at 70 percent and they do 10 not introduce a significant reduction to safety. Next slide.

11 In the proposed license amendment, you'll see a commitment, and 12 it specifically reads that we will submit and obtain NRC approval of -- with the 13 license amendment request for long term continued operation beyond cycle 17.

14 So with that, that provides a synopsis and an overview of the proposed license 15 amendment, and at this time we'd like to offer up any questions that the NRC 16 may have with this proposal.

17 RICK DANIEL: NRC folks, questions.

18 MICHELE EVANS: Want to start?

19 ROB ELLIOTT: Have any questions about --

20 MICHELE EVANS: In general?

21 ROB ELLIOTT: Are we going to go through slide by slide just --

22 your slides have specific topic areas. Do you want to --

23 RYAN TREADWAY: Yeah.

24 ROB ELLIOTT: And we do have questions regarding scope. Do 25 13 you want me to raise that now or?

1 RYAN TREADWAY: Well we can do it by the slides that we've 2 outlined that go by topic if you'd like.

3 RICK DANIEL: Or go slide by slide and take questions --

4 ROB ELLIOTT: Yeah.

5 RICK DANIEL: -- by the slide then.

6 ROB ELLIOTT: We can do that.

7 RICK DANIEL: All right. So no questions so far, right? All right.

8 MALE SPEAKER: Rick.

9 RICK DANIEL: Yes?

10 MALE SPEAKER: Microphones?

11 RICK DANIEL: Okay. Yes, w hen you -- when you speak turn the 12 microphone on. Doug, did you have some --

13 DOUG BROADDUS: From , I mean, I think you're going to -- so are 14 you, you're going to be going through the questions that are in the topics --

15 RICK DANIEL: The topics --

16 DOUG BROADDUS: -- down here?

17 RYAN TREADWAY: The topics will address the questions that we 18 have for the staff.

19 DOUG BROADDUS: Okay, yeah, and I think, yeah, I think the 20 questions that I have will be covered in --

21 RYAN TREADWAY: Related?

22 DOUG BROADDUS:

So go ahead.

23 RYAN TREADWAY: Okay, so with that we'll proceed, and if you go 24 to the next slide you see the topic we hav e there is maximum power. So we had 25 14 a question, does the staff see any further information that's needed beyond what 1 was provided in reference to RAI 11 t hat is needed for the evaluation or the 2 review of this tech spec change?

3 ROB ELLIOTT: Not at this time, from a preliminary view --

4 RYAN TREADWAY: Okay.

5 ROB ELLIOTT: -- review of it.

6 DOUG BROADDUS: The one

-- when you're talking about 7 maximum power, I'm assuming that woul d also encompass the analysis of the 8 change of the power level from 100 perc ent to 70 percent. You referenced RAI 9 number 11. In our previous RAIs ther e was a 12, 13, and 14 as well, also 10 address that topic area. And I'm wonder ing why you're not including as RAI 11 number 11, the responses to that as part of this overall. And if there's a specific 12 basis for why you don't believe that it's not applicable to this request --

13 RICHARD ST. ONGE: Just to clarify, so I think what I heard your 14 question was, you know, had we considered submitting 12, 13, and 14 and 15 decided not to do that. Is that --

16 DOUGH BROADDUS: Is that -- yeah.

17 RYAN TREADWAY: So we specifically chose to include RAI 11 by 18 reference due to the questions that were coming, you know, back and forth 19 dialogue between the NRC staff and Southe rn California Edison. So we 20 understand that there are some additional related questions addressed in RAIs 21 12 and 13 and possibly 14. At this time we felt that the license amendment and 22 the no significant hazards consideration and the inclusion by reference of what 23 we supported in the reference documents was satisfactory; so if the NRC sees 24 that additional RAI responses may be necessary we can include them by 25 15 reference as well.

1 DOUG BROADDUS: Okay, yeah, and I believe you got some 2 questions later on about corporation by reference and so I'll discuss that when 3 we get to that point.

4 RANDY HALL: Yeah, just to follow up, questions 11 through 14 5 were generated along the theme of performing confirmati on if you will that the 6 accident analyses and tech specs were unaffected by the proposal to operate at 7 70 percent. In your RAI 11 response, which we understand you've just recently 8 revised, you have a table that captures I gu ess the extent of t he review you did of 9 the UFSAR and the tech specs to evaluate the impacts. Does that, at least in 10 part, address the responses to the other questions, 12, 13, and 14 in terms of --

11 how would you measure flow, I believe, was a focus of question 12.

12 RICK DANIEL: Vic?

13 VIC NAZARETH: Yeah, RAI 11 is all encompassing, okay?

14 Twelve, 13, 14 is a little more detailed basically on specific aspects of RAI 11.

15 So RAI 11 incorporates the entire accident analysis, okay? RAI 12 goes into 16 some specifics about uncertainty and t hen RAI 13 talks about LOCA in more 17 detail, okay? So they're all incorpor ated through RAI 11, but RAI 11 has the 18 entire what we do for 70 percent power. So we can incorporate them specifically 19 if you like and just add them on or -- but they are incorporated through RAI 11.

20 RICHARD ST. ONGE: Yeah, again, if it supports the staffs review, 21 we would be willing to include those other responses, so if that's what we're 22 hearing we'll do that. If you need some more time and you want to look at a little 23 bit differently and then have a discussion over it later we can do that too.

24 DOUG BROADDUS: What I would say is just on our quick review 25 16 from the tech staff standpoint, the question was really, you know, they appeared 1 to be applicable and so we wanted to under stand if there was a specific reason 2 why they had been excluded. If there was just because you thought 11 covered 3 everything -- I mean it sounds like inco rporating those would probably be an 4 appropriate thing to do.

5 RYANTREADWAY: Okay are there any other questions associated 6 with the topic of maximum power?

7 MICHELE EVANS: No.

8 DOUG BROADDUS: No, I guess not.

9 RYAN TREADWAY: Okay, so the next slide in the topic we 10 proposed to discuss is RAI 32. Again, like was discussed in the presentation, we 11 understand that there are two paths to address the concerns and the questions 12 raised by the authors of RA I 32. One would be a 100 pe rcent OA that's reviewed 13 and approved by the NRC, the other would be an amendment to make that 14 change. And so would the proposed amend ment that's been provided, do the 15 proposed tech spec changes provide a response that is adequate to address the 16 questions raised in RAI 32?

17 DOUG BROADDUS: I think I have to use my normal canned 18 response which is, we can't provide any determinations at this particular time, 19 obviously, as to the adequacy of the am endment, whether we would be able to 20 approve that or not and what we will be doing -- we'll be doing a -- once we 21 received the actual request we'll be doing an acceptance review to ensure that it 22 has all the information we need in order to complete our review. So we will be 23 able to give specific feedback at that poi nt as to whether it contains that 24 information. As to whether it adequately addresses RAI 32, that's not something 25 17 we can -- till we complete the revi ew we wouldn't be able to make that 1 determination, the full review of it.

2 ROB ELLIOTT: Well I will say tha t, that is what the RAI is asking 3 you there. Give us an assessment of a 100 percent, operation at 100 percent 4 power, or --

5 RYAN TREADWAY: Right.

6 ROB ELLIOTT: -- or you'll need a license amendment. So you're 7 correct that those are the two paths that RAI 32 is asking you about.

8 RYAN TREADWAY: Okay, so I guess the follow would be are 9 there any other changes that you see would be necessary to facilitate the review 10 for RAI 32?

11 ROB ELLIOTT: This is where I th ink I was going to talk a little bit 12 about scope. You reference -- you incorporat e by reference RAI 11, which, in the 13 discussion I understand you took a look at how the change in power level would 14 change LCOs and surveillances. The question we have is did you also look at 15 conditions and actions? It looks like ther e's potential where there's -- where you 16 have action statements that are tied to gr eater thermal power, that you need to 17 make sure you either adjust them or c an you do them and remain in compliance 18 with your tech specs.

19 RYAN TREADWAY: A comple te review was done and for the 20 details I'll turn to Vic to provide a response.

21 VIC NAZARETH: The answer to your question is yes. We looked 22 at all of them. We looked at the acti ons and we looked at everything that's 23 related to power, okay, and so we did a thorough review of all of that. That's 24 correct.

25 18 ROB ELLIOTT: That's the only question I had.

1 RYAN TREADWAY: Okay. Okay, any other questions for the topic 2 of addressing RAI 32? Okay. Next sli de we've got, kind of segued into this 3 already, but the scope of the license amendment request.

So that one particular 4 question was already answered. With the scope of the lic ense amendment that 5 we proposed, is this appropriate for bot h the tech spec 5.5.2.11 and the license 6 condition changes that we are proposing to make? You know, more specifically 7 you talked about the two paths in RAI 32, and so you see we have a proposed 8 license amendment put together that has changes to bot h tech spec 5.5.2.11 and 9 the license condition. So I understand that you can't make any pre-decision or 10 determinations yet, but would they address the scope of what is considered to be 11 the issue at heart of RAI 32?

12 ROB ELLIOTT: Well there's ov erlap between the questions here, 13 and part of the scope question does RAI also provide is the questions of RAIs 12, 14 13, 14 having relevance also to the overall basis for the amendment.

15 RYAN TREADWAY: Okay.

16 DOUG BROADDUS: I want to make sure we understand 17 specifically what you're trying to ask in this particular instance. The question in 18 RAI 32 was, you know, demonstrate complia nce with the tech spec or provide an 19 OA that would essentially demonstrate compliance with the tech spec. Is your 20 question, you know, is this a way to be able to demonstrate compliance? Is that 21 what you're asking? You know, by the manner that you've requested in the 22 amendment --

23 RYAN TREADWAY: Again, referencing back to the two paths to 24 address RAI 32, if we propose a license amendment and you see the changes in 25 19 front of you specific to tech spec 5.5.

2.11 for the steam generator program and to 1 the license condition would there be any other changes that would be necessary 2 to address the concerns raised with RAI 32 or the question raised with RAI 32?

3 So it gets to the heart of t he compliance aspect that's, you know, ultimately what 4 we're after. But the proposed changes we have to tech spec 5.5.2.11 and the 5 license condition we've determined woul d be satisfactory to demonstrate 6 compliance, and obviously we want ensur e that there are no additional changes 7 that would be needed to be addressed as well.

8 DOUG BROADDUS: Okay. I me an the purpose of RAI 32 was, as 9 I indicated, to address compliance with the te ch spec. With what the draft you've 10 given to us, you know, changing the power level to 70 percent and the tech spec 11 to 70 percent then the requirement woul d be to show -- you have to meet 12 compliance, be able to demonstrate complia nce with that revised power level.

13 That's, so I mean, believe that's -- I mean I think that's what you're asking. So it 14 appears that wouldn't -- I mean, if that's what your intent is, that that wouldn't -- I 15 would address that particular issue. But we still have to look at the law. I mean 16 there's more to it than just does it demonstrate compliance and with respect to 17 the 70 percent, it's, you know -- what are the implications of the change to a 70 18 percent power and longer term operation at 70 percent? And that's where Rob 19 was getting at with -- we need to make sure we -- that you fully address and 20 considered the implications at 70 percent power for all operations, all tech specs, 21 all analyses and such. And so that's goi ng to be part of our review as well.

22 ROB ELLIOTTT: Just would add, after looking at it with a day or 23 two days -- whatever we've had. No, we haven't identified other specs, if that 24 what you're getting to -- that we woul d say you need to address this. That's not 25 20 to say that when we were doing more thorough review, we won't, but we haven't 1 identified anything through a cursory review.

2 RYAN TREADWAY: Okay, appreciate that.

3 RANDY HALL: I think a variation on that is if you're asking us was 4 there more to RAI 32 than you've perceiv ed in trying to address it in several 5 different ways. I think the answer is no, we'll have to look at the LAR on its 6 merits, but did the staff have something si gnificantly different in mind than what 7 you're proposing. I don't there was any assumption that was not conveyed by 8 the staff regarding compliance with the --

9 RICK DANIEL: Nothing at this time, then, right? So we can move 10 on. 11 RYAN TREADWAY: Okay. Apprecia te that response. If there are 12 no other questions for this topic, we c an go ahead and go to the next slide. And 13 this topic is License Amendments, Request Process Issues. And so this kind of 14 gets into the incorporation by reference topic. So, the abil ity to incorporate 15 what's already been done and reviewed by the NRC staff by the CAL response 16 and return to service report Will this sati sfy the ability of the NRC to complete 17 their review of this proposed license amendment?

18 DOUG BROADDUS: I think from the standpoint of incorporation by 19 reference, I think the feedback that we would provide is we need to know 20 specifically and clearly what is the -- what are you in corporating by reference?

21 It's in the draft that we got. It wasn't always clear to us that what exactly you --

22 everything that you were referencing. You know, there were some cases where 23 it seemed like you might be referencing, in cluding by reference everything that 24 was submitted in the previous, you know, March 3 rd [October 3 rd] submittal and 25 21 all the RAIs and other cases. That there's only limited amount of information 1 from that. You made previous commitments as well in that submittal and it's not 2 clear whether those commitments are also being incorporated by reference into 3 this LAR. So it -- we need to make sure it

's clear to us that, you know, what it is 4 that you plan on incorporating by reference.

Otherwise it -- you know -- if it's 5 everything, it's a much broader scope. If it's more limited, you know, then that 6 wouldn't limit that --

7 RYAN TREADWAY: We see this as two distinct processes, and so 8 for the license amendment, we provided a ju stification for operation at 70 percent 9 power. We're making a change to tech spec 5.5.2.11 and in our license condition 10 to operate at 70 percent power. And we believe we've included the technical 11 basis and justification within the proposed license amendment and the 12 determination for no significant hazards consideration within the proposed LAR.

13 Separate from that, we know that to meet the steam generator tech 14 specs, we have to complete the oper ational assessment and the tube-to-tube 15 wear that was -- the tube-to-tube wear issue that wa s identified for the steam 16 generators. So that is a separate action that's bei ng addressed with the CAL and 17 the return to service report. And the te chnical justification for addressing tube-to-18 tube wear and fluid elastic instability is separate in our minds from the license 19 amendment to operate at 70 percent power.

20 DOUG BROADDUS: Yeah. An d I don't think that there was a 21 question from our mind as to, you know, the distinction between those two types 22 of activities as well. I mean, a lic ense amendment request and a CAL process 23 are two distinct activities, so. But I think it's for our purposes to understand what 24 information you believe is necessary to support the LAR and the license 25 22 amendment request. It's important for you to clearly identify and make sure it's 1 very clear to us -- you know -- whic h information you are incorporating by 2 reference so that we can know which info rmation to look at. And, you know, if 3 there's additional information that we need, we would ask RAIs in that case, so.

4 RICHARD ST. ONGE: Thanks for that clarification, Doug. I think 5 we understand what you're looking for.

6 RYAN TREADWAY: Okay, so with the regards to the license 7 amendment request process, are there any other ques tions that need to be 8 addressed at this time?

9 RICHARD ST. ONGE: Just maybe one thing to put on the table, 10 Ryan. I think we went over pretty quickly, but this is a one-cycle license 11 amendment request. I think you understand that. And it would be our intention 12 during that operating cycle -- cycle 17

-- we would continue to work with 13 Mitsubishi and our experts and determine th e long-term power level would be.

14 Perform or create another license amendment request and then submit that to 15 you in sufficient time that we would establish what the long-term power level of 16 the plant would be for cycle 18 operation. So I just want to make sure I was clear 17 on the --

18 RANDY HALL: As you stated, Rich, that your intent is to request 19 this license amendment for cycle 17 -- a full fuel cycle. Do you have an 20 estimation at this point, how many act ual start-ups and shut-downs that might 21 include or additional period of operation beyond this five months, or...

22 RICHARD ST. ONGE: Ask Mr. S hort to answer that question.

23 MICHAEL SHORT: The question is how many start-ups and shut-24 downs are we likely to go through during t he timeframe of cycle 17. Cycle 17 will 25 23 be approximately two years long at 70 perc ent power. So if you assume for a 1 moment, I think conservatively that the five-month operating interval is sustained 2 throughout that cycle -- could be as many as four or five start-ups and shut-3 downs over that period of time. And that would be, I think, a conservative 4 estimate of the number.

5 DOUG BROADDUS:

Along those lines, again, getting back to my 6 previous question as well. In the res ponse that you provided to RAI 32 there --

7 the first path of the response that you provided to RAI 32, there was an approach 8 described on how you plan to go forwar d with operation, you know -- and I had 9 asked the question at the time, you know, were you planning to make those 10 statements commitments. And so I guess the question still applies here. You 11 know, I think my understanding of the re sponse was that it would depend upon 12 whether or not we agreed, I guess, at the end, you know, to allow -- to restart and 13 such. So I am trying to understand, st ill, you know, are there going to be 14 additional commitments beyond the one to submit a license amendment request 15 for -- prior to cycle 18? Or are the commitments part of this LAR request, or are 16 they part of the CAL response? And how do they kind of work together?

17 RYAN TREADWAY: For the actions we've outlined and that portion 18 of the response for RAI 32, those are actions that we're obviously willing to 19 commit to take. Fo r the proposed license amendment, we

've only identified this 20 specific commitment that's necessary to support the NRC's review of this 21 proposed licensed amendment. And with those actions that we outline in our 22 response, we obviously wouldn't commit to. The vehicle at which we decide to 23 commit to in this case would be the CAL re sponse. We also knew that some of 24 those actions that we outlined in the RAI 32 response still had some critical 25 24 decisions that influence the outcome or the final language in those commitments 1 as we move forward.

2 But to answer your question, we feel that the CAL response would 3 be the vehicle on which to address those commitments, if necessary for a long-4 term continued operation for the proposed license amendment -- the one 5 commitment you see identified as the one that we felt was necessary to support 6 the NRC's review.

7 DOUG BROADDUS: Okay. And from that perspective to -- a one 8 time, temporary change generally, you know , when we've handled these types of 9 requests before, previously, with a one-ti me change, there was something that, 10 you know, there's something that's goi ng to end at the end of that temporary 11 period that would either allow you to go back to normal operations or there would 12 be some type of commitment of, you know, that there would be a change. In this 13 case, if I'm understanding correct ly, that it would just be to submit another LAR.

14 At the end of the period, t hough, what would your expect ation be, or what do you 15 perceive at the end of that time period

-- the end of cycle 17, you know, if you 16 haven't submitted a LAR at that point or you've submitted a LAR to us -- a license 17 amendment request to us, and we haven't fi nished it yet. What do you see --

18 foresee the action that would be taken at that point? What are you asking for 19 from that perspective?

20 RICHARD ST. ONGE: I think fr om Southern California Edison's 21 perspective, we would give you lots of time to look through and approve that 22 license amendment request. So we understand the urgency of getting that cycle 23 18 -- if I can call it that -- license amendm ent request in front of you as quickly as 24 possible. Now we do want to inform that license amendment request for full --

25 25 you know, long-range maximum power bas ed on the five-month operating period 1 that Mike referred to just a moment ago. So, you know, it's not like we'll give it to 2 you at the very beginning of the cycle, bec ause we do want to see the results of, 3 you know -- we expect the five months to confirm our analysis.

That's what our 4 expectation. And if there's a change to that, then we'll have to regroup. But at 5 this point, we believe it'll confirm out analysis, and we'll be prepared to come 6 forward with a long-term LAR sooner than later.

7 RYAN TREADWAY: In addition to that five-month operating cycle -

8 - confirming and validating our initial analysis -- there are other ongoing actions 9 that we're working with MHI to address continued operation beyond cycle 17. So 10 both of those would factor and feed into that decision, but, you know, like Rich 11 said, once we get through the first five-month operating window, and those 12 results come back and confirm and validate our initial results, we'll have a better 13 idea of what the final LAR would be and the proposed changes necessary to put 14 in front of the NRC for review and approval. But we wanted to also highlight the 15 fact that there are additi onal actions we're consider ing for long-term continued 16 operation.

17 RANDY HALL: I think you mentioned earlier that if the staff accepts 18 the 100 percent OA, that y ou would withdraw the amendm ent request that we're 19 contemplating, would the commitment st ill stand? Would it be captured in the 20 context of the CAL response, or?

21 RYAN TREADWAY: If at such time that the NRC approves 100 22 percent OA and we demonstrate compliance, we would have to address the 23 commitment made in the proposed license amendment, but we -- you know, at 24 that point in time, we wouldn't know exactly what the commitment would change 25 26 to. It would depend on, you know, the re sults and the conclusi ons made from the 1 NRC staff's review of the 100 percent operational assessment.

2 RICHARD ST. ONGE: Yeah, we've talked about that, Randy, and 3 you end up in a cycle of continuing to do 100 percent OAs indefinitely. And so 4 we'd have to look at the sustainability of that. It's just that in our mind, 5 sustainable or not -- and the answer was not, then I think we're back to a license 6 amendment.

7 RYAN TREADWAY: So, to address your question specifically, 8 there may be a change to the commitment necessary if the staff approves 100 9 percent operational assessment.

10 RANDY HALL: Thanks.

11 RICK DANIEL: Any other questions, comments from the NRC? All 12 right. Go ahead.

13 RYAN TREADWAY: Okay, the la st slide and the last topic for 14 discussion that we had was the tec hnical basis that was provided and 15 documented for the no significant hazards consideration. And so we've, you 16 know, touched the aspects of the no significant hazards consideration and the 17 basis. And I guess we wanted to broach the topic. Is this satisfactory for the 18 NRC's review that the inclusion by reference and the supporting basis that we 19 have? Supports our no significant hazards consideration, or is there additional 20 information at this point in time, preliminary that the NRC feels is necessary to 21 support that conclusion?

22 DOUG BROADDUS: Yeah, I thin k on that one -- again, we can't 23 provide a determination -- any decisions at this point. However, we have not --

24 with our preliminary review, we haven't identified any issues associated with that.

25 27 RYAN TREADWAY: Okay, that was the question we had on the 1 table where the no significant hazards consideration.

2 RICHARD ST. ONGE: So our next slide is a closing slide. But 3 before we go there, are t here other questions that t he staff has for Edison?

4 KEN KARWOSKI: Yeah, I guess as you were going through your 5 presentation, something came into my mind. As you know, your technical 6 specifications have reporting requirement s for the steam generator results.

7 Those typically say 180 days following entry into mode 4. Given that you're only 8 going to be operating five months, that would mean that report would come in 9 basically -- it could potentially be in your second five-month interval if we were to 10 approve this request or the return to power report. Have you given any 11 consideration in this request to revise that reporting requirement?

12 RYAN TREADWAY: And at this point in time, our review has 13 concluded that there w ould be no necessary changes to that 180-day report 14 requirement. So once we enter mode 4, that would start t he clock for our 180-15 day report, and we woul d provide that --

16 KEN KARWOSKI: Okay, you rec ognize those results will come in 17 after -- you would already potentially star ted another interval of operation.

18 RYAN TREADWAY: Correct.

19 KEN KARWOSKI: Whereas currently the 180 days gives sufficient 20 time for the staff to take a look at it before you complete your current operating 21 cycle. That'd be a little inconsistent.

22 RYAN TREADWAY: Okay. I un derstand the question that you're 23 raising and we'll have to look at that a little more closely.

24 RICHARD ST. ONGE: Let us take that one off line here, Ken, and 25 28 we'll talk internally. It is a good question. It sounds like what the NRC would be 1 looking for is a report sooner, right?

2 KEN KARWOSKI: Yes.

3 RICHARD ST. ONGE: We'll take a look at that.

4 KEN KARWOSKI: Or we would need to understand why you want 5 me to change that requirement.

6 RICHARD ST. ONGE: Okay. All right. Any other questions? Let 7 me move on, then, to my closing remar ks here. I really w ant to thank NRC for 8 this opportunity today. Really apprec iate the candid and insightful feedback 9 we've been getting. It is helpful. This is very important to our ability to, again, to 10 return the unit to service, meet our cust omers' needs. And that's important to the 11 company, important to our customers and our other stakeholders. We look 12 forward to working with your staff and -- y ou know -- should we decide to submit 13 this LAR, which, again we're still under cons ideration, we look forward to working 14 with the staff to iron out any other problems or process iss ues that are out there.

15 With that, I'll turn it back over to Rick.

16 RICK DANIEL: All right. Thank you, Rich. Any closing -- Doug?

17 DOUG BROADDUS: And act ually, I apologize. I did have one 18 additional request. I think you said earlier you were planning to -- have you 19 made a decision that you are going to s ubmit this to us, and when would we 20 expect that?

21 RICHARD ST. ONGE: Okay, very good question. We are in the 22 decision making process right now. And this is part of that, you know. Results of 23 today's meeting, we'll incorporate -- be incorporated into our decision. So we 24 haven't made the decision yet. I expect within a week, we will have made a 25 29 decision and we'll -- and if we have made that decision, we'l l have submitted a 1 LAR to you. So I think in about a week's time, you'll have both a decision and --

2 as well as the LAR, should that decision be affirmative.

3 DOUG BROADDUS: Yeah. The

-- I mean, your timeframe that 4 you specified, you know, June 1 st start-up timeframe. Just from the perspective 5 of processing a license amendment in t hat amount of time -- that short a 6 timeframe is a -- would be a challenge by it self. We also have in parallel the --

7 also the ongoing CAL actions and our revi ews associated with that and finalizing 8 that -- those reviews as well. So ther e are going to be competing priorities for --

9 from that respect as well as, you know, just getting through the -- even from a 10 process standpoint, just going through each of the steps in that timeframe is --

11 will be a challenge.

12 RICHARD ST. ONGE: Sure.

13 DOUG BROADDUS: I just -- you know.

14 RICHARD ST. ONGE: I think we understand the --

15 DOUG BROADDUS: If you're lo oking for a date to that -- the 16 sooner you get something into us, the qui cker we can start working on it. But 17 that -- you know, and I'm not going to ma ke any commitments as to whether or 18 not we can meet that date or not in any way, other than, you know, we typically, 19 you know, when utilities ask for -- a lic ensee asks for a quick turnaround or -- we 20 try to meet their dates as the best we can. But --

21 RICHARD ST. ONGE: So we under stand it's a strain on the 22 resources for the NRC and to the extent we can help in terms of priorities. We're 23 willing to do that. Try to get the license amendm ent to you as soon as we can.

24 That's my commitment.

25 30 DOUG BROADDUS: Okay, all righ

t. With that, from a close-out 1 standpoint, I just wanted to say thank you for coming in and giving the 2 presentation today. I think, you know, we also appreciate getting the materials 3 ahead of time. It gave us an opportunity to look at those and try to see if there 4 are any specific questions that we might hav

e. We did have a few, but in general 5 I think we understand what you're asking for, and we hope -- we've been able to 6 convey what it is we're, you know, w hat else would be needed in order for us to 7 move forward with the review.

8 As you've mentioned, and you re cognized in your presentation, I 9 want to make sure it's clear, you know. The CAL -- the CAL process and the 10 amendment process are two different, distin ct processes. They are -- and they 11 can, in fact, you know, proceed in para llel. As I indicated through -- we'll 12 probably be having the same people workin g on both, so it'll be, you know --

13 they'll be working those in parallel. But they're -- you know -- we -- you know, we 14 are planning to work on both of these going forward. Both the OA as well as the 15 -- any amendment request you might s end it to us in finalizing that.

16 The one thing, as well, is I want ed to just mention that the two are 17 not dependent upon each other. We don't s ee that any -- that a license 18 amendment would be dependent on a CAL or a CAL would be dependent on a 19 license amendment in this case. But I think I -- as you've recognized, completion 20 of both of these actions is necessary.

It's an important component to your ability 21 to be able to restart, and so I think, you know, although from our perspective, 22 they may be independent and can be c onducted in, you know, separate from 23 each other. I understand from your posit ion that you're seeing them as one 24 needing to go forward, so. Wi th that, you know, and I think that's why we do plan 25 31 to work on them concurrently together going forward.

1 But and the one thing I want to make sure is clear as well, we don't 2 necessarily have to complete each of them at the same time as well. And so if 3 we finish one before the other, then that -- it'd just be how it works out. I think 4 that's about all I wanted to say is one --

the other point is we do have a schedule 5 that we've laid out on the -- on our website and such. You know, once we get the 6 LAR and we know, you know, that basically starts the clock from that standpoint.

7 We'll try to make sure that that's updated. We'll also do a review of the schedule, 8 you know, and make you aware of that review of the schedule. And we'll also 9 update that information on the website as well so that we have that information 10 as well as, you know, the current process information in there together. We think 11 that that's important to get that information out both to you as well as to the public 12 and the stakeholders -- the external stak eholders -- so that they understand the 13 process. All right? And I think that's all I had to say -- wanted to say, so.

14 RICK DANIEL: Okay. Is there anything else from either licensee or 15 regulator?

16 RICHARD ST. ONGE: I thin k our team is satisfied.

17 RICK DANIEL: Okay. NRC?

18 MICHELE EVANS: All right. We ll, I'd like to say thank you to 19 Southern California Edison and the vari ous stakeholders who are here today, 20 and also to the NRC staff. Think this has been a good dialogue, and at this point, 21 Rick will move us into the next part of the meeting.

22 RICK DANIEL: All right. Thank you, Michele. So, ladies and 23 gentlemen, this concludes the technical portion and discussion between 24 Southern California Edison and the NRC.

We're going to be opening up the 25 32 phone lines and we're going to be taking questions from the audience. So, 1 operator, I assume you can hear me at this point. Why don't you go ahead and 2 give directions to the folks on the phone and as soon as you do that, we'll wait for 3 you to do that. And as soon as you do that, we'll be starting out with questions 4 here in this room firs

t. So, go ahead, operator.

5 OPERATOR: [inaudible]

6 RICK DANIEL: Okay, thank you, operator. And fr om there, we're 7 going to take a question here in the room first, and we're going to bounce back 8 and forth according to who has questions where. Sir, why don't you stand up, 9 and there's a microphone coming here to you.

And we'll take your question.

10 And, again, ladies and gentlemen, and I ask that you keep your questions and 11 comments contained to the subject at hand -- this draft license amendment 12 request. 13 S. DAVID FREEMAN: My name is S. David Freeman. I was the 14 CEO of several nuclear utilities, including the Tennessee Valley Authority, the 15 New York Power Authority, and Sacramento Municipal Utility District. I have had 16 probably more experience with nuclear pow er as a responsible CEO than anyone 17 in the room. And I must say to you that I find this meeting shocking. It's 18 shocking because it's portrayed as a pub lic meeting, and yet I feel like I am 19 looking through a peephole be hind the nuclear curtain at discussions that are 20 going on, that the public is not participating in. And this is simply a chance for us 21 to see one discussion. But I know these discussions will continue. And the idea 22 that the utility has the right to ask the judges to tell them what they need to 23 supply in order to get approval just st rikes me as unreal.

We're talking about a 24 nuclear reactor with steam generators that are so damaged that no utility -- if it 25 33 were initially trying to get a license -- would come before the Nuclear Regulatory 1 Commission with equipment of that kind and ask for a license. I'm sure that no 2 one in the room would disagree with me.

And my question is this is -- all about 3 paperwork, but, frankly, with the chairperson of your Commission and others 4 talking about transparency and public hear ings, the public is not being heard 5 here today. And there is no public heari ng, and we're talkin g about restarting a 6 reactor that has not been fixed which t he utility admits is br oken. And we're 7 talking about footnotes and paperwork instead of safety. And then you have 8 three judges that are also sitting there tr ying to decide whether your CAL process 9 is a de facto licensing process. And so here, going behind everybody else's 10 attempt to grant people a license without changing anything and without the 11 public having a voice in it. And frankly, I think -- I know everyone here is very 12 sincere in what you're doing. Don't get me wrong. I've been a staff person 13 myself, and I've worked in agencies. And I've worked in utilities.

14 People believe they're doing the right thing. But you folks need a 15 mirror. This is -- this is the opposite of a public hearing, and the idea of restarting 16 this reactor without having the public hearing is an insult to the 6-, 7 million 17 people in Southern Ca lifornia that are scared to death of what's going on.

18 RICK DANIEL: All right. Thank you very much, Mr. Freeman, for 19 your comments and your question. Why don't you folks go ahead and address --

20 MICHELE EVANS: Yeah, I'll just start by thanking you for your 21 comment. And the intent here is not a hearing. As we indicated in the beginning, 22 this is a pre-submittal meeting between Southern California Edison and the NRC 23 to do exactly what we did -- was to allo w them to ask, you know, present their 24 draft license amendment request and have a dialogue with us abo ut the content 25 34 of it, and ask any questions that they may have. Part of our -- you know, as we 1 move forward, the goal here was to have an understanding and maybe share 2 some information to enable us to -- if they do submit it -- to be able to go through 3 a review process in a timely manner. That

's the purpose of this type of meeting.

4 Anyone want to add anything?

5 DOUG BROADDUS: Yeah. From the perspective of -- the second 6 half of what you were addressing, which is, you know, a public participation in the 7 process. That begins, you know, after some thing is actually submitted to us. So 8 once a LAR -- a license amendment request

-- is submitted to us, we'll go 9 through our --

10 S. DAVID FREEMAN: Needs to occur before they get a license.

11 DOUG BROADDUS: We'll go thr ough the process, you know, that 12 -- our defined process, which is to do the 13 S. DAVID FREEMAN: My question, will you guarantee that that 14 real hearing will occur befor e you give them a license?

15 DOUG BROADDUS: A reques t -- a hearing request -- an 16 opportunity for a hearing request will be part of the notice of t he receipt of the 17 application. So, there wil l be an opportunity for --

to request a hearing once we 18 get that -- the request in. And when we issue that, one of our requirements is 19 that there's -- we can't take action until that comment period, which is typically a 20 30-day comment period, is -- ends. So, we won't take acti on until that occurs.

21 S. DAVID FREEMAN:

Guaranteeing we will actually have a public 22 hearing in which our experts can te stify before you make a decision?

23 DOUG BROADDUS: I cannot guarantee that anyone would ever 24 have a hearing because that is not a decision that we make. It is a decision that 25 35 the ASLB makes. The ASLB are the ones who hear the request for the hearing, 1 they hear the -- whether they're --

2 3 S. DAVID FREEMAN: [inaudibl e] before you issue a license 4 amendment?

5 DOUG BROADDUS: We're going to follow our process, which -- it 6 depends upon the outcome of our review, and specifically with the notice of no 7 significant hazards consideration determinat ion. If that is determined that the 8 amendment request meets the crit eria for that, there -- we are -- the regulation 9 specifies that we would proceed without --

even if we have a -- or the amendment 10 request could be issued even if we have a hearing request.

11 RICK DANIEL: And this is a k nown process. It's outlined in NRC 12 regulations. It's on the website.

13 S. DAVID FREEMAN: -- quite we ll known, that's my problem.

14 RICK DANIEL: Pardon me?

15 S. DAVID FREEMAN: The process is quite well known, that's my 16 problem.

17 RICK DANIEL: Okay. Well --

18 S. DAVID FREEMAN: I want to know whether the NRC is actually 19 going to practice what they're preaching now, which is to give the public a right to 20 present testimony and witnesses in contradictory. People -- I believe that these 21 folks believe that reactor sank.

22 RICK DANIEL: Okay.

23 S. DAVID FREEMAN:

[inaudible] self-serving.

24 RICK DANIEL: Sir, I think he answered the question regarding the 25 36 ASLB and there is a process, an ex isting process, and Mr. Broaddus has 1 addressed your question. If you want to discuss it in greater detail, we'll be 2 happy to take it up with you after the meeting. Okay?

3 S. DAVID FREEMAN: We both agr ee this is not a public hearing.

4 RICK DANIEL: That is correct. That is correct, nor was it billed as 5 one. Operator, do you have someone standing by on the phone? We can take 6 your call.

7 Thank you.

8 MALE SPEAKER: [inaudible]

9 RICK DANIEL: All right. Thank you for your question. Mr. St.

10 Onge. 11 RICHARD ST. ONGE: Rick, I think the NRC probably should 12 answer that question. They're asking once y ou're in receipt of the LAR, how long 13 would it take before you had some cert ainty around the June date, is what I 14 heard. 15 MICHELE EVANS: So, the way the process works, they need to 16 submit this amendment, get it in-hous e to us, we need to do an acceptance 17 review, we need to notice the no significant hazards determination in the 18 amendment --

19 DOUG BROADDUS: And t he opportunity for hearing.

20 MICHELE EVANS: -- and an opport unity for hearing, thank you.

21 And there's a -- that comes with a 30-day window once it's posted and noticed, 22 so you have a 30 day window there. And then after that point in time, if our 23 review, you know, if we agree that t he amendment can be i ssued and at that 24 point in time, the earliest we can move forward would be after that 30-day 25 37 window. So, maybe you're talking a week plus 30 days, you know, the 1 acceptance review and the getting it not iced, plus a 30-day window, plus any 2 time on the other end, a few days.

3 DOUG BROADDUS: Yeah, I think the important point is, you know, 4 we'll do our best to try to meet the timeframe that's being requested, but we will 5 take whatever time we need in order to co mplete our review of this request, just 6 as we've indicated previously that we'll take as much time as we need to -- in 7 order to complete the CAL process as we ll. And the one thing that I wanted to 8 clarify is that they are -- you know, as I tried to indicate previously, they are two 9 different processes and so I think -- what -- the caller -- what y ou indicated is this 10 appeared to be a -- an alternative path to get to the same result.

I want to make 11 sure it's understood that the CAL process and our review and closeouts, in 12 conclusion of that, will proceed, you know, in the same -- you know, regardless of 13 whether there's a license amendment request or not. And that will not be 14 completed until we've completed it. So, you know, from that perspective, the 15 CAL is there -- there's a commitment from the licensee to not restart until we've 16 completed that. And we've indicated that we will provide a notification when 17 we've made a decision regarding the re start at that poi nt and based upon that 18 CAL. This amendment reques t -- we will also proceed in the manner that Ms.

19 Evans just indicated, and, you know, we wil l also make a notific ation at the end of 20 that when we're completed with our licens e amendment review at that point and 21 the determination we have at that point, as well.

22 MALE SPEAKER: Can I just follow up what I heard out of the 23 answer is that it will take a week to certify that the application is complete and 24 that there's -- that they've met the no hazar d test, is that what I heard? And then 25 38 you will issue a notice for the hearing, which has to have a 30-day period 1 attached to it. Is that what I heard?

2 DOUG BROADDUS: No. I thin k what Michele was trying to 3 indicate, we have to do two initial steps.

One is acceptance review. The second 4 is the review, our own internal review of the notice of the no significant hazards 5 consideration determination, and then a publication of the notice of the receipt of 6 the application, the opportunity for a hear ing, and the opportunity to comment on 7 the no significant hazards determination in t hat case. Yes, it takes -- in order to 8 get it published, a notice published, it takes a couple days to actually just do that, 9 and once we actually have the notice prepared and put out there. So, in order to 10 be able to get through that entire process, you know, would be -- we would need 11 at least a week, I think, to get through that process if everything went perfectly 12 smoothly. It may take longer.

13 MICHELE EVANS: Well, and to clar ify, the actual review that the 14 amendment is acceptable, you know, doesn't occur in that first week, that just 15 keeps us moving along and then we have a 30-day window, but I do want to 16 point out that we have been reviewing this issue for a year or so already. So, it'll 17 be -- even though they're separate paths, the content is similar to what we've 18 been looking at for the past year, so, you know, the -- we're trying to just provide 19 a time line of the -- at the earliest w hen, you know, my math shows, you know, 20 seven weeks of a timeframe based on the dat es that I've laid out. Whenever you 21 do submit it until there c ould be a point when we issued it if we found it 22 acceptable.

23 RICK DANIEL: All right. Thank you, Michele. Go ahead, do you 24 have something else? Okay. Thank you, caller. We're going to take a question 25 39 from Kendra Ulrich here from Friends of the Earth in the room and then we're 1 going to go back to the phone. Go ahead, Kendra.

2 KENDRA ULRICH: Hi. My name's Kendra Ulrich. I'm with Friends 3 of the Earth. First, I just want to say that I find the fact that Edison is literally 4 making safety a footnote at the bottom of their page is absolutely appalling, that 5 this does not address all of the safety c oncerns that were raised in the restart 6 proposal for this incredibly damaged r eactor. But specifically, I have two 7 questions, one related to something that Mr. Nazareth said regarding the 8 analysis that you had done. You had said that you had done an analysis of all 9 reactor systems that are impacted by operation at reduced power levels for 10 extended periods of time. I would like to know when that analysis is going to be 11 made public.

12 MALE SPEAKER: Made available on your website.

13 DOUG BROADDUS: Yeah, I mean, I -- if what you're talking about 14 is what they've submitted to us, I believe the response is any -- either -- unless 15 they're proprietary, all of the responses are available either on Adams or on our 16 public website.

17 KENDRA ULRICH: I haven't seen it. My question is when?

18 DOUG BROADDUS: Is that --

do you know [unintelligible]?

19 RANDY HALL: Are you talking about -- excuse me, would that be 20 included in RAI-11 responses then?

21 VIC NAZARETH: Yeah, RAI-11 has already been out, right? The 22 original then would be just revised RAI-11.

23 MALE SPEAKER: Yeah, that's right.

24 VIC NAZARETH: The initial RAI-11 response, I understand is out, 25 40 so. 1 MALE SPEAKER: Right.

2 DOUG BROADDUS: Do you reca ll if that contained proprietary 3 information off the top of y our head? I don't remember --

4 VIC NAZARETH: That R.A.I. --

the initial one did not. Okay, the 5 new one does and very selected sections.

Okay? The revision is in selected 6 sections. Most of it is cleaned up, right?

7 RANDY HALL: Right. So, the prior response to RAI-11 is publicly 8 available. The most recent one, we understand, was dated on Monday and that 9 has not been processed yet, but the porti on of that response that's publicly 10 available will be made public in Adams shortly.

11 KENDRA ULRICH: Okay. Well, we'll be looking for that. I look 12 forward to seeing your analysis of all the various reactor systems that are 13 impacted by this proposal.

14 RICK DANIEL: So, what's your second question, Kendra?

15 KENDRA ULRICH: My second question, well, it specifically relates 16 to the fact that, you kn ow, Edison has asserted here over and over again that 17 they have some degree of certainty about the safety of this proposal of operation 18 at 70 percent, when, in fact, Westinghouse and AREVA, their own experts, 19 disagree as to the cause of the tube wear. Westinghouse says t hat it's tube pitch 20 and turbulence. AREVA says that it is fluid elastic instability. Intertek and 21 AREVA disagree on the time the tube bur st. So, there's no agreement between 22 the experts that Edison has submitted to y ou for their justificat ion for restarting 23 and restarting for five months. I --

Mr. Broaddus had made a comment that, you 24 know, the CAL could be, you know, comple ted afterwards. I would assume that 25 41 having a technical basis for approving a license amendment of this type would be 1 a requirement. So, that -- therefore, that would have to be completed before you 2 could issue a new license amendment, or at least the technical evaluation report 3 would have to be completed. As such, the --

4 RICK DANIEL: Why don't t hey answer that first, Kendra.

5 KENDRA ULRICH: Okay.

6 RICK DANIEL: Go ahead. Ken?

7 KEN KARWOSKI: The licensee's proposed license amendment 8 request is basically changing the acceptanc e criteria for the steam generator 9 tubes. It's redefining the power level at which they have to determine what the 10 acceptance limits are. That review can be handled independently of the CAL 11 response, which is how are they demonstr ating that they are actually meeting 12 that. The steam generator technical specifications are performed-based. We've 13 specified the acceptance criteria, licensees are responsible for ensuring that they 14 meet those acceptance crit eria and those analyses that they perform to do that 15 are subject to the inspection and oversight process. And in this particular case, 16 it's being covered as one of the CAL items.

17 KENDRA ULRICH: Right. So, thei r justification for why they can 18 demonstrate tube integrity at 70 percent is based upon operational assessments.

19 Is that correct?

20 KEN KARWOSKI: That is correct, yes. But that's --

21 KENDRA ULRICH: Okay. And t heir operational assessments that 22 they've submitted to you only show that they can demonstra te that. Again, 23 disagreement amongst the expert [spelled phonetically] that they submitted to 24 you, but they've only submitted anything fo r five months. They are asking for 25 42 approval for two years. So, essentially, Edison is coming to the NRC and asking 1 you to approve something with no technical basis to actually be able to fall back 2 on. So, if there is an accident, you are li able as the regulators. And quite frankly, 3 any regulator that's worth their name woul d turn this down on its face. Or, my 4 second question was, are you going to be requiring them to submit an 5 operational assessment that actually gives you a technical basis for approving a 6 license amendment for two years?

7 KEN KARWOSKI: The proposal is to change the acceptance 8 criteria that the steam generator tubes have to meet. Every -- the licensee is 9 required to follow those --

10 KENDRA ULRICH: For two years, right?

11 KEN KARWOSKI: Yes. Thei r counterproposal is for a cycle 17 12 operation, so it's one cycle --

13 KENDRA ULRICH: Which is what he just said, is two years, right?

14 KEN KARWOSKI: Right. But th e licensee is required to meet 15 those acceptance criteria. They have to determine how long they can operate, 16 whether it's five months, four months , six months, they have to make that 17 determination and that's cons istent with how every licensee in the country does it 18 for their steam generators. They have to make the determination of how long 19 they can run while still meeting those requirements. Those analyses are subject 20 to the inspection and oversight process and in this particular case we're 21 reviewing those as part of the CAL response.

22 KENDRA ULRICH: Except that t heir technical experts that they've 23 submitted to you also disagree with one anot her. So they were asking you to 24 accept something for two years with no technical basis and no agreement 25 43 amongst their experts.

1 KEN KARWOSKI: The return to power report that's being reviewed 2 under a separate process -- our review is still ongoing and we'll make a 3 determination -- and that's -- in their current proposal.

4 KENDRA ULRICH: And that will be completed prior to a license 5 amendment being issued.

6 KEN KARWOSKI: I -- those ar e two independent processes. If 7 they can --

8 KENDRA ULRICH: So, your te chnical evaluation for justifying 9 restart, for allowin g them to restart these reac tors, the basis for 70 percent 10 integrity, tube integrity, is separate from approving a license amendment to make 11 a footnote at the bottom of the tube integrity te chnical specification?

12 KEN KARWOSKI: Yes, because t he current proposal is just to 13 change the acceptance criteria, which the t ubes are required to meet. That is a 14 separate review from how do they go about meeting them. So, it's two separate 15 reviews, and so --

16 KENDRA ULRICH: So, you're literally taking safety out of the 17 question.

18 RICK DANIEL: Kendra, why don' t you let them answer while we 19 hang on. 20 KEN KARWOSKI: The safety is being addressed as a result of our 21 review and the return to power recorded in response to the confirmatory action 22 letter, so, the answer is no. We are fo cused on safety, but they're two separate 23 processes, the acceptance criteria for the tubes is in the license amendment 24 request and the safe -- how you go about meet ing that acceptance criteria is part 25 44 of the CAL response.

1 RICK DANIEL: Michele?

2 MICHELE EVANS: Yeah, to clarify, this license amendment 3 doesn't give them -- this is not the only thing they need to restart the unit. So, we 4 need license amendment, you know, ideally, if things line up right, you'd have a 5 license amendment. We would get thr ough and finish our review of the 6 confirmatory action letter submittal to rest art, which only -- where a proposal is to 7 run for five months. At the end of an inspection report, that still has to be -- we 8 still need an exit meeting and a report, so the close-out inspections that have 9 been going on for the past six months or so, okay? So those things all need to 10 come together, at which point, if they do and they line up, we would authorize 11 restart for five months. So, that five month cycle.

12 RICK DANIEL: Not two years.

13 MICHELE EVANS: Not two years.

14 KENDRA ULRICH: Except they're asking you for a no significant 15 hazard consideration for restarting a reactor --

16 DOUG BROADDUS: Now what they're asking in no significant 17 hazard -- what they provided for their proposed no significant hazards 18 consideration determination is on the change to the tech spec --

19 KENDRA ULRICH: But on tube integrity, right?

20 DOUG BROADDUS: On the per formance criteria for the tube 21 integrity.

22 KENDRA ULRICH: Yeah. I understand that wholly, and Michele, I 23 just want to make clear I understood that, as well, that approving a license 24 amendment isn't approving restart. It's removing a critical licensing question 25 45 from this process and approving a no significant hazard consideration with so 1 much uncertainty. I can't imagine that any engineer also worth their name and 2 their professional reputat ion, would approve such a thing. Thank you.

3 RICK DANIEL: All right. Thank you, Kendra.

Operator, we're 4 going to take another question from someone on the phone, and do we have 5 someone lined up, please?

6 OPERATOR: Certainly. The next question will come from Linda 7 Adams. Your line is open.

8 RICK DANIEL: Hi Linda. Go ahead, what's your question?

9 LINDA ADAMS: Good after noon. My name is Linda Adams, 10 former secretary of the California Environmental Protection Agency. I also 11 served as the legislative secretary to Governor Gray Davis during the California 12 electricity crisis. In that capacity, I was responsible for negotiating emergency 13 legislation that allows the state to take over the purchase of power in order to 14 keep the lights on in our state. As a longtime advocate for environmental 15 protection, it's critically important that we have a safe and reliable supply of 16 power generation in Californi

a. One of the key questi ons that must be addressed 17 with regard to the restart of SONGS, is what is the impact from a power delivery 18 and reliability perspective should SONGS not restart. More importantly is the 19 question of operational safety of the uni t, including whether the best available 20 technology is being used to ensure the safety. And finally, the NRC has been 21 reviewing data from Edison for several months now, and the question is whether 22 the NRC has the resources, and more importantly, the information needed to 23 evaluate the data and make a decision prior to the beginning of California's peak 24 period. I believe strongly we need to ensure reliability of our electricity service in 25 46 California, but not at the expense of pub lic safety. And I know a lot of these 1 questions have been discussed over the course of this meeting, and I know that 2 NRC may not be able to immediately answer these questions, but I think these 3 are the questions that need to be addressed prior to any decision being made.

4 And, so thank you. That concludes my statement.

5 RICK DANIEL: Thank you very much, Linda.

6 DOUG BROADDUS: So, to answe r your question, do we have all 7 the information that we need in order to be ab le to make a decisi on in time for the 8 -- what I understood -- the cr itical time for power, I guess, the peak summertime 9 period, I think is what you said. From the standpoint of the CAL actions, we do 10 still have some RAIs as Rich St. Onge mentioned earlier, there are still some 11 additional RAIs responses that are pending. We do need those in order to be 12 able to continue that review. From the standpoint of any license amendment 13 request, we don't have one yet, so we can't

-- we can only move forward when 14 we get that, and we'll move forward as quickl y as we can. But, again, as we've 15 specified, there are specific timeframes that are, you know , required, and those 16 timeframes for comments and hearing requests and such, will be provided in this 17 process as well. So, we're going to have to

-- those are going to be part of that --

18 the timeframe and the schedule for that.

So, I can't answer the second half from 19 that perspective, until we have all the information we need.

20 LINDA ADAMS: Correct. Correct. Thank you.

21 RICK DANIEL: [affirmative] All right. Thank you, Linda. A question 22 in the room and we'll get back to you in a minute, operator.

23 ANTHONY CRAWDOW [spelled phonet ically]: Anthony Crawdow, 24 just a timeline question. If you want to take it off-line it's easier because you 25 47 probably addressed it. Just if you go thr ough the steps on from today to potential 1 restart, it's one of the m ilestones and if you have the sc hedule online I'll just -- if 2 you'll just walk me through then, I would really appreciate it.

3 DOUG BROADDUS: Okay. Again, I'm not going to necessarily put 4 dates on and -- except for the dates that are specified by regulations or 5 someone, for a first step --

6 ANTHONY CRAWDOW: Easy question compared to your last 7 couple. 8 DOUG BROADDUS: [laughs] Sure. Our first step is once we 9 receive the license amendment request is to conduct an acceptance review and 10 to review the proposed no significant hazards consideration determination 11 submitted by the licensee. We then take --

if we accept that -- the application, we 12 would then notify the licensee of that, we would then put --

13 ANTHONY CRAWDOW: Does t hat mean approve or that's a 14 different part?

15 DOUG BROADDUS: No, accept means that it's accepted for our 16 review. Our acceptance review -- the pur pose of the acceptance review is to 17 determine whether the request has sufficient information for us to be able to do 18 our review. And, you know, it's kind of a completeness review, you know, is 19 everything there that we need? If it's not, we would then give the licensee an 20 opportunity to supplement that or, if it's something where they're going to have to 21 need significant amount of additional analyses in order for us to be able to do our 22 review, we would not accept it at that point in that case. So, that's our first step 23 in the process is our acceptance review.

Once it's accepted, then we would --

24 soon after that, we would issue the notice that would include the -- basically the 25 48 fact that we received it, what -- as a su mmary of what that --

of what the request 1 is, our proposed notes, and this is the staff's proposed no significant hazards 2 consideration determination, which ma y be different than what the licensee 3 submitted to us. I mean, we have to do our own review and make sure --

4 whether we agree with what they provided or whether we think that there's 5 something, some -- a difference in what they provided. So that would be 6 provided and the opportunity for comments on that as well as an opportunity to 7 request a hearing, would all be included in that notice. Ther e would be a 30-day 8 period, a minimum 30-day period for co mments and a minimum 60-day period for 9 -- to request a hearing. Okay, once that's -- the 30-day period is complete, we 10 would -- 11 ANTHONY CRAWDOW: Do they run parallel or --

12 DOUG BROADDUS: Yes.

13 ANTHONY CRAWDOW: Or t hat 30/60 day run parallel --

14 DOUG BROADDUS: Parallel. Yeah, they're concurrent.

15 ANTHONY CRAWDOW: And the 30-day starts when you agree to 16 accept --

17 DOUG BROADDUS: It starts on the date of the notice.

18 ANTHONY CRAWDOW: Is that when you accept the application?

19 Or is it the 30-day --

20 DOUG BROADDUS: No, that's the date the notice is published in 21 the Federal -- typically it's published in t he Federal Register.

All right. So, then 22 once the 30 days is over, then it's however much time we need to complete our 23 review at that point. And the 30 days, you know, for a comment period, we'll be 24 conducting our review during that time peri od. So, it's not like we wait until the 25 49 end of the 30 days to start t hat, no we don't. We -- we're reviewing it from --

1 essentially from day one as soon as we've accepted it, we start reviewing it. And 2 so, however much time we need after that is when we would actually issue the 3 final determination. And it would either be an approval or a denial at that point.

4 ANTHONY CRAWDOW: Is the time of decision approval, is that 5 the approval for restart?

6 DOUG BROADDUS: No. It's --

it would -- what we would do is 7 issue -- THE request -- the question was because there wasn't a mic there --

8 ANTHONY CRAWDOW: I apologize.

9 DOUG BROADDUS: --

I'll restate it. It's okay. The question was is 10 that an approval to restart, no, and that's why -- I wanted to make it clear that 11 there is a distinction between the CAL process that we're following and the 12 amendment process that we would follow. It would only be the issuance of the --

13 of an amendment at that poi nt. If approved, we wo uld issue the amendment.

14 That would also be issued in the Federal

-- we would put a notice in the Federal 15 Register at that point and it would specify the date that it's applicable -- the 16 amendment is applicable, and which would ty pically be immediately after -- upon 17 issuance of that.

18 ANTHONY CRAWDOW: Okay. So , now at that period it's an 19 amendment to run at 70 percent, you know --

20 DOUG BROADDUS: Yeah. And it would -- the approval in a case 21 based upon what they've submitted to us --

I mean, provided to us as a draft at 22 this point, is the issue -- the amendment that would be issued would only be an 23 amendment that changed the tech spec and changed -- and we put those 24 footnotes in place -- that's what would be issued. They would be -- that in 25 50 essence would restrict them from that point going forward from operating above 1 70 percent. Right now, their license aut horizes them to operate up to 100 2 percent. If we approve that amendm ent and issued it, then they would be 3 restricted from that point on from operating above that 70 percent level. It would 4 not give them any authorization to operate other than any more than what they 5 have right now. And so, through the CAL pr ocess, that's not -- we're working 6 right now on whether or not we would provide any -- you know, a determination 7 on whether they should be allowed to restart.

8 ANTHONY CRAWDOW: And when does the decision come out on 9 the CAL process to -- like so that's running parallel to the license amendment --

10 DOUG BROADDUS: Yes.

11 ANTHONY CRAWDOW: -- and like is there a timing that that 12 happens before or after you get a license?

13 DOUG BROADDUS: As I said, it doesn't have to happen -- it could 14 happen before or after. Right now, what we expect is that -- and this is what we 15 put on our website -- is we don't expect --

let me take a step back. The next step 16 in that process would be a public meeting that we're pl anning to have out in the 17 Southern California area, that -- where we would pres ent basically the -- we 18 would have it as an exit meeting on t he inspection report itself, the inspection 19 that's being conducted as well as our fi ndings from our technical evaluation of 20 their restart time that they submitted back in October. So, that -- we don't expect 21 to be able to have that meeting until some -- until early May timeframe at this 22 point. 23 ANTHONY CRAWDOW: That's t he public meet -- the early May 24 timeframe.

25 51 DOUG BROADDUS: The May timeframe would be a public 1 meeting. At that point, we expect to be essentially done -- well, actually the 2 meeting will not occur until we're essentially done with that review. And so, when 3 that happens, you know, when we have that public meeting, we'll be essentially 4 done. We will give the information about w hat our findings are, you know, and 5 provide that information. And then we'l l -- shortly thereafter we expect to issue 6 the inspection report and the technical evaluation and then the restart decision 7 would be based on those two documents.

8 RICK DANIEL: And there's mo re information on the website about 9 a lot of this and we can ta ke some more discussion w hen you have the meeting.

10 Operator, why don't you give us the next caller, please.

11 OPERATOR: Thank you, the next question will come from Tom 12 Gurdziel. The line is now open.

13 RICK DANIEL: Thank you. How you doing, Tom?

14 TOM GURDZIEL: I'm doing real good here. I'm about eight miles 15 away from three operating nuclear reactors up here in New York -- in New York 16 state. I've got three thi ngs to make -- three comment s to make here. Number 17 one is, if the use of the Unit 3 generator asynchronous condenser which stabilize 18 electric voltage and the grid, has anybody co nsidered doing that? That's number 19 one. Number two, I can't see where we can spend all this time going through this 20 process and that process because the ot her process isn't quite done yet. So, 21 what I'm suggesting is the NRC do a preemptive action of putting the license at 22 Unit 2 to 65 percent for three months -- for five months, excuse me, with the 23 stipulation that if there's any leaks in t hose five months, their power goes to zero 24 percent and that's permanent. And the third thing I want to say is I think Unit 3 25 52 ought to get a zero percent power lic ense change right now. I don't understand 1 what the delay is. So, it's 14 months and where are we? No place. Okay.

2 That's all I got. Thanks, Rick, bye.

3 RICK DANIEL: Thank you, To

m. Operator, ho w about the next 4 caller? 5 OPERATOR: Thank you. Gr eg Van Pelt [spelled phonetically], 6 your line is open.

7 Greg Van Pelt: Thank you very mu ch. I'm Greg Van Pelt. I'm from 8 the California ISO. I appreciate the opport unity to ask a question here. I think 9 the question's been asked and answered perhaps a couple times, and not to 10 belabor it, I want to ask a question about a schedule for the process. Clearly, the 11 ISO is interested in safety, and nothing we w ant to do is to put safety at risk in 12 any way. Our interest is in reliabilit y and, of course, we have to enable planning 13 and we appreciate the previous comments about the need for electric reliability.

14 And so, we're hopeful that a firm schedul e can be established for the issues 15 associated with San Onofre as to w hen it may be available or may not be 16 available. And our interest, again, is in a firm schedule to enable planning 17 without looking to rush or cause any bypass of process or by any means to put 18 safety at risk, but I think it's important to say that we all recognize the need to 19 assure that the reliability planning can be done in a somewhat time-urgent way 20 and we'd like you to take that under t hat consideration. And with that, I 21 appreciate the opportunity. Thank you.

22 RICK DANIEL: Thank you very much, Greg. Operator, we'll take 23 the next caller, please.

24 OPERATOR: Thank you. Dan Hirsch, you may ask your question.

25 53 RICK DANIEL: Hi Dan, how you doing?

1 DAN HIRSCH: Miserably, how are you?

2 RICK DANIEL: Better than y ou, better than you. Go ahead.

3 What's your question or comment?

4 DAN HIRSCH: I'm quite struck by the lack of candor in response to 5 Secretary Adams' question as to whether the process that you are contemplating 6 will permit all of the necessary safety in formation to be available and be reviewed 7 prior to making a decision.

8 RICK DANIEL: Well, let's take another --

9 DAN HIRSCH: Excuse me. Let me try to finish.

10 RICK DANIEL: Go ahead.

11 DAN HIRSCH: What has not been said here clearly is that what is 12 being proposed by Edison, and apparently with some kind of indication of prior 13 agreement by NRC staff, is to get this license amendment, which is essential for 14 a restart of the crippled reactor, and do so with a safety hearing that would occur 15 after the fact. The phrase that has been us ed over and over again is that they're 16 requesting a no significant hazards consideration, but you really have not 17 disclosed what that means, is as in the Old West days w here the judge says, 18 "We'll hang him now, but we will give him a fair trial later." What you are 19 proposing through this entire session have not been candid about is to permit a 20 hearing but only after it is too late to give them the approval and allow a hearing 21 to occur long after the fact. And this occurs after Edison had screwed up initially 22 on the steam generators, but insisting t hat they be able to be put in without a 23 hearing, a hearing which could have disclosed the fundamental design problems, 24 and NRC staff having screwed up in allowing that to occu

r. So, what is going on 25 54 right now, I think we just have to be r eally clear about. About 10 days ago there 1 was a oral argument before the Atomic Safety and Licensing Board about 2 whether or not what the two of you are doing violates t he law and is, in fact, a de 3 facto license amendment process, and that a hearing would be required. And 4 what NRC staff and Edison are doing, after being given a very rough time by the 5 licensing board, which was very skeptical of what you are doing, is you're trying 6 to pull the rug out from under three adm inistrative law judges of the Nuclear 7 Regulatory Commission, carrying out a mandate given to them by the 8 Commission to determine whether what you're doing really does require a 9 hearing. The idea that you could try to get this thing turned on in less than two 10 months from now and hold the hearing long afterwards, I think is simply 11 scandalous. And at least you should be candid about it. You should say, "Yeah, 12 Edison wants us to give them this approv al," but make sure that none of the 13 safety concerns that the experts who are not at Edison and not at NRC staff wish 14 to raise before a licensing board could be heard before they get the approval.

15 We really do not have a system of justice in this country that is supposed to hang 16 you first and give you your trial later.

But that is what you two entities are doing 17 right now. I don't think you'll succeed. I thin k you'll do it from the

-- in the face of 18 that licensing board that will anger them gr eatly. I think it will create a furor on 19 the Hill because the Commission has promised the Congress that there would be 20 complete review and that review completed before any decision to start up. But 21 at least you should today have been clear that what you're proposing is to have 22 the review after the approval, the hearing would be permitted and long after it 23 could make any difference.

And I just think that y ou're undercutting any chance 24 of credibility for Edison to be believed that it can run a facility safely or for the 25 55 NRC staff to be viewed as an entity that c an determine whether or not it is safe.

1 So, I just want to say it's exceeding troubling, and if y ou're going to do it, at least 2 you should be candid about it. To have gon e through this whole meeting and not 3 really made clear to people that you're proposing that any safety hearing occur 4 after the fact really shows how embarrassed you are about what you're really 5 doing. 6 RICK DANIEL: All right. A ll right. Thank you, Dan.

7 DOUG BROADDUS: I'm not sure there's specific questions in 8 there. What I'll try to do is respond to some of the statements that were made in 9 that, first of all, as we've stated in numerous instances previ ously, and I'll restate 10 again today, that it is --

you know, we will not allow a restart until we're confident 11 that there -- the unit c an be operated safely. And t hat's independent of any 12 license amendment requests or even the ASL B activities, you know, we would 13 not allow them to operate if we did not believe that they were safe to operate, 14 and we will not allow that to occur. And we will take whatever time necessary in 15 order to make that determination. T he -- from a standpoint of the license 16 amendment request and any hearing process, we're going to follow the process 17 that's required of us, and we are going to do that, we are going to be in full 18 compliance with that. We're going to follow the normal -- it's our normal process.

19 We are going to do that -- the licensee, t he SCE has not asked for an exigent or 20 an emergency amendment request, so, you k now, there is no cutting short any 21 timeframes by which people can make, you know, can request a hearing or 22 cutting short the opportunity for public participation because of making 23 emergency or exigent situations, you know, that apply. So we're going to follow 24 that process, the normal process. So t hat's, I mean, I hope that that response to 25 56 the -- 1 DAN HIRSCH: Not at all. You just weren't candid. Is it not true 2 that what you and Edison are proposing to hold the hearing as to whether this is 3 safe after the fact? Is t hat not what you're proposing?

4 DOUG BROADDUS: I'm indicati ng that we're going to follow our 5 process. The regulation --

6 DAN HIRSCH: But the process you are following is to hold the 7 hearing after the decision to approve the license amendment.

8 RICK DANIEL: Okay. All right.

9 DOUG BROADDUS: The regulation --

10 DAN HIRSCH: You're having the trial after the hanging.

11 RICK DANIEL: All right. Hang on a second, Dan. He's trying to 12 respond to you. Doug?

13 DOUG BROADDUS: The right --

the regulation that dictates our 14 review of the no significant hazards consideration specifies that if we, the staff, 15 are able to make a no significant hazards consideration determination, that we 16 are able to proceed with that regardless of whether there is a -- any request for 17 hearing or other pending action within the ASLB, you know, whether it's either 18 before the ASLB. What we do plan to do is make the notification, notifications 19 that are specified in that r egulation as well, if there is a hearing request or if the 20 ASLB, you know, the action is still ongoing, we will make anot her -- our plan is to 21 make a notification prior to that action being completed, any action being 22 completed, whether it's our restart decision under the CAL or in a decision under 23 a license amendment. That

-- my understanding of this, and I'm getting outside 24 of my range of full understandi ng here, but my understanding is that -- so that 25 57 there's an opportunity for parties, you know, parties of the -- of those actions to 1 be able to make -- to take action as a resu lt of that, that possible action that could 2 be reoccurring. So, that's

-- you know, we want to make that notification prior to 3 either of those two decisions being made.

4 DAN HIRSCH: All right.

5 RICK DANIEL: All right. Thank you, Dan. Thank you for your 6 comments and your opinions. We appreciate them. Operator, we

'll take the next 7 caller, please.

8 OPERATOR: Certainly, sir.

Frank Lopez, your line is open.

9 RICK DANIEL: Go ahead, Frank.

10 FRANK LOPEZ: Thank you. G ood afternoon. My name is Frank 11 Lopez. I'm commenting today on behalf of the Los Angeles Area Chamber of 12 Commerce. The Chamber is the largest business association here in Southern 13 California. We represent the intere sts of about 1,600 member companies and 14 organizations who collectively employ about 650,000 people. On the call today 15 to make sure that the business community here in L.A. has a voice during this 16 important public review process. The C hamber has participated in multiple public 17 meetings now as part of t he NRC's regulatory review of the SONGS restart plan.

18 We're concerned that with the impact of SONGS having on good reliability and 19 energy affordability in the region, and we're really concerned that during the 20 summer we won't have the capacity to deal with the peak demand. Businesses 21 depend on reliable and affordable electr icity, and reliable and affordable 22 electricity is going to be hard to come by if SONGS is offline during the summer.

23 We understand that there needs to be a thorough public review of the proposed 24 restart plan to determine if SONGS can be sa fely restarted, but we believe that 25 58 what we need right now, in our view, is a reliable and impartial regulatory 1 process. A regional economy cannot afford to have this rigorous, time-tested 2 process that has been built on a foundatio n of safety and thorough technical 3 review, politicized. The question I have for the NRC today is, what are you doing 4 to ensure that your decision-making pr ocess regarding the proposed restart of 5 SONGS is based on sound technical review, and not political influence or special 6 interests?

7 RICK DANIEL: Thank you, Frank.

8 DOUG BROADDUS: Ken, do you want to talk from a technical 9 standpoint? How we're ensuring the review is technically justified.

10 KEN KARWOSKI: Yeah, I guess ju st from a technical perspective, 11 you know, we've gotten the return to pow er report and we've been reviewing that 12 for several months. And we've identifi ed a number of issues and we've provided 13 RAIs so that the licensees provide some

-- most of the responses. We're still 14 waiting on some of those. But our re view is independent of any external 15 influence. We're engineers.

We take a look at those submittals and we review 16 them and we make recommendations to our management on the acceptability of 17 those reviews.

18 RICK DANIEL: Okay. So the NRC is just following the process 19 that's mapped out for them, correct?

20 DOUG BROADDUS: Yes. And, I mean, our process for making 21 decisions is very well laid out and very well established throughout. It has been 22 established and, you know, for years.

It's not a new process, we're not changing 23 our process in this particular situation, you know. And, you know, if there's a 24 desire to influence our decision, as an independent regulator, we're going to do 25 59 our best to ensure that that does not -- that there is no influence on our decision.

1 You know, it's why we have our technical experts, we have people here that have 2 been doing this for a long time, and we rely upon them to provide to us the best 3 advice and their review of the technical issues. And that's who we rely upon to 4 provide us the basis for our decision making.

5 RICK DANIEL: Okay. All right.

Thank you, Doug. Thank you, Mr.

6 Lopez. Operator, we'll take the next call, please.

7 OPERATOR: Mike Tyner [spelled phonetically], you may ask your 8 question.

9 MIKE TYNER: Yes. I'm a representative of the building 10 construction trades department at the AFL-CIO. I understand that the NRC has 11 conducted a series of public meetings on San Onofre and I w onder if the staff 12 could outline the NRC's public meetings and hearings on SONGS since it's 13 January 31, 2012, shutdown.

14 RICK DANIEL: You know, Frank, I mean --

15 MIKE TYNER: Mike.

16 RICK DANIEL: I'm sorry, Mike.

I'm still on the last caller. You 17 know, Mike, that information is readily available on the NRC website and it's all 18 mapped out for you there by date and everything.

So, I'd prefer for right now that 19 we don't spend time on that. It is very much available to you if you go in and look 20 at the public meetings under the NRC websit

e. It talks about SONGS and all the 21 dates and the meetings are laid out there and what the meeting was about, and 22 so on. And there's even public -- ther e's even transcripts available for each 23 meeting, okay? Does that answer your question?

24 MIKE TYNER: It does. Thank you very much.

25 60 RICK DANIEL: Yes, sir.

1 DOUG BROADDUS: And just for everybody's information, I think, 2 you know, it's about 10 meetings that we

've done total, you know, but, again, all 3 that information is -- we're making all that information available on our website, 4 as, you know, we will in this case -- we'll make the final set of slides that SCE 5 provided to us, we'll make those available on the website. And when we receive 6 license amendment requests, I expect we'll put that on there, as well. The --

7 we've put out the draft version of that is there. So, what we'r e trying to do is 8 making sure that, you know, all the info rmation we have -- the information that 9 can be made publicly available, as l ong as, you know, that would exclude 10 proprietary information, obviously. But, all that information that's, you know, is 11 readily available on that website.

12 RICK DANIEL: All right. Thank y ou, Mike. Operator , we'll take the 13 next caller, please?

14 OPERATOR: The next question is from Opti Ahmed [spelled 15 phonetically], your line is open.

16 RICK DANIEL: Hi, Mr. Ahmed.

Go ahead, we're listening to you.

17 OPTI AHMED: Thank you very much and good morning. I'm a 18 small business owner in the service area and I wanted to acknowledge your firm.

19 Now, what is critical for me and for my employees is, (a) reliability and safety, 20 and more importantly also, a ffordability. What is NRC going to do to protect my 21 business? Because at the end of the day if there's no electricity, especially 22 during the peak period, then I will not be able to be in business. If I'm not in 23 business, then I will not have employees that I can support. So, what are the 24 complete plans for NRC to actually address this prior to the peak period? Thank 25 61 you very much.

1 RICK DANIEL: Thank you.

2 DOUG BROADDUS: That's --

I mean, I think we understand the 3 desire to ensure that there is reliable power and is affordable available. Our 4 primary responsibility is safety. So, we hav e to make sure that before any restart 5 can be authorized that the plant can be safe ly operated. And I do want to make, 6 you know, just try providing some type of reassurance that we are -- this is, you 7 know, a high priority action for the agency. We are taking -- you know, we are 8 doing this -- we have dedicated teams for th is that are working on this, you know, 9 and so this is something that we are focusing on and we're not taking, you know, 10 we're not putting this on the backburner and just taking our time on it. We're 11 trying to do this as expeditiously as we can.

12 RICK DANIEL: And there's a lot of interest on all sides.

13 DOUG BROADDUS: Yeah.

14 RICK DANIEL: Thank you, Doug.

Operator, we'll take the next 15 caller, please.

16 OPERATOR: The next one is from Betty Jo Toccoli.

17 RICK DANIEL: Hi, Betty Jo.

18 BETTY JO TOCCOLI: Good afte rnoon, or I guess it's afternoon 19 there and morning here. I represent the California Small Business Association 20 and we have over 200,000 small business owners. And I think you partially 21 answered my question on reliability. We certainly understand that safety needs 22 to be and we think you're doing a great job, both you and Edison. We don't have 23 any concerns about either party not bei ng concerned about safety, but reliability 24 is our issue several have addressed, and so here's my question. Even if you 25 62 started SONGS and something went wrong, is there any reason you couldn't 1 shut it down again?

2 DOUG BROADDUS: If your question is whether we have the ability 3 to require them to shut down once they've started up, and yes, we do. We have, 4 you know, we can issue an order to the licensee to, you know, if there's a safety 5 issue to require them to shut down. We have a resident inspector that's there all 6 the time. You know, resident inspectors are there monitori ng their day-to-day 7 activities and that person is there specif ically to look at the, you know, the 8 ongoing safety in the oper ation of the plant.

9 MICHELE EVANS: Yeah, I was just going to add the licensee is 10 required to follow their technical specifications. So, if there is additional issues 11 related to the steam generators they would become awar e of that and be 12 required to shut down the plant at various parameters.

13 BETTY JO TOCCOLI: Well, we w ould just like to encourage you to 14 take care of us over these hot summer months. We were lucky last year, but I 15 don't think we're going to be this year and we're extremel y concerned about 16 small businesses staying in business and t he jobs they create.

And we thank 17 you for all your hard work.

18 RICK DANIEL: Betty Jo, S outhern California Edison wants to 19 comment on your question as well.

20 RICHARD ST. ONGE: Well, it's ou r ultimate responsibility to run 21 the plant safely and we certainly wouldn' t want to go into a scheme while we're 22 waiting for the NRC to tell us to follow our tech specs or when it's time to shut 23 down the unit. So, long before the NRC came to that conclusion, we would come 24 to that conclusion.

25 63 RICK DANIEL: Thank you, gent lemen and ladies. Thank you, 1 Betty Jo. How about take a question from Mr. Freeman here in the audience, Mr.

2 Freeman? 3 S. DAVID FREEMAN: I just wonder if the panel is aware of the fact 4 that the ISO has said publicly that they are not planning on San Onofre running 5 this summer at all. Thei r plans for the summer, which are quite well publicized 6 and well known to everyone, assume that San Onofre will provid e zero power. I 7 am a founding trustee of the ISO. I ran two utilities in California as a CEO, and I 8 was Gray Davis' Senior Advisor duri ng the energy crisis. So, there's nobody 9 more concerned about reliability than I am.

But the State of California is not one 10 power plant away from a blackout anymo re, that was 10 years ago. The ISO has 11 worked diligently last year and this year to make sure that there's adequate 12 power supply, and that reliability is a res ponsibility of the Stat e of California, not 13 the responsibility of the NRC and you all know it. And that issue should have no 14 bearing on your decision. I'm sure it doesn't, and it should not have any bearing 15 on the Edison Company's decision making either. We have a serious safety 16 problem that has not been fixed at this pow er plant, and all this paperwork is not 17 assuring anybody that a restart is in the public interest. And all this hyped up 18 concern by the Edison Company's PR department really should be ignored by 19 you today because it's irrelevant to your decision.

20 RICK DANIEL: All right. Thank you very much, Mr. Freeman. Any 21 comments?

22 MICHELE EVANS: Well, no, I would just thank you for that 23 information. As Doug had indicated, our focus is on safety and the safe 24 operation of the unit. We won't authorize restart until we believe it is safe to do 25 64 so. With regard to California's power si tuation, that is not our concern.

1 RICK DANIEL: Thank you, Mic hele. Operator, we'll take the next 2 question.

3 OPERATOR: Thank you. The next question is from Arnold 4 Packard. 5 RICK DANIEL: Okay, go ahead, Arnold.

6 RON PACKARD: It's Ron, Ron Packard.

7 RICK DANIEL: Ronald, I'm sorry. Ronald, go ahead.

8 RON PACKARD: Let me introduce myself. I'm Ron Packard. I 9 had the honor and privilege of serving in the United States House of 10 Representatives for 18 years in the 43 rd and later the 48th Congressional 11 Districts in California. During the last part of my service, I was chairman of the 12 House Appropriation Subcommittee on Energy and Water Development, which 13 has jurisdiction over all generating plants in the United States , including nuclear 14 plants. My congressional district covered North San Diego County, South 15 Orange County, and Western Riverside County. The San Onofre nuclear 16 generating station, SONGS, was in the geographic heart of my district. I officially 17 visited SONGS frequently during my tenure in congress and each time reviewed 18 carefully the operation and maintenance of t he plant. I always felt convinced that 19 safety was the priority of San Onofre and knew that the ow ners and operators of 20 the plant were operating and maintaining the plant properly. My energy and 21 water subcommittee funded research and dev elopment on alternative sources of 22 energy, but these sources of energy wil l only fill a small percentage of our 23 national as well as our regional energy needs. While I totally support alternative 24 energy production through solar, wind, biomass, geothermal, and all other 25 65 sources of alternative energy, they can never replace the need for nuclear 1 generation. The NRC would serve the people of California and the Western 2 states best if they woul d allow San Onofre to reopen before summer when we 3 could be faced with potentia l brownouts or blackouts.

It is incumbent upon the 4 NRC and any other governmental regulat ory agency to do the right thing here 5 and complete their work with Edison on this issue in a timely manner. To do 6 otherwise would be to act overly bureauc ratic or even adversarial and would 7 directly hurt the day-to-day wellbeing of the very same constituents that I was 8 honored to serve in Congress.

9 RICK DANIEL: Yeah.

10 RON PACKARD: Clearly, there are some stakeholders who want 11 no nuclear power in the Unit ed States at all, not just safe nuclear, no commercial 12 nuclear plants whatsoever. These parties are motivated to grind the regulatory 13 process to a halt and it seems to me t hat the process has already been dragging 14 on and on.

15 RICK DANIEL: Okay.

16 RON PACKARD: That just -- t hat simply can't happen because we 17 do not want Washington to have an impact negatively on the people of California.

18 RICK DANIEL: We --

19 RON PACKARD: It's already been answered. I was going to ask 20 the question.

21 RICK DANIEL: Sure, go ahead.

22 RON PACKARD: What your pr ocess would do and -- what's your 23 process and when do you intend to make the decisions on a safe restart?

24 You've already answered that question, for which I appreciate. I simply would 25 66 like to know if you are going to be able to meet the timeline and allow the plant to 1 operate during this next summer.

2 RICK DANIEL: Thank you, Mr. Packard. I think the timeline's 3 existing on the website, Michele?

4 MICHELE EVANS: Yeah, thank y ou for your comments. Yes, we, 5 as I indicated we are completing our safe ty review in as timely a manner as 6 possible. The licensee does still owe some information in some areas, so we are 7 waiting for that input and we'll continue to move forward. I will say the timeline 8 on the website says, you know, a public m eeting in the April/

May timeframe.

9 Internally, we've talked about it's rea lly the May/June timeframe. So, we're 10 shooting for the May timeframe, but it could be June, I'll be, you know, honest 11 here. So, that's w here we are with it.

12 RON PACKARD: You indicated, and I've listened to your entire 13 presentation today, and it's been very info rmative, but you've been working on 14 this for the past year and I'm sure you've been reviewing much of the technical 15 data. There's additional technical data t hat you will need to review between now 16 and the start time. And I a ssume that you can do that in a manner of time that 17 would allow the amendment to be approved and thus the operation could take 18 place -- the start could take place dur ing the summer months. It's the summer 19 months we're very concerned about.

This coming summer we simply cannot 20 afford brownouts or blackouts, and I'm c onvinced that you'll be able to do the 21 right thing.

22 RICK DANIEL: All right. Thank you very much, Mr. Packard.

23 DOUG BROADDUS: The one thi ng, if I will commit to everybody 24 that we will do is, you know, as soon as we develop a schedule, you know, for 25 67 this and for the review of our license amendm ent. I want you to be assuming that 1 we would receive one, we will get that information up on the website as well so 2 that we can have that as well as the CAL review process, that information 3 available on the website.

4 RICK DANIEL: Thanks, Doug.

Operator, we'll take the next caller, 5 please. 6 OPERATOR: Question from Ruben Guerra.

7 RUBEN GUERRA: Hey, this is Ruben Guerra, can you hear me?

8 RICK DANIEL: Yes, we can hear you loud and clear, go ahead.

9 RUBEN GUERRA: Thank you. My name is Ruben Guerra and I'm 10 the Chairman and CEO of the Latin Business Association out of California, 11 representing over 800,000 Latino-run businesses. And, you know, I just -- I've 12 been reading all the remarks today and it's very wowing to me that we've been 13 given all this rhetoric, you know, that the NRC has been listening to all these 14 people talking about SONGS when they rea lly have no experience, they haven't 15 been to SONGS, they just go by what they hear. [unintelligible] was calling 16 people scandalous. You know, unfortunatel y people that do that are scandalous 17 themselves. You know, there's nobody more that knows about the situation of 18 electricity in California than we do. You know, we experience it every day. Right 19 now our businesses are suffering with rate hikes. We're looking at future rate 20 hikes if SONGS isn't opened soon. And I'm in the renewable energy business.

21 And I would be saying, you know, for me to be here to support SONGS would be 22 against my rules of doing business, but I' m here to support it because it's the 23 right thing to do. Renewable energy will not be sufficient enough. It's going to 24 take another 20 to 30 years to come up to speed on renewable energy. You 25 68 know, according to the information rel eased by the U.S. Energy Information 1 Administration, costs for energy are beginning to rise in Southern California, you 2 know, the EIA has attributed those differ ence of SONGS being offline. Operating 3 SONGS directly generates economic activi ty worth an average of $2.2 billion per 4 year. You know, in other countries -- th is is why our economy suffers. But 5 because there's too much process, there' s too much hearing, there's too much 6 rhetoric. We need to get this online and we need to do it now.

7 RICK DANIEL: All right. Thank you very much, Ruben, for your 8 comments. Operator , we'll take the next caller, please.

9 OPERATOR: Next question is from Ace Hoffman.

10 RICK DANIEL: Operator, can you just tell us --

11 ACE HOFFMAN: Thank you for taking my call.

12 RICK DANIEL: -- do you have any clue as to how many callers are 13 left on the line?

14 OPERATOR: Yes, sir. We hav e about six questions remaining.

15 RICK DANIEL: Okay, we're likely only going to take six more 16 questions. Go ahead, Ace.

17 ACE HOFFMAN: Okay, t hank you for taking my call.

18 RICK DANIEL: And we're running over, but go ahead.

19 ACE HOFFMAN: Okay. We --

some of us have been studying San 20 Onofre very, very carefully for many years and we are not hearing a lot of 21 answers to question that we have right now. For example, we didn't hear 22 anything about a multi-tube break in the ca se of a main seam line break because 23 there are thousands of damaged tubes. We don't know if those tubes are 24 damaged by inward elastic instability, probably not in Unit 2, but flow-induced 25 69 vibration certainly, and what about fatigue? That hasn't been mentioned at all.

1 These are technical issues that the public would like to see the answers to. We 2 don't want them to be redacted or ignored.

3 DOUG BROADDUS: Yes --

4 ACE HOFFMAN: Is there any chance that we will be getting a full 5 technical description of why San Onofre thin ks that they can rest art the reactor?

6 And I also want to make a comment about some of the early comments at the 7 beginning, where they said that San Onofre is needed, that was their word 8 "needed," for voltage support and to supply pow er to Southern California Edison -

9 - to Southern California. But the ISO has made it clear that we have an excess 10 of power without San Onofre even having tried to install thousands of rooftops, 11 solar, demand response, wind generat ion, and all these things have been 12 ignored for nearly two years now. So, it

's time to move on, and perhaps the NRC 13 should stand up, get a spine, and tell San Onofre that they're nowhere near close 14 to restarting. You can't start a brok en reactor. Thank you very much.

15 RICK DANIEL: Thank you, Ace.

16 DOUG BROADDUS: Okay, yeah.

I just briefly --

we, you know, 17 that the, as I mentioned earlie r the CAL actions, the review of the restart plan is a 18 separate activity, and that's really the intent of the meeting today. But I wanted 19 to just reinforce that we are planning to have another public meeting in California, 20 in probably the May timeframe is what we'r e looking at at this point, where we 21 would be able to discuss the issues, you k now, that we have reviewed as part of 22 this the return to service plan and our CAL actions as well as the inspection 23 activities. Ken can kind of give you some background on those, you know, the 24 specific technical questions that y ou asked about and how those, you know, 25 70 would be considered.

1 KEN KARWOSKI: Yeah, I guess in terms of you brought up the 2 multiple tube break during the steam line break. The technical specification 3 requirements for San Onofre and for other units are intended to prevent that from 4 occurring. They're supposed to have margins of safety against breakage during 5 a steam line break accident of approximately 1.4. So, the technical specification 6 requirements are intended to prevent that. That is one of the focuses of our 7 review of the return to power report is to ensure that tube int egrity would be 8 maintained consistent with those fa ctors of safety and the technical 9 specifications.

10 RICK DANIEL: All right. Thank you, gentlemen.

Operator, we'll 11 take the next caller, please.

12 FEMALE SPEAKER: John Geesman.

13 JOHN GEESMAN: This is John G eesman. I was a member of the 14 California Energy Commission during the Davis and Schwarzenegger 15 Administrations. I'm a former board mem ber of the ISO. I have a question for 16 both the NRC and for Edison. Based on information Edison has turned over for 17 the investigation being conducted by the California Public Utilities Commission, 18 even if both Units 2, Unit 3 were worki ng perfectly, there were only 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> in 19 2012 when they would've been competitiv e with the market price for power 20 Southern California. That's a little more than 1 percent of the time. Why are we 21 putting ourselves through so much regulator y pain and suffering for a plant that is 22 not cost effective 99 per cent of the time?

23 MICHELE EVANS: Well, thank you for your comments, John.

24 However, as we indicated earlier, for t he agency our focus here is on the safety 25 71 of the units and, you know, making a decis ion as to whether they're able to be 1 operated safely. With regard to your other comments and reliability and those 2 issues, that's not in the jurisdiction in the NRC.

3 JOHN GEESMAN: What's Edison's explanation?

4 RICHARD ST. ONGE: You know , we're not prepared today to be 5 talking to that. We came here with a group of technical folks, not financial folks, 6 so no comment.

7 RICK DANIEL: All right. Thank y ou, John. Operator , we'll take the 8 next caller, please.

9 OPERATOR: Ray Lutz.

10 RAY LUTZ: Yes, hello. This is Ray Lutz with Citizens Oversight.

11 And in talking about this no hazards determi nation, there were some words that I 12 didn't hear from the NRC when this wa s proposed. And the words are "you've 13 got to be kidding." I mean this is a plant that we know now -- I mean, we should 14 be given an award to SCE for their ability to avoid public meetings and public 15 scrutiny and a full technical review. The defective steam generator design 16 occurred because they worked to avoid a license amendment process, and now 17 we know that they actually didn't make changes to their steam generators after 18 they already knew that they were going to be subject to excessive fluid elastic 19 instability type of dangers. A nd they didn't do that because they didn't want to 20 have a license amendment process happen.

Now, they're coming in with a 21 request to avoid any kind of full technical re view of a plant that is already known 22 to be completely defective because of thes e steam generators. And they want to 23 add a footnote and then say to you guys, "Now we can -- we're going to be, this 24 plant is just like its brand new. It's -- there's nothing wrong with it and there's no 25 72 hazard at all." I cannot believe that thes e words did not come out of your mouth, 1 "you've got to be kidding." To make this request of the NRC and the public 2 review of this situation to come in t here, Southern California Edison, and ask for 3 a no hazard determination when we know th is plant is a suffering design mistake 4 because of your fault, a $1 billion mistake that you guys are still sucking money 5 out of the public to fund. Now, if this goes forward and the NRC says this is fine, 6 I mean, I've got to ask the NRC, doesn't th is take your breath away for someone 7 to come in and say there's no hazard at all? Even though the thing was shut 8 down, there's hundreds of tubes that ar e plugged, we put in stuff, and we did 9 analysis. We're talking about fluid elastic in stability even though a lot of it has to 10 do with random turbulence.

11 RICK DANIEL: All right.

12 RAY LUTZ: It's got to take your breath away. I mean I cannot 13 believe that this -- you guys are si tting there talking about process and how 14 you're following the procedure, but I don't even know why you're getting past 15 square one. The answer should be, "No, we

're not going to even look at that 16 stupid thing."

17 RICK DANIEL: All right.

Thank you, Ray. Michele?

18 MICHELE EVANS: Thank you for your input. You know the 19 licensee is following their process and they are looking at a license amendment 20 request, and I know you don't want to hear th at and that is the process and that's 21 the one we're following. Along with that we are doing a thorough technical 22 review of the technical issues associated with the steam gener ators. That's 23 about all I can say.

24 DOUG BROADDUS: Yeah, the only other thing that I would add to 25 73 that is that from the standpoint of the no significant hazards consideration, there 1 is specific criteria that ar e called out in the regulations that we have to review that 2 against. And actually, I'll go ahead and ju st read those so that everyone can 3 understand what those are.

"The consideration has to look at whether the 4 requested change in the amendment involv es a significant increase in the 5 probability of consequences of an accident previously evaluated. Number 2:

6 creates a possibility of a new or differ ent kind of an accident from an accident 7 previously evaluated. Number 3 involves a significant reduction in the margin of 8 safety." Those are the criteria that would have to be evaluated and they have to 9 be evaluated based upon the requested c hange in the amendment. Those are --

10 it is not something that goes beyond what is being requested in the amendment.

11 It is only what is requested in the am endment and does the change result in any 12 of those occurring and that's the criteria that we hav e to evaluate that against.

13 RICK DANIEL: Any other comment s, Ray? All right. Operator, 14 we'll take the next caller, please.

15 OPERATOR: Thank you, Thomas Herring.

16 THOMAS HERRING: Hello, this is Tom Herring; I'm a resident at 17 Mission Viejo, California, and a practici ng mechanical engineer and I just wanted 18 to respond to an earlier comment that the NRC has not done a good job with 19 making these meetings public. I've been to all the local public meetings and I'm 20 enjoying this meeting here. And I just wanted to compliment the NRC in being 21 balanced and doing a good job and t hat's all I had to say.

22 MICHELE EVANS: Thank you.

23 RICK DANIEL: Thank you, To

m. We'll take the next caller, 24 operator.

25 74 OPERATOR: Hugh Moore.

1 HUGH MOORE: Good morning.

2 RICK DANIEL: Good morning.

3 HUGH MOORE: My name is Hugh Moore; I'm a member of the --

4 treasurer of the San Diego County Green Part y, I'm also a past Navy Veteran. I 5 worked as a radiation safety technician in the Navy. And back then, you know, 6 the discussion was always you talk about sa fety, safety always comes down to a 7 risk-benefit analysis. And when you do a risk-benefit analysis, you determine the 8 amount of risk depending upon the benefits that you get back from whatever 9 you're doing. And with the SONGS plant, the benefit, of course, is energy 10 production. And when it was originally applied for -- when Edison originally 11 applied for its application, it was guar anteed 100 percent power usage from two 12 different plants that would produce power that we would be able to get from it, 13 making the benefit. And with that amount of power, that benefit was accepted as 14 a proper risk. There was enough, you know, benefit to pay for the risk that you 15 were going to receive, I mean, pay fo r the benefit that yo ur -- enough benefit to 16 pay for the risk that you were going to put the public at. Well, at this point we 17 know that neither power plant is going to work at 100 percent because there are 18 increased significant risks, which the Ed ison Company is admitting to, saying, 19 "We can't run at 100 percent. We're asking for the amendment to allow us to run 20 at less than 100 percent of only one plant."

That being the case the amount of 21 power that they're going to produce never meets the benefit to outweigh the risk.

22 So, yeah, well there is all this regulatory issue going on which I, you know, 23 respect and think we have to do obviously because we have to produce safe 24 power and we can't put the public at any gr eater risk. But I think the decision has 25 75 already been made. And I would like the NRC to respond to, how can you say 1 that the risk from running a nuclear power plant when they say they can't run it at 2 full power because of the dangers inherent in the design that they have already 3 made mistakes in, ever outweighs the --

I mean, the benefit ever outweighs the 4 risk and therefore, safety, if it is your primary concern, you can never approve 5 this amendment. So, can you respond to that?

6 RICK DANIEL: Thank you, Mr. Moore.

7 DOUG BROADDUS: I would just indicate that, you know, I 8 reinforce what I said before that as par t of the CAL process, we would not allow 9 restart of the unit, either unit, unless we

've determined that they are safe to 10 operate. And what I mean by safe to oper ate is are they able to meet all the 11 criteria, all the requirement s that are specified in our regulations, you know, all 12 the requirements in the license, you know, which are all based upon safe 13 operation, a reasonable assurance of safe operation. So, that's, you know, when 14 you talk about do the benefits outweigh the risks, you know, from that 15 perspective we need to make sure that it meets our safety criteria, all the safety 16 criteria in our requirements, and that is what we're going to be doing.

17 HUGH MOORE: Then clearly you're correct. You should be 18 looking at only safety and you are right; t herefore, you would have to approve it if 19 it met your criteria. Well, let's reme mber that your criteria should not be 20 dependent upon the capability of t he plant that's left. Your criteria should remain 21 at the same level of what you would do at a new plant. And if it can't operate at 22 100 percent, then it can' t meet the criteria.

23 RICK DANIEL: Okay. All right.

Thank you very much, Mr. Moore.

24 HUGH MOORE: I appreciate the time, thank you.

25 76 RICK DANIEL: Yes, sir. Oper ator, we'll take another caller. You 1 have how many more on the line?

2 OPERATOR: We currently have three standing by. And the next 3 question is from Gary Headrick.

4 MALE SPEAKER: Hi, Gary, go ahead.

5 GARY HEADRICK: Hi, I'm Ga ry Headrick; representing San 6 Clemente Green, about 2,000 people living in ha rm's way near it. Fi rst off, I think 7 it's important to look at the total picture when we're talking about the processes 8 the NRC is considering. And it certainly must've been a humbling experience 9 when you look back on Fukushima and rea lize how badly the seismologists and 10 engineers missed the mark in predicting what might happen. And now, you have 11 the opportunity to follow the process, which I've heard a lot about today, but 12 another process the NRC has available is the adjudicated license amendment 13 hearing. And the question to NRC is why not just go with the most safe bet, do a 14 more thorough investigation, and use all of the great minds that are at your 15 disposal to make this determination, es pecially in the fact that we need to be 16 absolutely certain that if you allow them to restart it that everyone's had a chance 17 to weigh in on that very important proc ess. So, that's a question for NRC. Why 18 not just jump right to the adjudicated license hearing and then I'd like to follow up 19 with a question to Edison.

20 RICK DANIEL: Ok ay, thank you.

21 DOUG BROADDUS: Again, I th ink, you know, I appreciate the 22 question there. You know, again, we are going to follow the process, which in 23 this case would, you know, for a --

for any license amendment request would 24 provide an opportunity to request a hearing or an opportunity for a hearing. So, 25 77 that would be there, you know, and that

's going to be provided in accordance 1 with our normal process. So, I mean, I'm not sure what else I can --

2 RICK DANIEL: Well, what you're saying, Doug, is that it's still --

3 GARY HEADRICK: Well, your process, as I understand it, your 4 process could allow for approval of a restart before we get a more thorough 5 hearing that would follow after the fa ct that Dan Hirsch so aptly put.

6 RICK DANIEL: [affirmative]

7 DOUG BROADDUS: And in that case the regulation will provide 8 that if the staf f is able to make a, you know, significant hazards consideration 9 determination that none of those criteria are met, in this case that the -- we could 10 issue an amendment in that case, even if the hearing had been requested. The 11 hearing would still occur, yes, and it woul d still occur if it was granted by the 12 ASLB. I mean that would be up to them to make that determination as to 13 whether it met all their contention and admi ssibility criteria from that standpoint.

14 But it could occur, you know, we wouldn't be able to issue it if we were able to 15 make that determination.

16 RICK DANIEL: He had a follow-up question for Edison?

17 GARY HEADRICK: Well, yeah, just to follow up on that a little 18 further. Now, you guys are the ones that got it wrong the first time when they 19 should've had a license and then to avoid this problem to begin with. And if you 20 expect the public to trust your judgment without getting ev eryone's input on this, 21 then I think you're going to get a lot of resistance and I hope it will change your 22 mind. It's just astounding to me that you would even cooperate with Edison and 23 avoid that adjudicated license amendment hearing. That's -- I just still don't 24 understand it, but I'll go on with the question for Edison, if you don't mind.

25 78 RICK DANIEL: Sure.

1 GARY HEADRICK: Edison conti nues to recite the mantra that 2 safety is first, and we know from Davi d Freeman's testimony and other people, 3 experts in the field, that we really do not have a problem meeting our energy 4 needs in the summer regardless of what their friends in the Chamber of 5 Commerce and business communities say. We

're going to be fine. And so, what 6 other reason besides profit for Edison is there to rush this decision? Can you 7 please explain why you have to rush this , because it's not for the benefit of 8 Californians?

9 RICHARD ST. ONGE: Gary, again, the folks that are with us today 10 are technical people; I don't have system-planning folks available to me. If you 11 want to get a hold of us outside of th is meeting, we can tell you what our 12 forecasts are for the Sout hern California area. I don' t have anybody here that 13 can talk to that right now.

14 RICK DANIEL: All right, thank you, Rich.

15 GARY HEADRICK: Well, thanks for your time and just please be 16 exceptionally safe and err on t he side of caution, please.

17 RICK DANIEL: Got it. Thank y ou very much, Gary.

Operator, we'll 18 take the next caller, please.

19 OPERATOR: Ted Quinn, I believe.

20 TED QUINN: Oh, yeah, my name is Ted Quinn; I'm a 30-year-21 resident of Southern Orange County, and I ce rtainly support the restart of San 22 Onofre, if in fact the NRC review and determination approves that. So, my 23 question goes to a fundamental that both our last speak er addressed and others.

24 It has to do with this no significant hazar d determination. I think there's some 25 79 confusion in this area and I'd like to ask a couple questions. First to the NRC 1 staff, is it uncommon for nuclear facili ties to request a no significant hazard 2 determination as part of a license amendm ent submittal; and second, honestly, 3 what is the purpose of a no significant hazard determination? If you could go 4 over it -- I know you read t he text earlier, if you could reinforce it, if you could, 5 please. 6 RANDY HALL: The no significant hazards consideration 7 determination, I think there' s a lot -- fair amount of misunderstanding about that.

8 That's a procedural standard to determine whether the staff can make a decision 9 as to whether a license amendment shoul d be or could be issued prior to the 10 conduct of a hearing. I think the proce ss would, as explained, would have the 11 licensee in the proposed amendment request provide their proposed no 12 significant hazards consideration determination, addressing the three criteria that 13 Doug Broaddus mentioned just a few minutes ago. The NRC in turn would 14 review that proposed no significant hazards consideration determination and 15 make its own independent judgment as to whether it agreed with the licensee's 16 analysis or believes that a no significant hazards consideration determination 17 was appropriate, and that would be published as a, again, a proposed 18 determination. The staff would review an amendment, if they found it acceptable; 19 would prepare to issue that amendment, appr ove it. If there was a request for a 20 hearing in the interim, then the staff woul d make, potentially, a finding -- a final 21 finding of no significant hazards consideration. So, it's at that point in the 22 process when the staff consciously determines there is no significant hazards 23 consideration in accordanc e with the criteria to be applied, that there'd be a 24 conscious decision to go forward with the amendment request and hold a hearing 25 80 after the fact. Once again in accordance with our process, we would notify the 1 Commission itself, the five commissioners, with at least fi ve days' notice prior to 2 issuing that amendment that we had made the final determination and we're 3 proposing to issue the amendment ev en though a hearing had been requested in 4 that case. So, the Commission would have t he discretion at that point to direct 5 the staff otherwise or take some other action, if they so chose. So, that -- did I 6 answer your question or was there a sec ond part to it that I didn't address?

7 TED QUINN: Yes, no, you answered it. I think if I could just clarify 8 what you've stated is independent of what San Onofre submits, the SCE submits, 9 the NRC staff will make an independent determination on whether it's acceptable 10 on the no hazards significant hazards determination or not, right?

11 RANDY HALL: That's correct. A nd I believe the first part of your 12 question was whether this was uncommon or common. It's required that they 13 make in their application a proposed no significant hazards determination so that 14 part is standard. I would say in a majority of cases, I don't have the statistics, the 15 staff would agree or independ ently determine that a proposed no significant 16 hazards determination was appropriate for a particular amendment request.

17 There are some cases in which that's not the case, but it is common.

18 TED QUINN: Okay. Thank y ou for going through that, I appreciate 19 it. 20 RICK DANIEL: All right. Thank you, Mr. Quinn. And operator, 21 we'll take the final caller, please.

22 OPERATOR: And Myla Reson, your line is open.

23 MYLA RESON: I'm here, and th ank you very much for taking my 24 call. I'm calling from Los Angeles, which I also consider to be part of the San 25 81 Onofre nuclear danger zone. Should a serious event happen at San Onofre, I 1 don't think that anyone in Southern Califor nia's safe. My question is, in the two 2 years following the events that tri ggered the ongoing nuclear catastrophe in 3 Fukushima, has the NRC evaluated the ability of Unit 2 to withstand a beyond 4 basis -- beyond-design-basis event, such as a great tsunami or an earthquake of 5 greater magnitude of 7.0?

And following on that, because I believe you have not, 6 and you talked about how you would only be evaluating a previously evaluated --

7 I'm sorry -- that you would be making y our determination about the no significant 8 hazard consideration based on previously evaluated criteria. Is it my 9 understanding that, in fact, you did not make this previous evaluation of the 10 beyond design basis events and you w ould not be taking them into 11 consideration?

12 RICK DANIEL: Thank you.

13 MICHELE EVANS: Okay. For th e first part of your question --

14 MYLA RESON: I have a follow up.

15 RICK DANIEL: Okay.

16 MICHELE EVANS: Okay, well wait. Let me get the first part.

17 MYLA RESON: Please.

18 MICHELE EVANS: With regard to the events of Fukushima, the 19 agency reviewed the status of our operating reactors at the, you know, not long 20 after the events of Fukushima occurr ed and determination was made that the 21 plants were safe to continue to operat

e. Actions have occurred since then, 22 though, to request additional information with regard to seismic, for one. There's 23 flooding, seismic, and several other areas.

And the plants have been, you know, 24 grouped and prioritized and we're in a proc ess now where each operating plant is 25 82 reevaluating their seismic hazards in light of new, current information in the U.S.

1 So, that was the first part. I didn't -- y ou did ask something else, but I didn't catch 2 what that was.

3 MYLA RESON: So, let me follow up on that. So, given that you're 4 still in the process of re viewing whether or not S an Onofre can withstand an 5 earthquake of greater magni tude than 7.0 and run safe ly or can withstand a 6 potential great tsunami, it is in a tsunami zone.

Is it -- there is a possibility that in 7 fact you will allow Edison to restart their damaged nuclear reactor prior to having 8 that full evaluation in place?

9 MICHELE EVANS: Okay. So, yeah --

10 MYLA RESON: Yes.

11 MICHELE EVANS: Yeah, the other view you --

12 MYLA RESON: Are you saying, yes, there is a potential for you to 13 grant that --

14 MICHELE EVANS: Yes, I'm saying --

15 MYLA RESON: -- permit pr ior to making that evaluation?

16 MICHELE EVANS: I'm saying that the activity's ongoing at all the 17 plants in the country, with regard to Fukushima follow up are not, you know, 18 nothing needs to be resolved at this point prior to the restart decision on -- for 19 SONGS. 20 MYLA RESON: And why is that?

21 MICHELE EVANS: That goes back to the initial thing I said where 22 following the events of Fukushima, the reviews were conducted and the agency 23 determined that all plants at that point, unless there's something specific about a 24 particular plant, were safe to continue to operate.

25 83 RICK DANIEL: All right. And Doug, you're going to address the no 1 significant hazards question.

2 DOUG BROADDUS: Yeah, I thin k you asked the question as well 3 as to whether or not those actions are part of the no si gnificant hazards 4 consideration determination, and those are not. What is part of that no significant 5 hazards consideration determination is the change to the license that is being 6 requested. That's what we have to l ook at is, is the change that is being 7 requested; does that change increase the probability or, you know, significantly 8 increase -- result in a significant increase and the probability of those criteria.

9 So, and again, that does not consider other ac tivities that are ongoing. It's not --

10 you can't -- it doesn't go beyond the amend ment request. It has to be focused 11 only on the changes in the amendment request.

12 RICK DANIEL: And just a follow up --

13 MYLA RESON: You know, w hat I'd like to remind you that 14 Chairman Macfarlane stated, that as a geologist she has "an acute appreciation 15 of the challenge of predicting the earth's behavior, and that since the earth is 16 constantly changing and our reco rded knowledge represents roughly one-17 millionth of the ear th's history, there is much we don't know. In light of this, we 18 must be wise in balancing confidence in our engineering prowess with the 19 humble recognition that natural syst ems have repeatedly dem onstrated the ability 20 to confound us." Those are the word s of Chairman Macfarlane. I have no 21 confidence that you, you know, that y ou would restart a damaged nuclear reactor 22 in a tsunami zone riddled with earthquake f aults. I'm just appalled by that 23 possibility. I think that t he hubris that is demonstrated by your confidence in your 24 determination is just absolutely shocking.

25 84 RICK DANIEL: All right. Thank you very much, ma'am, for your 1 comments and your questions. We certai nly appreciate your opinion. And 2 operator, that will conclude our questions from folks on the phone today. I'm 3 going to ask for closing comments from Southern California Edison, anything you 4 folks like to say in conclusion of the meeting today?

5 RICHARD ST. ONGE: Again, I want to thank the NRC for their 6 time today in providing Edison with a very candid feedback on the proposed 7 license amendment. Doug, I understand you'd like to get a proposed 8 amendment to you as soon as possible so you can continue the work so I'll take 9 that back to the management at Southern Califor nia Edison and we'll arrive at a 10 decision as quickly as possible, thank you.

11 RICK DANIEL: NRC?

12 MICHELE EVANS: Yeah. Once again, I just want to thank 13 everyone for their time and every one's input and opini ons, thank you.

14 RICK DANIEL: And that wraps up our meeting, but I'd just like to 15 add a personal note. I've had the privilege, and I'd be remiss if I didn't say 16 something, but I want to thank the NRC for giving me the opportunity to facilitate 17 these meetings over the last year.

They've been interesting, they've been 18 challenging, but I'm going to be leavi ng the NRC here in 30 days, moving on to 19 new horizons, and I certainly want to thank the activists and the non-20 governmental organizations and all the peopl e I've met for having faith in me 21 running these meetings. And Southern California Edison and the NRC, I know 22 you'll continue to try to do what you're saying you're going to do and I have faith 23 in the process. So, thank you very much. I wish you all a good evening.

24 DOUG BROADDUS: And we really do appreciate, Rick, all the 25 85 help you've given to us, I mean, you've been an integral part of these meetings 1 and helped us out in getting through them and being a facilitator to help, you 2 know, make things run smoothly and we will certainly miss you. And it'll be hard 3 to find somebody to fill your shoes, but --

4 RICK DANIEL: Well, honestly, it

's been my pleasure and I wish the 5 very best to the next person that comes along, thank you.

6 DOUG BROADDUS: Thank you.

7 MALE SPEAKER: Thanks, the meeting is concluded.

8 [Whereupon, the proceedings were concluded]

9