ML082490514

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License Renewal Public Scoping Meeting Transcript: Evening Session, July 30, 2008, Pages 1-79
ML082490514
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 07/30/2008
From:
Advisory Committee on Reactor Safeguards
To:
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NRC-2313
Download: ML082490514 (78)


Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Prairie Island Nuclear Plant Public Meeting: Evening Session Docket Number: (n/a)

Location: Red Wing, Minnesota Date: Wednesday, July 30, 2008 Work Order No.: NRC-2313 Pages 1-78 NEAL R. GROSS AND CO., INC.

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

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

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 PUBLIC MEETING TO DISCUSS THE LICENSE RENEWAL 5 AND ENVIRONMENTAL SCOPING PROCESS FOR THE 6 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, 7 UNITS 1 AND 2, 8 LICENSE RENEWAL APPLICATION REVIEW 9 + + + + +

10 Red Wing Public Library 11 225 East Avenue 12 Red Wing, Minnesota 13 Wednesday, July 30, 2008 14 7:00 p.m.

15 + + + + +

16 17 NRC PARTICIPANTS:

18 Lance Rakovan, Moderator 19 Nathan Goodman 20 Rani Franovich 21 Richard Plasse 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1

2 3 P-R-O-C-E-E-D-I-N-G-S 4 (7:00 p.m.)

5 MR. RAKOVAN: Good evening, everyone. My 6 name is Lance Rakovan. I am a Communications 7 Specialist at the Nuclear Regulatory Commission, or 8 NRC.

9 It is my pleasure to facilitate tonight's 10 meeting, and what I'm going to do is just try to make 11 sure that we have an effective meeting for everyone 12 involved.

13 The purpose of us being here tonight is 14 to discuss the License Renewal and Environmental 15 Scoping Process for the Prairie Island Nuclear 16 Generating Station Units 1 and 2 License Renewal 17 Application Review.

18 Before we really got things started, I 19 just wanted to take a moment to let you know what to 20 expect from tonight's meeting and to go through a few 21 ground rules.

22 Essentially there's going to be two parts 23 to tonight's meeting. First we're going to start out 24 with a couple presentations by NRC staff specifically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 focusing on the license renewal process and the 2 environmental review process.

3 After that we're going to open it up for 4 questions and answers to see if you have anything 5 that you want to ask in terms of clarifying questions 6 on the presentations, and then we're going to open it 7 up for environmental scoping comments.

8 When you signed in for the meeting, we 9 had some yellow cards that were up there. A few of 10 you signed them out that you specifically knew that 11 you wanted to make a comment at tonight's meeting, 12 and so we'll let those people speak first.

13 After that, if you decide that you want 14 to make a comment, I have plenty of the yellow cards.

15 Just make sure that we have the correct spelling of 16 your name, which leads to my next point, which is the 17 fact that we are transcribing tonight's meeting, 18 which is why I'm standing up here using a microphone 19 even though this is a fairly small room.

20 If you are going to ask questions or make 21 a comment, we're going to ask that you go ahead and 22 come up here to use the microphone. That way we can 23 make sure that not only everybody can hear you but 24 also that our transcriber can record you and make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 1 sure that we get a clear, concise version of what 2 you're saying on the transcript.

3 To help make sure that we do get a clean 4 transcript, I'd ask that you try to keep side 5 conversations down to a minimum; and also, if you 6 have any cell phones or other electronic devices that 7 you put them on mute or turn them off at this time so 8 they don't go off during the meeting and distract.

9 If you do come up and ask a question or 10 make a comment, if you could just make sure that you 11 introduce yourself and let us know if there's any 12 association or organization that you're with. Again, 13 that helps us make sure that we know who's commenting 14 or making a particular comment during the meeting and 15 so we can get it all on the transcript.

16 On the table outside that we had when you 17 signed in, there were copies of tonight's 18 presentations, so hopefully you picked one up.

19 If you didn't, flag me down after I'm 20 done giving my little spiel here, and I'll go, you 21 know, get a copy for you.

22 There were also public meeting feedback 23 forms. Those are just a little tool that we use that 24 we ask that you fill out.

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5 1 If there's something that we're doing 2 well with the meeting, if there is a particular 3 improvement that you think we could do better with a 4 meeting, if you could fill those out; you can either 5 leave them on the table on your way out or, if you 6 drop them in the mail, there is no postage necessary, 7 so it will get to us.

8 And that's just something you can do to 9 help us make sure that these meetings are effective.

10 We did have a lot of information in the 11 side room across the way, so if you didn't have a 12 chance to get that information before the meeting, I 13 think we might still have it set up after. But 14 that's another place that you could probably go and 15 get some additional information as background for 16 tonight's meeting.

17 I wanted to introduce our speakers 18 tonight. We have Rick Plasse, who is Project Manager 19 for Prairie Island license renewal. We also have 20 Nathan Goodman, who is the Project Manager for the 21 environmental part of the license renewal.

22 And I also wanted to point out Paul 23 Zurawski. He's our resident inspector that works at 24 the Prairie Island plant who's with us tonight.

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6 1 That's all I have to say at this point, 2 so I'm going to turn things over to Rick for the 3 first presentation.

4 And, like I said, once the presentations 5 are over, we'll open things up to the crowd.

6 Rick?

7 MR. PLASSE: Thanks.

8 Good evening. My name is Rick Plasse.

9 I'm a Project Manager within the Division of License 10 Renewal, and I am coordinating the staff's review of 11 the Prairie Island Nuclear Generating Plant Units 1 12 and 2 license renewal application.

13 Thank you all for taking the time this 14 evening come to the meeting. We appreciate it.

15 Tonight we will provide an overview of 16 the license renewal review process, which includes 17 both the safety review and an environmental review.

18 We also will describe in more detail the 19 environmental processes associated with the license 20 renewal review.

21 But the most important part of tonight's 22 meeting is to --

23 Okay. Sorry about that.

24 The most important part of tonight's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 meeting is to receive comments that you may have on 2 the scope of the environmental review. We also will 3 give you information about how you can submit 4 comments outside of this meeting.

5 At the conclusion of tonight's 6 presentation, we will be happy to answer any 7 questions that you may have on the license renewal 8 review process. However, I must ask you to limit 9 your participation to questions only and hold your 10 comments until the appropriate time during tonight's 11 meeting.

12 Once all questions are answered, we can 13 begin to receive any comments that you have on the 14 scope of our environmental review. I hope the 15 information we provide will help you to understand 16 the license renewal review process and the role that 17 you can play in helping us make sure that our 18 environmental review considers relevant information.

19 Next slide, please.

20 Before I get into the discussion of the 21 license renewal process, I'd like to take a minute to 22 talk about the NRC in terms of what we do and what 23 our mission is.

24 The NRC is a federal agency established NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 by the Energy Reorganization Act of 1974 that 2 regulates the civilian use of nuclear material. The 3 Atomic Energy Act of 1954 authorizes the NRC to grant 4 a 40-year operating license for nuclear power 5 reactors. This 40-year term was based primarily on 6 economic considerations and antitrust factors, not on 7 safety or technical limitations.

8 The Atomic Energy Act also allows for 9 license renewal.

10 The National Environmental Policy Act of 11 1969, NEPA, established a national policy for 12 considering the impact of federal decision-making on 13 the human environment.

14 As a matter of policy, the Commission 15 determined that reactor license renewal constitutes a 16 major federal action for which an environmental 17 impact statement is warranted.

18 The NRC's regulations governing nuclear 19 safety, security, and environmental protection are 20 contained in Title 10 of the Code of Federal 21 Regulations, which is commonly referred to as 10 CFR. 22 In exercising its regulatory authority, 23 the NRC's mission is threefold: To ensure adequate 24 protection of public health and safety; to promote NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 the common defense and security; and to protect the 2 environment.

3 The NRC accomplishes its mission through 4 a combination of regulatory programs and processes 5 such as establishing rules and regulations, 6 conducting inspections, issuing enforcement actions, 7 assessing licensee performance, and evaluating 8 operating experience from nuclear plants across the 9 country and internationally.

10 The NRC has resident inspectors -- Paul, 11 who's here tonight representing the residents -- at 12 all operating nuclear power plants. These inspectors 13 are considered the eyes and ears of the NRC. They 14 carry out our safety mission on a daily basis and are 15 the front lines of ensuring acceptable safety 16 performance and compliance with regulatory 17 requirements.

18 Next slide.

19 Now turning to Prairie Island, for Units 20 1 and 2 the current 40-year operating licenses expire 21 on August 9th, 2013, and October 29th, 2014, 22 respectively. NRC received Nuclear Management 23 Company's application for license renewal on both 24 units on April 15th, 2008.

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10 1 Next slide.

2 A license renewal application is required 3 to contain general information such as the 4 applicant's name and address, business and 5 administrative information; 6 Technical information pertaining to aging 7 management -- this information is the focus of the 8 staff's safety review, which we'll discuss later; 9 Technical specifications which define the operating 10 parameters of the plant -- the application indicates 11 what, if any, changes or additions to the technical 12 specifications are necessary to manage the effects of 13 aging during the period of extended operation; 14 And, finally, the application also 15 includes an environmental report, which is the 16 applicant's assessment of the environmental impacts 17 of continued operation.

18 And this information serves as a starting 19 point for the staff's environmental review, which 20 we'll talk about later also.

21 Next slide.

22 License renewal involves two parallel 23 reviews, the safety review and the environmental 24 review. These two reviews evaluate separate aspects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 of the license renewal application.

2 The safety review focuses on the aging of 3 components and structures that the NRC deems 4 important to plant safety. The staff's main 5 objective in this review is to determine the effects 6 of aging will be adequately managed by the applicant.

7 The results of the safety review are 8 documented in a safety evaluation report, or what we 9 commonly call the SER.

10 For the environmental review, the staff 11 considers, evaluates, and discloses the environmental 12 impacts of continued plant operation for an 13 additional 20 years.

14 The staff also evaluates the 15 environmental impacts of alternatives to license 16 renewal.

17 The objective of the review is to 18 determine if the environmental impacts of license 19 renewal are so great that license renewal would not 20 be a reasonable option or the staff prepares and 21 environmental impact statement, or EIS, to document 22 its environmental review.

23 Next slide.

24 Ongoing regulatory oversight. I'd like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 to mention a few very important areas of NRC 2 oversight that routinely come up during our 3 interactions with members of the public.

4 NRC staff address these areas of 5 performance every day as part of the ongoing 6 regulatory oversight provided for all current 7 operating power reactors. They include emergency 8 planning, security, current safety performance as 9 defined by the NRC inspection findings, violation, 10 and general assessments of plant performance.

11 For specific information on current 12 performance of Prairie Island's Unit 1 and 2, you can 13 use the links provided at the bottom of the slide.

14 We've got the two locations on that.

15 And they're also in your handout. We 16 have that in there for your information that you can 17 take back with you.

18 The NRC monitors and provides regulatory 19 oversight of activities in these areas on an ongoing 20 basis under the current operating license, thus we do 21 not re-evaluate them in license renewal.

22 That's not to say that they are not 23 important; we just do not duplicate the regulatory 24 process in these areas for license renewal. It is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 ongoing, and that's what -- Paul's job at the site 2 feeds into that.

3 Next slide.

4 Okay. This diagram illustrates the 5 safety environmental review processes. It also 6 features two other considerations in the Commission's 7 decision of whether or not to review an operating 8 license.

9 One of these considerations is the 10 independent review performed by an Advisory Committee 11 on Reactor Safeguards. Statutorily mandated by the 12 Atomic Energy Act in 1955, the ACRS is a group of 13 scientists and nuclear experts who serve as a 14 consulting body for the Commission.

15 The ACRS reviews license renewal 16 application and the NRC staff's SER. The ACRS 17 reports their findings and recommendations directly 18 to the Commission.

19 Hearings may also be conducted.

20 Interested stakeholders may submit concerns or 21 contentions and request a hearing.

22 If a hearing is granted, the Commission 23 considers the outcome of the hearing process in its 24 decision of whether or not to issue a renewed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 operating license.

2 Now I'm going to describe the license 3 renewal review process in a little more detail, 4 starting with the safety review.

5 Next slide.

6 The regulations governing license renewal 7 are based on two guiding principals. To effectively 8 communicate these principles, I need to describe a 9 concept used by the NRC. The concept is licensing 10 basis.

11 Licensing basis consists of a wide range 12 of design and operational requirements and conditions 13 that must be met for the plant to comply with its 14 operating license. It serves as the basis upon which 15 the NRC originally licensed the plant; and to 16 continue to operate, a plant must conform with its 17 licensing basis.

18 As I mentioned, the regulations governing 19 license renewal are based on two guiding principles 20 that relate back to licensing basis.

21 The first principle is that the current 22 regulatory process is adequate to ensure that the 23 licensing basis of all operating plants provides and 24 maintains an acceptable level of safety.

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15 1 The second principle is that the current 2 plant's specific licensing basis must be maintained 3 during the renewal term in the same manner and to the 4 same extent as during the original license term. In 5 other words, the same rules that apply under the 6 current license will apply in the renewal term.

7 In addition, a renewed license will 8 include conditions that must be met to ensure aging 9 of structures and components important to safety are 10 adequately managed so that the plant's current 11 licensing basis is maintained during the period of 12 extended operation.

13 Next slide.

14 We'll talk a little bit about the safety 15 review. The safety review is rigorous. The staff 16 reviews the applicant's license renewal application 17 and supporting documentation.

18 This review includes an evaluation of new 19 and existing programs and surveillance activities to 20 determine with reasonable assurance that the effects 21 of aging for certain plant structures and components 22 will be adequately managed or monitored.

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16 1 renewal application and to confirm that the 2 applicant's aging management programs and activities 3 conform with how they are described in the 4 application.

5 The staff documents the basis and 6 conclusions of its review in a safety evaluation 7 report, or SER, which is publicly available.

8 In addition, a team of specialized 9 inspectors travels to the site to verify that aging 10 management programs are being implemented, modified, 11 or planned consistent with the license renewal 12 application.

13 Finally, as I have mentioned, the 14 Advisory Committee on Reactor Safeguards performs an 15 independent review of the license renewal application 16 and the staff's SER and makes a recommendation to the 17 Commission regarding the proposed action to issue a 18 renewed operating license.

19 Next slide.

20 Now we'll speak to the environmental 21 review. This review is performed in accordance with 22 the National Environmental Policy Act of 1969, or 23 NEPA.

24 NEPA provides the basic architecture for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 federal environmental review requirements. It 2 requires that all federal agencies follow a 3 systematic approach in evaluating potential impacts 4 associated with major federal actions and 5 alternatives to those actions. By law the NEPA 6 process involves public participation and public 7 disclosure.

8 The National Environmental Policy Act 9 also established the U.S. Council on Environmental 10 Quality, CEQ, within the Executive Office of the 11 President; and CEQ establishes policy for 12 implementation of NEPA. The NRC's environmental 13 regulations contained in 10 CFR, Part 21, are largely 14 based on those that CEQ developed.

15 Our environmental reviews consider the 16 impact of the license renewal and any mitigation for 17 those impacts we consider to be significant.

18 We also consider the impacts of 19 alternatives to the license renewal, including 20 impacts of not issuing a renewed license.

21 The staff documents its environmental 22 review in an environmental impact statement, EIS.

23 Next slide.

24 For a license renewal review, the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 looks at a wide range of environmental impacts. In 2 conducting our environmental review, we consult with 3 various federal, state, and local officials as well 4 as leaders of Indian nations and gather pertinent 5 information from these sources to ensure it is 6 considered in our analysis.

7 Examples include Fish and Wildlife 8 Service, Environmental Protection Agency, State 9 Bureau of Reactor Protection -- Radiation -- I'm 10 sorry, Radiation Protection, State Department of 11 Natural Resources.

12 In this case the NRC has signed a 13 Memorandum of Understanding, or what we call an 14 "MOU," with the Prairie Island Indian Community 15 establishing an official cooperating agency 16 relationship for purposes of the environmental 17 review.

18 The MOU provides a framework for 19 cooperation and coordination between the NRC and the 20 Prairie Island Indian Community in recognition of the 21 community's special expertise in the areas of land 22 use, socioeconomics, environmental justice, and 23 historic and archeological resources.

24 Now I'd like to introduce Nathan Goodman, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 another P.M., who will complete today's presentation 2 on the environmental aspects.

3 MR. GOODMAN: Thank you, Rick.

4 I'm the Project Manager leading the 5 staff's environmental review for Prairie Island Units 6 1 and 2 license renewal. As Rick said, I will 7 provide more information on our environmental review 8 processes.

9 The environmental review begins with a 10 scoping process. The purpose of the scoping process 11 is to identify significant issues that should be 12 considered in the environmental review.

13 We are now gathering information that we 14 will use to prepare an environmental impact 15 statement. As part of that process, we are here to 16 collect your comments on the scope of the 17 environmental review -- that is, the environmental 18 impacts that the staff should consider.

19 The staff has developed a generic 20 environmental impact statement, generic EIS, that 21 addresses a number of issues common to all nuclear 22 power plants.

23 The staff is supplementing that generic 24 EIS with a site-specific EIS in which we will address NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 issues that are specific to Prairie Island.

2 The staff also re-exams the conclusions 3 reached in the generic EIS to determine if there's 4 any new and significant information that would change 5 those conclusions.

6 The scoping period started on July 22nd, 7 2008, when the notice of intent to prepare an EIS and 8 conduct scoping was published. The NRC will be 9 accepting comments on the scope of the environmental 10 review until September 22nd, 2008. We've extended 11 that date from September 8th, which some of you might 12 have seen on the fliers that have been hanging about, 13 to September 22nd to allow more time for your 14 comments.

15 In general we are looking for information 16 about the environmental impacts from continued 17 operation of Prairie Island. You can assist us in 18 that process by telling us, for example, what aspects 19 of your community we should focus on, what local 20 environmental, social, and economic issues the NRC 21 should examine during our environmental review and 22 what reasonable alternatives are most appropriate for 23 this region.

24 These are just some examples of the input NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 we're looking for, and they represent the kind of 2 first we are seeking through the environmental 3 scoping process. Your comments tonight should be 4 helpful in providing insights of this nature.

5 This slide illustrates the things the 6 Commission considers in deciding if a renewed 7 operating license will be issued.

8 So how do we use your input?

9 Public comments are an important part of 10 the environmental review process. We consider all 11 the comments that we receive from the public during 12 the scoping process.

13 Next slide, Andy.

14 Now, in addition to providing comments at 15 this meeting, there are other ways that you can 16 submit comments for our environmental review process.

17 You can provide written comments by mail 18 to the chief of our Rules and Directives Branch at 19 the addresses provided on the slide, which are in 20 your handout as well, or email at the addresses 21 provided on the slide and in your handouts.

22 You can also make comments in person if 23 your travels happen to take you to Rockville, 24 Maryland. And please contact Rick or myself in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 advance to make arrangements. As I mentioned before, 2 comments should be submitted by September 22nd.

3 This slide shows important milestone 4 dates for the environmental review process. The 5 opportunity to submit contentions and a request for a 6 hearing closes on August 13th, 2008; and if you have 7 comments you would like to submit outside of today's 8 meeting, you have until September 22nd.

9 Please note that a draft supplemental 10 environment impact statement will be issued for 11 public comment in March of 2009.

12 While the slide lists milestones for the 13 environmental review and opportunities for public 14 involvement, the safety review will also be performed 15 in accordance with its own review schedule.

16 This slide identifies me, Nathan Goodman, 17 as the primary point of contact within the NRC for 18 environmental issues and Rick, Project Manager, 19 spearheading the staff's safety review.

20 It also identifies where documents 21 related to our review may be found in the local area.

22 The Red Wing Public Library has agreed to make the 23 license renewal application available for public 24 review.

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23 1 When it is published for comment, the 2 draft environment impact statement will also be 3 available at this library. In addition, these 4 documents will also be on NRC's website at the web 5 address shown at the bottom of this page.

6 As you came in, you were asked to fill 7 out a registration page at the front of our reception 8 table. If you've included your address on that page, 9 we will mail a copy of the draft and final EIS to 10 you.

11 This concludes my presentation, and I 12 will turn it back over to Lance.

13 Thank you.

14 MR. RAKOVAN: Thanks, guys.

15 Before we go ahead and go to the cards, 16 people who have signed up to speak, I wanted to just 17 pause a moment to see if anyone had clarifying 18 questions to the material that Rick and Nate 19 presented.

20 If you do, just raise your hand and get 21 my attention somehow; and we'll ask, of course, that 22 you come up and use the microphone so we can make 23 sure that we get it on the transcript.

24 Did anyone have any questions on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 presentations?

2 (No response.)

3 And again, if you don't want to ask a 4 question in a public venue like this, we will be 5 sticking around after the meeting and you can 6 certainly go up to Nate, Rick, or any of the other 7 NRC staff here and have a one-on-one conversation, if 8 that's what you prefer.

9 Okay. What I'm going to do now then --

10 Sir, if you could please come to the 11 podium so that we can make sure that we get you on 12 the transcript.

13 ALAN MULLER: Yeah, sure.

14 MR. RAKOVAN: And if you could, you know, 15 identify yourself and let us know any organizations 16 you might be with.

17 ALAN MULLER: Yeah. My name is Alan 18 Muller. I'm a part-time resident of Red Wing and a 19 part-time resident Port Penn, Delaware, and I'm the 20 Executive Director of Green Delaware, and we have had 21 many interactions with the regional office and 22 headquarters of the NRC involving nuclear facilities 23 in that part of the world.

24 I just have a question here. I came in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 late and I didn't see your whole presentation, but on 2 page 3 there's a slide here at the bottom that says 3 "License renewal and safety principles."

4 And it says, "The ongoing regulatory 5 process is adequate to ensure the safety of all 6 currently operating plants."

7 And I wonder if you could explain what 8 that means in this context, because obviously there 9 are many people in the world who don't agree with 10 that statement, and I'm not sure exactly what it has 11 to do with the question of license renewal for the 12 Prairie Island reactors.

13 MR. RAKOVAN: Rani, if you could 14 introduce yourself, please?

15 MS. FRANOVICH: That's a good question.

16 I'm Rani Franovich. I'm the chief of the 17 branch of the license renewal staff that is 18 responsible for reviewing the license renewal 19 application for Prairie Island.

20 I'm afraid you may have come in after we 21 had a discussion of something called "current 22 licensing basis," and it's the set of design and 23 operational parameters that a plant is required to 24 operate within in order to meet the conditions of its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 license.

2 And so one of the premises of license 3 renewal is that that licensing basis is adequate to 4 ensure public health and safety to the end of the 5 current license.

6 For that reason, issues like emergency 7 planning, security, current operational performance 8 are not issues that we look at again under license 9 renewal. We don't duplicate the efforts of our 10 ongoing regulatory oversight and regulations that 11 ensure adequate public health and safety today.

12 So that's what that bullet on the slide 13 means.

14 MR. RAKOVAN: Sir, if you're going to 15 speak, I'm going to have to come and sit next to you.

16 ALAN MULLER: Fine.

17 Not to prolong the discussion, but does 18 that mean that the past history of the plant and any 19 concerns or difficulties would not be considered 20 relevant to the question of whether the plant would 21 be allowed to continue to operate?

22 MS. FRANOVICH: That's true. The past 23 performance issues at a plant presumably will have 24 been addressed through ongoing regulatory oversight, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 and so because license renewal involves the aging of 2 a facility, our concern really is managing of that 3 aging.

4 And so recognizing that there are 5 performance issues that occur at these plants, we 6 have the reactor oversight process that evaluates the 7 significance of those and characterizes the findings 8 in a process by which the regulatory response is 9 determined.

10 Because of that and because we're 11 confident that that process is working to ensure that 12 the plants are operating safely today, we can just 13 focus on aging for license renewal.

14 BRIAN HOLIAN: Can you mention operating 15 experience?

16 MS. FRANOVICH: We also apply that 17 operating experience that we glean from those 18 performance issues to the extent they're relevant to 19 aging management. We incorporate that into our aging 20 management reviews for relicense renewal.

21 Thank you, Brian.

22 ALAN MULLER: Well, I'm not particularly 23 familiar with the operating history of these two 24 reactors, but it does seem to me what you said has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 the effect of inappropriately narrowing the 2 re-licensing proceeding almost to the point of 3 tending to render it meaningless.

4 MS. FRANOVICH: I understand your view.

5 I understand your view on that.

6 ALAN MULLER: Okay. Thank you.

7 MS. FRANOVICH: Umhum.

8 MR. RAKOVAN: Any other --

9 Yeah, sure. Why not.

10 Unfortunately, I don't have a handheld, 11 so I have to use this lapel.

12 Please introduce yourself.

13 KIRSTEN EIDE TOLLEFSON: I'm Kirsten Eide 14 Tollefson, and I live down in Frontenac, which is 15 about 10 miles down river, 10, 15 miles down river.

16 And I'm a little confused as to whether 17 or not I am part of the scope. I mean I've been 18 involved in Prairie Island reactors. In Frontenac we 19 had our own review process down there for waste, and 20 we had a very difficult time being recognized for 21 notice. Our newspaper, the Lake City Graphic, which 22 is one of closest newspapers, was not on the notice 23 list in the application and in fact never received 24 notice.

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29 1 Those of us who signed up with Justin --

2 then I signed up with Justin to receive notice of 3 this meeting -- in fact didn't receive notice until 4 Monday morning, the 28th. It was mailed on July 24th 5 from Washington.

6 And now you have a deadline, I believe, 7 for August 13th, you know, for any kind of -- I mean 8 I understand that there's a deadline and --

9 I guess I want to understand the deadline 10 for August 13th.

11 MS. FRANOVICH: I understand. Okay.

12 KIRSTEN EIDE TOLLEFSON: And so when it 13 says, "What about your community should the NRC focus 14 on in the EIS?" what community is NRC referring to?

15 Is that only Red Wing? What is the scope, the 16 distance parameters that you consider both for -- and 17 why? And why?

18 MS. FRANOVICH: Let me first address your 19 comment on the notice.

20 And I appreciate that, you know, the 21 notices did go out late. We had an unexpected 22 retirement for the former project manager, so we had 23 to recover from that a little bit.

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30 1 understand, and we apologize for that.

2 KIRSTEN EIDE TOLLEFSON: Excuse me. It's 3 not okay. I need you to know.

4 MS. FRANOVICH: Okay.

5 KIRSTEN EIDE TOLLEFSON: Because there is 6 -- you know, for you it is a regular routine thing, 7 because you do plants across the nation. For us it's 8 once.

9 MS. FRANOVICH: I understand. We also 10 have a website that's had the review schedule and 11 this particular meeting on the website for a couple 12 of months, and we've had people come out I think 13 about five weeks ago to meet with some local 14 officials and let them know in the Prairie Island 15 Indian Community.

16 So we've gotten the word out in other 17 ways, but I do understand your comment. Noted.

18 KIRSTEN EIDE TOLLEFSON: And the 19 officials that you met with? Maybe that will help me 20 understand who you consider part of the scope here.

21 MS. FRANOVICH: Well, let me just kind of 22 explain it depends on what the particular issue area 23 that the comment is on.

24 KIRSTEN EIDE TOLLEFSON: Uh-huh.

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31 1 MS. FRANOVICH: For environmental 2 justice, for example, we look at a 50-mile radius.

3 And so what I would do is encourage 4 anyone who has comments to provide them to us, and to 5 the extent that we can, we'll consider them.

6 We also issue a scoping summary report 7 where we identify what all the comments were and we 8 provide responses to those comments, and we make that 9 publicly available.

10 So I would say if you've got comments, 11 provide them to us. It's not like we're limiting the 12 area for which we're interested --

13 KIRSTEN EIDE TOLLEFSON: Oh. Okay.

14 MS. FRANOVICH: -- to a certain zone.

15 KIRSTEN EIDE TOLLEFSON: So it's --

16 because the river, of course, is a major connector 17 for all of us, when it says, "What about your 18 community should the NRC focus on in the EIS?" that 19 would include communities within 50 miles. Is that 20 what you're saying?

21 MS. FRANOVICH: Well, like for 22 environmental justice, the 50-mile zone is what we 23 consider. But I think what I said was it depends on 24 the issue area; provide your comments to us, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 we'll consider them.

2 In other words, I'm not going to 3 discourage you from providing your comments because 4 of where you live.

5 KIRSTEN EIDE TOLLEFSON: Right.

6 MS. FRANOVICH: Okay.

7 KIRSTEN EIDE TOLLEFSON: And there is a 8 way to me to further find out what issue areas you 9 connect with what distances? Is that information 10 that I could --

11 MS. FRANOVICH: I think what I'm trying 12 to ask you to do is give us whatever comments you 13 have, and we'll consider them.

14 KIRSTEN EIDE TOLLEFSON: Oh. Okay.

15 Thank you.

16 MS. FRANOVICH: Thank you.

17 Lance, we have another question in the 18 back.

19 MR. RAKOVAN: Okay. I see two hands.

20 I'm going to go to the one that I saw first.

21 GEORGE CROCKER: Yeah. It's a concern 22 about --

23 MR. RAKOVAN: Sir, if you could introduce 24 yourself, please?

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33 1 GEORGE CROCKER: George Crocker, 2 Executive Director of the North American Water 3 Office.

4 I've had several people from Wisconsin 5 tell me that they didn't receive notice of this 6 meeting, and I'm wondering if -- if such notice did 7 go out to people on the other side of the river and, 8 if so, when? Or if there could -- if not, if there 9 could be efforts to include people on the Wisconsin 10 side.

11 MS. FRANOVICH: I'll have to go back to 12 my project managers to know exactly who was contacted 13 with a formal letter, who was contacted perhaps with 14 some phone calls and get back to you, Mr. Crocker.

15 I'm not sure off the top of my head.

16 PREMA CHANDRATHIL: Hi. My name is Prema 17 Chandrathil. I'm a public affairs officer out in 18 Region III, which is located down by Chicago.

19 As soon as we received the press release, 20 we went ahead and -- we went ahead and distributed it 21 to the local media in this area. That does also 22 include folks in Wisconsin.

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34 1 ahead and give them a heads-up that, you know, we 2 would be coming and that this meeting would be taking 3 place.

4 So I hope that answers your question.

5 GEORGE CROCKER: Well, you have a list.

6 Right? I mean a notice list where you mail out that 7 you notified individuals specifically who are on a 8 list of meetings such as this? Is that true?

9 MS. FRANOVICH: I'll have to check with 10 my project manager, Mr. Crocker. I'm not sure 11 exactly who they sent by name the notices to, so 12 we'll have to get back to you on that one.

13 There was a question about the meeting --

14 not the meeting, but the opportunity -- opportunities 15 for hearing and to provide scoping comments.

16 August 13th is the deadline not to submit 17 comments on the scope of the review but to submit 18 requests for hearing.

19 September 22nd is the deadline for 20 submitting scoping comments. We extended it by a 21 couple of weeks because we acknowledged that there 22 were some delays in getting the notice out originally 23 for the opportunity for scoping.

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35 1 that that shouldn't affect anyone's ability to 2 request a hearing for some reason?

3 MS. FRANOVICH: Well, the ability to 4 request a hearing was noticed some time ago. I don't 5 have the date here with me, I have it in my 6 briefcase. And that's what triggered the opportunity 7 for hearing. And the period for that, I believe, is 8 60 days.

9 KIRSTEN EIDE TOLLEFSON: Oh, I see. That 10 was a separate notice?

11 MR. RAKOVAN: Correct. That was a 12 Federal Register notice.

13 KIRSTEN EIDE TOLLEFSON: Thank you.

14 BRIAN HOLIAN: Sure.

15 MR. RAKOVAN: If you could introduce 16 yourself, please?

17 CAROL OVERLAND: Carol Overland. I'm a 18 resident of Red Wing. And my question -- a couple, 19 but also pertains to notice.

20 I had a very difficult time getting a 21 copy of the application, and in that process I was 22 put on a list at the NRC to get notice, and I did not 23 get notice either.

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36 1 standing, likely, you know, to intervene, but I did 2 not get notice of this meeting.

3 And is that a deadline that can be 4 extended because of the ineffective notice?

5 MS. FRANOVICH: Okay. When you talk 6 about standing as a resident, that's the hearing 7 opportunity.

8 CAROL OVERLAND: Right.

9 MS. FRANOVICH: So are you talking about 10 the opportunity to submit contentions and request a 11 hearing?

12 CAROL OVERLAND: That's right. That 13 August 13th deadline, it seems to me that ought to be 14 extended.

15 MS. FRANOVICH: Okay. Well, I'll tell 16 you what: We'll talk with you after the comments are 17 provided and try to -- I need to understand a little 18 bit more about what it was that you requested notice 19 for and see if we can understand that a little 20 better.

21 CAROL OVERLAND: Well, specifically what 22 I requested was to be on the list to get notice for 23 anything pertaining to this, after fighting really 24 hard for three weeks to get a copy of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 application, which the company did provide to me 2 finally.

3 MS. FRANOVICH: Okay.

4 CAROL OVERLAND: But the notice process 5 for the NRC is clearly flawed, and I think that 6 because of that the hearing opportunity deadline 7 should be extended, and perhaps, you know, scoping 8 comments, that deadline should be extended as well.

9 MS. FRANOVICH: I understand. And we'll 10 talk about that.

11 CAROL OVERLAND: I think it should be 12 something that should be discussed on the record, so 13 I would urge that.

14 MS. FRANOVICH: I think that -- I'm not 15 sure if I can get those --

16 Do you have those details on who you 17 talked to --

18 CAROL OVERLAND: I could email them to 19 you. I've got an in box full of them.

20 MS. FRANOVICH: Right. So I don't know 21 that we can necessarily do it on the record here, but 22 I would like to talk with you and understand a little 23 bit better what was told to you and by whom so we can 24 figure out where things didn't happen that should NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 have.

2 CAROL OVERLAND: Then what can I say?

3 LEA FOUSHEE: I'm Lea Foushee. I work 4 with the North American Water Office, and we've been 5 involved with this Prairie Island process for over 25 6 years, and we did not receive a notice either.

7 Just to make it very clear that those of 8 us that have been working on this reactor site 9 historically have not received notice from the NRC 10 period.

11 I got a copy of the NRC notice from 12 another anti-nuclear organization in Washington, D.C.

13 They said, "Hey, do you know about this?"

14 And I said, "Well, yeah, I do, but not 15 because they told me about it."

16 MS. FRANOVICH: You're talking about the 17 notice for the public meeting?

18 LEA FOUSHEE: I'm talking about the 19 notice for this meeting, this --

20 MS. FRANOVICH: For the meeting.

21 LEA FOUSHEE: This -- right.

22 MS. FRANOVICH: I understand.

23 LEA FOUSHEE: And we are in the 50-mile 24 zone for an environmental justice notification, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 I'm the Director of Environmental Justice for my 2 organization and I did not receive any kind of notice 3 whatsoever.

4 MS. FRANOVICH: Okay. Thank you.

5 MR. RAKOVAN: Any further questions?

6 Okay. You want me to come to you or --

7 JEFF ERPINE: Jeff Erpine. I'm just a 8 resident.

9 I was wondering as far as Units 1 and 2 10 are concerned, will there be any talk about the 11 critical components they're talking about as far as, 12 like, the aging process, you know, what's being done 13 to manage it?

14 MS. FRANOVICH: Okay. Can you repeat 15 your question? I'm not quite sure I understood you.

16 JEFF ERPINE: Oh, I'm sorry. Will there 17 be a meeting to discuss the critical components?

18 MS. FRANOVICH: The critical components 19 that are being evaluated?

20 JEFF ERPINE: Yes, and what's being done 21 to manage the aging process there?

22 MS. FRANOVICH: Right. We just received 23 the application in mid April, and so we're going 24 through the process now of evaluating what's called NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 scoping and screening for license renewal.

2 The criteria and the rule are if it's 3 safety related, it's in the scope of license renewal.

4 If it's not safety related but it's failure could 5 affect a component or structure that does perform a 6 safety-related function, it goes in the scope of 7 license renewal.

8 And then there's a third category, and 9 it's any component or structure that is relied upon 10 to mitigate what are called regulated events. Those 11 events include fire, so fire protection equipment; 12 station blackout mitigation, that equipment would be 13 within the scope; recovery from station blackout; 14 anticipated transients without scram; and -- let's 15 see -- environmental qualification; and there's one 16 more that I'm missing, but it's in the regulations.

17 So we don't really know what those 18 critical components are yet, but we're doing our 19 review to make sure that whatever components are 20 required to be within the scope of license renewal 21 are within the scope of license renewal based on the 22 scoping criteria.

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41 1 components. If they have moving parts, then we have 2 other ways of making sure that those are managed such 3 that their aging is not going to result in a failure.

4 So we're looking at the passive 5 structures and components who aren't challenged on a 6 daily basis such their failures would be revealed 7 just through the operation of the facility.

8 MR. RAKOVAN: Any further questions 9 before we move on to the comments?

10 (No response.)

11 Okay. I'm going to go ahead and start 12 going through the yellow cards that people filled 13 out.

14 Again, this -- you know, if you didn't 15 fill out a yellow card at the beginning of the 16 meeting, it's not that big of a deal. We'll go ahead 17 and, you know, open it up for further comments, of 18 course, after we're done with these.

19 But I'll just go ahead in the order that 20 I have them. We'll start out with Lea Foushee, go to 21 George Crocker, and then third, Alan Muller.

22 So Lea, if you'd like to take the 23 microphone.

24 LEA FOUSHEE: Thank you.

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42 1 I'm Lea Foushee. I'm the Environmental 2 Justice Director for the North American Water Office.

3 About two months ago I received an 4 anonymous letter telling me that the Routine 5 Radioactive Effluent Release Report for Prairie 6 Island was not available to the public as it 7 ordinarily is in May of the following year that the 8 emissions have been generated.

9 And I said, "Well, you know, maybe it 10 will come out later," and so I didn't do anything 11 about it.

12 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ago I got a request to update a 13 flyer that we produced on Monticello when the 14 Monticello nuclear reactor was being relicensed and 15 make it specific for Prairie Island instead of 16 Monticello, and I said, "Well, okay."

17 And so I went and looked for those 18 reports thinking that by now it's got to be there, 19 it's two months later.

20 It wasn't there. It wasn't there.

21 Every other year it was there, 2008 -- or 22 2006 all the way back to 1999. So I downloaded all 23 those, and so I have all those and it's on my hard 24 drive.

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43 1 And I said, "Well, you know, let's go see 2 if we can find the missing report."

3 So I called the Health Development; they 4 of course are totally unavailable. And kept calling 5 them.

6 And I called and they gave me the name of 7 the worker at the plant that supposedly deals with 8 those sort of things, Amy -- Amy what? I can't 9 remember Amy's last name.

10 She didn't answer her phone. I left her 11 a message. She still didn't answer her phone two 12 days later. I called her cell phone; she didn't 13 answer that either.

14 So I called the NRC themselves after 15 looking over and over again for the missing 16 information, and I called the Office of Public 17 Assistance finally and got a warm body. And I was 18 really surprise, because you ordinarily don't get a 19 warm body, you get an answering machine.

20 And they said that I should send them an 21 email with the request for the information and they'd 22 send me a link and give me that information that 23 afternoon.

24 And I thought, "Well, great. Great.

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44 1 Talk about service."

2 And lo and behold the afternoon came and 3 went, of course no email. Of course no email.

4 So I called them back in the morning, and 5 they of course said that they would have to forward 6 that request to a man named Scott Burnell.

7 And said, "Well, how about a" -- "Can I 8 talk to a warm body? Can I really talk to the guy?"

9 They put him on the phone. And so I 10 talked to him, and he said he would talk to the staff 11 of the project and see what he could do, but there 12 was -- he was surprised that it wasn't there, 13 obviously, but there was nothing he could do anyway.

14 So I ended up talking to J.P. Leous. I 15 don't -- I don't know who J.P. is, but he told me 16 that the report was being put through a sensitivity 17 review.

18 Now, I don't know what that means or why 19 the document is two months late and has to go through 20 a sensitivity review, but in 2006, when it was down 21 for refueling, there were ten abnormal releases. Ten 22 abnormal releases.

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45 1 around 500. Some years they have -- historically 2 have been in the thousands of curies.

3 So my question is what are you covering 4 up? What are you covering up? Why aren't you 5 releasing it in a routine manner if it's routine 6 releases?

7 Monticello is already up there, no 8 problem. Prairie Island, sensitivity scrubbing.

9 Sensitivity scrubbing.

10 So that means one of two things to me.

11 Now, speculation, obviously, but if 2006 12 was several orders of magnitude more radioactive 13 effluent releases than normal, I can only hazard to 14 think what your refusal to release that to the public 15 in a timely fashion might mean.

16 I was summarily told that I was not going 17 to get that information. And there was probably some 18 not-so-happy feelings about that, but nonetheless I 19 think I was denied a public document because of where 20 I work and my history of long-term opposition to this 21 facility.

22 Now Andrew, he told me he would get it to 23 me right away. He was very nice. He said he'd send 24 me a CD and he'd send me the entire thing.

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46 1 So Andrew -- you'd better take a page 2 from young Andrew. He knows how to treat the public.

3 Thank you.

4 MR. RAKOVAN: Okay. Next, George 5 Crocker.

6 And again, after George we'll go to Alan 7 Muller.

8 GEORGE CROCKER: Thank you. My name is 9 George Crocker. I'm with the North American Water 10 Office, and I have a comment for the scope of your 11 environmental review relative to considering 12 analyzing, disclosing environmental impacts of 13 continued plant operation.

14 And the comment that I have relates to 15 the story you just heard about routine releases, 16 because I think that the NRC should require Prairie 17 Island and all of the other commercial reactors to 18 document where reported released radionuclides go.

19 Where do they go? I know that you do 20 monitoring. You do a lot of monitoring. If you 21 don't really know what you're looking at when you see 22 all of the little thermal luminescent dosimeter 23 mappings and where the pics are, why you say "Aha, 24 there's monitoring."

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47 1 But, you see, that monitoring tells us 2 where the released radiation isn't. And we don't 3 care about that for the very simple reason that it's 4 not there.

5 We want to know where it is. We want to 6 know the isoplats. Like you look at a map of 7 geography and you can see the terrain, we want to see 8 the dispersion pattern for the routine releases.

9 And we know you can do it.

10 Remember the Russian spy who died of 11 plutonium 210 and they tracked him months later with 12 minute amounts of radionuclides that they tracked all 13 over Europe?

14 Remember how the United States busted 15 North Korea a week later from 50,000 feet because of 16 minute quantities of radioactive material?

17 We know how to track radiation, in 18 exquisite detail. But, you see, we're not applying 19 that ability to the routine releases.

20 So my comment is that any environmental 21 report that does not include the primary routine 22 environmental impactor is bogus.

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48 1 you're not fooling, and sooner or later we're going 2 to get some traction on it.

3 We did pass a bill through the Minnesota 4 House not last year but the year before. We lost it 5 in conference. But it would require Minnesota 6 authority to track the radiation, where does it go, 7 so we can specify the isoplat, the dispersion 8 pattern.

9 Now, I'm not challenging the NRC's or the 10 federal government's preemption right to say whether 11 or not it's safe. That's not the point. You have 12 the authority to determine what's inspect and what's 13 not.

14 But the public has the right to know 15 where it goes. And the reason that's important is 16 because the National Academies of Science in its BEIR 17 VII report -- that stands for the Biological Effects 18 of Ionizing Radiation, which came out in June of 2005 19 -- states clearly and unequivocally that there is no 20 safe dose of radiation, that every exposure to 21 radionuclide increases the risk of deleterious 22 effect.

23 And because of that the public has a 24 right to know where the hot spots are, where the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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49 1 concentration points may be, what is the dispersion 2 pattern, are they living within that pattern.

3 And so, please, let's get serious. If 4 this is going to be a technology that's going to be 5 with us for a while -- I have no illusions that until 6 something heads south real fast, which could happen 7 anytime, that we're going to continue living with 8 this threat, but let's at least inform ourselves 9 about what it is. You do not have the right to 10 conceal from the public where the routine reported 11 emissions go. Thank you very much.

12 MR. RAKOVAN: Thank you, sir.

13 Next we'll go to Alan Muller and then to 14 Carol Overland.

15 ALAN MULLER: I brought these 16 (indicating) up because these are the paper copies of 17 the license renewal, at least that which has been 18 released to the public. It's not particularly light 19 reading, but I have had a chance to review some of 20 it, and it seems to me that what is in here raises a 21 great many more questions than are answered.

22 And in fact it answers a lot of rather --

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50 1 engineering details; but if you look for something 2 like health effects, this application is silent. At 3 least it's silent to me. Perhaps I missed something.

4 But as Ms. Overland commented, it has not 5 been particularly easy to obtain copies of this. It 6 certainly required some agitation on her part to 7 obtain this one, which I borrowed.

8 And I'm wondering -- and I guess this is 9 question -- if the applicant is expected by the NRC 10 to provide copies of the applications to interested 11 citizens, you might want to --

12 Can I -- is it appropriate for me to pose 13 that as a question?

14 MR. RAKOVAN: We're kind of taking 15 comments right now.

16 ALAN MULLER: Okay.

17 MR. RAKOVAN: I mean if you want, we can 18 handle that after the period, but we were -- I think 19 we're just looking for specific comments right now, 20 if you don't mind, sir.

21 ALAN MULLER: Okay. My comment, then, is 22 that the applicant ought to provide copies of the 23 application to anybody who wants one. I suppose it 24 costs a few bucks to reproduce these two books, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 1 there are other prices that will be paid by the 2 residents of the world for the continued operation of 3 this facility.

4 Now, one of the interesting things in 5 this book is that the one operating license expired 6 in 2013 and the other one in 2014. That's not very 7 far from now, and it's difficult not to form the 8 impression that the license renewal is regarded as a 9 done deal, because it's a little bit hard to believe 10 that in fact if there was a serious possibility that 11 that wasn't to be approved, that NSP is actually 12 prepared to carry out the process of shutting the 13 facility down and obtaining substitute sources of 14 power.

15 I have looked at the filed resource plan 16 of Xcel, and there was no mention of the possibility 17 that the facility might not be allowed to continue to 18 operate. In fact, contained in their resource plans 19 are the assumption that the electrical output is 20 going to be increased by some tens of megawatts from 21 each reactor.

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52 1 this paragraph to you:

2 "A licensed amendment request requesting 3 NRC approval for the transition to a new fuel type 4 for use in Prairie Island Units 1 and 2 reactors is 5 expected to be submitted concurrent with the NRC 6 review of the license renewal application. A review 7 of the effect of the transition to a new fuel type on 8 the LRA has been completed with the following 9 results:

10 "Scoping the transition to a new fuel 11 type will have no effect on the application of the 12 system scoping criteria or the results of system 13 scoping," and so on and so forth, which to me says in 14 nuclear regulatory lingo that this is another major 15 aspect relating to the continued operation of this 16 plant that is being handled in isolation from the 17 license renewal, and that's not appropriate.

18 If anyone is going to make an informed 19 judgment about whether this facility ought to 20 continue to operate, that ought to include the future 21 plans for changes there. How do we know that a, 22 quote/unquote, "new fuel type" doesn't pose 23 additional hazards or whatever that we don't know 24 anything about?

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53 1 Very likely that might involve, you know, 2 the use of plutonium in the plant, plutonium mixed 3 with something else, and that has a whole range of 4 implications of its own.

5 So I think as always seems to me to be 6 the case with the NRC, there's sort of a blinders-on 7 proceeding here, which, unless one is very 8 persistent, has more the effect of obscuring what's 9 going on than shedding light on it.

10 Now, just a couple of comments and then 11 I'll shut up.

12 There's mention here of environmental 13 justice as something to be considered within a 14 50-mile radius of the site.

15 Now, in my world, in my concept of this, 16 it seems obvious that if the plant is going to 17 operate for 20 more years, that's going to result in 18 the mining and processing of more uranium; and the 19 doing of that is going to have major health impacts 20 that are far beyond 50 miles.

21 It's going to have impacts in Navajo 22 communities many hundreds of miles away from here. It 23 may have impacts in the state of Virginia, where 24 uranium mining is being proposed. And anybody who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 knows thing anything about uranium mining knows that 2 it's left a trail of sick and dying people behind it.

3 So my suggestion is that the NRC ought to 4 forget about this 50-mile business and look at the 5 actual impacts of the continued operation of these 6 two nuclear reactors.

7 Now, looking a little bit further down 8 the fuel cycle, it's obvious that more nuclear waste 9 is going object generated by 20 more years of 10 operation and that something is going to happen to 11 that.

12 If in fact, as seems unlikely to me, what 13 happens is that it ends up in Nevada at a proposed 14 nuclear waste dump there, that will certainly have an 15 impact on people in that area. And there are many 16 opinions about that that have been expressed by the 17 State of Nevada's Nuclear Projects Office, the 18 congressional delegation from that state and so on.

19 Also, by the western Shoshone, who live in the area 20 and whose concerns have been disregarded by the 21 federal agencies that are trying to permit that 22 nuclear dump.

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55 1 be fully considered in the relicensing proceeding for 2 Prairie Island.

3 Now, maybe that's all that I should take 4 the time to say, but another interesting aspect of 5 this application is the consideration of 6 alternatives, which is something that's required 7 under the National Environmental Policy Act. And the 8 alternatives that are brought forth by NSP or Xcel in 9 the application are burning gas, burning coal, and 10 purchased power.

11 But that does not strike me as an 12 appropriate scope of alternatives to be considered.

13 The investment that would go into the continued 14 operation of this plant could go into demand side 15 management activities such as load response and 16 conservation and efficiency programs; it could go 17 into solar-thermal electricity-generating facilities; 18 it could go into electrical storage facilities to be 19 associated with the growing wind industry in 20 Minnesota.

21 There are lots of alternatives, all of 22 which would make more sense -- or many of which would 23 make more sense than coal and gas and purchased 24 power; and the impression one gets from reading the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1 discussion of alternatives is that the applicant has 2 chosen his alternatives carefully in order to support 3 the conclusion that the plant should continue to 4 operate.

5 But I think the NRC has broader 6 responsibilities to the public and should extend the 7 scope of the review of alternatives far beyond what 8 we've seen in the application.

9 I mentioned earlier that there's little 10 or nothing in here said about health effects; but as 11 Mr. Crocker pointed out, quite rightly, there is a 12 continuous release of radioactivity from this kind of 13 a facility, particularly release of radioactivity 14 into the Mississippi River and also into the air 15 breathed by the community, the host community for the 16 facility.

17 So there ought to be a full evaluation of 18 the cumulative health impacts of an additional 20 19 years of radioactive releases from these two 20 reactors, and it ought to be a real review, not a 21 review carried out by a certain establishment of 22 tamed scientists who believe with religious intensity 23 that radiation is either harmless or perhaps it's 24 even good for you.

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57 1 And I might mention that -- and I might 2 be there, but I'm here -- a study has been carried 3 out in the vicinity of the Salem nuclear complex and 4 other places in the country where baby teeth were 5 collected, the teeth of babies who were born and 6 lived some stage of their lives in the vicinity of 7 the reactor; and people took a look to see if there 8 was more -- were more radioactive elements in those 9 teeth than in the teeth of babies who lived further 10 away, and the answer appears to be yes.

11 I haven't seen the raw data, but this is 12 certainly something that the NRC ought to take a very 13 close look at, because it would not be appropriate to 14 relicense a facility if doing that was going to have 15 major negative health impacts.

16 Okay. That's what I have to say. Thank 17 you.

18 MR. RAKOVAN: I think she's following me 19 up here, but Carol Overland.

20 CAROL OVERLAND: That's correct.

21 Well, I'm Carol Overland, and I don't 22 have all that much to say other than it is correct 23 that it was really hard to get a copy of this 24 application, and I do want to make sure for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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58 1 record that everyone who requests an application 2 should get an application.

3 There aren't that many of us odd people 4 that like to read this stuff, and if we really want 5 to put the time in, give us the application. It will 6 make your lives a lot easier.

7 And actually, you know, Alan Muller 8 addressed many of the things I wanted to raise, but 9 as far as replacement power goes, there was this 10 great study a while back -- Kirsten Eide Tollefson 11 will remember it -- of the Prairie Island replacement 12 power using a wind/gas combo.

13 Was that wind/gas? It was. Right?

14 Anyway -- right.

15 KIRSTEN EIDE TOLLEFSON: It was a 16 conversion, a gas conversion.

17 CAROL OVERLAND: Right.

18 KIRSTEN EIDE TOLLEFSON: It was an 19 integrated resource plant.

20 CAROL OVERLAND: So it was strictly gas?

21 MR. RAKOVAN: Miss, if you're going to 22 talk, I'm going to have to get you on the transcript.

23 I'm sorry.

24 CAROL OVERLAND: Oh. Well, I'm just --

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59 1 I'm trying to make sure -- I referred to -- I thought 2 it was a wind/gas combo, but maybe I'm not right.

3 Maybe it was just gas conversion. But we'll get a 4 copy of that into the record, so that will show one 5 more alternative that is possible.

6 And speaking of wind/gas conversions, I 7 also want to bring up that that is a very real 8 possibility, and the state of Delaware has just 9 ordered an off-shore wind project, and that's to have 10 gas back-up to make it for power. If Delaware can do 11 it, Minnesota can do it. You know, there are things 12 that we can do that are alternatives to this.

13 And I'll submit further comments by the 14 deadline.

15 And as far as notice goes, you know, this 16 obviously is a problem. Many of us did not get 17 notice who have been participating in nuclear issues 18 for a long time.

19 And because of that, the comment period 20 should be extended at least as long as the defective 21 -- the notice was defective. So if notice didn't go 22 out until the 25th and should have gone out when, 23 extend it the other way. That only fair.

24 Thank you.

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60 1 MR. RAKOVAN: That was the last card that 2 I had for comments. If someone else has a comment 3 that they'd like to make, if you could just come on 4 up to the mike, and if you could please introduce 5 yourself.

6 KIRSTEN EIDE TOLLEFSON: I am Kirsten 7 Eide Tollefson, and I live in Florence Township, just 8 down the road a little bit.

9 I've been reading nuclear documents for 10 about 12 years and have not, I have to admit, made my 11 way all the way through this one; but I do have a 12 pretty fundamental concern that I would appreciate 13 being addressed by the environmental review.

14 Under NEPA and environmental review in 15 general, the consideration of connected actions and 16 cumulative effects are very important elements to be 17 reviewed, and there are a number of processes 18 concurrently happening.

19 There is the application for the 20 relicensing; there is the fuel change that was 21 mentioned; and then there's a fuel upgrade 22 application, and there's also an extended storage 23 application. And all of these are being 24 simultaneously considered by NRC and by the Minnesota NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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61 1 Public Utilities Commission.

2 I'm extremely concerned about the timing 3 of the fuel uprate application. It seems to me that 4 if the plant is going to be run longer and hotter and 5 to a greater capacity, that's going to affect -- and 6 with a different fuel type, that's going to affect 7 both the operations and the pool storage; it's going 8 to affect the safety of the pool; it's of course 9 going to affect the particulars on the long-term 10 storage of the waste at the reactor site, and I'm 11 very, very concerned that that fuel uprate be part of 12 the review of the safety analysis.

13 And it seems very inappropriate for there 14 to be significant factors like heat that are not 15 included in the safety review of an aging reactor.

16 I'm just very, very concerned about that and, again, 17 how that also may affect the pool safety.

18 I'm -- the pool is in the plant, so I'm 19 hoping we consider that part of operations. But I 20 realize we might have cordoned it off into storage 21 areas -- into storage.

22 I also have a question that I wish I had 23 asked earlier. It's a concern about what seems to me 24 to be a changed circumstance in the storage of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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62 1 nuclear wastes at the reactor site.

2 If someone would like to explain this to 3 me later, that would be great, but it seems to me 4 that the difference in waste -- in the confidence 5 decision that waste is safe at a reactor site for 30 6 years after the closure of the plant, which would, of 7 course, put it out into the '70s somewhere -- or -- I 8 have -- I'm not going to add that right now -- there 9 is -- the difference that it makes is that there's 10 not a federal plan that I'm aware of for the waste 11 for the relicensed reactors, and so that confidence 12 has -- doesn't to me have the same bases as the 13 confidence that the waste that has already been 14 generated which is the in queue will have a place to 15 go.

16 So none of the waste for the relicensed 17 reactors has a queue that's in to go anywhere, and I 18 think that's a significant changed circumstance that 19 should be considered in this proceeding.

20 I read the background documents for the 21 EIS for Yucca Mountain for the no-action alternative.

22 And these are the engineering studies upon which they 23 base the recommendation for the no-action 24 alternative.

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63 1 The no-action alternative recommended 2 that any site where the waste -- the no-action 3 alternative assumed that waste would not be removed 4 from the site but that it would be there for -- it 5 may have been 10,000 years. I think that was the 6 basis. I didn't bring it.

7 But the three factors that were 8 considered in that review that made -- that were the 9 factors for the breakdown of the storage containment 10 which the EIS recommended be replaced fully every 50 11 years, there were three factors in the engineering 12 studies: Precipitation, freeze/thaw cycle, and 13 proximity to populations.

14 And I believe that in Minnesota the 15 precipitation, the freeze/thaw cycle, and the 16 proximity to populations are an extremely critical 17 factor.

18 And so if we have waste that has nowhere 19 to go, isn't in a queue, and doesn't have a federal 20 plan for its removal, I would submit that this is a 21 serious cumulative issue and would like to understand 22 more how that's going to be handled.

23 Thank you.

24 MR. RAKOVAN: Any other comments tonight?

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64 1 Brian?

2 BRIAN HOLIAN: That's why I'm coming up 3 here.

4 MR. RAKOVAN: Introduce yourself.

5 BRIAN HOLIAN: That's one of the reasons 6 -- if there were no other public comments, I just 7 wanted to get up and introduce myself.

8 I'm Brian Holian, the Director of License 9 Renewal back at headquarters, and I just appreciate 10 being at this meeting tonight.

11 And I did have a couple of comments on a 12 few of the comments here, just to clarify.

13 I'm also the one -- wanted to come up and 14 give my name since I was the one who stated 15 "operating experience" over there when Rani was 16 talking, so I wanted to make sure that was me that 17 added that comment.

18 Just a few comments. I thought it was a 19 very good meeting, and NRC staff will be around for 20 other comments or questions, should you have them, 21 but I think the purpose of the meeting was well fed, 22 some of the comments on especially the environmental 23 aspects, which is the reason we're tonight. So I 24 think that worked well.

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65 1 But a few comments, just on general 2 issues. Rani is going to close out the meeting, Rani 3 Franovich, and she will probably pick up on a few of 4 these items; but in case she didn't, I just wanted to 5 comment on them.

6 One on the plant service list, I took 7 that comment to make sure that license renewal folks 8 at headquarters make sure we have the Prairie Island 9 plant service list. So if you're on that list, I 10 would expect that you would get notice, so we will 11 take that and verify that. And I think Rani 12 mentioned that.

13 Secondly, on the issue of the report that 14 is late from Prairie Island, I just didn't want other 15 audience members that are here to go away with the 16 perception that the NRC might be doing the 17 sensitivity review of a document before releasing it.

18 You know, hopefully you can follow up 19 with the resident inspector afterwards also, but I 20 believe that's probably the plant still doing a peer 21 review of a public document.

22 And I'll let you address that in a 23 minute.

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66 1 (indicating).

2 But I just wanted to bring that up, 3 because the NRC, when we get a document like that, 4 would make that publicly available. So, you know, if 5 you -- that's a right thing to question, whether the 6 NRC is altering data or something, so I'm glad that 7 was brought up.

8 But the NRC does not do that. When we 9 get those, those go on our public website, those 10 annual reports from the utility. So I wanted to 11 clarify that.

12 The third thing I wanted to mention was 13 when I mentioned operating experience earlier when 14 Rani mentioned that, I think one of the comments was, 15 you know, "Do you look at how well the plant has been 16 operating?"

17 And Rani did mention that, well, the 18 license renewal scope, you know, has been criticized 19 for being narrow, as some people have said; but in a 20 part of that review is looking at operating 21 experience. We talk about how well the plant learns 22 from, you know, their own issues that happen at the 23 plant -- pipe thinning, containment codings, do they 24 have a history of issues there. We call it operating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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67 1 experience: In the 20 to 30 years that they've 2 operated, what does that tell us about how well they 3 feed that information back in to their plant systems 4 and plant processes.

5 So we do look at that in license renewal, 6 how well they learn from that.

7 And I will mention one other resource for 8 us -- for you, really -- and that's our Office of the 9 Inspector General. I, you know, have a copy here of 10 their report that they did on license renewal just 11 back in 2007, and as a matter of fact they picked at 12 the NRC a little bit for not doing as well on our 13 operating experience reviews when we do license 14 renewal. So that was an item that was in the 15 Inspector General, who is an independent organization 16 that looks over our shoulder. So I just wanted to 17 make you aware of that, that that organization is out 18 there.

19 And of course if you ever had questions 20 about whether we're holding reports back or doing 21 something like that, that's another resource for you 22 to call and say, "Hey," you know, "I might have this 23 wrong, but could you check on this for me?"

24 So that's another public advocacy that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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68 1 you have as an outlet to check on us and our reviews, 2 and we value that.

3 And, you know, that's all I had. I just 4 wanted to mention those things. I know Rani's going 5 to close it out, so I will go back and --

6 The one individual who was going to add 7 to the plant report, I think you can talk to the 8 individual later and verify that.

9 Lance, should I turn it over to Rani?

10 Thank you.

11 MS. FRANOVICH: Thanks, Brian.

12 And thanks, Lance, for facilitating this 13 meeting.

14 And thank you all for coming. I think 15 we've heard some really good comments, and we've all 16 taken notes and it's being transcribed. We've had a 17 lot of really good discussion of alternatives and 18 impacts of radioactive waste on human health, and so 19 I just wanted to say thank you for providing those 20 comments to us.

21 And this is an important part of our 22 environmental review process. This is an opportunity 23 for us to come out and hear from folks in the 24 community, and so we appreciate just the time and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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69 1 effort that you spent coming to our meeting tonight.

2 Brian touched on a few of the items that 3 I was going to, you know, just kind of respond to 4 real briefly.

5 I'm not sure if the discussion about the 6 sensitivity review was on the license renewal 7 application or some other document. I kind of got 8 the impression that it was on the license renewal 9 application, but I could be wrong.

10 I'm seeing these heads turning, so it 11 must have been a different document.

12 So we'll let the plant person, Mike in 13 the back, respond to the peer review aspects of that.

14 The health effects in the license renewal 15 application, we heard a concern that that wasn't 16 addressed in the environmental report; and I think 17 that the topic in the environmental report, at least 18 that we found in a quick review, has to do with 19 radioactive waste treatment systems and talks about 20 whether or not they meet requirements that govern the 21 release of radioactive waste into effluent streams.

22 And so what the NRC does with that is we 23 look at that to evaluate impacts to human health in 24 our environmental impact statement. So you may see NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 in the environmental report discussions in sections 2 that don't translate one for one to what will be in 3 our environmental impact statement, so I just wanted 4 to mention that real quickly.

5 Also, I've heard a lot of concerns about 6 the application itself not being available in a 7 timely manner. And I'm not familiar with people 8 making requests for copies, but I do know that if 9 they contacted Justin Leous, that he -- hopefully he 10 shared with folks that it's available on the website, 11 it has been since May.

12 And so even though hard copies may not 13 have been provided, because we get a limited number 14 ourselves, then there is a website that you can go to 15 to review the application; and if you will request to 16 send one, we certainly could send one on disk to save 17 paper and save more trees.

18 So I just wanted to get that out there.

19 If there's anyone who would like a copy of the disk, 20 we have one at this meeting tonight; we can certainly 21 provide one.

22 And let's see.

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71 1 in the same timeframe we had hoped. We were looking 2 to start it around June 30th; it didn't actually 3 start until I believe it was July 22nd. And so we 4 have extended the scoping period to give the public a 5 full 60 days, so I think we've already accommodated 6 that request.

7 And so with that, I just wanted to remind 8 everyone Lance had indicated that there are public 9 meeting feedback forms that were provided when the 10 meeting first started, so if there are ways we can 11 improve our meetings, make them better, do them 12 differently, please do fill out one of these feedback 13 forms and leave it on the table, or you can mail it 14 to us. The postage is pre-paid. And I know a couple 15 of you have questions; what I'd like to do is go on 16 and close the meeting and then get with you to talk 17 about your questions.

18 LEA FOUSHEE: I want this on the record.

19 MR. RAKOVAN: She wants something on the 20 record.

21 LEA FOUSHEE: The document is Routine 22 Radioactive Effluent Releases.

23 MS. FRANOVICH: Okay.

24 LEA FOUSHEE: That document -- the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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72 1 results of that document, the radiation that is 2 contained in that document is nowhere in the 3 application to demonstrate that there is anything 4 relating with radiation and health impact.

5 MS. FRANOVICH: I understand. Okay.

6 LEA FOUSHEE: It needs to be in there, 7 the routine radiation releases from Prairie Island 1 8 and 2 must be in the environmental impact statement, 9 and they are not.

10 And in fact there should be a historical 11 record, because the radiation doesn't just go away in 12 a year.

13 MS. FRANOVICH: I'm thinking that the 14 plants are required to submit effluent reports 15 annually to the NRC, so --

16 LEA FOUSHEE: Yes, but the application 17 should have a summary of at least the last 10 years, 18 and certainly the last 20, if possible.

19 MS. FRANOVICH: Point noted. But just so 20 you're -- I just want to --

21 LEA FOUSHEE: But it's not there.

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73 1 point. We look at a lot more than what's in the 2 environmental report, including those annual reports.

3 And so rest assured the NRC staff will be 4 reviewing those data. It will be considered in part 5 of our analysis.

6 But thank you for your comment and your 7 concern.

8 LEA FOUSHEE: Thank you.

9 MR. RAKOVAN: Okay. One more question on 10 the record, and then we'll close the meeting.

11 And we'll be around. We wanted to talk 12 with a couple folks to follow up on some concerns 13 that were expressed earlier.

14 ALAN MULLER: With regard to that, if 15 people want to have substantive discussions, it's 16 important that they have them on the record; because 17 if they have them informally, they may carry less 18 weight in the process.

19 And so I would urge you to continue the 20 meeting and let people, you know, ask their questions 21 on the record.

22 But my question is simply when will the 23 transcript of this meeting be available? Will it be 24 posted anytime soon?

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74 1 MS. FRANOVICH: Okay. I think it takes 2 us a couple of weeks to get the transcript, and then 3 we have to go through and make sure that it 4 accurately reflects the things that we said, so that 5 process could take another couple of weeks.

6 I would hope that in the next five or six 7 weeks we could have it available.

8 ALAN MULLER: Well, if the opportunity to 9 seek a public hearing closes on August 13th and the 10 transcript won't be available until after that, that 11 creates a problem for someone wanting to request a 12 hearing.

13 So my recommendation would be that you 14 extend the opportunity to ask for a public hearing at 15 least a couple of weeks after the transcript is 16 available.

17 MS. FRANOVICH: Well, let me talk about 18 that for a minute, because I think a few people have 19 talked about the opportunity for hearing and the 20 opportunity to provide scoping comments, and they're 21 really two different things.

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75 1 Act. So when we're soliciting comments on the scope 2 of our review, which is what this meeting is about, 3 what we're looking for is what should our 4 environmental review consider.

5 Now, the opportunity to request a hearing 6 and submit contentions is independent of that 7 process. So I think what needs to be available to 8 the public for the public to determine if they have 9 any concerns they want to submit as part of a request 10 for hearing would be in the application itself, not 11 in our scoping documents.

12 Beth, did you want to add anything to 13 that? If you do, you need to come up to the 14 microphone so it will be on the transcript.

15 (Negative response.)

16 Okay.

17 Okay. Thanks again, everyone, for 18 coming.

19 And Lance, we're just going to go on and 20 close the meeting, but I know there that there are 21 some folks who still want to talk.

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76 1 concerns further.

2 Thank you.

3 (Whereupon, at 8:30 p.m. the proceedings 4 were adjourned.)

5 6

7 8

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77 1 (The following text was submitted prior to 2 the meeting:

3 "Permanency or Term of Storage.

4 "Good evening. I am Joan K. Marshman of 5 Frontenac Station, Minnesota. I am the 6 chair of the Florence Township Board of 7 Supervisors and have had ongoing concerns 8 pertaining to the permanency issues with 9 the cask storage at the Prairie Island 10 Nuclear Plant.

11 "As I stated in testimony before the 12 Minnesota Environmental Quality Board on 13 January 18, 1996, 'The permanency issue is 14 a major concern for many residents of 15 Florence Township, as it should be for the 16 rest of the State of Minnesota.' This has 17 been my concern for the past 12 years.

18 "High-level radioactive waste storage 19 must 20 be sited away from growing centers of 21 population, major highways, and waterways.

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78 1 repository is by far preferable to on-site 2 storage at reactor reactor sites throughout 3 the United States.

4 "The question of permanency is still 5 unresolved. To date, the Yucca Mountain 6 repository is ten years past due in 7 accepting the first shipment of irradiated 8 fuel. The Department of Energy (DOE) had a 9 responsibility to remove spent fuel from 10 reactors beginning in 1998. Now the DOE 11 must take immediate action to ensure that 12 the necessary infrastructure is in place to 13 accept the spent fuel that is now in 14 storage on-site at all the nuclear plants 15 across the country.

16 "Thank you for considering my concerns.

17 "Joan K. Marshman, resident of Frontenac 18 Station, Goodhue County, Minnesota; Chair, 19 Florence Township Board of Supervisors.")

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