ML102520183
| ML102520183 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/19/2010 |
| From: | Division of License Renewal |
| To: | |
| jeremy susco | |
| References | |
| NRC-390 | |
| Download: ML102520183 (90) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Seabrook Station License Renewal Public Meeting Docket Number:
(n/a)
Location:
Hampton, New Hampshire Date:
Thursday, August 19, 2010 Work Order No.:
NRC-390 Pages 1-88 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 PUBLIC MEETING 4
LICENSE RENEWAL AND ENVIRONMENTAL SCOPING PROCESS, 5
SEABROOK STATION LICENSE RENEWAL APPLICATION 6
+ + + + +
7 Thursday, August 19, 2010 8
+ + + + +
9 Galley Hatch Conference Center 10 Palladium Room 11 815 Lafayette Road 12 Hampton, New Hampshire 03842 13 1:09 p.m.
14 PARTICIPANTS:
15 Elva Bowden-Berry, Esq., NRC 16 Lance Rakovan, NRC Communications Specialist 17 Jeremy Susco, NRC Division of License Renewal 18 Richard Plasse, NRC Division of License Renewal 19 Michael Dreher, Esq., NRC 20 Bo Pham, Branch Chief, NRC Division of License Renewal 21 Jon Johnson, NRC Seabrook Resident Inspector 22 Leslie Perkins, NRC Division of License Renewal 23 Scott Burnell, NRC Office of Public Affairs 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 2
SPEAKERS:
1 Paul Blanch 2
Kathy Wolf 4
Diane Teague 5
Representative Robin Read 6
Dr. Robert McDowell 7
Paul Gunter 8
Doug Bogen 9
Joe Casey 10 Janet Guen 11 Tim Noonis 12 Bob Backus 13 Michael Schidlovsky 14 Dennis Wagner 15 Kevin Fleming 16 17 18 19 20 21 22 23 24 25 26
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 1
1:09 p.m.
2 MS.
BOWDEN-BERRY:
Good afternoon 3
everyone. My name is Elva Bowden-Berry. Good 4
afternoon. My name is Elva Bowden-Berry, and I'm an 5
attorney at the
- NRC, the Nuclear Regulatory 6
Commission. You'll hear -- be called NRC today, and 7
I'm co-facilitating today with Lance Rakovan, over 8
here to my right.
9 We're going to do our best today to help 10 make this meeting worthwhile for everyone, and we hope 11 that you'll help us out to make this a good meeting.
12 The purpose of today's meeting is to 13 discuss the license renewal and environmental scoping 14 process for review of the license renewal application 15 for the renewal of the operating license for Seabrook 16 Station, and to provide members of the public with an 17 opportunity to provide comments regarding 18 environmental issues that the NRC should consider 19 during its review.
20 I'd like to stress that this is an NRC 21 public meeting. The mission of the NRC is to regulate 22 the nation's civilian use of byproducts source and 23 special nuclear materials to ensure the adequate 24 protection of public health and safety, and to promote 25
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the common defense and security, and to protect the 1
environment.
2 Now a term you're going to hear a lot 3
today is about the scoping. Scoping means determining 4
the scope of the environmental review, in this case 5
for the Seabrook Station. Today's meeting is just one 6
way that you can participate in the process, and 7
you'll be hearing later on about the ways that you 8
will be able to participate.
9 The meeting today will essentially have 10 two parts. First, we'll hear some presentations from 11 the NRC staff of the License Renewal Division and 12 about the environmental review process, information we 13 think is important for you to understand when it comes 14 to the Seabrook license renewal process.
15 There are copies of the presentation on 16 the registration table outside, but in case you need a 17 copy, then I can run some copies around. We're going 18 to try to keep these presentations short and so we can 19 get to the real reason we're here today, and that's to 20 get your comments and to listen to what you have to 21 say.
22 There were yellow cards and blue cards 23 that we asked you all to fill out, and the yellow 24 cards were for those of you who knew you wanted to 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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speak today, and I collected the cards. So when it's 1
time for people to speak, I can call you up or pass 2
you the mic.
3 If you decide later that you want to 4
speak, I have a couple of yellow cards and I can pass 5
them to you. Otherwise, you can fill out the blue 6
card to, you know, sign up to be on our mailing list.
7 I also want to inform you that we're 8
transcribing this meeting. So that means it's 9
important for everyone to speak clearly, and when you 10 get up to speak and state, you know, your name and 11 where you're from, what agency you're representing, 12 and so that we get a clean transcript, we want to keep 13 sidebar conversations to a minimum.
14 And we want everyone to remember to turn 15 your phones or other electronic devices, turn them off 16 or either put them on vibrate, so that it doesn't 17 interfere with our transcription.
There's the 18 restrooms are out the doors and to your right, and 19 there's emergency exits. These doors here and out the 20 front where you came in, there are emergency exits.
21 We're going to do our best to address any 22 questions you have today about license renewal, and 23 other NRC regulatory topics you want to discuss.
24 However, please remember that we only have a few of 25
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our NRC staff here today, and if can't get you a good 1
answer on something here, we'll do our best to get 2
back to you at a later time.
3 One other item I'm hoping that you picked 4
up when you came in is our public feedback form. You 5
can fill that out here today and give it to any NRC 6
staff member, or you can drop it in the mailbox and 7
the postage is free.
8 Okay. Let's go ahead and get started.
9 I'd like to introduce you to some of the NRC staff in 10 attendance today. Bo Pham is our branch chief in the 11 Division of License Renewal. He's actually at the 12
- slides, and Jeremy Susco will be one of our 13 presenters. He's the environmental project manager in 14 the Division of License Renewal.
15 Rick Plasse, he's the safety project 16 manager with the Division of License Renewal. Leslie 17 Perkins is out at the sign-up table. She's a project 18 manager in License Renewal. Jon Johnson over to my 19 left is the plant resident inspector. Mike Dreher is 20 one of the attorneys in the Office of General Counsel, 21 and Scott Burnell is our -- with our Office of Public 22 Affairs.
23 With that, I'll hand it over to Rick and 24 Jeremy, and we'll be back when we move to the second 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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part of the meeting.
1 MR. PLASSE: Okay, thank you Elva.
2 Welcome everyone. I'm Rick Plasse. I'm the safety 3
project manager, and as Elva said, the meeting's going 4
to be over the Seabrook license renewal process and 5
scoping overview. Jeremy will do a presentation on 6
the environmental
- aspects, and I
will do a
7 presentation on the safety side. Can we go to the 8
next slide?
9 Again, the meeting purpose is to provide 10 an overview of license renewal and review process, the 11 safety and environmental reviews, and then at the end, 12 as Elva said, we'll collect your input on the scope of 13 the environmental review. Next slide.
14 The NRC accomplishes its mission through a 15 combination of regulatory programs and processes. We 16 conduct inspections, issue enforcement actions, assess 17 licensee's performance and evaluate operating 18 experience in nuclear plants across the country.
19 As you mentioned Jon, I wanted to just 20 point out that one important element of our inspection 21 program is the resident inspector.
22 PARTICIPANT: Excuse me, do you have your 23 mic on?
24 MR. PLASSE: The mic's not on. Okay, I'm 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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sorry. Okay. The resident inspectors, we have them 1
at all of the nuclear plants. Their job is to carry 2
out our safety mission on a daily basis by ensuring 3
that the plants have acceptable safety performance and 4
are in compliance with the regulatory requirements.
5 They're considered the eyes and ears of 6
the NRC, and Jon lives up here in the Seabrook area 7
and is the resident at Seabrook. With respect to our 8
mission, it's three-pronged: to protect health and 9
safety, promote common defense and security and to 10 protect the environment. Next slide please.
11 The current license for Seabrook expires 12 in 2030. That's the 40 years of operation. The 13 application was received at NRC on June 1st, and if 14 renewed, the license would expire in 2050. So the 15 period of extended operation requested is between 2030 16 and 2050. Next slide.
17 PARTICIPANT: Could you speak into the 18 mic?
19 MR. PLASSE: Next slide, okay. One of the 20 questions that's come up several times in the recent 21 couple of months is why can Seabrook apply for renewal 22 with 20 years remaining on its current license?
23 Well, if you go to the Statements of 24 Consideration for the rule, it's Part 54.17 Charlie, 25
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the NRC determined that 20 years of operational 1
regulatory experience provides an applicant with 2
substantial amounts of information and would disclose 3
any plant-specific concerns with regard to age-related 4
degradation.
5 And also from the other aspect, 20 years 6
remaining on the operating license would be 7
reasonable, considering the estimated time for 8
utilities to plan for replacement of retired plants, 9
if they decide to retire the plant. There have 10 actually been several plants that have actually 11 applied prior to 20 years. That requires an actual 12 exemption to the NRC.
13 I'll give some examples. Milestone II 14 applied at 18 years. Nine Mile Point Unit II was at 15 approximately 17 years. A couple of plants that are 16 up in the Northeast. Next slide please.
17 Here, we're going to go over a little bit 18 of the license renewal process. As I said earlier, 19 the license renewal application was submitted to the 20 NRC June 1st, and then we have basically two parallel 21 paths.
22 We have the safety review and the 23 environmental
- review, and both areas we have 24 independent reviews by ACRS, and then consultation and 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 10 comment, based on what comes up in the scoping and the 1
environmental -- draft environmental impact statement, 2
and then a final environmental impact statement. On 3
the safety side, we'll have a safety evaluation 4
report.
5 We'll be -- the initial one will go to the 6
ACRS for review, and then after the ACRS meeting, 7
we'll have a final SER that will be issued, based on 8
any other issues that may come at the ACRS besides the 9
ones that, you know, may come through our inspection 10 review and audit process.
11 Then the final SER will be issued and then 12 a final ACRS meeting will be conducted, and then the 13 ACRS will weigh in on their review. All that will 14 come together for final NRC decision. Go to the next 15 slide.
16 A typical target, and this is just a 17 target, is 22 months for a typical review. If 18 hearings are granted, that will add time, typically 19 maybe around 30 months but it can be longer. We've 20 had some that have gone longer.
21 The schedule now, it's on our website, 22 nrc.gov under the License Renewal website page. In 23 fact, the documents are also on that page. But the 24 schedule shows our review being completed in April of 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 11 2012, and that's if there is no hearing. If there is 1
a hearing, it will be at some time thereafter.
2 MS. BOWDEN-BERRY: Would you just tell 3
everybody what the ACRS is?
4 MR. PLASSE: Yes. The ACRS is Advisory 5
Committee of Reactor Safeguards. They're independent.
6 They work for the Commission, and the ACRS does an 7
independent review to the whole process that the staff 8
review is. Typically, they're senior people who have 9
been either in industry or academia, scientists, and 10 they have a broad, diverse background.
11 They do their own review, look at the 12 document that we put together, and then they will 13 probe whatever areas that they feel at the time is 14 appropriate, and the staff and also the applicant will 15 be at the meeting to answer the questions as 16 appropriate. If they ask the applicant, they'll 17 respond. If it's more appropriate to the review that 18 the NRC conducted, we'll respond. Okay.
19 Application content.
It's general 20 information about the plant owner and the operator of 21 the facility. The application is broken down into 22 various sections for technical information about the 23 plant and how the applicant proposes to manage the 24 aging.
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 12 Chapter 2 typically will be scoping, what 1
is the equipment that's scoped into aging management.
2 You know, basically it's the passive components of 3
the plant. The active components, the pumps and the 4
valves, they test them in accordance with their tech 5
specs all the time. So they're constantly monitoring 6
the active components.
7 Also, any changes to the plant operating 8
limits related to aging management. The environmental 9
report will evaluate the effects of extending the 10 license by 20 years. So that big picture, that's kind 11 of what the application contents are. Next slide.
12 We're going to talk a little bit about the 13 safety review. It's in accordance with 10 C.F.R. Part 14 54, and we focused on how aging affects the structures 15 important to plant safety.
The staff review 16 determines that the aging effects will be effectively 17 managed. We review the application and supporting 18 documents. We do an on site audit.
19 We actually will do basically two audits.
20 One's a one-week audit and one's a two-week audit.
21 The first audit is in September, and that's what we 22 call scoping and screening, and in that audit, we look 23 at the drawings, the systems and ensure that all the 24 equipment that needs to be scoped in in accordance 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 13 with the rule is scoped in.
1 We also look at that time at operating 2
experience. Any of the equipment in scope, if they've 3
had any operating experience with respect to failures, 4
anything that may be aging-related, look at the 5
corrective action system to see what is the root cause 6
of the various equipment that they've had some 7
operating experience that, you know, they had to do 8
some repairs or is it related to the environment that 9
the equipment operates in, that type of thing.
10 We also do what we call an aging 11 management program review, an AMP audit, and that will 12 be in October, the second and third week of October, 13 where we bring in NRC tech staff, consultants, some 14 experts in various areas, and we'll do a complete 15 review of all the various aging management programs.
16 All that kind of feeds into the safety 17 evaluation report. A lot of the -- the SER is also 18 reviewed in office. We look at their documents.
19 Where we may need some clarification, we'll ask for 20 requests for additional information, for more details, 21 so that we can come to our conclusions of reasonable 22 assurance.
23 And as Elva brought up, the independent 24 review by the ACRS will be on that, those documents 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 14 when they're completed. Next slide.
1 All
- right, License Renewal Safety 2
Principles. The two guiding principles from the basis 3
of the NRC's approach in performing its safety review.
4 The first principle is that the current regulatory 5
process is adequate to ensure that the licensing basis 6
of operating plants provides and maintains an 7
acceptable level of safety.
8 The second principle is that the current 9
plant licensing basis must be maintained during the 10 renewal term, in the same manner and to the same 11 extent as during the original license term and, you 12 know, the ongoing reviews that we do. As I said 13 earlier, Jon, as the resident, is our eyes and ears in 14 the
- field, in ensuring
- that, you
- know, these 15 principles, you know, are in place.
16 To ensure that the plant's current 17 licensing basis is maintained during the extended 18 period of operation, the effects of aging must be 19 understood and addressed. So that the staff conducts 20 a detailed review of the new and existing programs and 21 surveillance activities to determine, with reasonable 22 assurance, that the effects of aging for certain plant 23 structures, systems and components will be adequately 24 managed or monitored. So that's how we couple it 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 15 together with the two principles that we just 1
discussed. Next slide please.
2 Now before I turn it over to Jeremy, just 3
to discuss a couple of examples here, I'd like to 4
mention a few areas that are important that the NRC 5
has oversight, and are separate to the license renewal 6
process. These include NRC planning, security and 7
current safety performance.
8 The NRC monitors and provides regulatory 9
oversight of activities in these areas on an ongoing 10 basis under the current operating license. Therefore, 11 we do not reevaluate them in license renewal space, 12 because they are subject to ongoing NRC inspections 13 and oversight the activities that Jon is responsible 14 for, and also various inspectors come up and do a lot 15 of our routine inspections as part of the reactor 16 oversight program.
17 Any issues identified in these areas, 18 they're addressed immediately under the current 19 operating license. For more information on the 20 reactor oversight process for operating reactors, 21 again you can go to nrc.gov and you can search reactor 22 oversight program, and you can see the details of that 23 program there.
24 With that, that concludes my remarks of 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 16 the big picture from the safety side, and I'd like to 1
introduce Jeremy. Oh, I thought -- I'm sorry. Okay.
2 Yeah, all right. Hearing requests. The deadline is 3
September 20th. That's a 60-day comment period if 4
anyone has any issues that they want to put in, that's 5
the deadline.
6 I kind of mentioned the two ACRS meetings.
7 They're scheduled right now for September of 2011 and 8
February of 2012. So we'll get the SER out a couple 9
of months before the September meeting, and then at 10 least a month if not more before the February meeting.
11 With that, that concludes my presentation and I'll 12 turn it over to Jeremy.
13 MR. SUSCO: Thanks Rick. As Rick said, my 14 name is Jeremy Susco. I'm the environmental project 15 manager. Rick's doing the safety side and I'm doing 16 the environmental side of the licensing application.
17 So the environmental review. As Rick said earlier, we 18 have a safety part. That's in Part 54 of our 19 regulations. Part 51 is our environmental review.
20 I want to stress that public input drives 21 the environmental considerations that we look at, and 22 that's why we're here today, is to hear your comments 23 on what we should look at and what we shouldn't look 24 at as part of our review. What all that goes into is 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 17 we're working on an environmental impact statement, 1
and this environmental impact statement is going to 2
disclose the impacts of the plant operating for 3
another 20 years beyond its initial 40 year license.
4 And what we're going to try to decide by 5
doing this is does it make sense environmentally to 6
allow Seabrook to operate for 20 more years. Are the 7
environmental impacts so great that it would deny the 8
option of energy planning decision-makers to renew 9
that license. Next slide please.
10 So the purpose. The purpose is to 11 rigorously investigate the license renewal option, as 12 well as any reasonable alternatives for the area. The 13 decision-makers at the NRC and on the state level, 14 they use this impact statement. We use this to inform 15 them and to publicly disclose any impacts of license 16 renewal in the alternatives. Next slide please.
17 I promise you this looked much better on 18 my computer screen on my desk. But some of the things 19 that go into an environmental impact statement is 20 we're going to look at the impacts on fish and 21 wildlife, historical and cultural resources. We're 22 going to look at the socioeconomic impact, human 23 health and land use.
24 We're not going to do it just by 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 18 ourselves. We're going to coordinate with other local 1
and state agencies. For example here, we've already 2
been in touch with the Massachusetts Division of Fish 3
and Wildlife and New Hampshire Natural Heritage Bureau 4
and the New Hampshire Department of Environmental 5
Protection. Next slide please.
6 Again, I promise this looked much better 7
on my computer screen. But this is the process for 8
the environmental impact statement, and this first 9
slide -- so the first one is issue the Notice of 10 Intent, and we did that back in July. There was 11 actually a copy of it back on the table. That's our 12 Notice of Intent, letting everybody know that we're 13 going to be creating this environmental impact 14 statement for the license renewal application.
15 This next block says "Public 16 Scoping/Meeting." This is where we solicit public 17 comments, and that's why we're here today. So that's 18 where we are now. We're going to use those comments 19 and all the coordination we do with other agencies, 20 and we're going to prepare a draft environmental 21 impact statement.
22 We're going to publish it -- next block 23 over here. We're going to publicly issue the draft 24 environmental impact statement, and we're going to 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 19 have another public meeting like this, where we're 1
going to come and we're going to request your comments 2
on the environmental impact statement.
3 We will address those public comments. As 4
well we will address the comments in the report that 5
we receive today. We'll use those. We'll prepare the 6
final environmental impact statement, and then we'll 7
publicly issue the final statement. That will be one 8
of the things that the NRC looks at when making its 9
overall license renewal determination.
10 So it says yellow blocks represent key 11 public steps. That's blue in this case. Next slide 12 please.
13 So why are we here today? As Elva and 14 Rick mentioned, this isn't really a Q and A of sorts.
15 This is a chance for you to have the microphone and 16 to tell the NRC what issues, environmental issues that 17 you think that we should look at through the course of 18 our review.
19 Why do we need that input? We need that 20 to better focus what we're going to look at, what we 21 definitely should and what we shouldn't look at as 22 part of our environmental review. Next slide please 23 Bo?
24 So the type of input that we're looking 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 20 for. What makes your community unique? What are the 1
local issues that we should be investigating?
2 Socioeconomic impacts, you know. What should we be 3
looking at? And are there reasonable alternatives 4
that are appropriate for the Seabrook area? Next 5
slide please.
6 How do you make comments? Number one, 7
here today, on the record. Mail. This, if everyone 8
wanted to grab, there are copies of the slide. You 9
don't have to write this down. There's copies of the 10 slides out there. You can submit your comments by 11 mail. There's the address. You can fax.
12 Regulations.gov.
This is the federal 13 government-wide site for any sort of rulemaking or 14 when we do things like this, where we want public 15 comments. This is the -- this is what you need to use 16 if you're going to search that.
17 If you search under that docket ID, it 18 will bring you to essentially the Seabrook 19 environmental impact statement page, and that will be 20 where you can submit your comments electronically.
21 They are due by September 21st, and we do take your 22 comments seriously and we do respond to them.
23 If you want to hear our response, we put 24 together what's called a scoping summary report, and 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 21 we either need your mailing address, and you can put 1
those on the blue cards that are out on the front 2
desk, or as well if you signed up on -- if you put 3
your email address on the sign-in sheet, and as well 4
we can get that scoping summary report to you via 5
email. That is the way we prefer is via email. Next 6
slide please.
7 So I wanted to highlight this again, the 8
opportunities for public involvement in this whole 9
process, why we're here today, the scoping meeting.
10 There's an opportunity for a hearing that ends on the 11 20th.
12 Draft environmental impact statement. We 13 will be back here probably right in this room. Next 14 June is about when we anticipate being back here, and 15 we're going to again ask for your comments on the 16 draft environmental impact statement.
17 You are invited as well to Washington, 18 D.C. for the -- our independent review by the Advisory 19 Committee on Reactor Safeguards, and any other 20 meetings that we have as required as we go along in 21 this process. We will let you know when we're going 22 to have those meetings in advance. Like I said, there 23 will be Federal Register notices for the things that 24 are starred, and we'll also have press releases. Next 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 22 slide please.
1 Final Agency Decision. So the final 2
agency decision comes from -- what goes into that 3
comes from several components. What Rick talked 4
about, the safety evaluation report on the safety 5
side; the environmental impact statement; and our 6
inspections that we do and the findings and 7
conclusions that come out of those; and the 8
recommendation from the Advisory Committee on Reactor 9
Safeguards, from their independent review. Next slide 10 please.
11 Places you can go look at the documents.
12 You can see those two big thick binders on the back.
13 That actually is the application. A copy of that is 14 at the Seabrook Public Library, and it's also in 15 Massachusetts at the Amesbury Library.
16 You can always access it at this website.
17 It's devoted to the Seabrook license renewal review.
18 As well, this website will also be a place we'll put 19 the draft environmental impact statement on there, and 20 the libraries will also get that if you want to see 21 paper copies. Next slide please.
22 Keeping up to date. We have, at the NRC 23 now, we have a list server, and here's the web page 24 right there. You essentially just click on Seabrook.
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 23 You put the email address at the bottom and you press 1
"submit." You will get all of our public documents 2
related to Seabrook that the NRC puts out. That 3
includes the license renewal piece.
4 You can sign up yourself at this website, 5
and if you want, we can also sign you up if we have 6
your email address in the back. Next slide.
7 So that's actually everything I have to 8
say. We're going to leave this up, Rick and I.
9 Rick's safety, I'm the environmental side. If you 10 have any questions, there's our email address and our 11 phone number. With that, I'll turn it back over to 12 Elva.
13 MS. BOWDEN-BERRY: Jeremy, could you have 14 yourself or one of the other NRC representatives go 15 over the hearing process a little bit and overview?
16 MR. SUSCO: Absolutely. I'll let one of 17 our attorneys answer that question.
18 MR. DREHER: Elva introduced me before.
19 My name is Mike Dreher. I'm an attorney with the 20 Office of the General Counsel at the NRC. The hearing 21 process, I guess, is just a real quick rundown of it.
22 It's the public's opportunity to have any issues or 23 objections that they have heard during the NRC's 24 review of the license application.
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 24 What it boils down to is from the date 1
that the NRC published the notice of opportunity for 2
hearing in the Federal Register, which was July 21st, 3
if I'm not mistaken, there are 60 days to file a 4
petition to intervene with a contention in that 5
hearing, and that date will be September 20th, I 6
believe, is the last date that those petitions can be 7
filed.
8 After that, the agency and the licensing 9
board will review the petitions to intervene, and if 10 the contentions in the petition are admitted, then 11 they are adjudicated through the agency's review 12
- process, which is in front of the agency's 13 adjudicatory body, the Atomic Safety Licensing Board.
14 Now this whole process is run through much 15 clearer on our website. If you go to the NRC.gov 16 website, go to the how to get involved, the public 17 involvement tab on the web page, this is all 18 explained. There are links to the rules and the 19 process, and I can explain it in more detail to 20 anybody who'd like to hear it, during or after the 21 meeting.
22 MS. BOWDEN-BERRY: Thank you, Mike. With 23 that, right. I was going to open it up to questions, 24 and I wanted to remind all of you that all these 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 websites are listed in your handouts of slides. If 1
you don't have the handouts, then we can get them to 2
you later. All right, questions? Yes sir.
3 MR. BLANCH: Yes. Jeremy, you said that 4
documents were available at the local public document 5
room. Would this include a copy of all the 6
regulations in the FSAR and all the documents that are 7
being reviewed? When I say "regulations," I'm talking 8
about those regulations that are codified under 9
50.55(a), such as ASME codes for piping and buried 10 piping.
11 Can members of the public go to the local 12 public document room and review the regulations that 13 are applicable to this plant, and I'm specifically 14 talking, you know, some of the regulations are ASME, 15 American Society of Mechanical Engineers. Some of 16 them are endorsed by IEEE, which is Institute of 17 Electrical and Electronic Engineers?
18 Can members of the public go to the public 19 document room and access these documents to see what 20 requirements are applicable to the design of this 21 plant?
22 MR. SUSCO: As part of license renewal, 23 no, we do not put every document in the libraries.
24 They have limited space and limited resources. So we 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 26 put the documents that are pertinent to license 1
renewal. For example, the application itself, the 2
draft environmental impact statement and the final 3
environmental impact statement.
4 There is a public document room in 5
Washington, D.C. where a lot of those are accessible.
6 I understand that's not great if you live here in 7
Seabrook or the area. But on our website as well, 8
there also is information on how you can access that 9
type of thing.
10 On our website as well, there is a lot of 11
-- a lot of this information is available, as well as 12 through Google. So no. To answer your question, the 13 libraries do not have every piece of documentation 14 that the public might possibly want. But pertinent 15 documents are there.
16 MR. BLANCH: So one would have to fly to 17 Washington to take a look at ASME codes that are 18 applicable. They're not accessible on the web, by the 19 way.
20 MR. SUSCO: I can talk to you more about 21 this afterwards, but no, it's not. You don't have to 22 fly to Washington. The web also describes ways that 23 you can get the documents without going to Washington.
24 But were not actually here to talk about ADAMS.
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 27 We're here to hear the scoping comments. So I can 1
talk to you afterwards about that.
2 MS. BOWDEN-BERRY: Are there any more 3
questions on the presentation, any clarifying 4
questions about the process?
5 (No response.)
6 MS. BOWDEN-BERRY: Okay. Please state 7
your name and the organization you're with.
8 MS.
LAMPERT:
I'm 9
associated with C-10, and my question is for when you 10 can sign up on Seabrook's website. Will all the 11 motions filings in the hearing process be available on 12 that site? You said we get everything from Seabrook.
13 Will we get every filing in the adjudicatory process?
14 MR. PLASSE: I can tell you -- what I can 15 say for sure, Seabrook will be part of what we call 16 the electronic hearing docket.
All of the 17 adjudications that the agency undertakes at this point 18 all go onto an electronic docket available on our 19 website, and within usually a business day or two of 20 their
- filing, all documents filed before an 21 adjudication do come up as available on that website.
22 It may take a day or two so that it can 23 run through the Secretary's office, but it will up 24 there, yes.
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 28 MS. LAMPERT: And you'll provide that 1
address, so people will be able to access it, the 2
general public?
3 MR. PLASSE: Yes. If you go to the 4
Seabrook website that's on the NRC.gov site, under 5
each licensing action that has a page, there will be 6
-- there is a link to the electronic hearing docket, 7
to access docket filings in that particular case. So 8
Seabrook will be part of that.
9 MS. WOLF: Okay, excuse me. I'm just 10 curious. Who appoints the independent ACRS? How many 11 members does it have? In final evaluation by the NRC, 12 does it carry more weight than any of these other 13 three factors noted, which were safety evaluation 14 report, EIS, NRC inspections and findings, and the 15 ACRS report?
16 MS. BOWDEN-BERRY: Will you state your 17 name and -- okay.
18 MS. WOLF: My name's Kathy Wolf. I'm a 19 concerned citizen.
20 MR. PHAM: My name is Bo Pham. I'm the 21 branch chief for License Renewal. Your first 22 question, does the ACRS -- well actually --
23 MS. WOLF: Who appoints the ACRS?
24 MR. PHAM: Who appoints the -- statutorily, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 they're required, you know, the Commission appoints 1
the ACRS.
So they work directly for the 2
commissioners. They're separate from the staff. How 3
many members are there? I can't remember the exact 4
number at this point, right. But at about 12 to 15, I 5
believe, was the correct number.
6 Does their consideration or review carry 7
more weight than the other three? It's not a 8
weighting factor. I mean the Commission takes all 9
three sources of input into consideration, and the 10 Commission makes that weighing. I can't tell you, you 11
- know, how they'll weigh the different factors 12 basically.
13 But the ACRS review is independent of what 14 the staff, you know, our folks do basically.
15 MS. WOLF: One final follow-up question on 16 that. Why is the ACRS needed, if the NRC comes to 17 objective conclusions on its own? Why are two 18 independent reviews of the licensing extension needed?
19 MR. PHAM: That may be a legal question 20 beyond my ability to answer. But I would guess that 21 the ACRS is an independent body that's required by law 22 when we established the Atomic Energy Act, to have the 23 ACRS appointed as probably -- you know, if I were to 24 give an answer, I probably would say just for checks 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 and balances.
1 MS. BOWDEN-BERRY: Please state your name 2
and your organization.
3 MS. TEAGUE: Good afternoon. My name is 4
Diane Teague. I'm here as a parent, a grandparent and 5
a member of C-10, since we're talking about 6
potentially 40 years from now, and this will affect my 7
grandchildren.
8 So my question is pretty much a process 9
question. In looking at this outline and the meeting 10 purpose, I notice that it's to collect our input on 11 the scope of the environmental review. I'd like some 12 clarification as to whether this is a typo, that a 13 safety review and our input on that aspect is not 14 invited at this time, or why that is excluded? Thank 15 you.
16 MR. PHAM: This is Bo Pham, and the 17 question is does this -- is our message here that the 18 safety review is not, you know, are we not soliciting 19 comments with the safety review. We never exclude any 20 comments. The NRC always considers the comments.
21 But just from the environmental aspect, 22 the National Environmental Policy Act and NEPA law 23 requires that we go out and directly take the input 24 from members of the public. That's why we're 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 31 implementing that, the requirements of that law.
1 With the Atomic Energy Act, I don't 2
believe the Atomic Energy Act has such provisions in 3
it. So typically we don't, but that doesn't mean we 4
don't take input from the public. So process-wise or 5
procedurally, we don't normally have that process in 6
there.
7 MS. BOWDEN-BERRY: Okay. With that, we'll 8
go on to the second part of the meeting, and we'll 9
take your comments. The first speaker that I have is 10 Mary Lampert.
11 MS. LAMPERT: Hello. I'm Mary Lampert. I 12 am Director of Pilgrim Watch, but I am not here in 13 that capacity. I'm here to provide technical advice 14 for C-10. Impacts, environmental impacts can be both 15 from normal operations and also from accidents, 16 design-based accidents and severe accidents.
17 I'd like to direct my questions and 18 comments solely to severe accidents. There is a 19 requirement of the applicant to do a severe accident 20 mitigation analysis. It can be found in their 21 application. In reading it, it's akin to reading a 22 fairy tale. There is absolutely nothing in it that 23 has a commonality of what one would expect of a severe 24 accident from a nuclear reactor.
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 32 It is NRC's job in the SEIS to not just 1
describe what the applicant did, and summarize it in a 2
chapter, as has been done at other licensees. It is 3
rather to do, and we expect a detailed analysis of 4
this issue. A SAMA, that's the shorthand, they're 5
required to analyze. It's a cost-benefit analysis, 6
the consequences of off-site of an accident, and then 7
weigh that against costs for mitigative measures that 8
would help reduce risk.
9 So this is very, very important. The 10 applicant used a computer code called the MAC code, 11 MAC-S2. My question is I think it's necessary to 12 justify the use of that code. First, it is not -- it 13 was not held to the same quality assurance 14 requirements of the American Society of Mechanical 15 Engineering QA Program, requirements for nuclear 16 facilities.
17 So therefore there is a very important 18 question. It was designed solely for research. There 19 is a paper on this by the author of the code. It was 20 not designed for licensing. So therefore the question 21 is why is it being used?
22 Also in the code, if you read it, go 23 through it, there's no explanation of exactly how it 24 works, which is a problem and your responsibility to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 explain to the public. The problem, there are many 1
problems with this code, and it's not appropriate for 2
use.
3 As it was used by Seabrook in this 4
application to determine off-site consequences. Why?
5 It's important, when you're looking at consequences, 6
to understand atmospheric dispersion and deposition.
7 The code has embedded in it a module called ATMOS, and 8
relevant for you, that uses the straight-line Gaussian 9
plume model, which assumes that wind blows like a beam 10 of a flashlight.
11
- NRC, DOE, the
- public, the
- world, 12 meteorologists know that is not how the wind blows in 13 a coastal location. Therefore, it is very important 14 when you are doing your review, that you do site-15 specific analysis, analyses of plume distribution, 16 meteorology in this area.
17 There have been numerous studies ignored 18 by the applicant, but they cannot be ignored by NRC, 19 of how the meteorology is on the coast of 20 Massachusetts, New Hampshire and Maine, specifically 21 discussing the sea breeze effect, which occurs here, 22 increases deposition, number one, and also when it 23 looks like the wind's blowing offshore, it's brought 24 in sometimes 20 to 40 miles. Very significant, 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 34 ignored by the applicants in their application.
1 Also ignored is the fact of how plumes 2
travel over water, where they because of lack of 3
turbulence, they remain concentrated, and as a result 4
you can find, when there are northeast winds, 5
deposition blowing down to the dense urban areas, such 6
as a Boston, where you'd expect to find hot spots, or 7
conversely up the New Hampshire coast, to densely 8
populated areas such as Portsmouth and Portland.
9 This is ignored by the licensee. It 10 cannot be ignored. Nor can it be ignored that they 11 got their meteorological data from one source, the on-12 site meteorological tower, which simply will tell how 13 wind is blowing on site, but not what happens to it 14 off site.
15 So the data they used is essentially 16 worthless. We expect and demand NRC to do more. The 17 economic costs were also grossly underestimated, 18 particularly the cleanup costs. The MAC-S2 models 19 bases its assumptions on clean up, on WASH 1400.
20 Therefore, the DF factor, decommissioning factor, 21 decontamination rather factor, is 15.
22 We want you to look at that. What is the 23 DF factor that Seabrook has assumed?
More 24 importantly, what level of cleanup? They never talk 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 35 about the level of cleanup. Would it be required to 1
go EPA, 15 millirem a year? Are we going to 25? Are 2
we going to 50? Are we going to 500? Because what is 3
allowable greatly affects the cost of cleanup.
4 A GOE report has reported that in fact 5
there's no agreement between EPA and NRC. The public 6
here wants to know. The public wants to know some 7
other factors that were ignored. Where's the waste 8
going to go? How much waste? What is the volume that 9
is expected in a severe accident?
10 While you're looking for a place, how is 11 it going to be safeguarded? That's a cost that's not 12 accounted for. Are they going to put lead blankets 13 over it? How is resuspension going to be covered?
14 What about workers? Whereas WASH 1400 and the MAC-S2 15 code that they use for their cost calculations assume 16 and was based on a weapons event, cleaning up; it was 17 during the Cold War, of a weapons event.
18 That is the fundamental underpinning of 19 the code, cleanup cost factors. However, there is a 20 vast difference between cleaning up on a weapons event 21 than cleaning up from a reactor event. A weapons 22 event has larger particles, larger mass loading. They 23 assumed, as the MAC-S2 code assumes, the buildings 24 will be hosed down and fueled to be plowed under.
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 36 This will not be allowed by the public, by 1
CERCLA, by EPA. So let's get some real cost here, 2
real cost. You don't have real cost.
3 Also underestimated are the health costs.
4 Look at, and we want to know. This has to be site-5 specific. We cannot have the health costs that are 6
assumed in the code, that go back to understandings of 7
the 1960's, at best early 70's. We've had BEIR-7.
8 BEIR-7 is not conservative enough, because it does not 9
include the Techna River studies. It does not include 10 the studies by Cardis, which show far greater damage 11 from lower doses than BEIR-7.
12 So therefore the health costs. Health 13 itself is taken off the table as a Category 1 issue.
14 But the costs of health belong in the SAMA.
15 Next, and I'm almost finished, what is 16 missing is consideration of a spent fuel pool 17 accident. I think obviously this is important, 18 because there's far more radioactivity in a spent fuel 19 pool, and you can have migration from a reactor 20 accident to a spent fuel pool accident, so you get a 21 double whammy, or it can move the other way.
22 The argument for not considering this 23 holds no water. They go to the GEIS and look at 24 Section 6, which takes spent fuel and low level waste 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 for that matter off the table for adjudication, but 1
the first paragraph says "Normal operations."
2 Section 5 of the GEIS, which this process 3
is under, describes and gives a definition of severe 4
accidents, and it defines it in terms of consequence, 5
not in terms of the origin of the accident.
6 Therefore, consideration of the spent fuel pool 7
accident in a severe accident mitigation analysis, 8
must be considered.
9 Last in the application, they talk about 10 evacuation time estimates, which are required, because 11 how long it takes and how many people will get out of 12 dodge will affect -- in time will affect health costs.
13 However, when you read the application, 14 the only reference is to Seabrook's radiological 15 emergency plan. There is no reference, no information 16 of evacuation time estimates, no provision if they 17 used KLD, whether these time estimates were performed 18 during peak commuter hours, during bad weather in peak 19 commuter hours, during holidays, during high beach 20 season. There's no information whatsoever.
21 Just a mere "other" reference to new Reg 22 1150, which has absolutely nothing to do with this, 23 that was an analysis of consequence at five reactors, 24 not Seabrook included in 1991. So it is really 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 38 irrelevant. So that has to be updated. Last, they do 1
a sensitivity analysis to show that we put in more 2
numbers to make a severe accident look a little worse, 3
and see it didn't make enough of a difference.
4 But what they did was use the same code, 5
the same assumptions, the same processes, so repeating 6
the same mistake one, two, three, four times, that 7
never will give you the right answer. And so these 8
are the questions. We will send these questions to 9
the NRC, because we will not accept, and nor will you 10
-- we're sure you would like to do a good job --
11 simply to read what they did and then briefly describe 12 it in Reader's Digest form.
13 We expect analyses, and we're very willing 14 to help you with this process.
15 MS. BOWDEN-BERRY: Mary, thank you very 16 much for your comment. We're going to go to 17 Representative Read next, and then Dr. McDowell.
18 Could you spell your name when you get up to the mic 19 please?
20 MR. READ: My name is Robin Read, R-E-A-D.
21 I'm a
member of the New Hampshire House of 22 Representatives from Portsmouth, which as you all know 23 is within the evacuation zone. I was also a member of 24 the House in the 1980's when we went through the 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 39 financial struggles related to the plant and would 1
like to say that I think the new owners have done a 2
better job of communicating with the public and 3
letting us know what's going on than the previous 4
owners.
5 You're going to hear -- you've heard a lot 6
about the evacuation issue, and you're going to be 7
hearing I'm sure more about the problems that we 8
really should be looking at, including waste, the 9
issue of nuclear waste in the review.
10 But I'd like to talk just for a minute on 11 the reasonable alternatives appropriate for the area.
12 I was at a conference of legislators from all over 13 the Northeast in Maine on Monday, where Gordon Van 14 Welie, who's the ISO -- the president of ISO New 15 England, which runs the grid in New England, said that 16 there are 3,000 megawatts of wind power currently in 17 the pipeline in New England. 12,000 megawatts is 18 available.
19 Maine in 2008 passed the Maine Wind Energy 20 Act, which calls on Maine to produce 3,000 megawatts 21 of wind by 2020. New Hampshire, we now have renewable 22 portfolio standard, which calls on the state to have 23 25 percent of its energy produced from renewable 24 sources by 2025.
25
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seriously question the need for 1
Seabrook, and I still don't understand how we can be 2
doing this process, looking at what the environmental 3
and renewable energy situation and energy efficiency 4
improvements 20 years and 40 years down the road.
5 I think it's way premature to be doing 6
this process now. I agree with the petitioners, who 7
say that ten years would be a much better time period 8
to look at. There have been huge advances in 9
renewable energy and energy efficiency. There have 10 been huge advantages in storing alternative energy 11 through battery technology.
12 There was a recent article in the New York 13 Times about storing wind power. I think that this is 14 just way premature, and I think that the NRC should 15 look seriously at the petitioners' proposal, and look 16 at the alternatives seriously.
17 MS.
BOWDEN-BERRY:
Thank
- you, 18 Representative Read. Now we'll have Dr. McDowell.
19 DR. McDOWELL: I'm Robin McDowell. I'm a 20 professor of Oceanography and Environmental Science, 21 American Military University. You've heard a lot of 22 negatives and cons in Seabrook. I think you need to 23 hear the positive side. Right now, there are 24 something like 131 nuclear power plants being 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 41 constructed around the world, and they're not all in 1
Iran, by the way.
2 I worked at Los Alamos for 18 months, and 3
I still have all my hair, and as far as I know, I 4
don't have leukemia. I live in Portsmouth, down wind 5
from the Schiller and Newington fossil fuel plants.
6 When the air's humid there, Portsmouth smells like 7
Pittsburgh used to, yet nobody's protesting that one.
8 Nuclear is a proven technology. Seabrook, 9
as far as I know, has never had an incident or a 10 problem. I see no good reason to deny a license, 11 although you guys ought to work on the fuel disposal 12 problem, and we spent a little money out in Yucca 13 Mountain. We ought to do something with it.
14 Other than that, there is no, unless we 15 want to start turning lights off and shutting off air 16 conditioners and other facilities around here, wind 17 and solar are nice. But look out that window.
18 There's not enough wind going out there right now to 19 fly a decent-sized kite. So unless you want to start 20 turning switches off, we need Seabrook, like it or 21 not.
22 It hasn't had a problem, you know, I see.
23 But I assure you guys when you get back to Rockville 24 Pike will do a very thorough job, as you usually do, 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 42 in looking at things. Thank you.
1 MS. BOWDEN-BERRY: Thank you. We'd like 2
to have Paul Gunter. Please spell your name and 3
indicate where you're from. Thank you.
4 MR. GUNTER: Thank you. My name's Paul 5
Gunter. That's G-U-N-T-E-R, and I'm Director of the 6
Reactor Oversight Project at Beyond Nuclear, and we're 7
based out of Takoma Park, Maryland, just outside of 8
Washington, D.C. I'm a former resident of New 9
Hampshire for 23 years, and also I was one of the 10 petitioners that filed with the U.S.
Nuclear 11 Regulatory Commission yesterday under the provision 12 for petition for rulemaking, in a request that the 13 agency change the current rule under 10 C.F.R. 14 5417(c), from 20 years in advance of the expiration 15 date to ten years in advance.
16 And one of the key reasons that we've 17 requested this petition for rulemaking is precisely 18 because a premature application will do nothing but 19 provide meaningless data for this agency's 20 consideration.
21 This application is the equivalent of 22 green fruit. It's not ripe. It needs more time. It 23 needs more time to consider a whole host of issues, 24 ranging from system structures and components at this 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 43 plant that you're required to look at, in the context 1
of aging.
2 But more particularly, I would like to 3
just say a few words about the due process issue. One 4
of the key concerns that we have here with an 5
application that's coming 20 years in advance of the 6
expiration date is that it excludes a whole generation 7
of citizens, commercial interests from participating 8
in this process.
9 I mean people who should be here are in 10 grade school right now, particularly when you're 11 talking about a federal action that will not occur 12 until 2030. So it's alarming that -- well first of 13 all, the slide that you had up earlier with regard to 14 why 20 years, I've participated in many of these 15 license renewal proceedings.
16 We've been an intervener before, and 17 that's the first time I've ever seen this slide. It 18 was not reassuring that the basic message of the slide 19 was because we say so. What you've addressed here is 20 that -- I mean you've determined that 20 years of 21 operational and regulatory experience provides an 22 applicant with substantial amounts of information.
23 But I would refer you to the National 24 Environmental Policy Act, the reason we're here in the 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 44 first place, provides that at Section 1501(b), it says 1
NEPA procedures must ensure that environmental 2
information is available to public officials and 3
citizens before decisions are made and before actions 4
are taken.
5 The information must be of high quality.
6 Accurate scientific analysis, expert agency comments, 7
public scrutiny are essential to implementing NEPA.
8 Most important, NEPA documents must 9
concentrate on issues that are truly significant to 10 the action in question, rather than amassing needless 11 detail. What you have before you in this application, 12 now 20 years before the time of expiration, it 13 basically constitutes nothing but
- nonsense, an 14 amassing of needless, meaningless detail.
15 Let's look just in, you know, a license 16 renewal application for a
nuclear power plant 17 submitted 20 years in advance of its expiration date 18 cannot, according to Section 1500.2 of the same Act --
19 provide to the fullest extent possible is the 20 requirement of NEPA
-- accurately and reliably 21 evaluate what's foreseeable, particularly for the 22 renewable energy alternatives that the representative 23 from New Hampshire has already addressed as a 24 tremendous resource.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 45 I mean essentially what this application 1
currently puts forth in its claim that the 2
contribution of wind and solar to the consideration of 3
alternatives under
- NEPA, they fix it the 4
nonsensical comparison is much like saying the Model T 5
is going to be what we have for the next 20-40 years.
6 It casts aside any kind of consideration 7
for advancement. But in fact, it's not just -- we're 8
not just pulling this out of the air. The Department 9
of Energy's own National Renewable Energy Laboratory, 10 in its assessment, particularly of offshore wind, is 11 that the contribution for the region of interest that 12 we're discussing here under NEPA is -- ranges from 13 good to superb.
14 This basically still this all 15 contradicts what the applicant has put forward for 16 your consideration. They don't even mention that the 17 potential here, as rated by the Department of Energy, 18 is that this offshore wind resource is superb.
19 But, you know, it remains a concern that 20 you have -- you've got an application here that's 21 before you, and now it's your duty under NEPA to 22 rigorously explore and objectively evaluate all 23 reasonable alternatives and for the alternatives that 24 are to be eliminated by the detailed study that you 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 46 have before you, you have to discuss the reasons that 1
they have been eliminated.
2 Frankly, that's why you've got green fruit 3
on your hands right now. There's really no rational, 4
reasonable way to assess a resource 20 years out from 5
the time that you're talking about this federal action 6
to be considered, to be in effect.
7 So I urge you, as we have petitioned the 8
agency, to essentially reject this application as 9
premature, as simply -- in many sections of it, simply 10 an amassing of needless detail, and let's come back to 11 this issue when the time is right, as the petition has 12 suggested, in 2020. Thank you.
13 MS. BOWDEN-BERRY: Thank you for your 14 comment. We'll have Doug Bogen. Can you spell your 15 name, and indicate where you're from please when you 16 get to the mic? Thank you.
17 MR. BOGEN: Good afternoon. My name is 18 Doug Bogen. That's B-O-G-E-N, and I'm the executive 19 director for the Seacoast Antipollution League. I'm 20 also a 25-year resident of the seacoast New Hampshire 21 region. Seacoast Antipollution League was founded in 22 1969, and has been engaged since the inception of the 23 Seabrook nuclear plant and the original licensing, as 24 well as in watch dogging the operation and the 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 47 regulatory process since its start-up.
1 We are very concerned about the ongoing 2
air and water emissions from these plants. You've 3
heard some from others and probably will hear more on 4
that.
5 One in particular that hasn't been 6
mentioned is the radioactive water, otherwise known as 7
tritium, which we have seen leakage from the plant 8
already, and is a problem throughout the industry.
9 We've most recently heard about the problems at 10 Vermont Yankee.
11 We're just amazed that in all these years 12 and all the time we've known about the security and 13 leakage problem, that the NRC does not require the 14 power plant owners to have a maintenance plan to 15 report that information. It's a voluntary program.
16 I just find this appalling that for all 17 this time we've known about this problem, and for all 18 the problems it's caused in particular with the 19 relicensing of Vermont Yankee, that this is still an 20 issue, and that we do not have public access to this 21 information. It just isn't available.
22 Now I recognize that the purpose of this 23 meeting is to identify environmental impacts of this 24 plant. But we're more concerned actually right now 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 48 I'd like to talk about the plant impacts from the 1
environment. We know now that our environment is 2
changing.
3 I think most everybody and certainly the 4
science is in on this, and to others it should be 5
obvious from recent calamities occurring across the 6
globe as well as in the region, that the climate is 7
- changing, that we know now the environmental 8
parameters we have today are not going to be in effect 9
20, 40, 50, 100 years from now.
10 Just look at a few of these, sea level in 11 particular. Sea level is going up. It has been going 12 up for decades. But it's going to accelerate. We 13 know this. The question is how quickly will it 14 accelerate? How many meters higher will it be in 50 15 or 100 years?
16 The current best
- estimate, without 17 dramatic reductions in carbon emissions, which we 18 certainly aren't seeing in our country, according to 19 recent events, that estimate is that by the end of 20 this century, sea level will rise upwards of a meter.
21 That will affect the, obviously the coastline, the 22 ground water levels, the salinity of the ground water.
23 It will have dramatic effects on our sea coast 24 environment.
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 49 Now another organization that I've worked 1
with in the past, Clean Air Cool Planet out of 2
Portsmouth, has put together a map of what the 3
Hampton-Seabrook Harbor will look like with a one 4
meter sea level rise.
5 I'm sorry, I don't have a blow-up of this.
6 I just pulled it out of my files this morning. But 7
if you can see the area in blue, it's essentially all 8
the salt marsh and much of the low-lying coastal area 9
will be under water with a one meter sea level rise.
10 The Seabrook plant is on this little 11 peninsula right in the middle here. It will be almost 12 surrounded by water. Most of the routes out of the 13 plant, out of Seabrook and Hampton will be under 14 water. Route 1, Route 1A, Route 101, they will not be 15 accessible if this sea level rise continues, as is 16 predicted now.
17 We have to take this into account. We'll 18 have a much better picture 10 or 20 years from now.
19 But we certainly can't say right now that everything's 20 going to be fine and that the current water regime is 21 going to be the same.
22 Now looking at groundwater, this is a very 23 important concern. I've mentioned the issues with 24 tritium, but we're also concerned about all the 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 50 underground infrastructure specifically at this plant, 1
and what effects this groundwater change will have on 2
that, on those systems.
3 The salinity increases certainly will 4
affect the corrosion levels, the amount of damage 5
going on to these critical infrastructure, and it will 6
affect the coastal area in many other ways. There are 7
studies that have already been done.
8 The United States Geological Survey did a 9
report on sea coast water resources. They have 10 determined that there will be much greater reliance on 11 groundwater, more extraction of groundwater in our 12 seacoast area in coming decades, and that will also 13 affect the salinity levels of groundwater.
14 We know this on the sea coast. When you 15 pump water out of the ground, you draw in more of the 16 ocean water, the saline water and certainly with sea 17 level rising, that makes it all the much worse. One 18 other key issue we've heard a little bit about, 19 especially down in the Gulf Coast, is violent storms.
20 We haven't had a significant hurricane up 21 on this region, a really big one since, I think, 1938.
22 But it is predicted that there will be much more and 23 more frequent violent storms in this area. Again, 24 looking at this map here, one of the things that it 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 51 shows with the one meter sea level rise is that 1
Hampton Beach will be largely under water. Seabrook 2
Beach will be under water.
3 Those are the barrier beaches that we rely 4
on to protect our salt marsh area and our inland 5
coastal areas. And with those barrier beaches gone, 6
it's much more likely that you're going to see damage.
7 I don't know exactly how high Seabrook plant is above 8
sea level or the spent fuel pools or the dry cast 9
storage area. But I know it's not that high. I know 10 with the 20 foot sea level rise, the whole place will 11 be under water.
12 So I do hope that you will be, if you 13 don't have on staff, you'll be hiring a climatologist 14 to look at the latest research on this, and a 15 hydrogeologist to look at the impacts on ground water 16 and the impacts of a changing water regime, because we 17 need to know this information.
18 This could be vitally important to the 19 integrity of the plant in coming decades. But again, 20 the bottom line is that we don't have all the 21 information. This is highly premature to be assuming 22 that we have any idea what's going to be happening in 23 40, 50, 60 years down the road.
24 When we're talking about the nuclear 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 52 waste, those of us who have been following this issue 1
for some years, we know that that waste is not going 2
to be hauled out of there the day the plant closes.
3 It needs to cool off. It's got to be transported.
4 There are many, many issues.
5 That means we are going to be dealing with 6
that waste on that site for many decades after that, 7
and that is a scary prospect with the ocean roaring in 8
with storms and increased sea level. We need to be 9
addressing these issues in this environmental impact 10 study.
11 It has been mentioned about alternative 12 resources. I think it's very important that we be 13 looking at the other options, particularly if you're 14 saying that, you know, utilities need to plan for the 15 future. I do wonder, though, how this plant as a 16 merchant plant, it's not like they have, you know, a 17 specific clientele that they have to service. It's 18 not Public Service of New Hampshire anymore.
19 We are still paying for it, by the time.
20 I resent every month I have to pay a little fee to 21 help pay the stranded costs of this plant from the 22 expenses of decades ago. But we don't get any direct 23 benefit. My understanding is that Public Service of 24 New Hampshire does not directly get power from 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 53 Seabrook. It's just bought through the wholesale 1
market.
2 So this idea that somehow if the plant was 3
to close in 2030, that would somehow, you know, really 4
disrupt the current utilities. It boggles my mind.
5 I mean I think that we really need to be 6
looking more broadly and look at, you know, really the 7
current and future power systems and power policy in 8
the Northeast, and right now New Hampshire has, I 9
think, 3,500 megawatts of capacity. That's like three 10 times our stage usage of power. We are essentially an 11 energy colony for the rest of the Northeast.
12 Now that's okay. Obviously some areas are 13 going to be better at producing power, you know, and 14 we fully expect other states will jump in and be major 15 power producers. It was mentioned, I think earlier, 16 the offshore potential for wind power.
17 The state of Maine in particular has 18 looked into this. They did a report. It came out 19 last December, which said that there was the potential 20 of large scale offshore wind power to produce 149 21 gigawatts of power. That's about 120 Seabrooks just 22 off the coast of Maine.
23 I'm sure some of you have seen this map, 24 but this is the Department of Energy map that Mr.
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 54 Gunter referred to later. In this map, the color code 1
is bright red there. That's not "warning, get out of 2
here"; that is the highest potential, excellent 3
potential, outstanding is the word they use, the 4
Department of Energy, and that's off the coast of 5
Maine, off the coast of New Hampshire and on down the 6
coast.
7 We need to be looking very carefully at 8
these alternative power sources, and also the economic 9
impact of that. I mean just think of all the many 10 thousands of jobs that would be created if we were to 11 convert some of our coastal facilities to the 12 production of wind power.
13 I think of the Portsmouth Naval Shipyard, 14 the Bath Armworks. All up and down the coast we have 15 facilities that could be producing very useful 16 technology for the future of our energy system in this 17 region, and we need to be looking at the potential 18 huge public benefit of developing those resources, 19 instead of relying on old, obsolete, potentially 20 unsafe resources like the Seabrook reactor.
21 So just to sum up, I don't want to take 22 too much time. But just for the record, we do 23 recommend no action at this point. I know that is one 24 of the options you have. We do feel this whole 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 55 license renewal process to be highly premature.
1 It cannot possibly take into account all 2
the many key factors affecting plant maintenance, 3
reliability and safety from the deterioration of vital 4
plant systems and infrastructure, to climate change 5
and future power needs as I've described over the next 6
40 years.
7 So that's why we are also petitioning the 8
NRC to suspend the process now in the public interest.
9 We need to keep in mind we are talking about 10 decisions now that will affect future generations, 11 people that aren't even born yet, our children and 12 grandchildren. Most of us here won't even be alive 13 when this plant is still chugging away under this 14 proposal.
15 So we need to be thinking very carefully 16 about what the impacts will be for their benefit, not 17 just for a current corporate interest that clearly has 18 some financial benefit or they wouldn't be here 19 advocating for this at this time.
20 We need to be thinking foremost about the 21 public benefit and the environmental benefit of our 22 future energy policy, and we need to be keeping that 23 foremost in deciding on whether to renew this plant at 24 this time. Thank you very much, and I will be 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 56 submitting probably written comments, and I think can 1
provide these maps to you as well. Thank you.
2 MS. BOWDEN-BERRY: Thank you, Mr. Bogen, 3
and I apologize for mispronouncing your name. We're 4
going to have Janet Guen, then Joe Casey and Tim 5
Noonis next. So Janet Guen. Can you spell your name 6
for the record and tell us what organization you're 7
from? Thank you.
8 MS. GUEN: Good afternoon. My name is 9
Janet Guen. I'm a senior director with the United Way 10 of the Greater Seacoast. My last name is G-U-E-N.
11 I'm not a technical person and I'm not here in a 12 technical capacity. I'm simply here to answer the 13 question or part of the purpose of the meeting, which 14 was providing input on the scope of the environmental 15 review.
16 I'd simply ask that in a definition of 17 environment, it be looked at in the broadest possible 18
- context, to review not just the traditional 19 definitions of environment, but also environment as it 20 relates to the quality of life that we all experience 21 in our communities, and in particular the health and 22 human service needs of the people who live in our 23 local area.
24 I would ask that the scope include looking 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 57 at the role that Nextera plays in helping to provide 1
for the health and human service needs in our area, 2
the large number of jobs it provides that pay a living 3
wage, the taxes it pays to its local communities, and 4
the role that it plays a good citizen in working with 5
local health and human service and other non-profit 6
agencies, the leadership its employees provide on 7
boards and other committees, the financial support 8
that it provides, not just to United Way but other 9
organizations, and the volunteer time and energy that 10 it puts back into the community. Thank you.
11 MS. BOWDEN-BERRY: Thank you for your 12 comments. Joe Casey, and next is Tim Noonis. Thank 13 you.
14 MR. CASEY: Good afternoon. Can you hear 15 me? Good afternoon. My name is Joe Casey. I am from 16 Rochester, New Hampshire, and I am the president of 17 the New Hampshire Building and Construction Trades.
18 Is this working?
19 I
represent the outside construction 20 workers currently employed at Seabrook Station. I 21 myself worked on the construction and a couple of the 22 maintenance, first maintenance refuels, refuelages at 23 the plant. I'm no longer involved with the plant, 24 other than representing the construction workers on 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 58 site. I worked as an electrician by the way.
1 Currently, there are about 110 craftsmen 2
that work on the maintenance year-round at Seabrook 3
Station. During the refueling cycle, that number 4
grows to about 600 construction workers, and it's 5
vitally important to the construction economy in the 6
state of New Hampshire. This is a continuing cycle of 7
good paying jobs for our people.
8 I deal with Florida Power and Light, the 9
owners of Seabrook
- Station, and the current 10 maintenance contractor on site, and other than the 11 skilled craftsmen that we supply for the continued 12 maintenance and the refueling outages, there are very 13 demanding tasks that they have to go through and 14 perform for every installation in the constructing and 15 maintaining of the facility.
16 Currently, when we send somebody down to 17 Seabrook, in my case it would be electricians, they're 18 already licensed or trained electricians and trained 19 construction workers.
20 Seabrook Station puts them through 21 rigorous training for each and every task that they 22 have to perform, whether it be lift training or, you 23 know, hilti training. Any type of training that 24 requires anything that's involved with the 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 59 maintenance, which is very critical to the plant.
1 They have to undergo rigorous testing, 2
every weld that's done and performed down there. They 3
have to do all kinds of certifications for it, and 4
it's a very difficult place to work. Excuse me.
5 A lot of my people, you know, can't work 6
at Seabrook Station, because they can't pass these 7
exams that they have to go through, which is fine and 8
we understand that, and are very cognizant to the fact 9
that it is very demanding down there.
10 The communication between the building 11 trades, we meet on a quarterly basis with the 12 representatives from each craft with Florida Power and 13 Light, the maintenance people and the building trades, 14 and the number one issue is the personnel safety, the 15 safety of our personnel on site, as they perform their 16 tasks down there.
17 Florida Power and Light has been more than 18 open and honest in every question that has to be 19 performed, and safety is number one to our people.
20 Now over the past three years, the last three years, I 21 ran the numbers this morning, the building and 22 construction trades has accumulated over 1.4 million 23 man hours in the last three years.
24 Now that's a significant number of man 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 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, and these are all New Hampshire people who work 1
and support families in the sea coast area in the 2
state of New Hampshire. These jobs are, you know, 3
top-paying jobs with health care and pensions. I 4
also, you know, since the wind industry has been dried 5
up, I also was involved with the New Hampshire's first 6
wind farm up in Lempster, which we constructed just 7
over a year ago.
8 I had 20 people on that job. There was 9
about 12 towers that was put up over there. We had 10 about 20 people on that job, 20 electricians. They 11 worked for about four months, completed the project 12 and now they're off the job, you know. It's a 13 beautiful job and the wind's blowing and it's 14 generating electricity, and there's not one person 15 left up there maintaining those wind towers.
16 Over the next 20 years, there will be zero 17 man hours produced out of that wind farm into the New 18 Hampshire economy. So you know, the significance to 19 the New Hampshire building trades of the continuation 20 of the operation of Seabrook Station is unbelievable, 21 and you know, there's a lot of people that count on 22 and look forward to continued work down there.
23 I can guarantee you that the construction 24 workers that are working on that site are 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 61 professional, and every task that they perform is 1
overlooked and overlooked again by Florida Power and 2
Light and the NRC.
3 MS. BOWDEN-BERRY: Thank you, Mr. Casey.
4 Can we have Tim Noonis?
5 MR. NOONIS: Yes, hi. That's N-O-O-N-I-S.
6 I'm actually wearing two hats today. My first hat is 7
I am the chairman of the board of directors of the 8
Hampton Area Chamber of Commerce. Seabrook Station is 9
a very strong supporter of the Hampton Area Chamber of 10 Commerce, and through it all the members that we 11 serve.
12 Seabrook Station is always willing to 13 sponsor and participate in many events and festivities 14 that the Chamber promotes to encourage business and 15 tourism in the areas that we serve. I personally have 16 had the privilege to serve on various boards and civic 17 committees with employees of Seabrook Station. I have 18 found them to be a very bright and positive group, and 19 an asset to the communities that we live in.
20 Our Chamber runs the gamut, from small mom 21 and pop businesses to very large corporations. These 22 businesses depend on reliable and reasonably-priced 23 electricity to operate their businesses successfully.
24 The long-term viability of Seabrook Station is 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 62 integral to the success of our members.
1 Seabrook Station is a crucial part of this 2
area's economy, and you could not ask for a better 3
corporate citizen than Seabrook Station. On behalf of 4
the members of the Hampton Area Chamber of Commerce, I 5
would encourage you to extend Seabrook Station's 6
operating license.
7 My second hat today is as a 17-year 8
resident and a homeowner here in Hampton. A few years 9
ago I went to a conference where the keynote speaker 10 was the co-founder of Greenpeace. In his address, he 11 said the biggest mistake Greenpeace made was equating 12 nuclear power with nuclear weapons. He continued on 13 to say that nuclear power has proven to be a safe and 14 reliable source of electricity, and that the operation 15 of the plant does not contribute to climate change.
16 I hear the clamoring for good jobs, cheap 17 power and a clean environment. But when it comes to 18 siting a plant or even a wind turbine, everyone 19 screams "not in my backyard." Seabrook Station is in 20 my backyard, and I have found them to be a very good 21 neighbor. I encourage you to extend Seabrook 22 Station's license.
23 MS. BOWDEN-BERRY: Thank you. We're going 24 to have Bob Backus and then next we'll have Michael 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 63 Schidlovsky. I hope I pronounced that right, and I 1
apologize if I didn't. Can you spell your name when 2
you get to the mic and tell us where you're from.
3 MR. BACKUS: Okay. It is Bob Backus. You 4
are quite correct, B-A-C-K-U-S. I've represented --
5 I'm a lawyer and I've represented the Seacoast 6
Antipollution League for many, many years. I'm from 7
Manchester, New Hampshire.
8 Like Mr. Gunter, I wanted to comment 9
initially on the slide that was shown about why 20 10 years, which says the NRC has determined that 20 years 11 of operational and regulatory experience provides an 12 applicant with substantial amounts of information.
13 My questions, and I guess there's two NRC 14 lawyers here. I particularly address this to them.
15 How can you base your reasonable assurance on merely 16 substantial information? When you fill out an 17 application for college or practically anything else, 18 you're asked for complete information, not substantial 19 information.
20 Well, the answer's obvious. You can't 21 have substantial you can't have complete 22 information, because we're trying to relicense this 23 plant 20 years before that license will become 24 effective.
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 64 One of the key questions, as many have 1
said here, is what's going to happen to age-related 2
degradation on systems and components and structures 3
over the next 20 years?
4 We can't know that. So again, I want to 5
support those who have said that this application is 6
extremely premature. I don't know how you came up 7
with a rule that said you could apply 20 years in 8
advance, you know. Can I apply 20 years in advance 9
for my next motor vehicle license need? I don't think 10 the State Department of Motor Vehicles would permit 11 that.
12 And we know that as time goes on, as 13 radiation takes its effect and other wear and tear 14 occurs, we are going to have age degradation of 15 important structures and components. We know the 16 Yankee Road plant had an embrittled reactor vessel 17 which led to its shutdown. But would we have been 18 able to detect that if we were licensing it 20 years 19 before that became known? I mean how long did it take 20 that to develop?
21 So I have a real grave concern of whether 22 you can meet the requirements you have to have for 23 reasonable reassurance lining, just on the basis of 24 accepting substantial information rather than complete 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 65 and accurate information.
1 Obviously starting at this point, in 2010, 2
30 years, 20 years before the license is to be 3
renewed, you can't possibly have that. So I think 4
this is extremely premature.
5 The other reason you give for starting 20 6
years ahead is that it takes maybe that long for it to 7
come up with alternative supplies. Well, you've heard 8
others speak about that, and there's going to be 9
technological progress.
There's going to be 10 developments in many areas, whether it be solar or 11 wind or other things that we can't foresee now.
12 We're really way out ahead of ourselves, 13 and I think being highly irresponsible in undertaking 14 this license review here in 2010, when the license 15 will not be renewed for another 20 years. I was 16 interested to hear you say there's a couple of other 17 plants that have applied early. But I didn't hear 18 anybody has applied as early as this one. So I think 19 that's a real problem.
20 Just a couple of other points I'd like to 21 make. As part of your review, I would hope that you 22 would determine that this plant is in full compliance 23 with its current design basis in all regards, and how 24 will we find that out? How will we know what the 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 66 design basis is and whether the plant is in compliance 1
with it?
2 This plant, like so many of them, went 3
through any number of changes as a way of sort of 4
being designed as it was being built in some respects.
5 So how will we know that? It seems to me that that 6
will have to be demonstrated.
7 On environmental impacts, you know, one of 8
the big issues when this plant was going through its 9
original licensing was the operation of the once-10 through cooling system, which is a total mortality 11 system with a total loss of all entrained organisms in 12 the plant. Will we be able to have baseline data to 13 know whether that plant is having an adverse effect on 14 the environment? How will that be looked at? I 15 assume that that will be covered.
16 We know the plant has routine releases, 17 and as somebody mentioned, I
think Mr.
Bogen 18 mentioned, we know that there's been some tritium 19 releases which was certainly not intended. We need to 20 look at that. I was going to mention the sea level 21 rise, but that was well-discussed by Mr. Bogen. I 22 won't go into that.
23 Lastly, of course, I know that these 24 licensing proceedings and these individual plant 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 67 proceedings, we're shuffled off with many of the 1
important things are shuffled off as a generic issue 2
to how those are handled on a big national basis. A 3
quintessential example of that is of course nuclear 4
waste disposal.
5 But we think that this needs to be dealt 6
with in this specific context of this plant. If we're 7
going to license this plant for 20 more years, we're 8
going to have a lot more spent fuel. That means a lot 9
of very much greater level of high level waste 10 disposal. We think that the environmental impacts of 11 that have to be considered in regard to the particular 12 characteristics of this site, where there's, as we 13 say, a spent fuel pool which is pretty close to the 14 ambient sea level and the concerns that that raises.
15 So those are the concerns that I have.
16 But again, my major point is 20 years ahead, to get 17 your license renewed 20 years ahead and do so on the 18 basis of what you apparently admit can only be 19 substantial information, which I think may be a 20 generous term, it seems just not regulating and not 21 putting safety first, which should be what is first.
22 Thank you.
23 MS. BOWDEN-BERRY: Thank you. Could we 24 have Michael Schidlovsky? Please spell your name and 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 68 the organization you're with when you get up.
1 MR. SCHIDLOVSKY: Good afternoon. My name 2
is Michael Schidlovsky. I am the president of the 3
Exeter Area Chamber of Commerce, and I'm here to 4
represent the board of directors and the 400 plus 5
members of the Chamber. I'll be very short and sweet.
6 I'm here to express the Chamber's and the Chamber 7
members' support of the application.
8 Like Mr. Noonis, he beat me to the punch.
9 Seabrook Station has been an outstanding corporate 10 citizen. There's support and willingness to help the 11 business community has been extraordinary, and I can 12 only again express that I hope that the NRC views this 13 as a favorable application. So thank you very much.
14 MS. BOWDEN-BERRY: Thank you. Could we 15 have Paul Blanch and then Dennis Wagner?
16 MR. BLANCH: Good afternoon. My name's 17 Paul Blanch. I reside in West Hartford, Connecticut.
18 I'm here solely on my own. I'm not being paid for by 19 anyone, no organization, no utility, and I am a 20 registered professional engineer working in the 21 nuclear industry for close to 45 years.
22 In fact, I've worked for the company that 23 originally licensed this plant when it was licensed 24 back in around 1990. I was working for Northeast 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 69 Utilities. I've worked in many different areas over 1
the nuclear side, from operating Navy nuclear power 2
plants, engineering degree in Electrical Engineering, 3
registered professional engineer.
4 I've been an expert witness on litigation 5
involving Florida Power and Light at the St. Lucie 6
plant, and I've been involved as an expert witness on 7
the litigation for license renewal, working for the 8
attorney general for the state of New York.
9 I think people need to know what the 10 effort is to oppose a license renewal application such 11 as this, and I heard this afternoon for the first time 12 that if anyone wants to intervene, it has to be done 13 by September 20th. Let me just give an example of the 14 manpower effort that went into our litigation against 15 Indian Point.
16 Needless to say, there were many, many 17 attorneys involved in that litigation. The effort and 18 it involved literally thousands if not tens of 19 thousands of hours. I've got to admit, and I'm 20 speaking again on my own, not for the state of New 21 York. What I'm speaking of is the license renewal 22 application, and my areas are -- I'm not addressing 23 ten years, twenty years prior to the expiration of the 24 present license.
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 70 My concerns are the adequacy of 1
maintaining this plant in a safe condition for the 2
next 20 years, and if the license renewal is granted, 3
which the NRC has never even hinted at not granting 4
one, I want to assure that that plant is operated 5
safely.
6 Now it was said earlier by some of the NRC 7
representatives that their objective is to protect the 8
public health and safety, and I agree that is their 9
mission. Their mandate by Congress is to protect the 10 health and safety of the general public.
11 After working in this industry on the 12 inside, on the outside, as a consultant, as an expert 13 witness, I've come to the belief that the NRC is not 14 fulfilling their Congressional mandate of protecting 15 the health and safety of the public.
16 I'd like to provide a few examples, and 17 again it's very, very bothersome to me that I see 18 September 20th as a
deadline date for formal 19 intervention to oppose this license. Believe me, it 20 costs millions of dollars to effectively intervene in 21 opposing a license renewal application. The purpose 22 of this whole license renewal application, as was 23 stated earlier by the NRC personnel, is to assure that 24 the CLB, which is the current licensing basis, which 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 71 is defined in 10 C.F.R. 54.3.
1 The current licensing basis includes all 2
the applicable regulations, and the public needs to 3
and I believe the NRC needs to, in order to protect 4
the public health and safety, assure the public that 5
this current licensing basis is maintained for the 6
next 20 years, and if the license renewal is granted, 7
for the 20 years following that.
8 Again, I mentioned I was an expert, am an 9
expert named in Indian Point litigation related to 10 buried pipes and vital cables, and other electrical 11 devices including transformers. The current licensing 12 basis is not available. In contrast to what Jeremy 13 said, the current licensing basis includes, and he 14 said these documents were available, it includes all 15 regulations.
16 All the regulations of 10 C.F.R. Part 2, 17 Part 20, Part 26, Part 50, Part 54, Part 72 and all 18 the other regulations that are applicable to Seabrook.
19 The current licensing basis also includes such items 20 as the final safety analysis report, orders and anyone 21 can look under 10 C.F.R. 54.3 and find the definition.
22 What is really strange about the current 23 licensing basis, Mr. Pham is here and a few years ago, 24 I wrote Mr. Pham a letter. could you please identify 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 72 for Indian Point's Unit II and III what the current 1
licensing basis
- was, and what regulations are 2
applicable to Indian Point's Unit II and III.
3 His response, and again these responses 4
are public information, can be found on ADAMS. Mr.
5 Pham's response, Mr. Pham is sitting right in front of 6
me, was one can find the current licensing basis if 7
you go into ADAMS. That is not an accurate statement.
8 One cannot find the current licensing basis in ADAMS.
9 There are certain portions of the current 10 licensing basis that are not in ADAMS. The FSAR, part 11 of the current licensing basis, is not in ADAMS.
12 In the Indian Point application, a license 13 renewal application and I'd like to make a comment 14 right here, and I have reviewed various applications 15 for license renewal, that this particular one for 16 Seabrook is the most deficient application I have 17 reviewed so far.
18 Let me just provide just some contrast 19 between this application at Seabrook and Indian Point, 20 and I don't consider Entergy to be one of the more 21 superior operating companies in the country. But at 22 least their application identified things that an 23 intervener who's concerned about safety would want to 24 know about before it was able to file a meaningful 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 73 contention.
1 For instance, in the Indian Point license 2
renewal application, all the drawings that identified 3
the buried pipe that are within scope of the buried 4
pipe and tank inspection program were supplied.
5 In fact, there were about, and don't hold 6
me to this number, somewhere between 50 and 100 7
detailed drawings of Indian Point systems, and this is 8
not only mechanical systems, but also included the 9
electrical systems that were within the scope of 10 license renewal.
11 Seabrook, and I don't think I missed it, 12 but I've been wrong in the past, there are no drawings 13 that identify the buried pipes that are part of the 14 buried pipe inspection program. So I don't think 15 there could be any meaningful intervention contentions 16 filed by the present deadline, and for the NRC to 17 accept this application that is so extremely deficient 18 in reality and from an engineering standpoint, borders 19 on irresponsibility.
20 I have a few examples, and by the way, I 21 have taken a few hours to go through, I believe it was 22 somewhere around a 1,800 page document of the license 23 renewal. I would just like to point out some of the 24 technical shortcomings, and again my expertise is not 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 74 on severe accident management. It's more on systems, 1
systems interaction, mechanical systems, electrical 2
systems, cabling, requirements for cabling and so on 3
and so forth.
4 Let me -- and by the way, just for 5
informational purposes and this may be informational 6
also for the Nuclear Regulatory Commission, that 7
Congressman Markey and I believe Congressman Hodes 8
might be involved with it.
9 But Congressman Hall from New York, a few 10 other Congressmen from New York, Congressman Peter 11 Welch from Vermont have requested the GAO, which is 12 General Accountability Office, to investigate the 13 adequacy of the NRC's program for buried pipe 14 inspection program.
15 And I have been working very, very closely 16 with the General Accounting Office in identifying 17 shortcomings of the proposed programs that the NRC 18 accepts and considers adequate for buried pipe 19 inspection. And working with the GAO, we found, and 20 even though I've been working with this for three or 21 four years, we find new stuff.
22 It's interesting. It's repeated in the 23 Seabrook license renewal application. If we look at 24 the Seabrook's application, for instance, for buried 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 75 pipe, very interesting in the fact that buried is not 1
even defined within the regulation. Nobody knows what 2
"buried" means. We saw the confusion up at Vermont 3
Yankee, where they said we didn't have buried pipes.
4 Well, that resulted in some criminal 5
investigation against some people. Unfortunately, 6
some of them are friends of mine who I used to work 7
with. But buried is not defined. Does "buried" mean 8
in contact with the soil? Yes, it does mean that 9
among other things. Does it mean that if it's in a 10 pipe trench, a concrete trench that's located 14 feet 11 underground, is that considered buried? We don't 12 know.
13 Buried pipe does not necessarily include 14 piping that contains highly radioactive material.
15 Buried pipe only covers those items that are listed 16 within the scope of the license renewal, which I 17 believe is 10 C.F.R. 54.4. So buried pipes containing 18 radioactive material are not necessarily covered by 19 the license renewal application, and that is 20 reinforced by the license renewal application.
21 Another
- example, and again this is 22 something that I just found out recently, that the 23 buried pipe and tank inspection program only covers 24 carbon steel and stainless steel. It does not cover 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 76 other materials such as titanium, bronze, copper, 1
nickel, aluminum and other exotic materials that are 2
used in vital systems at the Seabrook plant.
3 So Seabrook conveniently says, and NRC 4
buys it, that it only covers steel or ferrous material 5
including cast iron. But it's not going to cover any 6
fiberglass pipe or any of the other exotic metallic 7
materials that are used in safety-related systems.
8 Now we've seen a lot of recent information 9
on cables that are, and it's interesting how when we 10 go to piping, they use the term "buried." But when we 11 go to cables, they use the term "inaccessible." Well, 12 I think we need some consistency here between piping 13 and cables. Really, the intent to protect the public 14 health and safety is it should be inaccessible piping 15 and not buried piping. There's a lot of inaccessible 16 piping.
17 But let me just move on to show and 18 demonstrate how the NRC can ignore protecting the 19 health and safety of the general public. By the way, 20 I'm not here to close Seabrook or to stop its license.
21 My only intention is to assure that Seabrook operates 22 safely for as long as it continues to operate.
23 But I've recently identified a shortcoming 24 with respect to vital cables contained within these 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 77 nuclear power plants. We have many vital cables that 1
go out to supply motor operated valves, vital motors 2
and many pieces of vital equipment.
3 The NRC has recently acknowledged that 4
some of these vital cables are running conduits that 5
are underground, and many of these conduits, and in 6
fact I've heard from the NRC 95 percent of the plants, 7
including Seabrook, these cables are submerged. May 8
be submerged under water, and at Seabrook it's even 9
worse, because that water contains high salinity 10 levels because it's right on the ocean.
11 This is a
clear violation of NRC 12 requirements that are specifically stated in 10 C.F.R. 13 50, Appendix B. So the NRC says well, Vermont Yankee, 14 where it was originally identified -- well not 15 originally identified, but recently identified in an 16 inspection report. The NRC says "It's okay to violate 17 the regulations. You can continue to operate because 18 we consider the risk to be low."
19 The NRC does not have the authority within 20 the regulations to say you can violate those 21 regulations without going through the exemption 22 process, which is under 50.12, to allow a plant to 23 continue to operate outside of the regulations of 10 24 C.F.R. 50, Appendix B. Let me just give you a few 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 78 examples of just some of the observations I found and 1
shortcomings in the license renewal application from 2
the Seabrook.
3 MS. BOWDEN-BERRY: Excuse me, excuse me.
4 Can you wrap it up in a few? Because we have about 5
five more minutes.
6 MR. SCHIDLOVSKY: I can wrap it up or I 7
can continue tonight, and in the interest of time, and 8
I know other people have very important things to say.
9 But I think this is premature, that the 10 NRC should not have accepted a license with all the 11 shortcomings, and without a clear identification of 12 the current licensing basis, which includes the 13 regulations. And contrary to what Jeremy said, those 14 regulations, especially the ASME codes, are not 15 accessible to anyone in this area and they're not 16 accessible on ADAMS. Thank you very much for your 17 time.
18 MS. BOWDEN-BERRY: Thank you, and you're 19 welcome to submit your comments. We have Dennis 20 Wagner. Again, spell your name and your affiliation, 21 and identify your affiliation.
22 MR. WAGNER: My name is Dennis Wagner.
23 I'm a citizen of Hampton. W-A-G-N-E-R. I didn't plan 24 on speaking today. I thought I'd just come and listen 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 79 for a while. I am pleased to see the diverse comments 1
that are being offered to the NRC, to guide them from 2
what we're interested in as a public.
3 I did feel compelled to make a couple of 4
comments, though. The comments that 20 years is too 5
long I disagree with. Looking at what companies have 6
to cope with, and the NRC has to regulate to go 7
through these licensees, probably 20 years is about 8
the right time. Look, you know, if you go ahead and 9
delay it until a time closer to the renewal, closer to 10 the expiration, it just allows more time for delaying 11 tactics.
12 If you're going to plan major 13 infrastructure, you need to do it in advance, and you 14 need to do it in as much in advance as you can. This 15 is reasonable. They're allowing 20 years of operating 16 experience to provide a basis on which to look at past 17 capability and look towards the future. As an 18 individual, that seems reasonable to me.
19 As far as other alternative forms of 20 energy to look at, I just spent a vacation in Maine.
21 Beautiful coastline. The potential for all the 22 megawatts of power? Give me a break. You can't get 23 wind power in Cape Cod. You're not going to get much 24 wind power to compensate for the need for energy in 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 80 this country, and in our New England states.
1 Those kinds of renewal energy are 2
important and are becoming more important, but they 3
don't stack up with the big picture. I am sick of 4
being held hostage by foreign countries for oil. I'm 5
sick of the air pollution we get from coal. Those are 6
where we get our energy in this country, close over 75 7
percent of it, okay.
8 Nuclear power is a reasonable way to go.
9 It's proven it's been reasonable in this country, and 10 it is an answer for us in the future. I am confident, 11 as I look across the marsh from my home to Seabrook 12 power plant, that it's going to continue to be a safe 13 generator of power. I'm confident in the NRC in 14 overseeing that operation, to make sure it's going to 15 stay safe for me and for my family.
16 We do make decisions in advance, 10, 20 17 years, 30 years. We all do that in our budgets, and 18 we do that as a country, and this advance planning is 19 required. Thank you.
20 MS. BOWDEN-BERRY: Thank you for your 21 comments. We want to thank all of you for your 22 comments. Our time is up, so I'm going to turn it 23 over to --
24 (Off mic comments.)
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 81 MS. BOWDEN-BERRY: Okay. Yes. Please 1
just identify yourself when you get up there.
2 MR. FLEMING: Thank you. Good afternoon, 3
for those of you -- is this the correct mic? For 4
those of you that might remember a Paul McGinnis 5
auction here, I guess I can be referred to as the next 6
number, when they allow somebody into the bidding at 7
that point. So I thank you. A little Hampton Falls 8
reference there.
9 My name is Kevin Fleming, F-L-E-M-I-N-G, 10 and I work and live in the neighborhood here of 11 Seabrook, within the ten-mile zone. That's my 12 question, is really speaking to the evacuation issue.
13 Perhaps the general counsel or maybe someone from the 14 staff could offer some perspective. But does the 15 evacuation -- we get calendars in the mail annually.
16 Does the evacuation plan and the accuracy 17 of the evacuation plan figure into the process of 18 license renewal? That's my question. I'm sorry if 19 that's something I could have found online or, you 20 know, other documents. But with that, at the same 21 time, with this license renewal then being considered, 22 then could evacuation be considered further, such as 23 the 2000 census data or does it go to a 2010? Is 24 there a requirement for updating?
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 82 And then particularly we're talking about 1
the evacuation of special, "special needs," whether it 2
be school children, retirement communities, retirement 3
homes, nursing homes, elderly, of whatever or special 4
needs people of any sort. So that's all. My question 5
coming here today is really to ask if evacuation 6
updating is required, and if it's not, then could it 7
be given consideration at this point? Thank you.
8 MS. BOWDEN-BERRY: Okay, yes.
9 (Off mic comment.)
10 MS. BOWDEN-BERRY: All right.
11 MR. PHAM: Good afternoon again. My name 12 is Bo Pham. Just to answer your question, the 13 emergency planning is an issue that we consider and 14 the need for update, you know. Our regulations 15 require the licensees, regardless of whether they put 16 in an application for license renewal, to have a plan 17 in place, and to implement that plan working with the 18 local authorities as well as FEMA, and there are 19 periodic audits and inspections that we do, to make 20 sure that they have that in place. So it doesn't --
21 it's not part of the license renewal review, because 22 it is an ongoing review that we do all the time.
23 MR. PHAM: Just to -- yes Mary.
24 MS. LAMPERT: Wait. I'll pass you the 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 83 mic. Mary. I was wondering whether you would 1
entertain any other comments, or is it cocktail hour 2
now?
3 MR. PHAM: I was going to close it out, 4
unless somebody else had a yellow card that didn't --
5 that they didn't have a chance to give us. Also, the 6
staff's going to be available for, you know, after the 7
8 MS. LAMPERT: Oh, I had a yellow card. I 9
wanted to make another comment.
10 MR. PLASSE: I think we can make -- we'll 11 hear from you. Do you want to come up here?
12 MS. LAMPERT: I just wanted -- Mary 13 Lampert, speaking for C-10, director of Pilgrim Watch.
14 I just wanted to make a comment regarding the aging 15 management program for buried pipes, tanks, components 16 within scope.
17 Currently, there seems to be a legal 18 debate on whether consideration will be given to the 19 leaking of radioactive liquids or other toxics 20 unmonitored off site. The issue seems to be that 21 currently only what will be accepted will be the 22 dysfunction, if you will, of those components as it 23 affects safety systems.
24 However logically, I'd like to bring to 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 84 your attention the potential of bringing it under the 1
environmental umbrella, because it seems clear if the 2
aging management program has not found to be 3
sufficient to monitor potential leaks going 4
unmonitored off site, then in fact it would be a 5
violation of regulation and a negative impact on the 6
environment.
7 That also should go for components that 8
are buried, if we figure out how that's defined, that 9
contain fuel from the diesel fuel tanks. I think that 10 would be another way of getting at it, if you will.
11 But the exam question is what you should be doing in 12 your review of the SEIS.
13 So I would suggest that you fill in the 14 blanks, provide a map, a list first of all the 15 components within scope that are submerged, buried, 16 what have you.
17 Second, provide a map of where they are on 18 the site. Provide to us in the SEIS information 19 regarding the age of those components, the history of 20 repairs, the results of sampling, the material that 21 they're made of, specifics such as their contours, 22 their elbows, etcetera, that would affect corrosion.
23 Also very important, provide to us, and 24 you should be looking at this yourselves actually, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 85 what hydro geo studies have been done to determine 1
where the monitoring wells are currently being placed, 2
and provide those hydro geo studies that have done 3
subsurface investigation to the public in your report, 4
and the date at which those were done.
5 So were the monitoring wells, in other 6
words, put in helter skelter, or have there been very 7
recent hydro geo studies performed? So I think this 8
can come. You can deal with these components in two 9
ways. You can bring it under the safety review end, 10 and also you should be able to bring it under the 11 environmental umbrella.
12 It belongs in the SEIS, because of the 13 potential impact of leakage going unmonitored off 14 site.
15 MS. BOWDEN-BERRY: Okay, thank you Mary.
16 We're past our time. We're going to let Mr. Pham make 17 some concluding remarks. Thank you.
18 MR. PHAM: Once again, my name is Bo Pham, 19 and I'm the branch chief at the NRC for not just the 20 Seabrook license renewal review, but of several other 21 reviews going on currently as well.
22 I just wanted to say, you know, this has 23 been one of my most enjoyable scoping meetings, 24 because as I'm sitting here listening to a lot of the 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 86 comments, you know, the thoughts are running through 1
my head, you know, how are we going to address this 2
and how do we involve or roll this into part of the 3
license renewal environmental review?
4 You know, subjects that I've heard that 5
keeps coming up is SAMAs and alternatives. I just 6
want to give you guys sort of a big picture. What's 7
going to happen next year is that Jeremy is going to 8
take your comments back to our staff. He's going to 9
sit down with our technical reviewers, as well as 10 contractors that we have as well, to take a look at 11 the issues and see how we can address them as part of 12 the environmental review.
13 Now a few of the comments, I've got to 14 say, are policy issues. The one that kept coming up 15 was the 20-year issue, and just to clarify, the 16 purpose of putting that slide on there was because we 17 had several questions about it prior to the meeting.
18 What Rick was trying to portray, excuse 19 me, the message from that slide wasn't coming from, 20 you know, is it too early or not too early? It was 21 simply a reiteration of what the Commission had 22 considered when it came up with the rule for license 23 renewal.
24 So the 20-year time frame was to say -- it 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 87 wasn't to -- it didn't have any consideration of 1
whether it was too early or not, okay. Now that, you 2
know, I appreciate hearing about the petition that's 3
been put in, that's what the rulemaking process is 4
for.
5 So I definitely hear you guys, and we 6
acknowledge that that is something to consider.
7 That's on the table now and has been petitioned for 8
the Commission to consider. But not to punt the 9
issue, but really that decision needs to be made at 10 the Commission level and not the staff level.
11 The other thing I wanted to talk about 12 was, you know, we'll talk -- we can talk more, but I 13 just want to confirm that when Mr. Blanch said that 14 currently there's a violation at the plant, as I 15 understand, there are no current violations with 16 respect to the cables at the plant. Do we have a 17 violation on record right now?
18 PARTICIPANT: Yes, we do. Yes, we do.
19 (Off mic comments.)
20 MR. PHAM: Okay, so I just want to make --
21 is the plant operating? You know, is it in a 22 violation condition as we hear today? So I think 23 there are issues to be clarified regarding the cable 24 issues, and the staff is available to talk about it 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 88 afterwards. But big picture, we're here to hear you 1
from an environmental scoping perspective.
2 We definitely heard some very good 3
comments regarding that, and so we'll look forward to 4
get back with you in that process. So thank you for 5
taking the time to come today.
6 (Whereupon, at 3:40 p.m., the public 7
meeting was concluded.)
8 9
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