ML13317A029
| ML13317A029 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/26/2013 |
| From: | Brian Benney Plant Licensing Branch IV |
| To: | Peter Dietrich Southern California Edison Co |
| Benney B | |
| References | |
| Download: ML13317A029 (148) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting to Discuss the Decommissioning Process at San Onofre Nuclear Generating Station Docket Number:
50-361 and 50-362 Location:
Carlsbad, California Date:
Thursday, September 26, 2013 Work Order No.:
NRC-362 Pages 1-148 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
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3 PUBLIC MEETING TO DISCUSS THE 4
DECOMMISSIONING PROCESS AT 5
SAN ONOFRE NUCLEAR GENERATING STATION 6
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7 THURSDAY 8
SEPTEMBER 26, 2013 9
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10 CARLSBAD, CALIFORNIA 11
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12 The Public Meeting convened at the Omni La 13 Costa, 2100 Costa Del Mar Road, Carlsbad, California, at 14 6:00 p.m., Chip Cameron, Facilitator, presiding.
15 16 17 18 19 20 21 22 23 24 25
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NRC STAFF PRESENT:
1 CHIP CAMERON, Facilitator 2
LARRY CAMPER, Director, Division of Waste Management 3
and Environmental Protection, FSME 4
BRUCE WATSON, Chief, Reactor Decommissioning Branch, 5
FSME 6
BLAIR SPITZBERG, Chief, Repository and Spent Fuel 7
Safety Branch, RIV 8
MIKE DUSANIWSKYJ, Financial Analyst, Financial 9
Analysis and International Projects Branch, NRR 10 BOB EVANS, Senior Inspector, NRC 11 RYAN LANTZ, Chief, Region IV Reactor Projects Branch 12 D, NRC 13 PAUL MICHALAK, Chief, Environmental Impact Statement 14 Branch, Waste Confidence Directorate, NRC 15 16 17 18 19 20 21 22 23 24 25
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T-A-B-L-E O-F C-O-N-T-E-N-T-S 1
Welcome, Agenda and Ground Rules for Q&A Session 2
(Chip Cameron, Facilitator).................. 4 3
NRC Decommissioning Overview (Larry Camper)........ 9 4
Reactor Decommissioning Process 5
(Bruce Watson).............................. 21 6
Decommissioning Inspection Program 7
(Blair Spitzberg)........................... 32 8
Decommissioning Funding (Mike Dusaniwskyj)........ 41 9
Spent Fuel Management (Blair Spitzberg)........... 44 10 Questions and Comments from Members of the Public 11 (Chip Cameron).............................. 50 12 Brief Recess...................................... 75 13 Questions and Comments Continued.................. 77 14 Meeting Adjourned 15 16 17 18 19 20 21 22 23 24 25
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P R O C E E D I N G S 1
(6:21 p.m.)
2 MR. CAMERON: My name is Chip Cameron and I'd 3
like to welcome you to the public meeting tonight. And 4
the topic for tonight is the Nuclear Regulatory 5
Commission.
6 I'm going to use the term and I think 7
everybody else will use "NRC," but we'll try not to use 8
acronyms tonight except for that one or others that are 9
easily understood, but it's the NRC's decommissioning 10 process.
11 And specifically, NRC's decommissioning 12 process relative to SONGS Unit 2 and 3, San Onofre Nuclear 13 Generating Station.
14 And it's my pleasure to serve as your 15 facilitator tonight. And I'm going to be assisted by Bob 16 Hager who is in the back of the room.
17 And Bob is a certified facilitator in the 18 NRC's facilitator program. And what Bob and I are going 19 to do is to try to help all of you to have a productive 20 meeting tonight.
21 I just wanted to cover a few items on the 22 process for the meeting so that you know what to expect 23 tonight. And I'd like to talk about the objectives for 24 the meeting, the format for the meeting, go over some 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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simple ground rules with you for the conduct of the 1
meeting and then introduce the NRC speakers who are up 2
here in front of you and what their topics are going to 3
be.
4 In terms of objectives for the meeting, the 5
NRC's primary objective tonight is to give you clear 6
information on NRC's decommissioning process.
7 And these are the rules that the NRC and the 8
licensee, in this case Southern California Edison, these 9
are the rules that the NRC and the licensee has to follow 10 over the course of the decommissioning of the reactors.
11 We'll also try to provide you with 12 information on specific aspects of the SONGS facility's 13 decommissioning and we're going to provide that 14 information to you in two ways.
15 One is we have a number of presentations 16 from the NRC staff, and then we're going to answer any 17 questions that you might have about the decommissioning 18 process after the NRC staff is done with their 19 presentation. And that's the format, presentations, 20 and then question/answer with all of you.
21 Now, some simple ground rules for the 22 meeting tonight. I would just ask you to hold all of your 23 questions until we get done with the NRC presentations 24 so that you'll have a complete picture before we go on 25
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to you for questions.
1 And I would just thank you for your patience 2
in advance. It's not an overly long set of 3
presentations, but it will take some time because the NRC 4
wants to give you as much information as possible.
5 When we go on to you for questions, just 6
signal me and I will bring you this cordless microphone 7
or Bob Hager back there will bring you the cordless 8
microphone. And just please introduce yourself to us 9
and ask your question, or make a comment.
10 I would just ask you to be brief so that we 11 can make sure that we get to everybody who wants to talk 12 tonight.
13 We don't have as big a turnout as we were 14 planning for. So, that may give us more time tonight, 15 but I would ask you to be brief. And I would also ask 16 you to follow the rule of only one person at a time 17 speaking. We want to give our full attention to whomever 18 has the microphone at the moment.
19 As I mentioned, the objective of the meeting 20 is to give you information on the NRC decommissioning 21 process, but we realize that there is broader concerns 22 in relationship to SONGS than just decommissioning and 23 we want to try to answer questions that you might have 24 on any of those broader concerns.
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They may not be in-depth answers, but we do 1
want to try to address those questions, but the primary 2
focus is on the decommissioning process.
3 And I mentioned that the way we're going to 4
get the information to you is through the presentations 5
and through answering your questions. That doesn't mean 6
that if you have a concern or a comment that you want to 7
give the NRC that you can't make a comment. Okay?
8 It doesn't have to be a question, but I would 9
just say that tonight is not the night for long speeches 10 on anything. And let me introduce the NRC staff that's 11 going to be speaking to you tonight.
12 First we're going to go to Larry Camper who 13 is right here. And he's the director of the Division of 14 Waste Management and Environmental Protection in the NRC 15 Office of Federal, State and Environmental Management.
16 And that's a headquarters office in Rockville, Maryland.
17 And Larry is going to give you a broad overview of the 18 reactor decommissioning process.
19 After that, we're going to get into a little 20 bit more depth and we're going to go to Bruce Watson who 21 is right here.
22 And Bruce is the chief of the Reactor 23 Decommissioning Branch in Larry Camper's division also 24 NRC headquarters in Rockville, Maryland.
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Next we're going to go to Blair Spitzberg.
1 And Blair is the chief of the Fuel Safety and 2
Decommissioning Branch in NRC's Region IV. And that's 3
one of four regional offices. And that one is in 4
Arlington, Texas. And Blair is going to talk to you 5
about the NRC inspection program for decommissioning 6
reactors.
7 And we know there's going to be a lot of 8
interest in how the NRC inspects what's going on during 9
the decommissioning process.
10 After Blair is finished, we're going to go 11 to Mike Dusaniwskyj who is up here. And Mike is an 12 economist. And he's in the Decommissioning - well, he's 13 in the Financial Analysis and International Projects 14 Branch in the NRC's Office of Nuclear Reactor Regulation, 15 also NRC headquarters Rockville, Maryland. And he's 16 going to talk to you about decommissioning funding, 17 because we know that that's also of interest of you.
18 Then we're going to go back to Blair 19 Spitzberg who is going to talk to the NRC regulation of 20 spent fuel storage at the San Onofre facility.
21 And I think we're ready to go to Larry.
22 We'll go through all the presentations, and then we'll 23 be back to you for question and answer.
24 Larry.
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MR. CAMPER: Thank you, Chip. Good evening, 1
everyone. Thanks for coming out tonight and 2
participating in this important meeting and taking time 3
out of your busy schedule. And I must tell you it really 4
is a pleasure to be here with you. This is a beautiful 5
place that you live. So, really, it's a nice spot. So, 6
it's a pleasure to be here.
7 I am Larry Camper, the director of the 8
Division of Waste Management and Environmental 9
Protection.
10 As Chip said, I do have responsibility and 11 my staff has responsibility for the decommissioning for 12 the Nuclear Regulatory Commission, including nuclear 13 power plants. And so, we do hope to share some 14 information with you this evening about that process and 15 answer your questions.
16 As Chip said, though, we also want to make 17 ourselves available to answer other questions you might 18 have. There's been a lot of interest around this 19 particular site and we understand there may be some other 20 things you'd like to hear about and we'll try to answer 21 those issues at least briefly.
22 I'm joined by a lot of NRC staff. And I'd 23 really like the NRC staff that are with me this evening 24 to stand up.
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 I do this because we wanted to bring 1
expertise to bear. We felt this meeting was important 2
enough to have the right people here. We have people 3
from headquarters, from the regions, Region IV, and we 4
thank them for being here.
5 And over the course of the evening, some of 6
them will be participating. Thanks, guys. We can sit 7
down and take it easy, but over the course of the evening 8
some of them will be joining in with answers to questions.
9 We will take a break. You can catch one of 10 them if you have a question that you don't want to go 11 through the trouble of having the microphone in your 12 face, but you can say, hey, I'd really like to know 13 something more about that. So, they're all here and 14 they're all willing to talk to you.
15 We also have some folks from California.
16 We actually have people here from the California Public 17 Utility Commission, the California Energy Commission, 18 the California Coastal Commission, the California 19 Department of Public Health, California Emergency 20 Services and also representatives from the United States 21 Navy because of Camp Pendleton.
22 And so, some of them are here this evening 23 because there may be questions that you have that are not 24 within the NRC jurisdiction. And so, we want to have 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 11 right type of expertise here to turn to for those kinds 1
of questions as well.
2 So, we thank all of those folks for being 3
here from the State of California and their various 4
organizations and we'll turn to them as need be, or they 5
may even hear a question and they know it's best for them 6
to be involved.
7 Okay. What I want to start with is our 8
mission. The slide you see in front of you depicts the 9
NRC's mission which is to regulate the Nation's civilian 10 use of radioactive materials, to protect public health 11 and safety, promote common defense and security and 12 protect the environment. That is our mission.
13 When a facility such as nuclear power plants 14 and other nuclear facilities are operating, it remains 15 our mission during the decommissioning of nuclear 16 facilities.
17 First and foremost our mission is safety.
18 We are an independent Federal regulator and our business 19 is all about protecting public health and safety. That 20 will remain throughout the process of decommissioning 21 until it is complete.
22 What you see in front of you is the 23 regulation that cites our decommissioning criteria. It 24 doesn't matter about that. What is important 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 12 explained to you when we use the term "decommissioning,"
1 what does it mean?
2 It means to remove a facility, in this case 3
a nuclear power plant, safely from service and reduce 4
radioactivity to a level that allows either release of 5
that property for unrestricted use and termination of the 6
license or reduction of the license in the case of a 7
nuclear power plant to spent nuclear fuel storage, or 8
release of the property under restricted conditions and 9
termination of the license.
10 I will point out that while our regulations 11 for decommissioning allow restricted release, no nuclear 12 power plant that has been decommissioned in the United 13 States has pursued restricted release. All have been 14 successfully completed using unrestricted release.
15 The slide that I have here for you is 16 designed to share with you the kind of scientific and 17 technical expertise that will be brought to bear by the 18 Nuclear Regulatory Commission as we address the 19 decommissioning of SONGS 2 and 3.
20 You'll see that there is a lot of different 21 expertise such as mechanical engineers and chemical 22 engineers and geologists, mathematicians, biologists, 23 environmental engineers and so forth and so on. And the 24 point is all of this expertise is brought to bear 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 13 decommissioning of our nuclear facilities including what 1
takes place on the site that we're here to discuss 2
tonight.
3 I
would also point out that the 4
decommissioning staff that Bruce directs as the branch 5
chief has over 300 years of cumulative professional 6
expertise in dealing with the decommissioning of nuclear 7
power plants. So, we hope that that will inspire some 8
confidence in our decommissioning process and you can 9
have some realization of the type of expertise and the 10 experience that will be brought to bear and the oversight 11 of the decommissioning of the SONGS facility.
12 This slide depicts the successful 13 decommissioning completions that have taken place over 14 the last 15 years. A lot of information to try to absorb, 15 but I'll summarize it for you.
16 There have been 50 materials licensee 17 sites. Materials licensee sites are sites that, for 18 example, processed or produced uranium or thorium for 19 various industrial uses.
20 We have decommissioned 11 nuclear power 21 plants, 13 research and test reactors and a large number 22 of uranium recovery facilities. On the order of 80 sites 23 have been decommissioned successfully over the past 15 24 years under Nuclear Regulatory Commission oversight.
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 What we have here is a list of the nuclear 1
power plants that have been decommissioned. I mentioned 2
a moment ago that there were 11 of them.
3 You'll see that the ones that are depicted 4
in yellow have been depicted under what's called the 5
License Termination Rule which went into effect in 1997.
6 The ones in white below that were 7
decommissioned by an earlier standard before our 8
existing standard in the License Termination Rule. That 9
rule is the standard by which the decommissioning will 10 take place at the SONGS facility. So, 11 nuclear power 11 plants in the United States decommissioned thus far.
12 What we have here is key decommissioning 13 milestones. Now, Bruce in his presentation will go into 14 the process in considerable detail, but I thought it was 15 worthwhile to at least share with you some of the major 16 milestones you can begin to think about and be aware of 17 as Bruce goes through this presentation.
18 First you'll see that there are two 19 certifications that have to be filed by the utility. A 20 certification whereby there has been a permanent 21 cessation of operations, and a certification where the 22 nuclear fuel has been permanently removed from the 23 reactor. Both of those have been filed by the utility 24 operating the SONGS facility.
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 Next is a Post Shutdown Decommissioning 1
Activities Report. A PSDAR you will hear us say and 2
refer to.
3 Then comes decommissioning and 4
environmental remediation. I have that activity 5
highlighted in yellow, as well as a little bit further 6
down, the final status survey, because that represents 7
activity that takes place on the site. That's not a 8
submission to the Nuclear Regulatory Commission.
9 That's actual remediation and decommissioning of the 10 facility.
11 There is a requirement that a license 12 termination plan be submitted along the way. Of course 13 the final status survey whereby the operator of the 14 utility is ensuring through surveys that the dose 15 standard that I'll mention to you in a moment is, in fact, 16 satisfied.
17 The Nuclear Regulatory Commission also does 18 a confirmatory survey of the results within the final 19 status survey.
20 And last, but not least, is either a 21 termination of the Part 50 license - Part 50 is that part 22 of our regulations under which nuclear power plants are 23 regulates - or as is more common today, the license is 24 shrunk in size to the footprint of the remaining 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 independent spent fuel storage installation.
1 In terms of release criteria, I mentioned 2
that there are two possible pathways for release of any 3
facility that undergoes decommissioning, including 4
nuclear power plants. There's unrestricted release, 5
and restricted release.
6 As I mentioned, no nuclear power plant thus 7
far has gone for restricted release for a myriad of 8
reasons. All have pursued unrestricted release 9
although they certainly could pursue restricted release.
10 There's a lot of information on this slide, 11 but I want to draw your attention to just two points.
12 The dose criteria that we use in this 13 regulation is referred to as total effective dose 14 equivalent of equal to or less than 25 millirem and as 15 low as reasonably achievable.
16 In other words, the site must be cleaned up 17 to satisfy that dose standard and the licensee must 18 demonstrate that the level to which it has cleaned up the 19 site is, in fact, as low as reasonably achievable based 20 upon a rather sophisticated cost benefit analysis.
21 Now, when you see and you hear 25 millirem, 22 what does that mean? Can I understand what he's saying 23 when he says 25 millirem?
24 Well, let me put it into perspective. When 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 you get in an airplane in Los Angeles and fly across the 1
country to New York, you receive about 3 millirem of 2
exposure from cosmic radiation.
3 In the United
- States, the natural 4
background radiation including exposure from medical 5
radiation is on the order of 300 to 600 millirem per year 6
depending upon where you are in the United States.
7 There are places in the world with a natural 8
background radiation, Saskatchewan, Canada comes to 9
mind, for example, where the natural background 10 radiation is 4,000 millirem per year.
11 So, hopefully now when you see 25 millirem 12 and you hear about it in the months to come as we talk 13 about the decommissioning standard, at least you'll have 14 some perspective of what that number means.
15 Tonight for our public meeting I'll be 16 giving you the decommissioning overview. Of course 17 Bruce will talk about the reactor decommissioning 18 process. Blair Spitzberg will talk about the inspection 19 plan. Michael Dusaniwskyj will talk about the 20 decommissioning funding. Blair will then come back and 21 talk about spent fuel management and then of course we'll 22 go to questions and answers and dialog.
23 I would reiterate that these are the primary 24 topics and the purpose for our meeting tonight, but 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 18 also recognize as Chip said and I said earlier and would 1
repeat now, there are other things you might want to talk 2
about.
3 And we'll do the best we can to at least give 4
you brief answers and help us to the extent that we can 5
stay on the purpose of the program, but we're here to 6
answer your questions about other issues as well.
7 In terms of the decommissioning inspection 8
program, you'll hear a lot about this. We do remain very 9
engaged during the decommissioning process and we'll 10 give you some clarification as to the level of resources 11 that will be involved during that process.
12 We also know that another topic that's on 13 people's minds these days is the Waste Confidence 14 Decision Rulemaking and Environmental Impact Statement 15 that the Nuclear Regulatory Commission is currently 16 working on.
17 We do have a representative here from the 18 Waste Confidence Directorate this evening that can 19 answer some questions if that comes up. So, I think we 20 can give you some insights into that as well.
21 Public involvement. Clearly you're very 22 concerned about public involvement and, again, I want to 23 thank you for being here and taking part in what we 24 consider to be a very important part of our regulatory 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 program.
1 The meeting this evening that we're 2
conducting is not required by our regulations, but we 3
felt it was important to be here.
4 Our chairman is very interested in 5
conveying information, our management is very interested 6
in conveying information, our entire organization wants 7
to convey as much information as we can to the community 8
here, because there's been a lot of very challenging 9
issues and we know that you've had a number of concerns 10 and a lot of interest. So, we decided to hold this 11 process meeting for that purpose.
12 There is a meeting that will take place once 13 the Post Shutdown Decommissioning Activity Report is 14 submitted by the utility. That's required by our 15 regulations.
16 There is a public meeting that will take 17 place once the License Termination Plan is submitted by 18 the utility. That's again required by our regulations.
19 And because the decommissioning program and 20 the approval of the License Termination Plan involves an 21 amendment to the existing license for the utility, there 22 is the opportunity for a hearing within our adjudicatory 23 process as well. So, there are a number of opportunities 24 for public awareness and public involvement along the way 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 with the decommissioning process.
1 So, I'll stop there and later on will 2
entertain questions, of course. And Bruce Watson, our 3
branch chief for the Decommissioning Branch for Nuclear 4
Power Plants will provide more detail into the areas that 5
I've just touched upon lightly. Thank you very much.
6 MR. WATSON: Well, good evening and thank you 7
for being here. I am Bruce Watson. I'm chief of the 8
Reactor Decommissioning Branch. I'd like to discuss 9
some of our current activities and their requirements for 10 decommissioning nuclear power reactors.
11 I want you to keep in mind that we regulate 12
- the NRC regulates the radiological decommissioning of 13 these sites.
14 There may be other requirements in the 15 decommissioning requirements that were beyond what the 16 NRC requires and those will be addressed by other 17 regulators.
18 In 2013, four power reactors permanently 19 ceased operations and are transitioning from operating 20 status, which is managed by our Office of Nuclear Reactor 21 Regulation and will be transferring to my office and 22 FSME.
23 Each of these reactors are at various stages 24 of decommissioning and are transitioning at their own 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 rate.
1 In 1997, the NRC implemented 10 CFR 20 2
Subpart E, which is commonly known as the License 3
Termination Rule.
4 It establishes the release criteria for 5
unrestricted and restricted release that Larry Camper 6
just covered.
7 These rules that I'm going over took into 8
account the decommissioning experience we gained from 9
our decommissioning at Saxton and Fort St. Vrain in 10 Colorado.
11 To date, all US reactors had been 12 unrestricted released for use, which means they can be 13 used for any purpose. And this regulation is a 14 risk-informed dose base regulation.
15 10 CFR 50, specifically 10 CFR 50.82 is the 16 License Termination Requirements for power reactors.
17 I'm going to discuss this rule in a regulation in great 18 detail this evening.
19 (Pause in the proceedings.)
20 MR. WATSON: Part 72 deals with the 21 Independent Spent Fuel Storage Installation License, 22 licensing of the ISFSI. It's an important regulation, 23 because it's where the spent fuel goes during the 24 decommissioning process.
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 All right.
The NRC offers three 1
decommissioning options in our guidance, but only two of 2
those have been implemented to date.
3 DECON, or prompt remediation is what it's 4
called in international terms, decommissioning begins 5
shortly after the licensee has prepared the plant for 6
decommissioning.
7 Like I said, we currently have four reactors 8
in DECON; the plant at Humboldt Bay in California, Zion 9
1 and 2 in Illinois and La Crosse in Wisconsin.
10 Regardless of the strategy chosen by the 11 licensee, the preparation for decommissioning typically 12 takes one to two years in order to get the plant prepared 13 for decommissioning.
14 During this time period, the plant will be 15 set up so that the systems are drained, electrical 16 connections are de-energized and that it would 17 facilitate decommissioning and this does take some time.
18 The plant also may include some 19 modifications that will facilitate future 20 decommissioning of the plant.
21 During this time frame, the NRC will 22 generally keep one of the resident inspectors at the site 23 for about a period of a year. And that's to ensure that 24 all the operational issues that were under review during 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 the process of shutting down are maintained compliant and 1
to make sure that any plant modifications are maintained 2
safely.
3 In the SAFSTOR, or deferred dismantling 4
mode, the plant is placed in safe storage, as we would 5
call it, cold and dark, until the licensee decides to 6
dismantle the plant and the decommissioning of the plant 7
can begin.
8 The licensee may perform some 9
decommissioning activities during this time frame and 10 the NRC will inspect the plant periodically, at least 11 annually, or if the plant is doing some significant 12 decommissioning activities, we will inspect the plant 13 more frequently.
14 Although entombment is an option in our 15 guidance, no power reactors have opted for this option.
16 No US NRC licensed reactors had been entombed, nor have 17 any licensees requested entombment. So, it's really not 18 an option at this point.
19 Our regulations in 10 CFR 50.82 for power 20 reactors are performance-based, they are flexible, and 21 they require that the licensee complete the 22 decommissioning in 60 years.
23 I know you may ask why 60 years. Again, the 24 basis for that 60-year requirement allows the radiation 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 doses to significantly decrease to about one percent of 1
those which they were when the plant originally shut 2
down.
3 This represents significant radiation 4
exposure savings to the workers who will conduct the 5
decommissioning.
6 It will also reduce the biome of radioactive 7
waste to about ten percent of what it was when the plant 8
was shut down. This is due to radioactive decay.
9 Some of the principal radionuclides in that 10 such as Cobalt-60 will have gone through numerous half 11 lives, approximately ten, where the radiation levels are 12 reduced and the amount of radioactivity is significantly 13 minimized.
14 During this period the Decommissioning Fund 15 can also increase since it's invested and can increase 16 by compound interest.
17 Coincidentally, this 60-year also 18 corresponds to the 20-year license extension for 19 multi-unit facilities. So, the operator can focus on 20 safe operation of the remaining units.
21 This is, in particular, specific to San 22 Onofre, because San Onofre 1 was in SAFSTOR for quite a 23 while. Then, the utility elected to decommission it.
24 It's complete other than the reactor vessel still being 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 onsite and there was a
significant physical 1
differentiation between the operating units in it that 2
allowed that to be done very safely.
3 The NRC policy is that the decommissioning 4
can be formed Day 1 after the plant shuts down and is ready 5
for decommissioning, or at the 50-year point. Because 6
the 60-year point year point takes into 7
consideration it will take seven to ten years to complete 8
the decommissioning.
9 Again, some of the decision factors 10 licensees use in determining the decommissioning 11 strategy whether it's a multi-unit site as I just 12 discussed, the ability to have the financial fund 13 available - this is important for plants that are 14 prematurely shut down - whether there is access to the 15 radioactive waste disposal capacity, the actual future 16 use of the site - some of these sites are very valuable 17 to the utility in that they do put new generating capacity 18 on the site and this has happened at many of the 19 single-unit facilities.
20 Decisions also that affect the 21 decommissioning strategy are input from the 22 stakeholders. There is a new business model out there.
23 I will let you know that we're - the utility basically 24 transfers the license to a decommissioning company who 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 does the decommissioning and then returns the fuel and 1
the site back to the utility. This is the current model 2
at Zion.
3 There may be other special circumstances 4
which will affect the licensee's decision on the 5
strategy. Such a special circumstance would be the - for 6
SONGS, would be the US Navy's lease with the utility.
7 There are a number of certifications that 8
come about from the - that are required from - in the 9
initial stages of the decommissioning.
10 First, the licensee will certify that the 11 NRC that within 30 days they will be permanently shutting 12 down. The second certification is that the fuel has been 13 permanently removed from the reactor vessel.
14 At this point, the - after this is 15 completed, the licensee is no longer permitted to operate 16 the reactor or put fuel back in the vessel.
17 Within two years the licensee is required 18 to submit the Post Shutdown Decommissioning Activities 19 Report. As we call it, it's the PSDAR. And that is 20 required to be, like I said, required to be submitted to 21 us two years after cessation of operations.
22 What's in the PSDAR? Well, it basically is 23 comprised of three things. It's a description and 24 schedule for the planned decommissioning activities.
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 And it describes the strategy that the utility will take 1
for decommissioning.
2 It includes an estimate of the expected 3
decommissioning costs and a discussion on the means for 4
concluding that the environmental impacts associated 5
with the decommissioning have not changed.
6 The NRC will notice the PSDAR in the Federal 7
Register. We will hold a public meeting to discuss the 8
PSDAR and solicit comments from the public.
9 I want to point out that we do not approve 10 the PSDAR. It is merely a letter to us with specific 11 requirements in the regulations that they are to report 12 to us on what their plans are for the site. The licensee 13 may begin decommissioning 90 days after the NRC receives 14 the PSDAR.
15 The next step in the process is that the 16 power reactor - the licensee will perform the 17 decommissioning.
18 The NRC will continue to conduct 19 inspections, as I mentioned. The licensee will submit 20 to us within two years of when they plan to terminate -
21 request termination of the license, the License 22 Termination Plan. And we'll talk about that in much 23 later detail.
24 But in the meantime, the plant can be - can 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 conduct decommissioning activities within the current 1
license that it - within the license that is issued once 2
the plant is fully defueled. And those are called the 3
defueled tech specs.
4 We will hold a public meeting to discuss the 5
LTP and solicit your comments. And we will also submit 6
- publish that in the Federal Register.
7 What's in the LTP? Well, the LTP is a very 8
large document. It contains a lot of technical detail 9
on how the plant will be decommissioned, finish the 10 decommissioning. It will contain a lot of radiological 11 data, including some dose modeling, and the licensee's 12 plans to complete the site remediation.
13 Probably one of the most important things 14 in the LTP is the description of how the - the detailed 15 plans on how the licensee will conduct the final status 16 surveys or the final surveys of the site to demonstrate 17 that it meets the license criteria.
18 The License Termination Plan contains a 19 description of the end use of the site if the site is going 20 to be restricted use.
21 As I said before, none of the power reactors 22 have requested a restricted use as a final state. All 23 of them have been decommissioned to unrestricted release 24 criteria.
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 29 It also will contain an updated 1
site-specific estimate of the remaining decommissioning 2
costs and of course it will supplement the - any 3
supplement to the Environmental Report that was 4
previously issued.
5 the NRC will conduct a full review of the 6
LTP. Initially we will conduct an acceptance review 7
basically to make sure that the major components of the 8
LTP are in the LTP. And then we will perform a detailed 9
technical review. That detailed technical review will 10 take approximately a year to do.
11 If there is missing information or 12 clarifications required, we will issue additional 13 information - request for additional information. And 14 we will hold public meetings - a public meeting. And 15 also with this since it is a major licensing action, the 16 public also has the opportunity for a hearing.
17 Eventually if the LTP meets all our 18 requirements, the NRC will approve the LTP by amending 19 the license. So, the LTP basically becomes part of the 20 license.
21 The licensee will perform the remaining 22 decommissioning activities and we will perform 23 inspections, including independent in-process and 24 confirmatory surveys to verify the licensee's results.
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 30 We also employ a
contractor, Oak 1
Ridge-Associated Universities, as an independent group 2
to do surveys to verify compliance with the radiological 3
criteria.
4 At the end of the decommissioning, the 5
licensee will submit to us the final Status Survey 6
Reports. They describe the radiological condition in 7
which the site was left.
8 We will continue to perform confirmatory 9
surveys. And if they meet our criteria, we will approve 10 the Final Status Survey Report. We will terminate the 11 license by letter and notice the action in the Federal 12 Register.
13 Keep in mind that the license termination 14 will only occur when the licensee demonstrates to us that 15 they have met the radiological criteria required in the 16 License Termination Plan which is consistent with the 17 regulations.
18 I would just like to briefly discuss the 19 status of San Onofre 2 and 3. Here are the key 20 decommissioning milestones.
21 Obviously the first two were met. And as 22 I mentioned, the deadline for the SONGS PSDAR is actually 23 two years after the shutdown date, which is June 7th, 24 2015. We understand that the licensee has plans 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 31 hopefully do that in 2014.
1 We will notice the PSDAR when it is sent to 2
us to - in the Federal Register and we will hold another 3
public meeting. And of course when the LTP is submitted, 4
we also do the same.
5 One of the key features that happens within 6
the NRC is the transfer of the inspection program.
7 During operations the plant is under the 8
Reactor Oversight Program. It will be transferred to 9
what we call Inspection Manual 2561, which is the Reactor 10 Decommissioning Inspection Program.
11 And Blair Spitzberg will give you some 12 information on that. Thank you.
13 MR. SPITZBERG: Good evening. My name is 14 Blair Spitzberg and I'm the chief of the Fuel Safety and 15 Decommissioning Branch in the Region IV office in 16 Arlington, Texas.
17 Some of you may be aware of the fact that 18 the NRC has four regional offices. And the purpose of 19 these offices were very interesting and it's a very good 20 decision that was made years ago by the Commission to 21 establish regional offices for the basic purpose of 22 conducting the inspections programs associated with our 23 licensees.
24 It's important to do adequate safety 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 reviews and to license the licensees to undertake the 1
activities that they undertake.
2 In the regional offices where we do 3
inspection, we believe in the axiom of a former president 4
from California, trust, but verify. And that's what we 5
do as inspectors.
6 My inspection branch is a small group of 7
health physicists and engineers and we do inspections of 8
both the decommissioning activities at reactors and 9
non-reactor sites. We also inspect spent fuel storage 10 installations. And we inspect, as well, some fuel cycle 11 facilities.
12 Now, let me show a picture of some sites here 13 that I think would be of interest. On the left you see 14 four sites. And there's a number that - Larry went 15 through a number of them showing reactor sites throughout 16 the country.
17 And on the right-hand side is an aerial 18 photograph showing what they look like at the end of the 19 decommissioning process.
20 As you can see, Connecticut Yankee 21 basically removed the entire site and went to a 22 greenfield, as did Maine Yankee.
23 We show the Trojan, Oregon site there which 24 was decommissioned in Region IV a number of years ago.
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 33 And as you can see on the photograph there 1
at San Onofre Unit 1, you may be aware of the fact that 2
there was another operating reactor at San Onofre years 3
ago and they were successfully decommissioned with the 4
exception of the reactor vessel which remains onsite.
5 So, asking the question how NRC ensures 6
safety, as we mentioned and Bruce went through in detail, 7
we establish and ensure compliance with the requirements 8
contained in the regulations, in a number of different 9
safety standards that pertain, decommissioning and 10 storage of spent fuel, and then we also write license 11 conditions and technical specifications that the 12 licensee has to comply with.
13 And all of this is done in the licensing 14 process performed in Washington where they undertake 15 these safety evaluations and all those are subject to 16 public input.
17 And then finally as the inspection 18 enforcement, and that's what we do in the regional 19 offices, we have a - our regional office staff numbers 20 in excess of 150 safety professionals that do various 21 inspections not only of the operating reactors, but of 22 the decommissioned reactors and the nuclear materials 23 licensees that are located basically west of the 24 Mississippi River. That's a large geographic region.
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 Some of the inspection activities that will 1
be undertaken at San Onofre now that it is permanently 2
defueled and in decommissioning status, is that we will 3
continue to perform inspections of spent fuel pool 4
safety. Because as you know, there's a number of spent 5
fuel assemblies that are still in storage in pools at Unit 6
2 and 3. We'll continue to inspect those.
7 We'll perform decommissioning inspections 8
out here and most of those will be intense during the 9
periods of dismantlement, which probably will not occur 10 for some period of time. But once they start actually 11 dismantling and cutting up systems and deconning the 12 facility, we'll be out here on a regular basis, but will 13 continue to do programmatic inspections up until that 14 time.
15 It's important to note that during the 16 remediation activities the NRC conducts independent 17 radiological measurements. And the purpose of this is 18 to confirm the licensee's results.
19 We inspect the radiological measurements 20 that the licensee performs. We observe them doing the 21 measurements, and then we'll do our own measurements.
22 And in some cases we'll bring out independent 23 laboratories that are contracted to the NRC to perform 24 independent measurements to verify the accuracy 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 35 licensee's results. And this has been very successful 1
in our inspection program.
2 As I mentioned, we also inspect the safety 3
of the independent spent fuel storage installation, and 4
I'll discuss that in my next presentation in a few 5
minutes. And then we also continue to inspect the 6
physical security program at the site.
7 So, what are the objectives of the 8
inspection program?
Basically it's very 9
straightforward.
10 It's to verify safe conduct of the licensee 11 activities. And we've looked at the adequacy the 12 licensee controls, we ensure that safety problems and 13 violations are properly identified and that they're 14 corrected and that effective actions are taken to prevent 15 recurrence.
16 And then we also examined trends in licensee 17 safety performance. And this is something that's very 18 important particularly at - well, at all plants, but we 19 find it important to decommissioning plants as well, 20 because decommissioning plants the licensees quite often 21 will bring in contractors that have special expertise in 22 decommissioning activities.
23 And so, as these contractors come in even 24 though they're regulated under the licensee's program, 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 we find that we have to look at trends in their 1
performance as well.
2 Next are some of the inspection procedures.
3 These are the core inspection procedures that we will 4
implement during and throughout the inspection program 5
for the decommissioning.
6 They cover everything from the 7
organizational, management and cost controls, the safety 8
reviews, any design changes and modifications to the 9
plant that will be made, the licensee's QA program that 10 includes self-assessments, audits and corrective 11 actions, the safety of the spent fuel, the radiation -
12 occupational radiation exposures to the workers, 13 inspection of final surveys, the radioactive waste 14 treatment, effluent and environmental monitoring 15 program, the transportation of radioactive materials off 16 site, a lot of waste material will be packaged and 17 transported to waste disposal sites out of state mostly, 18 the maintenance and surveillance program, physical 19 security and the contingency response program.
20 So, let me talk just a minute about how we 21 plan our inspections and how we communicate our 22 inspection results.
23 Most of our inspections, we try and lay out 24 an inspection plan for a year in advance. We're not 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 37 always going to hold to that inspection schedule, because 1
conditions will change at the plant and activities will 2
be moved up or new activities will be introduced and we 3
have an inspection plan that is something that we can 4
change on short notice to adjust to any activities at the 5
site.
6 We coordinate our inspection plan with a 7
Program Office in Washington and we get their buy-in on 8
what we're planning to do.
9 we work for the Program Office in 10 Washington. So, they're the ones that set our 11 objectives and give us funding to do our job.
12 As I mentioned, we adjust the schedule as 13 needed throughout the year. Then we execute the 14 inspections.
15 The inspections can be announced or 16 unannounced. Most of our inspections are announced, but 17 not always.
18 There may be occasions where we want to do 19 an unannounced inspection in which case we can do - we 20 do backshift inspections and weekend inspections 21 throughout the year.
22 And then as I mentioned, we have - the 23 inspection plans are approved in advance by the NRC 24 management in the region. And then we have exit meetings 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 following every inspection where we communicate the 1
results of our inspections to the licensee so that they 2
can examine the results and take corrective action if 3
needed.
4 We issue inspection reports. We have two 5
different goals for the timeliness of our inspection 6
reports.
7 For routine inspections involving one or 8
two inspectors, our goals are 30 days for the inspection 9
reports from the date following the exit. For team 10 inspections, it's a 45-day goal for team inspection 11 reports.
12 And then as I mentioned, we do also have an 13 enforcement policy. If we identify violations, we 14 examine the significance of the violation and we get our 15 enforcement staff involved.
16 We have an enforcement staff in the regional 17 office and in our headquarters office and will panel the 18 findings and make a determination of what enforcement to 19 take.
20 We have a number of different enforcement 21 tools that we can take. We're looking ultimately to get 22 the attention of the licensee to correct any violations.
23 If violations are significant according to 24 our enforcement policy, then we have sanctions such as 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 39 civil penalties or orders that we can invoke in order to 1
bring about compliance.
2 Some of the other post-inspection 3
activities. When the inspectors return to the office 4
and oftentimes before they return to the office, they'll 5
call me up and they'll brief me on the inspection results.
6 Then, we make a determination collectively, 7
the inspector and the other staff and the management in 8
the regional office as to the significance of the 9
findings.
10 And then we'll issue the inspection report 11 and I've listed here the website address where you can 12 get copies of our inspection reports.
13 Most of our inspection reports are publicly 14 available. For obvious reasons, some minor - few 15 inspection reports are not publicly available for 16 security reasons, but most of the decommissioning 17 inspection reports will be publicly available and you can 18 access them on our website. And then finally, we'll 19 track and follow the inspection findings to closure.
20 MR. DUSANIWSKYJ: Good evening. My name is 21 Michael Dusaniwskyj. I am an economist in the Office of 22 Nuclear Reactor Regulation in the Division of Inspection 23 and Regional Support in the Financial Analysis and 24 International Projects Branch.
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 40 There are regulations on financial 1
qualifications, and more importantly on decommissioning 2
funding assurance.
3 These standards are based on regulations 4
that have been involved since the enactment of the Atomic 5
Energy Act of 1954.
6 And ultimately what it is ultimately trying 7
to do is to determine whether it can be built, operated 8
and decommissioned safely. To do that, it takes money.
9 A
licensee begins funding for 10 decommissioning when a license is issued. There is a 11 difference between decommissioning funding and 12 decommissioning funding assurance.
13 The regulations at the NRC stipulate that 14 a licensee shall have the necessary funds to decommission 15 to NRC standards by the time the decommissioning 16 activities begin and certainly before it is concluded.
17 Requirements while operating, we are always 18 forecasting the collection process to determine whether 19 or not there is enough funding in the Decommissioning 20 Trust to complete decommissioning to NRC standards.
21 Our basic tool for that is that every two 22 years in odd number of years by March 31st of an 23 odd-numbered year, a licensee is to report to us seven 24 significant pieces of information. Two of them 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 what is the minimum amount that is necessary to put aside.
1 And more importantly, how much money has been collected 2
as of December 31st of the year prior to the March 31st 3
submittal.
4 We also do spot checks. We check to make 5
sure that what they have in a decommissioning trust fund 6
is, in fact, in the decommissioning trust fund.
7 Decommissioning funds used, are used 8
directly for the facility to decontaminate and 9
decommission to NRC standards.
10 If it can be proven to us by the licensee, 11 it can also be used indirectly for use on spent fuel 12 management. Any residual funds can be used for site 13 restoration and greenfielding. While they are in 14 decommissioning, we are forecasting the withdrawal 15 process.
16 Actual decommissioning funding assurance 17 status reports come in annually once a licensee has 18 declared that they are, in fact, in decommissioning 19 status.
20 Two things that must be remembered is that 21 as of June 7th, 2013, two clocks have already started.
22 Number 1, the licensee has until for 60 years, to 23 decommission to NRC standards. And, more importantly, 24 we are waiting for the PSDAR to which we can then 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 determine whether or not there is reasonable assurance 1
that the funding in place will be, in fact, enough to 2
carry on the decommissioning activities as prescribed by 3
the licensee.
4 So, waiting for the PSDAR, we know the 5
following facts and they are listed for you on this slide.
6 Fundamentally as of December 31st, 2012, 7
Unit 2 has almost 1.7 billion dollars set aside for 8
decommissioning. Unit 3 about 1.9 billion.
9 And for comparison, Unit 1 has a remaining 10 trust fund of about 295 million of which there is an 11 estimated cost resulting - excuse me - remaining cost of 12 almost 206 million.
13 The intention of the NRC is not necessarily 14 to claim how many nominal dollars will be involved in the 15 decommissioning process, but my job is to more or less 16 tell the Commission whether or not the purchasing power 17 of those dollars will, in fact, cover all of the 18 decommissioning costs associated with the requirements 19 under NRC regulations.
20 The one thing that I would like to also point 21 out is that of course greenfielding is not under the 22 jurisdiction of the NRC. That is primarily under the 23 jurisdiction of the California Public Utility 24 Commission.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 43 So, until we have a PSDAR, these are the only 1
facts that I can present to you at this time. Thank you.
2 MR. SPITZBERG: Okay. So, you get me one 3
more time, and then we'll open it up to questions. I'd 4
like to speak a few minutes about the regulation of the 5
spent fuel at SONGS.
6 Let me start from basic fundamentals, and 7
that is that spent fuel must have active heat removal in 8
a pool for several years after leaving the operating 9
reactor. After this period of time, it may be passively 10 cooled by air.
11 Spent fuel is being safely stored at San 12 Onofre in fuel pools and in the onsite Independent Spent 13 Fuel Storage Installation.
14 And we use the term "ISFSI" for that long 15 string of words, Independent Spent Fuel Storage 16 Installation. So, if I slip up and use the term "ISFSI,"
17 I apologize.
18 Spent fuel pools are able to withstand the 19 same environmental hazard conditions as the reactors and 20 will be operated by certified fuel handlers who are on 21 shift around the clock.
22 Each spent fuel pool has redundant and 23 independent cooling systems, power supplies, pool water 24 sources and other safety and emergency equipment.
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 Both the spent fuel pools and the ISFSI are 1
protected by the San Onofre Physical Security Force and 2
its associated security systems.
3 Why do we need an ISFSI at these sites?
4 It's a long story, but I'll try and summarize it. The 5
need for the alternatives to spent fuel pool storage 6
emerged in the 1970s.
7 When these plants were initially designed, 8
it was anticipated and expected that the fuel would be 9
stored in the pools for a number of years to allow it to 10 decay after which it would be packaged up and shipped to 11 a DOE site for disposal.
12 The Nuclear Waste Policy Act of 1982 and the 13 Amendments Act of 1987 laid out a process for licensing 14 a geologic repository. But as most of you know, a 15 geologic repository is still decades away.
16 Dry cask storage was developed to meet the 17 need for expanded onsite storage of the spent fuel due 18 to the lack of a national repository available for use.
19 The ISFSI at SONGS became operational in October 2003.
20 To give you an example that ISFSIs are now 21 in widespread use around the country, this is a map of 22 the US showing all of the nuclear sites, the commercial 23 reactors and some of the non-commercial reactors where 24 no longer commercial reactors exist that have ISFSIs that 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 45 are constructed and currently storing spent fuel.
1 Speaking of the SONGS ISFSI, they use a 2
model Transnuclear Advanced NUHOMS Horizontal Storage 3
Module System. The major components of this system are 4
the dry shielded canister, or what we refer to as the DSC, 5
and the horizontal storage module, or the HSM.
6 These photographs depict those. I don't 7
know if I have a pointer on here, but on the left is the 8
dry shielded canister open on one end. This is during 9
the fabrication process.
10 And then the middle photograph is the 11 fabrication process of the horizontal storage module.
12 And then there is a horizontal storage module still under 13 construction there showing with the concrete in place.
14 Each DSC has an outer shell consisting of 15 5/8th-inch thick stainless steel with steel internal 16 spacer discs. The DSC has a welded internal confinement 17 boundary and a separate welded lid.
18 The DSC is placed horizontally inside each 19 advanced horizontal storage module and into a steel 20 support structure. And that's depicted in this 21 photograph here on the transporter in a shielded cask 22 that is especially designed to move these canisters out 23 to the horizontal storage modules on site.
24 The advanced horizontal storage module has 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 thick steel-reinforced concrete walls that are greater 1
than four feet thick and roof slabs that are about five 2
feet thick. And you saw the reinforcing steel in that 3
structure as it was being constructed, in the previous 4
photograph.
5 And this provides for additional structural 6
protection to the canister and the radiation shielding.
7 The horizontal storage modules set on 8
concrete pads that are steel-reinforced concrete of a 9
minimum thickness of three feet.
10 I know those of you out here in southern 11 California are concerned about seismic conditions. And 12 any of us that have recalled the Fukushima accident are 13 concerned about flooding and tsunami considerations when 14 you live on the ocean. So, let me speak to that with 15 respect to the SONGS ISFSI.
16 The SONGS ISFSI is designed for 17 high-seismicity sites. The design basis earthquake 18 used to analyze the SONGS ISFSI is 2.24 times higher 19 than that used in the licensing of the reactors.
20 For tsunami considerations and flooding, 21 the SONGS ISFSI is located 19.75 feet above sea level.
22 The maximum flood condition of 29 feet was evaluated for 23 the ISFSI, which would potentially put the ISFSI pad 24 under nine feet of water.
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 The design basis flood for the advanced 1
horizontal storage module design is to withstand a 2
submersion at 50 feet underwater.
3 The maximum tsunami including storm height 4
of the waves was evaluated at 27 feet for the SONGS ISFSI, 5
which is less than the maximum flood conditions evaluated 6
for the site.
7 All these evaluations did not take into 8
credit for the 28-foot sea wall which exists between the 9
ocean and the ISFSI.
10 And finally if the ISFSI were to get 11 temporarily flooded during a tsunami, there would be no 12 adverse thermal effects.
13 Let me talk about how we do the inspection 14 of the spent fuel storage. For the pool, we do routine 15 inspections normally semiannually using an inspection 16 procedure 60801.
17 And the reason I mention the inspection 18 procedure number is that I would invite you all to go onto 19 our website. You can call up these inspection 20 procedures and read them for yourself to see what it is 21 we look at in detail.
22 For the ISFSI inspections, we do ISFSI 23 routine inspections normally once every two years 24 following the guidance contained in the Manual Chapter 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 48 2690.
1 And this manual chapter references an 2
assortment of individual inspection procedures that we 3
also implement during that inspection.
4 We attempt to schedule our routine 5
inspections of the ISFSI when there's an active loading 6
campaign in progress.
7 We are not always able to do that. For 8
those ISFSIs that have been fully loaded, we're not able 9
to do that, obviously, but we do make every effort to come 10 out when they're actually loading the cask.
11 And once again I'll reference the website 12 of the NRC where you can find out inspection guidance and 13 NRC inspection reports for the ISFSI.
14 MR. CAMERON: Okay, thank you. Thank you 15 all. Good information for everybody. And before we 16 start the question and answer, I forgot to tell you that 17 if you want to write a question tonight instead of 18 speaking, you can do that. And my colleague Bob Hager 19 who's right in the back of the room, he has these yellow 20 cards. You can write a question and at some point during 21 the night we'll read some of them.
22 And also, we're going to take a ten-minute 23 break around 7:30 and then come back and finish the 24 evening off.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 49 We're going to start the 1
question-and-answer session by going to Gene Stone who's 2
right here. He's the spokesperson for a new coalition 3
of concerned citizen groups. It's the Coalition to 4
Decommission San Onofre.
5 The coalition has taken the time and effort 6
to put together some basic questions about the 7
decommissioning of SONGS. And the NRC appreciates that 8
effort.
9 The questions are from the coalition, but 10 the answers to those questions are for all of you. And 11 I think that a lot of these questions are on everybody's 12 mind.
13 So, I'm going to ask Gene to say a few words 14 about the coalition and to read us the first question.
15 I'll read the second question.
16 We're going to put them up on the screen so 17 that they're easier to understand for all of you. The 18 NRC will then answer two questions and then we're going 19 to go on to all of you to see what else is on everybody's 20 mind out here.
21 We'll come back to the next two coalition 22 questions at some point. Go back to all of you and we'll 23 just continue doing that.
24 And at some point towards the end of the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 50 evening we'll see if there's any follow-up questions to 1
the NRC answers that have been given.
2 And, Gene, could you talk to us a little bit 3
right now? I can hold this, or you can. Whatever you 4
want.
5 MR. STONE: The coalition consists of 6
different citizens here in the southern California area 7
and different groups as well.
8 The Sierra Club is here with us. San 9
Clemente Green, Residents Organized for a Safe 10 Environment. Citizens Oversight Project is here, 11 Women's Occupy and the Peace Resource Center of San Diego 12 are here. And the Sierra Club chapter is the Angeles 13 Chapter, which includes LA and Orange County.
14 So, we are here today in hopes that the NRC 15 will make San Onofre a flagship project for the safe and 16 sane cleanup of America's effort to decommission our old 17 and dangerous nuclear fleet and its highly radioactive 18 problems.
19 The original Manhattan Project brought us 20 to where we are now and it's time for this kind of 21 resources and energies to be put into a new project to 22 rid us of the dangerous, highly dangerous radioactive 23 waste that we have here at SONGS and all the nuclear power 24 plants.
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 To this end, the coalition to decommission 1
is forming a true citizens oversight committee to watch 2
out for the health and safety of Californians and the 3
workers at the plant during the decommissioning process.
4 Our second goal is to monitor the cost of 5
decommissioning so that the citizens and rate payers of 6
California are not gouged during this process. Most of 7
that obviously will happen with the PUC.
8 So, my first question is, is the NRC willing 9
to recognize and give us, the Coalition to Decommission 10 San Onofre, official status? Will the public have an 11 opportunity to
- review, comment on significant 12 decommissioning plans, including plant expenditures?
13 MR. CAMERON: Okay, thank you. Thank you, 14 Gene.
15 Larry, would you like to address the first 16 one?
17 (Applause.)
18 MR. CAMPER: Thank you, Gene. Appreciate 19 your comments.
20 The NRC will take that into consideration, 21 absolutely. I think there's a lot of merit in what 22 you're suggesting and I guess I would probably like for 23 you to tell us just a little bit more about how you think 24 that might work or the merit of that type of relationship.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 52 MR. STONE: Well, first I'd like to say 1
before I tell you what I think that might entail, because 2
what that entails is limited by what you say is possible.
3 So, let me start by saying what I think this will do for 4
the NRC to have citizens involved.
5 It will give the credibility to the NRC that 6
the chairman is trying to achieve by openness and dealing 7
with groups like ourselves.
8 It will also lend itself to having our 9
communities at large have interested people who will be 10 there to oversee the safety from a citizen's point of 11 view, not from a technical point of view, but just to keep 12 an eye on to help inform what goes on out there during 13 the process.
14 And we envision doing this through some sort 15 of process where we establish an ongoing group of people 16 that would somehow - and we haven't formulated all these 17 ideas, but like a board of directors and but we want this 18 to be a true citizens oversight.
19 So, we'd like to join with you during 20 inspections with the NRC. Not that we have an eye for 21 a technical point of view, but we - a critical eye and 22 critical thinking from different perspectives brings a 23 whole new light on any story.
24 So, again, how that will manifest will come 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 53 from, I'm sure, the chairman and the other commissioners, 1
but we'd like to be part, an active part of participating 2
in the safety of this lengthy process. Thank you.
3 MR. CAMPER: Well, thank you. We hear that.
4 And, like I said, we'll take it under consideration and 5
we'll do that very promptly. Thanks, Gene.
6 MR. CAMERON: Okay. Could we get the second 7
question up on the screen for everybody to see? And this 8
is a multi-part question. So, I'm going to read it and 9
it will be up on the screen for everybody to see.
10 And this is about high burnup fuel. And the 11 question is, high burnup fuel has been used at San Onofre 12 since 1996 we were told by the NRC recently, but we cannot 13 find a public notice of that from the NRC or SEC. Even 14 the union and other workers we have talked to were not 15 aware of its use.
16 Was a notice ever given to the public and 17 workers? Were workers made aware that this high burnup 18 fuel is more than twice as radioactive?
19 And there's a further statement that high 20 burnup fuel is hotter and between two and 158 times more 21 radioactive requiring the waste to be cooled onsite in 22 spent fuel pools for at least 12 to 15 years rather than 23 five years.
24 Does the NRC agree with these statements?
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 54 If not, how much more radioactive would the NRC say high 1
burnup is?
2 Edison reported to the CPUC, that's 3
California Public Utilities Commission, they must keep 4
some of their fuel in spent fuel pools for at least 12 5
more years.
6 Why don't we go to the NRC for answers to 7
that before we go to the other parts of the question.
8 And, Blair, are you going to answer that for us?
9 MR. SPITZBERG: I will try. Okay. I'll 10 answer what I can. I'm not from the licensing 11 organization and headquarters that would license the 12 authorization for the high burnup fuel, but what I can 13 tell you is that they have used high burnup fuel.
14 They are authorized for storage casks to 15 contain that high burnup fuel once it's brought out of 16 the pool.
17 I don't have the tech spec requirements here 18 with me and I wasn't able to get them two days ago when 19 I got the question. So, I apologize for not having been 20 able to get the answer to the question about what the 21 storage time in the spent fuel pool must be for the high 22 burnup fuel.
23 I think in general terms high burnup fuel 24 does have to remain in the pool for some period of time 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 55 longer than the normal five years for regular fuel.
1 I think seven years is the number that I've 2
seen normally as a figure for high burnup fuel, but it 3
really depends on the level of burnup and what was 4
authorized on the license and I don't have that 5
information.
6 What I can say is that the high burnup fuel 7
will not be loaded into a canister for long-term storage 8
in the ISFSI unless it meets the certificate of 9
compliance for that canister system. And we will 10 inspect that.
11 MR. CAMERON: Okay. Thanks, Blair. I'm 12 going to go through - there's three other parts here and 13 I'm going to read all of them. And then we'll go back 14 to the NRC staff for answers.
15 How does the high burnup fuel affect the 16 decommissioning process at San Onofre? What specific 17 problems does this higher radioactive fuel present for 18 waste storage in fuel pools and dry cask storage at San 19 Onofre and just how much longer will this radiation last?
20 How will decommissioning be impacted by the current 21 onsite storage of the spent fuel?
22 Third part of the question is, we understand 23 the NRC staff is worried about short and long-term waste 24 storage in dry cask of high burnup fuel and has initiated 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 56 a new study to determine if it can be safely stored in 1
dry cask.
2 Is this report complete? Will it be 3
released public and when? One of your concerns is that 4
there is no way to monitor what's occurring inside the 5
dry cask.
6 How does the NRC propose to monitor the 7
highly radioactive material in a dry cask? How many 8
casks will be required to safely store all the high burnup 9
fuel that is onsite in both the spent fuel pool and dry 10 casks at San Onofre?
11 MR. SPITZBERG: That's a lot of questions.
12 MR. CAMERON: Okay.
13 MR. SPITZBERG: Let me see if I can attack 14 them one at a time.
15 MR. CAMERON: And just one - how much high 16 burnup fuel is on site in fuel pools and dry casks at San 17 Onofre? Okay.
18 MR. SPITZBERG: Okay. And I will tell you 19 that I worked over the last day and a half with some of 20 our folks from headquarters. So, some of the 21 information I'm relying on to respond to this question 22 is information that they helped to gather while we were 23 traveling out here.
24 What I can say is that the NRC does collect 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 57 data on the total amount of spent fuel stored at 1
commercial facilities like SONGS throughout the country.
2 The information and much more concerning 3
the nuclear fuel is available on our website. If you go 4
to our website NRC.gov and look at what - under waste and 5
spent fuel storage, you'll get the webpage with that 6
information.
7 However, for any given facility, the 8
information is considered security-sensitive 9
information and is, therefore, not disclosed to the 10 public as to the amount of spent fuel.
11 You can find this in other publications, 12 though, because I found a publication yesterday called 13 Store Fuel that does have the number of fuel assemblies 14 here at SONGS published.
15 When the last routine ISFSI inspection 16 report was issued in May of - May 20th, 2011, and this 17 is a report that's available on our website, SONGS had 18 loaded 11 canisters that contained at least one fuel 19 assembly that was greater than the criteria for high 20 burnup fuel.
21 I'll mention that criteria to you. I know 22 it won't mean a lot to most of you, but it's anything 23 greater than 45 gigawatt days per metric ton of uranium 24 in the fuel and it basically relates to how long the fuel 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 58 was in the reactor at power. And that's what - if you're 1
greater than that number, then it's considered high 2
burnup.
3 Out of the 55 canisters that are loaded on 4
the ISFSI pad currently or at that time of the inspection, 5
the NRC does not maintain records showing how many fuel 6
assemblies have been loaded that were high burnup.
7 However, licensees and certificate holders 8
are required to register each cask with the Nuclear 9
Regulatory Commission under the provisions of Part 10 72.212(b)(2). And the registrations and information 11 contained therein is subject to routine inspection.
12 The NRC does agree that there is currently 13 no way to monitor the behavior of fuel inside a sealed 14 cask. We are actively monitoring the efforts of 15 industry and the Department of energy to better 16 understand fuel aging mechanisms.
17 The DOE is taking an active role in funding 18 the Nuclear Energy University Program projects to look 19 into this issue.
20 In
- addition, DOE is sponsoring a
21 demonstration test with a variety of high burnup fuels 22 to benchmark their models of the behavior of the fuel and 23 to obtain through monitoring of this cask the temperature 24 and gases evolved, which will tell them how the fuel is 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 59 behaving. This demonstration will provide data that 1
monitors the behavior of the spent fuel.
2 It depends on which dry cask storage system 3
is used at San Onofre for the decommissioning effort and 4
when the spent fuel is actually moved to the dry cask 5
storage to the different sizes of casks and the actual 6
heat load being given off by the assemblies that the 7
licensee wants to load into the casks. And this 8
information is not yet available from the licensee on the 9
new casks that they're wanting to put into use.
10 MR. CAMERON: Are you ready for the last part 11 of the question, or do you still have some more on that?
12 MR. SPITZBERG: Is that D?
13 MR. CAMERON: Yeah, this is D. We know that 14 MOX fuel was -
15 MR. SPITZBERG: Okay.
16 MR. CAMERON: - used in Unit 1 and removed 17 from San Onofre to the GE Morris facility in Illinois.
18 How and when was that done and under what 19 permit was that done? If MOX fuel was transported away, 20 can other high burnup fuel be moved from the site in the 21 same way to the same place?
22 MR. SPITZBERG: Okay. the MOX fuel was not 23 moved to GE Morris in Illinois. And what I can say was 24 that between March of 1972 and September 1980, 270 fuel 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 60 assemblies were shipped to GE Morris and MOX fuel was not 1
included in these shipments.
2 NRC does not require/retain records of 3
which transportation package was used at that time for 4
the specific shipments.
5 That was a unique shipment. Normally fuel 6
can't be shipped to an intermediate storage facility like 7
GE Morris without specific authorization from the NRC, 8
in which case they were authorized under their license.
9 Those shipments are no longer being conducted, but the 10 MOX fuel was not part of those shipments. The MOX fuel 11 is in storage here at San Onofre.
12 MR. CAMERON: Okay. Thank you, Blair. And 13 we're going to go to other people now. We will be back 14 to the coalition's questions and eventually we're going 15 to go to - for follow-up questions there.
16 And, yes, sir, if you could just introduce 17 yourself to us?
18 MR. CRAYCRAFT: Thank you very much, 19 gentlemen. Thank you for being here with us this evening 20 and allowing the public to respond. It's commendable.
21 Applaud you on the efforts of not only your group, but 22 the entire NRC for progressing what everyone in this room 23 hopes to be a safe and honorable process in the 24 decommissioning.
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 I have a couple quick questions for you. My 1
name is William Craycraft. I'm a four-term mayor -
2 former mayor of Mission Viejo, California, which is South 3
County's largest city close to SONGS.
4 The first question I have is, given that SCE 5
has decommissioned Number 1, Generator Number 1 6
successfully as I understand what you have shared with 7
us
- here, were there any problems with that 8
decommissioning process?
9 PARTICIPANT: I'll address that because -
10 MR. CAMERON: Why don't you ask your second 11 question as well?
12 MR. CRAYCRAFT: Okay, I can go that. And 13 were there - the other question is, were there any 14 problems with the decommissioning of Unit Number 1 and 15 have the regulations changed since that decommissioning 16 of Unit Number 1? In other words, something applying to 17 Two and Three?
18 The second question, please, is I heard at 19 the beginning in the introductions that Chip gave that 20 there are a number of state agencies possibly here, maybe 21 another Federal agency representing. What is their 22 function in the decommissioning process? If they could 23 briefly share with everyone here what their 24 responsibility is, please.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 62 Thank you kindly.
1 MR. CAMERON: Okay. Good questions, Bill.
2 And after we get the first one, we're going to go to some 3
of the state agencies so that they can explain that.
4 And NRC staff, you heard the first question.
5 And I think part of the essence of that question also is 6
what lessons have been learned in the decommissioning of 7
San Onofre Unit 1 or other decommissioning experiences 8
since then that you might want to talk about.
9 Blair, you go. And I don't know if Doug 10 Broaddus from NRR wants to say anything, but we're going 11 to leave it to you and then we'll go to the state agencies.
12 Blair.
13 MR. SPITZBERG: Okay. I was the branch 14 chief over decommissioning during the decommissioning of 15 Unit 1. And one of my principal inspectors for the 16 decommissioning of Unit 1 is here tonight, Rob Evans.
17 So, I'll invite him to weigh in if he has any input as 18 well.
19 Unfortunately, in preparation for this 20 meeting I didn't go back and review all the inspection 21 reports from the Unit 1 decommissioning, but I'll rely 22 on my memory as best I can.
23 In my recollection, the decommissioning of 24 Unit 1 went very well and very smoothly and it was pretty 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 63 much on schedule.
1 I do remember that there were some routine 2
violations that we identified throughout. I remember 3
one in particular that was what we considered to be a more 4
significant violation that involved a shipment of some 5
liquid radwaste to a disposal site in Utah that had some 6
leakage when it was at a truck stop in Utah.
7 The licensee responded very promptly and 8
they went out there and performed a little bit of decon 9
at the truck stop and reconfigured the waste shipment and 10 got it on its way to the disposal site.
11 And there were no health effects as a result 12 of that, but it was still a leaking shipment, which is 13 unacceptable to us and a violation. So, we did cite the 14 licensee at that time. And I do believe that was what 15 we considered to be escalated enforcement, but I don't 16 think that there were any monetary sanctions because of 17 the good performance history at the time of the 18 decommissioning effort.
19 I think the second part of your question, 20 was there anything unusual that we saw during the 21 decommissioning, I would say that there is not.
22 The one thing that sticks with me is the fact 23 that they have not yet terminated the license there. And 24 one of the principal reasons for that is that the reactor 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 64 vessel is still on site in storage and that I know that 1
they had developed plans to grout the reactor vessel and 2
to ship it to a disposal site, I believe, in South 3
Carolina, which was the only open site that could accept 4
that reactor vessel at the time.
5 And I think they had some difficulties and 6
challenges in getting some of the approvals for the right 7
of the way for the transportation of that.
8 They went through several different 9
iterations, as I recall, of different routes that they 10 could pursue. And I think they finally made a decision 11 just to keep it on site until the decommissioning of Units 12 2 and 3. And so, it still rests there today.
13 MR. CAMERON: Okay. Thank you very much, 14 Blair. And, Larry, Bruce?
15 MR. CAMPER: Yeah, I would just footnote that 16 and thanks for the question. There has not been a change 17 in the regulations since Unit 1
underwent 18 decommissioning, but there have been a number of 19 information notices put out by our agency in terms of 20 lessons learned. For example, there's been information 21 put in about how to enhance site characterization that 22 comes to mind.
23 And there have been workshops we've had with 24 industry over the years where we've gone back and looked 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 65 at what we now know about decommissioning.
1 So, no regulatory change, but much 2
additional information.
3 MR. CAMERON: Anything else that you want to 4
add, Bruce, on this?
5 MR. WATSON: San Onofre 1 was somewhat unique 6
in that we did what we would call a partial site release 7
under 10 CFR 50.83. And it was determined that the - I 8
believe it's the intake structure which extends out into 9
the ocean was released.
10 And of course it was unconditionally 11 released and it was determined that removal of that 12 particular structure may create more environmental 13 damage than leaving it in place. And so, that was 14 somewhat unique in the decommissioning for Unit 1.
15 MR. CAMERON: Okay, thank you. Let's go to 16 the second part of Mr. - pardon me?
17 MS. RUSEN (phonetic): I'm wondering if I 18 could just follow up. I have a couple of follow-up 19 questions on what was just said.
20 Is that possible rather than moving on?
21 MR. CAMERON: We'll follow up with you later 22 on. We're going to go to the state agencies right now.
23 Thank you.
24 Okay. Second question was about the state 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 66 agencies and let me introduce Cynthia Walker from the 1
California Public Utilities Commission and Rob Oglesby 2
from the California Energy Commission.
3 And, Cynthia, do you want to go first and 4
just say a little bit about what the PUC is doing, and 5
then we'll go to Rob. Cynthia.
6 MS. WALKER: So, the California Public 7
Utilities Commission's role in decommissioning is we 8
have oversight of the management of the decommissioning 9
of the funds that are set up for all the decommissioning 10 of the plants and in California.
11 So, there is a separate board. It's all 12 established by commission decision that oversees the 13 investments in the fund.
14 And what we do is, and what we'll be doing 15 with SONGS, is they will be filing an application for 16 their plan for decommissioning and they've forecasted an 17 amount that they are likely to spend, and we will be 18 releasing funds for each of the - as they do the 19 decommissioning and overseeing that process.
20 The fund is pretty substantial at this 21 point. The plan was always to have it that way. Because 22 of the lease with the Navy, there is a requirement that 23 it be a greenfield restoration.
24 So, and then we also establish the rates.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 67 We keep track, make sure that there is funding. As 1
Michael was saying, California is more strict than the 2
NRC in some ways. We have our own - not maybe more 3
strict, but we have additional requirements. And so, we 4
will make sure that there is sufficient funding for the 5
decommissioning as required by the state.
6 MR. OGLESBY: So, I'm Rob Oglesby. I'm the 7
executive director of the California Energy Commission.
8 And the California Energy Commission has been involved 9
with this since the plant was first shut down 20 months 10 or so ago.
11 And our role in the process isn't so much 12 with decommissioning, but it's been to work with our 13 sister agencies to make sure going forward that there is 14 reliable electricity supplied in the absence of SONGS.
15 And over 2012, for example, we worked with 16 our sister agencies, the CPUC, the CAISO, to make sure 17 that we could make system changes in the near term to take 18 care of the summer of 2012. And that included restarting 19 an old power plant in order to give some voltage support, 20 making improvements in transmission and also working to 21 get additional conservation.
22 We made other changes to get through the 23 summer of 2013. Now, with the certainty of this resource 24 not being online, we're working to design plans going 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 68 forward to have a stable and reliable supply of energy 1
for this region.
2 MR. CAMERON: Thank you, Cynthia. Thank 3
you, Rob. Let's see what the woman in the red sweater 4
has on her mind and then we'll answer that. And then 5
we'll take a break.
6 If you could just please introduce yourself 7
to us?
8 Ms. RUSEN: Thanks. My name is Mila Rusen.
9 I live in Los Angeles and I have - there were a couple 10 of things that struck, me.
11 One, there was a statement made that there 12 was release of radioactivity during the decommissioning 13 of - that there was a release of radioactivity during some 14 kind of an incident that happened in transporting some 15 of the equipment from Unit 1 and there was an assertion 16 made that there was no health impact. And so, I'd like 17 to know the basis of that assertion.
18 And then, I'd also like to know - someone 19 else stated after that, that there was another release, 20 I think, into the ocean.
21 And so, I want to know about how you can be 22 so sure that there were no health consequences whatsoever 23 as a result of these releases of radiation.
24 MR. CAMERON: Thank you. Thank you very 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 69 much. And we're going to see if we can give you some 1
information on that. And perhaps more information can 2
be given during the break to you from the NRC staff, but 3
anybody - who would we suggest address that? Blair?
4 MR. SPITZBERG: I can address that.
5 Although, my memory is vague on this now. And, Bob, you 6
may have to help me is that when we - this would have been 7
a reportable event that we were notified of. And when 8
we get a report like this, we would dispatch an inspector 9
to the site to take surveys of not just the vehicle, but 10 any areas that the vehicle may have leaked to.
11 And my recollection is that based upon the 12 surveys that were conducted and the information that we 13 were able to gather from the route of the vehicle and the 14 circumstances of the leakage, that it was not 15 significant.
16 If you need more details than that, what 17 I'll have to do is find the inspection report that 18 documented our follow-up inspection of that and then we 19 can make sure that you're aware of that. It's on our 20 website.
21 I just think that that was - what was that, 22 Bob? That was bout 2006. Okay. So, that was about 23 eight or nine years ago.
24 MR. CAMERON: And let's see if Bob has 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 70 anything to add to that. And I don't want to lose the 1
last part of the question, because I think it's 2
important. It goes to how the NRC does things about how 3
can you be certain that - what process do you use to make 4
sure that - to ascertain whether there is affects or not.
5 And, Bob, you can address -
6 MR. EVANS: Bob Evans. I'm a senior 7
inspector for the NRC. The event occurred in 2006.
8 There was liquid radwaste that was being disposed in 9
Utah.
10 And a vent on the tanker leaked and I 11 understand it leaked on a road. And this occurred in 12 Utah, which is what we call an agreement state. And the 13 state of Utah responded on behalf of the NRC.
14 The licensee at the time dispatched a team, 15 remediated the roadway and just basically it did not 16 create a significant radiological hazard to health and 17 safety.
18 It was an environment release and it was 19 eventually cleaned up.
20 MR. CAMERON: Okay. Thank you and anybody 21 else from the NRC want to add something before we go on 22 break?
23 Bruce and Blair.
24 MR. SPITZBERG: Let me just add one final 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 71 point on that.
1 MR. CAMERON: Okay.
2 MR. SPITZBERG: And that is under the 3
transportation regulations from DOT which we enforce 4
when it comes to transportation of radioactive 5
materials, is that certain materials that are 6
radioactive cannot be transported in liquid form if there 7
is above a certain level of radioactivity.
8 And so, for something that's of a liquid 9
nature to be transported in a bulk form like that, it has 10 almost by definition to be a low-level activity.
11 So, that's one of the things that gave us 12 confidence that there were no significant radiological 13 consequences associated with this, but we had to wait 14 until the final surveys and information came in from the 15 inspection team from Utah and that we were able to assess 16 that.
17 Nevertheless, I will say that it was a 18 significant violation to us. It fell into what we call 19 a Severity Level 3 category under our enforcement 20 policies, which is the threshold for when we consider 21 escalated enforcement.
22 And when we consider escalated enforcement, 23 we take into account the significance of it. And we take 24 into account other factors like enforcement history and 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 72 other parameters that we go through with our enforcement 1
staff to make a final determination of what enforcement 2
mechanism to use.
3 MR. CAMERON: Okay. Thank you very much.
4 And is it Cynthia? What was your name?
5 MS. RUSEN: Mila.
6 MR. CAMERON: Mila. Okay. Sorry, Mila.
7 We're going to take a break now for ten minutes. I have 8
7:36. And we'll get started again after ten minutes and 9
you can come back at your leisure.
10 (Whereupon, the proceedings went off the 11 record at 7:36 p.m. for a brief recess and went back on 12 the record at 7:46 p.m.)
13 MR. CAMERON: And just let me give you a 14 preview of what we're going to do for the next few minutes 15 at any rate, and then we're going to try to get to the 16 rest of everybody.
17 We have first - and, Bob, just hold off one 18 second. First of all, we have a woman right here who's 19 going to ask a question, okay, but someone asked - there's 20 a video being taken of this meeting. That's going to 21 be the record of the meeting. And I was told that that 22 would be available in a couple of weeks.
23 MR. LANTZ: Maybe less than that, actually.
24 MR. CAMERON: Okay.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 73 MR. LANTZ: Yeah, the video of the meeting 1
tonight, it will be posted on our website. And that 2
should be within about two weeks. And it will also be 3
transcribed so you can read it, if you don't want to watch 4
it.
5 MR. CAMERON: Okay, thanks. That's Ryan 6
Lantz from Region IV.
7 We also were asked the question of who 8
authorizes the use of high burnup fuel. It was in the 9
coalition's question and people weren't sure that we 10 answered that. So, we want to get back to that.
11 The NRC is going to be back out here in ten 12 days or so at the Sheraton to do a public meeting on the 13 draft environmental impact statement on waste 14 confidence.
15 And it's very important for everybody to 16 know about that. And I don't want to - I don't want to 17 let that languish.
18 So, I was going to ask Paul Michalak who's 19 here from the Waste Confidence Directorate at the NRC 20 headquarters in Rockville, Paul, can you just tell people 21 about - a little bit about the meeting, the schedule and 22 everything? And let's get that done now.
23 Paul.
24 MR. MICHALAK: Yes, we're going to be back 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 74 here - well, in Carlsbad in Wednesday, October 9th.
1 We're going to be over at the Sheraton.
2 We're going to have an open house between 3
6:00 and 7:00 and we're going to be taking comments from 4
7:00 to 10 o'clock.
5 And that has to do with we've been 6
developing over the last year a Generic Environmental 7
Impact Statement having to do with the continued storage 8
of spent nuclear fuel. That being the time from the end 9
of the license life of a reactor until the fuel is taken 10 then to a mine geologic repository.
11 We have this document out for comment.
12 Went out Friday the 13th in September. September 13th.
13 And the commenting period ends November 27th. So, we're 14 doing a lot of meetings around the country and we start 15 next week.
16 We have a meeting next Tuesday at 17 headquarters that's going to be webcast and then it's 18 also going to be teleconferenced. You can call into that 19 meeting if you couldn't make our October 9th meeting.
20 Then at the end, or near the end of the 21 commenting period on November 14th, Thursday, we're 22 going to have another meeting at headquarters that would 23 also be webcast and teleconferenced and you could also 24 call into that as well if you had comments.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 75 MR. CAMERON: Thank you, Paul. And if 1
you're interested in more information on waste 2
confidence, Paul will be here.
3 MR. MICHALAK: And I'm sorry. We have 4
flyers out on the table with a lot more detailed operation 5
about the October 9th meeting.
6 MR. CAMERON: Okay. Thanks. Thanks, Paul.
7 And after we hear from this woman right here, we're going 8
to go over to Gale and two women over here, okay? So, 9
thank you. Please address us.
10 MS. BORCHMANN: Hello. My name is Patricia 11 Borchmann. I'm a resident in Escondido, San Diego 12 County. And I have family in Carlsbad, I have family in 13 Seal Beach and I consider in, you know, the 8.46 million 14 people within 50 miles of San Onofre, I consider all of 15 you my family. So, that's where I'm coming from.
16 And I, you know, I think that the public 17 expects NRC to fully perform and carry out your duties 18 for public safety. And so, anyway, some of my questions 19
- one of my comments is related to your announcement just 20 now that NRC is going to be having public meetings 21 regarding a Generic Environmental Impact Statement 22 that's going to be prepared.
23 One comment I'll give you up front so you 24 can give your NRC people a head up, I think that the people 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 76 in southern California think that a site-specific 1
Environmental Impact Statement as opposed to a Generic 2
Impact Statement would be required given the specific and 3
very important physical circumstances at San Onofre 4
which don't exist elsewhere in the nation.
5 Generic documents don't, you know, provide 6
site-specific assessments and I think that would be a 7
real important -
8 MR. CAMERON: Okay. Thank you, Patricia.
9 MS. BORCHMANN: Okay. Anyway, that wasn't 10 my question.
11 MR. CAMERON: Well, go ahead.
12 MS. BORCHMANN: Thank you for allowing me the 13 time. There's been a lot of discussion by each team 14 member, you know, to convey reasons why the Nuclear 15 Regulatory Commission has such confidence, waste 16 confidence, you know, and that's what this EIS is going 17 to be talking about, but basically confidence in every 18 aspect.
19 Unfortunately, the public here in southern 20 California, we've grown skeptical over a long history of 21 living here near San Onofre and being exposed to, you 22 know, circumstances which we feel impacts have been 23 minimalized, trivialized, marginalized, sanitized and 24 pretty much, you know, comments and concerns of even 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 77 independent experts who are engineers, who are, you know, 1
physical scientists, physicists and, you know, highly 2
qualified specialists that they have conclusions that 3
are in contrast with the safety assurances that the NRC, 4
you know, provides us to members of the public because 5
6 MR. CAMERON: Patricia, is there a question?
7 MS. BORCHMANN: Okay, yes. For example, the 8
use of high burnup fuel started in 1996. Why is it or 9
what basis for public safety was your approval, the NRC's 10 decision to approve the use of high burnup fuel used when 11 there has been no analysis, there has been no proof, 12 credible proof that the long-term effects will have no 13 significant impact, you know?
14 MR. CAMERON: Okay. Patricia, we're going 15 to - that matches the concern that someone had during the 16 break about the authorization of the high burnup fuel.
17 So, we're going to - let's take that now and then I want 18 to go to Gale and to Larry Kramer and - right here, okay.
19 And then we've got to get Three and Four of the 20 coalition's questions up there.
21 Authorization, Bruce, Blair, you heard the 22 question. How is the use of high burnup fuel at a 23 particular site at this site, how is that authorized?
24 MR. SPITZBERG: Chip, that's authorized by 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 78 our Office of Spent Fuel Storage and Transportation.
1 And what they do is they will get an application for a 2
cask for storage of spent fuel. And as part of that 3
application, they'll get all the specifications for the 4
spent fuel including heat load and the type of fuel 5
assemblies and how long the burnup was and a whole 6
assortment of parameters of which I'm not fully aware of 7
all the questions that they ask.
8 They have thermal specialists, they have 9
health physicists, they have structural specialists, 10 they have criticality specialists, they have all these 11 specialists that will review that application.
12 And if that application meets the criteria 13 for licensing that cask, they will approve the cask.
14 Once they approve that cask, they'll certify it. And 15 then that is open to the public comment and to hearings 16 and that process.
17 What they do is they will rely on historic 18 data, a fuel that has been stored in casks of that nature 19 that they have either from the vendors or from licensees 20 or from, in some cases, DOE they have a historic database 21 and models that they use to develop the thermal models 22 and the health physics models associated with that. And 23 that's part of the licensing basis.
24 It's unfortunate we don't have somebody 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 79 from a licensing organization that does that licensing 1
that will be able to provide a more detailed answer to 2
that, but that's basically - excuse me?
3 MR. CAMERON: Please, please, please.
4 Please, we're trying to get the answer to your question.
5 Okay? So, just let's please let people try to answer the 6
question.
7 And I think that the issue is you're talking 8
about the use of the cask for it, but I think the question 9
is, is why was high burnup fuel authorized to begin with.
10 We're going to go to Doug Broaddus from the 11 Office of Nuclear Reactor Regulation. Doug.
12 MR. BROADDUS: What I can talk about is the 13 licensing process for fuel. I don't have specifics on 14 the applications that occurred with San Onofre at the 15 time, you know, back in the early `90s.
16 I didn't have a chance to research that yet, 17 but the fuel itself is - there would be an application 18 originally that would be approved with the license 19 originally, the type of fuel that would be used at the 20 reactor site.
21 The manufacturers may come in and want to 22 use different fuel and they'll - or produce different 23 fuel. They'll come in for a - what would be more of a 24 generic type of approval. We would do that through a 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 80 topical report. And then that would be approving the 1
design of the fuel itself.
2 And then if each reactor wants to come in 3
and use that fuel at their particular facility, they'd 4
have to come in for a specific - a site-specific amendment 5
request at their site to use that fuel.
6 So, that's the process that's used. And 7
each of those, there would be a licensing amendment and 8
application. There would be an opportunity for public 9
involvement in that, but I don't have the specifics for 10 San Onofre as the one that happened - which one - we can 11 get that information and provide that at a later date.
12 MR. CAMERON: That's the process that was 13 gone through. And you can get specifics on that, okay.
14 Thank you very much, Doug, and we're going to go to Gale 15 and to Mr. Kramer and then we're going to come to you, 16 okay?
17 Gale. Yes, we'll get you in there. We're 18 going to do it a little bit later. Go ahead, Gale.
19 GALE (phonetic): Yes. This is perhaps a 20 very difficult thing to have to face, but I think we need 21 to keep track of the fact that the San Onofre nuclear 22 generating station is on the edge of the ocean and we need 23 to learn lessons from Fukushima also on the edge of the 24 ocean.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 81 One of the things that's happened across the 1
last few years in Orange County is that its entire coast 2
under every municipality from San Clemente to Seal Beach 3
has qualified tsunami ready.
4 SONGS has qualified as something called 5
storm ready, but we've been down there and we've taken 6
a look at their so-called wall. And I really think 7
almost that whatever needs to be kept for a while in 8
cooling ponds needs to be transported to cooling ponds 9
that are further inland or the disaster for the coastal 10 area and a really significant tsunami will be enormous.
11 When you get that radioactive material 12 spread that way, you have Fukushima where they're not 13 trying to take care of even more water that they tried 14 to get out of the picture, because it's become 15 radioactive. So, I bring this problem to your 16 attention.
17 I don't know what the answer is, but I'm not 18 sure that's a good place to put it to sleep to the sound 19 of the waves.
20 MR. CAMERON: Okay. Thank you for that 21 comment, Gale.
22 (Applause.)
23 MR. CAMERON: We're going to go to Councilman 24 Kramer. Councilman Kramer.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 82 MR. KRAMER: Yeah, I'm Larry Kramer. I'm on 1
the City Council of San Juan Capistrano and I've been to 2
I think every meeting that's been held in the last couple 3
years, but I've got a real simple question.
4 I appreciate all the questions and I've 5
learned a lot from all these meetings. I think they're 6
fascinating and I think everybody brings a different 7
perspective as they come in here and it's been very 8
interesting to hear all the different perspectives.
9 I heard something tonight, though, that 10 peaked my interest and I'm curious. On Unit Number 1, 11 the reactor vessel is still there and you had some 12 difficulty shipping it. And now, that method of 13 shipping apparently has gone away.
14 It makes me wonder are there other parts of 15 Unit 1 that are still here, and does that imply that for 16 Units 2 and 3 that the reactor vessels and other primary 17 components may be here for a long time, if not forever.
18 That's my simple question.
19 MR. CAMERON: Simple question, but perhaps 20 the answer isn't. I don't know. Who's going to deal 21 with that one up on the platform?
22 MR. SPITZBERG: I would have to go back and 23 check, but I believe that the only thing remaining of a 24 radiological nature from Unit 1 is the reactor vessel and 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 83 the spent fuel.
1 There may be some what we call greater than 2
Class C waste that may have been also containerized and 3
put in their SOC, but I would have to verify that. That's 4
something that has been done at other sites.
5 I'm not aware of any other certainly 6
significant sources from Unit 1 there.
7 MR. CAMERON: Okay. Go ahead, Bruce, and 8
then we'll go to Bob. Go ahead.
9 MR. WATSON: You want to talk about Unit 1?
10 MR. EVANS: Yes.
11 MR. WATSON: Go ahead. I'll follow up with 12 Unit 2 and 3 questions.
13 MR. EVANS: Just as a reminder, Unit 1 shut 14 down in `92. They started decommissioning the DECON 15 mode in 1999. It took about ten years.
16 What they did at the time was what's called 17 phased decommissioning and they basically disposed of 18 everything that was above the surface.
19 At this point in time besides the reactor 20 pressure vessel, there are still some subsurface 21 structures like the foundations of the building are still 22 there with some very low levels of radioactivity and 23 contamination.
24 The idea at the time was, is they were going 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 84 to finish the substructures of Unit 1 in conjunction with 1
completing the substructures at Two and Three. And the 2
disposal of the Unit 1 reactor pressure vessel will be 3
disposed at the same time Units 2 and 3 are disposed.
4 So, again, it was called a phased 5
decommissioning.
6 MR. CAMERON: Okay. Thank you very much and 7
- I'm sorry. Go ahead, Bruce.
8 MR. WATSON: I think that with the response 9
to the questions on Unit 2 and 3, Southern California 10 Edison is going to have to make the determination on how 11 they're going to handle those large components.
12 I can give you the example that Trojan were 13 because they had access to the barge traffic on the 14 Columbia River, the reactor vessel was packaged so it 15 could be shipped by barge up to the disposal facility at 16 Hanford.
17 Maine Yankee was the same way. The reactor 18 vessel which is probably the largest component was barged 19 to Barnwell, South Carolina and then up the Savannah 20 River and then carried over land for a distance to get 21 it to the Barnwell disposal facility.
22 Right now Zion 1 and 2 are under inactive 23 decommissioning. Their plan because they are on the 24 Great Lakes and the large components are too big to go 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 85 on rail or across the road, their plan is to segment the 1
reactor vessel into small pieces and then ship it in 2
radioactive, you know, approved radioactive transport 3
packages then.
4 So, it's all in the approach in what the 5
infrastructure will support on how you do the 6
decommissioning. Those are things that you have to take 7
into consideration when you put your plan together.
8 And so, again, what I was saying before in 9
this Phase 1 of the decommissioning, they have a number 10 of significant items to evaluate so they can put their 11 plan together and make it effective so they can safely 12 complete the decommissioning and dispose of the 13 materials.
14 MR. CAMERON: Okay. Thank you very much.
15 We're going to go to you. We know there's people out 16 here. We need to get to Three and Four and we have some 17 good written questions, but why don't you go ahead and 18 then we'll see where we are.
19 MS. MAGDA: Hi. I'm Marni Magda from Laguna 20 Beach. I've been attending all the meetings with Elmo 21 Collins and on into the time we are now.
22 I'm very concerned that this latest report 23 on the steam generators lets us know that a little hand 24 slap on something that was known to be dangerous - the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 86 record that southern California Edison has, has shown us 1
over and over again that they worry about profit, not 2
safety. Though, they will always tell us it's safety.
3 I am begging all of you from my heart to help 4
us in southern California. Of the 104 reactors, 5
southern California has a danger that we are more aware 6
of with rising tides, global warming, tsunami.
7 The report just came out about Alaska that 8
would come across our coast. The seawall is not enough.
9 Even if we had it all in dry cask storage 50 feet 10 underground, then it's in saltwater.
11 We must have your help getting final 12 geological disposal dry cask storage that starts today 13 in the kind of dry cask - and I'm going to ask you how 14 we get these, because I've been told you haven't licensed 15 anything transportable.
16 The US Navy is right now having to get its 17 nuclear waste out of Idaho by 2035 that I used to say was 18 forever from now, because tomorrow southern California 19 could die.
20 How do we get casks like the Navy is using 21 and put our money where it needs to go even if it's more 22 expensive.
23 They have 50 of the - oh, I'm sorry, but they 24 will have 400 by 2035 that are final deposit 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 87 transportable casks that they will be moving out of 1
2 Can we use those? How do we get them? We 3
must start moving that - those spent fuel ponds are an 4
absolute accident waiting to happen tomorrow. We can't 5
be waiting. Please help us.
6 I hear that it's up to southern California 7
Edison -
8 (Discussion off the record.)
9 MS. MAGDA: Okay, but the PSDAR says that 10 this is all up to Edison. That you don't even approve 11 what they plan.
12 Who do we get involved? How do we get 13 involved to make this change and not let them take 60 14 years?
15 MR. CAMERON: Okay.
16 (Applause.)
17 MR.
CAMERON:
Can we address the 18 transportation issue?
19 MR. SPITZBERG: Yes.
20 MR. CAMERON: Go ahead.
21 MR. SPITZBERG: Let me take that little piece 22 of the comment. I think I've heard tonight and earlier 23 today some information about whether or not the casks 24 that are used in the dry storage facility at SONGS are 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 88 transportable.
1 What I can tell you is that there are 2
currently two models of casks that are in use. They are 3
the 24PT1 and the 24PT4. Both of those have been 4
approved for transport.
5 the 24PT1 canister has been certified for 6
transport under Certificate of Compliance 9255. You can 7
access that on our website. That's the NP 187 Transport 8
Cask.
9 The 24PT4 canister is also certified for 10 transport. And that's under Certificate of Compliance 11 9302. And that's the MP 197 Transportation Cask.
12 The transportation cask for the 32PTH2 13 canister has not yet been approved, but application has 14 been made. They're not authorized yet to load canisters 15 into that canister as yet, but the application has been 16 made by San Onofre. So, that's the status of the 17 transportation.
18 MR. CAMERON: Okay. And let's go to the 19 final part of the question.
20 MR. CAMPER: Well, there was a couple 21 questions embodied within your remarks. Let me try to 22 address the ones that I heard.
23 The
- PSDAR, the Post Shutdown 24 Decommissioning Activities Report, it is correct that we 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 89 don't approve it, but we do review it and we do ask 1
questions.
2 We look for completeness. We look for 3
adequacy. If all of the criteria in our regulations are 4
not addressed - and one of Bruce's slides identified the 5
things that has to be contained within the PSDAR - we will 6
ask questions.
7 And the reason that we don't approve it, but 8
we approve the License Termination Plan, is because the 9
activities carried out in decommissioning have been 10 evaluated within the Environmental Impact Statement and 11 the considerations for licensing and operating a 12 reactor.
13 And the kinds of activities that go on 14 during decommission are considered to be less severe, 15 less risk than the operating reactor conditions, which 16 is the basis for not approving the PSDAR, but I don't want 17 you to go away with the impression that we don't hold the 18 applicant to satisfy all of the criteria that was 19 identified in the slide about the contents of the PSDAR.
20 The 60-year thing just to reiterate 21 something that was in one of Bruce's slides, I mean, the 22 reason that the Commission in the 1996-1997 time frame 23 put into its regulations the 60-year criteria, which is 24 considered to be 50 years for the facility to cool off 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 90 in terms of radiation decay and in ten years to dismantle, 1
is because at 50 years the dose to workers is reduced to 2
on the order of one percent of what it would have been 3
had the reactor gone into immediate dismantlement and 4
decommissioning.
5 And the volume of waste that has to be moved 6
out of the community and transported to a waste disposal 7
facility is reduced on the order of ten percent.
8 And what drives that principally is one 9
particular isotope called Cobalt-60 which is a very 10 energetic gamma matter that has a half life of 5.2 11 years-5.7 years.
12 So, in that period of 50 years, it's gone 13 through ten halve lives, which means that radiation 14 contribution has gone away through decay. So, that's 15 the basis for those 60 years.
16 I know that it seems like a long time, but 17 that's the basis.
18 MR. CAMERON: Okay. We have to get you on 19
- here's the deal. Here's the deal is that we can go into 20 depth on any one of these questions.
21 What we're trying to do in the time we have 22 available is to hear as many questions on different 23 topics as we can. I mean, that's just practically what 24 we have to do here, okay? So, we can't just keep 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 91 following up on it.
1 MR. CAMPER: There is one question of hers 2
I didn't answer, though.
3 MR. CAMERON: Go ahead.
4 MR. CAMPER: There was another part of your 5
question that needs an answer. You really in the 6
beginning of your comments expressed concerns about the 7
availability or the lack of availability of a high-level 8
repository for where the spent nuclear fuel should go.
9 That is a significant, national issue that 10 continues to play out. The Nuclear Regulatory 11 Commission is charged with certain responsibilities 12 under the Nuclear Waste Policy Act to license the 13 high-level waste repository, but the Department of 14 Energy is charged with developing and seeking 15 authorization for that high-level repository.
16 That matter is ongoing. It has political 17 sensitivities associated with it. It has court -
18 ongoing court proceedings associated with it. There was 19 recently a position issued by one of the courts and the 20 Commission is currently - is evaluating that recent court 21 decree by communicating and asking for comments from the 22 parties that were subject to the hearing about the best 23 way to proceed, but the Nuclear Regulatory Commission 24 will proceed to look at this, you know, come out in a 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 92 situation once it starts - it completes gathering its 1
comments that it's undergoing right now.
2 So, it's a very complicated national 3
problem.
4 MR. CAMERON: Do you have something?
5 CHRIS (phonetic): Hi, I'm Chris. I live in 6
San Clemente and I think we're all here because we want 7
just the transparency and to know that this will be safely 8
handled and we're putting our lives in your hands.
9 Almost eight and a half million of us.
10 You did a slide in which you compared how 11 do we get safely from, for example, Connecticut Yankee 12 and San Onofre and so forth and do you - it's a two-part 13 question - do you consider Connecticut Yankee safely in 14 a safe spot? Question 1.
15 MR. WATSON: Yes, absolutely.
16 CHRIS: Okay. And then -
17 MR. WATSON: We've met all our license 18 criteria for license termination. The site was - I guess 19 we want to call it a greenfield in many respects. They 20 did leave some subterranean, I'll call it, foundations 21 which were radiologically clean. And so, the actual 22 decommissioning was completed safely.
23 They do - the state of Connecticut is 24 continuing to monitor some of the groundwater. They did 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 93 remove a significant amount of soil, because they did 1
have some underground tankage and piping leakage. Most 2
of that contaminated soil was removed.
3 And so, yes, it did meet our criteria and 4
it will meet our criteria through the future.
5 CHRIS: So, the second part of my question 6
is in a report in my research in 1994, Connecticut Yankee 7
did leak Tritium which is a highly radioactive material.
8 And I guess you are saying that you were able 9
to successfully decon that because there were 10 deteriorating underwater pipes.
11 So, my question and how that correlates on 12 the slide that you put together is, how do we know that 13 San Onofre, the underground pipes are not deteriorating 14 and leaking in the same fashion?
15 MR. WATSON: At Connecticut Yankee they did 16 what they called the big dig, which was remove all the 17
- I'll say most of the contaminated soils. Some of it 18 went to the bedrock which they continue to monitor.
19 At San Onofre they have a groundwater 20 monitoring program. They also investigate any 21 contamination events so that they see that the soil or 22 whatever if they did have some kind of leak would be 23 monitored and assessed.
24 And so, as part of their environmental 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 94 report they do do annual environmental monitoring. They 1
do groundwater sampling and other sampling along the site 2
to make sure that these type of events aren't occurring.
3 MR. CAMERON: Okay, thank you. Could we 4
have the coalition questions Three and Four? And I'm 5
going to read them.
6 Will the NRC allow the resale of 7
non-radioactive equipment and secondary side 8
components, turbines, MSRs, heat exchangers? And you 9
can see all that up there. So, will the NRC allow the 10 resale of this?
11 And since some of these are almost new, will 12 they be sold and where will the proceeds go? Is that 13 something that's within our scope?
14 MR. WATSON: As the NRC, we regulate the safe 15 use of radioactive materials. Any of these materials 16 that are not contaminated or have any radioactive 17 material associated with them, the utility or the 18 licensee is free to do whatever they want to with the 19 surplus equipment, scrap steel, whatever it is that they 20 produce as part of the decommissioning.
21 And so, the proceeds from that would be more 22 subject to the California regulators and not the NRC.
23 MR. CAMERON: Okay.
24 MR. WATSON: We don't regulate commerce. We 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 95 regulate radioactive materials.
1 MR. CAMERON: All right. And let's go to the 2
California regulator. This is Cynthia Walker.
3 MS. WALKER: So, any proceeds that come from 4
the sale of any of the components of the reactor would 5
actually offset the cost of decommissioning. So, that 6
would be part of what we would be looking at in the 7
decommissioning proceeding.
8 There's also - I just want to mention 9
there's also an investigation that's going on separately 10 that I know many of you who are active are aware of and 11 involved and maybe even have party status.
12 So, there's going to be some overlap, but 13 all of these things are going to be happening and being 14 coordinated together. But, yes, any revenues that are 15 received would then be offset for the decommissioning 16 costs.
17 MR. CAMERON: All right. Thank you very 18 much, Cynthia. The fourth question, could we have that?
19 Oh, there it is.
20 We would like to know if there can be public 21 announcements when any, quote, allowable, unquote, toxic 22 waste is to be re-released into the environment.
23 We would also like to know in general and 24 relative terms that everyone can understand, what the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 96 upper limits are for releasing radiation and toxic 1
chemicals into the environment during the 2
decommissioning process, when were those limits 3
established and what would trigger a process to 4
reevaluate them.
5 So, there is a lot there, but I think that 6
could be pretty simply answered, I hope, Bruce.
7 MR. WATSON: Yes. The regulations for 8
monitoring and the release of radioactive materials from 9
the site, the radioactive effluence, were instituted 10 decades ago in 10 CFR 20.
11 In decommissioning, the regulation still 12 applies if the plant was operating. And so, from that 13 standpoint the radioactive effluence from the plants are 14 continuously monitored and measured. Blair's people 15 will inspect to that to make sure that that is being done.
16 And the utility typically will issue an environmental 17 report reporting the effluence they've had from the 18 plant.
19 Now, the NRC regulates the radiological 20 part of that. Other state or Federal agencies take care 21 of other materials that may be released from the site and 22 they typically have permits for that.
23 So, the state of California may issue 24 permits for the release of other materials that we would 25
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1 MR. CAMERON: Okay, thank you. Thank you 2
very much, Bruce. I think we need to give people on this 3
side of the room a chance.
4 And, Bob, at some point can you read the one 5
question we got about climate change and how that is taken 6
into account? Why don't we go to the woman you're 7
standing next to.
8 PARTICIPANT: Thank you. My question is 9
about NRC oversight during the decommissioning process 10 as two parts.
11 When SONGS was operating, there was an NRC 12 employee who worked on site everyday. Does the NRC use 13 the same approach during decommissioning? And if so, 14 how do onsite staffing and the role of those onsite staff 15 evolve during the various phases of decommissioning?
16 MR. CAMERON: Good. Blair Spitzberg.
17 MR. SPITZBERG: The question relates to 18 basically we have had during the operation of the San 19 Onofre unit, we've had resident inspectors that are based 20 at the site. They work at the site everyday. They have 21 an office there and they are inspecting day in and day 22 out throughout the year.
23 Once the plant shuts down, we will continue 24 to have a resident inspector there at the site for at 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 98 least a year, maybe longer. And that person is going to 1
be certified to do decommissioning inspections as well.
2 So, he will be utilized in that capacity.
3 He's already qualified and trained and very 4
seasoned inspector. And we value his input to the 5
inspection process there.
6 Beyond a year I can't speak to whether or 7
not he will remain there or not. It's usually a 8
case-by-case basis and depends on the level of activities 9
at sites and whether we can justify the level of 10 inspection at the site at that time.
11 We also plan to utilize this inspector at 12 some of our other decommissioning inspections in the 13 state of California and elsewhere as well. So, yes, we 14 will have a full-time senior inspector there at site for 15 at least a year.
16 MR. CAMERON: Okay. And, Bob, let's go to 17 your people over there. I think we have four people over 18 here that we'll get to, but let's take care of people on 19 your side of the street.
20 MS. PADD: Yes, my name is Marsha Padd. I'm 21 part of the Group to Decommission San Onofre. And I 22 share the concerns of the previous questioners, but I do 23 have a somewhat different concern.
24 This regards to the safeguards that you 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 99 hopefully have in place and will implement with regard 1
to potential security risks in the future that could 2
endanger the integrity of the plant and the safety of the 3
surrounding communities.
4 Regarding the decommissioning process, 5
what kind of safeguards have you planned for the 6
transportation of nuclear waste?
7 This would also include transportation of 8
radioactive material to a permanent depository. And in 9
addition especially with regard to the proliferation of 10 drones and the private sector, private ownership, it's 11 become a hobby nowadays, what safeguards have you 12 implemented and thought about in this area? Thank you.
13 MR. CAMERON: Okay. The concern generally 14 was about security and safeguards, but the questions went 15 to transportation safeguards. And could you just repeat 16 the last part of that so everybody can hear it?
17 Did you say "drones"?
18 MS. PADD: Yes.
19 MR. CAMERON: Okay. All right.
20 MS. PADD: That's a serious problem.
21 MR. CAMERON: Okay. Thank you. And I don't 22
- if anybody knows anything about the drone issue, 23 address that, but can we talk about the security in 24 transportation issue for her?
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 100 MR. SPITZBERG: The site will remain under 1
the Physical Security Plan that it has been under during 2
operations. And that will continue into the future.
3 They have a very substantial security force on site and 4
substantial number of security systems.
5 Obviously I can't go into specifics about 6
that, because that's information that we restrict access 7
to. But, nonetheless, it has the security that's 8
equivalent to any of the nuclear sites throughout the 9
country and it will remain that way.
10 What was the second question? The drones.
11 I cannot specifically answer the question to the drones.
12 I don't know whether there's been a risk assessment 13 associated with that or not.
14 MR. CAMERON: Okay. If anybody - go ahead, 15 Larry.
16 MR. CAMPER: I was going to address the waste 17 issue.
18 MR. CAMERON: Okay.
19 MR. CAMPER: With regards to the waste 20 question as you know from earlier discussion this 21 evening, the spent nuclear fuel will remain on site for 22 some period of time either in the pool or in dry cask 23 storage. And so, there's probably nothing more that I 24 can say about that than we've already talked about. I 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 101 think we all understand the reasons for that.
1 With regards to the waste, you expressed a 2
question or concern about the waste, when the reactors 3
decommissioned, the majority - we have a waste 4
classification system in our regulations where waste is 5
classified as Class A, Class B, Class C or greater than 6
Class C.
7 When nuclear power plants are 8
decommissioned, by and large the majority of the waste 9
that comes out of decommissioning is Class A waste, which 10 is at the very low end of our risk scale for waste.
11 There is some Class B and some Class C waste.
12 A very small amount of greater than Class C waste which 13 will remain on site in a canister in the independent spent 14 fuel storage installation, but the waste will then be 15 taken in approved canisters for shipping waste and in 16 accordance with Department of Transportation 17 regulations, and will ultimately be disposed of at a 18 commercial disposal facility.
19 It is conceivable, for example, that the 20 waste, especially the Class A waste, which is the 21 majority of waste that comes out of decommissioning, 22 could find its way to the energy solution site in Clive, 23 Utah. It is also possible that it may make its way to 24 the site in Andrews, Texas.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 102 There is also a site in the northwestern 1
United States that's a possibility, but what's important 2
is that the majority of the waste, Class A, it's the 3
low-risk end of waste, transported in approved shipping 4
containers for that type of waste following Department 5
of Transportation regulations and will ultimately be 6
disposed of in a commercially operated disposal 7
facility, which there are four in the United States 8
today.
9 MR. CAMERON: Okay, thank you. And could 10 one of the staff members from the NRC after the meeting, 11 talk in more depth with the woman who asked the question 12 about the drones so that we can try to find more about 13 that.
14 You want to talk to that, Bruce? Go ahead.
15 MR. WATSON: Just briefly discuss this.
16 MR. CAMERON: Okay.
17 MR. WATSON: It's not really my area of 18 expertise, but I think everyone can recall that the 19 assessment for an aircraft hitting a nuclear power plant 20 has been pretty well established and studied and the 21 design in the plant. And that was revisited after the 22 9/11 terrorist attacks.
23 And so, I think the bounding of a drone 24 striking the nuclear facility or the reactor containment 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 103 building has been analyzed and it would be well within 1
that safety envelope.
2 MR. CAMERON: Okay, great. Thank you for 3
that. And we're trying to get as many different areas 4
out as possible. And we did security. We had the state 5
regulators talk. We talked about high burnup fuel.
6 We do have a question on another pressing 7
concern and this is climate change, I believe. This was 8
a written question given to us.
9 Bob, would you read that question?
10 MR. HAGER: Chip, yeah. This is one of the 11 written questions and it is, has the effects of climate 12 change been considered? Recent science suggests the 13 rises in sea level from ocean temperature increases and 14 contributions from snow melt. In addition, extreme 15 precipitation events will likely become more common.
16 For example, the hundred-year storm may occur every 50 17 or 75 years.
18 So, how are climate change - how are these 19 climate change variables accounted for during long-term 20 decommissioning?
21 MR. CAMERON: Okay, good question. How does 22 that happen? Larry.
23 MR. CAMPER: Well, there is a generic 24 environmental - and let me make something very clear. 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 104 use the term - Generic Environmental Impact Statement is 1
an NRC vernacular. It's the same thing as a Programmatic 2
Environmental Impact Statement which is a term that's 3
used elsewhere when NEPA, the National Environmental 4
Policy Act, evaluations take place.
5 And sometimes - one of the comments earlier 6
was about a concern about something being generic.
7 That's a criticism we've heard before, but it's just a 8
vernacular that we use for a Programmatic Environmental 9
Impact Statement.
10 But there is a Generic Environmental Impact 11 Statement or Programmatic Environmental Impact 12 Statement that has been prepared by the Agency dealing 13 with decommissioning of nuclear power plants.
14 Also, in the PSDAR the applicant, the 15 licensee, has to provide any update in terms of any 16 environmental consequences that were not considered at 17 the time the site was constructed and the environmental 18 impact statement for that or the Generic Environmental 19 Impact Statement associated with decommissioning of 20 nuclear power plants.
21 One of the things that not only our agency, 22 but all federal agencies as a result of recent Council 23 of Environmental Quality directions is to look at climate 24 change.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 105 And so, the primary impact of 1
decommissioning with regards to climate change is 2
equipment, caterpillars and things of that type that 3
actually move material around while the decommissioning 4
is going on and those emissions and so forth.
5 But any contribution to the climate change 6
via greenhouse gases has been and is evaluated as part 7
of the environmental assessment that we conduct.
8 MR. CAMERON: Okay. Thank you and we have 9
Ray Lutz.
10 MR. LUTZ: Yes, thank you. My name is Ray 11 Lutz with Citizens Oversight and the Coalition to 12 Decommission San Onofre. I am involved with the 13 California Public Utilities Commission investigation 14 that's going on.
15 One of the things that has come up, and this 16 is actually with regard to the decommissioning triennial 17 cost review, has to do with the fact that they say that 18 they haven't had any decommissioning costs approved by 19 the NRC and this is the reason they don't know how much 20 it's going to cost even for Unit 1.
21 So, I'm wondering if the PSDAR has been 22 submitted and approved - or you say you don't approve it, 23 which is a catastrophe, in my view. You guys should 24 review the PSDAR and stamp it "Approved" or "Not 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 106 Approved" and put your butt on the line, because we're 1
putting our butt on the line out here.
2 And for you to say we don't approve it is 3
something that takes my breath away. You either approve 4
it, or not approve it, and don't give me this stuff about 5
asking questions.
6 So, Question 1 is, have you received the 7
PSDAR and approved it for Unit 1? Don't go on. I've got 8
a few more questions here.
9 And the License Termination Plan. Now, 10 maybe there's a terminology problem here. Maybe you're 11 saying that they haven't submitted the License 12 Termination Plan yet.
13 Well, when are we going to know how much it's 14 going to cost? Because Unit 1 has been sitting there for 15 many years now and they say in our meeting that they still 16 don't know how much it's going to cost to decommission 17 that as if they haven't started it.
18 I'm wondering also you say these casks can 19 be transported. It seems to me they need to be 20 transported right away.
21 Now, is there an interim location where we 22 can put these casks away from these population centers 23 and in a non-seismic and non-coastal area? So, that's 24 really kind of like my second question there.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 107 So, if you can answer those, I'd appreciate 1
it.
2 MR. CAMERON: Okay. And thank you, Ray.
3 And the staff can quickly reiterate the scheduling things 4
about the PSDAR and all that, but I think Ray's question 5
about the process for the NRC review, Larry, you talked 6
to this a little bit.
7 Can you talk about why there is a review and 8
not an approval, but first can we talk about has there 9
been a submission of the PSDAR or License Termination 10 Plan? Can we just clear that - emphasize that for 11 people?
12 MR. WATSON: For Unit 1.
13 MR. CAMERON: For Unit 1, okay. Unit 1.
14 MR. WATSON: For Unit 1, there was a PSDAR.
15 (Speaking off mic.)
16 MR. WATSON: I don't know that off the top 17 of my head.
18 MR. CAMERON: We'll get you that offline.
19 Go ahead.
20 MR. WATSON: But let me -
21 (Speaking off mic.)
22 MR. CAMERON: Wait one second. One second.
23 Let's let Bruce finish.
24 MR. WATSON: The rationale behind the fact 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 108 that we are not required to approve the PSDAR was a 1
Commission decision. It was decided by the five NRC 2
commissioners.
3 MR. CAMERON: Not the present -
4 MR. WATSON: No, not the present Commission, 5
but it was a Commission decision.
6 MR. CAMERON: Okay.
7 MR. WATSON: And the basis for that was that 8
within the realm of decommissioning activities, the 9
licensee could conduct those activities safely within 10 the existing license. And so, that was their basis for 11 that decision.
12 The Commission voted and approved the fact 13 that we would not have to approve a PSDAR, because they 14 could conduct the decommissioning activities safely 15 within the existing license which they already 16 possessed.
17 In other words, they are allowed to do 18 maintenance. They are allowed to do shipment of 19 radioactive materials all during operations. And we 20 expect - and the Commission decided that they could 21 continue with those types of activities which are part 22 of the decommissioning without us approving a PSDAR.
23 Okay?
24 MR. CAMERON: Okay.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 109 MR. WATSON: It may sound funny, but it was 1
a policy decision by the Commission.
2 MR. CAMPER: Well, let me add to that. Let 3
me just add to that.
4 MR. CAMERON: Go ahead, Larry.
5 MR. CAMPER: At the time the Commission made 6
the decision, at the time the Commission made the 7
decision in 1996-1997 time frame that exists today for 8
the decommissioning of reactors, there was a recognition 9
of what Bruce just said. There was also recognition that 10 the expertise that resided within an operating reactor 11 facility was such that it could accommodate 12 decommissioning.
13 The activities of decommissioning were 14 considered to be less severe from a risk standpoint as 15 compared to, if you will, a material site.
16 When a material site, let's say, for 17 example, a facility existed where certain metals like 18 vanadium were processed, but there was uranium and 19 thorium as a consequence, those types of facilities - we 20 call them materials facilities - can't proceed to do 21 decommissioning at all until such time that it's 22 approved.
23 And to a large degree, that's because those 24 types of facilities don't have the expertise. They 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 110 don't have the operating experience that nuclear power 1
plants have.
2 So, that was part of the logic that led the 3
Commission to believe that given the point that Bruce 4
made that if they could operate a nuclear power plant and 5
they could ship waste and do those types of things, they 6
could begin the process of identifying how they wanted 7
to decommission that facility. And, therefore, we 8
review, but don't approve the PSDAR.
9 But what's, I think, the most critical 10 component in the decommissioning process is the License 11 Termination Plan, because it is in the License 12 Termination Plan that we do review and approve and which 13 they identify, for example, the final status survey, the 14 concentration of radioactive materials that will remain 15 in the soil that will identify and ensure that they meet 16 the dose standard that I cited during my presentation.
17 So, that is the critical part in terms of 18 what that site is going to ultimately look like in terms 19 of satisfying the dose criteria. And we do review and 20 approve that.
21 MR. CAMERON: Okay. Let's hear what you 22 have to say. And the last part of Ray's question has been 23 a concern that we've heard from others in the audience.
24 In other words, the movement of fuel from the site.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 111 Can we talk a little bit about that before 1
we go on? I have four people over here I want to get to, 2
but go ahead.
3 MR. EVANS: I just wanted to clarify a Unit 4
1 PSDAR was submitted in 1998. And a couple of weeks ago 5
I dug up a hard copy of it and put it into our ADAMS system.
6 So, if you go into the Unit 1 docket file, 7
it should be there, but keep in mind that the Unit 1 PSDAR 8
is kind of like a high-level document. It doesn't 9
provide a tremendous amount of detail. It's just sort 10 of like a management level, this is how we're going to 11 do Unit 1 decommissioning.
12 I was aware that a draft License Termination 13 Plan was developed, but I don't think it was ever 14 submitted to the NRC. I will double-check that, but I 15 don't think the LTP was ever submitted. Drafted, and 16 then that's as far as it got.
17 MR. CAMERON: Okay. Thank you very much.
18 Good information. Can we go to the last issue that Ray 19 raised and it was raised over here?
20 MR. CAMPER: Yeah, the essence of your 21 concern, if I understood correctly, was the idea of 22 moving the spent nuclear fuel away from the coast, away 23 from this site and putting it in some interim storage 24 facility.
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NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 112 In every nuclear power plant that's been 1
decommissioned thus far, there is spent nuclear fuel 2
there in an independent spent fuel storage installation.
3 That's because in the United States today, we as a nation 4
have not solved the issue of the final geological 5
repository for the disposal of spent nuclear fuel.
6 And so, what has happened is the industry 7
has reacted to that by developing the cask storage 8
systems that we've been discussing tonight. That was 9
done out of necessity, because the kinds of actions that 10 were envisioned in the Nuclear Waste Policy Act of 1982 11 and amended a few years later have, in fact, not 12 transpired.
13 With regards to interim storage, there is 14 no interim storage facility in the United States today.
15 Recently the President's Blue Ribbon 16 Commission on America's Nuclear Future undertook an 17 in-depth analysis. And one of the key findings that was 18 contained within that report was that the country should 19 proceed to develop one or more interim storage facilities 20 until such time as the high-level repository issue could 21 be addressed.
22 Currently, the contents of that report are 23 under consideration by the Congress. Certain 24 congressional acts would have to transpire if, in fact, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 113 those recommendations were to be successfully carried 1
out.
2 There was several years ago a company called 3
Private Fuel Storage that applied for and did receive a 4
license to operate an interim storage facility in Utah.
5 They underwent an in-depth evaluation by the Nuclear 6
Regulatory Commission, a Safety Evaluation Report was 7
issued, a license was issued, and in-depth Environmental 8
Impact Statement was prepared.
9 However, in the final analysis, that 10 facility for a number of different reasons could not 11 receive authority from the Federal government for the 12 railroad line to be built to that facility. And 13 ultimately that facility did not open for that purpose.
14 And not too long ago, in fact, PFS, Private 15 Fuel Storage, decided they would not proceed with that 16 license activity at all. So, we do not have in the United 17 States today an interim storage facility.
18 Some communities have started to express 19 interest in hosting an interim storage facility. One of 20 the fundamental principles that the Blue Ribbon 21 Commission thought was important was that there should 22 be a buy-in, a stakeholder interest, a community interest 23 in hosting an interim storage facility. Or for that 24 matter, a high-level waste repository.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 114 There is a county in New Mexico that has, 1
in fact, written a letter to us indicating that they have 2
a strong interest in submitting an application for an 3
interim storage facility.
4 There's some movement in Mississippi around 5
the possibility of hosting an interim storage facility.
6 And there's some interest in South Carolina as well at 7
the Savannah River site.
8 So, we'll have to wait and see what happens 9
with regards to an interim storage facility becoming a 10 reality for this fuel to be removed not only from the 11 SONGS facility, but from other facilities that have 12 undergone decommissioning and currently have spent 13 nuclear fuel in dry cask storage or, for that matter, what 14 the United States is going to ultimately do about, in 15 fact, developing a high-level repository.
16 I wish I could paint a prettier picture than 17 that, but that is reality.
18 MR. CAMERON: Okay, thank you. We're going 19 to go here, then the gentleman in the green hat, to white 20 shirts, and then the gentleman back there.
21 Dave.
22 MR. WEISMAN: David Weisman, Alliance for 23 Nuclear Responsibility. To follow on to that and the 24 concerns raised about this, may we look at the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 115 intermediate step, which would be the expedited removal 1
of spent fuel from the pools with an inherent 2
vulnerability at least to the dry cask storage even as 3
it should exist at the site on an expedited matter.
4 Now, I know this is a subject for national 5
discussion, Tier 3 Post-Fukushima Recommendation on 6
Expedited Transfer of Spent Fuel, and that's being 7
discussed at a national level, but we have state 8
regulators here today.
9 Mr. Oglesby's agency, the California Energy 10 Commission, has been recommending every year since 2008 11 that the utilities undertake the expedited removal of 12 spent fuel from the pools and place them in dry casks in 13 that matter.
14 The Public Utilities Commission would hold 15 the purse strings on the decommissioning funding being 16 used for that purpose.
17 In fact, I raise that question because in 18 a request for additional information that came out on 19 this, the question the NRC asked was, please specify if 20 any of the accumulated fund balances for 21 non-radiological decommissioning costs such as spent 22 fuel management or other non-radiological 23 decommissioning activities.
24 Now, they may just be asking the costs, but 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 116 I hope they're not attempting to imply, and you alluded 1
to this earlier, that money can be moved around within 2
categories for parts of the decommissioning.
3 Should our state recommend it and wish them 4
to do it? And should our state's public utilities 5
commission say we think that's a fine use of the money.
6 Any intent by the NRC to put any brakes on the state of 7
California proceeding with that irrespective of your 8
national Tier 3 spent fuel movement issues?
9 MR. CAMERON: Thank you.
10 MR. DUSANIWSKYJ: I believe that the 11 document you have in your hand was a result of the 12 Biannual Decommissioning Funding Report that was 13 submitted by all the licensees back on March 31st of this 14 year.
15 What we were asking was specifically to 16 determine that the amount that was stated in that report, 17 and I have a copy of it here with me, was, in fact, the 18 amount of money that they have stated is dedicated to the 19 NRC's requirements for decommissioning.
20 So, we were asking that question to verify 21 that, in fact, that the statements in the March 31st 22 submittal were, in fact, what was supposed to have been 23 stated.
24 In determining what you've also proposed as 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 117 to whether or not money can be shifted around in whatever 1
manner you want to call it, there is a certain sequence 2
of events that will probably have to take place in any 3
decommissioning activity.
4 First and foremost being that the licensee 5
shall have to decontaminate that facility before you 6
start to even begin to think about greenfielding.
7 And the basic answer to that question is 8
that once the decommissioning to the NRC standards has 9
been completed, the NRC has no jurisdiction over that 10 money and the licensee is free to use that money for 11 whatever additional decommissioning can be anticipated 12 with the funds that have been indicated to us in the March 13 31st submittal.
14 MR. CAMERON: Okay, thank you. Yes, sir.
15 Please, David, we're going to have to go on.
16 MR. GARDNER: Hi, I'm Richard Gardner. Just 17 some maybe answers or some questions I have. One would 18 be out of all the nuclear facilities in the United States, 19 how many pounds or cubic yards or the volume of waste?
20 And then I know it's following an exponential decay, you 21 know, curve so that in time it will be less and less. So, 22 and then on the other hand I'm thinking about the NRC and 23 your staffing level.
24 So, what year do you think the most number 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 118 of nuclear plants will be decommissioned and you'll have 1
the most amount of fuel to deal with? You'll need 2
inspectors.
3 Now, out of the 96 I think that are 4
operating, you know, there will be some day ten years out, 5
15, where you're going to have 25 decommissioning 6
facilities and it will be, you know, hopefully there will 7
be some more really choreographed, orchestrated, you 8
know, national approach to doing this so that it isn't 9
purely in the hands of utility companies with separate 10 branches of new people that are working. You know what 11 I'm saying?
12 Even though I have great confidence in the 13 NRC, I'm thinking this somehow could be standardized.
14 Maybe you already have a standard review plan for 15 decommissioning in place.
16 MR. CAMERON: Thanks, David. Larry.
17 MR. CAMPER: A lot of interesting things in 18 your comments. Thank you. NEI, the Nuclear Energy 19 Institute, there's a graphic that comes to mind that I've 20 seen several times, but they did put it together just a 21 few years ago. I want to say like three or four years 22 ago.
23 But it showed at that time the next bow wave 24 of decommissioning, if you would, when the Class A and 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 119 some Class B and Class C waste would be created because 1
of reactor decommissioning, was in the 2035 to 2045 2
period.
3 Now, that peak has changed slightly in the 4
last few years because there has been renewals of power 5
plants that wasn't anticipated at that time. So - but 6
I still think it's fair to say that the next bow wave of 7
decommissioning is in the 2035 to 2055 period and the fact 8
of the matter is that at some point they're all going to 9
have to come down. They're all going to decommissioning 10 at some point. That's in some ways, that's a long time 11 from now. And in some ways, it's tomorrow.
12 What we're trying to do about tomorrow, if 13 you will, is memorialize and capture all the information 14 that we can about the decommissioning we've already done, 15 the 11 nuclear power plants that I showed in my slide, 16 you know. Now, we've had five units go into sudden 17 announced decommissioning in the last year. There may 18 be others.
19 So, what we're trying to do is, is capture 20 as much information as we can for those who will follow 21 us doing the decommissioning in that 2035 to 2050 time 22 frame.
23 But we do have a standardized review 24 process, we have an extensive amount of guidance that we 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 120 have put together to facilitate decommissioning in the 1
future. We continue to take lessons learned and put out 2
information and/or modify our guidance.
3 I can tell you that the staff right now is 4
already starting to look at in view of the fact that five 5
units are going to decommissioning recently, maybe 6
others, the staff is already starting to look at what we 7
think is a very successful decommissioning program as 8
witnessed by the number of facilities available for 9
decommissioning, but we're also starting to already look 10 at are there any changes we need to make to the program, 11 are there lessons learned from what we've done and make 12 some adjustments.
13 And we do plan to communicate with our 14 commission about it, because the Commission has a lot of 15 interest in it as well.
16 MR. CAMERON: Thank you very much. Yes, 17 sir.
18 MR. CHRISTMAN: Good evening. Thank you for 19 your patience and perseverance. My name is Patrick 20 Christman. I'm the assistant chief of staff for Marine 21 Corps Installations West Camp Pendleton.
22 I'd like to ask a question. Camp Pendleton 23 has one of the largest environmental staffs in the whole 24 Marine Corps and one of the largest budgets.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 121 Obviously that's because of the unique 1
challenges of dealing with the California regulatory 2
scheme. We've heard from the PUC and the CEC tonight.
3 Could you please talk a little bit about 4
your interaction through the NRC process with the other 5
state agencies such as the Coastal Commission or Cal/EPA 6
or any of those other folks that we have to deal with on 7
a regular basis? Thank you.
8 MR. CAMERON: Thank you. Larry, are you 9
going to -
10 MR. CAMPER: Well, whether it be California 11 or any other states where decommissioning takes place, 12 there are state laws and regulations that the operator 13 of the facility has to satisfy.
14 I mean, for example, a little bit earlier 15 we were talking about discharge permits, but that's a 16 state function or EPA or depending on how it's been 17 delegated to the state function.
18 We do interface with those state agencies 19 along the way. They are carrying out their regulatory 20 responsibility. We're carrying out our regulatory 21 responsibility. There's a lot of communication that 22 goes on, but let me say this and I'll give you an example.
23 Even though the nuclear power plants are 24 authorized to operate under our Part 50 license and even 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 122 though they are subject to our regulations in 1
decommissioning, one of the things we always say to the 2
utilities is you need to make sure that you understand 3
what your state requirements are wherever they may be.
4 Because that's the last jurisdiction you're going to be 5
facing.
6 Even if you successfully decommission the 7
reactor under our regulations, some states even though 8
we have a federal standard in our regulations that I 9
shared with you earlier, some states have developed their 10 own decommissioning criteria for nuclear power plants.
11 Maine comes to mind. Connecticut comes to mind.
12 Connecticut developed a
19 millirem 13 standard as compared to our 25 millirem and ALARA 14 standard. So, the licensee has to deal with the state 15 agencies and recognize those requirements, but we do 16 communicate with the state agencies throughout the 17 process, but each of us are caring in our respective 18 regulatory regimes.
19 MR. CAMERON: Okay, thank you. Thank you.
20 We have this gentleman right here and then we're going 21 to go over to right here. Yes, sir.
22 MR. FAWCETT: My name is Ed Fawcett. I'm 23 president of the Costa Mesa Chamber of Commerce. I've 24 attended several of these public hearings pertaining to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 123 SONGS and wrote in support of Edison's safe restart of 1
Unit 2 reactor.
2 I say "wrote," because there never previous 3
to tonight, there was never a time for anybody on this 4
side to make a statement on behalf of the - voice an 5
opinion.
6 Yet again I'm spending quite a bit of time 7
watching without great humor, another spectacle that 8
leaves me both baffled and disheartened in our elected 9
and appointed leaders.
10 Whose hearing is this? The NRC has again 11 allowed a handful of anti-nuclear activists to have 12 center stage obviously on the agenda without being 13 written in the agenda just dominating the proceeding.
14 My question followed by a brief comment, why 15 hasn't the NRC provided the same air time to those who 16 support nuclear energy and have previously supported the 17 safe restart of SONGS?
18 While we're waiting for NRC to do its job 19 and make the decision, SCE was required to keep SONGS 20 operation-ready. The cost of about a million dollars a 21 day.
22 Due to mounting costs, SCE finally had to 23 make the good business decision to retire SONGS after 24 more than 500 million dollars in cost runup.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 124 As a business person and Chamber person, I 1
can easily understand SCE's need to make this decision 2
to stop the growing cost to taxpayers and to ratepayers.
3 Why can't the NRC make decisions in a 4
reasonable amount of time without hiding behind a lot of 5
public opinion, multiple hearings - and just multiple 6
hearings? Thank you.
7 MR. CAMERON: Thank you for that comment.
8 And I think that just your reading that statement 9
provided air time to others who feel a different way, but 10 part of the explanation, I have to repeat this again, is 11 that the questions that we got from the coalition of 12 citizen groups are questions that are on a lot of people's 13 minds or should be on a lot of people's minds. And that's 14 why we started with that.
15 We're going to go to this gentleman right 16 here. Yes, sir.
17 MR. NELSON: Hi. My name is Douglas Nelson.
18 I'm from up the coast with a company, my own company 19 called Levitical Network.
20 I wrote down as a follow-up to Dale's 21 eloquent question to what extent is the NRC interested 22 in either prolonging or quickly executing the 23 decommissioning of the San Onofre reactor, this meeting 24 only seems to be prolonging the process of 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 125 decommissioning with each passing day and the failure to 1
shut down the second and third units.
2 As was mentioned by the councilman earlier, 3
the reactor remains open to natural catastrophic 4
occurrences.
5 Is it because of Cobalt-60 as was mentioned 6
earlier, or is it due to the use to use more money of your 7
annual billion dollar budget that we, the taxpayers, 8
generate?
9 In addition to that, it's ironic perhaps 10 that we generate through our taxes a billion dollars for 11 NRC for its billion dollar budget, but the tax - the taxes 12 that have been created are now diminishing for the 13 individuals who have been unemployed at the San Onofre.
14 And so, there appears to be, I think, a conflict, if you 15 will.
16 We're spending our tax dollars to have these 17 kind of meetings in large places where only two or three 18 people show up, and yet there are individuals whose tax 19 dollars are being used who are no longer employed by the 20 San Onofre reactor.
21 So, I would appreciate a response to that.
22 MR. CAMERON: And, Larry, there was a lot 23 there, but maybe one simple way to clarify something as 24 you might talk about how the NRC budget gets made up.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 126 MR. CAMPER: Yeah, I was going to -
1 MR. CAMERON: Okay, thank you.
2 MR. CAMPER: Thank you, Chip, and thank you 3
for the question. From our standpoint, we don't want to 4
prolong or necessary expedite the decommissioning.
5 What we have to do as a staff is carry out the regulatory 6
construct that has been created by our commission as to 7
how nuclear power plants will be decommissioned.
8 And as I explained earlier and other members 9
of the staff have pointed out, the basis for this 60 10 years.
11 Now, we understand that 60 years sounds like 12 a long time. We get that, but there is a technical basis 13 behind it and a risk basis behind it that led to and 14 supported the Commission decision that was made in the 15 1996-1997 time frame.
16 But with regards to the billion dollar 17 budget and the taxpayers and so forth, I understand that 18 concern, but it's also important to point out that the 19 Nuclear Regulatory Commission is a fee recovery agency.
20 The industry pays for 90 percent of the NRC 21 budget. And the things that we do through fee recovery 22 whether it be the annual fees that we charge or the fees 23 that we charge for review work is borne by the industry.
24 So, only 10 percent or so comes from the general treasury.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 127 And that is a change that congress imposed several years 1
ago now.
2 MR. CAMERON: Okay. We're going over to my 3
colleague. Go ahead.
4 MS. OREN: Hi. Thank you. My name is Mary 5
Oren. I am a Carlsbad resident. Lived in the area for 6
about 30 years. And I want to thank you so much for the 7
chance to share information here tonight. It's been a 8
really great experience.
9 And I'm so grateful for utility contact to 10 see, because my question is really for her. And also the 11 gentleman that is representing energy over there.
12 I think one thing we learned tonight, one 13 reason we're here is it's obvious that big energy 14 installations often bring big problems. And we've seen 15 that with San Onofre.
16 I think some of us are concerned about the 17 natural gas issue with fracking and how that can 18 contaminate water and cause earthquakes and then there's 19 the methane issue.
20 There are bigger installations for wind 21 which can interrupt bird migration. And the bigger 22 solar installations, I guess that's still to be defined 23 whether or not that's going to be dangerous or not.
24 The reason I want to talk tonight is to just 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 128 take one moment and look at the big picture. And the big 1
picture means we're all in this together; industry, 2
science, government and citizens. And I think as 3
citizens, it's time that some of us consider taking a 4
bigger part.
5 I'm a solar homeowner. And when I bought 6
my system, my installer said, okay, well, this is how many 7
you need to meet your power use. Don't go over that, 8
because then you won' recoup your cost.
9 So, I'm just one of many out there who hear 10 this everyday still. And it's very disappointing to me 11 because there's businesses and homeowners out there who 12 would be willing to invest in a couple more panels and 13 contribute to more power being available.
14 This is being done in other parts of the 15 world. It's called a feed-in tariff. Germany, France, 16 some places in our country do it where the citizenry is 17 providing clean energy.
18 And in Germany, they do it at the level of 19 50 percent residential solar projection. Here in San 20 Diego, America's finest city, sunshine almost everyday, 21 our percentage is three percent. That's crazy when 22 there's rooftops everywhere and people willing to be a 23 part of the solution.
24 So, as time goes by and we end up in these 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 129 kinds of situations where we're all doing our best to 1
qualify, we care, we're all in this together, we are 2
ratepayers, we want more solutions. We want more 3
options.
4 A huge piece of the solution is not 5
happening. We need to make it easier for residents and 6
businesses to invest in solar.
7 So, my question is with our energy contact, 8
what energy is coming in and replace of the nuclear?
9 I've already heard that we don't really need that.
10 And then in terms of the utility, maybe you 11 could please tell me why residents and businesses are not 12 allowed to be a bigger part of this process.
13 MR. CAMERON: Okay.
14 (Applause.)
15 MS. OREN: Thank you so much.
16 MR. CAMERON: Thank you. We're going to go 17 to Rob Oglesby right here on that question.
18 MR. OGLESBY: Well, just really briefly to 19 a very large question related to what we're doing to work 20 around the nuclear power that we don't have any longer, 21 and there are many pieces to it, and about half of the 22 energy - oh, so let me say in terms of the math, 23,000, 23 22,000 and change megawatts from San Onofre gone.
24 But when we look at what we need to do to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 130 work around not having that, it's more than just 1
replacing the wattage from that generation facility.
2 We're looking at things that are called 3
voltage support and reactive power that are kind of like 4
in a water system pressure in the lines.
5 We look at where the generation resources 6
are and what transmission options we have that we can 7
optimize, what we can do to make the system run more 8
efficiently.
9 As we've developed our recommendations for 10 the strategy to go forward, which isn't final, but we've 11 been studying it for some time now and coming up with 12 various options and our website at the Energy Commission 13 you could see a paper and the plan that we put forward 14 as recommendations.
15 But about half of the energy need which also 16 accounts for growth and the phase out of once-through 17 cooling facilities, it's all related, come from what we 18 call preferred resources.
19 And preferred resources include 20 efficiency, which is one of the best alternatives we 21 have, demand response, distributed generation which 22 includes solar, as well as very efficient fast-ramping, 23 clean fossil traditional generation and enhancements to 24 the distribution system and transmission system.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 131 So, I would commend you to look at the 1
recommendations that have been developed by the Energy 2
Commission working with its sister agencies of the CPUC 3
and CAISO, the independent systems operator, and have put 4
forth some scenarios that we're analyzing and will be 5
developing to go not only for how we're going to get by 6
next summer, but going forward in the next several years.
7 In terms of the pricing mechanisms, that's 8
been a very active discussion in California legislature.
9 Feed-in tariffs met energy metering and I can tell you 10 that as one of the agencies that's responsible for 11 attaining 33 percent renewables and sustainable energy 12 in California, we're very enthusiastic about solar and 13 would like to see greater distribution and use of solar.
14 MR. CAMERON: Thank you very much, Rob.
15 We're going to go to two people here. One in the back 16 of the room. And then I'm going to ask Larry Camper to 17 close the meeting out for us.
18 Yes, ma'am.
19 PARTICIPANT: This is so vast and so 20 complicated an issue from the standpoint of the 21 billionaire's control of the - through the energies and 22 the military combined coalition that it's controlling 23 not only our nation, but our world.
24 And those of us who have been putting our 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 132 lives into trying to make some protection for our 1
children and grandchildren and possible future 2
generations here for 50 years, no, we know what we're up 3
against and you're just one of the tools of it all, but 4
I think that its time has come for those of you who really 5
understand what's happening to speak out and to do 6
something about it.
7 Because when you talk about two years - I 8
was told that you're giving - I say "you," but it's the 9
commissioners are giving two years to Edison to develop 10 its plan. And it already has dragged along and delayed 11 and delayed in starting the closing of everything from 12 the time the failure took place just trying to stay on 13 the payroll and we understand that.
14 I mean, we can understand that that's 15 important to those people, but it's not your role to help 16 them every step of the way.
17 All through the years the decision has never 18 been made for us. I shouldn't say "never." Never say 19 never, right? But the point is that now you're talking 20 about 60 years.
21 How can anybody comprehend leaving us in the 22 center of the target for the conditions that we have in 23 the world today for 60 years?
24 I live two miles from that plant and I'm 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 133 working with a lot of organizations and I know that there 1
are millions of people in this country who understand 2
what - part of what is happening enough that they are 3
trying - they're desperately trying to get you to help 4
us, because we know that you are - your sole 5
responsibility is to protect the public, right?
6 So, we say to you, please stop protecting 7
the industry instead of protecting us.
8 MR. CAMERON: Thank you. Thank you very 9
much.
10 (Applause.)
11 MR. CAMERON: Please introduce yourself to 12 us, sir.
13 MR. STEINMETZ: Hi. My name is Jeff 14 Steinmetz. I'm a resident of San Clemente, California.
15 My question has to deal with the transportation of the 16 high burnup fuel.
17 You did mention a couple of casks that were 18 approved for transportation. But in your sentence and 19 in the sentences leading up to it, you didn't specify that 20 they were approved for the high burnup fuel of the nature 21 that is stored at San Onofre.
22 So, could you please be specific and can you 23 please provide the documentation? Because we've looked 24 for it and we can't find it.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 134 MR. CAMERON: Okay, thank you. Blair.
1 MR. SPITZBERG: Yeah, I thought I did provide 2
the documentation. It's Certificate of Compliance 3
9255, which is for the 24PT1 canister. That's the MP187 4
transport cask.
5 Did you want me to repeat that? I'm sorry.
6 (Speaking off mic.)
7 MR. SPITZBERG: And the second one was the 8
Certificate of Compliance 9302 for the MP197 transport 9
cask. These are available on our website. If you go to 10 our website, you can call these up.
11 MR. CAMERON: Okay. And let's talk further 12 if you need to after the meeting. We have one final 13 comment back there, Bob, and then we're going to go to 14 Larry Camper. Go ahead.
15 MR. HAGER: Yeah, but, Chip, before we go to 16 that, I've got several written questions that we haven't 17 had time to get to.
18 So, if you submitted a written question that 19 hasn't been answered, please stay afterwards and find an 20 NRC staffer who can answer it for you, because I don't 21 want anybody to get away from here and I'm sorry we 22 haven't got to you. So, stick around right after the 23 meeting and we'll get your question answered too.
24 MR. CAMERON: Okay. Pete.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 135 MR. DIETRICH: Yes, thank you. Pete 1
Dietrich with Southern California Edison. Larry, I do 2
have a question and I'm seeking to just ensure that I 3
understand, because I think it is an important 4
clarification.
5 The term "greenfield" has been used here 6
tonight repeatedly. It's not specifically in the 7
presentation materials, but I believe it was mentioned 8
by the staff. And it was also mentioned by Ms. Walker 9
from the California Public Utility Commission.
10 And I think it's important I think we're all 11 aligned that the decommissioning of San Onofre needs to 12 be conducted safely, cost effectively, efficiently and 13 we think that that involves doing it in a very more rapid 14 manner.
15
- However, we have to conduct that 16 decommissioning using the decommissioning trust funds 17 that have been set aside to accomplish it.
18 If we're aligned on that point, I think it's 19 important to focus on beginning with the end in mind.
20 What does the end of decommissioning look 21 like? What are the criteria for agreeing that the site 22 has been appropriately decommissioned?
23 I look to seek to understand your 24 perspective. What I heard here tonight is that from a 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 136 radiological decommissioning standpoint from a Nuclear 1
Regulatory Commission requirement, we are required to 2
return the land to the ability to be used in an 3
unrestricted manner, which has a specific definition 4
from a radiological standpoint, also per our License 5
Termination Plan which you gentlemen have talked about 6
which has to be submitted and approved, but there is not 7
the term "greenfield" included in the Nuclear Regulatory 8
regulations related to the land restoration requirements 9
for radiological decommissioning; is that correct?
10 MR. CAMPER: That is correct. In fact, Mike 11 in his comments made that point very clear. We do not 12 have a requirement in our regulations that it be 13 greenfield.
14 I do not know what the requirements are in 15 the state of California in that regard.
16 MR. DIETRICH: Right. I appreciate that.
17 And I did have a chance to - go ahead, Larry. Sorry.
18 MR. CAMPER: You also said "restricted." It 19 can be - or "unrestricted." It can be as I pointed out 20 in my comments and Bruce did in his too, our regulations 21 allow unrestricted or restricted.
22 MR. DIETRICH: Right.
23 MR. CAMPER: The 25 millirem dose criteria 24 in ALARA is the same, but restricted has some other 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 137 provisions requiring institutional controls and so 1
forth, but no nuclear power plant -
2 MR. DIETRICH: Right.
3 MR. CAMPER: - thus far has opted for the 4
restricted release. In fact, they've cleaned up their 5
site on the order of a few millirem.
6 MR. DIETRICH: That's right. And we intend 7
to proceed for unrestricted use.
8 MR. CAMPER: Right.
9 MR.
DIETRICH:
That's certainly our 10 intention.
11 MR. CAMPER: Right.
12 MR. DIETRICH: The other point that was made 13 by the CPUC representative was that we would need to 14 return the land to greenfield requirements to meet the 15 requirements of the Department of the Navy.
16 And I was able to catch Ms. Walker at the 17 break and just ask her if her understanding was the same 18 as mine. And that is absent the radiological 19 decommissioning restoration requirements, our 20 requirements are to restore the land to the requirements 21 of the landlord, which is the Department of the Navy.
22 MR. CAMPER: Uh-huh.
23 MR. DIETRICH: So, there is not specifically 24 in any of the restoration requirements for the San Onofre 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 138 property either from a radiological standpoint or from 1
a landlord standpoint that some greenfield standard be 2
met.
3 We need to work with the Department of the 4
Navy to ensure that we have restored the property to their 5
satisfaction and meet the radiological requirements of 6
the decommissioning.
7 That's southern California's understanding 8
and we look forward to getting on with it in a safe, 9
cost-effective and efficient manner.
10 MR. CAMERON: Okay, thank you. Thank you, 11 Pete. Okay. Very quickly.
12 MR. STONE: (Speaking off mic) the fact that 13 it's going to take the 60 years and I understand that 14 that's because of the decay rate so that it will be safe 15 to work with.
16 But for those 60 years especially the first 17 30 of those years, that's when the 8.4 million people are 18 at more risk, at the greatest risk. So, that has to be 19 understood as well. And that has to be stated publicly, 20 which is why I'm trying to tell you this right now.
21 You are aware that the greatest danger is 22 now because the decay rate happens over the 30 to 60 23 years, but we're in more danger now.
24 MR. CAMERON: Okay, thank you very much. 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 139 are over time and let's -
1 (Speaking off mic.)
2 MR. CAMERON: Okay, go ahead.
3 PARTICIPANT: I would like to know why -
4 MR. CAMERON: Give her the mic.
5 PARTICIPANT: I'd like to know why these 6
spent fuel pools are not contained in the same way as the 7
reactors and as the dry cask.
8 I mean, outside of the reactor, that is the 9
most dangerous state of the fuel and it has to stay there 10 for up to 15 years.
11 Why are the spent fuel pools not contained 12 in the same way as the reactors and the dry casks when 13 they're going to be exposed to tsunami, earthquake and 14 any other kind of hazard?
15 MR. CAMERON: Okay, thank you. Important to 16 clarify that. Who's going to take - who wants to take 17 that? Doug?
18 MR. BROADDUS: Thanks. The spent fuel pools 19 are not contained in the same manner as the reactor, 20 because the reactor is under extremely high temperatures 21 and pressures so that the containment is there to contain 22 that, those high temperatures and pressures.
23 The pool itself is at ambient temperature 24 and pressure. It's not under those same high 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 140 temperatures and pressures. And as such, the risk 1
associated with a release is not the same as in a reactor.
2 The pools, the primary purpose of the pool 3
is to cool and keep the spent fuel cool. It's to maintain 4
cooling circulating around the fuel itself.
5 The fuel is put inside the pool in a manner 6
that it will not reach criticality and go into the same 7
type of reaction as in the reactor core itself. So, 8
criticality is not the issue with the pool. The cooling 9
of the pool - or the fuel itself is the specific issue 10 there.
11 As long as that's maintained, that's the-12 (Speaking off mic.)
13 MR. BROADDUS: I don' know the thickness off 14 the top of my head, but there's thick stainless steel 15 lining that goes all the way around the pool.
16 The pools themselves are 40 or 50 feet deep 17 and there's about 20 feet of water above the actual top 18 of the spent fuel. So, there's another 20 feet of water 19 above that.
20 There's about five feet of concrete that's 21 on the outside of the lining itself. And so, that's 22 what's protecting the pool, the fuel itself, you know.
23 And so, from the sides and, you know, from 24 a leaking standpoint there's no - that's all there 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 141 prevent it from leaking and making sure that the water 1
stays inside the pool.
2 MR. CAMERON: I think maybe we can continue 3
this conversation offline, but thank you for that 4
question. And we're out of time. We're out of time.
5 And so, I'm going to ask Larry Camper to close the meeting 6
out for us and thank you all. Larry.
7 MR. CAMPER: Okay. Thank you, Chip. Let me 8
start by saying as I did at the outset of my comments, 9
thank you for coming and thank you for great questions, 10 good dialog. Very, very good thought went into your 11 questions and we appreciate that and we hope that we have 12 been able to answer them at least to a reasonable degree.
13 You know, burnup fuel, I heard burnup fuel 14 again and again. And I think what we need to do is - there 15 are two things.
16 I want to make sure that we go back and on 17 our website post the approvals that Blair was citing with 18 regards to the casks for the high burnup fuel.
19 And I also want to go back, Doug, and we'll 20 take a look at the actual authorizations that were used 21 to allow the burnup fuel to be at SONGS to begin with.
22 So, we'll work at putting a better explanation of that 23 particular activity on the website for your review.
24 I would also point out that the 60 years has 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 142 come up a lot. We tried to provide a basis for that, but 1
also understand as I said, it may have just gotten lost 2
in passing.
3 Although the utilities have this 60 years 4
to decommission a nuclear power plant, none of them have 5
taken the 60 years. None of them have taken the full time 6
and a number of things drive that decision, not the least 7
of which is citizen concerns about it. That is a factor 8
that the utility considers as it goes about planning its 9
timeline.
10 Having the expert staff on site to do 11 certain things is a factor. Cost of waste disposal is 12 another. In fact, I think one of Bruce's slides got at 13 this. There's a number of parameters that go into the 14 decision that the utility makes as to how long it's going 15 to take to decommission that reactor.
16 Our process will remain a very transparent 17 process. Once we have that PSDAR, the Post Shutdown 18 Decommissioning Activities Report, it will be posted in 19 FRN. There will be an opportunity for comment. We will 20 have a meeting out here at that time. And we'll do what 21 we can, we'll strive to maintain as much transparency as 22 possible in this process.
23 And, Gene, with regards to your particular 24 request, as I said, we will take that into consideration 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 143 near term and get back to the coalition on that.
1 So, what that, again I think that all of you 2
being here taking part, it's an important part of the 3
process and we appreciate you taking the time out of your 4
day to be with us and we certainly have enjoyed the 5
opportunity to be with you and will continue to 6
communicate along the way. Thank you.
7 (Whereupon, at 9:15 p.m. the meeting was 8
adjourned.)
9