ML081130366

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Official Transcript of Pilgrim Limited Appearance Session in Plymouth Massachusetts; Pp 1-65
ML081130366
Person / Time
Site: Pilgrim
Issue date: 04/09/2008
From:
Atomic Safety and Licensing Board Panel
To:
SECY/RAS
References
50-293-LR, ASLBP 06-848-02-LR, NRC-2112, RAS J-103
Download: ML081130366 (67)


Text

-ýJ-- /03 Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION DOCKETED USNRC

Title:

Pilgrim Nuclear Power Station April 18, 2008 4:00 pm OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Docket Number:

Location:

Date:

50-293-LR; ASLBP No.: 06-848-02-LR Plymouth, Massachusetts Wednesday, April 9, 2008 Work Order No.:

NRC-2112 Pages 1-65 NEAL R. GROSS AND CO., INC.

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

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

Ikol

1 1

UNITED STATES. OF AMERICA 2

NUCLEAR REGULATORY COMMISSION 3

ATOMIC SAFETY AND LICENSING BOARD 4

LIMITED APPEARANCE SESSION 5

6 x-------------------------------x 7

In the Matter of:

8 Docket No.

9 ENTERGY NUCLEAR GENERATION 50-293-LR 10 COMPANY AND ENTERGY NUCLEAR 11 OPERATIONS, INC.

ASLBP No.

12 06-848-02-LR 13 (Pilgrim Nuclear Power Station) 14 --------------------------------

x 15 Wednesday, April 9, 2008 16 17 The Limited Appearance Session came to order 18 at 6:30 p.m. in the Mayflower Room of the Radisson 19

Hotel, 180 Water Street, Plymouth, Massachusetts.

20 Administrative Judge Ann Marshall Young, Chair of 21 the panel 22 PANEL:

23 Administrative Judge Ann Marshall Young, Chair 24 Administrative Judge Paul B.

Abramson, Ph.D.

25 Administrative Judge Richard F.

Cole, Ph.D.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

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TABLE OF CONTENTS 2

3 Welcome and Introduction of Panel 4

Administrative Judge Young........

3 5

6 Speakers 7

Lauren Mauriello...............

9 8

Bob Rio.................

12 9

Tim Sullivan.............

15 10 Rebecca Chin.............

20 11 Joanne Wheeler.............

25 12 Eric Dykeman.............

30 13 Jeff Berger..............

32 14 Kathleen O'Brien...........

36 15 Pine duBois...............

42 16 Sandra Woods...............

46 17 Sara Altherr.............

49 18 Paul Blanch..............

50 19 Paul Brown...............

54 20 Maurice Cion.............

56 21 Ronald Rothstein...........

58 22 Barbara Pye...............

60 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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P-R-O-C-E-E-D-I-N-G-S 2

6:31 p.m.

3 ADMIN.

JUDGE YOUNG:

Good evening, 4

everyone.

If I could have everyone's attention?

-5 Hi.

My name is Ann Marshall Young..

I'm 6

the chair of the licensing board and we welcome you 7

all here.

8 I'm going to introduce a few people in a

9 couple of minutes, but first I just wanted to say 10 that we expect to hear a number and variety of 11 viewpoints tonight.

We look forward to hearing from 12 all of you.

We welcome you.

13 We are an independent arm of the Nuclear 14 Regulatory Commission.

We are one board from the 15 Atomic Safety and Licensing Board Panel.

Our job is 16 to be neutral, hear all viewpoints and make rulings 17 that are neutral.

18 Tomorrow we will be asking questions of 19 various experts of the parties in this Pilgrim 20 proceeding.

This proceeding that involves the 21 request for renewal of the Pilgrim Power Plant's 22 license to operate.

23 Pilgrim Watch has been admitted as a 24 party and we will be hearing argument on one issue 25 that remains in the case having to do with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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plant's aging management programs and-whether 2

there's a need for monitoring wells to assure that 3

certain equipment properly fulfills its safety 4

functions.

5 Tonight, however, we won't be asking any 6

questions.

We are here to listen to you.

7 1 should say also that we are being 8

broadcast on, I think, WATO radio, so you can have 9

your five minutes of fame tonight.

10 Again, we look forward to hearing from 11 you.

12 1 am the lawyer member of the board.I 13 saw an article that --

I'm not sure if this person 14 knows we're we've started.

Is there someone 15 behind the 16 ADMIN. JUDGE ABRAM4SON:

Somebody behind 17 the screen.

Can we ask for quiet, please?

He's 18 broadcasting from behind the screen.

19 ADMIN. JUDGE YOUNG:

Well, we're 20 flexible.

21 ADMIN. JUDGE ABRAMSON:

Who is that man 22 behind the screen?

23 ADMIN. JUDGE YOUNG:

As I was saying, 24 Neil Sheehan, our public affairs person in this 25 region sent us an article that was published in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Boston Globe and they talked about three nuclear 2

experts that were coming here to conduct this 3

proceeding and I need to give a disclaimer right up 4

front.

I'm not an nuclear expert; I'm a lawyer.

My 5

colleagues will introduce themselves and tell you 6

their expertise.

7 But, I nonetheless will listen with just 8

as much attention as they will, and maybe have a 9

little less sophisticated questions tomorrow, but 10 will listen just as closely tonight.

11 So I'm going to ask my colleagues to 12 introduce themselves.

And then if there's anyone 13 from any of the parties in the proceeding tomorrow 14 who are here and would like to just stand up and say 15 hello, you're welcome to do that.

We don't have 16 separate tables for everyone, so you'll have to sort 17 of identify yourselves.

18 Judge Abramson?

19 ADMIN. JUDGE ABRAMSON:

I'm Judge 20 Abramson.

I'm a Ph.D. scientist, registered nuclear 21 engineer and an attorney.

I'm the only member of 22 the panel who's both a legal judge and a technical 23 judge.

24 One thing that Judge Young mentioned 25 that I think needs emphasis for all of you, and that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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is that we're an adjudicatory body.

We're a group 2

of judges, a panel of judges.

We don't make policy.

3 If you have policy comments that you'd like to make, 4

of course we will listen, but they will haveno 5

impact.

They're falling on ears that can have no 6

effect whatsoever.

So it would be most useful if 7

those of you have comments can address your comments 8

to the issue that's in front of us tomorrow which we 9

are to adjudicate, which is whether or not the plant 10 needs monitoring wells to assure that certain buried 11 pipes and tanks can meet their intended safety 12 function.

13 If you have policy questions, they 14 should be logically addressed to your legislators, 15 your congressmen and senators, or to the Nuclear 16 Regulatory Commission who makes policy.

We do not 17 report to the Commission.

We're an independent 18 group of judges.

19 ADMIN.

JUDGE COLE:

My name is Richard 20 F.

Cole.

I'm an environmental engineer.

I'm an 21 administrative judge technical.

I've got a Ph.D.

in 22 environmental engineering.

23 ADMIN.

JUDGE YOUNG:

Are any of the 24 parties here who'd like to just stand up and 25 introduce yourselves?

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2 3

4 5

6 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Ms.

Utall in the back from the NRC staff.

MS.

UTALL:

I am Susan Utall.

I will be representing NRC staff tomorrow.

ADMIN.

JUDGE YOUNG:

And, Mr.

Lewis?

MR.

LEWIS:

David Lewis.

I'm the counsel for Entergy, representing them tomorrow.

ADMIN.

JUDGE YOUNG:

I see Ms.

Hollis representing the town of MS.

HOLLIS:

Town of Plymouth.

ADMIN.

JUDGE YOUNG:

Plymouth.

MS.

HOLLIS:

Thank you.

ADMIN.

JUDGE YOUNG:

Is Mr. Nord here from Duxbury?

What about Ms.

Lampert?

Mary Lampert represents Pilgrim Watch, the intervener.

All right.

In a minute, I'm going to get a oh, we have the list.

Some people preregistered to speak tonight and I will read off their names in order in which we received them.

You may still speak even if you did not preregister.

Our law clerk, Joanna Teebo will be keeping time and she will hold up a card that says one minute when you've used up four of your minutes.

And again, we look forward to hearing from you.

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The first person on the list is Lauren 2

Mauriello; 3

Ms. Mauriello, are you here?

4 MS.

MAURIELLO:

I'm here.

-5 ADMIN.

JUDGE YOUNG:

Come on up to the 6

podium.

Thank you.

7 MS.

MAURIELLO:

Good evening.

My name 8

is Lauren Mauriello and I am the program coordinator 9

for the Massachusetts Affordable Reliable 10 Electricity Alliance, MassAREA for short.

11 First let me. thank you for this 12 opportunity tonight to address you.

13

Second, I'd like to tell you a bit more 14 about MassAREA and why we feel it's so important for 15 us to be here this evening.

MassAREA is a diverse 16 statewide group that is made up of more than 85 17 labor groups, trade associations, businesses, 18 including Entergy, educators, scientists and 19 community leaders.

20 During today's session you'll hear from 21 some MassAREA members, including the South Shore 22 Chamber of Commerce, the Mass AFL/CIO and the 23 Associated Industries of Massachusetts.

As a group 24 we are committed to finding clean, low-cost and 25 reliable electricity solutions that benefit all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Massachusetts.

This is an-urgent-public policy 2

challenge.

3 MassAREA and our members also strongly 4

support-a license extension for the Pilgrim Nuclear.

5 Power Plant.

On a typical day, Pilgrim Station 6

produces seven to nine percent of the Commonwealth's 7

electricity.

Without it Massachusetts and the 8

region as a whole could face power supply shortages, 9

including rolling blackouts a lot sooner than have 10 been predicted.

11 Central to MassAREA's support for the 12 license extension for Pilgrim is the fact that the 13 plant operates safely and continuously earns the 14 NRC's highest safety reading: green.

We also know 15 that the NRC staff is there on site at the plant 16 each and every day overseeing operations and helping 17 to maintain a safe and secure environment for all.

18 The real danger will be the scenario 19 that Massachusetts will face if the state does not 20 have enough affordable and reliable electricity.

21 Blackouts aren't simply an inconvenience or a 22 temporary loss of business.

Blackouts cause deaths 23 because people who are already frail and infirm 24 can't get the heat or cooling they need to sustain 25 life.

High prices are a danger too as they cause NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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folks to curtain electricity use and again result in 2

real life safety concerns and possible harm.

3 Without Pilgrim, Massachusetts would have to buy 4

much more high-priced out-of-state market power.

5 Over the past several months there have 6

been a few proposals for new power plants, but most 7

are small.

This makes it even more vital that we 8

maintain our current supply, including Pilgrim.

9 Opponents of the Pilgrim plant often say that we 10 would be better off if the generator was 11 decommissioned.

However, the base load power that 12 would replace Pilgrim would most likely come from 13 sources that are far more expensive and far more 14 polluting to the environment.

15 At this time, wind and other renewable 16 energy technology simply cannot generate the massive 17 base load power that would be needed if Pilgrim were 18 to cease operations.

The electricity that Pilgrim 19 supplies also does not produce any greenhouse gas 20 emissions and therefore it does not contribute to 21 global warming.

Pilgrim also mitigates the 22 production of hundreds of tons of sulfur dioxide and 23 nitrogen oxides annually.

Chemicals which are 24 harmful to human health, especially among young 25 children and the elderly.

These health and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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1i-1 environmental benefits alone are enough argument for 2

renewing Pilgrim's license to produce power.

This 3

helps make Massachusetts cleaner and safer.

4 The Pilgrim Nuclear Power Plant is a

5 safe, highly-scrutinized and well-operated tech 6

specs that not only provides clean power and 7

hundreds of jobs to the region, but is also a vital 8

piece to Massachusetts' energy portfolio and should 9

be renewed.

It must be noted that the contentions 10 brought forth for the ASLB hearing overlook the fact 11 that the plant has an adequate plan in place to 12 ensure the underground pipes and tanks at the 13 facility are sound and safe.

14 In summary, MassAREA has weighed all the 15 environmental, economic and energy supply traits of 16 Pilgrim, particularly its long safety record, and 17 concluded that the Pilgrim Nuclear Power Plant is 18 vital to the region, state and the local community.

19 Again, thank you for the opportunity to 20 speak with you tonight.

21 ADMIN.

JUDGE YOUNG:

Thank you very 22 much.

23 Is Bob Rio here?

24 MR.

RIO:

Thank you very much.

My name 25 is Robert Rio, Senior Vice President of Associated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Industries of Massachusetts.

Associated Industries 2

is a trade association representing over 7,000 3

employers in Massachusetts, about 680,000 employees.

4 One in five persons in Massachusetts works for an 5

AIM member.

We're here to support the license 6

extension for Pilgrim Nuclear Power Plant.

7 Generally revolves around four areas.

8 The price of electricity in Massachusetts, as you 9

may know, is the highest in the country right now.

10 It is affecting all of our jobs up here, it's 11 affecting our ability to attract companies, and it's 12 actually affecting our ability to keep companies.

I 13 have a whole stack of companies just in the last 14 couple days which have indicated that they will be 15 shutting down and moving out.

I have over 1,000 16 jobs right in this folder of companies that are 17 shutting down because of electricity costs in 18 Massachusetts.

19 When we survey our members, electricity 20 is either number one or two of their highest 21 concern, health care being number one or two, 22 depending on what day it is, frankly.

In a recent 23 survey 95 percent said electricity is a concern for 24 their ongoing business and 50 percent actually said 25 it's going to drive future decisions in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Massachusetts whether or not the locate here.

So we 2

need reliable low-cost power to help us, and Pilgrim 3

provides that.

4 Diversity of our power fleet is the 5

second area.

Massachusetts is about 45 --

in fact 6

the

  • New England area is 45 percent dependent on 7

natural gas, which is one of the reasons why we have 8

high electricity rates, because of natural gas.

We 9

need to keep every plant operating that is not 10 natural gas going forward and we need to keep them 11 operating as long as possible because the likelihood 12 is they will be substituted with a plant that uses 13 natural gas.

And frankly, when we start getting 14 into the 45 percent natural gas area, we are 15 dangerously reliant on one type of fuel.

Obviously, 16 Pilgrim helps us with that.

17 Greenhouse gas concerns was brought up 18 in a previous comment.

Massachusetts has committed 19 by signing onto the Regional Greenhouse Gas 20 Initiative, which is a 10-state agreement to reduce 21 greenhouse gases 10 percent by 2018.

We're capped 22 at the amount of greenhouse gases we produced, I

23 think it's five years ago was the date.

Obviously, 24 if Pilgrim were not here, those megawatts would be 25 made with facilities that produce greenhouse gases NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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and because we're capped, and in fact decreasing our 2

emissions of greenhouse gas under a cap, it would 3

obviously produce greenhouse gases and require the 4

purchasing of offsets, again adding to the cost.

5 And then finally, the local economic 6

impacts.

Seven-hundred good-paying jobs and there V7 are 75 Massachusetts-based companies that are 8

reliant on subcontracting and things like that, many 9

of them who are our members.

10 So in conclusion, Pilgrim provides a 11 clean dependable consistent supply of base load 12 power in Massachusetts with no greenhouse gas 13 emissions.

It helps our diversity, it helps our 14 electricity prices and we would urge you to grant 15 the relicensing for Pilgrim Power Plant.

Thank you 16 very much.

17 ADMIN.

JUDGE YOUNG:

Thank you, sir.

13 Mr.

Tim Sullivan.

19 MR.

SULLIVAN:

Evening.

Thank you very 20 much for the opportunity to testify.

21 My name is Tim Sullivan.

I'm the 22 Legislative and Communications Director of the 23 Massachusetts AFL/CIO.

We're the largest labor 24 umbrella organization in the Commonwealth, 25 representing 400,000 working families from close to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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750 local unions.

And here on behalf of anybody who 2

flips ý light switch, anybody who works behind a 3

computer, anybody who turns on a TV to go watch the 4

Red Sox.

We need this power because it's reliable, 5

because it's safe, because it's low-cost, it's 6

indispensable and it's irreplaceable.

7 My day job is to be up at the State 8

House often advocating for the quality of life of 9

our working families in this Commonwealth and high-10 quality economic development.

It is not often that 11 we are on the same side of an issue with the 12 Associated Industries of Massachusetts whom you just 13 heard from.

We agree with this one because it's a 14 no-brainer.

Massachusetts needs the Pilgrim Power 15 Plant.

We frequently hear about how Massachusetts 16 is losing jobs and talented residents, especially 17 young people around my age and younger to other 18 parts of the country where jobs are more plentiful 19 and cost of living lower.

20 The consequences of the loss of people 21 and jobs are felt particular hard by those of us who 22 are left to cover the costs, particularly working 23 families in the Commonwealth.

Fewer people and 24 employers on which to spread the charges means 25 higher percentages are levied on consumers and those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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  • 1 of us who remain.

2 One of. the biggest problems facing both 3

employers and residents here in Massachusetts is 4

high energy costs.

One way to stem the high energy 5

cost is to keep Pilgrim in operation.

Pilgrim 6

provides some of the lowest cost and more reliable 7

power available to our grid.

8 Another price contributor such as this 9

is that the demand for electricity in Massachusetts 10 is growing, but new suppliesare not.

The employers 11l that are fueling our economic engine such as 12 biomedical technology, health care, computer 13 technology developers,, these all require vast 14 amounts of energy to supply laboratories, life-15 saving medical equipment, clean rooms, data centers.

16 Working families need *these industries 17 in this new economy to thrive. We need the energy 18 produced at Pilgrim for our everyday lives and for 19 emergencies.

We need the energy produced at Pilgrim 20 for our necessities and those new technologies that 21 have become staples to our way of life.

We need the 22 energy produced at Pilgrim just to get through the 23 day and to insure that our entrepreneurs, businesses 24 and workers have the resources we need to research, 25 grow and plan for tomorrow.

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We need the energy provided by Pilgrim 2

in addition to cleaner renewable energies which the 3

Massachusetts AFL/CIO and our unions are profoundly 4

supportive of, but there is plenty of demand to go 5

around.

And for the next couple decades these two 6

kinds of power producers are going to have to go 7

hand-in-hand.

8 We've all heard the saying about in 9

business it's location, location, location.

Well, 10 for the Massachusetts AFL/CIO, our reason for 11 existence is jobs, jobs, jobs.

Now the Pilgrim 12 Nuclear Power Plant should have it's license renewed 13 because without it we'll lose 700 high-quality good 14 jobs, including 400 of our unionized AFL/CIO 15 members.

The 400 union members are highly-trained, 16 high-skilled, incredibly experienced professionals.

17 They are amongst the most high-skilled and safety-18 conscious workers in our economy.

19 The facility is safe.

In fact, the 20 culture of safety goes through everything the 21 employees do.

They take pride in keeping the 22 surrounding area safe as they carry out their tasks 23 and no employee would be at this plant, and the 24 Massachusetts AFL/CIO would never advocate, ever in 25 the history of our organization, asking workers to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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work in an unsafe place or asking famiiies, to live 2

'in an unsafe condition..

3 Every 24 months during the refueling and 4

maintenance outages, there's an additional 900 5

workers on site, many of them also union members.

6 The employees at Pilgrim are-people who live right 7

here in Plymouth and surrounding communities.

8 Approximately 63 percent of the permanent Pilgrim 9

work force lives in Plymouth County.

Another 19 1/2 10 percent make their homes in Barnstable County.

The 11 Mass AFL/CIO's members again would never work in a

12 place or live in an area if we thought it put our 13 families or loved ones at risk.

14 Additionally, there's economic impact 15 beyond the jobs.

Pilgrim provides more than 135 16 million in annual economic activity.

It also, as 17 you heard from AIM, purchases products and services 18 from more than 75 Massachusetts companies.

19 To prevent even higher energy costs in 20 Massachusetts, it's imperative to keep Pilgrim 21 Nuclear Power Plant open.

Additionally, without the 22 tax revenues, Plymouth could face loss of school 23 teachers, police and fire fighters.

We're hearing 24 over and over about the budget crunch.

25 So in closing I would like to say that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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we know the plant is safe.

We know it's crucial to 2

our economy.

We know the workers are highly-skilled 3

and the energy that is produced here is 4

indispensable, as are the jobs it provides.

We urge 5

you to please renew the license for the state's 6

economic well being and that of the region.

Thank 7

you.

8 ADMIN.

JUDGE YOUNG:

Thank you.

9 Ms.

Sandra Woods?

Sandra Woods?

10 If she comes in

later, we'll remember 11 her.

12 Let's see.

Jay Scheffer and Dr.

Brown 13 have been marked off the list.

Are they not here?

14

'Rebecca Chin?

15 MS.

CHIN:

Thank you.

I'm Rebecca Chin 16 and I'm the co-chairman of the Duxbury Nuclear 17 Advisory Committee.

I'm the former chair of the 18 Duxbury Board of Health and I'm the former chair of 19 the Duxbury Ad Hoc Committee on Water Quality.

20 On May 25th, 2006, Pilgrim Watch filed 21 its petition to intervene seeking the admission of 22 five contentions.

The licensing board admitted two 23 of Pilgrim Watch's contentions including an amended 24 version of contention 1 into the license renewal 25 proceeding.

The petition for contention 1 states NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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that the aging management program proposed in the 2

Pilgrim application for license renewal is 3

inadequate because: (1) it does not provide for 4

adequate inspections of all systems and components 5

that contain radioactivity contaminated water; and 6

(2) there is no adequate monitoring to determine if 7

and when leakage from these areas occur.

Some of 8

the systems include underground pipes and tanks 9

which the current aging management and inspections 10 programs do not effectively inspect and monitor.

11 As a basis for this contention, Pilgrim 12 Watch stated that recent events around the country 13 have demonstrated that leaks of underground pipes 14 and tanks can result in releases of massive amounts 15 of radioactive materials into the groundwater.

16 Exposure to this radiation can be a threat to human 17 health and is a violation of NRC Regulations.

18 Because older plants are more likely to experience 19 corrosion and leakage problems, and low energy 20 radionucleotides can speed up the rate of corrosion.

21 Pilgrim should be required as part of 22 its aging management program to adequately inspect 23 and monitor all systems and components that carry 24 radioactive water.

The aging management plan should 25 be revised to include this inspection and monitoring NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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before a license. renewal is granted..

This 2

contention raises serious safety and environmental 3

problems.

With each passing year emergency shut

.4 down, safety violations and radioactive 5

contamination have escalated.

Either Pilgrim's 6

existing AMPs omit to describe the programs and 7

procedures by which it will determine whether or not 8

buried pipes and tanks containing radioactive fluids 9

are leaking at such great rates that they cannot 10 satisfy their respective designated safety 11 functions, or there are no such programs.

12 Entergy's relicensing application fails 13 to address a wide range of critical safety and 14 security and environmental problems posed by the 15 operation of the Pilgrim Nuclear Power Plant.

16 Entergy fails to adequately address the plans for 17 managing the degradation of critical components 18 caused by metal fatigue and corrosion that could 19 compromise the safe operation of the plant if not 20 properly inspected and repaired.

21 Entergy fails to adequately assess the 22 environmental impacts of leaks of tritium, 23 strontium, nidium and cesium 137 on the ground water 24 and into the Plymouth Kingston Duxbury Bay's 25 ecosystem.

Issues of ground water flow are relevant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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not only to contaminated transport, but also to 2

detecting small leaks before they become large 3

enough to compromise safety functions.

4 The inspection is performed by the 5

company, not independent inspectors and by either a 6

visual inspection or by an untested ultrasonic 7

technique.

Inspections are required to occur only 8

once during the 10 years prior to license renewal 9

and one inspection during the first 10 years of 10 operations after 2012.

Any other inspections that 11 occur by happenstance when Entergy is correcting or 12 repairing a component in the area.

13 The inspection program does not specify 14 how many pipes need to be inspected, how large a 15 section, where they have to look in each pipe.

Some

16.

areas like wells are more susceptible to corrosion.

17 No thorough inspection of all pipes has been 18 performed, nor will it be required to be performed 19 prior to relicensing to determine the baseline 20 corrosion going forward to be able to assess what 21 the inspection schedule and repair schedule should 22 be.

How can you judge from a sample taken in 2020 23 the rate of corrosion if you did not look at a 24 previous sample taken prior to 2012?

25 Pilgrim and the NRC think the inspection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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schedule is just.

fine.

They base it on false 2

assumptions about corrosion.

They assume corrosion 3

is

gradual, so a one-time look in 10 years is fine.

4 Not so.

Corrosion is not gradual.

They assume 5

corrosion is linear; it occurs at the same-rate 6

year-to-year.

Not so.

Like any appliance, the 7

older it gets the faster it deteriorates, hence more 8

frequent inspections are needed.

They assume the 9

soil on Cape Cod's bay shoreline is not corrosive.

10 Not so.

Water, salt, moisture and acidity all cause 11 increased corrosion.

They assume corrosion occurs 12 evenly across the pipe so a sample will tell the 13 story of the condition further down the pipe.

Not 14 so.

Manufacturing and installation

.defects variety 15 in pipes, susceptible areas such as welds, joints 16 and elbows all require individual inspection.

17 Pilgrim installed four monitoring wells 18 at the end of 2007.

No thorough hydrological study 19 was performed to determine where to place these 20 wells.

These wells were not tested for the proper 21 array of radionucleotides and can cause harm to the 22 public once in our marine ecosystem and on our 23 beaches.

This nuclear reactor located on 1,600 24 acres with a mile of coastline should have many more 25 than four wells.

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1.

wells.. All the issues should have been allowed to 2

be argued in this process if public safety from 2012 3

to 2032 is a priority.

4 At the annual town meeting of Duxbury 5

2007, Article 38 passed-by unanimous voice vote.

6 The town of Duxbury advocates that Pilgrim Nuclear 7

Power Station's aging management plan, now and in 8

the future, shall consist of more effective methods 9

to inspect and monitor for leaks of radioactive 10 water from systems and components including 11 underground pipes and tanks, including the proper 12 placement and regular inspection of monitoring wells 13 between the reactor and Cape Cod Bay in order to 14 better protect public health safety and our marine 15 aquaculture.

Thank you.

16 ADMIN.

JUDGE YOUNG:

Thank you.

17 Ms.

Joanne Wheeler?

18 MS.

WHEELER:

Hello, everyone, and thank 19 you for allowing me to speak.

20 This is a shortened version of my 21 written statement that I submitted, because of time.

22 Not being a field professional and 23 having to educate myself on nuclear energy to prove 24 to the Government that my son's death was due to his 25 naval military duty repairing and maintaining NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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nuclear submarines has given me some knowledge 2

relative to nuclear energy.

Acdute lymphocytic 3

leukemia took his life at the age of 27 due to 4

exposure to ionizing radiation and radioactive 5

materials.

6 I've included excerpts of Dr. Ernest 7

Sternglass, Ph.D.,

professor emeritus,. radiological 8

physics, University of Pittsburgh Medical School and 9

Joseph J.

Mongano, MPH, MBA, public health 10 administrator and researcher studying the connection 11 between low dose radiation exposure and risk of 12 disease.

Their books, reports, technical and trade 13 articles are on www.radiation.org, website of the 14 Radiation and Public Health Project.

15 Nuclear facilities produce fission 16 products containing radioactive isotopes that are 17 spewed out into the air, small amounts, but 18 frequently.

Low doses accumulate in the body over 19 time which can cause illness and disease.

Those 20 living down wind from a nuclear facility are more at 21 risk.

22 From Mongano on Entergy's New York aging 23 reactors, I'm sorry, I'm a little nervous up here, 24 up for relicensing applicable to any aging reactor:

25 Nuclear power reactors split uranium 235 atoms.

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splitting process, known as fission, also produces 2

over 100 chemicals not found in nature similar to 3

atomic testing fallout.

Fission products take the 4

form of gases and particles, including cesium 137, 5

iodine 131, and strontium 90, highly unstable atoms 6

emitting alpha, beta and gamma rays.

Each causes 7

cancer after damaging DNA in cells creating 8

mutations.

Some decay quickly, having a short half-9

life, while others remain for long periods such as 10 strontium 90.

That's the end of his excerpt.

11 From Sternglass, August 21st, 2002, 12 evidence submitted to the Board of Veterans Appeals, 13 and I quote Dr. Sternglass.

"These bone-seeking 14 radioactive isotopes such as strontium 90, barium 15

140, and others weaken bone structure as well as 16 irradiating bone marrow where both red and white 17 cells of blood originate."

18 This irradiation this is my reading.

19 This irradiation has the potential to mutate the 20 bone marrow cells and other cells of the public.

21 Fetuses and children are most vulnerable because 22 they are still developing.

Our immune systems 23 develop and are kept in optimal working condition by 24 our bone marrow.

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they-are cells that are constantly in different 2

stages of development.-

3 From Dr. Sternglass, April 18th, 2003, 4

evidence to BVA again-and I quote.

"Any fluids, 5

for example, coolant and waste in any piping needing 6

repair or replacement is radioactive and exposes the 7

welder to the isotopes of radioactivity."

8 This is my words.

This can be applied 9

to the public being exposed to radioactivity if 10 radioactive fluids get into the ground and water 11 supply.

Leakage from aging pipes and possibly other 12 metals is a viable reason that these isotopes make 13 their way into the ground and water supply.

14 Mechanical properties of metals change due to 15 nuclear energy.

16 From Sternglass, December 16th, 2007, on 17 First Energy's Pennsylvania aging reactors.

These 18 internal radiation doses are particularly harmful to 19 infants developing in a mother's womb, to children 20 and to older people whose immune defenses have been 21 weakened by lifelong exposure to radiation.

No 22 nation can prosper when the cost of health care saps 23 its resources and harms its physical and mental well 24 being.

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development of alternative energy sources such as 2

wind and solar power will contribute to provid-ing 3

our nation's energy needs while protecting us from 4

global warming.

It is possible convert nuclear 5

power plants to natural gas.

This has been done 6

with Colorado's first Fort Saint Vramn plant that 7

saved most of the facility along with jobs, income 8

and community tax base.

Within two years infant 9

mortality began to decline as did childhood cancer 10 within a decade.

Improvement in human health has 11 been seen around a number of nuclear reactors that 12 were closed.

And that's the end of his excerpt.

13 I have a small paragraph I'd like to 14 read which explains about alpha particles and half-15 life for anybody who would-not understand that.

Is 16 it okay if I do that?

17 ADMIN. JUDGE YOUNG:

You have about a 18 minute left, so go ahead.

19

-MS.

WHEELER:

okay.

Thank you.

20 Alpha particles are the most massive and 21 energetic of radiative emissions and shortest in 22 range because of its strong interaction with matter.

23 Beta particles strongly interact with 24 matter and have a greater range of penetration than 25 alpha.

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Electromagnetic gamma rays are extremely 2

penetrating, enough to penetrate considerable 3

thicknesses of concrete.

4 Half-life is a mathematical and 5

scientific term given to the time required for one-6 half the atoms of any given amount of a radioactive 7

substance to disintegrate.

This tells me that it 8

takes at least twice the amount of time for all the 9

atoms to disintegrate and as they disintegrate, 10 transform into a mixture of other radioactive 11 substances.

12 In conclusion, my experience with and 13 gained knowledge of nuclear energy has convinced me 14 that nuclear power is not in the best interest of 15 Plymouth residents, or the citizens of any state of 16 our country.

Thank you.

17 ADMIN.

JUDGE YOUNG:

Thank you.

18 I think Eric Dykeman is next.

19 MR.

DYKEMAN:

Thank you.

My name is 20 Eric Dykeman and I'm the community development 21 director for the South Shore Chamber of Commerce.

22 The South Shore Chamber of Commerce is the largest 23 chamber of commerce, membership-wise, in the 24 Commonwealth.

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South Shore region.

If you're not familiar with the 2

South Shore region, it's approximately from Quincy, 3

to the Greater Plymouth area.

4 Let me start by thanking the ASLB for 5

the opportunity to testify before you this evening.

6 We all want a good economy on the South Shore with 7

businesses that provide jobs, pay taxes, produce the 8

goods and services that we need in order to have a 9

nice quality of life.

10 An important component of maintaining 11 and creating the good economy is the Pilgrim Nuclear 12 Power Plant.

Pilgrim provides the region with 13 inexpensive base load power that helps offset the 14 high prices of the natural gas plants.

In addition, 15 Pilgrim generates more than $135 million in annual 16 economic activity into the South Shore region, 17 economic activity we cannot stand to lose.

18 The South Shore needs the Pilgrim 19 Nuclear Power Plant.

Massachusetts has the fourth 20 highest electricity cost in the nation.

It is very 21 important to maintain Pilgrim's very reliable low-22 cost electricity so that we don't continue to have 23 an exodus of residents and businesses from our state 24 who can no longer afford to live or work here.

25 Talk to a local business owner and they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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will cite three main items that affect their bottom 2

line.

Energy costs, health care'and housing.

3 Despite taking advantage of every energy efficiency 4

program and product available, many businesses, 5

small and large, remain adversely-impacted by their 6

monthly electric bills.

Many of our businesses keep 7

lights on for security and operate computer 8

equipment 24/7 in order to meet the demands of 9

customers who want to access goods and services at 10 all hours.

Even small businesses such as health 11 clubs and 24-hour convenience stores have huge 12 electric bills to run equipment, lights, 13 refrigeration units and the like.

Given these big 14 demands for energy, the high cost of electricity is 15 making it difficult for companies to grow and invest 16 in new employees or expand operations.

17 We urge you grant a license renewal for 18 Pilgrim Station.

Our regional economy is depending 19 on it.

Thank you.

20 ADMIN.

JUDGE YOUNG:

Thank you.

21 Mr. Jeff Berger?

22 MR.

BERGER:

Good evening.

My name is 23 Jeff Berger.

I'm a Plymouth resident and I'm 24 chairman of Plymouth's town-appointed nuclear 25 matters committee.

Tonight I'm speaking as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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individual.

2 I understand you folks are not policy 3

makers, but I think these things need to be said, so

4.

I'm going to say them tonight.

5 I joined the committee in mid-2002, 6

about nine months after American Airlines Flight 11 7

slammed into the North Tower of the World Trade 8

Center.

When the plane hit, my daughter-in-law was 9

in an elevator on the way to the 78th floor.

She 10 was one of the lucky ones.

I joined the committee 11 to help make Plymouth safe from terrorists.

12 In 2002, I was pro-safe nuclear power; 13 I still am.

At that time I thought the NRC was the 14 nation's watchdog over nuclear power plants; I was 15 mistaken.

16 The problems we face today are not so 17 much aging plants or dangerous mechanics-or even 18 terrorism.

There is one, and only one, huge problem 19 we have today.

And that, in my humble opinion, is 20 the NRC.

I have only five minutes and many people 21 wish to speak, so I'll brief and I'll only cite a

22 few reasons the problem is the NRC.

Rest assured 23 there are many more.

24

First, you don't take into account 25 evacuation plans in your deliberations.

Plymouth's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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plans were hatched when Plymouth was a village of 2

15,000 people.

Today its population is about 3

60,000.

The town's evacuation plan by all sane 4

measures is unworkable and our board of selectmen 5-know it.

Regardless, the Nuclear Regulatory 6

Commission does nothing to make sure the evacuation 7

plan is both current and effective.

Nothing.

NRC, 8

it's time you made real evacuation plans that will

.9 actually work in worst case scenarios an integral 10 part of the relicensing process, not something 11 that's ancillary to it.

12 Second, you require no real time 13 meteorological monitoring outside plant grounds.

14 Consequently, if a fast moving accident or. attack 15 occurs which releases a deadly radioactive plume, 16 that plume leaves the plant and emergency officials 17 in the emergency protection zone haven't the 18 foggiest idea where it's going.

Any decision they 19 make about evacuation or about sheltering in place 20 is nothing more than guesswork.

And if they guess 21

wrong, my neighbors and I, and our kids could all 22 wind up dead.
NRC, it's time you made intense real 23 time meteorological monitoring that will actually 24 work in worst case scenarios an integral part of the 25 relicensing process, a requirement for Entergy to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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meet before it's relicensed.

2 Third, and last, until recently you

.3 wouldn't consider terrorism either.

A court had to 4

tell the NRC to consider it, but in your world 5

consider and make it invulnerable to any conceivable 6

attack have decidedly different meanings.

There may 7

as well be a huge illuminated red target painted on 8

top of Pilgrim Station.

You continue to do nothing 9

significant to require robust external protection of 10 plants.

11 I know a lot more about protection of 12 plants than a lot of people do.

It is not the 13 plant's responsibility.

It is the U.S.

Government's 14 responsibility to protect critical infrastructure, 15 but today all the NRC really does is window 16 dressing.

Unfortunately, we can't read terrorists' 17 minds and that fact alone makes me cringe with the 18 NRC in charge.

NRC, it's time you threw your design 19 basis threat out the window and work hand-in-glove 20 with real terrorism and security experts outside 21 your commission to create threats that make today's 22 worst care scenarios seem like a kindergarten 23 exercise.

24 But much more than that, it's time your 25

really, and I'm talking about the policy makers, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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started doing your jobs and protecting the taxpayers 2

who pay our salaries.

Until then, you will never be 3

the nuclear watchdog Congress intended you to be.

4 Instead, you'll be what my friend Joe Keating called 5

a lap dog to the nuclear power industry.

That's not 6

the same thing.

Thank you.

7 ADMIN.

JUDGE YOUNG:

Thank you.

8 Kathleen O'Brien?

9 MS.

O'BRIEN:

Good evening.

I've come 10 up here from Harwich, Massachusetts.

It's down on 11 Cape Cod, probably 18 or 20 miles across the bay, 12 the same bay that concerns all of us and the 13 implications for living in the general area.

14 I used to live in Duxbury, but I put 15 some little space between myself and the conditions, 16 and I've not been doing as much time, putting as 17 much time in on this on this subject until I found 18 out that the well monitoring is the one issue that 19 you'll listen to today and that you have put aside 20 all the other tabled subjects.

And I'd like to just 21 read what I put together here.

22 The issues of the highest concern to the 23 public were taken off the table and not allowed to 24 be litigated.

25 Number one, the spent fuel storage pool.

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The risk requiring low-density-pool storage and the 2

security of the dry cask on site until the off site 3

storage becomes available, which for years was 4

always going to --

now from the beginning, from the 5

'70s and here we are 2008, still no off site.

6 storage.

7 The Massachusetts attorney general is now in the 1st 8

Circuit Court, from what I understand, on the 9

appeals.

10 My second area that I want to mention is 11 the robust security that is needed to defend the 12

air, water and land from attack by multiple --

what 13 do I want to say, multiple agents or people 14 attacking.

They could come from any one of those 15 sources.

We need well-armed forces.

We need 16 effective emergency planning starting with 17 appropriate viable trajectory plume model.

Iknow 18 that 18 miles is outside the EPZ, but it's still 19 going to affect me and my family, my friends on the 20 cape that have been paying attention to what's going 21 on.

22 The health impact.

I'm a nurse, a 23 registered nurse, so I'm well aware of exposures to 24 radiation and the dangers that this lady so well 25 informed those not here, not informed that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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present here and *those listening.

But, I wanted to 2

say that the reduction in allowable releases to 3

match the current knowledge for the damage to the 4

human tissues at low-dose radiation demonstrated by 5

the National Academy and its most recent report and 6

application that our communities are more 7

susceptible because that there are site-specific 8

studies showing increases in radiation linked to 9

diseases in communities likely to be impacted by 10 Pilgrim.

11 Also, that the real time radiation 12 monitors located in the communities around Pilgrim 13 link to MIMA and the MDPH and the information should 14 be made public.

That the state of the art 15 monitoring well program on site to detect 16 radioactive leakage before it goes into the bay and 17 on our dinner plates, and on our beaches, not 18 totally adequate with four wells, hardly, that 19 Entergy has on site as of, from what I understand, 20 late 2007.

Part of the --

and from what I 21 understand, it's voluntary.

I can't believe that 22 the NRC is leaving the industry to self-monitor.

23 Monitoring of the wells, Pilgrim's 24 system, that there --

I'm going to put that aside 25 for just a minute, and I just want to continue on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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about let's see.

2 I wanted to assure oh, I know, about 3

the wells that are buried.

How can you be assured 4

that the pipes will continue to perform safely and 5

function during in between license renewal period?

6 And as I understand it, the period is 30 years.

I 7

can't believe you're going to 30 years.

Put it 8

another way, whether Pilgrim's existing aging 9

management program have elements that provide 10 appropriate assurance as required under relevant NRC 11 regulations that buried pipes will not develop 12 leaks.

Great.

Those pipes are unable to perform 13 their intended function.

I was given some 14 particulars as far as the program and it's only --

I 15 have just a little bit to read and a couple bullets, 16 and I won't --

I don't know where my time is at, but 17 I won't 18 ADMIN.

JUDGE YOUNG:

You're less than a 19 minute, so if you could just sort of wrap up.

20 MS.

O'BRIEN:

Well, okay.

I'll do that 21 at my best.

22 ADMIN.

JUDGE YOUNG:

Okay.

23 MS.

O'BRIEN:

One-time inspection 24 program before the license renewal from 2002 to 25 2012, not sufficient.

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Performed by licensee, does not specify 2

where the inspections are to occur, how large a 3

sample required, requirements for the corrective 4

actions stipulated.

5 one-time inspection in 10 years from 6

2012 to 2022, either by visual exam or yet~untested 7

ultrasonic exam.

Does not specify exactly where the 8

inspections occur, how large a sample required of 9

the component or requirements for corrective 10 actions.

11 Let's see.

Let me jump ahead here.

12 Inspections that happen to occur during the course 13 of operations.

Public safety is left up to 14 happenstance.

15 And some of the other people here have 16 mentioned things.

17 I have a couple bullets that I believe 10 are false assumptions.

19 Anything that ages, people or mechanical 20 components, deterioration happens more frequently as 21 years pass irrespective of the quality of 22 maintenance.

Look in the mirror.

Hence, more 23 frequent inspections should be required as a reactor 24 ages from 2012 to 2032.

I was here, 1991, almost 25 saying some of the things that some of the people NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 3

4 5

6 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 spoke before me said.

Corrosion is not constant across pipes.

Some areas are more susceptible at the wells, at the

joints, the elbows and they have specific samples that are needed in the areas of manufacturing.

Installation ADMIN.

JUDGE YOUNG:

You're going to need to sort of wrap up.

MS.

O'BRIEN:

Yes, I have one,
two, three, four, five little bullets.

It's getting too touchy?

Giving you too much information?

ADMIN.

JUDGE YOUNG:

No.

No, not at all.

It's just we want to have time.

MS.

O'BRIEN:

Why did that lady get to speak and I don't?

ADMIN.

JUDGE YOUNG:

You do.

You do.

MS.

O'BRIEN:

Okay.

So, can I have a little bit more time?

ADMIN.

JUDGE YOUNG:

You can have about 45 seconds more and then we want to let other peool e speak.

It doesn't area, salt MS.

O'BRIEN:

Okay.

The c say anything about the --

1 water.

Then the metals.

Metals c NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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with moisture, acid, microorganisms.

2 The pipes are not cathodically, with a 3

cathode ray, protected.

They say that they follow 4

the industry experience, but I know --

I understand 5

that there's leaks popping up all around the country 6

where they have been using a similar message --

7 sampling type of process and they followed the 8

reactor's industry experience.

9 Let's see, two more things.

They say 10 rules that keep being revised and not to be taken as 11 the word of God, that I know you've learned your 12 lessons and you've done your homework, and that's 13 why we're here and I feel like we're revisiting in 14 some ways some of the same processes.

The NRC staff 15 evaluated the safety of Pilgrim's components as part 16 of the license renewal process and gave Pilgrim a 17 green light.

But the NRC's own investigative unit, 18 Office of the Inspector General, reported that the 19 inspectors and the reports of the NRC safety reviews 20 of the GIG sampled put a serious cloud on the 21 quality of the staff's investigating and reporting.

22 So I won't go on.

I have more, but I've 23 taken too much time.

Thank you.

24 ADMIN.

JUDGE YOUNG:

Thank you, ma'am.

25 Thank you very much.

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-Pine duBois?

2 MR.

duBOIS:

Hello.

Thank you.

I am a 3

Kingston, resident.

I'm sorry I missed your 4

introductions and I don't really know where you're 5

from.

Could you just take a second to tell me what 6

part of the country you hail from?

7 ADMIN.

JUDGE YOUNG:

We're in 8

Washington.

9 MR: duBOIS:

Okay.

10 ADMIN.

JUDGE COLE:

I was born in 11 Philadelphia.

12 MR.

duBOIS:

Born in Philadelphia?

13

Well, I think the point that people are trying to 14 make about the corrosive soils has to do with the 15 fact that it is known by EPA in particular that the 16 soils in this region are extremely corrosive.

In 17 fact, they call them aggressively corrosive.

And as 18 a result, we have to add lime, for instance, to 19 raise the pH in our well water in Kingston because 20 all our bathtubs were turning green.

And the issues 21 that are being raised by these people have to do 22 with that reality.

23 Not just that, you know.

Corrosion 24 happens differently in different parts of the pipe, 25 but that our area is especially corrosive.

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water is what I spend a lot of time sampling waters 2

around for instance, in vernal pools in the area.

3 We have pH in some of our vernal pools of 4.5.

That 4

is extremely acidic.

And so. when you combine that 5

with some of our high iron in the soils and whatnot, 6

you're creating an atmosphere where things really 7

need to be looked at much more frequently.

And I 8

think, you know, so too when you have ground water 9

throughout the site, to put in four wells in certain 10 places doesn't necessarily mean you're going to 11 determine if there's a contaminant there.

What I 12 think we would like to see instead are-some kind of 13 array of wells so that if there is a contamination 14 in the ground water, it will get picked up, no t just 15 if it happens to be in one of those four spots 16 across this huge landscape.

17 1 work with the Jones River Watershed 18 Association in Kingston and have for a.very long 19 time and we are extremely concerned about the bay.

20 If those contaminants do leak toward the-bay, it's 21 going to affect our huge fishery and we do not want 22 to see that happen.

23 I spoke here the last time *on the intake 24 structure; I'm not going to address that again.

But 25 we would like to see some advancement in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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relicensing so that we can protect the rest of our 2

important resources.

It's not good enough to say we 3

have cheap power, we should keep it cheap.

Because 4

what's happening here is that we're using so much 5

light that it's lighting up the universe.

We don't 6

need to have an unlimited supply of power.

We have 7

to apply much more resources to ensuring that this 8

power is safe and that's the problem we have.

9 Everybody likes electricity; we're not here to 10 condemn electricity or even to condemn people that 11 are in the nuclear industry.

We would love it to 12 work.

The fear is and the concern is that it's not.

13 I spent 25 years with first Civil 14 Defense and then the Kingston Emergency Management 15 Agency and I left when they decided --

a speaker 16 came to them and said the biggest terrorist in the 17 United States is the Environmental Liberation Front.

18 That's not --

for that to be the perception of the 19 risk is shameful and it represents a level of denial 20 that is damaging to the public safety.

We have to 21 take these things seriously.

We have to not deny 22 that they exist.

We have to take and improve 23 measures where we can every time we can and simply 24 considering that this is a battle between the 25 environmentalists and people who like jobs is not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 1

good enough.

I hope you do better.

I hope that you 2

really put Enterav to the task of. improving this 3

facility so that we can all rest easy and live long 4

lives.

Thank you.

5 ADMIN.

JUDGE YOUNG:

Thank you.

6 Sandra Woods who had signed up earlier 7

has arrived.

8 Ms.

Woods, you want to go next?

Do you 9

want to wait?

10 MS.

WOODS:

I'll go now.

11 ADMIN.

JUDGE YOUNG:

Okay.

12 MS.

WOODS:

Good evening.

Thank you for 13 letting me speak.

I have something I prepared.

14

Again, my name is Sandra Woods and I 15 have lived here on the South Shore all of my life.

16

.UNIDENTIFIED SPEAKER:

Excuse me.

We 17 can't hear her.

18 ADMIN.

JUDGE YOUNG:

No?

Could you get 19 a little closer to the mike?

20 MS.

WOODS:

Sorry.

Okay.

My name is 21 Sandra Woods and I have lived here on the-South 22 Shore all of my life.

Currently I'm a resident of 23 Kingston, formerly most of my life I grew up on 24 Marshfield.

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and :work near the Plymouth nuclear power plant if I 2

thought it Was unsafe to do so.

Therefore, it is 3

with gratitude to you for this opportunity that I 4

testify why I'm in favor of granting a license for 5

Pilgrim Nuclear Power Plant.

6 Pilgrim Nuclear Power Plant is 7

environmentally safe, first and foremost.

It is a 8

clean, reliable source of energy because it does not 9

emit any greenhouse gases that contribute to global 10 warming and it produces no harmful byproducts.

11 Pilgrim uses a fuel supply that is far less 12 expensive than natural gas, petroleum and coal 13 sources and mitigates the need for 10 million 14 barrels of imported oil, which is something that's 15 on most everybody's mind nowadays.

I know I commute 16 to Dedham every day to work and so gas is ever on my 17 mind, between that and heating my home.

Being more 18 locally independent is something I'm very hopeful 19 for in the near future.

20 The fact that Pilgrim is environmentally 21 friendly is supported by the generic environmental 22 impact statement of 2006 where it notes that 23 pollution would increase if only part of Pilgrim's 24 power, 350 megawatts, was replaced by gas because 25 Pilgrim mitigates 10 tons of sulfur oxides annually, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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148 tons of nitrogen oxides annually, 141 tons of.

2 carbon monoxides annually and 324 tons of 3

particulates annually.

Furthermore, the hard 4

working people of Pilgrim are also members of the 5

community and it's good to know that an industrial 6

facility like Pilgrim can operate in such a clean 7

pristine manner.

When you go around there, you see 8

birds and all manner of wildlife enjoying their 9

natural habitat.

Pilgrim does not interrupt the 10 natural balance of their environment.

11 On an economical level, Pilgrim Nuclear 12 Power Plant provides hundreds of jobs for local 13 residents.

The plant also sells power to the long 14 term market enabling customers to realize 15 significant savings.

It should also be noted that 16 Entergy donates more than $135 million to Plymouth 17 annually.

18 Members of the panel, if Pilgrim is 19 forced to cease operation, what will be put in its 20 place?

The power plant provides seven to nine 21 percent of the Commonwealth's electricity supply on 22 a typical day and has consistently earned the 23 Nuclear Regulatory Commission's green rating, the 24 highest safety rating allotted to any nuclear power 25 plant.

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Finally, it should be kept in mind that 2

Pilgrim constantly works with officials in Plymouth 3

and surrounding communities, as well as state and 4

regional agencies to craft emergency plans that 5

would be valuable in any crisis situation, including 6

hurricanes, forest fires, floods and blizzards.

7 Pilgrim also provides funding for communications 8

equipment and specialized training of Plymouth 9

public safety personnel and other town employees to 10 ensure that there are no gaps in safety procedures.

11 I therefore urge the ALSB to consider 12 these facts and grant Entergy's Pilgrim Nuclear 13 Power Plant a license extension so that it can 14 continue to operate safely for an additional 20 15 years.

Again, thank you for the opportunity to 16 speak with you today.

Thanks.

17 ADMIN.

JUDGE YOUNG:

Thank you.

18 Ms.

Sara Altherr?

19 MS.

ALTHERR:

I live in

Kingston, 20 Massachusetts on the Jones River.

21 I didn't come prepared today and I'm 22 sorry about that.

But I have been concerned about 23 the existence of the nuclear power plant for the 25 24 years that I've lived in this area.

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the economic advantages of having this nuclear power 2

plant in our neighborhood, in our area.

I think 3

that when we weigh jobs against the safety of 4

people, all the people who have been saying well, 5

we're going to lose all these jobs, are saying the 6

plant is safe.

I don't believe that all of us agree 7

that the plant is safe.

We've heard testimony on 8

both sides.

I think there's an argument as to 9

whether the plant is actually a safe place.

And I 10 hope that you will really consider the 11 recommendations of the people who have asked for 12 more monitoring, because that's really important to 13 US.

What if it isn't safe and people are getting 14 sick, that's costing the employers more money for 15 health care and it's costing the lives and welfare.

16 of the people who live here.

17 So, I really don't want to go on because 18 I'm not very well prepared.

But I hope that you 19 will listen to the people who are asking for more 20 monitoring of what's actually going into our 21 environment.

Thank you.

22 ADMIN. JUDGE YOUNG:

Thank you.

23 Mr. Paul Blanch?

24 MR. BLANCH:

Good evening.

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and I wasn't planning to speak here tonight, but 2

just to observe.

But I did hear something that was 3

quite bothersome to me.

4 My experience is I have over 40 years of 5

nuclear experience, including the United States Navy 6

and I worked at Millstone Nuclear Power Plant for 7

over 25 years.

I'm a registered professional 8

engineer and I was in management at Northeast 9

Utilities.

10 And I've been following this issue and I 11 am not a party to this particular issue here.

I am 12 not an expert witness.

I'm an interested citizen.

13 But I hear testimony tonight about buried pipe and 14 monitoring wells.

And monitoring wells might be 15 satisfactory for detecting corrosion leakage for 16 systems and piping that contain highly radioactive 17 fluids, and that is a concern and I certainly 18 support some type of monitoring system. But we 19 can't forget the buried pipe that is the most 20 important piping to preventing a meltdown of this 21 nuclear power plant, and if it's similar to 22 Millstone Unit 1, which I believe it is, it's a 23 service water system.

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core.

Without the service water system, the core 2

will melt.

There is no cooling without the service 3

water system.

There is redundancy within the 4

service water system.

There are typically four 5

normal service water pumps and two emergency service 6

water pumps and there are anywhere from four to six.

7 buried pipes.

And these pipes are typically 20 to 8

30 inches in diameter.

And I'd like to just cite an 9

anecdotal story of something that happened in front 10 of my house two weeks ago.

11 Water was coming up from under the 12 street and we called the water company.

And it was 13 a leaking pipe and it was due to aging, and it was 14 due to corrosion of a fitting.

And I observed these 15 people as they repaired this pipe, and they did a 16 very good job and it was only a six-inch diameter 17 pipe, but it was leaking at about 10 gallons a 1s minute.

And the repair was quite extensive; but it 19 was not catastrophic.

And the people told me that 20 probably the pipe was leaking for six or eight years 21 before that water came to the surface.

Now I look 22 at that pipe and I relate that to the service water 23 pipe, and without the service water pipe, as I said 24 before, you won't have core cooling, you will have a 25 meltdown without service water.

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But if we had some type of perturbation 2

in a system such as the service water that had 3

degraded due to aging, be it corrosion or due to 4

some type of flange or connection, or weld that 5

wasn't routinely inspected and we had a perturbation 6

such as an earthquake or seismic event, or a 7

perturbation caused by a loss of coolant accident in 8

the sudden starting or stopping of these pumps, if 9

that corrosion in these pipes is not monitored 10 adequately on a periodic basis, we could have a 11 common mode failure of all redundant systems.. And 12 these pipes do have a history of corrosion and do 13 have a history of failure, at least from my 14 experience at Millstone.

15 And to reiterate, I think the most 16 important thing with respect to buried piping is the 17 monitoring of the age-related degradation or 18 potential degradation of the service water piping.

19 While I believe that the monitoring wells for highly 20 radioactive material leaking into the environment is 21 important, the most important thing is the aging 22 monitoring of that buried pipe that is used to 23 support the service water system.

I thank you very 24 much for your time.

25 ADMIN. JUDGE YOUNG:

Thank you, sir.

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Is there anyone else who would like to 2

speak?

Sir, I saw you first.

Why don't you come up 3

and tell us your name.

Also spell it.

We're taking 4

a transcript of this.

5 MR.

BROWN:

Want me to come up here?

6 ADMIN.

JUDGE YOUNG:

You could just 7

spell it.

That way it gets on the tape and it's 8

transcribed into a written transcript.

9 MR.

BROWN:

I'm Paul Brown.

I'm a 10 resident of Duxbury.

I came here from Rhode Island 11 in 1979.

12 In

1963, I went to work at Electric Boat 13 Company for Admiral Rickover.

After the Thresher 14 incident, so-called, when they lost the USS --

the 15 SNB.

I forget the actual number it was, but anyway, 16 she was lost.

Nothing to do with the reactor.

But 17 at that point, Admiral Rickover separated the 18 nuclear quality control department from the ship's 19 quality control department.

And I was in the 20 nuclear quality control department working directly 21 for Admiral Rickover in the inspection of nuclear 22 piping.

And it is not a coincidence that the Navy 23 has never lost a ship due to a malfunction of 24 piping.

The loss of the Thresher was due to 25 inadequate design.

She started to go down.

She NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1

went below her test depth.

This is all public 2

knowledge now.

It was then a testimony before 3

Congress where Admiral Rickover testified.

And she 4

exceeded her test depth and she couldn't blow her 5

tanks because the pressure was too great and down 6

she went.

The question was asked, how fast was she 7

going when she hit the bottom?

About 100 knots, and 8

that's why they couldn't find her for a long time.

9 Well, all of this I've been disturbed by 10 what has been taking place with these fellows down 11 at Pilgrim Nuclear Power Plant.

It's the Pilgrim 12 Station.

It happens to be a nuclear power plant.I 13 think there's no reason that this can't be a very 14 safe operation, but there has to be control and 15 there has to be oversight by knowledgeable people.

16 if that takes place, very appropriate to this, if I 17 may --

have I got time just to read a short thing 18 from an article here?

19 It's called, "The Case For Terrestrial, 20 or AKA Nuclear Energy," and this gentleman, his name 21 is William Tucker.

He's a journalist and he says 22 there have been a host of debates this year between 23 the Democrats and Republican candidates for 24 president. Many of these candidates believe that 25 among our top priorities is to address global NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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warming by reducing carbon emissions.

All our most 2

seem to agree that decreasing America's energy 3

dependence is another.

Yet few, if any, of the 4

candidates have mentioned that nuclear energy, or as 5

I prefer, terrestrial energy could serve both these 6

ends.

Right now there are 103 operating nuclear 7

reactors in America, but most are owned by 8

utilities, which also own coal plants.

The few 9

spinoffs that concentrate mainly on nuclear are 10 Entergy of Jackson, I think this is the people down 11 here, and Exelon of Chicago are relatively small 12 players.

13 There's only one steel company in the 14 world today that can cast the reactor vessel, the 15 42-foot egg-shaped container in the core reactor, 16 and that's located in Japan.

Now I say this is a

17 disgrace.

Here were are with MIT, which my father 18 attended and which I am now at the heart of the 19 nautical museum working with some people there, and 20 we can't cast our own reactor vessels.

This is a

21 disgrace.

Thank you very much.

22 ADMIN.

JUDGE YOUNG:

Thank you.

Sir?

23 MR.

CION:

My name is Maurice Cion.

I'm 24 a physician and a citizen of Plymouth.

25 ADMIN.

JUDGE YOUNG:

How do you spell NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1

your last name?

2 MR.

CION:

C-I-O-N.

3 ADMIN.

JUDGE YOUNG:

And I should have 4

asked your first

name, too.

5 MR.

CION:

Maurice.

Maurice.

6 ADMIN.

JUDGE YOUNG:

Maurice?

Okay.

7 MR.

CION:

I understand the issue that 8

this panel is here to decide is whether or not 9

monitoring wells are necessary to assure that buried 10 pipes will continue to perform their safety 11 function, so I'm going to limit my remarks to that.

12 I had a political statement to read, but others have 13 made those statements.

14 There is no operating experience to rely 15 on, as I see it.

There's no reactor in this 16 country, or in any country, that's operated 45, 50, 17 55 or 60 years.

That's what we're asking for, 18 another 20 years on top of the 40 years that this 19 plant has already been in existence.

There is a

20 paucity of site experience, specific experience at 21 Pilgrim to rely on and what there is shows problems.

22 There are leaks popping up all over the country as 23 reactors age and they put in monitoring wells.

24 Components age more rapidly as they get older.

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protocol.

We need to reduce the future corrosion 2

rate.

We need to.-add cathodic protection on piping 3

and we need to improve monitoring frequency and 4

specified coverage.

Specifically, I believe that 5

100 percent internal visual inspection of all 6

underground pipes and tanks must be implemented.

7 The inspection cycle should be such that all pipes 8

and tanks are inspected every 10 years, however, I 9

believe that the applicant should be required to 10 break the testing interval down such that one-sixth 11 of all pipes and tanks are inspected during each 12 refueling outage.

This assumes 18-month refueling 13 outages, or six every 10 years.

14 Finally, it's my outage that the 15 applicant should be required to inspect one-since of 16 the lineal piping, one-sixth of the elbows and 17 flanges and one-sixth of the tank seams at each 18 outage, even if such inspections lengthen the outage 19 time.

We need a proper monitoring well program, 20 properly placed and in sufficient number to actively 21 look for leaks once they have occurred.

The current 22 newly-installed four well program is a joke.

A real 23 program should be designed.

Thank you very much.

24 ADMIN. JUDGE YOUNG:

Thank you.

25 1 see someone else.

Sir?

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MR. ROTHSTEIN:

I'm Rich Rothstein.

I'm 2

a Plymouth resident and former West Hartford 3

resident, where I grew up.

So when I heard this 4

gentleman from West Hartford, Connecticut, I decided 5

that I should come up and say something, too.

6 ADMIN. JUDGE ABRAMSON:

Spell your last 7

name, please.

8 MR. ROTHSTEIN:

Sure, Rothstein.

Judge 9 Young has my spelling, because she used my 10 information in contention 3, I believe.

11 ADMIN. JUDGE YOUNG:

Okay.

R-O-T-H-S-T-12 E-I--N.

13 MR. ROTHSTEIN:

Yes.

And I lust wanted 14 to say that I wanted to thank Judge Young for having 15 the courage to dissent against her two colleagues 16 regarding some of the issues that I brought up 17 regarding meteorology and modeling issues with 18 regard to emergency preparedness planning.

And 19 having worked the past 36 years as an environmental 20 consultant and double-board certified, I think my 21 credentials are just as good as these gentlemen up 22 front, too.

And what I do and what I've done, I 23 just wanted to thank you for taking the time to read 24 through everything that I prepared as part of the 25 nuclear matters committee in Plymouth and having NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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used by other people who are intervening, but you 2

did take the time and I thank you for that.

3 ADMIN.

JUDGE YOUNG:

Would anyone else 4

like to speak?

Ma'am?

5 And incidently, we invite all of you to 6

come tomorrow and listen.

You can't speak, but you 7

might find it interesting.

8 Go ahead.

9 MS.

PYE:

My name is Barbara Pye.

I'm a 10 resident of Duxbury, Massachusetts.

11 ADMIN.

JUDGE YOUNG:

And your last name?

12 MS.

PYE:

P-Y-E.

13 ADMIN.

JUDGE YOUNG:

P-Y-E?

14 MS.

PYE:

Yes.

I came to the meeting 15 late; I got here about 7:00, so I missed quite a bit 16 of it and --

need to repeat everything said, but 17 basically I wanted to say the same thing about the 18 monitoring wells, that I wish actually that we could 19 get some of the people from New York up here and 20 get.

They have 40 or 50 down at Indian Point; we 21 only have four here at our power plant.

And so, 22 your job is to decide what needs to be done, and I 23 know you're going to be doing that.

I'm glad that 24 you're looking out for us.

I'm sure both of you 25 other gentlemen are attempting to do that too.

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But, we're all in this together and I 2

just want to make sure that we get the necessary 3

monitoring, you know, to ensure our safety.

That's 4

it.

Thank you.

5 ADMvIN. JUDGE YOUNG:

Thank you.

6 Anyone else?

Don't be shy.

7 I've got about ten to 8:00 on my watch, 8

maybe a quarter to 8:00.

We'll wait at least until 9

8:00 to see if anyone else comes in.

10 In the meantime, is there anyone who 11 would like to speak?

12 Judge Abramson?

13 ADMIN. JUDGE ABRAMSON:

Yes.

Let me say 14 a couple of words.

This is Judge Abramson for those 15 of you who can't see me.

16 Many of you have raised the question of 17 monitoring, and it's very important that you 18 understand that monitoring is something that the 19 Nuclear Regulatory Commission, the Agency and its 20 technical staff watches on a day-to-day basis as 21 part of the ongoing obligations of Entergy, the 22 owner of the plant, to have adequate monitoring.

it 23 is not proper subject matter for a license renewal 24 and it will not be heard here.

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because it's got to be done on a day-to-day basis.

2 It's part of what the Agency watches all the time.

3 So if you're concerned about that, I'd 4

suggest you take those issues directly to the staff.

5 ADMIN. JUDGE YOUNG:

Anyone else?

6 Well as I said, we'll wait a few minutes 7

to make sure that there's no one else who's on their 8

way.

And then I think in our notice we indicated 9

that if we run out of speakers, we would adjourn 10 early, but we'll give people another little over 10 11 minutes to see if anyone else comes in.

Probably 12 everyone who intended to come is here since we said 13 6:30 in the notice.

14 Why don't we go off the record and then 15 if we need to, we'll come back in 10 minutes and see 16 whether there's anyone else.

17 (Whereupon, at 7:50 p.m. off the record 18 until 7:50 p.m.)

19 ADMIN. JUDGE YOUNG:

Okay.

Let's see.

20 Barbara Pye had a few more things she'd like to say.

21 MS. *PYE:

In reference to what you just 22 said about the monitoring.

It was my understanding 23 that just installed the four monitoring wells right 24 now.

So, I mean, it's something that has just 25 started.

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adequately, you know, perform this task, if they 2

just started it.

And what I said before is I wish I 3

was in New York because they have 40 or 50 at Indian 4

Point; we have four.

I mean, we're just 5

ADMIN.

JUDGE ABRAMSON:

It's important 6

to recognize we're not the technical staff.

We're 7

just judges here who adjudicate the single issue 8

that's in front of us tomorrow.

9 MS.

PYE:

Yes.

10 ADMIN.

JUDGE ABRAMSON:

So if you're 11 interested in what the staff's position is on 12 monitoring, then you should take it up with the 13 technical staff or take it up with Entergy.

We have 14 no information.

We're not involved with the fact 15 that they've installed those monitoring wells.

It's 16 not in front of us.

It's not part of the issue that 17 we're going to hear.

But the staff and the 18 Commission, the Agency itself watches over the day-19 to-day operations and monitoring for leaks is part 20 of that day-to-day operation.

We don't know 21 anything about the four wells and we're not involved 22 in them putting them in; it's not part of the 23 adjudication.

It's a totally different thing.

24 ADMIN.

JUDGE COLE:

It's part of the 25 staff's continuing job.

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MS. PYE:

Yes.

Well, we just want to 2

make sure that they're doing what needs to be done.

3 And that's what you're supposed to be doing 4

tomorrow, right?

5 ADMIN. JUDGE ABRAMSON:

What we are 6

doing tomorrow is we're the judges --

7 MS. PYE:

Right.

I know.

8 ADMIN. JUDGE ABRAMSON:

on an 9

argument between the applicant -

10 MS. PYB:

Right.

11 ADMIN. JUDGE ABRAM4SON:

and Pilgrim 12 Watch about whether or not these buried pipes and 13 tanks can leak at such great rates that they can't 14 perform their particular safety function, which by 15 the way, if you come tomorrow you'll be very 16 interested, if there's any testimony.

If not, you 17 should look at the record.

But you will find that 18 the intended safety function is to protect in 19 extremely severe conditions, not small leaks.

And 20 that means that they have to leak at huge rates in 21 order for them not to satisfy the safety function.

22 So it's a very different issue.

23 MS. PYE:

That's a little scary to think 24 that, you know, everything isn't being considered.

25 I mean, it has to be a severe leak?

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ADMIN.

JUDGE ABRAMSON:

No, I'm not --

2 MS.

PYE:

I mean, you know, that's what 3

the monitoring wells are supposed to be fore.

4 ADMIN.

JUDGE ABRAIMSON:

We're not --

no, 5

we're not saying to you that the Agency doesn't deal 6

with leaks.

The Agency deals with leaks.

That's 7

not the question that we've been asked to serve as 8

judges on.

9 MS.

PYE:

Okay.

10 ADMIN.

JUDGE YOUNG:

If anyone would 11 like to go to the NRC website, get more information 12 about what the NRC does, get more information about 13 this proceeding, there are copies, I believe there 14 are still come copies of the notice about tonight's 15 session and tomorrow's hearing that gives directions 16 on how to get to the site and to different parts of 17 the site where you can get information about this 18 proceeding and other aspects of the NRC.

19 UNIDENTIFIED SPEAKER:

What time is the 20 meeting tomorrow?

21 ADMIN.

JUDGE YOUNG:

We start at 9:00.

22 We're one floor up in the ballroom and we welcome 23 everyone to come and listen.

24 ADMIN.

JUDGE ABRAMSON:

But it's not a 25 meeting.

It's a courtroom hearing.

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UNIDENTIFIED SPEAKER:

Oh, yes.

I'm 2

sorry.

Wrong word.

3 ADMIN.

JUDGE YOUNG:

Anyway, we invite 4

you to come.

Everyone's welcome.

5 Anyone else have anything that you'd 6

like to say?

7 We appreciate you all coming out.

We 8

understand that it takes some effort to come out.

9 And the weather's pretty nice now, but it still 10 takes some effort to come out.

And so we really 11 thank you all for taking the time and putting in the 12 effort to come here and share your thoughts with us.

13 14 All right.

Then we'll adjourn.

And 15 again, we hope to see as many of you as can make it 16 tomorrow morning at 9:00.

17 (Whereupon, the limited appearance 18 session was concluded at 7:54 p.m.)

19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com

CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:

Name of Proceeding: Pilgrim Nuclear Power Station Docket Number:

50-293-LR; ASLBP No.06-848-02-LR Location:

Plymouth, Massachusetts were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

-Eric 'endrixson Official Reporter Neal R.

Gross & Co.,

Inc.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com