ML061700046

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Enclosure 3: Afternoon Transcript, Public Scoping Meeting for Pilgrim, 05/17/2006
ML061700046
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Site: Pilgrim
Issue date: 05/17/2006
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Williamson A
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1 2 UNITED STATES OF AMERICA 3 NUCLEAR REGULATORY COMMISSION 4 + + + + +

5 6

7 - - - - - - - - - - - - - - - - -x 8 IN THE MATTER OF:  :

9 PUBLIC SCOPING MEETING 10  :

11 FOR 12  :

13 PILGRIM NUCLEAR POWER STATION  :

14 - - - - - - - - - - - - - - - - -x 15 Aternoon Meeting 16 Wednesday 17 May 17, 2006 18 19 Ballroom 20 Radisson Hotel Plymouth 21 180 Water Street 22 Plymouth, Massachusetts 23 24 The above-entitled matter was convened, 25 pursuant to Notice, at 1:30 p.m.

26 BEFORE: Chip Cameron Neal R. Gross & Co., Inc.

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1 Rani Franovich 2 Robert Schaaf Neal R. Gross & Co., Inc.

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2 1 I N D E X 2 SPEAKER: PAGE:

3 Chip Cameron 3 4 Rani Franovich 8 5 Robert Schaaf 16 6 Molly Bartlett 24 7 Mary Lampert 27 8 Keith Maxwell 29 9 Corwne Young 31 10 Mark Sylvia 33 11 Alba Thompson 41 12 Joyce McMahon 45 13 Pine du Bois 49 14 Robert Ruddock 59 15 Jim O'Connell 61 16 Frank Collins 64 17 Rick Anderson 67 18 19 20 21 22 23 24 25 Neal R. Gross & Co., Inc.

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3 1 P R O C E E D I N G S 2 (1:30 p.m.)

3 MR. CAMERON: Good afternoon, everyone, we 4 are going to get started with this afternoon's meeting.

5 My name is Chip Cameron and I am the Special Counsel 6 for Public Liaison at the Nuclear Regulatory 7 Commission, which we will be referring to as the NRC 8 today. And I would just like to welcome all of you to 9 the NRC's public meeting and our subject this afternoon 10 is the environmental review that the NRC conducts as 11 part of its evaluation of an application that we 12 received from the Entergy to renew the operating 13 license for the Pilgrim reactor, and it's my pleasure 14 to serve as your facilitator today and, in that role, 15 I'll try to help all of you to have a productive 16 meeting.

17 I just want to talk a little bit about 18 some meeting process items before we get into the 19 substance of our discussions today and I would like to 20 address three things: First, the format for today's 21 meeting, second of all, the ground rules for the 22 meeting and, third, I just want to introduce the NRC 23 speakers who will be giving you some brief 24 presentations in a short while.

25 In terms of the format for the meeting, Neal R. Gross & Co., Inc.

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4 1 it's a two-part format. The first part of the meeting 2 is to provide you with some background information on 3 the NRC's license renewal process, generally, and 4 specifically on the environmental review that the NRC 5 conducts as part of its evaluation about whether to 6 grant this license application. And we'll be having 7 some questions, we'll go on to you for questions after 8 those two brief presentations.

9 The second part of the meeting is to hear 10 from you, it gives us an opportunity to listen to your 11 comments and concerns on license renewal and 12 specifically on the environmental review. The NRC 13 staff is going to tell you that this is a scoping 14 meeting and that is a term that is associated with the 15 preparation of an environmental impact statement and, 16 basically, it stands for what should be the scope of 17 this environmental impact statement? What issues 18 should the NRC look at in preparing the environmental 19 impact statement? What alternatives should the NRC 20 look at?

21 We are going to give you an opportunity to 22 give us some formal comments during the second part of 23 the meetings, and we are going to be taking written 24 comments and the staff will tell you more about that, 25 but we wanted to be with you in person today, to listen Neal R. Gross & Co., Inc.

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5 1 to you, and any comments that you make today will carry 2 the same weight as written comments that we receive.

3 In terms of ground rules, they are very simple.

4 If you have a question, when we go to the 5 question part of the meeting, just raise your hand, and 6 I'll bring you this cordless microphone, and please 7 introduce yourself to us and any affiliation, if that 8 appropriate, and we'll do our best to answer your 9 question.

10 And I would just ask you to keep it to 11 questions during that question period because a lot of 12 times we get into a comment with the question, but save 13 the comment for the comment part of the meeting. I 14 would ask that only one person speak at a time for two 15 very important reasons, one is so that we can give our 16 full attention to whomever has the floor at the moment 17 but, secondly, so that we can get a clean transcript.

18 Mr. Marty Farley is our court reporter and he is taking 19 a transcript of this meeting that will be available to 20 anybody that wants to get a copy of it. It's our 21 record for the meeting so, if there is only one person 22 speaking at a time, Marty will know who it is.

23 And I would just ask you to try to be 24 brief, it's difficult with these issues, they are 25 complicated, they are controversial, but try to be Neal R. Gross & Co., Inc.

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6 1 brief and when we get to the formal comment part of the 2 meeting, I like to use a five minute guideline for the 3 presentations. We'll ask you to come up here to talk 4 to us, and it is a guideline, we have the flexibility, 5 I think, at least this afternoon, with the number of 6 speakers that we have, to let you go on a little bit, 7 but usually five minutes is enough time to summarize 8 the comments and it does achieve two important 9 objectives for us.

10 First of all, it alerts the NRC staff to 11 issues of concern that we can start trying to address 12 and think about immediately, including talking to you 13 in more detail after the meeting. And the second thing 14 it does, even though it's five minutes, it alerts 15 everybody else in the community, in the audience, to 16 what some of the concerns are. And of course, if you 17 want to amplify on your oral comments today, you can 18 always amplify by submitting written comments.

19 And I guess a last ground rule is the fact 20 that you are going to hear different opinions, opinions 21 that you might not agree with today, and I just would 22 ask you to extend courtesy to everybody, even though 23 they have a different, they might have a different 24 opinion than you do, and just listen to what people are 25 saying. That's certainly why the NRC is here, to Neal R. Gross & Co., Inc.

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7 1 listen to everybody.

2 And in terms of our speakers, we are going 3 to start off in a minute or so with Ms. Rani Franovich, 4 who is right here, and Rani is the chief of the 5 environmental section in our license renewal and 6 environmental impact program and she is in charge of 7 the NRC staff who does the environmental analysis on 8 these license renewal applications. And Rani has been 9 with the NRC for approximately 15 years in a number of 10 positions, including being a resident inspector of the 11 NRC at Catawba, the nuclear power plant down in South 12 Carolina, and Rani in fact is going to tell you what 13 our resident inspectors do, we have them at every 14 reactor that we oversee.

15 She also has been a project manager on 16 license renewal applications, in terms of the safety 17 evaluation that's done, and she has also served as the 18 enforcement coordinator for our Office of Nuclear 19 Reactor Regulation and, in that position, she 20 coordinated what enforcement actions should be taken 21 against licensees who had not complied with our 22 regulations.

23 In terms of education, she has a 24 bachelor's degree in psychology from Virginia Tech and 25 she has a master's degree from Virginia Tech in Neal R. Gross & Co., Inc.

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8 1 industrial and systems engineering, and she is going to 2 be giving you an overview of the license renewal 3 process.

4 We are then going to get into more detail 5 on the environmental aspects of the license renewal 6 process and we are going to go to Mr. Bob Schaaf, who 7 is right here, and Bob is in Rani's section and Bob has 8 been with the agency for about 15 years, with the 9 Nuclear Regulatory Commission. And he was a project 10 manager for operating reactors and also has served as a 11 project manager for the environmental review on a 12 number of other license applications. And before Bob 13 came to the NRC, he was with the Charlestown Naval 14 Shipyard, he was an engineering supervisor down there, 15 and he has also had some regional experience with the 16 NRC. He has a bachelor's in mechanical engineering 17 from Georgia Tech.

18 And I would just thank all of you for 19 being here to help us with this decision, and we knew 20 it was an auspicious day to have this meeting on 21 environmental issues because when we woke up this 22 morning, we saw some strange object in the sky, and we 23 are still not sure what that is but, at any rate, Rani?

24 MS. FRANOVICH: Thank you, Chip.

25 And thank you all for taking the time out Neal R. Gross & Co., Inc.

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9 1 of your schedules to participate in this meeting, it's 2 an important part of our environmental review process 3 and we are very happy to have you here. I hope the 4 information we provide today will help you understand 5 the process we'll be going through and the role that 6 you can play in helping us make sure that the 7 environmental impact statement for Pilgrim is accurate 8 and complete.

9 The next slide, please, Andy?

10 I would like to start off by briefly going 11 over the purpose of today's meeting. We'll explain the 12 NRC's license renewal process for nuclear power plants 13 with emphasis on the environmental review process, and 14 we'll talk about typical areas included in our 15 environmental review. We'll also share with you the 16 license renewal review schedule, then really the most 17 important part of today's meeting is to receive 18 comments from you that you may have on the scope of our 19 environmental review. We also will give you some 20 information about how you can submit comments outside 21 this meeting.

22 At the conclusion of the staff's 23 presentation, we will be happy to answer any questions 24 and receive any comments that you may have on the 25 process and the scope. However, I must ask you to Neal R. Gross & Co., Inc.

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10 1 limit your participation to questions only and hold 2 your comments until the appropriate time during today's 3 meeting. Once all questions are answered, we can begin 4 to receive any comments you have on the scope of our 5 environmental review.

6 Next slide, please.

7 Before I get into a discussion of the 8 license renewal process, I would like to take a minute 9 to talk about the NRC in terms of what we do and what 10 our mission is. The Atomic Energy Act is the 11 legislation that authorizes the NRC to issue operating 12 licenses. The Atomic Energy Act provides for a 40 year 13 license term for power reactors, this 40 year term is 14 based primarily on economic considerations and anti 15 trust factors, not on safety limitations of the plant.

16 The Atomic Energy Act also authorizes the NRC to 17 regulate the civilian use of nuclear materials in the 18 United States.

19 In exercising that authority, the NRC's 20 mission is threefold, to ensure adequate protection of 21 public health and safety, to promote the common defense 22 and security, and to protect the environment. The NRC 23 accomplishes its mission through a combination of 24 regulatory programs and processes, such as conducting 25 inspections, issuing enforcement actions, assessing Neal R. Gross & Co., Inc.

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11 1 licensee performance and evaluating operating 2 experience from nuclear plants across this country and 3 internationally. The regulations that the NRC enforces 4 are contained in Title 10 of the Code of Federal 5 Regulations, which is commonly referred to as 10 CFR. 6 Next slide, please.

7 As I've mentioned, the Atomic Energy Act 8 provides for a 40 year license term for power reactors.

9 Our regulations also include provisions for extended 10 plant operation for up to an additional 20 years. For 11 Pilgrim, the operating license will expire June 8, 12 2012. Entergy has requested license renewal for 13 Pilgrim. As part of the NRC's review of the license 14 renewal application, we will perform an environmental 15 review to look at the impacts on the environment of an 16 additional 20 years of operation.

17 The purpose of this meeting is to give you 18 information about the process and to seek your input on 19 what issues we should consider within the scope of our 20 review.

21 Next slide, please.

22 The NRC's license renewal review is 23 similar to the original licensing process in that it 24 involves two parts, an environmental review and a 25 safety review. This slide really gives a big picture, Neal R. Gross & Co., Inc.

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12 1 overview, of the license renewal process, which 2 involves these two parallel paths. See, the safety 3 review in the upper part of the slide and then the 4 environmental review below. I'm going to briefly 5 describe these two review processes, starting with the 6 safety review.

7 Next slide, please.

8 Two guiding principles form the basis of 9 the NRC's approach to performing its safety review.

10 The first principle is that the current regulatory 11 process is adequate to ensure that the licensing basis 12 of all currently operating plants provides and 13 maintains an acceptable level of safety with the 14 possible exception of the effects of aging on certain 15 structures, systems and components.

16 The second principle is that the current 17 plant specific licensing basis must be maintained 18 during the renewal term in the same manner and to the 19 same extent as during the original license term. Next 20 slide, please.

21 You might ask what does the safety review 22 consider? For license renewal, the safety review 23 focusing on aging management of systems, structures and 24 components that are important to safety, as determined 25 by the license renewal scoping criteria contained in 10 Neal R. Gross & Co., Inc.

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13 1 CFR Part 54. The license renewal safety review does 2 not assess current operational issues such as security, 3 emergency planning and safety performance. The NRC 4 monitors and provides regulatory oversight of these 5 issues on an ongoing basis under the current operating 6 license. Because the NRC is addressing these current 7 operating issues on a continuing basis, we do not 8 reevaluate them again in license renewal.

9 Next slide, please.

10 As I have mentioned, the license renewal 11 safety review focuses on plant aging and the programs 12 that the licensee has already implemented or will 13 implement to manage the effects of aging.

14 Let me introduce Mr. Ram Subbaratnam. Ram 15 is the safety project manager, he is in charge of the 16 staff safety review. Thank you, Ram.

17 The safety review involves the NRC staff's 18 evaluation of technical information that is contained 19 in the license renewal application, this is referred to 20 as the safety evaluation. The NRC staff also conducts 21 audits as part of its safety evaluation. There is a 22 team of about 30 NRC technical reviewers and 23 contractors who are conducting the safety evaluation at 24 this time.

25 The safety review also includes plant Neal R. Gross & Co., Inc.

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14 1 inspections, the inspections are conducted by a team of 2 inspectors from both headquarters and NRC's Region One 3 office in King of Prussia, Pennsylvania. A 4 representative from our inspection program is here 5 today, the senior resident inspector at Pilgrim is Bill 6 Raymond. Bill, could you stand up?

7 As Chip mentioned, we have resident 8 inspectors who live in the community for all nuclear 9 power plants, live in the community and work at the 10 plant 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> a week. They are the eyes and the ears 11 of the agency and Bill serves that role at Pilgrim.

12 The staff documents the results of its 13 review in a safety evaluation report, that report is 14 then independently reviewed by the Advisory Committee 15 on Reactor Safeguards or the ACRS. The ACRS is a group 16 of nationally recognized technical experts that serve 17 as a consulting body to the Commission. They review 18 each license renewal report or license renewal 19 application and safety evaluation report, they form 20 their own conclusions and recommendations on that 21 requested action and they report those conclusions and 22 recommendations directly to the Commission.

23 Next slide, please.

24 This slide illustrates how these various 25 activities make up the safety review process. I would Neal R. Gross & Co., Inc.

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15 1 like to point out that the hexagons on the slide, like 2 these, these represent opportunities for public 3 participation and also, when the staff presents the 4 results of its safety review to the Advisory Committee 5 on Reactor Safeguards, that presentation will be open 6 to the public.

7 Next slide, please.

8 The second part of the review process 9 involves an environmental review with scoping 10 activities and the development of an environmental 11 impact statement. As I've said, we are here today to 12 receive your comments on the scope of that review, we 13 will consider any comments on the scope that we receive 14 at this meeting or in any written comments. Then, in 15 December of this year, we expect to issue the draft 16 environmental impact statement for comment.

17 Next slide, please.

18 So, the final agency decision on whether 19 or not to issue a renewed operating license depends on 20 several inputs, inspection reports and a confirmatory 21 letter from the Region One administrator, conclusions 22 and recommendations of the ACRS which are documented in 23 a letter to the Commission, the safety evaluation 24 report which documents the results of the staff's 25 safety review and the final environmental impact Neal R. Gross & Co., Inc.

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16 1 statement which documents the results of the 2 environmental review.

3 Again, the yellow hexagons on the slide 4 indicate opportunities for public participation, an 5 early opportunity is during the scoping meeting today.

6 The meeting on the draft EIS is another opportunity.

7 At this time, there is still an opportunity to request 8 a hearing, that opportunity remains open until May 27th 9 of this year. As I mentioned, the ACRS meetings also 10 are open to the public.

11 Before I turn the presentation over to Bob 12 Schaaf, I would like to mention a change in the staff 13 safety review team. Bob has been the environmental 14 project manager for Pilgrim up until this time.

15 However, he is assuming new responsibilities and is 16 turning the project over to Alicia Williamson. Alicia, 17 can you please stand? Alicia will be the new project 18 manager for Pilgrim, pretty much effective today.

19 Bob will now discuss the environmental 20 review in more detail.

21 Bob?

22 MR. SCHAAF: Thank you, Rani.

23 Again, my name is Bob Schaaf, I'm the 24 Environmental Project Manager with the NRC staff 25 responsible for review of the Pilgrim license renewal Neal R. Gross & Co., Inc.

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17 1 application. As Rani mentioned, Alicia will be taking 2 on that responsibility going forward, I will continue 3 to have some involvement in the process, as we transfer 4 that responsibility, going forward. I would like to 5 take the next 15 minutes or so just to discuss, in a 6 little more detail, the environmental review process 7 and how the public can participate in that process.

8 The National Environmental Policy Act of 9 1969, or NEPA, requires that federal agencies follow a 10 systematic approach in evaluating potential 11 environmental impacts associated with certain actions.

12 We are required to consider the impact of the proposed 13 action and to consider mitigation for impacts that we 14 consider to be significant. We are also required to 15 consider the impacts of alternatives to proposed 16 action, in this case, license renewal. Alternatives 17 include the no action alternative. In other words, 18 simply not renewing the license, as well as 19 construction and operation of replacement power 20 generating facilities or other means of accounting for 21 the loss of generation in the event that the license 22 were renewed.

23 The NEPA process requires development of 24 an environmental impact statement, or EIS, for any 25 proposed action that may significantly effect the Neal R. Gross & Co., Inc.

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18 1 quality of the human environment. NEPA and our 2 environmental impact statement are disclosure tools, 3 they are specifically structured to involve public 4 participation, this meeting is a part of that effort to 5 involve the public in our environmental review.

6 Specifically, we are here to gather information on the 7 scope of our review, what special issues should the 8 staff consider for the proposed Pilgrim license 9 renewal?

10 The Commission has determined that an 11 environmental impact statement will be prepared for the 12 proposed renewal of nuclear power plant licenses. The 13 NRC staff developed a generic impact statement for 14 license renewal, referred to as the GEIS, that 15 identifies a number of issues common to all nuclear 16 plant license renewals. The staff is supplementing 17 that generic impact statement with a site specific 18 impact statement, referred to as the SEIS, that will 19 address issues that are specific to the Pilgrim site.

20 Now I would like to provide a little more 21 information about the GEIS. The generic environmental 22 impact statement for license renewal, which is referred 23 to as the GEIS, it's also known as NUREG 1437, 24 identifies 92 environmental issues that are evaluated 25 for license renewal, 69 of these issues are considered Neal R. Gross & Co., Inc.

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19 1 generic, or category one, which means that the impacts 2 are similar for all reactors or for all reactors with 3 certain features, such as plants that have cooling 4 towers. Only certain issues addressed in the GEIS are 5 applicable to Pilgrim. For example, GEIS issues 6 related to cooling towers would not be applicable 7 because the plant does not use cooling towers.

8 For those category one issues that are 9 applicable to Pilgrim, we will assess whether there is 10 any new information related to the issue that might 11 effect our conclusion reached in the GEIS. If there is 12 no new information, then the conclusions of the GEIS 13 will be adopted for Pilgrim. If new information is 14 identified and determined to be significant, then a 15 site specific analysis will be performed for that issue 16 and, as shown on the left of the slide, identification 17 of new and significant information is one area where 18 public participation, during scoping, is particularly 19 important.

20 Of the remaining 23 issues, 21 are 21 referred to as category two, indicating that the NRC 22 staff found that a site specific analysis is needed to 23 determine the potential impacts. For example, 24 potential impacts to threatened or endangered species 25 need to be evaluated for each site because the species Neal R. Gross & Co., Inc.

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20 1 present will differ from one site to another.

2 The remaining two issues, environmental 3 justice and potential chronic effects of transmission 4 line electromagnetic fields, were not categorized in 5 the GEIS and a site specific analysis is required for 6 these issues as well, and a site specific analysis will 7 be performed for all category two and uncategorized 8 issues that are applicable to Pilgrim.

9 Finally, the NRC staff will look for 10 potential new issues that were not identified in the 11 GEIS and, again, identification of potential new issues 12 is another area where public participation, 13 participation, during scoping, is important. This 14 slide shows our decision standard for the environmental 15 review. To paraphrase, we are trying to determine 16 whether the environmental impacts of license renewal 17 are great enough that license renewal for Pilgrim would 18 be unreasonable. In other words, is license renewal 19 acceptable from an environmental perspective?

20 This slide lists important milestone dates 21 for our review, the highlighted dates indicate 22 opportunities for public involvement. Our Federal 23 Register notice of intent to prepare an environmental 24 impact statement and conduct scoping started the 25 scoping period for our environmental review. The Neal R. Gross & Co., Inc.

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21 1 purpose of scoping, again, is to scope out or define 2 the bounds of our environmental review. As I noted 3 previously, we are especially interested in identifying 4 any potential new and significant information and any 5 potential new issues. This meeting is a part of the 6 scoping process, comments from the public are an 7 important tool in helping us define the scope of the 8 review.

9 The meeting is being transcribed, as Chip 10 noted, and comments provided here carry the same weight 11 as written comments submitted to the NRC. Written 12 comments can also be submitted to the NRC through June 13 16th. We'll issue a scoping summary report in August, 14 2006, that will address all of the comments we received 15 during the scoping period. We currently anticipate 16 publishing the draft impact statement, the supplement, 17 in December of 2006 and we will provide an opportunity 18 for public comment on the draft impact statement and 19 plan to have another meeting here in January to receive 20 comments on the draft.

21 Once the comment period closes, we will 22 develop the final impact statement, which we expect to 23 publish in August of 2007. If you would like a copy of 24 any of these reports sent directly to you, please be 25 sure and leave your name and mailing address with us by Neal R. Gross & Co., Inc.

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22 1 filling out either a blue or yellow card, depending 2 upon whether or not you intend to provide comments, at 3 the registration desk. At this point, we are in the 4 process of gathering information needed to prepare our 5 draft supplemental impact statement.

6 As indicated here, we rely on a range of 7 information sources. Two weeks ago, members of the NRC 8 staff and a team of contracted environmental experts 9 conducted an environmental audit to help us gather 10 information to support our review. In addition to 11 meeting with the applicant and observing conditions at 12 the site, members of our team also met with local, 13 state and other federal agencies to gather information.

14 Comments provided at this meeting and written comments 15 submitted to the NRC by June 16th will also inform our 16 review.

17 Our team looks at a wide range of 18 environmental impact areas, some of the areas 19 considered include air quality, water quality and 20 potential effects on plants, wildlife and the people 21 living in the vicinity of the plant. We also consider 22 environmental justice, which focuses on whether there 23 are minority or low income population groups that may 24 be disproportionately impacted by the proposed license 25 renewal. This slide provides contact information, in Neal R. Gross & Co., Inc.

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23 1 case you have additional questions after today.

2 Alicia and myself are the designated 3 points of contact at the NRC for the environmental 4 portion of the license renewal review. As noted 5 earlier, Ram is the project manager for the aging 6 management portion of the review and contact 7 information for Ram is available on our website.

8 Although our phone numbers are provided here, we still 9 need to get your specific comments regarding the 10 environmental review in a form that we can document, 11 either in writing or, as Chip has indicated, through 12 oral comments given at this transcribed meeting, the 13 transcript will become the written record of your 14 comments.

15 Arrangements have been made for the 16 documents associated with the environmental review to 17 be available locally. The Plymouth Public Library, 18 Kingston Public Library and the Duxbury Free Library 19 have all been kind enough to make some shelf space 20 available for documents related to our environmental 21 review. Also, documents are available through our 22 document management system, which can be accessed on 23 our internet home page, and the draft and final impact 24 statements will be posted on the license renewal Web 25 page. After this meeting, comments can be submitted by Neal R. Gross & Co., Inc.

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24 1 mail, by e-mail or in person at NRC headquarters.

2 You can send specific written comments to 3 us at the address shown, you can submit comments by 4 e-mail at the e-mail address provided. Finally, 5 although not too many people take advantage of this 6 option, comments can be delivered in person, if you 7 happen to be in the Rockville, Maryland area. And that 8 concludes the formal presentation on the review 9 process, we can take questions.

10 MR. CAMERON: Thank you, Bob, and thanks, 11 Rani.

12 We have some time for questions about the 13 process. Yes? And if you could just introduce 14 yourself to us?

15 MS. BARTLETT: Hi. Molly Bartlett from 16 Duxbury. Bob, I just wasn't sure whether you meant 17 that those site audit documents are also available to 18 the public at the libraries. Is that what you meant?

19 Like information that you've gathered from your site 20 visit.

21 MR. SCHAAF: All of the information that 22 we gather will be placed in our document management 23 system on our website. We can look into providing 24 copies of the documents for the libraries.

25 MS. BARTLETT: That's not necessary, as Neal R. Gross & Co., Inc.

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25 1 long as they are going to be online, the actual 2 information that you are going to be putting into--

3 MR. SCHAAF: Right, it will all be placed 4 in the document management system.

5 MR. CAMERON: And Bob, is that, is the 6 best way to get that information to go to the website 7 and go to the Pilgrim license renewal part or to 8 actually go into what's called ADAMS, which is the 9 document management system?

10 MR. SCHAAF: Selected documents are on the 11 license renewal website, the application and the 12 supplements, when it's issued, will be on the license 13 renewal website. Most of the documents, you'll need to 14 go through ADAMS.

15 MR. CAMERON: Yeah, it's easier to get 16 them off the Web, but I think what Bob is saying is 17 that the complete collection will be in ADAMS, but 18 there will be several that will be on the website.

19 Rani, do you want to amplify a little bit 20 on this?

21 MS. FRANOVICH: Yes, I just wanted to 22 mention that there will be an appendix to the draft 23 supplement that sites all of the ADAMS documents by 24 accession number, so that should help you access those.

25 That wont be available until we, until we actually Neal R. Gross & Co., Inc.

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26 1 issue the draft SEIS, but the other thing I wanted to 2 mention was that the application itself and our draft 3 and final documents will be available at the library.

4 MR. CAMERON: I think what Rani is saying 5 about the accession numbers is that makes it much 6 easier to find the document in ADAMS because you just 7 put the accession number in, rather than having to do a 8 search.

9 Is that correct, Bob?

10 MR. SCHAAF: Yeah, yeah.

11 MR. CAMERON: All right.

12 MR. SCHAAF: The accession number is one 13 way to more easily locate documents in ADAMS.

14 MR. CAMERON: And where will the numbers 15 be, on the website?

16 MR. SCHAAF: Well they will be listed in 17 the draft, when it's issued, but we'll also, I don't 18 have an exact time frame but we will be issuing a brief 19 audit summary and that will list all of the documents 20 that we collected during the audit and list their 21 accession numbers.

22 MR. CAMERON: And will that be if someone 23 wants to get those accession numbers from the audit, 24 can they go to the website and see here is all the 25 accession numbers for the audit?

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27 1 MR. SCHAAF: Yeah, we'll figure out the 2 best way to get that information to you.

3 MR. CAMERON: All right, thank you.

4 MR. SCHAAF: We'll make it easily 5 available. We'll certainly send a copy of the audit 6 summaries to the library and then we can look at 7 providing a link to the audit summary at the license 8 renewal website.

9 MR. CAMERON: Okay, great. And we have 10 another question here.

11 MS. LAMPERT: Yes, Mary Lampert, Town of 12 Duxbury Nuclear Advisory Committee. I just wanted to 13 know whether that will include the models that the 14 licensee based their decisions on too, meaning like the 15 direct torus vent system when they said a filter would 16 reduce by half what was put out. I would like to see 17 where the model is, so will you have their data there 18 too?

19 MR. SCHAAF: I'm not sure I caught all of 20 that, with the technical problems.

21 MR. CAMERON: We apologize for, I guess 22 it's this microphone in a certain position, perhaps, 23 and I don't know why. It may just be Mary and Molly, I 24 don't know, no, I'm teasing.

25 The models that the licensee relies on in Neal R. Gross & Co., Inc.

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28 1 the application to predict certain things, will those 2 models be available to people? And when you say models 3 available, you mean the actual computer program or ?

4 MS. LAMPERT: What I was meaning, how they 5 came to their conclusion, their inputs, and that's why 6 I gave the example of the direct toras vent system 7 where they came up with what a filter would and would 8 not do, but there is not an explanation of the basis on 9 how they came to that conclusion, so what I'm looking 10 for is to see the substance so we can determine whether 11 their conclusions were accurate and then whether your 12 assessment was accurate of them also.

13 MR. SCHAAF: You are speaking specifically 14 of the severe accident mitigation alternatives 15 analysis? Some of the models will be available, if 16 they are available, and if they are referenced and they 17 have been reviewed by the staff before. If the staff 18 believes that they need to have those available to 19 review, then we would ask for those to be docketed, but 20 we are just getting into the review, particularly of 21 the SAMAs, and so I don't know exactly what they are 22 asking for, at this point.

23 MR. CAMERON: But it would be publicly 24 available, if we requested it?

25 MR. SCHAAF: If we request that it be Neal R. Gross & Co., Inc.

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29 1 submitted, it would be docketed. If it's a model that 2 exists and the staff is aware of, it may be in our 3 docket files and we can certainly check on that.

4 MR. CAMERON: Okay, thank you, Bob.

5 Other questions about the process? Yes, 6 sir?

7 MR. MAXWELL: Keith Maxwell.

8 There is some generic industry information 9 being researched and coming out, for instance, the 10 generic letter 200402 for containment cooling, long 11 term cooling of fuel is being applied now to PWRs, 12 which originally started with the BWRs, and the NRC is 13 doing some extensive research on chemical effects, 14 specifically, which could impact containment peak 15 temperatures, temperatures in the modeling just 16 discussed. Is the NRC including this emerging 17 experience and information in their modeling? And 18 specifically, are they taking a look at generic letter 19 200402 for chemical effects on BWRs, and recirculation 20 in long term cooling?

21 MR. CAMERON: Thank you, Keith.

22 MR. SCHAAF: I think that would fall under 23 current operating issues that we look to resolve for 24 all plants, regardless of whether they are in license 25 renewal space or if they are just operating and have Neal R. Gross & Co., Inc.

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30 1 not submitted, so I would say that's not something 2 that's considered. I mean we evaluate all issues for 3 their potential implications for the license renewal 4 safety review, whether if, to look for whether there 5 are additional issues that require aging management 6 programs.

7 If there were an aging issue associated 8 with that particular technical issue, our safety review 9 staff does issue what are referred to as interim staff 10 guidance documents that are interim updates to the 11 guidance documents which guide the aging management 12 review, and any evolving issues related, that are 13 related to aging, that need to be considered for 14 license renewal, that come out of operating issues, 15 would be captured in those documents, and so that's, if 16 there is a suggestion that this is something that has 17 an aging management component, our staff may already 18 have considered that, or they are here, and they've 19 heard that concern, and they can take that, and go back 20 and consider whether it should be considered as part of 21 the aging management review.

22 MR. CAMERON: Keith, does that answer your 23 question? Okay, all right.

24 Other questions, at this point? Okay, 25 great. Let's move to the comment part of the meeting, Neal R. Gross & Co., Inc.

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31 1 and I would ask you to come up here. If you feel more 2 comfortable staying where you are, you can use the 3 cordless. We are going to first go to a representative 4 from Congressman Delahunt's office and it's Ms. Young.

5 I'm not sure exactly how to pronounce your first name, 6 so perhaps you can tell us that. Go ahead.

7 MS. YOUNG: Hello. Is this on? Okay. My 8 name is Corwne, Corwne Young, District Representative 9 for Congressman Bill Delahunt, and I'm here to thank 10 the NRC and all, everyone who came out today to focus 11 on this plant. Brief remarks.

12 Clearly nuclear power today is an 13 important part of our nation's energy mix. For 14 Pilgrim, specifically, for the region, it's a 15 significant energy source, it provides high paying, you 16 know, good jobs and revenues for the communities. All 17 this being said, the plant get a green light, and we 18 know the NRC takes very seriously public comments today 19 and those that will be provided in the future. The 20 congressman will provide written comments in the 21 future.

22 Four issues of particular importance, two 23 of them outside the scope of this environmental review, 24 emergency evacuation plans and safety. Today, the 25 congressman sent a letter with Ed, with Congressman Ed Neal R. Gross & Co., Inc.

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32 1 Markey to the NRC, specific to safety, on the design 2 basis threat, you'll get that soon. On emergency 3 evacuation plans, he does feel that although MEMA and 4 FEMA are doing their best, money needs to be provided 5 for an independent analysis of the plant today, 6 irrespective of relicensing, and he is working on that.

7 For relicensing, for scoping, the 8 congressman's office does request and urge that you do 9 include rigorous, new safeguards for public health and 10 safety, particular to ground water, potentially new 11 wells and air protections for any potential new 12 insignificant radiation exposure, and also 13 meteorological upgrades, potentially. All of these 14 should be included in your scope, the analysis 15 rigorous, de novo is the term the congressman likes to 16 use. He recognizes that these all come at a cost, but 17 the failure to detect any new or significant concerns 18 is too high of a cost.

19 And you know, the community, while there 20 is a lot of support for the plant, the community 21 demands, and expects and should get due diligence and 22 proper attention to public health and safety. Thank 23 you.

24 MR. CAMERON: Great, thank you, Corwne, 25 and thank you, thank the congressman for us, for those Neal R. Gross & Co., Inc.

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33 1 remarks.

2 We are going to go to Mr. Mark Sylvia, who 3 is the Town Manager here in Plymouth.

4 MR. SYLVIA: Thank you very much.

5 Corwne is a hard act to follow. I 6 certainly echo her comments and the comments of 7 Congressman Delahunt in terms of the nuclear industry, 8 and certainly thank the NRC for their work in providing 9 these forums and to Entergy for their engagement in 10 this process. We filed a notice of intent to 11 participate in this process on May 12th, my purpose 12 really today is to just further emphasize to the public 13 and for the record that we will be actively 14 participating in this process. We will be filing our 15 comments on or by June 16th, which is the deadline to 16 do so.

17 We feel that this is an important part of 18 the overall relicensing process, we are here certainly 19 to represent the citizens of Plymouth, certainly their 20 concerns and, at the same time, open that meaningful 21 dialogue to make sure that any of those issues are 22 addressed in this process.

23 So, on behalf of the Board of Selectmen in 24 the Town of Plymouth, that's really what my purpose 25 here today is for. So I'm here now to sit, and listen Neal R. Gross & Co., Inc.

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34 1 and learn from the dialogue today. We'll have 2 representatives here this evening as well and certainly 3 appreciate this opportunity. Thank you.

4 MR. CAMERON: Okay, thank you, thank you, 5 Mark.

6 We are going to go to Mary, Mary Lampert, 7 and then we are going to go to Alba Thompson.

8 Mary?

9 MS. LAMPERT: Yes, I'm Mary Lampert, 10 speaking for the Town of Duxbury Nuclear Advisory 11 Committee.

12 First item. We know that realistic plume 13 modeling assumptions and wind weather data are key to 14 forecasting and implementing appropriate and effective 15 emergency response plans and to assess damage 16 afterwards. We hope you will look and compare, for 17 this particular site, whether Class A models or Class B 18 models would be the most appropriate way to detect 19 plume dispersion and whether to compare multiple 20 meteorological towers, appropriately located in sites 21 in the community, would give a more accurate picture, 22 in our coastal environment with a varied terrain, than 23 relying simply on the tower on site.

24 We hope you will also be looking at the 25 new information, since `72, of health impacts in our Neal R. Gross & Co., Inc.

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35 1 communities. There has been a case controlled study of 2 adult leukemia, there has been review that has been 3 done of the cancer, of the Massachusetts Cancer 4 Registry, since it started in `82, showing a consistent 5 rise in thyroid and leukemia cancers in the seven towns 6 that the meteorological `82 study said would be most 7 likely to be impacted. And also, you would consider, 8 in your health analysis, the projected demographic 9 changes, from 2012 forward, of a one in three people in 10 this area over 55 and tie that to the BIERS 7 which 11 indicates that older and very young people are more 12 susceptible to damage.

13 And third, in assessing health, you would 14 look at, as BIERS 7 said, to bioaccumulation and the 15 cumulative effect of health impact by looking at what 16 is documented in the REMPs of how much radiation has 17 been released, and also pay special attention to what 18 was stated by Mass. Department of Public Health in a 19 public meeting that Senator Kerry held, that there is 20 no reason, I can provide the exact quote later, no 21 reason to trust what the licensee has put into their 22 reports of what has been emitted and "they have emitted 23 far too much than they should have" including, for 24 example, transgeneric elements such as neptunium.

25 I hope, in that, you will also be looking Neal R. Gross & Co., Inc.

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36 1 at the necessity in the future, and actually now, for 2 better monitoring to assess whether the current 3 environmental monitoring program reports are reliable 4 and accurate, whether, instead, we need to include more 5 sampling to have another look at where control and 6 indicator stations are placed and also to consider, in 7 the future, whether it's appropriate to have the 8 licensee get the samples, and have their own labs 9 analyze the samples and to provide the reports, whether 10 a system would better protect health and public safety, 11 for 2012-2032, what would you advise?

12 For the SAMA, the site area, what is it?

13 Severe environmental impact statement, mitigation 14 analysis, rather, I just call it the SAMA. For the 15 SAMA, I hope that you will look that mitigation means 16 to diminish the effect on the public. I think somehow, 17 in reading it, and I don't mean to, you know, sound 18 flip, but it seems to be more mitigating the damage to 19 the licensee's pocketbook. That you would look, for 20 example, in the economic damage, that they only seem to 21 consider, they have put, they have two buckets, farm 22 wells and non-farm, but they don't differentiate for 23 business, for example, and what you see there is a 24 determination of valuation based on assessed value, in 25 a county, divided by the population.

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37 1 We know assessments, number one, are low 2 and, more importantly, we know that a piece of 3 property, like a business, the businesses on Court 4 Street, are not only the value of the bricks and the 5 roof but the value of a business. The value of this 6 area involves its tourist appeal, historical value, 7 etcetera, etcetera, and none of those inputs have been 8 put into the model in the SAMA. The same for emergency 9 planning, they just consider two elements, one is 10 evacuation delay time and another one is how long it 11 will take to cross the ten mile EPC border.

12 The assumptions under both are not 13 accurate. You notice, for example, how long 14 evacuations take, they use a KLD evacuation time 15 estimate that is not the latest time estimate, one came 16 out a couple of years ago, and the assumptions in the 17 KLD are really not applicable for what will happen in 18 real life. So, you see, emergency planning can come 19 in, under the SAMA, for discussion and I think it would 20 be important for you to look at such factors as 21 sheltering, which is one of the responses in 22 evacuation, is not considered. Shadow evacuation is 23 not considered.

24 For time estimates, they look at and 25 consider the worst, the longest time it would take to Neal R. Gross & Co., Inc.

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38 1 evacuate would be in the winter, when an extra hour for 2 shoveling would be required, as opposed to looking at 3 an attempt evacuation on July 4th, in a summer weekend, 4 etcetera, etcetera. So what they seem to have done, 5 and this will be in a written report, is to take the 6 best case for themselves, put it into the inputs to 7 come out with a very diminished effect.

8 Last, I hope you consider, and I know I've 9 taken too much time, and looking at the direct, this is 10 under the SAMA, adding a filter to the direct toras 11 vent system, they come up with that it would cost $3 12 million and it would only reduce the amount of 13 radiation released by half but, somehow, it's not 14 worthwhile. And so I think that that really speaks to 15 the community and I hope it speaks to you that the 16 emphasis does not seem to be on mitigating effect 17 public health, safety and property, but rather to 18 protect their own wallets.

19 And I think I can leave it there, except, 20 also, marine impact is a huge area and it doesn't make 21 any sense to say, well, let's not consider it because 22 they have made an application to EPA for their water 23 discharge permit, which is overdue, so, hence, they can 24 rely on 1996 data that they have provided and got a 25 permit back then. We are talking about 2012. It would Neal R. Gross & Co., Inc.

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39 1 be like myself saying, you know, I've applied for a 2 license to drive so, therefore, I have the right to 3 drive and nobody should question me, so that doesn't 4 make any sense.

5 And I think you should look carefully at a 6 memo prepared by Jerry Szal, S-Z-A-L, of the DEP, 7 specifically on the marine effect of Pilgrim on our 8 environment, the once through cooling system. In it, 9 he mentions some very important items. One is, is it 10 appropriate to average the temperature discharge or is 11 it more important to be required to have an 12 instantaneous discharge so the maximum number is always 13 adhered to? Other issues were mitigation, adding, you 14 know, fish to the bay to make up for those that happen 15 to get chopped up in the system, do they breed with 16 native stock? Does that make a difference?

17 As far as impringement goes, fish that are 18 smacked against the grate and then removed, have they 19 been permanently damaged so that they do not have a 20 survival affect, has that been studied? Would we be 21 better off having a grate at the mouth of the canal 22 that might decrease the number of fish impringed or 23 increase their survivorability and, at the same time, 24 have a security effect by catching any explosive that a 25 bad guy wanted to put up the intake canal? And also, I Neal R. Gross & Co., Inc.

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40 1 would hope that you and EPA DEP would work together to 2 come up with a number of how many fish, what is it, per 3 acre?, can be damaged, as opposed to a more general 4 statement of what is or is not acceptable.

5 So I'll let it go then and you'll be 6 hearing from me. Thank you for coming, really 7 appreciate it.

8 MR. CAMERON: Thank you, Mary, for those 9 specific comments.

10 MS. LAMPERT: Oh, can I just add one more 11 item?

12 MR. CAMERON: Go ahead.

13 MS. LAMPERT: The other item, of course, 14 is waste, that supposedly it's off the table but I 15 think, quite clearly, you cannot have a severe accident 16 mitigation analysis without including what could happen 17 by accident, and accidents can happen, to the spent 18 fuel pool. That seems like a logical place to pull the 19 issue of spent waste, high level waste, into the SAMA, 20 and I hope also that you would consider an analyze 21 buried waste that was allowed to be buried on site 22 until 1981. I assume that when it was allowed to be 23 buried, there was an assumption and analyses of the 24 time that it would remain stable, until the license 25 ended in 2012 and decommissioning would begin.

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41 1 What will another 20 years do to it? Will 2 it remain stable for another 20 years? Do you even 3 know what is buried there, what the packaging is, 4 etcetera? There should be a complete inventory of 5 what's there, curies, volume, packaging, a map where it 6 is and whether the six feet of soil is still over it, 7 and whether you would recommend, for mitigation, 8 monitoring wells so we can see whether it is going into 9 the bay, which is the only other place it can go 10 because of the topography. Last would be low level 11 radioactive waste. In 2008, North Carolina has stated 12 they will not be taking waste from Massachusetts.

13 We are not a member of any compact state.

14 There was a determination that we were not going to be 15 a low level radioactive waste site, so what would the 16 future be, having both high level waste and low level 17 waste, which isn't necessarily low in toxicity or 18 longevity, on site? What should we be doing for that?

19 Again, thank you. No more surprises.

20 MR. CAMERON: Thank you, thank you, Mary.

21 We are going to go to Alba now. Is Alba 22 here? Mrs. Alba Thompson.

23 MS. THOMPSON: Anyone who follows Mary had 24 to better be on his dangerous level of ignorance 25 because she always is overwhelming, we are so happy to Neal R. Gross & Co., Inc.

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42 1 have her in the area. My name is Alba Thompson and I'm 2 a former Air Force Major, Retired, a former teacher, 3 former selectman, former mother or still mother, 4 grandmother and so forth but, most of all, what you 5 need to know about me is I am a citizen and I love the 6 Town of Plymouth. I happened to be born here, I'm not 7 one of those endangered citizens, however, that won't 8 happen to the day when they put me in Pine Hill 9 Cemetery.

10 I do want the Nuclear Regulatory 11 Commission to come off of the regulations and the 12 constant din of those regulations. I know that's your 13 work and I know that has to guide you, and I'm grateful 14 that you have it, but there is a humanitarian and 15 social context for those of us who live here and I 16 would like you to understand what that really is. We 17 are 103 square miles, we are America's home town. We 18 are 76,000 people, we are not the little town that we 19 were, nor are we the naive little town that we were 20 when that nuclear plant opened in 1972. The whole 21 nation is not that naive, a great deal has happened 22 since that time, a great many years, over 30, have 23 elapsed since that time, so we are not today what we 24 used to be, we are not tomorrow what we used to be.

25 I want you to understand, for those of us Neal R. Gross & Co., Inc.

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43 1 who live here and, in my case, I was born here, I want 2 you to know we do not see ourselves living in the 3 boondocks, nor do we see ourselves as victims, we see 4 ourselves as a vigorous and ongoing community with a 5 wonderful potential, and we insist that anything that 6 lives with us in our town add to that potential.

7 Technologically, we have come a long, long way, and I 8 must say that the record of Entergy with the nuclear 9 plant has been a good one, certainly much better than 10 Boston Edison ever hoped to have, and you know that, 11 Nuclear Regulatory Commission, because it was you that 12 fined them again, and again and again for accidents and 13 other deviations from your regulations, with one of the 14 worse and greatest of the fines ever applied to a 15 nuclear plant. We don't want that ever to happen 16 again.

17 But you ought to know that we look upon 18 the plant as being one of the businesses that must 19 itself recognize the humanity of the people who live 20 here and in this entire area. We look to the sea, but 21 it also means we have our back to the sea, if you are 22 thinking about evacuation.

23 And if you are thinking about Cape Cod, 24 poor Cape Cod. In the summer, we can't get over the 25 bridges. What would it take, in a real disaster, for Neal R. Gross & Co., Inc.

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44 1 Cape Cod to be evacuated? In speaking with, and rather 2 recently, a Coast Guard Captain, he admitted that they 3 could not adequately patrol the harbor outside of the 4 nuclear plant because they are stretched too thin in 5 these days because they don't have enough money, 6 because they don't have enough ships, because they 7 don't have enough men and women.

8 So what we are saying to you, when you are 9 dealing with your regulations and that sea of paper, 10 remember what we really are, people who think of 11 themselves as living with a business that, in some way, 12 threatens them unless run very badly. The Nuclear 13 Regulatory Commission has never denied a license to any 14 nuclear plant that wanted an extension, we are not 15 under any illusions about what happens here today or 16 what happens here tonight. We think you will extend 17 that plant, but what we are saying is do it with all 18 safety and other precautions, thinking always of the 19 people who live here, the people who work here, the 20 people who are going to be born here.

21 And always, when that impact statement 22 comes out, will you remember it is very important, at 23 that time, to have had some public hearings and public 24 meetings so that we may know what it is you have found 25 and not found? And we ask you always to remember this Neal R. Gross & Co., Inc.

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45 1 is America's home town, it is sacred in many ways.

2 (Applause) 3 MR. CAMERON: Thank you, thank you, Alba.

4 We are next going to hear from Joyce 5 McMahon from Mass AREA.

6 MS. MCMAHON: Good afternoon. My name is 7 Joyce McMahon and I am the Communications Director for 8 the Massachusetts Affordable Reliable Electricity 9 Alliance, Mass AREA, for short.

10 First, let me thank you for this 11 opportunity to address the Commission, we do appreciate 12 your time. Second, I would like to tell you a little 13 bit about Mass AREA and why we felt it was important to 14 be here. Mass AREA is a diverse, statewide group 15 comprised of more than 50 labor/trade associations, 16 businesses, in full disclosure, including Entergy, 17 educators, scientists, advocates and community leaders.

18 We are committed to finding clean, low cost and 19 reliable electricity solutions that benefit all of 20 Massachusetts, this is an urgent public policy 21 challenge.

22 Mass AREA came together in early January 23 after several warnings were issued by the Federal 24 Energy Regulatory Commission, ISO New England, the 25 Federal Reserve Bank of Boston and the Federal Deposit Neal R. Gross & Co., Inc.

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46 1 Insurance Corporation that all said that energy 2 supplies will be insufficient to meet demand as early 3 as 2008, and that energy prices are causing hardship 4 for the region's businesses, its residents and 5 especially the most vulnerable populations, such as 6 elderly and low income.

7 While Mass AREA's mission is broad and 8 focused to include new electric generation in the form 9 of renewable energy sources, developing natural gas 10 supplies and encouraging energy efficiency and 11 conservation, Mass AREA and its members fully support 12 the relicensing of the Pilgrim Nuclear Power Plant.

13 Given this pending electricity supply problem, we must 14 keep Pilgrim station in operation as, on a typical day, 15 it provides seven to nine percent of the commonwealth's 16 electricity. Without it, Massachusetts and the region, 17 as a whole, could face power supply shortages, 18 including rolling blackouts, a lot sooner than the 19 prediction of two years from now.

20 Further, since no new major power plants 21 are planned and Cape Wind, the only one that's in 22 process, becomes, faces opposition, it becomes even 23 more vital that we maintain our current supply, 24 including Pilgrim. From an economic standpoint, since 25 the owners of the plant sell their power through long Neal R. Gross & Co., Inc.

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47 1 term contracts and not on the volatile short term 2 market, the power produced at Pilgrim is much lower 3 cost than the regional average.

4 Massachusetts ranks third in the nation in 5 terms of highest electricity cost and, since we also 6 have some of the highest housing and health care costs, 7 it becomes even more important to maintain Pilgrim's 8 very reliable, low cost electricity so that we don't 9 continue to have an exodus of residents and businesses 10 from our state who can no longer afford to live or work 11 here.

12 Speaking of work, Pilgrim is also an 13 important source of jobs, there is more than 700 14 permanent, full time employees, most of whom live in 15 Plymouth and the surrounding communities. Indeed, 16 Pilgrim supports the local economy to the tune of $135 17 million a year in local economic activity. More 18 importantly, the electricity that Pilgrim supplies is 19 created without generating any greenhouse gas emissions 20 and, therefore, it does not contribute to global 21 warming.

22 Entergy, the owners of the plant, is also 23 involved in a number of valuable environmental 24 initiatives, perhaps one of the most interesting is 25 that they did a great deal of study in the waters of Neal R. Gross & Co., Inc.

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48 1 Cape Cod and the indigenous fish populations. That 2 result, excuse me, that resulted in their working with 3 Llennoco, a fish hatchery in Chatham, down on the Cape, 4 which every year hatches, rears and releases 25,000 5 winter flounder into Plymouth Harbor for the benefit of 6 the state and the local fishing industry. Entergy also 7 contributes a large amount of money, in the form of 8 grants, to several local environmental groups working 9 with aquatic and other environmental issues.

10 Also, from an environmental standpoint, 11 Pilgrim doesn't require any potentially environmentally 12 perilous actions, such as drilling wells, sending 13 tankers across the oceans loaded with fossil fuel 14 cargos, nor laying pipelines over land or under sea to 15 get fuel for this plant, nor does it require the taking 16 of tens of thousands of acres of land to erect wind 17 turbines for similar electrical output.

18 My point here is not to disparage any and 19 all fuel sources, but rather to demonstrate that no 20 energy option is going to please all the people all the 21 time, nor is there a silver bullet that is going to 22 solve our energy supply crisis.

23 Mass AREA has weighed all the 24 environmental, economic and energy supply traits of 25 Pilgrim, particularly its high NRC safety rating, and Neal R. Gross & Co., Inc.

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49 1 concluded that the Pilgrim Nuclear Power Plant is vital 2 to the region, state and local community for its 3 environmentally sound operations, its economic 4 contribution to the local community through the 5 provision of jobs and purchase of goods and services 6 and its provision of reliable and low cost electricity.

7 Mass AREA encourages the NRC to grant Entergy's Pilgrim 8 station an extension of its license so that it 9 continues to safely operate for an additional 20 years.

10 Thank you again for the opportunity to 11 speak here today, Mass AREA looks forward to 12 contributing to the process embarked upon by the NRC 13 over the course of the next 18 to 24 months.

14 MR. CAMERON: Thank you very much, Joyce.

15 Pine du Bois?

16 MR. DUBOIS: Thank you. My name is Pine 17 du Bois, I work with the Jones River Watershed 18 Association, I am the Executive Director. The Jones 19 River Watershed Association is located in Kingston, 20 which used to be part of Plymouth, so we like to think 21 of ourselves as America's home town as well.

22 I am not in any way, shape or form 23 prepared, as the former speakers have been, and I have 24 not read the environmental report, but I am here 25 because I did notice the meeting in the Globe this past Neal R. Gross & Co., Inc.

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50 1 weekend and felt compelled to come this afternoon 2 because I can't come this evening. However, I would 3 like the opportunity to prepare a longer presentation 4 in writing for the NRC.

5 What I do have to say is this, that the 6 watershed association has been at work in Kingston 7 since 1985 because of the importance of the Jones River 8 system. The Jones River, being the largest river in 9 Cape Cod Bay, is important to the ecosystem, not only 10 to itself, but to the bay and to the entire Gulf of 11 Maine. What we have noticed in the Jones River is that 12 the fish are diminishing and while it is true that 13 Pilgrim and Entergy have contributed to our work, that 14 contribution has not overcome what we believe is a 15 growing lessening of the populations of fish, 16 particularly herring and smelt, in the system. Herring 17 and smelt have both a history of intrainment at the 18 plant.

19 And I think that what Mary Lampert said 20 about adjusting the screening and the intake makes a 21 lot of sense in term of trying to mitigate further the 22 ongoing damage in the intake structure to those 23 populations.

24 There is apparently significant influence 25 by the plant on the bay area, people that are familiar Neal R. Gross & Co., Inc.

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51 1 with the area do say that it is relatively barren. The 2 problem that results from that and the raising of the 3 temperature is that there are various impacts on the 4 ecosystem that we are seeing today, for instance, in 5 the ongoing concern about red tide. If our bay 6 temperature rises, like, for instance, Mt. Hope Bay 7 where Brayton Point, the coal power station, has 8 significantly raised the temperature of the bay, there 9 is a lot of changing of the population to fish, the 10 aquatic life in the system. We lose fish, like 11 sturgeon, we lose the larger fish that we ourselves 12 depend on for our survival and begin to have problems 13 with algae, we begin to have problems with low oxygen 14 levels.

15 It also effects the plant life in the sea 16 that supports nursery habitats. We are seeing, through 17 Kingston, Duxbury, Plymouth bays, that our eel grass 18 beds are vanishing. We don't necessarily know the 19 reason why and we are not in a position to blame the 20 nuclear power station, but I can say that those kinds 21 of impacts are real, are logical and should be looked 22 at and addressed with a great deal of diligence, 23 especially in view of what Mary was saying before. We 24 cannot pretend that we are, in 2006, where we were in 25 1996, the environmental system has changed and it is Neal R. Gross & Co., Inc.

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52 1 changed dramatically.

2 If a relicensing is in fact in order, then 3 I think that much greater mitigation and much greater 4 contributions to the environment have to result from 5 this energy. We have to remember that our energy 6 consumption, like our water consumption, is way out of 7 whack with the rest of the world. It is not essential, 8 it is a convenience, it is something that we are 9 growing accustom to in our lifestyle of having three 10 and four computers in the home that require this level 11 of energy. We can compare our need for that energy 12 with our need to water our lawns, for instance, we 13 don't need this, we want it, and we are trading 14 something for it and what we are trading here is the 15 value of our ecosystem.

16 What we have learned, over time, and I was 17 trained as a psychologist, I was not trained as an 18 environmentalist, so we had a lot of learning to do and 19 what we learned, over time, was that the importance of 20 the Jones River, as the largest river in Cape Cod Bay, 21 relates to the larger Gulf of Maine ecosystem, and the 22 Gulf of Maine is one of those very few and rare systems 23 in the world, globally, that provide us with all of our 24 ocean fish. What we are learning is that if the Jones 25 River's fish populations are lost, then the Gulf of Neal R. Gross & Co., Inc.

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53 1 Maine health is impacted.

2 We believe that you have to do much, much, 3 much more examination of the impact of the heated water 4 going into the bay than has been done and you have to 5 do much, much more than have a hatchery for winter 6 flounder. These are requirements, these are not 7 optional. Our energy consumption is optional, our 8 environmental integrity is not, and I would like the 9 opportunity to read the environmental report that has 10 been made and make more specific comments. Thank you 11 very much.

12 MR. CAMERON: Thank you for those 13 comments, Pine, and you'll certainly have that 14 opportunity to do that.

15 Let's go to Keith Maxwell.

16 MR. MAXWELL: My name is Keith Maxwell.

17 And I would like to address what I 18 consider environmental equity, and what I would really 19 like to talk about today is the changing environment 20 and how important nuclear power's future is in all of 21 our lives. Last winter, I was in Juno Beach, Florida 22 and I sat through a category four hurricane. I watched 23 my windows blown out, I drove through Dade County, 24 Miami. I watched a city of millions of people on the 25 cusp of the end of organized civilization for a month.

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54 1 There are five hurricanes planned for this season, one 2 of which may hit New England.

3 This month was the warmest month on record 4 for the United States of America. We just watched 5 flooding in Massachusetts disrupt industries, people 6 pumping their cellars out. Now, experts agree today 7 that with global warming and global dimming competing, 8 as we clean our air up, within the next generation or 9 two, we will see the Iceland ice sheet melt and not if 10 but when that happens, the Town of Duxbury, Plymouth 11 and Washington, D.C. will be under water. This will 12 all be a fishery where we are sitting right now. It's 13 not an if, it's pretty much now a when, and the window 14 of opportunity is about ten years.

15 Plants like Pilgrim and nuclear power 16 plants are a stopgap piece of addressing the issue.

17 Nuclear power and nuclear power plants for everyone in 18 this room, environmentalists, industrialists, people in 19 the public sector, it is now a must, it is mandatory.

20 And when we talk about equity, Pilgrim Nuclear Power 21 Station, as a piece of equity, is indispensable. It's 22 indispensable for your town, it's indispensable for the 23 environment, it's indispensable for business. No one 24 in this room, in the future, will be able to live 25 without nuclear power. Wind and some of the other Neal R. Gross & Co., Inc.

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55 1 alternative energies will be part of it. Mankind is 2 going to change in the next generation or two, it's in 3 the cards, that's just the way it's going to be.

4 Now, when it comes to equity, 5 environmental equity, we all recognize today, also 6 includes money and financial impacts, impacts on 7 businesses destroyed by the changing environment, 8 whatever. The for-profit utilities have to invest in 9 the infrastructure. In the case of environmental 10 assessment and analysis for the NRC, its systems, 11 structures and components, investigating in long term 12 fuel storage, whether it's Yucca Mountain, or regional 13 or site storage, but for the for profit companies, they 14 do need to address proper investment in the system, 15 structures and components because this is not just a 20 16 year license extension.

17 Ladies and gentlemen, Congressman 18 Delahunt's office has to appreciate these plants 19 conceivably could be around after the 20 years, and a 20 prudent for profit corporation should plan accordingly.

21 And with the changes we are now experiencing, whether 22 it's the wet weather. This is a great day, but it's 23 one sunny day in quite a few weeks that we've had. It 24 has to, government has to get involved.

25 Global warming, nuclear power, is going to Neal R. Gross & Co., Inc.

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56 1 become much, much more a governmental issue, the NRC is 2 going to have for hire outside. The NRC is going to 3 have so much work in the next generation or two, it's 4 indispensable, and people in Duxbury or Plymouth, don't 5 worry about your habitats and your rivers. Unless we 6 get this situation turned around and we keep plants, 7 like nuclear power in Plymouth, on line, you won't have 8 to worry about your fisheries because they are going to 9 be part of the greater ocean, and this is no joke.

10 I'm a conservative. Initially, I never 11 believed this information, but there is so much data 12 now, the government is on board, the world community is 13 on board, Pilgrim is part of it. We need Pilgrim on 14 line, we need to reduce our CO2 global warming issues 15 and Massachusetts is a high tech state, hopefully it 16 can get involved. Well, let me tell you, when the fire 17 department has to come out and start pumping your 18 cellar out, and the ocean is moving up towards Main 19 Street, you will be involved.

20 I appreciate the efforts and the work that 21 the NRC is doing. Ladies and gentlemen, they really 22 are stretched, they are hiring right now. They have so 23 much work, as far as license renewal, new license 24 applications, it's incredible, and they are a leader 25 for the world. The whole world looks to the NRC for Neal R. Gross & Co., Inc.

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57 1 regulatory leadership, China does, the international 2 community does. I just recently had an opportunity, 3 possibly, to do some work in South Africa with the 4 Peddle bed reactor. They look to the NRC, they are 5 truly world regulatory leaders and we should all be 6 thankful that they are doing such a hard job and the 7 job that they are doing, they are doing a great job.

8 Entergy has done a fantastic job. I 9 worked at Pilgrim at one time when it was being 10 operated by the Boston Edison Company and I can 11 guarantee you that when Boston Edison ran it as a 12 single nuclear power plant, as part of a fossil fleet, 13 they didn't really know what they were doing, Entergy 14 does. Entergy is a world class nuclear organization 15 with the expertise to address issues and make the 16 investments to keep Pilgrim going for a long time. We 17 should all appreciate Entergy being here and Pilgrim 18 staying on line, even distractors that have 19 historically been here from the towns surrounding, they 20 have provided a valuable input when Boston Edison was 21 poorly managing the plant. I think they recognize the 22 situation, we all do.

23 Well let's really get behind, as a 24 community, and support Pilgrim and nuclear power 25 because the lights and electricity in this room may not Neal R. Gross & Co., Inc.

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58 1 be on when the next hurricane blows through. And let 2 me tell you, I was in Florida during a category four 3 hurricane, I watched my windows blow out, I did not 4 have electricity for one month. And let me tell you 5 when you can't pump, electricity runs everything, it 6 runs the refrigeration, it runs the pumps at your gas 7 station, it keeps your grocery stores open.

8 When you don't have electricity and there 9 is a couple of million people wandering around, looking 10 for food and water, you start appreciating your Second 11 Amendment rights and you start wondering about it. I 12 don't personally own a gun or anything, but I'm telling 13 you that it got to that point in Florida. I drove 14 through Miami, Dade County and I saw gas lines ten 15 miles long on the turnpike because the turnpike was the 16 only gas stations that had individual power generators 17 to run their gas pumps. There were fights, there were 18 state police helicopters flying overhead, the National 19 Guard was out, it was incredible. We are due, we may 20 get a hurricane this year. Global warming is real, 21 nuclear power is part of the solution, Pilgrim is part 22 of that and I applaud the NRC and the people that are 23 working hard to keep it on line.

24 MR. CAMERON: Thank you very much, Keith.

25 How about Mr. Bob Ruddock, is Bob here?

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59 1 Where is Bob?

2 MR. RUDDOCK: Good afternoon. My name is 3 Robert Ruddock and I am General Counsel for Associated 4 Industries in Massachusetts. AIM is a 90 year old 5 diversified trade association, we have 7,600 members 6 and they, in turn, have about 600,000 employees.

7 Our mission is to improve the 8 Massachusetts economy and to respond to the cost of 9 doing business in Massachusetts, including the cost of 10 energy, and that all translates, frankly, to the 11 continued growth of jobs here in our state. I want to 12 thank the NRC for the opportunity to testify today and 13 to submit comments with regard to the scope of the 14 environmental impact statement, we will do that by the 15 written deadline of June 16th.

16 They will focus primarily on what we 17 believe is an appropriate role, appropriate scope, I 18 should say, of the NRC's inquiry into the socioeconomic 19 impacts and to the environmental impacts of relicensing 20 Pilgrim Station. This is an interesting day for me.

21 Not three hours ago, I addressed 250 people at a 22 conference in Boston with regard to energy efficiency 23 and the need to really improve those programs in 24 Massachusetts and the Northeast, in fact, and to bring 25 energy efficiency as a valuable part of reducing the Neal R. Gross & Co., Inc.

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60 1 amount of demand there is on the system.

2 But there was myself and a number of 3 others who cautioned that there was no silver bullet, 4 that efficiency will not respond entirely to our 5 reliability problems or to our potential shortage 6 problems, nor to our cost problems and, therefore, we 7 need a generation in lockstep with energy efficiency 8 and demand response. And so this morning I was a 9 supporter of energy efficiency and we continue to be 10 so. This afternoon, we are a supporter of maintaining 11 the generation capacity that we have here in our state 12 and in our region.

13 Our view is that the environmental impact 14 statement should examine closely the socioeconomic 15 impacts of this plant in relationship to its 16 reliability in the grid in New England, as well as to 17 its support of the pricing of energy in Massachusetts 18 and again in the region. Additionally, the 19 environmental analysis in the EIS should include the 20 plant's value, on a positive basis, to the overall 21 environmental context of our state, and I mean that in 22 terms of as the previous speaker was talking about, its 23 positive impacts on the reduction or the non 24 contribution to greenhouse gasses and to the other 25 pollutants that may come from fossil fuel plants, and Neal R. Gross & Co., Inc.

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61 1 so we will elaborate on those two aspects.

2 But we would urge the Commission to be 3 very thorough in addressing the off site, if you will, 4 positive environmental and socioeconomic values of this 5 plant. Make no mistake about it, AIM is a supporter of 6 the relicensing of this facility, as well as the 7 relicensing of other nuclear plants in the region, as 8 well as the expansion of the outputs of some of these 9 plants, as appropriate by the operators and the needs 10 of our region. I thank you for the opportunity to 11 testify.

12 MR. CAMERON: Thank you, Mr. Ruddock.

13 We are going to go to Mr. O'Connell, Jim 14 O'Connell.

15 MR. O'CONNELL: Hi, I'll be very brief.

16 My name is Jim O'Connell, I'm from Chatham on what a 17 previous speaker called poor Cape Cod. We or I'm here 18 to point out to the NRC that my experience with 19 Entergy, as stewards of the environment, has been a 20 very positive one.

21 We are a small research and development 22 company, we got in the business about seven years ago, 23 hoping to help rebuild the ground fish stocks through 24 hatchery restoration. I'm sure the NRC doesn't know, 25 if they are not from this area, but most of the people Neal R. Gross & Co., Inc.

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62 1 in the room do know that there is a northeast fishing 2 crisis going on, the fishermen cannot go fishing, there 3 is no cod, there is no haddock, there is no flounder 4 out there.

5 And this has nothing to do with the 6 nuclear power plant, it has to do with the management 7 of the species but, anyway, we thought we would try and 8 develop the means to replace the fish in the oceans, to 9 allow the fishermen to go fishing for more than 50, or 10 48 or 30 days a year, which is what they are at right 11 now. I don't know how many people in this room could 12 support their families working one month or two months 13 a year and then expect to live the same kind of 14 lifestyle that you are living.

15 At the time we got in the business, we 16 didn't even know who the Pilgrim Nuclear Power Plant 17 was. We got onto this idea and, after two years of an 18 experimental laboratory, we thought we had something 19 and we wanted to find somebody to sponsor the building 20 of a pilot plant so that we could put fish back in the 21 ocean and see if it worked.

22 One of the previous speakers concerns was 23 that the fish that were added back, she was wondering 24 whether they were normal and we find, and seven years 25 of experience has proven, that they are normal, just Neal R. Gross & Co., Inc.

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63 1 like the every day fish, the young of the native fish 2 that are out there now. Not only did we find that they 3 were normal but we found out that they flourish out 4 there. I'm oversimplifying for the purpose of keeping 5 it brief, but we did this with flounder and the reason 6 we started with flounder first was because their 7 reproduction cycle, their spawning season, more closely 8 matched our slow time on Cape Cod when we could 9 actually deal with them.

10 And I'm again oversimplifying but we found 11 that now that we found we can do it, we can also do it 12 with cod and we can do it with haddock. In other 13 words, we are on the verge of actually being able to 14 make a difference and we are doing this because Entergy 15 actually helped us, they supported us and helped us 16 build this pilot facility for their own reasons, I'm 17 sure. Nobody in this room thinks they did it for 18 nothing, they did it because we thought, they thought 19 we might answer a problem for them at some time but, to 20 my knowledge, as I'm standing here, I don't think they 21 have ever gotten credit for it, I don't think they've 22 gotten any points for it or anything like that but, 23 yet, seven years in a row they have given us a contract 24 so that we are learning.

25 I mean we are learning really neat things, Neal R. Gross & Co., Inc.

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64 1 we are learning how to put fish back in the ocean and 2 we are pushing the envelope on the science. We think 3 that, seven years later, not only are we onto something 4 but it might be something big. It seems to me that, 5 having gotten no credit or no points, as I said, for 6 helping us, and they do it year after year, even the 7 most jaded person would have to say that they are good 8 stewards of the economy. Excuse me, not good stewards 9 of the economy, good stewards of the environment.

10 That's all I have to say and, if anybody 11 has any questions, I would be glad to answer it.

12 MR. CAMERON: Thanks a lot, Mr. O'Connell, 13 for that information.

14 We are going to go to Nancy Landron. Oh, 15 you're okay? All right. And how about Frank Collins?

16 MR. COLLINS: Good afternoon. I'm Frank 17 Collins, a precinct six town meeting member, I live up 18 on Manomet Point, and I've lived there for many years 19 and been associated with the point for probably 50 20 years. I was familiar with the Greenwood Estate where 21 the power plant is built, I watched the power plant 22 under construction and I've been comfortable with it 23 since. I was a Navy officer familiar with nuclear 24 power and nuclear weapons and was comfortable with the 25 plant when it was constructed. I also had a seafood Neal R. Gross & Co., Inc.

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65 1 business, primarily lobsters, The Lobster Pound up on 2 Manomet Point.

3 And when they proposed the building of the 4 plant, Boston Edison funded a study and it was funded 5 by Boston Edison and carried out by the Division of 6 Marine Fisheries, and they studied what impact the 7 warmer water had on lobsters for a period of three 8 years before the plant opening and probably about three 9 years after it opened, and the conclusion of that study 10 was that lobsters came in a little earlier in the 11 spring and stayed there a little later in the fall, 12 with the warm water. Now fisherman are not able to 13 fish there, not because there is no lobsters but for 14 security reasons, and they've established a no boating 15 area in the vicinity of their plant.

16 The other thing that I would like to 17 address, I think they started the plant probably in 18 1968 and I believe it came on line in 1972. When the 19 plant came on line in 1972, it was equal in value to 20 all the other assessed property in the Town of 21 Plymouth, so it effectively halved our tax rate. We 22 were the next town, that was South of Boston, that was 23 probably going to experience some strong growth and, 24 coupled by our large land area, 103 square miles, and 25 relatively cheap land prices, and dirt cheap real Neal R. Gross & Co., Inc.

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66 1 estate prices, the savings that, at that time, the 2 Boston Edison Plant brought us was soon surpassed by 3 the demands of the burgeoning population on the 4 infrastructure.

5 We built new elementary schools, new high 6 schools, new middle schools, a lot of roads were 7 developed, some at the expense of developers and often 8 they were maintained at the expense of the town. We're 9 in a position now that we are dependent on the town for 10 a significant portion of our tax, the plant, rather, 11 for a significant portion of our tax revenue. I'm 12 comfortable with, I haven't seen any adverse 13 environmental impact in the period that I've watched 14 the plant in operation. There are times that there 15 have been fish kills of herring, I have also seen 16 herring crowd into the corner of the harbor and I have 17 seen significantly more of the herring die there from 18 lack of oxygen than I've seen at the plant, albeit I've 19 never seen all the herring that may have been killed at 20 the plant.

21 But the bottom line is, for the Town of 22 Plymouth, that we are dependent upon the revenues that 23 are produced by the plant and perhaps as much so now as 24 any time in the past. I'm in favor of the relicensing 25 of the plant and the sooner it happens, the happier Neal R. Gross & Co., Inc.

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67 1 I'll be. Thank you.

2 MR. CAMERON: Thank you, Mr. Collins.

3 Do we have Mr. Stone here? Is there 4 anybody that I've missed? Oh, yes, sir?

5 MR. ANDERSON: Good afternoon. My name is 6 Rick Anderson and I represent Carpenters Local 624.

7 Our members not only live in this community but they 8 are very concerned about what happens within it. And 9 just to give you a personal perspective, I have worked 10 at this plant and I can tell you that the difference 11 between the way this plant was maintained when Boston 12 Edison was here and the way Entergy maintains this 13 plant is like night and day, and I'll just give you a 14 specific example of Entergy's commitment. Following 15 the most recent refueling outage, Entergy is developing 16 specific site specific training to reduce injury, 17 injuries during refuel outages and maintenance.

18 And just I, I just don't want to, I just 19 want to just make a point that the economic benefit of 20 relicensing this plant cannot be overstated, and I 21 appreciate being part of this opportunity and this 22 process and urge the NRC to renew this license for the 23 economic vitality of this town. Thank you.

24 MR. CAMERON: Okay, great, thank you, 25 thank you, Mr. Anderson.

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68 1 I think that's our last speaker for this 2 afternoon, and we are going to be back here tonight, 3 6:00 for an open house and then 7:00 for another 4 meeting. And I would just like to thank you all for 5 the comments, impressive comments, and thank you for 6 following the ground rules.

7 I'm going to turn it back to Rani 8 Franovich to close the meeting out for us.

9 MS. FRANOVICH: Thank you, Chip.

10 I want to reiterate something Chip just 11 said. There were some very, very good comments that 12 were provided today that we've got transcribed. We are 13 going to take them back, we are going to take them into 14 consideration, they add value. So, again, thank you 15 for taking time out of your busy schedules, this is a 16 very important part of our environmental review and we 17 do appreciate your participation. I wanted to remind 18 everyone that we have an NRC public meeting feedback 19 form. You guys can't see this but they are out on the 20 table in the lobby, as you came in.

21 If you have any suggestions on how we can 22 improve our meetings, things we can do differently, 23 things perhaps we are doing well that you want to 24 mention, please take the time to fill out one of these 25 forms. The postage is prepaid, you can just fold it Neal R. Gross & Co., Inc.

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69 1 up, mail it in or you can leave it with a member of the 2 NRC staff. I also wanted to remind everyone that if 3 you have comments on the scope of our environmental 4 review, we will be taking those comments in writing up 5 until June 16th.

6 Alicia Williamson and Robert Schaaf are 7 the points of contact for your comments and, finally, 8 the NRC staff and our contractors will be hanging 9 around here for a few minutes after the meeting so, if 10 you want to take us aside and spend some time asking 11 questions, talking with us, we would be delighted to 12 talk with you. And thank you again for being here.

13 (Whereupon, at 3:11 p.m., the hearing 14 was adjourned.)

15 16 17 18 19 20 21 22 23 24 25 Neal R. Gross & Co., Inc.

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