ML14141A087

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NRR E-mail Capture - G20130629 - pre-PRB Meeting Held November 19, 2013 10 CFR 2.206 Petition Review Board in Re Pilgrims Emergency Preparedness Plan - Transcript
ML14141A087
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Site: Pilgrim
Issue date: 05/20/2014
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Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
G20130629
Download: ML14141A087 (31)


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1 NRR-PMDAPEm Resource From:

Morgan, Nadiyah Sent:

Tuesday, May 20, 2014 2:25 PM To:

NRR-PMDA-ECapture Resource

Subject:

Document to add to ADAMS: G20130629 - pre-PRB Meeting Transcript Attachments:

1119NRC.PDF

Hello, Would you please add the attached document to ADAMS?

Plant: Pilgrim Docket #: 05000293

Thanks, Dee Nadiyah S. Morgan Calvert Cliffs and Pilgrim Project Manager, NRR US Nuclear Regulatory Commission O-8F4 (301) 415-1016 Nadiyah.Morgan@NRC.GOV

Hearing Identifier:

NRR_PMDA Email Number:

1297 Mail Envelope Properties (9C2386A0C0BC584684916F7A0482B6CAFCB2DC5E56)

Subject:

Document to add to ADAMS: G20130629 - pre-PRB Meeting Transcript Sent Date:

5/20/2014 2:24:35 PM Received Date:

5/20/2014 2:24:35 PM From:

Morgan, Nadiyah Created By:

Nadiyah.Morgan@nrc.gov Recipients:

"NRR-PMDA-ECapture Resource" <NRR-PMDA-ECapture.Resource@nrc.gov>

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Recipients Received:

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

10 CFR 2.206 Petition Review Board IN RE Pilgrim's Emergency Preparedness Plan Docket Number:

05000293 Location:

(teleconference)

Date:

Tuesday, November 19, 2013 Work Order No.:

NRC-413 Pages 1-28 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 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6

RE 7

PILGRIM'S EMERGENCY PREPAREDNESS PLAN 8

+ + + + +

9 TUESDAY 10 NOVEMBER 19, 2013 11

+ + + + +

12 The conference call was held, Allen Howe, 13 Acting Chairperson of the Petition Review Board, 14 presiding.

15 PETITIONER: MARY LAMPERT, Pilgrim Watch, Director 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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NRC STAFF PRESENT:

2 ALLEN HOWE, Acting Petition Review Board 3

Chairman 4

JOE ANDERSON, Chief of Operating Reactor 5

Licensing, NSIR 6

LEE BANIC, 2.206 Coordinator, NRR 7

RAY HOFFMAN, Emergency Preparedness 8

Specialist, NSIR 9

RICK KINARD, Emergency Preparedness Specialist, 10 NSIR 11 ERIC MICHEL, Attorney, Office of General 12 Counsel 13 NADIYAH MORGAN, Pilgrim Nuclear Power Station 14 Project Manager 15 SERITA SANDERS, On Behalf of the Various 2.206 16 Coordinators 17 MEMBERS OF THE PUBLIC PRESENT:

18 REBECCA

CHIN, Co-Chair, Duxbury Nuclear 19 Advisory Committee 20 MARISCHKA DOPP, Pilgrim Coalition 21 BILL MAURER, Cape Downwinders 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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

3:06 p.m.

3 MS. MORGAN: Okay, I'd like to thank 4

everyone for attending the meeting. My name is 5

Nadiyah Morgan. I'm the Pilgrim Nuclear Power Station 6

project manager. And we are here today to allow the 7

Petitioner, Ms. Mary Lampert, to address the Petition 8

Review Board regarding the 2.206 petition, dated 9

August 30, 2013.

10 I am the petition manager for the petition 11 and the Review Board chairman is Ho Nieh. Right now 12 he's out. Allen Howe is subbing for me.

13 As part of the Petition Review Board or 14 PRB review of this petition, Ms. Lampert has requested 15 this opportunity to address the PRB.

16 This meeting is scheduled from 3 to 4 p.m.

17 Eastern Time. The meeting is being recorded by the 18 NRC Operations Center and will be transcribed by a 19 court reporter. The transcript will become a 20 supplement to the petition and the transcript will 21 also be made publicly available.

22 I'd like to open this meeting with 23 introductions. And as we go around the room, please 24 clearly state your name, your position and the office 25 that you work for within the NRC for the record. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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then once we've completed introductions here. I'll go 2

to the phone.

3 So again, I'm Nadiyah Morgan, the Pilgrim 4

project manager for NRR.

5 MR. HOWE: Good afternoon. I'm Allen 6

Howe. I'm the Acting Petition Review Board Chairman.

7 MS. SANDERS: I'm Serita Sanders attending 8

with the various 2.206 coordinators. The lead is 9

Rebecca.

10 MR. KINARD: Good afternoon. My name is 11 Rick Kinard. I'm the Emergency Preparedness 12 Specialist in NSIR.

13 MR. MICHEL: This is Eric Michel from the 14 Office of General Counsel.

15 MR. ANDERSON: Joe Anderson, NSIR, Chief, 16 Operating Reactor Licensing branch.

17 MR. HOFFMAN: This is Ray Hoffman, also 18 from NSIR and an EP specialist.

19 MS. BANIC: Lee Banic, 2.206 petition 20 coordinator, NRR.

21 MS. MORGAN: We've completed introductions 22 here at headquarters. Are there any NRC participants 23 on the line?

24 (No response.)

25 Are there any NRC participants from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Regional Office?

2 (No response.)

3 Are there any representatives from the 4

Licensee on the phone?

5 (No response.)

6 Ms. Lampert, will you please introduce 7

yourself?

8 MS. LAMPERT: Yes. I'm Mary Lampert, L-A-9 M-P-E-R-T. Director of Pilgrim Watch and the 10 Petitioner.

11 MR. HOWE: Ms. Lampert, could you -- it's 12 very difficult to hear you. Could you speak up, 13 please, so to ensure that we can properly hear your 14 comments when we get to that portion of the 15 discussion?

16 MS. LAMPERT: Certainly. Is my voice loud 17 enough now?

18 MR. HOWE: It's a little better. It's 19 still a little low.

20 MS. LAMPERT: I'll try to shout.

21 MR. HOWE: Thank you.

22 MS. MORGAN: While it's not required for 23 members of the public to introduce themselves for this 24 call, however, if there are any members of the public 25 on the phone that wish to do so at this time, please NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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state your name for the record.

2 MS. CHIN: Yes, this is Rebecca Chin. I 3

co-chair the Duxbury Nuclear Advisory Committee in 4

Duxbury, Massachusetts and we joined the petition.

5 MS. MORGAN: Okay.

6 MS. DOPP: This is Marischka Dopp with the 7

Pilgrim Coalition.

8 MR. MAURER: Hi, my name is Bill Maurer.

9 I'm with the Cape Downwinders.

10 MS. MORGAN: Okay, well, thank you.

11 Again, as Allen said, we'd like to emphasize that we 12 need everyone to speak clearly and loudly to make sure 13 that the court reporter can accurately transcribe this 14 meeting. If you do have something that you would like 15 to say, please state your name first for the record 16 and for those that are dialing in to the meeting, 17 please remember to mute your phones to minimize any 18 background noise. If you do not have mute on your 19 phone, you can mute your phone by pressing *6. And 20 then you also press *6 again to unmute your phone.

21 And so at this time I'll turn the meeting 22 over to our PRB Chairman, Allen Howe.

23 MR. HOWE: Thank you, Di, and good 24 afternoon and I want to welcome everyone to this 25 meeting regarding the 2.206 petition submitted by Ms.

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Lampert.

2 Let me start out, I want to start just a 3

quick background on our process for the 2.206 4

petitions. Section 2.206 of Title X of the Code of 5

Federal Regulations describes the petition process.

6 It's the primary mechanism for the public to request 7

enforcement action by the NRC in a public process.

8 This process permits anyone to petition the NRC to 9

take enforcement-type action related to NRC licensees 10 or licensed activities. Depending on the results of 11 its evaluation, NRC could modify, suspend, or revoke 12 an NRC-issued license or take any other appropriate 13 enforcement action to resolve the problem.

14 The NRC staff's guidance for the 15 disposition of 2.206 petition request is located in 16 Management Directive 8.11 which is publicly available.

17 The purpose of today's meeting is to give 18 the Petitioner an opportunity to provide any 19 additional explanation or support for the petition 20 before the Petition Review Board's initial 21 consideration and recommendation.

22 Just a couple of things I want to mention 23 associated with this meeting today. This meeting is 24 not a hearing, nor is it an opportunity for the 25 Petitioner to question or examine the PRB on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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merits or the issues presented in the petition 2

request. No decisions regarding the merits of this 3

petition will be made at this meeting. So this is 4

really an information-gathering meeting for the 5

members of the Petition Review Board.

6 Following this meeting, the Petition 7

Review Board will conduct its internal deliberations 8

and the Petitioner will be informed of the outcome of 9

this internal meeting. The Petition Review Board 10 typically consists of a chairman, usually a manager at 11 the Senior Executive Service level at the NRC. It has 12 a Petition Manager and a PRB Coordinator. Other 13 members of the Board are determined by the NRC staff 14 based on the content of the information in the 15 petition request. We also obtain advice from our 16 Office of General Counsel.

17 As described in our process, the NRC staff 18 may ask clarifying questions in order to better 19 understand the Petitioner's presentation and to reach 20 a reasoned decision whether to accept or reject 21 Petitioner's request for review under 2.206 process.

22 With that, I would like to summarize the 23 scope of the petition under consideration and the NRC 24 activities to date. As was mentioned earlier, the 25 petition was submitted on August 30, 2013 from Ms.

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Lampert. The petition was submitted under 2.206 2

regarding Pilgrim's Emergency Preparedness Plan. In 3

this Petitioner request, Ms. Lampert identified the 4

following areas of concern. And I'm going to 5

summarize these concerns rather than iterating the 6

entire content of the petition.

7 Ms.

Lampert requests that the NRC 8

institute a proceeding to modify, suspend, or take any 9

other action as may be proper to the operating license 10 of Pilgrim in order to ensure that Pilgrim's 11 radiological emergency plan and standard operating 12 procedures and guidelines are based on accurate and 13 credible evacuation time estimates. These are also 14 referred to as ETEs.

15 Ms. Lampert stated that the primary basis 16 for this request is in response to two documents 17 prepared to KLD for Entergy. The Petitioner maintains 18 that Entergy's evacuation time estimates for Pilgrim 19 are based on inaccurate assumptions and simply are not 20 credible. The Petitioner further stated that the 21 ETE's fundamental assumptions and data were flawed 22 which explained the ETE's conclusions that even in the 23 worst case scenario everyone in the emergency planning 24 zone will be evacuated in about six hours.

25 The Cape survey is one of the two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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documents referenced. The Petitioner discussed the 2

results of the Cape survey and maintains that it was 3

not properly used to determine Pilgrim's evacuation 4

time estimates.

5 Let me discuss NRC activities to date. On 6

September 24th, the Petitioner Manager contacted Ms.

7 Lampert to discuss the 10 CFR 2.206 process and to 8

offer her an opportunity to address the PRB by phone 9

or in person. the Petitioner requested to address the 10 PRB by phone prior to its internal meeting to make the 11 initial recommendation to accept or reject the 12 petition for review.

13 As a reminder for the phone participants, 14 please identify yourself to make any remarks as this 15 will help in the preparation of the meeting transcript 16 and that transcript will be made publicly available.

17 I'd like to thank everyone for your 18 attention at this point and Ms. Lampert, I'd like to 19 turn over the discussion to you to allow you to 20 provide any information you believe that the Petition 21 Review Board should consider as a part of this 22 petition.

23 MS. LAMPERT: Hello, I hope that you can 24 hear me. This is Mary Lampert and I appreciate the 25 opportunity to address the Board this afternoon.

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Your summary was correct. I wasn't quite 2

clear what the summary of the meaning of the Cape's 3

telephone survey was. The importance of the Cape Code 4

telephone survey by KLD for Entergy is as follows. It 5

provided a test to show that number one, if a 6

telephone survey in preparation for the KLD is 7

performed and it does not identify the purpose of the 8

survey, that is, questions regarding a radiological 9

emergency, then the responses will be useless. This 10 is important because the telephone survey for the KLD 11 ETE and the EPZ. I actually can speak in whole words, 12 did not identify the purpose of the survey, and hence, 13 the responses that underlay many of the assumptions in 14 the ETE were incorrect, where as the Cape Code 15 telephone survey identified the purpose and it showed 16 the difference in response to, for example, shadow 17 evacuations that will make a very large difference.

18 I will note also that Sandia previously 19 had also done a national survey and it suffered the 20 same deficient that Pilgrim's EPZ ETE did. I think 21 the point is that is almost like KLD had a pre-22 determined answer that they could get people out of 23 Dodge in the EPZ in a reasonable period of time and 24 then they worked backwards and came up with the 19 25 assumptions that we identified in the petition to get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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the "right answer."

2 In reality, the ETE is fundamentally 3

flawed in many respects as we identified. And as a 4

result, we do not have reasonable assurance that in 5

the event of an emergency, there would be a timely 6

evacuation so that public health and safety will be 7

protected in the event of an emergency here or that 8

NRC can satisfy its requirement to protect public 9

health and safety. We are fully aware that NRC bases 10 its findings of reasonable assurance on a review of 11 FEMA findings and FEMA has not criticized the ETE.

12 However, FEMA's findings constitute a 13 rebuttable presumption on questions of adequacy and 14 implementation capability.

And a

rebuttable 15 presumption can be overturned if the evidence 16 contradicting it is true and if a reasonable person of 17 average intelligence could logically conclude from the 18 evidence that the presumption is no longer valid. A 19 reasonable person of less than average intelligence 20 could see that the ETE is absurd.

21 Our analysis of the 19 false assumptions 22 that provide for the bases of the ETE provides ample 23 evidence that the ETE planning standard requirement in 24 50.47(2)(b)(10) is not being met. And so then we come 25 to you to make the wrong right. What we are after is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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plans that make sense, provide reasonable assurance so 2

that at least some of the people will be able to get 3

out of Doge in time.

4 The key issues that we showed are first 5

that the telephone survey without explaining the 6

purpose of the survey is worthless. Very key, we show 7

that a shadow evaluation assumption is incorrect. The 8

Cape Code survey, telephone survey, showed that a 9

larger geographic area than 10 to 15 miles will try to 10 evaluate. The Cape encompasses a little better than 11 25 miles and the survey covered all the population, 12 permanent population on the Cape.

13 Also, it shows that a larger number, 70 14 percent, of a shadow evacuation, not 20 percent, will 15 in fact try to evacuate. And what will that mean?

16 That will mean that those at the core, the most 17 impacted will not be able to get out because the 18 shadow evacuation will clog the roads upstream.

19 Therefore, what we need is a valid shadow 20 evacuation number so that proper planning will occur.

21 Proper planning would include educating those outside 22 the ten miles on a proper response and providing them 23 with plans, indicating for example, that on ramps to 24 major routes would be closed or opened on a schedule 25 of getting the core out first, etcetera, etcetera.

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Also, what was show was that the shadow 2

evacuation inside the EPZ or what's called the 3

segmented evacuation is incorrect, that if folks 4

currently in the segmented evacuation NRC has 5

responded to the fact the population has gotten much 6

greater than before and so the result is to shrink the 7

planning zone to first have all the population within 8

the two miles to evacuate and then a keyhole between 9

the two inside and eventually segment out if the 10 accident called for it.

11 We know, and it was shown by the Cape Code 12 survey, that people are not going to obey like trained 13 puppy dogs; that they, in fact, will evacuate also.

14 The Cape telephone survey showed that even if folks 15 said they were told that they were not in an 16 evacuation area that a little over 50 percent said 17 they would evacuate anyway. In the town of Duxbury, 18 this has been discussed at great length and the 19 Emergency Manager Director, the Board of Selectman, 20 all have supported the idea that this segmented theory 21 is bogus.

22 Also, in 2006, a non-binding article was 23 put before the town at annual town meeting and 24 overwhelmingly the citizens of the town of Duxbury 25 said this is ridiculous, that they in the town of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Duxbury are not going to listen to this foolishness 2

and they're going to evacuate. And also, the fact of 3

rapid telephone communication that people will hear of 4

the accident and both within and without will 5

evacuate. So those initial findings that were shown 6

in fact not people opining by the telephone survey on 7

the Cape shows that we do not have reasonable 8

assurance.

9 Now, I will also add as a piece of new 10 information that now Kevin Nord, the Emergency 11 Management Director of Duxbury, had written to Ed 12 Hartnett and Mr. White, Emergency Planners for 13 Entergy, on 7/30/12, explaining to them that there 14 were many, many problems with the KLD, but in 15 particular, this concept of shadow evacuation and 16 segmented evacuation was highlighted.

17 In addition, Aaron Wallace, who is the 18 Emergency Management Director of Plymouth, has told 19 MEMA, look, I know from the telephone survey and my 20 common sense in talking to Emergency Management 21 Directors on Cape Cod, that the shadow evacuation is 22 going to be far larger and because Cape Cod their only 23 way off is over two bridges over Cape Cod Canal that 24 feeds into one of the major evacuation routes of the 25 EPZ that being Route 6. And Aaron Wallace said, look, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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if this isn't changed, if we don't have some sense 2

here, I'm not going to follow it. I am not going to 3

send my people down Route 3 to Route 6 to be 4

overwhelmed at the base of the bridge with all the 5

folks from Cape Cod evacuating. And so although 6

they're tidbits that would be in my mind the only 7

necessary supplement, additional information to the 8

petition because I think this petition was very well 9

constructed and there were examples and references 10 indicating very clearly that currently, we do not have 11 reasonable assurance and part of the reason rests with 12 a bogus evacuation time estimate that is based on 13 flawed assumptions that make it appear that we have 14 reasonable assurance, but in reality if there were, 15 God forbid, an accident, it would be proven to be 16 inadequate.

17 What we're looking for is reasonable 18 assurance and action by you to correct these 19 assumptions so that we have a real document, not a 20 piece of fantasy. That is a disservice to the public 21 here, but it's a disservice to the NRC because it 22 means NRC is not doing its job which is to protect 23 public health and safety.

24 Do you have any questions on any of the 25 material that was provided to you or are there any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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more materials that you would like to have in order to 2

make a reasoned determination?

3 Hello?

4 MR. HOWE: Yes, Ms. Lampert, this is Allen 5

Howe. We were on mute. I'm just looking around the 6

room here to see if any of the staff have any 7

questions. So hold just a moment, please.

8 (Pause.).

9 MS. LAMPERT: Or I could add, just to 10 stimulate your thinking, if the shadow evacuation 11 assumption incorrectly assumes that only 20 percent of 12 those instructed not to evacuate will voluntarily 13 evacuate anyway and it was shown that between outside 14 the 10 miles to at least 25 miles, 70 percent would 15 try to evacuate or if somehow they heard that they 16 were not supposed to, how they didn't hear would be an 17 interesting question, over 50 percent. Consider what 18 that does for off-site planning. Consider how many 19 traffic control points and personnel to man them would 20 be -- are planned by the state now believing that the 21 20 percent only from 10 to 15 miles is all that has to 22 be prepared for.

23 Consider also the reception centers. They 24 are currently planning on -- this is ridiculous -- 20 25 percent of the EPZ population that is slated for that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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reception center. But then you have all these other 2

folks who are going to try to evacuate and get help 3

for themselves. How inadequate then, the reception 4

center's mass care facilities that are now in the 5

planning are because of the foolishness. Then you 6

could look at for the demand and road capacity.

7 In number eight, I showed how the 8

assumptions about traffic flow in inclement weather 9

and peak commuter/holiday traffic are incredible 10 because they look at not the peak commuter time to 11 come up with their estimates, but instead look at mid-12 day when people have gotten to work and are at work 13 and hence the result is inadequate. They've looked at 14 road capacity and traffic flow for snow mid-day in the 15 middle of the week as opposed to looking at it when 16 there is peak traffic. They look at only one holiday, 17 4th of July in Plymouth, where the big bang is a huge 18 traffic increase on Cape Cod that goes over the same 19 routes to get back home that are one of the major 20 evacuation routes.

21 And so you could go piece by piece by 22 piece, as I explained, that show or it indicates that 23 they came up with the answer they wanted first and 24 then worked backwards. We want and deserve reality so 25 that we have reasonable assurance that the folks here NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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and when you look at Pilgrim's EPZ and surrounding 2

communities, recognize number one, Pilgrim is in 3

Southeastern Massachusetts, the fastest-growing area 4

in the Commonwealth. Pilgrim is on the coast. We 5

don't have the availability of 360 degrees with roads 6

to be able to use the roads. The evacuation routes 7

are very limited.

8 So therefore, considering that situation 9

of now a dense population with limited infrastructure 10 that you better have the concept and numbers right on 11 the total number of people and vehicles likely to 12 evacuate, the capacity, in fact, for the roads, and 13 also the preparation time that is required, that will 14 be required to get people going.

15 I don't see any need to repeat, but I 16 would ask Rebecca Chin, who is on the phone to chime 17 in because she and myself, along with the Emergency 18 Management Director of Duxbury, read and re-read every 19 single page of that KLD and prepared an analysis for 20 our community and it was very influential for the 21 surrounding communities and for MEMA, Massachusetts 22 Emergency Management Agency, to realize there's a 23 problem.

24 MR. HOWE: Yes, Ms. Lampert, let me just 25 ask you to hold for just a minute. I want to allow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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the staff here to absorb the comments that you've made 2

in conjunction with the petition that you provided and 3

ensure that if they have any questions that we take 4

the time to get to those. We will have an opportunity 5

for other members to address the Petition Review Board 6

in a moment, but I wanted to ensure that the staff 7

here had their opportunity first. So if you could 8

hold for just another moment.

9 MS. LAMPERT: Sure.

10 (Pause.)

11 MR. HOWE: Okay, Ms. Lampert. Thank you 12 very much for your patience and also the other people 13 that were on the line. I've looked around at the 14 staff here and at this point in time we've heard the 15 remarks that you've made. We've reviewed the petition 16 that you provided and at this point we don't have any 17 questions for you as a part of this meeting today.

18 MS. LAMPERT: Okay, well, you know, what 19 we're saying is there are a lot of reasonable things 20 that we'd like to see you come up with. Let's make it 21 better. You could easily recommend, I would think to 22 do a telephone survey here, a new one, where -- put 23 the current KLD on hold. Let's correct the 24 inadequacies. Do a telephone survey here that 25 actually tells the respondents what it's for.

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Make some reasonable assumptions about 2

shadow evacuation or include in your telephone survey 3

25 mile ring, let's say around Pilgrim and ask folks 4

the same questions that were asked in the Cape to 5

assess what the shadow evacuation situation would be.

6 That makes sense. Then the same thing for the Staged 7

Keyhole Evacuation, which also by the way assumes a 8

straight-line Gaussian plume. False assumptions in a 9

coastal area where we have variable winds which NRC's 10 Steven LaVie says confirmed. I could send you that if 11 you want that.

12 Then take proper account of the summer 13 transient population. You could go through this, ask 14 KLD to redo it and where the assumptions were 15 identified as being bogus to correct that and come up 16 with an ETE that is honest and that is reliable. I 17 should that would be doable.

18 And if you're going to look at road 19 capacity, for example, you account for the heavy 20 traffic on summer weekends and special events. You 21 account for inclement weather during peak traffic 22 times.

23 MS. CHIN: I would like to echo, this is 24 Rebecca Chin, from the Duxbury Nuclear Advisory 25 Committee, the comments of Ms. Lampert. As she said NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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before, we did read page by page the entire report and 2

we actually asked for a meeting with Entergy Pilgrim 3

at our Emergency Management Center who was attended by 4

our Director, a member of the Board of Selectmen, who 5

was also a Captain in the Coast Guard.

6 And Mr. Tom White, I believe from Entergy 7

came to that meeting and he said pointedly that the 8

KLD report certainly had some weaknesses, some bad 9

analysis, but he didn't care. As long as he compared 10 favorably with other Entergy plants' ETEs, it didn't 11 matter to him at all if the report was bad science.

12 That's not okay with us up here.

13 MS. LAMPERT: We could get an affidavit 14 from attendees of the meeting if you'd like.

15 MR. HOWE: We will consider what we need 16 in that area.

17 MS. LAMPERT: Pardon me?

18 MR. HOWE: We will consider what we need 19 in that area. The question was was there any 20 documentation associated with that meeting and the 21 remarks made by the person from Entergy.

22 MS. LAMPERT: It was not a recorded 23 meeting. I was present. Becky Chin was present.

24 Theodore Flynn.

25 MS. CHIN: Who is a Captain in the Coast NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Guard.

2 MS. LAMPERT: And Chair of the Board of 3

Selectmen of the town of Duxbury, Chief Nord, and we 4

can easily --

5 MS. CHIN: And Ed Hartnett who was at 6

Entergy at the time, has now retired, but did not 7

speak at the meeting. He just sat in the meeting.

8 But Tom White was the representative of Pilgrim 9

Entergy.

10 MS. LAMPERT: And I will attest to the 11 fact as was reported by Becky Chin, it was accurate, 12 and again, if you want written documentation from the 13 other parties that were in attendance, we'd be happy 14 to provide it.

15 MR. HOWE: Okay, understand we are not 16 asking for that at this point in time, but we do 17 understand that offer is out there.

18 MS. LAMPERT: Yes.

19 MR. HOWE: Are there any other members of 20 the public that have any comments that they would like 21 to provide to the Petition Review Board?

22 MS. LAMPERT: Bill Maurer.

23 MR. MAURER: Hi, can you hear me? This is 24 Bill Maurer. I was muted.

25 MR. HOWE: Yes, Bill, we can hear you.

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MR. MAURER: Yes, the only thing I would 2

add to what Mary and Rebecca has said is that the Cape 3

Cod telephone survey surveyed only permanent residents 4

of Cape Cod and the permanent residents for even 5

numbers are 200,000 people. It's really 218,000. But 6

if 50 percent of them get on the road to self-7

evacuate, that's 100,000, just the permanent 8

residents. So that's the winter time or that's the 9

off-season.

10 In the summer time, if there were an 11 accident, we're going to have between 200,000 and 12 300,000 tourists here and you know, one can only guess 13 at the percentage of the tourists that would like to 14 leave Cape Cod if there were an accident. I would 15 guess 100 percent is probably pretty close to what it 16 will be. So you're talking another 200,000 to 300,000 17 people on the road wanting to leave Cape Cod and 18 contributing to the shadow evacuation volume coming 19 from the Cape. That's the only thing I would add.

20 MS. LAMPERT: Thank you, Bill. This is 21 Mary Lampert. I cited a study done in New Jersey and 22 it indicated that tourists are most ready to evacuate 23 because to take the psychological, they want to go to 24 where they see it as safe which is home. And they 25 don't have the education to do otherwise nor does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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anybody else for that matter.

2 And so it is very likely that the first 3

thoughts in the tourists' minds is to get out of there 4

and get home. Particularly, when you're on the Cape 5

and you know you're trapped. There are two bridges 6

off, one leading directly into the eye of the storm 7

and the other one, the Bourne Bridge is the option.

8 And again, that is why Aaron Wallace, 9

Emergency Management Director of Plymouth, is going 10 crazy and finds this unacceptable, this KLD 11 unacceptable because he will supposedly, according to 12 plan tell his folks in Plymouth to head into where the 13 Cape folks are evacuating.

14 MR. MAURER: This is not really a minor 15 wrong assumption. It hits the mark by orders of 16 magnitude as to what the shadow evacuation volume will 17 be from Cape Cod. I mean it's just remarkable how 18 grossly inaccurate that assumption is in the current 19 study.

20 MS. LAMPERT: Which affects real people, 21 affects the people on the Cape who will be sitting in 22 their cars. The cars won't protect you and it will 23 effect those within the EPZ who are directed to go on 24 the very routes that will be clogged up to a fair thee 25 well and they'll be in cars that provide no protection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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either.

2 Who is this serving other than Entergy?

3 As White said in the meeting in Duxbury, he doesn't 4

care if it's flawed, as long as it coincides with the 5

other ones. He doesn't care. We care. We hope you 6

care.

7 MR. HOWE: We understand that and we 8

appreciate the comments from the members of the public 9

and also from you, Ms. Lampert.

10 Let me just ask one additional time, are 11 there any questions from the staff here? Looking 12 around the room I don't see any.

13 Ms. Lampert, any final comments that you 14 would like to make?

15 MS. LAMPERT: No, I also presume that you 16 all read what our Senators Markey and Warren had to 17 say and I assume that -- I would hope would provide 18 some weight to the petition. So we have not only the 19 citizens here. We have Emergency Management Director.

20 We have a vote by the citizens of the town of Duxbury.

21 We have Board of Selectmen. We have MEMA being 22 concerned, whether they're going to take any action, 23 which would be uncharacteristic of MEMA is another 24 issue.

25 Also, we have the concern of the two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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Senators from the Commonwealth. So this is a broad-2 based issue of concern and therefore, we truly hope 3

you are looking at this seriously and can see that 4

there is an easy solution, just simply ask that the 5

KLD be redone with sensible assumptions and a 6

telephone survey that is real in that it explains it 7

is for a nuclear emergency at the Pilgrim Station.

8 It's easy to fix.

9 MR. HOWE: Okay, Ms. Lampert, I want to 10 thank you for your time and meeting with the NRC staff 11 and providing clarifying information on the petition 12 that you've submitted. I'm about to close the 13 meeting, but I do want to check with the court 14 reporter to see if there's any other information that 15 you need for the meeting transcript?

16 COURT REPORTER: Hi, this is the court 17 reporter. If I could just speak with Ms. Lampert and 18 Ms. Nadiyah Morgan just briefly for some name 19 spellings after we go off the record?

20 MS. LAMPERT: Sure.

21 COURT REPORTER: We can go off the record.

22 MR. HOWE: Yes.

23 MS. LAMPERT: Thank you very much.

24 MR. HOWE: With that, let me go and 25 conclude the meeting and we'll allow the court NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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reporter to get the appropriate spellings of the 2

names, but this meeting is hereby concluded. And than 3

you again.

4 MS. LAMPERT: Thank you.

5 MR. MAURER: Thank you 6

(Whereupon, at 3:52 p.m.

the 7

teleconference was concluded.)

8 9

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