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
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PUBLIC MEETING TO DISCUSS THE 5 DECOMMISSIONING PROCESS AT 6 SAN ONOFRE NUCLEAR GENERATING STATION 7 + + + + +
8 THURSDAY 9 SEPTEMBER 26, 2013 10 + + + + +
11 CARLSBAD, CALIFORNIA 12 + + + + +
13 The Public Meeting convened at the Omni La 14 Costa, 2100 Costa Del Mar Road, Carlsbad, California, at 15 6:00 p.m., Chip Cameron, Facilitator, presiding.
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2 1 NRC STAFF PRESENT:
2 CHIP CAMERON, Facilitator 3 LARRY CAMPER, Director, Division of Waste Management 4 and Environmental Protection, FSME 5 BRUCE WATSON, Chief, Reactor Decommissioning Branch, 6 FSME 7 BLAIR SPITZBERG, Chief, Repository and Spent Fuel 8 Safety Branch, RIV 9 MIKE DUSANIWSKYJ, Financial Analyst, Financial 10 Analysis and International Projects Branch, NRR 11 BOB EVANS, Senior Inspector, NRC 12 RYAN LANTZ, Chief, Region IV Reactor Projects Branch 13 D, NRC 14 PAUL MICHALAK, Chief, Environmental Impact Statement 15 Branch, Waste Confidence Directorate, NRC 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2 Welcome, Agenda and Ground Rules for Q&A Session 3 (Chip Cameron, Facilitator) .................. 4 4 NRC Decommissioning Overview (Larry Camper) ........ 9 5 Reactor Decommissioning Process 6 (Bruce Watson) .............................. 21 7 Decommissioning Inspection Program 8 (Blair Spitzberg) ........................... 32 9 Decommissioning Funding (Mike Dusaniwskyj) ........ 41 10 Spent Fuel Management (Blair Spitzberg) ........... 44 11 Questions and Comments from Members of the Public 12 (Chip Cameron) .............................. 50 13 Brief Recess ...................................... 75 14 Questions and Comments Continued .................. 77 15 Meeting Adjourned 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 (6:21 p.m.)
3 MR. CAMERON: My name is Chip Cameron and I'd 4 like to welcome you to the public meeting tonight. And 5 the topic for tonight is the Nuclear Regulatory 6 Commission.
7 I'm going to use the term and I think 8 everybody else will use "NRC," but we'll try not to use 9 acronyms tonight except for that one or others that are 10 easily understood, but it's the NRC's decommissioning 11 process.
12 And specifically, NRC's decommissioning 13 process relative to SONGS Unit 2 and 3, San Onofre Nuclear 14 Generating Station.
15 And it's my pleasure to serve as your 16 facilitator tonight. And I'm going to be assisted by Bob 17 Hager who is in the back of the room.
18 And Bob is a certified facilitator in the 19 NRC's facilitator program. And what Bob and I are going 20 to do is to try to help all of you to have a productive 21 meeting tonight.
22 I just wanted to cover a few items on the 23 process for the meeting so that you know what to expect 24 tonight. And I'd like to talk about the objectives for 25 the meeting, the format for the meeting, go over some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 simple ground rules with you for the conduct of the 2 meeting and then introduce the NRC speakers who are up 3 here in front of you and what their topics are going to 4 be.
5 In terms of objectives for the meeting, the 6 NRC's primary objective tonight is to give you clear 7 information on NRC's decommissioning process.
8 And these are the rules that the NRC and the 9 licensee, in this case Southern California Edison, these 10 are the rules that the NRC and the licensee has to follow 11 over the course of the decommissioning of the reactors.
12 We'll also try to provide you with 13 information on specific aspects of the SONGS facility's 14 decommissioning and we're going to provide that 15 information to you in two ways.
16 One is we have a number of presentations 17 from the NRC staff, and then we're going to answer any 18 questions that you might have about the decommissioning 19 process after the NRC staff is done with their 20 presentation. And that's the format, presentations, 21 and then question/answer with all of you.
22 Now, some simple ground rules for the 23 meeting tonight. I would just ask you to hold all of your 24 questions until we get done with the NRC presentations 25 so that you'll have a complete picture before we go on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 to you for questions.
2 And I would just thank you for your patience 3 in advance. It's not an overly long set of 4 presentations, but it will take some time because the NRC 5 wants to give you as much information as possible.
6 When we go on to you for questions, just 7 signal me and I will bring you this cordless microphone 8 or Bob Hager back there will bring you the cordless 9 microphone. And just please introduce yourself to us 10 and ask your question, or make a comment.
11 I would just ask you to be brief so that we 12 can make sure that we get to everybody who wants to talk 13 tonight.
14 We don't have as big a turnout as we were 15 planning for. So, that may give us more time tonight, 16 but I would ask you to be brief. And I would also ask 17 you to follow the rule of only one person at a time 18 speaking. We want to give our full attention to whomever 19 has the microphone at the moment.
20 As I mentioned, the objective of the meeting 21 is to give you information on the NRC decommissioning 22 process, but we realize that there is broader concerns 23 in relationship to SONGS than just decommissioning and 24 we want to try to answer questions that you might have 25 on any of those broader concerns.
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7 1 They may not be in-depth answers, but we do 2 want to try to address those questions, but the primary 3 focus is on the decommissioning process.
4 And I mentioned that the way we're going to 5 get the information to you is through the presentations 6 and through answering your questions. That doesn't mean 7 that if you have a concern or a comment that you want to 8 give the NRC that you can't make a comment. Okay?
9 It doesn't have to be a question, but I would 10 just say that tonight is not the night for long speeches 11 on anything. And let me introduce the NRC staff that's 12 going to be speaking to you tonight.
13 First we're going to go to Larry Camper who 14 is right here. And he's the director of the Division of 15 Waste Management and Environmental Protection in the NRC 16 Office of Federal, State and Environmental Management.
17 And that's a headquarters office in Rockville, Maryland.
18 And Larry is going to give you a broad overview of the 19 reactor decommissioning process.
20 After that, we're going to get into a little 21 bit more depth and we're going to go to Bruce Watson who 22 is right here.
23 And Bruce is the chief of the Reactor 24 Decommissioning Branch in Larry Camper's division also 25 NRC headquarters in Rockville, Maryland.
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8 1 Next we're going to go to Blair Spitzberg.
2 And Blair is the chief of the Fuel Safety and 3 Decommissioning Branch in NRC's Region IV. And that's 4 one of four regional offices. And that one is in 5 Arlington, Texas. And Blair is going to talk to you 6 about the NRC inspection program for decommissioning 7 reactors.
8 And we know there's going to be a lot of 9 interest in how the NRC inspects what's going on during 10 the decommissioning process.
11 After Blair is finished, we're going to go 12 to Mike Dusaniwskyj who is up here. And Mike is an 13 economist. And he's in the Decommissioning - well, he's 14 in the Financial Analysis and International Projects 15 Branch in the NRC's Office of Nuclear Reactor Regulation, 16 also NRC headquarters Rockville, Maryland. And he's 17 going to talk to you about decommissioning funding, 18 because we know that that's also of interest of you.
19 Then we're going to go back to Blair 20 Spitzberg who is going to talk to the NRC regulation of 21 spent fuel storage at the San Onofre facility.
22 And I think we're ready to go to Larry.
23 We'll go through all the presentations, and then we'll 24 be back to you for question and answer.
25 Larry.
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9 1 MR. CAMPER: Thank you, Chip. Good evening, 2 everyone. Thanks for coming out tonight and 3 participating in this important meeting and taking time 4 out of your busy schedule. And I must tell you it really 5 is a pleasure to be here with you. This is a beautiful 6 place that you live. So, really, it's a nice spot. So, 7 it's a pleasure to be here.
8 I am Larry Camper, the director of the 9 Division of Waste Management and Environmental 10 Protection.
11 As Chip said, I do have responsibility and 12 my staff has responsibility for the decommissioning for 13 the Nuclear Regulatory Commission, including nuclear 14 power plants. And so, we do hope to share some 15 information with you this evening about that process and 16 answer your questions.
17 As Chip said, though, we also want to make 18 ourselves available to answer other questions you might 19 have. There's been a lot of interest around this 20 particular site and we understand there may be some other 21 things you'd like to hear about and we'll try to answer 22 those issues at least briefly.
23 I'm joined by a lot of NRC staff. And I'd 24 really like the NRC staff that are with me this evening 25 to stand up.
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10 1 I do this because we wanted to bring 2 expertise to bear. We felt this meeting was important 3 enough to have the right people here. We have people 4 from headquarters, from the regions, Region IV, and we 5 thank them for being here.
6 And over the course of the evening, some of 7 them will be participating. Thanks, guys. We can sit 8 down and take it easy, but over the course of the evening 9 some of them will be joining in with answers to questions.
10 We will take a break. You can catch one of 11 them if you have a question that you don't want to go 12 through the trouble of having the microphone in your 13 face, but you can say, hey, I'd really like to know 14 something more about that. So, they're all here and 15 they're all willing to talk to you.
16 We also have some folks from California.
17 We actually have people here from the California Public 18 Utility Commission, the California Energy Commission, 19 the California Coastal Commission, the California 20 Department of Public Health, California Emergency 21 Services and also representatives from the United States 22 Navy because of Camp Pendleton.
23 And so, some of them are here this evening 24 because there may be questions that you have that are not 25 within the NRC jurisdiction. And so, we want to have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 right type of expertise here to turn to for those kinds 2 of questions as well.
3 So, we thank all of those folks for being 4 here from the State of California and their various 5 organizations and we'll turn to them as need be, or they 6 may even hear a question and they know it's best for them 7 to be involved.
8 Okay. What I want to start with is our 9 mission. The slide you see in front of you depicts the 10 NRC's mission which is to regulate the Nation's civilian 11 use of radioactive materials, to protect public health 12 and safety, promote common defense and security and 13 protect the environment. That is our mission.
14 When a facility such as nuclear power plants 15 and other nuclear facilities are operating, it remains 16 our mission during the decommissioning of nuclear 17 facilities.
18 First and foremost our mission is safety.
19 We are an independent Federal regulator and our business 20 is all about protecting public health and safety. That 21 will remain throughout the process of decommissioning 22 until it is complete.
23 What you see in front of you is the 24 regulation that cites our decommissioning criteria. It 25 doesn't matter about that. What is important is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 explained to you when we use the term "decommissioning,"
2 what does it mean?
3 It means to remove a facility, in this case 4 a nuclear power plant, safely from service and reduce 5 radioactivity to a level that allows either release of 6 that property for unrestricted use and termination of the 7 license or reduction of the license in the case of a 8 nuclear power plant to spent nuclear fuel storage, or 9 release of the property under restricted conditions and 10 termination of the license.
11 I will point out that while our regulations 12 for decommissioning allow restricted release, no nuclear 13 power plant that has been decommissioned in the United 14 States has pursued restricted release. All have been 15 successfully completed using unrestricted release.
16 The slide that I have here for you is 17 designed to share with you the kind of scientific and 18 technical expertise that will be brought to bear by the 19 Nuclear Regulatory Commission as we address the 20 decommissioning of SONGS 2 and 3.
21 You'll see that there is a lot of different 22 expertise such as mechanical engineers and chemical 23 engineers and geologists, mathematicians, biologists, 24 environmental engineers and so forth and so on. And the 25 point is all of this expertise is brought to bear in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 decommissioning of our nuclear facilities including what 2 takes place on the site that we're here to discuss 3 tonight.
4 I would also point out that the 5 decommissioning staff that Bruce directs as the branch 6 chief has over 300 years of cumulative professional 7 expertise in dealing with the decommissioning of nuclear 8 power plants. So, we hope that that will inspire some 9 confidence in our decommissioning process and you can 10 have some realization of the type of expertise and the 11 experience that will be brought to bear and the oversight 12 of the decommissioning of the SONGS facility.
13 This slide depicts the successful 14 decommissioning completions that have taken place over 15 the last 15 years. A lot of information to try to absorb, 16 but I'll summarize it for you.
17 There have been 50 materials licensee 18 sites. Materials licensee sites are sites that, for 19 example, processed or produced uranium or thorium for 20 various industrial uses.
21 We have decommissioned 11 nuclear power 22 plants, 13 research and test reactors and a large number 23 of uranium recovery facilities. On the order of 80 sites 24 have been decommissioned successfully over the past 15 25 years under Nuclear Regulatory Commission oversight.
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14 1 What we have here is a list of the nuclear 2 power plants that have been decommissioned. I mentioned 3 a moment ago that there were 11 of them.
4 You'll see that the ones that are depicted 5 in yellow have been depicted under what's called the 6 License Termination Rule which went into effect in 1997.
7 The ones in white below that were 8 decommissioned by an earlier standard before our 9 existing standard in the License Termination Rule. That 10 rule is the standard by which the decommissioning will 11 take place at the SONGS facility. So, 11 nuclear power 12 plants in the United States decommissioned thus far.
13 What we have here is key decommissioning 14 milestones. Now, Bruce in his presentation will go into 15 the process in considerable detail, but I thought it was 16 worthwhile to at least share with you some of the major 17 milestones you can begin to think about and be aware of 18 as Bruce goes through this presentation.
19 First you'll see that there are two 20 certifications that have to be filed by the utility. A 21 certification whereby there has been a permanent 22 cessation of operations, and a certification where the 23 nuclear fuel has been permanently removed from the 24 reactor. Both of those have been filed by the utility 25 operating the SONGS facility.
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15 1 Next is a Post Shutdown Decommissioning 2 Activities Report. A PSDAR you will hear us say and 3 refer to.
4 Then comes decommissioning and 5 environmental remediation. I have that activity 6 highlighted in yellow, as well as a little bit further 7 down, the final status survey, because that represents 8 activity that takes place on the site. That's not a 9 submission to the Nuclear Regulatory Commission.
10 That's actual remediation and decommissioning of the 11 facility.
12 There is a requirement that a license 13 termination plan be submitted along the way. Of course 14 the final status survey whereby the operator of the 15 utility is ensuring through surveys that the dose 16 standard that I'll mention to you in a moment is, in fact, 17 satisfied.
18 The Nuclear Regulatory Commission also does 19 a confirmatory survey of the results within the final 20 status survey.
21 And last, but not least, is either a 22 termination of the Part 50 license - Part 50 is that part 23 of our regulations under which nuclear power plants are 24 regulates - or as is more common today, the license is 25 shrunk in size to the footprint of the remaining NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 independent spent fuel storage installation.
2 In terms of release criteria, I mentioned 3 that there are two possible pathways for release of any 4 facility that undergoes decommissioning, including 5 nuclear power plants. There's unrestricted release, 6 and restricted release.
7 As I mentioned, no nuclear power plant thus 8 far has gone for restricted release for a myriad of 9 reasons. All have pursued unrestricted release 10 although they certainly could pursue restricted release.
11 There's a lot of information on this slide, 12 but I want to draw your attention to just two points.
13 The dose criteria that we use in this 14 regulation is referred to as total effective dose 15 equivalent of equal to or less than 25 millirem and as 16 low as reasonably achievable.
17 In other words, the site must be cleaned up 18 to satisfy that dose standard and the licensee must 19 demonstrate that the level to which it has cleaned up the 20 site is, in fact, as low as reasonably achievable based 21 upon a rather sophisticated cost benefit analysis.
22 Now, when you see and you hear 25 millirem, 23 what does that mean? Can I understand what he's saying 24 when he says 25 millirem?
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17 1 you get in an airplane in Los Angeles and fly across the 2 country to New York, you receive about 3 millirem of 3 exposure from cosmic radiation.
4 In the United States, the natural 5 background radiation including exposure from medical 6 radiation is on the order of 300 to 600 millirem per year 7 depending upon where you are in the United States.
8 There are places in the world with a natural 9 background radiation, Saskatchewan, Canada comes to 10 mind, for example, where the natural background 11 radiation is 4,000 millirem per year.
12 So, hopefully now when you see 25 millirem 13 and you hear about it in the months to come as we talk 14 about the decommissioning standard, at least you'll have 15 some perspective of what that number means.
16 Tonight for our public meeting I'll be 17 giving you the decommissioning overview. Of course 18 Bruce will talk about the reactor decommissioning 19 process. Blair Spitzberg will talk about the inspection 20 plan. Michael Dusaniwskyj will talk about the 21 decommissioning funding. Blair will then come back and 22 talk about spent fuel management and then of course we'll 23 go to questions and answers and dialog.
24 I would reiterate that these are the primary 25 topics and the purpose for our meeting tonight, but we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 also recognize as Chip said and I said earlier and would 2 repeat now, there are other things you might want to talk 3 about.
4 And we'll do the best we can to at least give 5 you brief answers and help us to the extent that we can 6 stay on the purpose of the program, but we're here to 7 answer your questions about other issues as well.
8 In terms of the decommissioning inspection 9 program, you'll hear a lot about this. We do remain very 10 engaged during the decommissioning process and we'll 11 give you some clarification as to the level of resources 12 that will be involved during that process.
13 We also know that another topic that's on 14 people's minds these days is the Waste Confidence 15 Decision Rulemaking and Environmental Impact Statement 16 that the Nuclear Regulatory Commission is currently 17 working on.
18 We do have a representative here from the 19 Waste Confidence Directorate this evening that can 20 answer some questions if that comes up. So, I think we 21 can give you some insights into that as well.
22 Public involvement. Clearly you're very 23 concerned about public involvement and, again, I want to 24 thank you for being here and taking part in what we 25 consider to be a very important part of our regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 program.
2 The meeting this evening that we're 3 conducting is not required by our regulations, but we 4 felt it was important to be here.
5 Our chairman is very interested in 6 conveying information, our management is very interested 7 in conveying information, our entire organization wants 8 to convey as much information as we can to the community 9 here, because there's been a lot of very challenging 10 issues and we know that you've had a number of concerns 11 and a lot of interest. So, we decided to hold this 12 process meeting for that purpose.
13 There is a meeting that will take place once 14 the Post Shutdown Decommissioning Activity Report is 15 submitted by the utility. That's required by our 16 regulations.
17 There is a public meeting that will take 18 place once the License Termination Plan is submitted by 19 the utility. That's again required by our regulations.
20 And because the decommissioning program and 21 the approval of the License Termination Plan involves an 22 amendment to the existing license for the utility, there 23 is the opportunity for a hearing within our adjudicatory 24 process as well. So, there are a number of opportunities 25 for public awareness and public involvement along the way NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 with the decommissioning process.
2 So, I'll stop there and later on will 3 entertain questions, of course. And Bruce Watson, our 4 branch chief for the Decommissioning Branch for Nuclear 5 Power Plants will provide more detail into the areas that 6 I've just touched upon lightly. Thank you very much.
7 MR. WATSON: Well, good evening and thank you 8 for being here. I am Bruce Watson. I'm chief of the 9 Reactor Decommissioning Branch. I'd like to discuss 10 some of our current activities and their requirements for 11 decommissioning nuclear power reactors.
12 I want you to keep in mind that we regulate 13 - the NRC regulates the radiological decommissioning of 14 these sites.
15 There may be other requirements in the 16 decommissioning requirements that were beyond what the 17 NRC requires and those will be addressed by other 18 regulators.
19 In 2013, four power reactors permanently 20 ceased operations and are transitioning from operating 21 status, which is managed by our Office of Nuclear Reactor 22 Regulation and will be transferring to my office and 23 FSME.
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21 1 rate.
2 In 1997, the NRC implemented 10 CFR 20 3 Subpart E, which is commonly known as the License 4 Termination Rule.
5 It establishes the release criteria for 6 unrestricted and restricted release that Larry Camper 7 just covered.
8 These rules that I'm going over took into 9 account the decommissioning experience we gained from 10 our decommissioning at Saxton and Fort St. Vrain in 11 Colorado.
12 To date, all US reactors had been 13 unrestricted released for use, which means they can be 14 used for any purpose. And this regulation is a 15 risk-informed dose base regulation.
16 10 CFR 50, specifically 10 CFR 50.82 is the 17 License Termination Requirements for power reactors.
18 I'm going to discuss this rule in a regulation in great 19 detail this evening.
20 (Pause in the proceedings.)
21 MR. WATSON: Part 72 deals with the 22 Independent Spent Fuel Storage Installation License, 23 licensing of the ISFSI. It's an important regulation, 24 because it's where the spent fuel goes during the 25 decommissioning process.
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22 1 All right. The NRC offers three 2 decommissioning options in our guidance, but only two of 3 those have been implemented to date.
4 DECON, or prompt remediation is what it's 5 called in international terms, decommissioning begins 6 shortly after the licensee has prepared the plant for 7 decommissioning.
8 Like I said, we currently have four reactors 9 in DECON; the plant at Humboldt Bay in California, Zion 10 1 and 2 in Illinois and La Crosse in Wisconsin.
11 Regardless of the strategy chosen by the 12 licensee, the preparation for decommissioning typically 13 takes one to two years in order to get the plant prepared 14 for decommissioning.
15 During this time period, the plant will be 16 set up so that the systems are drained, electrical 17 connections are de-energized and that it would 18 facilitate decommissioning and this does take some time.
19 The plant also may include some 20 modifications that will facilitate future 21 decommissioning of the plant.
22 During this time frame, the NRC will 23 generally keep one of the resident inspectors at the site 24 for about a period of a year. And that's to ensure that 25 all the operational issues that were under review during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 the process of shutting down are maintained compliant and 2 to make sure that any plant modifications are maintained 3 safely.
4 In the SAFSTOR, or deferred dismantling 5 mode, the plant is placed in safe storage, as we would 6 call it, cold and dark, until the licensee decides to 7 dismantle the plant and the decommissioning of the plant 8 can begin.
9 The licensee may perform some 10 decommissioning activities during this time frame and 11 the NRC will inspect the plant periodically, at least 12 annually, or if the plant is doing some significant 13 decommissioning activities, we will inspect the plant 14 more frequently.
15 Although entombment is an option in our 16 guidance, no power reactors have opted for this option.
17 No US NRC licensed reactors had been entombed, nor have 18 any licensees requested entombment. So, it's really not 19 an option at this point.
20 Our regulations in 10 CFR 50.82 for power 21 reactors are performance-based, they are flexible, and 22 they require that the licensee complete the 23 decommissioning in 60 years.
24 I know you may ask why 60 years. Again, the 25 basis for that 60-year requirement allows the radiation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 doses to significantly decrease to about one percent of 2 those which they were when the plant originally shut 3 down.
4 This represents significant radiation 5 exposure savings to the workers who will conduct the 6 decommissioning.
7 It will also reduce the biome of radioactive 8 waste to about ten percent of what it was when the plant 9 was shut down. This is due to radioactive decay.
10 Some of the principal radionuclides in that 11 such as Cobalt-60 will have gone through numerous half 12 lives, approximately ten, where the radiation levels are 13 reduced and the amount of radioactivity is significantly 14 minimized.
15 During this period the Decommissioning Fund 16 can also increase since it's invested and can increase 17 by compound interest.
18 Coincidentally, this 60-year also 19 corresponds to the 20-year license extension for 20 multi-unit facilities. So, the operator can focus on 21 safe operation of the remaining units.
22 This is, in particular, specific to San 23 Onofre, because San Onofre 1 was in SAFSTOR for quite a 24 while. Then, the utility elected to decommission it.
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25 1 onsite and there was a significant physical 2 differentiation between the operating units in it that 3 allowed that to be done very safely.
4 The NRC policy is that the decommissioning 5 can be formed Day 1 after the plant shuts down and is ready 6 for decommissioning, or at the 50-year point. Because 7 the 60-year point - 50-year point takes into 8 consideration it will take seven to ten years to complete 9 the decommissioning.
10 Again, some of the decision factors 11 licensees use in determining the decommissioning 12 strategy whether it's a multi-unit site as I just 13 discussed, the ability to have the financial fund 14 available - this is important for plants that are 15 prematurely shut down - whether there is access to the 16 radioactive waste disposal capacity, the actual future 17 use of the site - some of these sites are very valuable 18 to the utility in that they do put new generating capacity 19 on the site and this has happened at many of the 20 single-unit facilities.
21 Decisions also that affect the 22 decommissioning strategy are input from the 23 stakeholders. There is a new business model out there.
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26 1 does the decommissioning and then returns the fuel and 2 the site back to the utility. This is the current model 3 at Zion.
4 There may be other special circumstances 5 which will affect the licensee's decision on the 6 strategy. Such a special circumstance would be the - for 7 SONGS, would be the US Navy's lease with the utility.
8 There are a number of certifications that 9 come about from the - that are required from - in the 10 initial stages of the decommissioning.
11 First, the licensee will certify that the 12 NRC that within 30 days they will be permanently shutting 13 down. The second certification is that the fuel has been 14 permanently removed from the reactor vessel.
15 At this point, the - after this is 16 completed, the licensee is no longer permitted to operate 17 the reactor or put fuel back in the vessel.
18 Within two years the licensee is required 19 to submit the Post Shutdown Decommissioning Activities 20 Report. As we call it, it's the PSDAR. And that is 21 required to be, like I said, required to be submitted to 22 us two years after cessation of operations.
23 What's in the PSDAR? Well, it basically is 24 comprised of three things. It's a description and 25 schedule for the planned decommissioning activities.
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27 1 And it describes the strategy that the utility will take 2 for decommissioning.
3 It includes an estimate of the expected 4 decommissioning costs and a discussion on the means for 5 concluding that the environmental impacts associated 6 with the decommissioning have not changed.
7 The NRC will notice the PSDAR in the Federal 8 Register. We will hold a public meeting to discuss the 9 PSDAR and solicit comments from the public.
10 I want to point out that we do not approve 11 the PSDAR. It is merely a letter to us with specific 12 requirements in the regulations that they are to report 13 to us on what their plans are for the site. The licensee 14 may begin decommissioning 90 days after the NRC receives 15 the PSDAR.
16 The next step in the process is that the 17 power reactor - the licensee will perform the 18 decommissioning.
19 The NRC will continue to conduct 20 inspections, as I mentioned. The licensee will submit 21 to us within two years of when they plan to terminate -
22 request termination of the license, the License 23 Termination Plan. And we'll talk about that in much 24 later detail.
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28 1 conduct decommissioning activities within the current 2 license that it - within the license that is issued once 3 the plant is fully defueled. And those are called the 4 defueled tech specs.
5 We will hold a public meeting to discuss the 6 LTP and solicit your comments. And we will also submit 7 - publish that in the Federal Register.
8 What's in the LTP? Well, the LTP is a very 9 large document. It contains a lot of technical detail 10 on how the plant will be decommissioned, finish the 11 decommissioning. It will contain a lot of radiological 12 data, including some dose modeling, and the licensee's 13 plans to complete the site remediation.
14 Probably one of the most important things 15 in the LTP is the description of how the - the detailed 16 plans on how the licensee will conduct the final status 17 surveys or the final surveys of the site to demonstrate 18 that it meets the license criteria.
19 The License Termination Plan contains a 20 description of the end use of the site if the site is going 21 to be restricted use.
22 As I said before, none of the power reactors 23 have requested a restricted use as a final state. All 24 of them have been decommissioned to unrestricted release 25 criteria.
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29 1 It also will contain an updated 2 site-specific estimate of the remaining decommissioning 3 costs and of course it will supplement the - any 4 supplement to the Environmental Report that was 5 previously issued.
6 the NRC will conduct a full review of the 7 LTP. Initially we will conduct an acceptance review 8 basically to make sure that the major components of the 9 LTP are in the LTP. And then we will perform a detailed 10 technical review. That detailed technical review will 11 take approximately a year to do.
12 If there is missing information or 13 clarifications required, we will issue additional 14 information - request for additional information. And 15 we will hold public meetings - a public meeting. And 16 also with this since it is a major licensing action, the 17 public also has the opportunity for a hearing.
18 Eventually if the LTP meets all our 19 requirements, the NRC will approve the LTP by amending 20 the license. So, the LTP basically becomes part of the 21 license.
22 The licensee will perform the remaining 23 decommissioning activities and we will perform 24 inspections, including independent in-process and 25 confirmatory surveys to verify the licensee's results.
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30 1 We also employ a contractor, Oak 2 Ridge-Associated Universities, as an independent group 3 to do surveys to verify compliance with the radiological 4 criteria.
5 At the end of the decommissioning, the 6 licensee will submit to us the final Status Survey 7 Reports. They describe the radiological condition in 8 which the site was left.
9 We will continue to perform confirmatory 10 surveys. And if they meet our criteria, we will approve 11 the Final Status Survey Report. We will terminate the 12 license by letter and notice the action in the Federal 13 Register.
14 Keep in mind that the license termination 15 will only occur when the licensee demonstrates to us that 16 they have met the radiological criteria required in the 17 License Termination Plan which is consistent with the 18 regulations.
19 I would just like to briefly discuss the 20 status of San Onofre 2 and 3. Here are the key 21 decommissioning milestones.
22 Obviously the first two were met. And as 23 I mentioned, the deadline for the SONGS PSDAR is actually 24 two years after the shutdown date, which is June 7th, 25 2015. We understand that the licensee has plans to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 hopefully do that in 2014.
2 We will notice the PSDAR when it is sent to 3 us to - in the Federal Register and we will hold another 4 public meeting. And of course when the LTP is submitted, 5 we also do the same.
6 One of the key features that happens within 7 the NRC is the transfer of the inspection program.
8 During operations the plant is under the 9 Reactor Oversight Program. It will be transferred to 10 what we call Inspection Manual 2561, which is the Reactor 11 Decommissioning Inspection Program.
12 And Blair Spitzberg will give you some 13 information on that. Thank you.
14 MR. SPITZBERG: Good evening. My name is 15 Blair Spitzberg and I'm the chief of the Fuel Safety and 16 Decommissioning Branch in the Region IV office in 17 Arlington, Texas.
18 Some of you may be aware of the fact that 19 the NRC has four regional offices. And the purpose of 20 these offices were very interesting and it's a very good 21 decision that was made years ago by the Commission to 22 establish regional offices for the basic purpose of 23 conducting the inspections programs associated with our 24 licensees.
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32 1 reviews and to license the licensees to undertake the 2 activities that they undertake.
3 In the regional offices where we do 4 inspection, we believe in the axiom of a former president 5 from California, trust, but verify. And that's what we 6 do as inspectors.
7 My inspection branch is a small group of 8 health physicists and engineers and we do inspections of 9 both the decommissioning activities at reactors and 10 non-reactor sites. We also inspect spent fuel storage 11 installations. And we inspect, as well, some fuel cycle 12 facilities.
13 Now, let me show a picture of some sites here 14 that I think would be of interest. On the left you see 15 four sites. And there's a number that - Larry went 16 through a number of them showing reactor sites throughout 17 the country.
18 And on the right-hand side is an aerial 19 photograph showing what they look like at the end of the 20 decommissioning process.
21 As you can see, Connecticut Yankee 22 basically removed the entire site and went to a 23 greenfield, as did Maine Yankee.
24 We show the Trojan, Oregon site there which 25 was decommissioned in Region IV a number of years ago.
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33 1 And as you can see on the photograph there 2 at San Onofre Unit 1, you may be aware of the fact that 3 there was another operating reactor at San Onofre years 4 ago and they were successfully decommissioned with the 5 exception of the reactor vessel which remains onsite.
6 So, asking the question how NRC ensures 7 safety, as we mentioned and Bruce went through in detail, 8 we establish and ensure compliance with the requirements 9 contained in the regulations, in a number of different 10 safety standards that pertain, decommissioning and 11 storage of spent fuel, and then we also write license 12 conditions and technical specifications that the 13 licensee has to comply with.
14 And all of this is done in the licensing 15 process performed in Washington where they undertake 16 these safety evaluations and all those are subject to 17 public input.
18 And then finally as the inspection 19 enforcement, and that's what we do in the regional 20 offices, we have a - our regional office staff numbers 21 in excess of 150 safety professionals that do various 22 inspections not only of the operating reactors, but of 23 the decommissioned reactors and the nuclear materials 24 licensees that are located basically west of the 25 Mississippi River. That's a large geographic region.
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34 1 Some of the inspection activities that will 2 be undertaken at San Onofre now that it is permanently 3 defueled and in decommissioning status, is that we will 4 continue to perform inspections of spent fuel pool 5 safety. Because as you know, there's a number of spent 6 fuel assemblies that are still in storage in pools at Unit 7 2 and 3. We'll continue to inspect those.
8 We'll perform decommissioning inspections 9 out here and most of those will be intense during the 10 periods of dismantlement, which probably will not occur 11 for some period of time. But once they start actually 12 dismantling and cutting up systems and deconning the 13 facility, we'll be out here on a regular basis, but will 14 continue to do programmatic inspections up until that 15 time.
16 It's important to note that during the 17 remediation activities the NRC conducts independent 18 radiological measurements. And the purpose of this is 19 to confirm the licensee's results.
20 We inspect the radiological measurements 21 that the licensee performs. We observe them doing the 22 measurements, and then we'll do our own measurements.
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35 1 licensee's results. And this has been very successful 2 in our inspection program.
3 As I mentioned, we also inspect the safety 4 of the independent spent fuel storage installation, and 5 I'll discuss that in my next presentation in a few 6 minutes. And then we also continue to inspect the 7 physical security program at the site.
8 So, what are the objectives of the 9 inspection program? Basically it's very 10 straightforward.
11 It's to verify safe conduct of the licensee 12 activities. And we've looked at the adequacy the 13 licensee controls, we ensure that safety problems and 14 violations are properly identified and that they're 15 corrected and that effective actions are taken to prevent 16 recurrence.
17 And then we also examined trends in licensee 18 safety performance. And this is something that's very 19 important particularly at - well, at all plants, but we 20 find it important to decommissioning plants as well, 21 because decommissioning plants the licensees quite often 22 will bring in contractors that have special expertise in 23 decommissioning activities.
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36 1 we find that we have to look at trends in their 2 performance as well.
3 Next are some of the inspection procedures.
4 These are the core inspection procedures that we will 5 implement during and throughout the inspection program 6 for the decommissioning.
7 They cover everything from the 8 organizational, management and cost controls, the safety 9 reviews, any design changes and modifications to the 10 plant that will be made, the licensee's QA program that 11 includes self-assessments, audits and corrective 12 actions, the safety of the spent fuel, the radiation -
13 occupational radiation exposures to the workers, 14 inspection of final surveys, the radioactive waste 15 treatment, effluent and environmental monitoring 16 program, the transportation of radioactive materials off 17 site, a lot of waste material will be packaged and 18 transported to waste disposal sites out of state mostly, 19 the maintenance and surveillance program, physical 20 security and the contingency response program.
21 So, let me talk just a minute about how we 22 plan our inspections and how we communicate our 23 inspection results.
24 Most of our inspections, we try and lay out 25 an inspection plan for a year in advance. We're not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 always going to hold to that inspection schedule, because 2 conditions will change at the plant and activities will 3 be moved up or new activities will be introduced and we 4 have an inspection plan that is something that we can 5 change on short notice to adjust to any activities at the 6 site.
7 We coordinate our inspection plan with a 8 Program Office in Washington and we get their buy-in on 9 what we're planning to do.
10 we work for the Program Office in 11 Washington. So, they're the ones that set our 12 objectives and give us funding to do our job.
13 As I mentioned, we adjust the schedule as 14 needed throughout the year. Then we execute the 15 inspections.
16 The inspections can be announced or 17 unannounced. Most of our inspections are announced, but 18 not always.
19 There may be occasions where we want to do 20 an unannounced inspection in which case we can do - we 21 do backshift inspections and weekend inspections 22 throughout the year.
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38 1 following every inspection where we communicate the 2 results of our inspections to the licensee so that they 3 can examine the results and take corrective action if 4 needed.
5 We issue inspection reports. We have two 6 different goals for the timeliness of our inspection 7 reports.
8 For routine inspections involving one or 9 two inspectors, our goals are 30 days for the inspection 10 reports from the date following the exit. For team 11 inspections, it's a 45-day goal for team inspection 12 reports.
13 And then as I mentioned, we do also have an 14 enforcement policy. If we identify violations, we 15 examine the significance of the violation and we get our 16 enforcement staff involved.
17 We have an enforcement staff in the regional 18 office and in our headquarters office and will panel the 19 findings and make a determination of what enforcement to 20 take.
21 We have a number of different enforcement 22 tools that we can take. We're looking ultimately to get 23 the attention of the licensee to correct any violations.
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39 1 civil penalties or orders that we can invoke in order to 2 bring about compliance.
3 Some of the other post-inspection 4 activities. When the inspectors return to the office 5 and oftentimes before they return to the office, they'll 6 call me up and they'll brief me on the inspection results.
7 Then, we make a determination collectively, 8 the inspector and the other staff and the management in 9 the regional office as to the significance of the 10 findings.
11 And then we'll issue the inspection report 12 and I've listed here the website address where you can 13 get copies of our inspection reports.
14 Most of our inspection reports are publicly 15 available. For obvious reasons, some minor - few 16 inspection reports are not publicly available for 17 security reasons, but most of the decommissioning 18 inspection reports will be publicly available and you can 19 access them on our website. And then finally, we'll 20 track and follow the inspection findings to closure.
21 MR. DUSANIWSKYJ: Good evening. My name is 22 Michael Dusaniwskyj. I am an economist in the Office of 23 Nuclear Reactor Regulation in the Division of Inspection 24 and Regional Support in the Financial Analysis and 25 International Projects Branch.
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40 1 There are regulations on financial 2 qualifications, and more importantly on decommissioning 3 funding assurance.
4 These standards are based on regulations 5 that have been involved since the enactment of the Atomic 6 Energy Act of 1954.
7 And ultimately what it is ultimately trying 8 to do is to determine whether it can be built, operated 9 and decommissioned safely. To do that, it takes money.
10 A licensee begins funding for 11 decommissioning when a license is issued. There is a 12 difference between decommissioning funding and 13 decommissioning funding assurance.
14 The regulations at the NRC stipulate that 15 a licensee shall have the necessary funds to decommission 16 to NRC standards by the time the decommissioning 17 activities begin and certainly before it is concluded.
18 Requirements while operating, we are always 19 forecasting the collection process to determine whether 20 or not there is enough funding in the Decommissioning 21 Trust to complete decommissioning to NRC standards.
22 Our basic tool for that is that every two 23 years in odd number of years by March 31st of an 24 odd-numbered year, a licensee is to report to us seven 25 significant pieces of information. Two of them being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 what is the minimum amount that is necessary to put aside.
2 And more importantly, how much money has been collected 3 as of December 31st of the year prior to the March 31st 4 submittal.
5 We also do spot checks. We check to make 6 sure that what they have in a decommissioning trust fund 7 is, in fact, in the decommissioning trust fund.
8 Decommissioning funds used, are used 9 directly for the facility to decontaminate and 10 decommission to NRC standards.
11 If it can be proven to us by the licensee, 12 it can also be used indirectly for use on spent fuel 13 management. Any residual funds can be used for site 14 restoration and greenfielding. While they are in 15 decommissioning, we are forecasting the withdrawal 16 process.
17 Actual decommissioning funding assurance 18 status reports come in annually once a licensee has 19 declared that they are, in fact, in decommissioning 20 status.
21 Two things that must be remembered is that 22 as of June 7th, 2013, two clocks have already started.
23 Number 1, the licensee has until for 60 years, to 24 decommission to NRC standards. And, more importantly, 25 we are waiting for the PSDAR to which we can then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 determine whether or not there is reasonable assurance 2 that the funding in place will be, in fact, enough to 3 carry on the decommissioning activities as prescribed by 4 the licensee.
5 So, waiting for the PSDAR, we know the 6 following facts and they are listed for you on this slide.
7 Fundamentally as of December 31st, 2012, 8 Unit 2 has almost 1.7 billion dollars set aside for 9 decommissioning. Unit 3 about 1.9 billion.
10 And for comparison, Unit 1 has a remaining 11 trust fund of about 295 million of which there is an 12 estimated cost resulting - excuse me - remaining cost of 13 almost 206 million.
14 The intention of the NRC is not necessarily 15 to claim how many nominal dollars will be involved in the 16 decommissioning process, but my job is to more or less 17 tell the Commission whether or not the purchasing power 18 of those dollars will, in fact, cover all of the 19 decommissioning costs associated with the requirements 20 under NRC regulations.
21 The one thing that I would like to also point 22 out is that of course greenfielding is not under the 23 jurisdiction of the NRC. That is primarily under the 24 jurisdiction of the California Public Utility 25 Commission.
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43 1 So, until we have a PSDAR, these are the only 2 facts that I can present to you at this time. Thank you.
3 MR. SPITZBERG: Okay. So, you get me one 4 more time, and then we'll open it up to questions. I'd 5 like to speak a few minutes about the regulation of the 6 spent fuel at SONGS.
7 Let me start from basic fundamentals, and 8 that is that spent fuel must have active heat removal in 9 a pool for several years after leaving the operating 10 reactor. After this period of time, it may be passively 11 cooled by air.
12 Spent fuel is being safely stored at San 13 Onofre in fuel pools and in the onsite Independent Spent 14 Fuel Storage Installation.
15 And we use the term "ISFSI" for that long 16 string of words, Independent Spent Fuel Storage 17 Installation. So, if I slip up and use the term "ISFSI,"
18 I apologize.
19 Spent fuel pools are able to withstand the 20 same environmental hazard conditions as the reactors and 21 will be operated by certified fuel handlers who are on 22 shift around the clock.
23 Each spent fuel pool has redundant and 24 independent cooling systems, power supplies, pool water 25 sources and other safety and emergency equipment.
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44 1 Both the spent fuel pools and the ISFSI are 2 protected by the San Onofre Physical Security Force and 3 its associated security systems.
4 Why do we need an ISFSI at these sites?
5 It's a long story, but I'll try and summarize it. The 6 need for the alternatives to spent fuel pool storage 7 emerged in the 1970s.
8 When these plants were initially designed, 9 it was anticipated and expected that the fuel would be 10 stored in the pools for a number of years to allow it to 11 decay after which it would be packaged up and shipped to 12 a DOE site for disposal.
13 The Nuclear Waste Policy Act of 1982 and the 14 Amendments Act of 1987 laid out a process for licensing 15 a geologic repository. But as most of you know, a 16 geologic repository is still decades away.
17 Dry cask storage was developed to meet the 18 need for expanded onsite storage of the spent fuel due 19 to the lack of a national repository available for use.
20 The ISFSI at SONGS became operational in October 2003.
21 To give you an example that ISFSIs are now 22 in widespread use around the country, this is a map of 23 the US showing all of the nuclear sites, the commercial 24 reactors and some of the non-commercial reactors where 25 no longer commercial reactors exist that have ISFSIs that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 are constructed and currently storing spent fuel.
2 Speaking of the SONGS ISFSI, they use a 3 model Transnuclear Advanced NUHOMS Horizontal Storage 4 Module System. The major components of this system are 5 the dry shielded canister, or what we refer to as the DSC, 6 and the horizontal storage module, or the HSM.
7 These photographs depict those. I don't 8 know if I have a pointer on here, but on the left is the 9 dry shielded canister open on one end. This is during 10 the fabrication process.
11 And then the middle photograph is the 12 fabrication process of the horizontal storage module.
13 And then there is a horizontal storage module still under 14 construction there showing with the concrete in place.
15 Each DSC has an outer shell consisting of 16 5/8th-inch thick stainless steel with steel internal 17 spacer discs. The DSC has a welded internal confinement 18 boundary and a separate welded lid.
19 The DSC is placed horizontally inside each 20 advanced horizontal storage module and into a steel 21 support structure. And that's depicted in this 22 photograph here on the transporter in a shielded cask 23 that is especially designed to move these canisters out 24 to the horizontal storage modules on site.
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46 1 thick steel-reinforced concrete walls that are greater 2 than four feet thick and roof slabs that are about five 3 feet thick. And you saw the reinforcing steel in that 4 structure as it was being constructed, in the previous 5 photograph.
6 And this provides for additional structural 7 protection to the canister and the radiation shielding.
8 The horizontal storage modules set on 9 concrete pads that are steel-reinforced concrete of a 10 minimum thickness of three feet.
11 I know those of you out here in southern 12 California are concerned about seismic conditions. And 13 any of us that have recalled the Fukushima accident are 14 concerned about flooding and tsunami considerations when 15 you live on the ocean. So, let me speak to that with 16 respect to the SONGS ISFSI.
17 The SONGS ISFSI is designed for 18 high-seismicity sites. The design basis earthquake 19 used to analyze the SONGS ISFSI is 2.24 times higher 20 than that used in the licensing of the reactors.
21 For tsunami considerations and flooding, 22 the SONGS ISFSI is located 19.75 feet above sea level.
23 The maximum flood condition of 29 feet was evaluated for 24 the ISFSI, which would potentially put the ISFSI pad 25 under nine feet of water.
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47 1 The design basis flood for the advanced 2 horizontal storage module design is to withstand a 3 submersion at 50 feet underwater.
4 The maximum tsunami including storm height 5 of the waves was evaluated at 27 feet for the SONGS ISFSI, 6 which is less than the maximum flood conditions evaluated 7 for the site.
8 All these evaluations did not take into 9 credit for the 28-foot sea wall which exists between the 10 ocean and the ISFSI.
11 And finally if the ISFSI were to get 12 temporarily flooded during a tsunami, there would be no 13 adverse thermal effects.
14 Let me talk about how we do the inspection 15 of the spent fuel storage. For the pool, we do routine 16 inspections normally semiannually using an inspection 17 procedure 60801.
18 And the reason I mention the inspection 19 procedure number is that I would invite you all to go onto 20 our website. You can call up these inspection 21 procedures and read them for yourself to see what it is 22 we look at in detail.
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48 1 2690.
2 And this manual chapter references an 3 assortment of individual inspection procedures that we 4 also implement during that inspection.
5 We attempt to schedule our routine 6 inspections of the ISFSI when there's an active loading 7 campaign in progress.
8 We are not always able to do that. For 9 those ISFSIs that have been fully loaded, we're not able 10 to do that, obviously, but we do make every effort to come 11 out when they're actually loading the cask.
12 And once again I'll reference the website 13 of the NRC where you can find out inspection guidance and 14 NRC inspection reports for the ISFSI.
15 MR. CAMERON: Okay, thank you. Thank you 16 all. Good information for everybody. And before we 17 start the question and answer, I forgot to tell you that 18 if you want to write a question tonight instead of 19 speaking, you can do that. And my colleague Bob Hager 20 who's right in the back of the room, he has these yellow 21 cards. You can write a question and at some point during 22 the night we'll read some of them.
23 And also, we're going to take a ten-minute 24 break around 7:30 and then come back and finish the 25 evening off.
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49 1 We're going to start the 2 question-and-answer session by going to Gene Stone who's 3 right here. He's the spokesperson for a new coalition 4 of concerned citizen groups. It's the Coalition to 5 Decommission San Onofre.
6 The coalition has taken the time and effort 7 to put together some basic questions about the 8 decommissioning of SONGS. And the NRC appreciates that 9 effort.
10 The questions are from the coalition, but 11 the answers to those questions are for all of you. And 12 I think that a lot of these questions are on everybody's 13 mind.
14 So, I'm going to ask Gene to say a few words 15 about the coalition and to read us the first question.
16 I'll read the second question.
17 We're going to put them up on the screen so 18 that they're easier to understand for all of you. The 19 NRC will then answer two questions and then we're going 20 to go on to all of you to see what else is on everybody's 21 mind out here.
22 We'll come back to the next two coalition 23 questions at some point. Go back to all of you and we'll 24 just continue doing that.
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50 1 evening we'll see if there's any follow-up questions to 2 the NRC answers that have been given.
3 And, Gene, could you talk to us a little bit 4 right now? I can hold this, or you can. Whatever you 5 want.
6 MR. STONE: The coalition consists of 7 different citizens here in the southern California area 8 and different groups as well.
9 The Sierra Club is here with us. San 10 Clemente Green, Residents Organized for a Safe 11 Environment. Citizens Oversight Project is here, 12 Women's Occupy and the Peace Resource Center of San Diego 13 are here. And the Sierra Club chapter is the Angeles 14 Chapter, which includes LA and Orange County.
15 So, we are here today in hopes that the NRC 16 will make San Onofre a flagship project for the safe and 17 sane cleanup of America's effort to decommission our old 18 and dangerous nuclear fleet and its highly radioactive 19 problems.
20 The original Manhattan Project brought us 21 to where we are now and it's time for this kind of 22 resources and energies to be put into a new project to 23 rid us of the dangerous, highly dangerous radioactive 24 waste that we have here at SONGS and all the nuclear power 25 plants.
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51 1 To this end, the coalition to decommission 2 is forming a true citizens oversight committee to watch 3 out for the health and safety of Californians and the 4 workers at the plant during the decommissioning process.
5 Our second goal is to monitor the cost of 6 decommissioning so that the citizens and rate payers of 7 California are not gouged during this process. Most of 8 that obviously will happen with the PUC.
9 So, my first question is, is the NRC willing 10 to recognize and give us, the Coalition to Decommission 11 San Onofre, official status? Will the public have an 12 opportunity to review, comment on significant 13 decommissioning plans, including plant expenditures?
14 MR. CAMERON: Okay, thank you. Thank you, 15 Gene.
16 Larry, would you like to address the first 17 one?
18 (Applause.)
19 MR. CAMPER: Thank you, Gene. Appreciate 20 your comments.
21 The NRC will take that into consideration, 22 absolutely. I think there's a lot of merit in what 23 you're suggesting and I guess I would probably like for 24 you to tell us just a little bit more about how you think 25 that might work or the merit of that type of relationship.
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52 1 MR. STONE: Well, first I'd like to say 2 before I tell you what I think that might entail, because 3 what that entails is limited by what you say is possible.
4 So, let me start by saying what I think this will do for 5 the NRC to have citizens involved.
6 It will give the credibility to the NRC that 7 the chairman is trying to achieve by openness and dealing 8 with groups like ourselves.
9 It will also lend itself to having our 10 communities at large have interested people who will be 11 there to oversee the safety from a citizen's point of 12 view, not from a technical point of view, but just to keep 13 an eye on to help inform what goes on out there during 14 the process.
15 And we envision doing this through some sort 16 of process where we establish an ongoing group of people 17 that would somehow - and we haven't formulated all these 18 ideas, but like a board of directors and but we want this 19 to be a true citizens oversight.
20 So, we'd like to join with you during 21 inspections with the NRC. Not that we have an eye for 22 a technical point of view, but we - a critical eye and 23 critical thinking from different perspectives brings a 24 whole new light on any story.
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53 1 from, I'm sure, the chairman and the other commissioners, 2 but we'd like to be part, an active part of participating 3 in the safety of this lengthy process. Thank you.
4 MR. CAMPER: Well, thank you. We hear that.
5 And, like I said, we'll take it under consideration and 6 we'll do that very promptly. Thanks, Gene.
7 MR. CAMERON: Okay. Could we get the second 8 question up on the screen for everybody to see? And this 9 is a multi-part question. So, I'm going to read it and 10 it will be up on the screen for everybody to see.
11 And this is about high burnup fuel. And the 12 question is, high burnup fuel has been used at San Onofre 13 since 1996 we were told by the NRC recently, but we cannot 14 find a public notice of that from the NRC or SEC. Even 15 the union and other workers we have talked to were not 16 aware of its use.
17 Was a notice ever given to the public and 18 workers? Were workers made aware that this high burnup 19 fuel is more than twice as radioactive?
20 And there's a further statement that high 21 burnup fuel is hotter and between two and 158 times more 22 radioactive requiring the waste to be cooled onsite in 23 spent fuel pools for at least 12 to 15 years rather than 24 five years.
25 Does the NRC agree with these statements?
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54 1 If not, how much more radioactive would the NRC say high 2 burnup is?
3 Edison reported to the CPUC, that's 4 California Public Utilities Commission, they must keep 5 some of their fuel in spent fuel pools for at least 12 6 more years.
7 Why don't we go to the NRC for answers to 8 that before we go to the other parts of the question.
9 And, Blair, are you going to answer that for us?
10 MR. SPITZBERG: I will try. Okay. I'll 11 answer what I can. I'm not from the licensing 12 organization and headquarters that would license the 13 authorization for the high burnup fuel, but what I can 14 tell you is that they have used high burnup fuel.
15 They are authorized for storage casks to 16 contain that high burnup fuel once it's brought out of 17 the pool.
18 I don't have the tech spec requirements here 19 with me and I wasn't able to get them two days ago when 20 I got the question. So, I apologize for not having been 21 able to get the answer to the question about what the 22 storage time in the spent fuel pool must be for the high 23 burnup fuel.
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55 1 longer than the normal five years for regular fuel.
2 I think seven years is the number that I've 3 seen normally as a figure for high burnup fuel, but it 4 really depends on the level of burnup and what was 5 authorized on the license and I don't have that 6 information.
7 What I can say is that the high burnup fuel 8 will not be loaded into a canister for long-term storage 9 in the ISFSI unless it meets the certificate of 10 compliance for that canister system. And we will 11 inspect that.
12 MR. CAMERON: Okay. Thanks, Blair. I'm 13 going to go through - there's three other parts here and 14 I'm going to read all of them. And then we'll go back 15 to the NRC staff for answers.
16 How does the high burnup fuel affect the 17 decommissioning process at San Onofre? What specific 18 problems does this higher radioactive fuel present for 19 waste storage in fuel pools and dry cask storage at San 20 Onofre and just how much longer will this radiation last?
21 How will decommissioning be impacted by the current 22 onsite storage of the spent fuel?
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56 1 a new study to determine if it can be safely stored in 2 dry cask.
3 Is this report complete? Will it be 4 released public and when? One of your concerns is that 5 there is no way to monitor what's occurring inside the 6 dry cask.
7 How does the NRC propose to monitor the 8 highly radioactive material in a dry cask? How many 9 casks will be required to safely store all the high burnup 10 fuel that is onsite in both the spent fuel pool and dry 11 casks at San Onofre?
12 MR. SPITZBERG: That's a lot of questions.
13 MR. CAMERON: Okay.
14 MR. SPITZBERG: Let me see if I can attack 15 them one at a time.
16 MR. CAMERON: And just one - how much high 17 burnup fuel is on site in fuel pools and dry casks at San 18 Onofre? Okay.
19 MR. SPITZBERG: Okay. And I will tell you 20 that I worked over the last day and a half with some of 21 our folks from headquarters. So, some of the 22 information I'm relying on to respond to this question 23 is information that they helped to gather while we were 24 traveling out here.
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57 1 data on the total amount of spent fuel stored at 2 commercial facilities like SONGS throughout the country.
3 The information and much more concerning 4 the nuclear fuel is available on our website. If you go 5 to our website NRC.gov and look at what - under waste and 6 spent fuel storage, you'll get the webpage with that 7 information.
8 However, for any given facility, the 9 information is considered security-sensitive 10 information and is, therefore, not disclosed to the 11 public as to the amount of spent fuel.
12 You can find this in other publications, 13 though, because I found a publication yesterday called 14 Store Fuel that does have the number of fuel assemblies 15 here at SONGS published.
16 When the last routine ISFSI inspection 17 report was issued in May of - May 20th, 2011, and this 18 is a report that's available on our website, SONGS had 19 loaded 11 canisters that contained at least one fuel 20 assembly that was greater than the criteria for high 21 burnup fuel.
22 I'll mention that criteria to you. I know 23 it won't mean a lot to most of you, but it's anything 24 greater than 45 gigawatt days per metric ton of uranium 25 in the fuel and it basically relates to how long the fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 was in the reactor at power. And that's what - if you're 2 greater than that number, then it's considered high 3 burnup.
4 Out of the 55 canisters that are loaded on 5 the ISFSI pad currently or at that time of the inspection, 6 the NRC does not maintain records showing how many fuel 7 assemblies have been loaded that were high burnup.
8 However, licensees and certificate holders 9 are required to register each cask with the Nuclear 10 Regulatory Commission under the provisions of Part 11 72.212(b)(2). And the registrations and information 12 contained therein is subject to routine inspection.
13 The NRC does agree that there is currently 14 no way to monitor the behavior of fuel inside a sealed 15 cask. We are actively monitoring the efforts of 16 industry and the Department of energy to better 17 understand fuel aging mechanisms.
18 The DOE is taking an active role in funding 19 the Nuclear Energy University Program projects to look 20 into this issue.
21 In addition, DOE is sponsoring a 22 demonstration test with a variety of high burnup fuels 23 to benchmark their models of the behavior of the fuel and 24 to obtain through monitoring of this cask the temperature 25 and gases evolved, which will tell them how the fuel is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 behaving. This demonstration will provide data that 2 monitors the behavior of the spent fuel.
3 It depends on which dry cask storage system 4 is used at San Onofre for the decommissioning effort and 5 when the spent fuel is actually moved to the dry cask 6 storage to the different sizes of casks and the actual 7 heat load being given off by the assemblies that the 8 licensee wants to load into the casks. And this 9 information is not yet available from the licensee on the 10 new casks that they're wanting to put into use.
11 MR. CAMERON: Are you ready for the last part 12 of the question, or do you still have some more on that?
13 MR. SPITZBERG: Is that D?
14 MR. CAMERON: Yeah, this is D. We know that 15 MOX fuel was -
16 MR. SPITZBERG: Okay.
17 MR. CAMERON: - used in Unit 1 and removed 18 from San Onofre to the GE Morris facility in Illinois.
19 How and when was that done and under what 20 permit was that done? If MOX fuel was transported away, 21 can other high burnup fuel be moved from the site in the 22 same way to the same place?
23 MR. SPITZBERG: Okay. the MOX fuel was not 24 moved to GE Morris in Illinois. And what I can say was 25 that between March of 1972 and September 1980, 270 fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 assemblies were shipped to GE Morris and MOX fuel was not 2 included in these shipments.
3 NRC does not require/retain records of 4 which transportation package was used at that time for 5 the specific shipments.
6 That was a unique shipment. Normally fuel 7 can't be shipped to an intermediate storage facility like 8 GE Morris without specific authorization from the NRC, 9 in which case they were authorized under their license.
10 Those shipments are no longer being conducted, but the 11 MOX fuel was not part of those shipments. The MOX fuel 12 is in storage here at San Onofre.
13 MR. CAMERON: Okay. Thank you, Blair. And 14 we're going to go to other people now. We will be back 15 to the coalition's questions and eventually we're going 16 to go to - for follow-up questions there.
17 And, yes, sir, if you could just introduce 18 yourself to us?
19 MR. CRAYCRAFT: Thank you very much, 20 gentlemen. Thank you for being here with us this evening 21 and allowing the public to respond. It's commendable.
22 Applaud you on the efforts of not only your group, but 23 the entire NRC for progressing what everyone in this room 24 hopes to be a safe and honorable process in the 25 decommissioning.
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61 1 I have a couple quick questions for you. My 2 name is William Craycraft. I'm a four-term mayor -
3 former mayor of Mission Viejo, California, which is South 4 County's largest city close to SONGS.
5 The first question I have is, given that SCE 6 has decommissioned Number 1, Generator Number 1 7 successfully as I understand what you have shared with 8 us here, were there any problems with that 9 decommissioning process?
10 PARTICIPANT: I'll address that because -
11 MR. CAMERON: Why don't you ask your second 12 question as well?
13 MR. CRAYCRAFT: Okay, I can go that. And 14 were there - the other question is, were there any 15 problems with the decommissioning of Unit Number 1 and 16 have the regulations changed since that decommissioning 17 of Unit Number 1? In other words, something applying to 18 Two and Three?
19 The second question, please, is I heard at 20 the beginning in the introductions that Chip gave that 21 there are a number of state agencies possibly here, maybe 22 another Federal agency representing. What is their 23 function in the decommissioning process? If they could 24 briefly share with everyone here what their 25 responsibility is, please.
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62 1 Thank you kindly.
2 MR. CAMERON: Okay. Good questions, Bill.
3 And after we get the first one, we're going to go to some 4 of the state agencies so that they can explain that.
5 And NRC staff, you heard the first question.
6 And I think part of the essence of that question also is 7 what lessons have been learned in the decommissioning of 8 San Onofre Unit 1 or other decommissioning experiences 9 since then that you might want to talk about.
10 Blair, you go. And I don't know if Doug 11 Broaddus from NRR wants to say anything, but we're going 12 to leave it to you and then we'll go to the state agencies.
13 Blair.
14 MR. SPITZBERG: Okay. I was the branch 15 chief over decommissioning during the decommissioning of 16 Unit 1. And one of my principal inspectors for the 17 decommissioning of Unit 1 is here tonight, Rob Evans.
18 So, I'll invite him to weigh in if he has any input as 19 well.
20 Unfortunately, in preparation for this 21 meeting I didn't go back and review all the inspection 22 reports from the Unit 1 decommissioning, but I'll rely 23 on my memory as best I can.
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63 1 much on schedule.
2 I do remember that there were some routine 3 violations that we identified throughout. I remember 4 one in particular that was what we considered to be a more 5 significant violation that involved a shipment of some 6 liquid radwaste to a disposal site in Utah that had some 7 leakage when it was at a truck stop in Utah.
8 The licensee responded very promptly and 9 they went out there and performed a little bit of decon 10 at the truck stop and reconfigured the waste shipment and 11 got it on its way to the disposal site.
12 And there were no health effects as a result 13 of that, but it was still a leaking shipment, which is 14 unacceptable to us and a violation. So, we did cite the 15 licensee at that time. And I do believe that was what 16 we considered to be escalated enforcement, but I don't 17 think that there were any monetary sanctions because of 18 the good performance history at the time of the 19 decommissioning effort.
20 I think the second part of your question, 21 was there anything unusual that we saw during the 22 decommissioning, I would say that there is not.
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64 1 vessel is still on site in storage and that I know that 2 they had developed plans to grout the reactor vessel and 3 to ship it to a disposal site, I believe, in South 4 Carolina, which was the only open site that could accept 5 that reactor vessel at the time.
6 And I think they had some difficulties and 7 challenges in getting some of the approvals for the right 8 of the way for the transportation of that.
9 They went through several different 10 iterations, as I recall, of different routes that they 11 could pursue. And I think they finally made a decision 12 just to keep it on site until the decommissioning of Units 13 2 and 3. And so, it still rests there today.
14 MR. CAMERON: Okay. Thank you very much, 15 Blair. And, Larry, Bruce?
16 MR. CAMPER: Yeah, I would just footnote that 17 and thanks for the question. There has not been a change 18 in the regulations since Unit 1 underwent 19 decommissioning, but there have been a number of 20 information notices put out by our agency in terms of 21 lessons learned. For example, there's been information 22 put in about how to enhance site characterization that 23 comes to mind.
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65 1 at what we now know about decommissioning.
2 So, no regulatory change, but much 3 additional information.
4 MR. CAMERON: Anything else that you want to 5 add, Bruce, on this?
6 MR. WATSON: San Onofre 1 was somewhat unique 7 in that we did what we would call a partial site release 8 under 10 CFR 50.83. And it was determined that the - I 9 believe it's the intake structure which extends out into 10 the ocean was released.
11 And of course it was unconditionally 12 released and it was determined that removal of that 13 particular structure may create more environmental 14 damage than leaving it in place. And so, that was 15 somewhat unique in the decommissioning for Unit 1.
16 MR. CAMERON: Okay, thank you. Let's go to 17 the second part of Mr. - pardon me?
18 MS. RUSEN (phonetic): I'm wondering if I 19 could just follow up. I have a couple of follow-up 20 questions on what was just said.
21 Is that possible rather than moving on?
22 MR. CAMERON: We'll follow up with you later 23 on. We're going to go to the state agencies right now.
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66 1 agencies and let me introduce Cynthia Walker from the 2 California Public Utilities Commission and Rob Oglesby 3 from the California Energy Commission.
4 And, Cynthia, do you want to go first and 5 just say a little bit about what the PUC is doing, and 6 then we'll go to Rob. Cynthia.
7 MS. WALKER: So, the California Public 8 Utilities Commission's role in decommissioning is we 9 have oversight of the management of the decommissioning 10 of the funds that are set up for all the decommissioning 11 of the plants and in California.
12 So, there is a separate board. It's all 13 established by commission decision that oversees the 14 investments in the fund.
15 And what we do is, and what we'll be doing 16 with SONGS, is they will be filing an application for 17 their plan for decommissioning and they've forecasted an 18 amount that they are likely to spend, and we will be 19 releasing funds for each of the - as they do the 20 decommissioning and overseeing that process.
21 The fund is pretty substantial at this 22 point. The plan was always to have it that way. Because 23 of the lease with the Navy, there is a requirement that 24 it be a greenfield restoration.
25 So, and then we also establish the rates.
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67 1 We keep track, make sure that there is funding. As 2 Michael was saying, California is more strict than the 3 NRC in some ways. We have our own - not maybe more 4 strict, but we have additional requirements. And so, we 5 will make sure that there is sufficient funding for the 6 decommissioning as required by the state.
7 MR. OGLESBY: So, I'm Rob Oglesby. I'm the 8 executive director of the California Energy Commission.
9 And the California Energy Commission has been involved 10 with this since the plant was first shut down 20 months 11 or so ago.
12 And our role in the process isn't so much 13 with decommissioning, but it's been to work with our 14 sister agencies to make sure going forward that there is 15 reliable electricity supplied in the absence of SONGS.
16 And over 2012, for example, we worked with 17 our sister agencies, the CPUC, the CAISO, to make sure 18 that we could make system changes in the near term to take 19 care of the summer of 2012. And that included restarting 20 an old power plant in order to give some voltage support, 21 making improvements in transmission and also working to 22 get additional conservation.
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68 1 forward to have a stable and reliable supply of energy 2 for this region.
3 MR. CAMERON: Thank you, Cynthia. Thank 4 you, Rob. Let's see what the woman in the red sweater 5 has on her mind and then we'll answer that. And then 6 we'll take a break.
7 If you could just please introduce yourself 8 to us?
9 Ms. RUSEN: Thanks. My name is Mila Rusen.
10 I live in Los Angeles and I have - there were a couple 11 of things that struck, me.
12 One, there was a statement made that there 13 was release of radioactivity during the decommissioning 14 of - that there was a release of radioactivity during some 15 kind of an incident that happened in transporting some 16 of the equipment from Unit 1 and there was an assertion 17 made that there was no health impact. And so, I'd like 18 to know the basis of that assertion.
19 And then, I'd also like to know - someone 20 else stated after that, that there was another release, 21 I think, into the ocean.
22 And so, I want to know about how you can be 23 so sure that there were no health consequences whatsoever 24 as a result of these releases of radiation.
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69 1 much. And we're going to see if we can give you some 2 information on that. And perhaps more information can 3 be given during the break to you from the NRC staff, but 4 anybody - who would we suggest address that? Blair?
5 MR. SPITZBERG: I can address that.
6 Although, my memory is vague on this now. And, Bob, you 7 may have to help me is that when we - this would have been 8 a reportable event that we were notified of. And when 9 we get a report like this, we would dispatch an inspector 10 to the site to take surveys of not just the vehicle, but 11 any areas that the vehicle may have leaked to.
12 And my recollection is that based upon the 13 surveys that were conducted and the information that we 14 were able to gather from the route of the vehicle and the 15 circumstances of the leakage, that it was not 16 significant.
17 If you need more details than that, what 18 I'll have to do is find the inspection report that 19 documented our follow-up inspection of that and then we 20 can make sure that you're aware of that. It's on our 21 website.
22 I just think that that was - what was that, 23 Bob? That was bout 2006. Okay. So, that was about 24 eight or nine years ago.
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70 1 anything to add to that. And I don't want to lose the 2 last part of the question, because I think it's 3 important. It goes to how the NRC does things about how 4 can you be certain that - what process do you use to make 5 sure that - to ascertain whether there is affects or not.
6 And, Bob, you can address -
7 MR. EVANS: Bob Evans. I'm a senior 8 inspector for the NRC. The event occurred in 2006.
9 There was liquid radwaste that was being disposed in 10 Utah.
11 And a vent on the tanker leaked and I 12 understand it leaked on a road. And this occurred in 13 Utah, which is what we call an agreement state. And the 14 state of Utah responded on behalf of the NRC.
15 The licensee at the time dispatched a team, 16 remediated the roadway and just basically it did not 17 create a significant radiological hazard to health and 18 safety.
19 It was an environment release and it was 20 eventually cleaned up.
21 MR. CAMERON: Okay. Thank you and anybody 22 else from the NRC want to add something before we go on 23 break?
24 Bruce and Blair.
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71 1 point on that.
2 MR. CAMERON: Okay.
3 MR. SPITZBERG: And that is under the 4 transportation regulations from DOT which we enforce 5 when it comes to transportation of radioactive 6 materials, is that certain materials that are 7 radioactive cannot be transported in liquid form if there 8 is above a certain level of radioactivity.
9 And so, for something that's of a liquid 10 nature to be transported in a bulk form like that, it has 11 almost by definition to be a low-level activity.
12 So, that's one of the things that gave us 13 confidence that there were no significant radiological 14 consequences associated with this, but we had to wait 15 until the final surveys and information came in from the 16 inspection team from Utah and that we were able to assess 17 that.
18 Nevertheless, I will say that it was a 19 significant violation to us. It fell into what we call 20 a Severity Level 3 category under our enforcement 21 policies, which is the threshold for when we consider 22 escalated enforcement.
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72 1 other parameters that we go through with our enforcement 2 staff to make a final determination of what enforcement 3 mechanism to use.
4 MR. CAMERON: Okay. Thank you very much.
5 And is it Cynthia? What was your name?
6 MS. RUSEN: Mila.
7 MR. CAMERON: Mila. Okay. Sorry, Mila.
8 We're going to take a break now for ten minutes. I have 9 7:36. And we'll get started again after ten minutes and 10 you can come back at your leisure.
11 (Whereupon, the proceedings went off the 12 record at 7:36 p.m. for a brief recess and went back on 13 the record at 7:46 p.m.)
14 MR. CAMERON: And just let me give you a 15 preview of what we're going to do for the next few minutes 16 at any rate, and then we're going to try to get to the 17 rest of everybody.
18 We have first - and, Bob, just hold off one 19 second. First of all, we have a woman right here who's 20 going to ask a question, okay, but someone asked - there's 21 a video being taken of this meeting. That's going to 22 be the record of the meeting. And I was told that that 23 would be available in a couple of weeks.
24 MR. LANTZ: Maybe less than that, actually.
25 MR. CAMERON: Okay.
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73 1 MR. LANTZ: Yeah, the video of the meeting 2 tonight, it will be posted on our website. And that 3 should be within about two weeks. And it will also be 4 transcribed so you can read it, if you don't want to watch 5 it.
6 MR. CAMERON: Okay, thanks. That's Ryan 7 Lantz from Region IV.
8 We also were asked the question of who 9 authorizes the use of high burnup fuel. It was in the 10 coalition's question and people weren't sure that we 11 answered that. So, we want to get back to that.
12 The NRC is going to be back out here in ten 13 days or so at the Sheraton to do a public meeting on the 14 draft environmental impact statement on waste 15 confidence.
16 And it's very important for everybody to 17 know about that. And I don't want to - I don't want to 18 let that languish.
19 So, I was going to ask Paul Michalak who's 20 here from the Waste Confidence Directorate at the NRC 21 headquarters in Rockville, Paul, can you just tell people 22 about - a little bit about the meeting, the schedule and 23 everything? And let's get that done now.
24 Paul.
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74 1 here - well, in Carlsbad in Wednesday, October 9th.
2 We're going to be over at the Sheraton.
3 We're going to have an open house between 4 6:00 and 7:00 and we're going to be taking comments from 5 7:00 to 10 o'clock.
6 And that has to do with we've been 7 developing over the last year a Generic Environmental 8 Impact Statement having to do with the continued storage 9 of spent nuclear fuel. That being the time from the end 10 of the license life of a reactor until the fuel is taken 11 then to a mine geologic repository.
12 We have this document out for comment.
13 Went out Friday the 13th in September. September 13th.
14 And the commenting period ends November 27th. So, we're 15 doing a lot of meetings around the country and we start 16 next week.
17 We have a meeting next Tuesday at 18 headquarters that's going to be webcast and then it's 19 also going to be teleconferenced. You can call into that 20 meeting if you couldn't make our October 9th meeting.
21 Then at the end, or near the end of the 22 commenting period on November 14th, Thursday, we're 23 going to have another meeting at headquarters that would 24 also be webcast and teleconferenced and you could also 25 call into that as well if you had comments.
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75 1 MR. CAMERON: Thank you, Paul. And if 2 you're interested in more information on waste 3 confidence, Paul will be here.
4 MR. MICHALAK: And I'm sorry. We have 5 flyers out on the table with a lot more detailed operation 6 about the October 9th meeting.
7 MR. CAMERON: Okay. Thanks. Thanks, Paul.
8 And after we hear from this woman right here, we're going 9 to go over to Gale and two women over here, okay? So, 10 thank you. Please address us.
11 MS. BORCHMANN: Hello. My name is Patricia 12 Borchmann. I'm a resident in Escondido, San Diego 13 County. And I have family in Carlsbad, I have family in 14 Seal Beach and I consider in, you know, the 8.46 million 15 people within 50 miles of San Onofre, I consider all of 16 you my family. So, that's where I'm coming from.
17 And I, you know, I think that the public 18 expects NRC to fully perform and carry out your duties 19 for public safety. And so, anyway, some of my questions 20 - one of my comments is related to your announcement just 21 now that NRC is going to be having public meetings 22 regarding a Generic Environmental Impact Statement 23 that's going to be prepared.
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76 1 in southern California think that a site-specific 2 Environmental Impact Statement as opposed to a Generic 3 Impact Statement would be required given the specific and 4 very important physical circumstances at San Onofre 5 which don't exist elsewhere in the nation.
6 Generic documents don't, you know, provide 7 site-specific assessments and I think that would be a 8 real important -
9 MR. CAMERON: Okay. Thank you, Patricia.
10 MS. BORCHMANN: Okay. Anyway, that wasn't 11 my question.
12 MR. CAMERON: Well, go ahead.
13 MS. BORCHMANN: Thank you for allowing me the 14 time. There's been a lot of discussion by each team 15 member, you know, to convey reasons why the Nuclear 16 Regulatory Commission has such confidence, waste 17 confidence, you know, and that's what this EIS is going 18 to be talking about, but basically confidence in every 19 aspect.
20 Unfortunately, the public here in southern 21 California, we've grown skeptical over a long history of 22 living here near San Onofre and being exposed to, you 23 know, circumstances which we feel impacts have been 24 minimalized, trivialized, marginalized, sanitized and 25 pretty much, you know, comments and concerns of even NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 independent experts who are engineers, who are, you know, 2 physical scientists, physicists and, you know, highly 3 qualified specialists that they have conclusions that 4 are in contrast with the safety assurances that the NRC, 5 you know, provides us to members of the public because 6 -
7 MR. CAMERON: Patricia, is there a question?
8 MS. BORCHMANN: Okay, yes. For example, the 9 use of high burnup fuel started in 1996. Why is it or 10 what basis for public safety was your approval, the NRC's 11 decision to approve the use of high burnup fuel used when 12 there has been no analysis, there has been no proof, 13 credible proof that the long-term effects will have no 14 significant impact, you know?
15 MR. CAMERON: Okay. Patricia, we're going 16 to - that matches the concern that someone had during the 17 break about the authorization of the high burnup fuel.
18 So, we're going to - let's take that now and then I want 19 to go to Gale and to Larry Kramer and - right here, okay.
20 And then we've got to get Three and Four of the 21 coalition's questions up there.
22 Authorization, Bruce, Blair, you heard the 23 question. How is the use of high burnup fuel at a 24 particular site at this site, how is that authorized?
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78 1 our Office of Spent Fuel Storage and Transportation.
2 And what they do is they will get an application for a 3 cask for storage of spent fuel. And as part of that 4 application, they'll get all the specifications for the 5 spent fuel including heat load and the type of fuel 6 assemblies and how long the burnup was and a whole 7 assortment of parameters of which I'm not fully aware of 8 all the questions that they ask.
9 They have thermal specialists, they have 10 health physicists, they have structural specialists, 11 they have criticality specialists, they have all these 12 specialists that will review that application.
13 And if that application meets the criteria 14 for licensing that cask, they will approve the cask.
15 Once they approve that cask, they'll certify it. And 16 then that is open to the public comment and to hearings 17 and that process.
18 What they do is they will rely on historic 19 data, a fuel that has been stored in casks of that nature 20 that they have either from the vendors or from licensees 21 or from, in some cases, DOE they have a historic database 22 and models that they use to develop the thermal models 23 and the health physics models associated with that. And 24 that's part of the licensing basis.
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79 1 from a licensing organization that does that licensing 2 that will be able to provide a more detailed answer to 3 that, but that's basically - excuse me?
4 MR. CAMERON: Please, please, please.
5 Please, we're trying to get the answer to your question.
6 Okay? So, just let's please let people try to answer the 7 question.
8 And I think that the issue is you're talking 9 about the use of the cask for it, but I think the question 10 is, is why was high burnup fuel authorized to begin with.
11 We're going to go to Doug Broaddus from the 12 Office of Nuclear Reactor Regulation. Doug.
13 MR. BROADDUS: What I can talk about is the 14 licensing process for fuel. I don't have specifics on 15 the applications that occurred with San Onofre at the 16 time, you know, back in the early `90s.
17 I didn't have a chance to research that yet, 18 but the fuel itself is - there would be an application 19 originally that would be approved with the license 20 originally, the type of fuel that would be used at the 21 reactor site.
22 The manufacturers may come in and want to 23 use different fuel and they'll - or produce different 24 fuel. They'll come in for a - what would be more of a 25 generic type of approval. We would do that through a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 topical report. And then that would be approving the 2 design of the fuel itself.
3 And then if each reactor wants to come in 4 and use that fuel at their particular facility, they'd 5 have to come in for a specific - a site-specific amendment 6 request at their site to use that fuel.
7 So, that's the process that's used. And 8 each of those, there would be a licensing amendment and 9 application. There would be an opportunity for public 10 involvement in that, but I don't have the specifics for 11 San Onofre as the one that happened - which one - we can 12 get that information and provide that at a later date.
13 MR. CAMERON: That's the process that was 14 gone through. And you can get specifics on that, okay.
15 Thank you very much, Doug, and we're going to go to Gale 16 and to Mr. Kramer and then we're going to come to you, 17 okay?
18 Gale. Yes, we'll get you in there. We're 19 going to do it a little bit later. Go ahead, Gale.
20 GALE (phonetic): Yes. This is perhaps a 21 very difficult thing to have to face, but I think we need 22 to keep track of the fact that the San Onofre nuclear 23 generating station is on the edge of the ocean and we need 24 to learn lessons from Fukushima also on the edge of the 25 ocean.
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81 1 One of the things that's happened across the 2 last few years in Orange County is that its entire coast 3 under every municipality from San Clemente to Seal Beach 4 has qualified tsunami ready.
5 SONGS has qualified as something called 6 storm ready, but we've been down there and we've taken 7 a look at their so-called wall. And I really think 8 almost that whatever needs to be kept for a while in 9 cooling ponds needs to be transported to cooling ponds 10 that are further inland or the disaster for the coastal 11 area and a really significant tsunami will be enormous.
12 When you get that radioactive material 13 spread that way, you have Fukushima where they're not 14 trying to take care of even more water that they tried 15 to get out of the picture, because it's become 16 radioactive. So, I bring this problem to your 17 attention.
18 I don't know what the answer is, but I'm not 19 sure that's a good place to put it to sleep to the sound 20 of the waves.
21 MR. CAMERON: Okay. Thank you for that 22 comment, Gale.
23 (Applause.)
24 MR. CAMERON: We're going to go to Councilman 25 Kramer. Councilman Kramer.
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82 1 MR. KRAMER: Yeah, I'm Larry Kramer. I'm on 2 the City Council of San Juan Capistrano and I've been to 3 I think every meeting that's been held in the last couple 4 years, but I've got a real simple question.
5 I appreciate all the questions and I've 6 learned a lot from all these meetings. I think they're 7 fascinating and I think everybody brings a different 8 perspective as they come in here and it's been very 9 interesting to hear all the different perspectives.
10 I heard something tonight, though, that 11 peaked my interest and I'm curious. On Unit Number 1, 12 the reactor vessel is still there and you had some 13 difficulty shipping it. And now, that method of 14 shipping apparently has gone away.
15 It makes me wonder are there other parts of 16 Unit 1 that are still here, and does that imply that for 17 Units 2 and 3 that the reactor vessels and other primary 18 components may be here for a long time, if not forever.
19 That's my simple question.
20 MR. CAMERON: Simple question, but perhaps 21 the answer isn't. I don't know. Who's going to deal 22 with that one up on the platform?
23 MR. SPITZBERG: I would have to go back and 24 check, but I believe that the only thing remaining of a 25 radiological nature from Unit 1 is the reactor vessel and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 the spent fuel.
2 There may be some what we call greater than 3 Class C waste that may have been also containerized and 4 put in their SOC, but I would have to verify that. That's 5 something that has been done at other sites.
6 I'm not aware of any other certainly 7 significant sources from Unit 1 there.
8 MR. CAMERON: Okay. Go ahead, Bruce, and 9 then we'll go to Bob. Go ahead.
10 MR. WATSON: You want to talk about Unit 1?
11 MR. EVANS: Yes.
12 MR. WATSON: Go ahead. I'll follow up with 13 Unit 2 and 3 questions.
14 MR. EVANS: Just as a reminder, Unit 1 shut 15 down in `92. They started decommissioning the DECON 16 mode in 1999. It took about ten years.
17 What they did at the time was what's called 18 phased decommissioning and they basically disposed of 19 everything that was above the surface.
20 At this point in time besides the reactor 21 pressure vessel, there are still some subsurface 22 structures like the foundations of the building are still 23 there with some very low levels of radioactivity and 24 contamination.
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84 1 to finish the substructures of Unit 1 in conjunction with 2 completing the substructures at Two and Three. And the 3 disposal of the Unit 1 reactor pressure vessel will be 4 disposed at the same time Units 2 and 3 are disposed.
5 So, again, it was called a phased 6 decommissioning.
7 MR. CAMERON: Okay. Thank you very much and 8 - I'm sorry. Go ahead, Bruce.
9 MR. WATSON: I think that with the response 10 to the questions on Unit 2 and 3, Southern California 11 Edison is going to have to make the determination on how 12 they're going to handle those large components.
13 I can give you the example that Trojan were 14 because they had access to the barge traffic on the 15 Columbia River, the reactor vessel was packaged so it 16 could be shipped by barge up to the disposal facility at 17 Hanford.
18 Maine Yankee was the same way. The reactor 19 vessel which is probably the largest component was barged 20 to Barnwell, South Carolina and then up the Savannah 21 River and then carried over land for a distance to get 22 it to the Barnwell disposal facility.
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85 1 on rail or across the road, their plan is to segment the 2 reactor vessel into small pieces and then ship it in 3 radioactive, you know, approved radioactive transport 4 packages then.
5 So, it's all in the approach in what the 6 infrastructure will support on how you do the 7 decommissioning. Those are things that you have to take 8 into consideration when you put your plan together.
9 And so, again, what I was saying before in 10 this Phase 1 of the decommissioning, they have a number 11 of significant items to evaluate so they can put their 12 plan together and make it effective so they can safely 13 complete the decommissioning and dispose of the 14 materials.
15 MR. CAMERON: Okay. Thank you very much.
16 We're going to go to you. We know there's people out 17 here. We need to get to Three and Four and we have some 18 good written questions, but why don't you go ahead and 19 then we'll see where we are.
20 MS. MAGDA: Hi. I'm Marni Magda from Laguna 21 Beach. I've been attending all the meetings with Elmo 22 Collins and on into the time we are now.
23 I'm very concerned that this latest report 24 on the steam generators lets us know that a little hand 25 slap on something that was known to be dangerous - the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 record that southern California Edison has, has shown us 2 over and over again that they worry about profit, not 3 safety. Though, they will always tell us it's safety.
4 I am begging all of you from my heart to help 5 us in southern California. Of the 104 reactors, 6 southern California has a danger that we are more aware 7 of with rising tides, global warming, tsunami.
8 The report just came out about Alaska that 9 would come across our coast. The seawall is not enough.
10 Even if we had it all in dry cask storage 50 feet 11 underground, then it's in saltwater.
12 We must have your help getting final 13 geological disposal dry cask storage that starts today 14 in the kind of dry cask - and I'm going to ask you how 15 we get these, because I've been told you haven't licensed 16 anything transportable.
17 The US Navy is right now having to get its 18 nuclear waste out of Idaho by 2035 that I used to say was 19 forever from now, because tomorrow southern California 20 could die.
21 How do we get casks like the Navy is using 22 and put our money where it needs to go even if it's more 23 expensive.
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87 1 transportable casks that they will be moving out of 2 Idaho.
3 Can we use those? How do we get them? We 4 must start moving that - those spent fuel ponds are an 5 absolute accident waiting to happen tomorrow. We can't 6 be waiting. Please help us.
7 I hear that it's up to southern California 8 Edison -
9 (Discussion off the record.)
10 MS. MAGDA: Okay, but the PSDAR says that 11 this is all up to Edison. That you don't even approve 12 what they plan.
13 Who do we get involved? How do we get 14 involved to make this change and not let them take 60 15 years?
16 MR. CAMERON: Okay.
17 (Applause.)
18 MR. CAMERON: Can we address the 19 transportation issue?
20 MR. SPITZBERG: Yes.
21 MR. CAMERON: Go ahead.
22 MR. SPITZBERG: Let me take that little piece 23 of the comment. I think I've heard tonight and earlier 24 today some information about whether or not the casks 25 that are used in the dry storage facility at SONGS are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 transportable.
2 What I can tell you is that there are 3 currently two models of casks that are in use. They are 4 the 24PT1 and the 24PT4. Both of those have been 5 approved for transport.
6 the 24PT1 canister has been certified for 7 transport under Certificate of Compliance 9255. You can 8 access that on our website. That's the NP 187 Transport 9 Cask.
10 The 24PT4 canister is also certified for 11 transport. And that's under Certificate of Compliance 12 9302. And that's the MP 197 Transportation Cask.
13 The transportation cask for the 32PTH2 14 canister has not yet been approved, but application has 15 been made. They're not authorized yet to load canisters 16 into that canister as yet, but the application has been 17 made by San Onofre. So, that's the status of the 18 transportation.
19 MR. CAMERON: Okay. And let's go to the 20 final part of the question.
21 MR. CAMPER: Well, there was a couple 22 questions embodied within your remarks. Let me try to 23 address the ones that I heard.
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89 1 don't approve it, but we do review it and we do ask 2 questions.
3 We look for completeness. We look for 4 adequacy. If all of the criteria in our regulations are 5 not addressed - and one of Bruce's slides identified the 6 things that has to be contained within the PSDAR - we will 7 ask questions.
8 And the reason that we don't approve it, but 9 we approve the License Termination Plan, is because the 10 activities carried out in decommissioning have been 11 evaluated within the Environmental Impact Statement and 12 the considerations for licensing and operating a 13 reactor.
14 And the kinds of activities that go on 15 during decommission are considered to be less severe, 16 less risk than the operating reactor conditions, which 17 is the basis for not approving the PSDAR, but I don't want 18 you to go away with the impression that we don't hold the 19 applicant to satisfy all of the criteria that was 20 identified in the slide about the contents of the PSDAR.
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90 1 in terms of radiation decay and in ten years to dismantle, 2 is because at 50 years the dose to workers is reduced to 3 on the order of one percent of what it would have been 4 had the reactor gone into immediate dismantlement and 5 decommissioning.
6 And the volume of waste that has to be moved 7 out of the community and transported to a waste disposal 8 facility is reduced on the order of ten percent.
9 And what drives that principally is one 10 particular isotope called Cobalt-60 which is a very 11 energetic gamma matter that has a half life of 5.2 12 years-5.7 years.
13 So, in that period of 50 years, it's gone 14 through ten halve lives, which means that radiation 15 contribution has gone away through decay. So, that's 16 the basis for those 60 years.
17 I know that it seems like a long time, but 18 that's the basis.
19 MR. CAMERON: Okay. We have to get you on 20 - here's the deal. Here's the deal is that we can go into 21 depth on any one of these questions.
22 What we're trying to do in the time we have 23 available is to hear as many questions on different 24 topics as we can. I mean, that's just practically what 25 we have to do here, okay? So, we can't just keep NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 following up on it.
2 MR. CAMPER: There is one question of hers 3 I didn't answer, though.
4 MR. CAMERON: Go ahead.
5 MR. CAMPER: There was another part of your 6 question that needs an answer. You really in the 7 beginning of your comments expressed concerns about the 8 availability or the lack of availability of a high-level 9 repository for where the spent nuclear fuel should go.
10 That is a significant, national issue that 11 continues to play out. The Nuclear Regulatory 12 Commission is charged with certain responsibilities 13 under the Nuclear Waste Policy Act to license the 14 high-level waste repository, but the Department of 15 Energy is charged with developing and seeking 16 authorization for that high-level repository.
17 That matter is ongoing. It has political 18 sensitivities associated with it. It has court -
19 ongoing court proceedings associated with it. There was 20 recently a position issued by one of the courts and the 21 Commission is currently - is evaluating that recent court 22 decree by communicating and asking for comments from the 23 parties that were subject to the hearing about the best 24 way to proceed, but the Nuclear Regulatory Commission 25 will proceed to look at this, you know, come out in a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 situation once it starts - it completes gathering its 2 comments that it's undergoing right now.
3 So, it's a very complicated national 4 problem.
5 MR. CAMERON: Do you have something?
6 CHRIS (phonetic): Hi, I'm Chris. I live in 7 San Clemente and I think we're all here because we want 8 just the transparency and to know that this will be safely 9 handled and we're putting our lives in your hands.
10 Almost eight and a half million of us.
11 You did a slide in which you compared how 12 do we get safely from, for example, Connecticut Yankee 13 and San Onofre and so forth and do you - it's a two-part 14 question - do you consider Connecticut Yankee safely in 15 a safe spot? Question 1.
16 MR. WATSON: Yes, absolutely.
17 CHRIS: Okay. And then -
18 MR. WATSON: We've met all our license 19 criteria for license termination. The site was - I guess 20 we want to call it a greenfield in many respects. They 21 did leave some subterranean, I'll call it, foundations 22 which were radiologically clean. And so, the actual 23 decommissioning was completed safely.
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93 1 remove a significant amount of soil, because they did 2 have some underground tankage and piping leakage. Most 3 of that contaminated soil was removed.
4 And so, yes, it did meet our criteria and 5 it will meet our criteria through the future.
6 CHRIS: So, the second part of my question 7 is in a report in my research in 1994, Connecticut Yankee 8 did leak Tritium which is a highly radioactive material.
9 And I guess you are saying that you were able 10 to successfully decon that because there were 11 deteriorating underwater pipes.
12 So, my question and how that correlates on 13 the slide that you put together is, how do we know that 14 San Onofre, the underground pipes are not deteriorating 15 and leaking in the same fashion?
16 MR. WATSON: At Connecticut Yankee they did 17 what they called the big dig, which was remove all the 18 - I'll say most of the contaminated soils. Some of it 19 went to the bedrock which they continue to monitor.
20 At San Onofre they have a groundwater 21 monitoring program. They also investigate any 22 contamination events so that they see that the soil or 23 whatever if they did have some kind of leak would be 24 monitored and assessed.
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94 1 report they do do annual environmental monitoring. They 2 do groundwater sampling and other sampling along the site 3 to make sure that these type of events aren't occurring.
4 MR. CAMERON: Okay, thank you. Could we 5 have the coalition questions Three and Four? And I'm 6 going to read them.
7 Will the NRC allow the resale of 8 non-radioactive equipment and secondary side 9 components, turbines, MSRs, heat exchangers? And you 10 can see all that up there. So, will the NRC allow the 11 resale of this?
12 And since some of these are almost new, will 13 they be sold and where will the proceeds go? Is that 14 something that's within our scope?
15 MR. WATSON: As the NRC, we regulate the safe 16 use of radioactive materials. Any of these materials 17 that are not contaminated or have any radioactive 18 material associated with them, the utility or the 19 licensee is free to do whatever they want to with the 20 surplus equipment, scrap steel, whatever it is that they 21 produce as part of the decommissioning.
22 And so, the proceeds from that would be more 23 subject to the California regulators and not the NRC.
24 MR. CAMERON: Okay.
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95 1 regulate radioactive materials.
2 MR. CAMERON: All right. And let's go to the 3 California regulator. This is Cynthia Walker.
4 MS. WALKER: So, any proceeds that come from 5 the sale of any of the components of the reactor would 6 actually offset the cost of decommissioning. So, that 7 would be part of what we would be looking at in the 8 decommissioning proceeding.
9 There's also - I just want to mention 10 there's also an investigation that's going on separately 11 that I know many of you who are active are aware of and 12 involved and maybe even have party status.
13 So, there's going to be some overlap, but 14 all of these things are going to be happening and being 15 coordinated together. But, yes, any revenues that are 16 received would then be offset for the decommissioning 17 costs.
18 MR. CAMERON: All right. Thank you very 19 much, Cynthia. The fourth question, could we have that?
20 Oh, there it is.
21 We would like to know if there can be public 22 announcements when any, quote, allowable, unquote, toxic 23 waste is to be re-released into the environment.
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96 1 upper limits are for releasing radiation and toxic 2 chemicals into the environment during the 3 decommissioning process, when were those limits 4 established and what would trigger a process to 5 reevaluate them.
6 So, there is a lot there, but I think that 7 could be pretty simply answered, I hope, Bruce.
8 MR. WATSON: Yes. The regulations for 9 monitoring and the release of radioactive materials from 10 the site, the radioactive effluence, were instituted 11 decades ago in 10 CFR 20.
12 In decommissioning, the regulation still 13 applies if the plant was operating. And so, from that 14 standpoint the radioactive effluence from the plants are 15 continuously monitored and measured. Blair's people 16 will inspect to that to make sure that that is being done.
17 And the utility typically will issue an environmental 18 report reporting the effluence they've had from the 19 plant.
20 Now, the NRC regulates the radiological 21 part of that. Other state or Federal agencies take care 22 of other materials that may be released from the site and 23 they typically have permits for that.
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97 1 not regulate.
2 MR. CAMERON: Okay, thank you. Thank you 3 very much, Bruce. I think we need to give people on this 4 side of the room a chance.
5 And, Bob, at some point can you read the one 6 question we got about climate change and how that is taken 7 into account? Why don't we go to the woman you're 8 standing next to.
9 PARTICIPANT: Thank you. My question is 10 about NRC oversight during the decommissioning process 11 as two parts.
12 When SONGS was operating, there was an NRC 13 employee who worked on site everyday. Does the NRC use 14 the same approach during decommissioning? And if so, 15 how do onsite staffing and the role of those onsite staff 16 evolve during the various phases of decommissioning?
17 MR. CAMERON: Good. Blair Spitzberg.
18 MR. SPITZBERG: The question relates to 19 basically we have had during the operation of the San 20 Onofre unit, we've had resident inspectors that are based 21 at the site. They work at the site everyday. They have 22 an office there and they are inspecting day in and day 23 out throughout the year.
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98 1 least a year, maybe longer. And that person is going to 2 be certified to do decommissioning inspections as well.
3 So, he will be utilized in that capacity.
4 He's already qualified and trained and very 5 seasoned inspector. And we value his input to the 6 inspection process there.
7 Beyond a year I can't speak to whether or 8 not he will remain there or not. It's usually a 9 case-by-case basis and depends on the level of activities 10 at sites and whether we can justify the level of 11 inspection at the site at that time.
12 We also plan to utilize this inspector at 13 some of our other decommissioning inspections in the 14 state of California and elsewhere as well. So, yes, we 15 will have a full-time senior inspector there at site for 16 at least a year.
17 MR. CAMERON: Okay. And, Bob, let's go to 18 your people over there. I think we have four people over 19 here that we'll get to, but let's take care of people on 20 your side of the street.
21 MS. PADD: Yes, my name is Marsha Padd. I'm 22 part of the Group to Decommission San Onofre. And I 23 share the concerns of the previous questioners, but I do 24 have a somewhat different concern.
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99 1 hopefully have in place and will implement with regard 2 to potential security risks in the future that could 3 endanger the integrity of the plant and the safety of the 4 surrounding communities.
5 Regarding the decommissioning process, 6 what kind of safeguards have you planned for the 7 transportation of nuclear waste?
8 This would also include transportation of 9 radioactive material to a permanent depository. And in 10 addition especially with regard to the proliferation of 11 drones and the private sector, private ownership, it's 12 become a hobby nowadays, what safeguards have you 13 implemented and thought about in this area? Thank you.
14 MR. CAMERON: Okay. The concern generally 15 was about security and safeguards, but the questions went 16 to transportation safeguards. And could you just repeat 17 the last part of that so everybody can hear it?
18 Did you say "drones"?
19 MS. PADD: Yes.
20 MR. CAMERON: Okay. All right.
21 MS. PADD: That's a serious problem.
22 MR. CAMERON: Okay. Thank you. And I don't 23 - if anybody knows anything about the drone issue, 24 address that, but can we talk about the security in 25 transportation issue for her?
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100 1 MR. SPITZBERG: The site will remain under 2 the Physical Security Plan that it has been under during 3 operations. And that will continue into the future.
4 They have a very substantial security force on site and 5 substantial number of security systems.
6 Obviously I can't go into specifics about 7 that, because that's information that we restrict access 8 to. But, nonetheless, it has the security that's 9 equivalent to any of the nuclear sites throughout the 10 country and it will remain that way.
11 What was the second question? The drones.
12 I cannot specifically answer the question to the drones.
13 I don't know whether there's been a risk assessment 14 associated with that or not.
15 MR. CAMERON: Okay. If anybody - go ahead, 16 Larry.
17 MR. CAMPER: I was going to address the waste 18 issue.
19 MR. CAMERON: Okay.
20 MR. CAMPER: With regards to the waste 21 question as you know from earlier discussion this 22 evening, the spent nuclear fuel will remain on site for 23 some period of time either in the pool or in dry cask 24 storage. And so, there's probably nothing more that I 25 can say about that than we've already talked about. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 1 think we all understand the reasons for that.
2 With regards to the waste, you expressed a 3 question or concern about the waste, when the reactors 4 decommissioned, the majority - we have a waste 5 classification system in our regulations where waste is 6 classified as Class A, Class B, Class C or greater than 7 Class C.
8 When nuclear power plants are 9 decommissioned, by and large the majority of the waste 10 that comes out of decommissioning is Class A waste, which 11 is at the very low end of our risk scale for waste.
12 There is some Class B and some Class C waste.
13 A very small amount of greater than Class C waste which 14 will remain on site in a canister in the independent spent 15 fuel storage installation, but the waste will then be 16 taken in approved canisters for shipping waste and in 17 accordance with Department of Transportation 18 regulations, and will ultimately be disposed of at a 19 commercial disposal facility.
20 It is conceivable, for example, that the 21 waste, especially the Class A waste, which is the 22 majority of waste that comes out of decommissioning, 23 could find its way to the energy solution site in Clive, 24 Utah. It is also possible that it may make its way to 25 the site in Andrews, Texas.
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102 1 There is also a site in the northwestern 2 United States that's a possibility, but what's important 3 is that the majority of the waste, Class A, it's the 4 low-risk end of waste, transported in approved shipping 5 containers for that type of waste following Department 6 of Transportation regulations and will ultimately be 7 disposed of in a commercially operated disposal 8 facility, which there are four in the United States 9 today.
10 MR. CAMERON: Okay, thank you. And could 11 one of the staff members from the NRC after the meeting, 12 talk in more depth with the woman who asked the question 13 about the drones so that we can try to find more about 14 that.
15 You want to talk to that, Bruce? Go ahead.
16 MR. WATSON: Just briefly discuss this.
17 MR. CAMERON: Okay.
18 MR. WATSON: It's not really my area of 19 expertise, but I think everyone can recall that the 20 assessment for an aircraft hitting a nuclear power plant 21 has been pretty well established and studied and the 22 design in the plant. And that was revisited after the 23 9/11 terrorist attacks.
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103 1 building has been analyzed and it would be well within 2 that safety envelope.
3 MR. CAMERON: Okay, great. Thank you for 4 that. And we're trying to get as many different areas 5 out as possible. And we did security. We had the state 6 regulators talk. We talked about high burnup fuel.
7 We do have a question on another pressing 8 concern and this is climate change, I believe. This was 9 a written question given to us.
10 Bob, would you read that question?
11 MR. HAGER: Chip, yeah. This is one of the 12 written questions and it is, has the effects of climate 13 change been considered? Recent science suggests the 14 rises in sea level from ocean temperature increases and 15 contributions from snow melt. In addition, extreme 16 precipitation events will likely become more common.
17 For example, the hundred-year storm may occur every 50 18 or 75 years.
19 So, how are climate change - how are these 20 climate change variables accounted for during long-term 21 decommissioning?
22 MR. CAMERON: Okay, good question. How does 23 that happen? Larry.
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104 1 use the term - Generic Environmental Impact Statement is 2 an NRC vernacular. It's the same thing as a Programmatic 3 Environmental Impact Statement which is a term that's 4 used elsewhere when NEPA, the National Environmental 5 Policy Act, evaluations take place.
6 And sometimes - one of the comments earlier 7 was about a concern about something being generic.
8 That's a criticism we've heard before, but it's just a 9 vernacular that we use for a Programmatic Environmental 10 Impact Statement.
11 But there is a Generic Environmental Impact 12 Statement or Programmatic Environmental Impact 13 Statement that has been prepared by the Agency dealing 14 with decommissioning of nuclear power plants.
15 Also, in the PSDAR the applicant, the 16 licensee, has to provide any update in terms of any 17 environmental consequences that were not considered at 18 the time the site was constructed and the environmental 19 impact statement for that or the Generic Environmental 20 Impact Statement associated with decommissioning of 21 nuclear power plants.
22 One of the things that not only our agency, 23 but all federal agencies as a result of recent Council 24 of Environmental Quality directions is to look at climate 25 change.
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105 1 And so, the primary impact of 2 decommissioning with regards to climate change is 3 equipment, caterpillars and things of that type that 4 actually move material around while the decommissioning 5 is going on and those emissions and so forth.
6 But any contribution to the climate change 7 via greenhouse gases has been and is evaluated as part 8 of the environmental assessment that we conduct.
9 MR. CAMERON: Okay. Thank you and we have 10 Ray Lutz.
11 MR. LUTZ: Yes, thank you. My name is Ray 12 Lutz with Citizens Oversight and the Coalition to 13 Decommission San Onofre. I am involved with the 14 California Public Utilities Commission investigation 15 that's going on.
16 One of the things that has come up, and this 17 is actually with regard to the decommissioning triennial 18 cost review, has to do with the fact that they say that 19 they haven't had any decommissioning costs approved by 20 the NRC and this is the reason they don't know how much 21 it's going to cost even for Unit 1.
22 So, I'm wondering if the PSDAR has been 23 submitted and approved - or you say you don't approve it, 24 which is a catastrophe, in my view. You guys should 25 review the PSDAR and stamp it "Approved" or "Not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 Approved" and put your butt on the line, because we're 2 putting our butt on the line out here.
3 And for you to say we don't approve it is 4 something that takes my breath away. You either approve 5 it, or not approve it, and don't give me this stuff about 6 asking questions.
7 So, Question 1 is, have you received the 8 PSDAR and approved it for Unit 1? Don't go on. I've got 9 a few more questions here.
10 And the License Termination Plan. Now, 11 maybe there's a terminology problem here. Maybe you're 12 saying that they haven't submitted the License 13 Termination Plan yet.
14 Well, when are we going to know how much it's 15 going to cost? Because Unit 1 has been sitting there for 16 many years now and they say in our meeting that they still 17 don't know how much it's going to cost to decommission 18 that as if they haven't started it.
19 I'm wondering also you say these casks can 20 be transported. It seems to me they need to be 21 transported right away.
22 Now, is there an interim location where we 23 can put these casks away from these population centers 24 and in a non-seismic and non-coastal area? So, that's 25 really kind of like my second question there.
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107 1 So, if you can answer those, I'd appreciate 2 it.
3 MR. CAMERON: Okay. And thank you, Ray.
4 And the staff can quickly reiterate the scheduling things 5 about the PSDAR and all that, but I think Ray's question 6 about the process for the NRC review, Larry, you talked 7 to this a little bit.
8 Can you talk about why there is a review and 9 not an approval, but first can we talk about has there 10 been a submission of the PSDAR or License Termination 11 Plan? Can we just clear that - emphasize that for 12 people?
13 MR. WATSON: For Unit 1.
14 MR. CAMERON: For Unit 1, okay. Unit 1.
15 MR. WATSON: For Unit 1, there was a PSDAR.
16 (Speaking off mic.)
17 MR. WATSON: I don't know that off the top 18 of my head.
19 MR. CAMERON: We'll get you that offline.
20 Go ahead.
21 MR. WATSON: But let me -
22 (Speaking off mic.)
23 MR. CAMERON: Wait one second. One second.
24 Let's let Bruce finish.
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108 1 that we are not required to approve the PSDAR was a 2 Commission decision. It was decided by the five NRC 3 commissioners.
4 MR. CAMERON: Not the present -
5 MR. WATSON: No, not the present Commission, 6 but it was a Commission decision.
7 MR. CAMERON: Okay.
8 MR. WATSON: And the basis for that was that 9 within the realm of decommissioning activities, the 10 licensee could conduct those activities safely within 11 the existing license. And so, that was their basis for 12 that decision.
13 The Commission voted and approved the fact 14 that we would not have to approve a PSDAR, because they 15 could conduct the decommissioning activities safely 16 within the existing license which they already 17 possessed.
18 In other words, they are allowed to do 19 maintenance. They are allowed to do shipment of 20 radioactive materials all during operations. And we 21 expect - and the Commission decided that they could 22 continue with those types of activities which are part 23 of the decommissioning without us approving a PSDAR.
24 Okay?
25 MR. CAMERON: Okay.
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109 1 MR. WATSON: It may sound funny, but it was 2 a policy decision by the Commission.
3 MR. CAMPER: Well, let me add to that. Let 4 me just add to that.
5 MR. CAMERON: Go ahead, Larry.
6 MR. CAMPER: At the time the Commission made 7 the decision, at the time the Commission made the 8 decision in 1996-1997 time frame that exists today for 9 the decommissioning of reactors, there was a recognition 10 of what Bruce just said. There was also recognition that 11 the expertise that resided within an operating reactor 12 facility was such that it could accommodate 13 decommissioning.
14 The activities of decommissioning were 15 considered to be less severe from a risk standpoint as 16 compared to, if you will, a material site.
17 When a material site, let's say, for 18 example, a facility existed where certain metals like 19 vanadium were processed, but there was uranium and 20 thorium as a consequence, those types of facilities - we 21 call them materials facilities - can't proceed to do 22 decommissioning at all until such time that it's 23 approved.
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110 1 don't have the operating experience that nuclear power 2 plants have.
3 So, that was part of the logic that led the 4 Commission to believe that given the point that Bruce 5 made that if they could operate a nuclear power plant and 6 they could ship waste and do those types of things, they 7 could begin the process of identifying how they wanted 8 to decommission that facility. And, therefore, we 9 review, but don't approve the PSDAR.
10 But what's, I think, the most critical 11 component in the decommissioning process is the License 12 Termination Plan, because it is in the License 13 Termination Plan that we do review and approve and which 14 they identify, for example, the final status survey, the 15 concentration of radioactive materials that will remain 16 in the soil that will identify and ensure that they meet 17 the dose standard that I cited during my presentation.
18 So, that is the critical part in terms of 19 what that site is going to ultimately look like in terms 20 of satisfying the dose criteria. And we do review and 21 approve that.
22 MR. CAMERON: Okay. Let's hear what you 23 have to say. And the last part of Ray's question has been 24 a concern that we've heard from others in the audience.
25 In other words, the movement of fuel from the site.
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111 1 Can we talk a little bit about that before 2 we go on? I have four people over here I want to get to, 3 but go ahead.
4 MR. EVANS: I just wanted to clarify a Unit 5 1 PSDAR was submitted in 1998. And a couple of weeks ago 6 I dug up a hard copy of it and put it into our ADAMS system.
7 So, if you go into the Unit 1 docket file, 8 it should be there, but keep in mind that the Unit 1 PSDAR 9 is kind of like a high-level document. It doesn't 10 provide a tremendous amount of detail. It's just sort 11 of like a management level, this is how we're going to 12 do Unit 1 decommissioning.
13 I was aware that a draft License Termination 14 Plan was developed, but I don't think it was ever 15 submitted to the NRC. I will double-check that, but I 16 don't think the LTP was ever submitted. Drafted, and 17 then that's as far as it got.
18 MR. CAMERON: Okay. Thank you very much.
19 Good information. Can we go to the last issue that Ray 20 raised and it was raised over here?
21 MR. CAMPER: Yeah, the essence of your 22 concern, if I understood correctly, was the idea of 23 moving the spent nuclear fuel away from the coast, away 24 from this site and putting it in some interim storage 25 facility.
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112 1 In every nuclear power plant that's been 2 decommissioned thus far, there is spent nuclear fuel 3 there in an independent spent fuel storage installation.
4 That's because in the United States today, we as a nation 5 have not solved the issue of the final geological 6 repository for the disposal of spent nuclear fuel.
7 And so, what has happened is the industry 8 has reacted to that by developing the cask storage 9 systems that we've been discussing tonight. That was 10 done out of necessity, because the kinds of actions that 11 were envisioned in the Nuclear Waste Policy Act of 1982 12 and amended a few years later have, in fact, not 13 transpired.
14 With regards to interim storage, there is 15 no interim storage facility in the United States today.
16 Recently the President's Blue Ribbon 17 Commission on America's Nuclear Future undertook an 18 in-depth analysis. And one of the key findings that was 19 contained within that report was that the country should 20 proceed to develop one or more interim storage facilities 21 until such time as the high-level repository issue could 22 be addressed.
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113 1 those recommendations were to be successfully carried 2 out.
3 There was several years ago a company called 4 Private Fuel Storage that applied for and did receive a 5 license to operate an interim storage facility in Utah.
6 They underwent an in-depth evaluation by the Nuclear 7 Regulatory Commission, a Safety Evaluation Report was 8 issued, a license was issued, and in-depth Environmental 9 Impact Statement was prepared.
10 However, in the final analysis, that 11 facility for a number of different reasons could not 12 receive authority from the Federal government for the 13 railroad line to be built to that facility. And 14 ultimately that facility did not open for that purpose.
15 And not too long ago, in fact, PFS, Private 16 Fuel Storage, decided they would not proceed with that 17 license activity at all. So, we do not have in the United 18 States today an interim storage facility.
19 Some communities have started to express 20 interest in hosting an interim storage facility. One of 21 the fundamental principles that the Blue Ribbon 22 Commission thought was important was that there should 23 be a buy-in, a stakeholder interest, a community interest 24 in hosting an interim storage facility. Or for that 25 matter, a high-level waste repository.
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114 1 There is a county in New Mexico that has, 2 in fact, written a letter to us indicating that they have 3 a strong interest in submitting an application for an 4 interim storage facility.
5 There's some movement in Mississippi around 6 the possibility of hosting an interim storage facility.
7 And there's some interest in South Carolina as well at 8 the Savannah River site.
9 So, we'll have to wait and see what happens 10 with regards to an interim storage facility becoming a 11 reality for this fuel to be removed not only from the 12 SONGS facility, but from other facilities that have 13 undergone decommissioning and currently have spent 14 nuclear fuel in dry cask storage or, for that matter, what 15 the United States is going to ultimately do about, in 16 fact, developing a high-level repository.
17 I wish I could paint a prettier picture than 18 that, but that is reality.
19 MR. CAMERON: Okay, thank you. We're going 20 to go here, then the gentleman in the green hat, to white 21 shirts, and then the gentleman back there.
22 Dave.
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115 1 intermediate step, which would be the expedited removal 2 of spent fuel from the pools with an inherent 3 vulnerability at least to the dry cask storage even as 4 it should exist at the site on an expedited matter.
5 Now, I know this is a subject for national 6 discussion, Tier 3 Post-Fukushima Recommendation on 7 Expedited Transfer of Spent Fuel, and that's being 8 discussed at a national level, but we have state 9 regulators here today.
10 Mr. Oglesby's agency, the California Energy 11 Commission, has been recommending every year since 2008 12 that the utilities undertake the expedited removal of 13 spent fuel from the pools and place them in dry casks in 14 that matter.
15 The Public Utilities Commission would hold 16 the purse strings on the decommissioning funding being 17 used for that purpose.
18 In fact, I raise that question because in 19 a request for additional information that came out on 20 this, the question the NRC asked was, please specify if 21 any of the accumulated fund balances for 22 non-radiological decommissioning costs such as spent 23 fuel management or other non-radiological 24 decommissioning activities.
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116 1 I hope they're not attempting to imply, and you alluded 2 to this earlier, that money can be moved around within 3 categories for parts of the decommissioning.
4 Should our state recommend it and wish them 5 to do it? And should our state's public utilities 6 commission say we think that's a fine use of the money.
7 Any intent by the NRC to put any brakes on the state of 8 California proceeding with that irrespective of your 9 national Tier 3 spent fuel movement issues?
10 MR. CAMERON: Thank you.
11 MR. DUSANIWSKYJ: I believe that the 12 document you have in your hand was a result of the 13 Biannual Decommissioning Funding Report that was 14 submitted by all the licensees back on March 31st of this 15 year.
16 What we were asking was specifically to 17 determine that the amount that was stated in that report, 18 and I have a copy of it here with me, was, in fact, the 19 amount of money that they have stated is dedicated to the 20 NRC's requirements for decommissioning.
21 So, we were asking that question to verify 22 that, in fact, that the statements in the March 31st 23 submittal were, in fact, what was supposed to have been 24 stated.
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117 1 to whether or not money can be shifted around in whatever 2 manner you want to call it, there is a certain sequence 3 of events that will probably have to take place in any 4 decommissioning activity.
5 First and foremost being that the licensee 6 shall have to decontaminate that facility before you 7 start to even begin to think about greenfielding.
8 And the basic answer to that question is 9 that once the decommissioning to the NRC standards has 10 been completed, the NRC has no jurisdiction over that 11 money and the licensee is free to use that money for 12 whatever additional decommissioning can be anticipated 13 with the funds that have been indicated to us in the March 14 31st submittal.
15 MR. CAMERON: Okay, thank you. Yes, sir.
16 Please, David, we're going to have to go on.
17 MR. GARDNER: Hi, I'm Richard Gardner. Just 18 some maybe answers or some questions I have. One would 19 be out of all the nuclear facilities in the United States, 20 how many pounds or cubic yards or the volume of waste?
21 And then I know it's following an exponential decay, you 22 know, curve so that in time it will be less and less. So, 23 and then on the other hand I'm thinking about the NRC and 24 your staffing level.
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118 1 of nuclear plants will be decommissioned and you'll have 2 the most amount of fuel to deal with? You'll need 3 inspectors.
4 Now, out of the 96 I think that are 5 operating, you know, there will be some day ten years out, 6 15, where you're going to have 25 decommissioning 7 facilities and it will be, you know, hopefully there will 8 be some more really choreographed, orchestrated, you 9 know, national approach to doing this so that it isn't 10 purely in the hands of utility companies with separate 11 branches of new people that are working. You know what 12 I'm saying?
13 Even though I have great confidence in the 14 NRC, I'm thinking this somehow could be standardized.
15 Maybe you already have a standard review plan for 16 decommissioning in place.
17 MR. CAMERON: Thanks, David. Larry.
18 MR. CAMPER: A lot of interesting things in 19 your comments. Thank you. NEI, the Nuclear Energy 20 Institute, there's a graphic that comes to mind that I've 21 seen several times, but they did put it together just a 22 few years ago. I want to say like three or four years 23 ago.
24 But it showed at that time the next bow wave 25 of decommissioning, if you would, when the Class A and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 some Class B and Class C waste would be created because 2 of reactor decommissioning, was in the 2035 to 2045 3 period.
4 Now, that peak has changed slightly in the 5 last few years because there has been renewals of power 6 plants that wasn't anticipated at that time. So - but 7 I still think it's fair to say that the next bow wave of 8 decommissioning is in the 2035 to 2055 period and the fact 9 of the matter is that at some point they're all going to 10 have to come down. They're all going to decommissioning 11 at some point. That's in some ways, that's a long time 12 from now. And in some ways, it's tomorrow.
13 What we're trying to do about tomorrow, if 14 you will, is memorialize and capture all the information 15 that we can about the decommissioning we've already done, 16 the 11 nuclear power plants that I showed in my slide, 17 you know. Now, we've had five units go into sudden 18 announced decommissioning in the last year. There may 19 be others.
20 So, what we're trying to do is, is capture 21 as much information as we can for those who will follow 22 us doing the decommissioning in that 2035 to 2050 time 23 frame.
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120 1 have put together to facilitate decommissioning in the 2 future. We continue to take lessons learned and put out 3 information and/or modify our guidance.
4 I can tell you that the staff right now is 5 already starting to look at in view of the fact that five 6 units are going to decommissioning recently, maybe 7 others, the staff is already starting to look at what we 8 think is a very successful decommissioning program as 9 witnessed by the number of facilities available for 10 decommissioning, but we're also starting to already look 11 at are there any changes we need to make to the program, 12 are there lessons learned from what we've done and make 13 some adjustments.
14 And we do plan to communicate with our 15 commission about it, because the Commission has a lot of 16 interest in it as well.
17 MR. CAMERON: Thank you very much. Yes, 18 sir.
19 MR. CHRISTMAN: Good evening. Thank you for 20 your patience and perseverance. My name is Patrick 21 Christman. I'm the assistant chief of staff for Marine 22 Corps Installations West Camp Pendleton.
23 I'd like to ask a question. Camp Pendleton 24 has one of the largest environmental staffs in the whole 25 Marine Corps and one of the largest budgets.
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121 1 Obviously that's because of the unique 2 challenges of dealing with the California regulatory 3 scheme. We've heard from the PUC and the CEC tonight.
4 Could you please talk a little bit about 5 your interaction through the NRC process with the other 6 state agencies such as the Coastal Commission or Cal/EPA 7 or any of those other folks that we have to deal with on 8 a regular basis? Thank you.
9 MR. CAMERON: Thank you. Larry, are you 10 going to -
11 MR. CAMPER: Well, whether it be California 12 or any other states where decommissioning takes place, 13 there are state laws and regulations that the operator 14 of the facility has to satisfy.
15 I mean, for example, a little bit earlier 16 we were talking about discharge permits, but that's a 17 state function or EPA or depending on how it's been 18 delegated to the state function.
19 We do interface with those state agencies 20 along the way. They are carrying out their regulatory 21 responsibility. We're carrying out our regulatory 22 responsibility. There's a lot of communication that 23 goes on, but let me say this and I'll give you an example.
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122 1 though they are subject to our regulations in 2 decommissioning, one of the things we always say to the 3 utilities is you need to make sure that you understand 4 what your state requirements are wherever they may be.
5 Because that's the last jurisdiction you're going to be 6 facing.
7 Even if you successfully decommission the 8 reactor under our regulations, some states even though 9 we have a federal standard in our regulations that I 10 shared with you earlier, some states have developed their 11 own decommissioning criteria for nuclear power plants.
12 Maine comes to mind. Connecticut comes to mind.
13 Connecticut developed a 19 millirem 14 standard as compared to our 25 millirem and ALARA 15 standard. So, the licensee has to deal with the state 16 agencies and recognize those requirements, but we do 17 communicate with the state agencies throughout the 18 process, but each of us are caring in our respective 19 regulatory regimes.
20 MR. CAMERON: Okay, thank you. Thank you.
21 We have this gentleman right here and then we're going 22 to go over to right here. Yes, sir.
23 MR. FAWCETT: My name is Ed Fawcett. I'm 24 president of the Costa Mesa Chamber of Commerce. I've 25 attended several of these public hearings pertaining to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 SONGS and wrote in support of Edison's safe restart of 2 Unit 2 reactor.
3 I say "wrote," because there never previous 4 to tonight, there was never a time for anybody on this 5 side to make a statement on behalf of the - voice an 6 opinion.
7 Yet again I'm spending quite a bit of time 8 watching without great humor, another spectacle that 9 leaves me both baffled and disheartened in our elected 10 and appointed leaders.
11 Whose hearing is this? The NRC has again 12 allowed a handful of anti-nuclear activists to have 13 center stage obviously on the agenda without being 14 written in the agenda just dominating the proceeding.
15 My question followed by a brief comment, why 16 hasn't the NRC provided the same air time to those who 17 support nuclear energy and have previously supported the 18 safe restart of SONGS?
19 While we're waiting for NRC to do its job 20 and make the decision, SCE was required to keep SONGS 21 operation-ready. The cost of about a million dollars a 22 day.
23 Due to mounting costs, SCE finally had to 24 make the good business decision to retire SONGS after 25 more than 500 million dollars in cost runup.
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124 1 As a business person and Chamber person, I 2 can easily understand SCE's need to make this decision 3 to stop the growing cost to taxpayers and to ratepayers.
4 Why can't the NRC make decisions in a 5 reasonable amount of time without hiding behind a lot of 6 public opinion, multiple hearings - and just multiple 7 hearings? Thank you.
8 MR. CAMERON: Thank you for that comment.
9 And I think that just your reading that statement 10 provided air time to others who feel a different way, but 11 part of the explanation, I have to repeat this again, is 12 that the questions that we got from the coalition of 13 citizen groups are questions that are on a lot of people's 14 minds or should be on a lot of people's minds. And that's 15 why we started with that.
16 We're going to go to this gentleman right 17 here. Yes, sir.
18 MR. NELSON: Hi. My name is Douglas Nelson.
19 I'm from up the coast with a company, my own company 20 called Levitical Network.
21 I wrote down as a follow-up to Dale's 22 eloquent question to what extent is the NRC interested 23 in either prolonging or quickly executing the 24 decommissioning of the San Onofre reactor, this meeting 25 only seems to be prolonging the process of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 decommissioning with each passing day and the failure to 2 shut down the second and third units.
3 As was mentioned by the councilman earlier, 4 the reactor remains open to natural catastrophic 5 occurrences.
6 Is it because of Cobalt-60 as was mentioned 7 earlier, or is it due to the use to use more money of your 8 annual billion dollar budget that we, the taxpayers, 9 generate?
10 In addition to that, it's ironic perhaps 11 that we generate through our taxes a billion dollars for 12 NRC for its billion dollar budget, but the tax - the taxes 13 that have been created are now diminishing for the 14 individuals who have been unemployed at the San Onofre.
15 And so, there appears to be, I think, a conflict, if you 16 will.
17 We're spending our tax dollars to have these 18 kind of meetings in large places where only two or three 19 people show up, and yet there are individuals whose tax 20 dollars are being used who are no longer employed by the 21 San Onofre reactor.
22 So, I would appreciate a response to that.
23 MR. CAMERON: And, Larry, there was a lot 24 there, but maybe one simple way to clarify something as 25 you might talk about how the NRC budget gets made up.
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126 1 MR. CAMPER: Yeah, I was going to -
2 MR. CAMERON: Okay, thank you.
3 MR. CAMPER: Thank you, Chip, and thank you 4 for the question. From our standpoint, we don't want to 5 prolong or necessary expedite the decommissioning.
6 What we have to do as a staff is carry out the regulatory 7 construct that has been created by our commission as to 8 how nuclear power plants will be decommissioned.
9 And as I explained earlier and other members 10 of the staff have pointed out, the basis for this 60 11 years.
12 Now, we understand that 60 years sounds like 13 a long time. We get that, but there is a technical basis 14 behind it and a risk basis behind it that led to and 15 supported the Commission decision that was made in the 16 1996-1997 time frame.
17 But with regards to the billion dollar 18 budget and the taxpayers and so forth, I understand that 19 concern, but it's also important to point out that the 20 Nuclear Regulatory Commission is a fee recovery agency.
21 The industry pays for 90 percent of the NRC 22 budget. And the things that we do through fee recovery 23 whether it be the annual fees that we charge or the fees 24 that we charge for review work is borne by the industry.
25 So, only 10 percent or so comes from the general treasury.
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127 1 And that is a change that congress imposed several years 2 ago now.
3 MR. CAMERON: Okay. We're going over to my 4 colleague. Go ahead.
5 MS. OREN: Hi. Thank you. My name is Mary 6 Oren. I am a Carlsbad resident. Lived in the area for 7 about 30 years. And I want to thank you so much for the 8 chance to share information here tonight. It's been a 9 really great experience.
10 And I'm so grateful for utility contact to 11 see, because my question is really for her. And also the 12 gentleman that is representing energy over there.
13 I think one thing we learned tonight, one 14 reason we're here is it's obvious that big energy 15 installations often bring big problems. And we've seen 16 that with San Onofre.
17 I think some of us are concerned about the 18 natural gas issue with fracking and how that can 19 contaminate water and cause earthquakes and then there's 20 the methane issue.
21 There are bigger installations for wind 22 which can interrupt bird migration. And the bigger 23 solar installations, I guess that's still to be defined 24 whether or not that's going to be dangerous or not.
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128 1 take one moment and look at the big picture. And the big 2 picture means we're all in this together; industry, 3 science, government and citizens. And I think as 4 citizens, it's time that some of us consider taking a 5 bigger part.
6 I'm a solar homeowner. And when I bought 7 my system, my installer said, okay, well, this is how many 8 you need to meet your power use. Don't go over that, 9 because then you won' recoup your cost.
10 So, I'm just one of many out there who hear 11 this everyday still. And it's very disappointing to me 12 because there's businesses and homeowners out there who 13 would be willing to invest in a couple more panels and 14 contribute to more power being available.
15 This is being done in other parts of the 16 world. It's called a feed-in tariff. Germany, France, 17 some places in our country do it where the citizenry is 18 providing clean energy.
19 And in Germany, they do it at the level of 20 50 percent residential solar projection. Here in San 21 Diego, America's finest city, sunshine almost everyday, 22 our percentage is three percent. That's crazy when 23 there's rooftops everywhere and people willing to be a 24 part of the solution.
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129 1 kinds of situations where we're all doing our best to 2 qualify, we care, we're all in this together, we are 3 ratepayers, we want more solutions. We want more 4 options.
5 A huge piece of the solution is not 6 happening. We need to make it easier for residents and 7 businesses to invest in solar.
8 So, my question is with our energy contact, 9 what energy is coming in and replace of the nuclear?
10 I've already heard that we don't really need that.
11 And then in terms of the utility, maybe you 12 could please tell me why residents and businesses are not 13 allowed to be a bigger part of this process.
14 MR. CAMERON: Okay.
15 (Applause.)
16 MS. OREN: Thank you so much.
17 MR. CAMERON: Thank you. We're going to go 18 to Rob Oglesby right here on that question.
19 MR. OGLESBY: Well, just really briefly to 20 a very large question related to what we're doing to work 21 around the nuclear power that we don't have any longer, 22 and there are many pieces to it, and about half of the 23 energy - oh, so let me say in terms of the math, 23,000, 24 22,000 and change megawatts from San Onofre gone.
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130 1 work around not having that, it's more than just 2 replacing the wattage from that generation facility.
3 We're looking at things that are called 4 voltage support and reactive power that are kind of like 5 in a water system pressure in the lines.
6 We look at where the generation resources 7 are and what transmission options we have that we can 8 optimize, what we can do to make the system run more 9 efficiently.
10 As we've developed our recommendations for 11 the strategy to go forward, which isn't final, but we've 12 been studying it for some time now and coming up with 13 various options and our website at the Energy Commission 14 you could see a paper and the plan that we put forward 15 as recommendations.
16 But about half of the energy need which also 17 accounts for growth and the phase out of once-through 18 cooling facilities, it's all related, come from what we 19 call preferred resources.
20 And preferred resources include 21 efficiency, which is one of the best alternatives we 22 have, demand response, distributed generation which 23 includes solar, as well as very efficient fast-ramping, 24 clean fossil traditional generation and enhancements to 25 the distribution system and transmission system.
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131 1 So, I would commend you to look at the 2 recommendations that have been developed by the Energy 3 Commission working with its sister agencies of the CPUC 4 and CAISO, the independent systems operator, and have put 5 forth some scenarios that we're analyzing and will be 6 developing to go not only for how we're going to get by 7 next summer, but going forward in the next several years.
8 In terms of the pricing mechanisms, that's 9 been a very active discussion in California legislature.
10 Feed-in tariffs met energy metering and I can tell you 11 that as one of the agencies that's responsible for 12 attaining 33 percent renewables and sustainable energy 13 in California, we're very enthusiastic about solar and 14 would like to see greater distribution and use of solar.
15 MR. CAMERON: Thank you very much, Rob.
16 We're going to go to two people here. One in the back 17 of the room. And then I'm going to ask Larry Camper to 18 close the meeting out for us.
19 Yes, ma'am.
20 PARTICIPANT: This is so vast and so 21 complicated an issue from the standpoint of the 22 billionaire's control of the - through the energies and 23 the military combined coalition that it's controlling 24 not only our nation, but our world.
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132 1 lives into trying to make some protection for our 2 children and grandchildren and possible future 3 generations here for 50 years, no, we know what we're up 4 against and you're just one of the tools of it all, but 5 I think that its time has come for those of you who really 6 understand what's happening to speak out and to do 7 something about it.
8 Because when you talk about two years - I 9 was told that you're giving - I say "you," but it's the 10 commissioners are giving two years to Edison to develop 11 its plan. And it already has dragged along and delayed 12 and delayed in starting the closing of everything from 13 the time the failure took place just trying to stay on 14 the payroll and we understand that.
15 I mean, we can understand that that's 16 important to those people, but it's not your role to help 17 them every step of the way.
18 All through the years the decision has never 19 been made for us. I shouldn't say "never." Never say 20 never, right? But the point is that now you're talking 21 about 60 years.
22 How can anybody comprehend leaving us in the 23 center of the target for the conditions that we have in 24 the world today for 60 years?
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133 1 working with a lot of organizations and I know that there 2 are millions of people in this country who understand 3 what - part of what is happening enough that they are 4 trying - they're desperately trying to get you to help 5 us, because we know that you are - your sole 6 responsibility is to protect the public, right?
7 So, we say to you, please stop protecting 8 the industry instead of protecting us.
9 MR. CAMERON: Thank you. Thank you very 10 much.
11 (Applause.)
12 MR. CAMERON: Please introduce yourself to 13 us, sir.
14 MR. STEINMETZ: Hi. My name is Jeff 15 Steinmetz. I'm a resident of San Clemente, California.
16 My question has to deal with the transportation of the 17 high burnup fuel.
18 You did mention a couple of casks that were 19 approved for transportation. But in your sentence and 20 in the sentences leading up to it, you didn't specify that 21 they were approved for the high burnup fuel of the nature 22 that is stored at San Onofre.
23 So, could you please be specific and can you 24 please provide the documentation? Because we've looked 25 for it and we can't find it.
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134 1 MR. CAMERON: Okay, thank you. Blair.
2 MR. SPITZBERG: Yeah, I thought I did provide 3 the documentation. It's Certificate of Compliance 4 9255, which is for the 24PT1 canister. That's the MP187 5 transport cask.
6 Did you want me to repeat that? I'm sorry.
7 (Speaking off mic.)
8 MR. SPITZBERG: And the second one was the 9 Certificate of Compliance 9302 for the MP197 transport 10 cask. These are available on our website. If you go to 11 our website, you can call these up.
12 MR. CAMERON: Okay. And let's talk further 13 if you need to after the meeting. We have one final 14 comment back there, Bob, and then we're going to go to 15 Larry Camper. Go ahead.
16 MR. HAGER: Yeah, but, Chip, before we go to 17 that, I've got several written questions that we haven't 18 had time to get to.
19 So, if you submitted a written question that 20 hasn't been answered, please stay afterwards and find an 21 NRC staffer who can answer it for you, because I don't 22 want anybody to get away from here and I'm sorry we 23 haven't got to you. So, stick around right after the 24 meeting and we'll get your question answered too.
25 MR. CAMERON: Okay. Pete.
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135 1 MR. DIETRICH: Yes, thank you. Pete 2 Dietrich with Southern California Edison. Larry, I do 3 have a question and I'm seeking to just ensure that I 4 understand, because I think it is an important 5 clarification.
6 The term "greenfield" has been used here 7 tonight repeatedly. It's not specifically in the 8 presentation materials, but I believe it was mentioned 9 by the staff. And it was also mentioned by Ms. Walker 10 from the California Public Utility Commission.
11 And I think it's important I think we're all 12 aligned that the decommissioning of San Onofre needs to 13 be conducted safely, cost effectively, efficiently and 14 we think that that involves doing it in a very more rapid 15 manner.
16 However, we have to conduct that 17 decommissioning using the decommissioning trust funds 18 that have been set aside to accomplish it.
19 If we're aligned on that point, I think it's 20 important to focus on beginning with the end in mind.
21 What does the end of decommissioning look 22 like? What are the criteria for agreeing that the site 23 has been appropriately decommissioned?
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136 1 radiological decommissioning standpoint from a Nuclear 2 Regulatory Commission requirement, we are required to 3 return the land to the ability to be used in an 4 unrestricted manner, which has a specific definition 5 from a radiological standpoint, also per our License 6 Termination Plan which you gentlemen have talked about 7 which has to be submitted and approved, but there is not 8 the term "greenfield" included in the Nuclear Regulatory 9 regulations related to the land restoration requirements 10 for radiological decommissioning; is that correct?
11 MR. CAMPER: That is correct. In fact, Mike 12 in his comments made that point very clear. We do not 13 have a requirement in our regulations that it be 14 greenfield.
15 I do not know what the requirements are in 16 the state of California in that regard.
17 MR. DIETRICH: Right. I appreciate that.
18 And I did have a chance to - go ahead, Larry. Sorry.
19 MR. CAMPER: You also said "restricted." It 20 can be - or "unrestricted." It can be as I pointed out 21 in my comments and Bruce did in his too, our regulations 22 allow unrestricted or restricted.
23 MR. DIETRICH: Right.
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137 1 provisions requiring institutional controls and so 2 forth, but no nuclear power plant -
3 MR. DIETRICH: Right.
4 MR. CAMPER: - thus far has opted for the 5 restricted release. In fact, they've cleaned up their 6 site on the order of a few millirem.
7 MR. DIETRICH: That's right. And we intend 8 to proceed for unrestricted use.
9 MR. CAMPER: Right.
10 MR. DIETRICH: That's certainly our 11 intention.
12 MR. CAMPER: Right.
13 MR. DIETRICH: The other point that was made 14 by the CPUC representative was that we would need to 15 return the land to greenfield requirements to meet the 16 requirements of the Department of the Navy.
17 And I was able to catch Ms. Walker at the 18 break and just ask her if her understanding was the same 19 as mine. And that is absent the radiological 20 decommissioning restoration requirements, our 21 requirements are to restore the land to the requirements 22 of the landlord, which is the Department of the Navy.
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138 1 property either from a radiological standpoint or from 2 a landlord standpoint that some greenfield standard be 3 met.
4 We need to work with the Department of the 5 Navy to ensure that we have restored the property to their 6 satisfaction and meet the radiological requirements of 7 the decommissioning.
8 That's southern California's understanding 9 and we look forward to getting on with it in a safe, 10 cost-effective and efficient manner.
11 MR. CAMERON: Okay, thank you. Thank you, 12 Pete. Okay. Very quickly.
13 MR. STONE: (Speaking off mic) the fact that 14 it's going to take the 60 years and I understand that 15 that's because of the decay rate so that it will be safe 16 to work with.
17 But for those 60 years especially the first 18 30 of those years, that's when the 8.4 million people are 19 at more risk, at the greatest risk. So, that has to be 20 understood as well. And that has to be stated publicly, 21 which is why I'm trying to tell you this right now.
22 You are aware that the greatest danger is 23 now because the decay rate happens over the 30 to 60 24 years, but we're in more danger now.
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139 1 are over time and let's -
2 (Speaking off mic.)
3 MR. CAMERON: Okay, go ahead.
4 PARTICIPANT: I would like to know why -
5 MR. CAMERON: Give her the mic.
6 PARTICIPANT: I'd like to know why these 7 spent fuel pools are not contained in the same way as the 8 reactors and as the dry cask.
9 I mean, outside of the reactor, that is the 10 most dangerous state of the fuel and it has to stay there 11 for up to 15 years.
12 Why are the spent fuel pools not contained 13 in the same way as the reactors and the dry casks when 14 they're going to be exposed to tsunami, earthquake and 15 any other kind of hazard?
16 MR. CAMERON: Okay, thank you. Important to 17 clarify that. Who's going to take - who wants to take 18 that? Doug?
19 MR. BROADDUS: Thanks. The spent fuel pools 20 are not contained in the same manner as the reactor, 21 because the reactor is under extremely high temperatures 22 and pressures so that the containment is there to contain 23 that, those high temperatures and pressures.
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140 1 temperatures and pressures. And as such, the risk 2 associated with a release is not the same as in a reactor.
3 The pools, the primary purpose of the pool 4 is to cool and keep the spent fuel cool. It's to maintain 5 cooling circulating around the fuel itself.
6 The fuel is put inside the pool in a manner 7 that it will not reach criticality and go into the same 8 type of reaction as in the reactor core itself. So, 9 criticality is not the issue with the pool. The cooling 10 of the pool - or the fuel itself is the specific issue 11 there.
12 As long as that's maintained, that's the-13 (Speaking off mic.)
14 MR. BROADDUS: I don' know the thickness off 15 the top of my head, but there's thick stainless steel 16 lining that goes all the way around the pool.
17 The pools themselves are 40 or 50 feet deep 18 and there's about 20 feet of water above the actual top 19 of the spent fuel. So, there's another 20 feet of water 20 above that.
21 There's about five feet of concrete that's 22 on the outside of the lining itself. And so, that's 23 what's protecting the pool, the fuel itself, you know.
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141 1 prevent it from leaking and making sure that the water 2 stays inside the pool.
3 MR. CAMERON: I think maybe we can continue 4 this conversation offline, but thank you for that 5 question. And we're out of time. We're out of time.
6 And so, I'm going to ask Larry Camper to close the meeting 7 out for us and thank you all. Larry.
8 MR. CAMPER: Okay. Thank you, Chip. Let me 9 start by saying as I did at the outset of my comments, 10 thank you for coming and thank you for great questions, 11 good dialog. Very, very good thought went into your 12 questions and we appreciate that and we hope that we have 13 been able to answer them at least to a reasonable degree.
14 You know, burnup fuel, I heard burnup fuel 15 again and again. And I think what we need to do is - there 16 are two things.
17 I want to make sure that we go back and on 18 our website post the approvals that Blair was citing with 19 regards to the casks for the high burnup fuel.
20 And I also want to go back, Doug, and we'll 21 take a look at the actual authorizations that were used 22 to allow the burnup fuel to be at SONGS to begin with.
23 So, we'll work at putting a better explanation of that 24 particular activity on the website for your review.
25 I would also point out that the 60 years has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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142 1 come up a lot. We tried to provide a basis for that, but 2 also understand as I said, it may have just gotten lost 3 in passing.
4 Although the utilities have this 60 years 5 to decommission a nuclear power plant, none of them have 6 taken the 60 years. None of them have taken the full time 7 and a number of things drive that decision, not the least 8 of which is citizen concerns about it. That is a factor 9 that the utility considers as it goes about planning its 10 timeline.
11 Having the expert staff on site to do 12 certain things is a factor. Cost of waste disposal is 13 another. In fact, I think one of Bruce's slides got at 14 this. There's a number of parameters that go into the 15 decision that the utility makes as to how long it's going 16 to take to decommission that reactor.
17 Our process will remain a very transparent 18 process. Once we have that PSDAR, the Post Shutdown 19 Decommissioning Activities Report, it will be posted in 20 FRN. There will be an opportunity for comment. We will 21 have a meeting out here at that time. And we'll do what 22 we can, we'll strive to maintain as much transparency as 23 possible in this process.
24 And, Gene, with regards to your particular 25 request, as I said, we will take that into consideration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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143 1 near term and get back to the coalition on that.
2 So, what that, again I think that all of you 3 being here taking part, it's an important part of the 4 process and we appreciate you taking the time out of your 5 day to be with us and we certainly have enjoyed the 6 opportunity to be with you and will continue to 7 communicate along the way. Thank you.
8 (Whereupon, at 9:15 p.m. the meeting was 9 adjourned.)
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