ML14336A178
| ML14336A178 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/27/2014 |
| From: | Thomas Wengert Plant Licensing Branch IV |
| To: | Thomas J. Palmisano Southern California Edison Co |
| Wengert T | |
| References | |
| NRC-1224 | |
| Download: ML14336A178 (152) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
San Onofre Nuclear Generating Station Post-shutdown Decommissioning Activities Report Docket Number:
05000361 and 05000362 Location:
Carlsbad, California Date:
Monday, October 27, 2014 Work Order No.:
NRC-1224 Pages 1-155 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
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2 NUCLEAR REGULATORY COMMISSION 3
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4 OFFICE OF NUCLEAR REACTOR REGULATION 5
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6 THE SAN ONOFRE NUCLEAR GENERATING STATION (SONGS) 7 POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT 8
(PSDAR) 9
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10
- MONDAY, 11 OCTOBER 27, 2014 12
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13 OMNI LA COSTA 14 CARLSBAD, CALIFORNIA 15
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16 PRESENT:
17 CHIP CAMERON, Facilitator 18 DOUG BROADDUS, NRR 19 LARRY CAMPER, NMSS 20 AL CSONTOS, NMSS 21 RAY KELLAR, Region IV 22 TOM PALMISANO, Southern California Edison 23 BRUCE WATSON, NMSS 24 25
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 C O N T E N T S 1
PAGE 2
Introduction by Chip Cameron 3
3 Comments from Panel Members 7 4
Public Comment 5
67 6
Closing Remarks by Larry Camper 150 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
P-R-O-C-E-E-D-I-N-G-S 2
6:00 p.m.
3 FACILITATOR CAMERON: Okay, good evening, 4
everyone. My name is Chip Cameron, and I'd like to 5
welcome all of you to the public meeting tonight.
6 I was going to make a joke and say welcome 7
to the annual meeting of Local 89, but --
8 (Laughter.)
9 Okay, but -- all right, all right.
10 But we do have a serious topic tonight, and 11 it's the decommissioning of the SONGS facility, and 12 specifically, it's a meeting on what's known as the 13 Post-Shutdown Decommissioning Activities Report.
14 We're going to try not to use many acronyms 15 tonight. We are going to use NRC, for Nuclear 16 Regulatory Commission, and you're probably going to 17 hear the term PSDAR -- that's the Post-Shutdown 18 Activities Report, Decommissioning Activities Report.
19 That document was submitted by Southern 20 California Edison under the regulations that the NRC has 21 for decommissioning, and you're going to hear a lot 22 about that tonight.
23 I just want to go through some meeting 24 process items for you so that you know what to expect 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 tonight, and I'd like to tell you about what the 1
objectives are for the meeting, what the format is going 2
to be, and just some simple ground rules that will help 3
us to have a productive meeting tonight.
4 In terms of objectives for the meeting, one 5
is to have the NRC provide you with a clear explanation 6
of the NRC regulatory process for decommissioning, and 7
the overview of what's in the PSDAR, the Southern 8
California Edison document.
9 We also have Tom Palmisano doing a 10 presentation for us tonight to go over the specifics of 11 the post-shutdown report, and we'll be hearing from a 12 panel of speakers including Tom in a few minutes.
13 So that's one objective, to clearly explain 14 all that to you.
15 Second objective is to hear any comments, 16 concerns you might have, and to also answer some 17 questions that you might have about the presentations.
18 And our panel reflects all the different organizations 19 that are involved for the NRC in decommissioning, and 20 Larry Camper, our lead senior official, is going to 21 explain that to you in a few minutes.
22 I am going to have to ask your patience. We 23 are going to have all the presentations before we go out 24 to you for questions so you can get the whole picture, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 but we might be here for 45 minutes talking, not at you, 1
but to you, and the speakers are going to try to keep 2
it brief.
3 But just let me ask your patience with that, 4
and after that's done, we'll go out to you for questions 5
and comments, and I would ask you to hold your questions 6
until all the presentations are finished.
7 In terms of ground rules, first of all, hold 8
your questions. Second of all, let's only have one 9
person speaking at a time, whoever has the floor at the 10 moment, whoever has the microphone. And that's just 11 very simply so that we can give our complete attention 12 to whomever is talking at the moment.
13 And I am going to have to ask you to be 14 brief. We're not going to be able to have lengthy 15 presentations by you tonight. We will have listened to 16 your comments, but luckily, there's a relief valve --
17 if you don't get to say everything that you want to say 18 tonight, the NRC is taking email, comments by email, on 19 these issues, and they're also taking hard copy comments 20 if you want to mail those in, and we'll put that address, 21 the email address and the mail address up for you at --
22 all during the meeting, so that you can copy that down.
23 And if your question or concern has already 24 been raised or has been answered, if you could try not 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to repeat that -- and I know sometimes that's difficult, 1
because you want to chime in with what you have to say 2
and sometimes it's a little different, but let's try to 3
keep it to what is necessary.
4 And the last ground rule is just please 5
extend courtesy to everybody, and that goes for all of 6
us, NRC, everybody. Just be courteous. You may hear 7
opinions tonight that are different from your opinions, 8
but just respect the person who is giving that opinion.
9 And when we do get to the discussion 10 session, after the presentations, I am going to call for 11 people, raise your hand if you have something to say --
12 I am going to do it section by section, and that is 13 because we are taking camera, web -- and that's going 14 to be for a webcast, and that will be available on the 15 NRC website, so if you want to see what was said, that 16 is going to be your record of the meeting, and also the 17 NRC's record of the meeting tonight.
18 And I just thank you all for being here 19 tonight, and I'm going to turn it over to Larry Camper.
20 MR. CAMPER: Thank you, Chip. Welcome, 21 everybody. It's great to see such a great turnout, 22 really. Thank you for taking time out of your busy 23 lives to come and be with us this evening.
24 We were here last September, and I 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 commented at the time in my remarks what a beautiful 1
place this is, and I can only repeat it again this 2
evening. You really do live in a lovely spot, so it's 3
good to be with you.
4 This evening we're going to conduct a 5
meeting that is a required meeting by our regulations, 6
and as Chip
- said, it's the Post-Shutdown 7
Decommissioning Activities Report Meeting, or PSDAR.
8 The meeting that we were here for last 9
September was an outreach meeting, as compared to a 10 required meeting. So we're here to gather comments.
11 We do have to share some information with you first, so 12 bear with us as we do that.
13 Good. I mentioned we were here last 14 September in an outreach meeting. Heard a lot of good 15 input from citizens, and we appreciated hearing all 16 that.
17 I'll cover the meeting agenda just briefly.
18 In terms of facilitation, you know that Chip Cameron is 19 going to be facilitating. He shared with you the ground 20 rules so we can have a productive and meaningful 21 interface tonight.
22 It's really about comments. We do have 23 some subjects to cover, but -- we want all of you to be 24 aware of the same information at the same time, but it 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 really is about getting comments from all of you here, 1
or as many of you as want to speak.
2 We do have some meeting feedback forms 3
outside on the table. I would ask you to take time to 4
complete the meeting feedback form. We like to get some 5
feedback as to how the meetings went, and did you find 6
it valuable and useful.
7 We will be adjourning at 9:00 p.m., we have 8
the room contractually until 9:00 p.m., so we do have 9
to stop at that point in time. If we go over a few 10 minutes, I don't think the hotel will come in here and 11 run us out, but let's strive for that 9:00 p.m.
12 objective.
13 During the September meeting, it was a 14 meeting that we initiated although it was not required 15 by our regulations. And we did that because there was 16 a lot of things that had happened at this particular 17 plant, and our agency, our chairman in particular, our 18 senior management, all had an interest in seeing to it 19 that we came out here, heard your concerns, and 20 communicated about not only the decommissioning 21 process, but anything that folks wanted to talk about, 22 and we did that.
23 At that
- time, we had a
24 government-to-government meeting with local elected 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 officials during the day, we did that again today. And 1
we also had a meeting with non-government organizations 2
at that time, and today we met with representatives from 3
the Community Engagement Panel.
4 Each of those meetings about an hour and a 5
half in duration, and we found them to be indeed very 6
useful, with much good input. And I would -- I think 7
it's fair to say that the elected officials and the 8
Community Engagement Panel is listening. They shared 9
a lot of very good information with us.
10 Last September, there were a myriad of 11 topics that were talked about. I put down two in this 12 particular slide, fuel management -- and I am sure we'll 13 hear about fuel management again this evening -- as well 14 as decommissioning timing, when will decommissioning 15 start, how long will it take, what are the guidelines 16 and the regulations by which they have to carry out their 17 decommissioning activities?
18 For tonight, I want to start out by saying 19 that I'm going to mention each of the speakers that are 20 up here at the table tonight. Each of these will be 21 making a presentation.
22 Chip alluded to the fact that our 23 responsibility for decommissioning is spread out in 24 several places, so we wanted to make sure we had the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 right expertise here. But I also want to point out --
1 and I'd ask the NRC staff here, if you'd stand up for 2
a moment and turn around and let the folks see you --
3 we have a number of NRC people here, and the reason for 4
that is because we wanted to make sure we had the 5
expertise here. Thank you very much.
6 And if some question comes up over the 7
course of the evening that one of the staff feel that 8
they can better answer, then they can certainly 9
indicate, and we'll recognize them, and they'll do that.
10 Also, we'll take a quick break, and we'll 11 be here just for a little bit after the meeting. Any 12 of these folks are a source of information for you, 13 especially if you're shy about getting up and asking 14 questions or making comments during the program this 15 evening.
16 First is Bruce Watson. Bruce will address 17 the Post-Shutdown Decommissioning Activities 18 Requirements.
19 Next to him is Doug Broaddus, and Doug will 20 cover the review, our review of the PSDAR, and the 21 licensing status of the facility at this point in time.
22 Al Csontos will address spent fuel safety.
23 Ray Kellar, who is with Region IV, will 24 address our inspection program.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And last but not least is Tom Palmisano, who 1
is actually with the SONGS unit and will provide the 2
contents of the PSDAR itself.
3 I did also want to mention that of our staff 4
sitting out here, Keith McConnell, Dr. McConnell, was 5
the manager that was in charge of our recent waste 6
confidence decision, our long-term storage rulemaking, 7
and so Keith is prepared to answer some questions about 8
that initiative if need be.
9 Chip will lead us into our public comment 10 session, and then at the end I like to make some summary 11 comments and share what I call aha moments, things that 12 we heard that were a big deal.
13 So let me say that it's about our mission.
14 Our mission, as you see on the slide, is to regulate the 15 nation's civilian use of radioactive materials to 16 protect public health and safety, promote the common 17 defense, security, and protect the environment.
18 That's our mission during operations.
19 That remains our mission during decommissioning. The 20 entire decommissioning process will be carried out 21 consistent with our regulations and our continuing 22 regulatory oversight to achieve the objective that you 23 see there on the slide defining our mission.
24 I would also point out that there is a great 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 deal of interest, of course, in things environmental, 1
environmental impacts. There is a law called the 2
National Environmental Policy Act of 1969, and we have 3
regulations in our regulatory Part you see there, Part 4
- 51. This is where we carry out our regulatory 5
responsibilities to fulfill the requirements of the 6
National Environmental Policy Act.
7 An important part of that is that the PSDAR 8
contains an updated environmental report, and Tom will 9
speak to the contents of that during his remarks.
10 And then of course ultimately, when we 11 ultimately receive a license termination plan for this 12 facility, we will be conducting an environmental 13 assessment as part of that licensing action.
14 Our regulations for decommissioning are a 15 set Part in Part 20, so Part E. What's important is to 16
-- what does the term mean. The term means to remove 17 as a facility safely from service, and reduce 18 radioactivity to a level that permits release of the 19 property for unrestricted use and termination of the 20 license, or release of the property under restricted 21 conditions and termination of the license.
22 I would point out that no nuclear power 23 plant to date has ever pursued the restricted release 24 pathway, and the facility for SONGS 2 and 3 is not doing 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that either, they're pursuing unrestricted release.
1 In terms of the release criteria for 2
unrestricted release, in order for a site to be suitable 3
for release in an unrestricted manner, the dose that 4
must be achieve is a total effective dose equivalent, 5
or TEDE, of equal to or less than 25 millirem, and as 6
low as reasonably achievable.
7 And achieving that, that means the dose to 8
the average member of the critical group, all pathways, 9
including groundwater, and the period of performance 10 is for 1,000 years.
11 You also see below it the dose criteria for 12 restricted release. I would note that the criteria is 13 the same except that there are provisions in place for 14 institutional controls, and some criteria if those 15 institutional controls fail, but that's not being 16 pursued here.
17 Now when you see or you hear 25 millirem, 18 what does that mean? Well, let me give you something 19 to think about.
20 Millirem is a dose unit of exposure to 21 people, radiation equivalent in man is what millirem 22 stands for.
23 If you get on an airplane in Los Angeles and 24 you fly to New York, you get about three millirem. The 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 natural background radiation in the United States, 1
depending upon where you are, ranges from about 300 to 2
600 millirem.
3 There are places in the world, though, 4
where the natural background radiation is much higher 5
than that. Saskatchewan, Canada comes to mind, about 6
4,000 millirem per year.
7 So at least when you hear that term now, 25 8
millirem, you'll have some idea of what we're talking 9
about.
10 I would point out that while our criteria 11 is 25 millirem and as low as reasonably achievable, the 12 decommissioning of nuclear power plants to date have all 13 achieved a level of exposure much lower than 25 14 millirem, on the order of a few millirem, four, five, 15 six millirem.
16 This is a very important slide for you as 17 members of the public. In fact, I think it's probably 18 the slide that, if I were you, I would be most interested 19 in, because it tells you what happens in the process, 20 and where in the process you have informational 21 awareness, or where in the process you get a chance to 22 make comments.
23 On the left you see what the licensee is 24 required to do. In the center is what our agency does.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And on the right, of course, is the public.
1 There's an initial notification that takes 2
place. It's a cessation of operations, and also a 3
certification that the fuel has been removed from the 4
reactor vessel.
5 Then, there comes a decommissioning 6
report. That is the PSDAR. That is why we are here 7
tonight.
8 Now you note that we review that, and we 9
conduct a public meeting near the site, and you, the 10 public, have an opportunity to comment.
11 I do want to be clear, though, that we don't 12 approve the PSDAR. We review the PSDAR, and the 13 licensee has to wait 90 days while we do that, while we 14 carry out our review to ensure that our regulations are 15 being satisfied, that the PSDAR is in fact adequate to 16 satisfy those regulations. We also go about the 17 comment-gathering process, and we will consider your 18 comments as we continue to carry out our review.
19 Then actual decommissioning takes place.
20 The reactor is completely decommissioned over a period 21 of time, and Tom will specify tonight in his remarks how 22 long this utility plans to take to accomplish that 23 objective.
24 And then the next major milestone in the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 process is a submittal of a license termination plan.
1 The utility will submit that license termination plan 2
approximately two years before it desires to terminate 3
its Part 50 license, that's the Part of our regulations 4
that we use to regulate power plants, or to shrink the 5
footprint to the remaining independent spent fuel 6
storage installation pad.
7 That process, that LTP, is something we do 8
review, and either approve or deny, and I think very 9
importantly for your awareness is that the LTP process 10 is a licensing action that carries with it the 11 opportunity to request a hearing.
12 And if parties, or a party, requests a 13 hearing and achieves standing, then we will carry out 14 a hearing through our adjudicatory process.
15 Then final decommissioning takes place, a 16 number of final surveys are done, we conduct 17 verification surveys, and all that information is 18 available to you the public through the inspection 19 reports that are generated as we go about monitoring the 20 Final Status Surveys.
21 And the Final Status Surveys are designed 22 to achieve that dose standard that I cited a moment ago.
23 This particular slide, the point of showing 24 you this slide is to show you that we've decommissioned 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a lot of sites. We've decommissioned on the order of 1
80 sites, including 11 nuclear power plants.
2 We have a lot of experience, we have a lot 3
of expertise, and not to sound puffy, because that's not 4
my intention, but I just want you to know we have a lot 5
of experience. We've done this a number of times. And 6
we're going to bring all that expertise and experience 7
to bear as we go about monitoring the decommissioning 8
of this facility as well.
9 There is a transition that goes on when we 10 move from an operating power plant to a power plant in 11 decommissioning. We have a number of program 12 responsibilities. Just so you know who's on first, I 13 put this slide in. It shows you that the Office of 14 Nuclear Reactor Regulation continues project 15 management until the post-shutdown defueled technical 16 specifications are issued, Doug will mention that a bit 17 in his commentary.
18 Then the project management is transferred 19 to my division within the Office of Nuclear Material 20 Safety and Safeguards, and we will shepherd it through 21 the entire decommissioning process until the very end.
22 Inspections continue to take place, and 23 that's transferred to the Division of Nuclear Materials 24 Safety and Safeguards from the Division of Reactor 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Projects, and of course, Region IV will carry out that 1
inspection activity, and you'll hear about that from our 2
Region IV representative.
3 And then, of course, support continues from 4
the Nuclear Security and Incident Response Program 5
within NRC.
6 So I will stop there. Bruce Watson will 7
follow me and talk to you more about the PSDAR process.
8 Bruce?
9 MR. WATSON: Thank you, and good evening, 10 and thank you for all sharing your evening with us.
11 The NRC regulations which Larry went over 12 that carry decommissioning have been in place for over 13 17 years. Larry went into a little more detail on the 14 Part 20, but the key factor for the reactor 15 decommissioning is in Part 50, specifically 50.82.
16 These regulations took into a lot of 17 experience that we incurred over the years with some of 18 the initial decommissioning of some reactors in the 19 early 1980s and 1990s.
20 Some of the key milestones from SONGS so far 21 have been that they ceased operations -- permanently 22 ceased operations on June 7, 2013. We received the 23 defueled certifications for the two units also during 24 the summer of 2013, and on September 23, they submitted 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the PSDAR for our review.
1 We issued a public notice for that PSDAR, 2
and of course the public -- the PSDAR is available in 3
ADAMS, which is our agency-wide document system, and 4
there's the number for putting that in [off] the public 5
website.
6 Our guidance allows three types of 7
decommissioning options. The first is DECON, which 8
basically means you're going to do prompt remediation, 9
you're going to begin fairly quickly after you 10 transition the reactor to a state where it can be 11 decommissioned.
12 That transitioning typically takes one to 13 two years, draining systems, isolating systems, 14 isolating electrical systems and making the plant safer 15 for disassembly.
16 The second option is SAFSTOR, in which you 17 can allow the plant to stay in a sort of a mothballed 18 state for a number of years.
19 And then ENTOMB, which we currently do not 20 use and do not have any regulations for and no one has 21 requested, and we don't expect anybody to request 22 entombment, is another option, but not currently 23 available.
24 But the bottom line is radiological 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 decommissioning, and I stress the radiological 1
decommissioning, which is what we regulate, the 2
radioactive part of the decommissioning has to be 3
completed within 60 years.
4 Now San Onofre has chosen to do DECON in 5
their PSDAR, so they're going to begin fairly quickly 6
with their schedule that's in there.
7 With the PSDAR from SONGS, though, they 8
meet the three criteria that we're reviewing. The 9
first part, major requirement, is a description and 10 schedule for the planned decommissioning activities, so 11 it isas a fairly high-level schedule on how they plan 12 to accomplish the decommissioning.
13 The purpose in this is to allow the NRC to 14 schedule our resources to support inspection activities 15 throughout the decommissioning to ensure that we're 16 there for major activities where we think we should be 17 there to ensure that the work is done safely.
18 The second item that's required to be in a 19 PSDAR is a site-specific decommissioning cost estimate, 20 including the costs of managing the irradiated fuel.
21 In most cases, this is a fairly extensive document and 22 has good detail in it.
23 The third thing is that the PSDAR must 24 require -- is required to provide a discussion that 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 provides the means for concluding that the 1
environmental impacts associated with the 2
decommissioning will be bounded by the appropriately 3
-issued Environmental Impact Statement.
4 Now, we have a document called NUREG-0586, 5
it's publically available. It is the generic 6
Environmental Impact Statement document where you can 7
look at all the things that have been previously 8
reviewed.
9 The PSDAR regulations require that we hold 10 a public meeting, which we are doing tonight. We are 11 here to hear your comments and hopefully answer your 12 questions. Like I said, the PSDAR is available for 13 public comment. You can find it, again, at that ADAMS 14 number. We also passed out a number of CDs for your use.
15 We will accept written comments, like Larry 16 said, and also ones from the website.
17 The key thing here is that the licensee can 18 begin major decommissioning 90 days after the PSDAR has 19 been submitted to us.
20 Lastly, I wanted to mention that we have 21 continued our transition activities. One of those 22 transitioning activities is in the inspection area, and 23 Senior Inspector Greg Warnick has been here a little 24 over a year now, and will be here for the near term, as 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 part of that -- ensuring that the plant continues to be 1
transitioned safely.
2 And with that, I'd like to turn it over to 3
Doug Broaddus, who is going to talk about the reviews 4
for the PSDAR.
5 MR. BROADDUS: Thank you, Bruce.
6 All right. So I am here tonight to talk to 7
you tonight about our review process for the PSDAR, but 8
I am also going to talk about some of the other review 9
activities that we have ongoing associated with SONGS, 10 both their licensing actions that they have, and some 11 other related activities that we have under review.
12 As Bruce indicated, the -- our primary 13 review is, you know, does the PSDAR contain the 14 information that's required by the regulations? And 15 Bruce talked about specifically those requirements.
16 The other area where we use as review 17 guidance is in our Reg Guide 1.185. It's a Guide that 18 provides the standard format and content of the PSDAR.
19 So we -- that provides more details as to what 20 information we expect to have in the PSDAR.
21 So the -- our review process, then, is that 22 once we receive it, our project manager for the SONGS 23 facility will send that out to all, and coordinate with 24 the various different technical expertises that are 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 needed to look at the various different issues within 1
the PSDAR.
2 And our general process is, if there's 3
additional information that we need to either confirm 4
that it meets the requirements or that there's specific 5
information that's missing that we need, we'll ask for 6
additional information of the licensee.
7 So what is our critera? What do we look for 8
specifically from the standpoint of the PSDAR?
9 There are a number of things that could 10 cause us to either need additional information on the 11 PSDAR, or in fact, to possibly find it deficient.
12 One is that it doesn't contain the 13 information that's required in the regulations, if it 14 doesn't provide all the information that's specifically 15 required.
16 The other is if the costs that the licensee 17 have indicated would exceed the costs -- or the funding 18 that they have available to them.
19 Another would be if they are -- if they 20 haven't fully described the process that they're going 21 to follow, or the process that they have described is 22 one that could not actually be implemented. So we would 23
-- that could cause us to have problems with that.
24 The other would be that the schedule is --
25
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 would not be completed within the 60 year required time 1
frame that Larry mentioned earlier.
2 The one caveat to that is if the NRC 3
determines that there's a specific reason why a longer 4
than a 60 year period would be necessary, for example 5
to protect public health and safety for a particular 6
reason, then that time period could be extended, but 7
that's something that we would have to specifically 8
review and authorize the licensee to go beyond the 60 9
years.
10 All right. And the last thing, obviously, 11 and the most important, is there -- are the activities 12 going to endanger public health and safety?
13 One example would be if there's no waste 14 disposal facility available, do they have to -- would 15 they -- well actually, I'm sorry that's for the 60 years.
16 If there wasn't a waste disposal available for disposal 17 of the material, it could be that they need to go beyond 18 the 60 years.
19 But from a health and safety standpoint, 20 that's part of our criteria, just to make sure that the 21 activities that they're doing are in compliance with our 22 regulations and aren't in violation of our health and 23 safety requirements.
24 All right. Next is, as part of the PSDAR, 25
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a site-specific decommissioning cost estimate has to be 1
provided, and this decommissioning cost estimate has to 2
address the specific -- the overall cost of the 3
decommissioning.
It has to provide a
good 4
understanding of the costs, the basis for those costs, 5
and it has to ensure, you know, provide enough 6
information to us to be able to say that they have 7
reasonable assurance that they have funds available to 8
complete their decommissioning activities.
9 The other thing is if the licensee has to 10 change their plans, or if they have unforeseen problems 11 as they go through the decommissioning process, that 12 they have a means of adjusting their cost estimate for 13 identifying new, or identifying new funding mechanisms 14 if they don't have enough money to pay for it.
15 And that's -- from that perspective, we've 16 heard the question of, so what happens if they get into 17 that type of situation?
18 So the licensee is required to maintain the 19 level of funding. If they have to change their plans, 20 they have to revise their cost estimate in the PSDAR and 21 submit that to us for a review, and we would look at that 22 to ensure that they've come up with another funding 23 mechanism or some other type of mechanism, or they've 24 changed their approach to ensure that they're going to 25
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 have the funding available to complete the 1
decommissioning activities.
2 And these -- the licensee also has to submit 3
a revision every year to this decommissioning cost 4
estimate, so we're going to see changes as they're 5
happening through the years, and so any problems that 6
would occur, we would see them well before they would 7
ever happen, and we would ensure that the licensee is 8
taking action to adjust those.
9 As Larry indicated before, NEPA is part of 10 the environmental process, is part of our review. In 11 this case, the -- what the licensee would address in 12 their PSDAR is that they've looked at the environmental 13 impacts of the activities that they're going to take, 14 they've looked at the previous environmental 15 assessments that have been conducted, both for the site 16
-- a site specific assessment that was done for the site 17 as well as the generic final environmental assessment 18 for decommissioning facilities -- looking at those to 19 determine whether or not the environmental impacts they 20 are going to incur for their activities would be bound 21 by those prior estimates.
22 And so they would have to provide the basis 23 for why they believe that it's met within, that it's 24 within those prior environmental impacts.
25
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 All right. And the inspection we do have, 1
as Bruce mentioned, we have an inspection program where 2
they'll go out and they'll confirm that the activities 3
they're doing are in accordance with the prior 4
environmental impacts and that they have the 5
appropriate analyses to support the fact that they don't 6
believe that their activities are going to exceed those 7
prior environmental impacts.
8 All right. So we are here tonight to get 9
comments back from the public. We are also going to be, 10 as Chip indicated, we are going to be receiving 11 additional comments for the 90 day period after we have 12 gotten the PSDAR, which is through December 22.
13 We'll take those comments and we'll look at 14 them, we'll consider them in our review as we're 15 reviewing the PSDAR.
16 In particular, we would be looking to 17 determine whether or not there is any health and safety 18 impacts that would be encountered by their plan.
19 If we have questions, we will ask 20 additional information from the licensee, we will ask 21 them to provide that additional information.
22 We -- as Larry indicated, we don't approve 23 the PSDAR, but we will document the completion of our 24 review and determining, if we've determined that 25
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there's no additional information necessary, and we'll 1
document the resolution of the comments that we would 2
receive.
3 One thing that's important is the licensee 4
cannot start major decommissioning activities until at 5
least 90 days after the PSDAR has been received by the 6
NRC. That gives us the time period to review the 7
document, to receive public comments, and to be able to 8
review those and act on them.
9 All right. One of the other areas that we 10 are reviewing, it's called the Irradiated Fuel 11 Management Plan.
12 Within two years after a licensee shuts 13 down, they are required to submit to us an Irradiated 14 Fuel Management Plan that addresses the costs of 15 managing all spent fuel that's at the facility.
16 And this is not -- it's not -- it's a 17 separate document from the PSDAR, but there is a 18 relationship between the
- two, because the 19 Decommissioning Cost Estimate has to include the cost 20 of managing the spent fuel.
21 So although we're not asking specifically 22 for comments on the Irradiated Fuel Management Plan, I 23 wanted to make sure everybody understood that we are 24 reviewing that as well. And that document does need --
25
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 was -- is required to be submitted for our review and 1
preliminary approval.
2 Our review on that will also look to ensure 3
that they've got a good plan for managing the irradiated 4
fuel and that they are able to account for the cost for 5
that as well, that's part of it.
6 And the other part of it is to ensure that 7
their plan complies with all the requirements for 8
possessing and storing irradiated fuel.
9 I think that's it. I'm sorry, I almost 10 missed one.
11 So there are other licensing actions that 12 we're also doing for the plant right now. So as the 13 plant, once it shuts down, the plant transitions from 14 an operating status to a decommissioning status. So to 15 do that, the licensee comes in and requests a number of 16 licensing actions.
17 Those licensing actions can either be 18 submitted as a license amendment, they could be an 19 exemption from a specific part of the regulations, or 20 they could be a request to rescind an order or have 21 relaxation of an order.
22 So the types of requests that we've 23 received are for changing the staffing levels of the 24 plant, to change the type of personnel that they'll have 25
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there to focus more on the spent fuel and 1
decommissioning activities; changes to the license 2
condition to address, to more focus on the managing of 3
the fuel activities; there's also been requests to 4
change the emergency preparedness activities given the 5
shutdown condition and the defueled condition of the 6
plant; and we've received requests for previous orders 7
for the licensee to, also to rescind some of those 8
previous orders.
9 So those are the types of licensing actions 10 that we've had, where we've approved a couple of them 11
-- we're still in the process of reviewing a number of 12 other ones, and we understand that the licensee is 13 probably going to submit some more to us, and so I can't 14 speak to those yet. So that's it.
15 MR. KELLAR: Good evening, I'm Ray Kellar, 16 I'm from Region IV.
17 You've heard a little bit from Bruce and 18 Doug, and you will be hearing from Al, about the 19 regulations, the reviews for the licensing conditions, 20 and also about safety reviews and evaluations here in 21 a little bit, but I am going to talk about how it all 22 comes together a little bit, and I am going to talk about 23 the inspection program, particularly in Region IV, from 24 a decommissioning and a spent fuel safety standpoint.
25
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So how do we get safely from [an]a 1
operating plant to a plant that's been fully 2
decommissioned? As Larry mentioned, there's been the 3
opportunity for the Nuclear Regulatory Commission to 4
have oversight of, I believe he said, 11 nuclear plants 5
over the last recent period.
6 I know in Region IV, we've had several 7
opportunities for decommissioning plants, specifically 8
Trojan, which is near Portland, Oregon; SONGS Unit 1; 9
and we're currently inspecting Humboldt Bay, which is 10 in Northern California.
11 So how do we assure compliance? The NRC 12 looks at the regulations, which is what we've been 13 talking about; we look at the licensing-based 14 conditions, including the technical specifications, 15 decommissioning technical specifications; also 16 guidance documents, which would be things such as 17 NUREGs. These are all part of the licensing basis which 18 are a part of the inspection when the inspectors go out 19 to do their work.
20 Also, the safety reviews will be performed.
21 Al will be talking some about the reviews, I am sure, 22 relative to spent fuel storage. And that leads down to 23 the NRC inspection activities, where the inspectors go 24 out using the regulations, using the licensing-based 25
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 documents, and they perform the inspections to ensure 1
that the licensee is doing things in accordance with 2
what is safe and what they have been approved to do.
3 If we find that something is not right, then 4
we will look at the NRC enforcement program and evaluate 5
whether or not that would come into play.
6 So the regional-based inspection 7
activities will consist of inspection of the spent fuel 8
pool. We will generally look at the higher-risk 9
activities, such as moving the fuel, such as loading the 10 fuel into casks. Those will get extra attention.
11 During and after remediation activities, 12 we will make sure that we're doing independent 13 measurements to confirm the licensee's survey 14 methodologies.
15 Additionally, inspection activities will 16 include the spent fuel, that's also in my branch, as well 17 as a movement to the ISFSI(inaudible), which includes 18 a series of operational tasks and oversight of those 19 activities.
20 Physical security, while it's not my 21 branch, will still be inspected according to the 22 requirements. And there are a number of inspection 23 plans that include oversight of activities including 24 licensee management and organization; review of the 25
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 license safety evaluations, so making sure that their 1
50.59s have been done correctly; reviews of licensee 2
self-assessments and audits; radiation exposures 3
during decommissioning, transportation, and rad waste, 4
making sure that all the requirements are met for that; 5
as well as effluent environmental monitoring.
6 So the objectives of the inspection program 7
include the independent verification of the safety of 8
the licensee's activities, the adequacy of the 9
licensee's controls and programs, ensuring that safety 10 programs are promptly identified and the licensee puts 11 effective corrective actions into place, identifying 12 violations that occur and utilizing the agency-enforced 13 policy to make sure that those are disciplined 14 correctly, as well as review and examine any trends that 15 develop dealing with the licensee's safety performance.
16 Using the inspection procedures, we 17 planned some of the activities up to a year in advance, 18 and the inspectors know what portion of those will occur 19 at what time.
20 Those activities are coordinated with 21 headquarters. We sometimes bring technical expertise 22 along with us to the site to assist in those program 23 inspections. They may be announced or unannounced, 24 quite often they're announced, but we have the 25
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 opportunity to do an unannounced inspection if there's 1
a need to.
2 We utilize inspection plans that document 3
those procedures and those activities that we want to 4
perform inspection activities of. We have exit 5
meetings at the end of each of the inspections where we 6
do an exit with the licensee and present their findings 7
at that time, and if there's any potential enforcement 8
actions, those are also discussed.
9 The inspection reports are normally issued 10 30 days after the exit, that would be for a -- not a team, 11 but a team inspection consisting of three or more 12 inspectors would normally be 45 days after the exit with 13 the licensee before that report is issued.
14 The NRC enforcement policy, there is a link 15 at the bottom of this slide that shows how you can get 16 to the enforcement policy if you're interested in how 17 the agency performs the enforcement activities.
18 So what happens after the inspection?
19 After the inspection, the inspectors come back to the 20 region. They brief the branch chief, and there is a 21 debrief that includes NRC management where the findings 22 are presented. And if enforcement actions need to be 23 taken, those are also discussed, along with the 24 enforcement officer, and those activities are followed 25
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 through with.
1 The inspection reports are available in 2
ADAMS, those that are available publically. Security 3
reports, the details are not available, but the cover 4
letter is usually available inwith ADAMS.
5 You can go to the link that I show on the 6
bottom half of this [web -- this] slide, and it shows 7
how you can get to the ADAMS website, the document 8
numbers -- docket numbers, are shown here as well, you 9
can do a search using Advanced Search under those docket 10 numbers using the website for ADAMS, and you can 11 actually look up the inspection reports that way. And 12 we also track and follow-up on inspection reports.
13 And that concludes my portion.
14 MR. CSONTOS: Hi, my name is Al Csontos. I 15 am the Chief of the Renewals and Materials Branch in the 16 Division of Spent Fuel Management in the Office of 17 Nuclear Material Safety and Safeguards.
18 What does that all mean? That's a 19 long-winded title. What we do is we develop and 20 implement the licensing certification and inspection of 21 spent fuel storage facilities, the dry cask storage 22 systems, the radioactive material transportation 23 packages, for the -- with the applicable regulations, 24 10 CFR Part 71 for transportation, 10 CFR Part 72 for 25
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 storage.
1 We also coordinate with federal agencies 2
like the Department of Transportation, for example, for 3
some of the transportation packages' certifications.
4 Four international bodies, regulatory bodies, as well, 5
IAEA, International Atomic Energy Agency, and our other 6
colleagues around the world.
7 Some of the things that we've learned in 8
what we've done has been from our interactions with 9
these international participants, and also Native 10 American tribes.
11 So what are these things? These are spent 12 fuel storage casks. Over here at SONGS, you have the 13 lower-left version. It's a NUHOMS System 1029, okay, 14 certificate of compliance.
15 What they are is that once the fuel has been 16 cooled in a spent fuel pool that are part of the reactor, 17 it is loaded into these special canisters, for these 18 canisters, they're stainless steel canisters, they're 19 about 5/8ths of an inch thick, and they're designed for 20 the specific fuel that's at these sites, these reactors 21
-- either a pressurized water reactor or a boiling water 22 reactor.
23 The canisters are then vacuumed down, take 24 all the water out, and they are backfilled with inert 25
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 gas. That inert gas is usually helium, and it has a 1
purpose of helping with the cooling of these canisters, 2
and also to -- just to stop any kind of corrosion from 3
occurring on the inside of the canisters.
4 So they're welded, they're vacuum-checked, 5
they're leak-checked -- when they're vacuumed down, 6
they're backfilled, and then they're checked for leaks, 7
helium leaks. And then once they've passed all those 8
rigorous tests and all the fabrication requirements and 9
the quality assurance procedures, they are put into 10 these casks.
11 And what these are, these concrete -- does 12 this have a -- so right here, that's about five feet of 13 concrete. And so that helps with the shielding, the 14 bioshielding from radiation, as well as structural, for 15 seismic concerns.
16 And so these are the ones that you have at 17 SONGS presently. There is a third one, I know that you 18 all were working with two vendors recently, and there's 19 a third one that's -- this is a vertical system that 20 multiple companies develop, and there's a third one 21 that's an underground system that I didn't show here.
22 So we have a total of 71 total sites in the 23 United States by this map. These are independent spent 24 fuel storage installations.
25
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 There are, in 34 states, there are over 1
2,000 casks that have been fabricated and are in place, 2
with over 82,000 fuel assemblies. They are all across 3
the country. There's 56 in -- this is, it gets into some 4
regulatory jargon here, but 56 General Licensed Sites 5
and 15 Specific Licensed Sites.
6 And there are seven at decommissioned sites 7
that will be similar to what is here at SONGS.
8 What is the difference between a general 9
license versus a site-specific license? A general 10 license is only granted to Part 50 licensees, reactor 11 licensees. They require us at NRC, in our division, to 12 review those cask designs.
13 We review them for certain things that I'll 14 go into in a little bit, and then we do the site 15 evaluations and such, and then the site-specific cases 16 are specific to Part 50 reactor licensees or other 17 applicants that would like to have -- would like to store 18 this waste at their site.
19 So, like, for example at Private Fuel 20 Storage in Utah, that is an SSC, a site-specifcspecific, 21 SSC, has no reactor there, but they were willing to take 22 fuel if they were allowed.
23 So Part 72 regulations. What are our 24 review areas? What do we do in our daily jobs? We 25
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 review the general design criteria, making sure that 1
they meet the requirements for offsite radiation dose, 2
subcriticality, and confinement.
3 What does all that mean? Confinement, we 4
retain and make sure that the radionuclides in the fuel 5
stay within the canister. For subcriticality, we don't 6
allow any type of -- we make sure that the fuel is sitting 7
in there so that they never get a place where they can 8
go into a critical state. And offsite radiation dose, 9
we have sensors around the associated pad to make sure 10 that there is no dose that is beyond the requirements, 11 the regulations.
12 We also have quality assurance programs, 13 that's what Ray was talking about earlier. We 14 fabricate these canisters -- or not we, but the licensee 15 buys them from a fabricator -- and we make sure that 16 they're done in a quality fashion.
17 Physical protection security, sighting, 18 reporting requirements, and then training and 19 certification of the personnel at the sites. We review 20 all of those.
21 This takes a lot of people. And what we 22 have is we have a cadre of subject-matter experts. We 23 have structural engineers, we have thermal engineers, 24 we have criticality specialists, we have health physics 25
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 folks who do the shielding and radiation protection.
1 We have materials folks like myself who 2
look at all the materials issues, the corrosion issues, 3
all the material properties issues, making sure that the 4
confinement is maintained, and also making sure that the 5
quality assurance folks are out there. Those are the 6
inspectors, in a lot of ways.
7 So, what do we also look at? We look at 8
three different types of scenarios -- normal, 9
off-normal, and accident conditions. Normal and 10 off-normal, normal occurs regularly, repeatedly.
11 Off-normal is occasionally, once a year, maybe. And 12 then accident conditions are things that we make sure 13 that the licensees, make sure that these are fabricated 14 to withstand these types of events -- tornado winds, 15 missiles, earthquakes, seismic activity, floods, 16 tsunamis, and fires and explosions.
17 Again, the technical reviews are quite 18 long, and a lot of our reviews for new applications can 19 be two, three years, okay?
20 We have structural engineers who look at 21 the confinement that are maintained under all these 22 accident -- the accident, normal, and off-normal 23 conditions. We have criticality folks who look at 24 making sure the fuel is sub-critical in all these three 25
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 cases. Shielding that meets the radiation dose 1
requirements at the site boundaries -- and then the 2
thermal, making sure the cladding temperature is 3
maintained so we have a defense in depth, so we can rely 4
on the cladding.
5 And then the materials folks, who look at 6
the property or properties, and also aging effects, 7
during the renewed operating period, and I'll go into 8
that a little bit later.
9 So for transportation of these systems, the 10 same technical reviews as for storage. There is a 11 little bit more in terms of, you need to show us, to the 12 licensees that are out there, you need to do a bunch of 13 tests.
14 Those tests are drops, 30 foot drops, 15 they're puncture tests, they're deep water immersion 16 tests, making sure that nothing will ever come out of 17 these canisters. Fire -- there is a 30 minute 18 requirement for jet fuel, making sure it doesn't fail 19 in that way -- and all these other normal types of 20 transportation, vibration loads, small drops, heat and 21 cold.
22 Cold is a big deal. Some licensees have 23 been rejected because they can't meet the requirements 24 for transportation at -40 degrees Celsius.
25
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So now, storage renewal. So what are we 1
doing now, the things that are changing on the landscape 2
here.
3 There are two periods. There is the 4
initial licensing period, which is the first 20 years.
5 And then after that, it's between 20 and 60 years is the 6
renewed operating period, okay?
7 The renewal, renewed operating period, has 8
been going through some updates of late, and so what 9
we've done is we've established a group at the agency, 10 a strategy team, and what we've done is we've been trying 11 to look at what we can do to update the guidance, because 12 what we're looking to do is we're looking to change our 13 approach to spent fuel management in the renewed period 14 of operation to an operations-focused aging management, 15 one that is learning from our operational experience.
16 It's proactive to get ahead of issues that, 17 possibly, for degradation aging effects of canisters.
18 You all know that your cars don't last 100 years, or 50 19 years. And they age. And the same thing happens to 20 canisters, or anything that's manmade, and so we're 21 trying to get ahead of these, and we're trying to be 22 proactive and have a responsive aging management, so if 23 we do find anything, we go over and fix it, or require 24 the licensee to fix it.
25
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So what that requires is aging management 1
programs that we're developing in-house, and we're 2
developing these guidance documents out there to help 3
the licensees with how to manage aging as time goes on.
4 So two issues that have come up that have 5
been recently dominating a lot of our discussions.
6 One is cladding integrity and high burnup 7
- fuel, in particular.
And the second is 8
chloride-induced stress corrosion cracking, which I'm 9
sure we'll hear a lot about today.
10 We have spent at the agency over $9 million 11 over the past eight, nine years. We have spent an 12 inordinate amount of staff resources on these issues.
13 We feel we're getting ahead of these issues now, okay?
14 We're developing aging management programs 15 for both, and we're -- we'll discuss in a little bit, 16 and you can ask a lot of questions, but in 1927, NUREG 17 1927, that will be coming out this springtime sometime, 18 and we will have these aging management programs, these 19 draft ones now, but they will be placed in there, to show 20 how we are going to manage these aging effects.
21 But ultimately, we believe high burnup fuel 22 is safe for storage and for transportation. We have 23 licensed both high burnup fuel for storage and for 24 transportation. Recently, we had the MP-197 that we've 25
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 approved for transportation casks for use of high burnup 1
fuel, okay.
2 We have other research that we're doing 3
right now, at Oak Ridge National Labs, and we also are 4
also working with the Department of Energy for their 5
Cask Demonstration Surveillance Project.
6 We have an information notice on chloride 7
SCC, chloride stress corrosion cracking, I hate to use 8
9 And we're also developing this aging 10 management program that's part of the NUREG 1927 that 11 we can talk about at length if you wish.
12 So in summary, our regulations in 10 CFR 71 13 and 72 ensure safety for both storing and transporting 14 spent nuclear fuel. We have a large group of people who 15 have a multi-disciplinary technical review for all of 16 the different issues that I identified, and we are 17 maintaining confinement under routine and accident 18 scenarios for these canisters.
19 We're going forward with an 20 operations-based aging management program, and it's 21 going to be a learning, proactive, and responsive 22 program for renewals and for aging management.
23 And you can read the rest. We're creating 24 a stable, predictable, and efficient renewal regulatory 25
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 framework, with clear, open, and transparent, reliable, 1
regulatory expectations to the licensees to manage 2
aging.
3 I think that's it.
4 MR. PALMISANO: Good evening. I'm Tom 5
Palmisano, Vice-President and Chief Nuclear Officer for 6
the San Onofre Nuclear Plant.
7 I've seen a number of you before in 8
community engagement panel meetings, and I am going to 9
cover the specific Post-Shutdown Decommissioning 10 Activities Report that we submitted, and summarize 11 what's in the report, talk about the different periods 12 for the decommissioning plan.
13 I'll summarize the Irradiated Fuel 14 Management Plan, and I'll also summarize the 15 Decommissioning Cost Estimate.
16 So before I get into the specific remarks, 17 Southern California Edison and our other co-owners 18 issued some decommissioning principles early this year 19 to provide clarity and guidance in terms of the 20 principles we will follow in developing the plan and 21 executing the plan to decommission San Onofre.
22 Particularly, our principles are safety, 23 stewardship, and engagement -- safety first, safety in 24 terms of all the activities, safe storage of spent fuel; 25
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 stewardship in terms of being good stewards of the 1
environment, good stewards of the decommissioning trust 2
fund, recognizing this fund has been contributed by our 3
rate payers; and engagement and transparency.
4 The Community Engagement Panel, which a 5
number of you have been at the meetings, is part of our 6
effort, our outreach effort, to engage the community, 7
to be transparent in what we intend to do, and to listen 8
actively to feedback.
9 I
would encourage you to visit 10 songscommunity.com. All the documents I am going to 11 discuss tonight have been posted throughout the course 12 of the last six months on songscommunity.com, so they're 13 not only available on the NRC website, but they're 14 readily available on our website, along with more 15 detail.
16 So just to recap, you've seen some of these 17 time frames before in the NRC presentations. June of 18 2013, we decided to permanently shut down both units 2 19 and 3. We certified permanent cessation of operations, 20 one of the regulatory requirements.
21 We also at that point certified we had 22 permanently defueled. The dates, I didn't put those 23 dates on this slide, they were on the NRC's slide.
24 Through the course of 2013, we transitioned 25
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 from operating plant staffing to decommissioning 1
staffing, and in January 2014, we developed a 20 year 2
decommissioning plan that we submitted as part of the 3
Post-Shutdown Decommissioning Activities Report.
4 As you've heard, by NRC regulations, we 5
have up to 60 years to complete the radiological 6
decommissioning of the plant.
7 As we look at the situation at San Onofre, 8
as we listen to feedback from our stakeholders, as we 9
look at where our trust fund is, we think the right thing 10 to do is to go into the prompt decontamination and 11 dismantlement process and decommission the plant in 12 basically a 20 year time period, and I'll show you a 13 little more detail in a minute.
14 And then in September 2014, we submitted 15 the required decommissioning documents, the 16 Post-Shutdown Decommissioning Activities Report, the 17 Irradiated Fuel Management
- Plan, and the 18 Decommissioning Cost Estimate.
19 So let me give you the highlights here.
20 Those of you who have been at the Community Engagement 21 Panel meeting have seen this slide before. This is a 22 simple look at the 20 year timeline for decommissioning 23 the plant.
24 The top line is not to scale. To the left 25
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 of the bold vertical line is between now and January 1
2016, so we are not in the major decommissioning phase 2
at this point. We need to submit the NRC documents we 3
have done. So everything we're doing to the left of 4
that line is planning and preparatory activities, and 5
the licensing submittals to change our design and 6
licensing basis.
7 There's a variety of physical plant changes 8
we make such as defueling the plant, draining systems, 9
eliminating non-radioactive hazards.
10 There's the licensing submittals, this was 11 referred to as some of the other licensing actions we've 12 requested, for example defuel technical specifications 13 that changes the conditions of the license to match the 14 fact that the plants are defueled; the specific 15 decommissioning submittals that I've talked about; and 16 then the dry fuel storage system.
17 I am going to talk about dry fuel storage 18 more in a minute. We already have a system on site with 19 50 canisters loaded with fuel that needs to be expanded 20 to allow for the decommissioning process.
21 So we're in the process, and we've 22 discussed this extensively at the Community Engagement 23 Panel, of selecting the best plan to expand the system 24 and load the remaining canisters.
25
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Then to the right of the heavy bold line is 1
actually the
- balance, first of
- all, of the 2
decontamination and dismantle period. It's about a ten 3
year period where we do the major decontamination and 4
dismantlement, and then farther to the right, you see 5
words like completion of remaining site restoration 6
work -- that's the non-radiological site restoration, 7
as well as the License Termination Plan.
8 On the NRC slides you saw, that's the formal 9
process where we submit the License Termination Plan, 10 submit the Final Survey Plan, and execute that plan 11 subject to NRC review and approval.
12 And then at the end of that 20 year period, 13 the plant is decommissioned, it's dismantled. What 14 will remain is an independent spent fuel storage 15 installation, and that will remain until the Department 16 of Energy starts taking fuel off the site, and we'll see 17 more about that in a minute.
18 Post-Shutdown Decommissioning Activities 19 Report, we've heard a lot about that, so I'll just 20 summarize this very quickly.
21 We have submitted a report that meets the 22 regulatory requirements. It describes the planned 23 decommissioning activities. It provides the schedule 24 for the activities. It summarizes the expected cost.
25
50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And it has the discussion of the environmental impacts 1
and concludes that our planned decommissioning 2
activities are bounded by the site-specific 3
environmental assessments that exist and the NRC's 4
generic Environmental Impact Statement for 5
decommissioning.
6 So our Post-Shutdown Decommissioning 7
Activities Report meets the regulatory requirements.
8 It is under review by the NRC.
9 So I want to go in a little more depth in 10 terms of what the three elements of the PSDAR are. The 11 license termination, and that is equivalent to 12 radiological decommissioning; the used fuel management 13 program; and site restoration, think about that as the 14 non-radiological decommissioning to finish restoring 15 the site.
16 This next graphic is just a bit hard to see.
17 This actually runs out to 2052. I am going to show you 18 more detail that's more readable here in a minute.
19 The green is going to be the license 20 termination
- periods, or the radiological 21 decommissioning periods; the orange in the middle, or 22 the yellow in the middle, is actually the used fuel 23 management periods that will go through the first 20 24 years and then extend out as far as 2052; and then the 25
51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 red is the site restoration period, think about this as 1
the non-radiological decommissioning, once the NRC 2
aspects of decommissioning are complete.
3 So we've created some graphics based on 4
some feedback from the public and the Community 5
Engagement Panel to try to make this a little more 6
visible.
7 Again, all these slides will be publically 8
available on our websites, and I'm sure the NRC will post 9
these as well.
10 So, and I've also tried to indicate the time 11 periods and the types of activities.
12 So we're talking about license termination 13 or radiological decommissioning on this slide. If you 14 look from the left, June 2013-December 2013 defueling 15 both reactors, certifying the reactors were defueled.
16 We're actually in Period 2 now, where we're 17 doing the initial planning. And the initial planning 18 is essentially complete, it's relatively high-level 19 planning, and we're making the NRC submittals.
20 So this is the initial planning phase where 21 we identify what the 20 year decommissioning plan is, 22 the expected cost, and the summary of the activities.
23 Once we enter the major decommissioning 24 phase, which we are not in, starting as early as July 25
52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 of 2015, we'll start major decommissioning activities.
1 This will be system decontamination to 2
reduce the radioactivity's level inside systems. This 3
will be starting the planning, and then as we get into 4
later in the period, removing the internals of the 5
reactor vessel. This, other than the fuel, is the most 6
radioactive part of the plant, done underwater. This 7
is done early in the process.
8 This would be something 2017, late 2016, 9
2017, would be a rough timeline for that to start.
10 And later in this period, and I'll talk 11 about spent fuel more in a minute, we will be offloading 12 the spent fuel pools, actually moving fuel likely in the 13 2017 time frame to an expanded ISFSI (phonetic) system.
14 Period 4, then, once the fuel pools are 15 offloaded, we'll get into the system-enlarged component 16 removal. At this point, we've reduced the level of 17 radioactivity in the plant, we've moved the fuel out of 18 the spent fool pools into the ISFSI or dry fuel storage 19 system, and then we'll start removing the major 20 components inside those reactor containment buildings 21 and the other safety-related buildings.
22 At the end of that period, then, October 23 2022 - July 2024, we're in a period where we're 24 decontaminating the buildings, once the internals have 25
53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 been removed, and ultimately in Period 6, 2024 to 2032, 1
we're actually demolishing the buildings themselves.
2 So that's roughly what a 20 year plan from 3
2013 to 2032 looks like, for the radiological 4
decommissioning of San Onofre.
5 Let me move on to used fuel or spent fuel 6
storage. So this is a companion timeline. Again, 7
we're in the planning period. We're now in Period 2.
8 We're evaluating how to expand the independent spent 9
fuel storage installation, preparing for the transfer 10 of used fuel from the spent fuel pools to the ISFSI.
11 This period for spent fool management runs 12 from 2014 to 2019. Our intent is to safely move spent 13 fuel out of the spent fuel pools to the dry fuel storage 14 pad in a safe and timely manner. We intend to finish 15 that by mid-2019.
16 The following period you see, 2019 to 2031.
17 This is an extended storage period where all the spent 18 fuel is in dry fuel storage on the independent spent fuel 19 storage pad.
20 Period 4, we're expecting the Department of 21 Energy, at some point, to start taking fuel off our site 22 and other sites around the country. Based on the 23 current information we have from the Department of 24 Energy, the old Unit 1 fuel, which is already partially 25
54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 decommissioning, and all the Unit I fuel is already in 1
the spent fuel system, would be removed first, starting 2
roughly in 2031 through a 2035 time period.
3 And then the Unit 2 and 3 fuel, with what 4
we currently understand the Department of Energy timing 5
would be, would be removed from 2035 to 2049.
6 This is part of a bigger nationwide plan 7
that the Department of Energy has to remove fuel from 8
all the reactor
- sites, operating sites and 9
decommissioning sites.
10 This is where we understand we would be in 11 their queue to remove fuel from San Onofre.
12 And then ultimately, 2049 to 2051, with all 13 the fuel offsite, we would then decontaminate and 14 demolish and remove the independent spent fuel storage 15 installation and go through a second license 16 termination period related to the spent fuel storage 17 system.
18 Site restoration, so think about this as 19 now the non-radiological decommissioning. Again, 20 we're in the planning period. You see a transition to 21 site restoration.
22 We're actually -- the mesa is property on 23 the other side of I-5, not part of the NRC's Part 50 24 license where we have warehouses and storage areas and 25
55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a training building, we're actually removing some 1
buildings there presently.
That's not a
2 decommissioning activity, it's part of turning the 3
facility back to the Navy.
4 You then see Period 3, and this is probably 5
more operative for the power plant itself -- 2019 to 6
2024, you know, consistent with moving fuel out of the 7
spent fuel pools, decontaminating systems, major 8
component removal, we start the engineering for the 9
sub-surface removal, engineering and permitting at that 10 point.
11 And actual sub-surface structure removal 12 is in the time frame 2028 to 2031. This will then follow 13 the major component removal, the major building 14 demolition, and then continue with sub-surface 15 structure removal.
16 I think it's important to note at this 17 point, San Onofre is on land owned by the Department of 18 the Navy. So the power plant itself is under what's 19 called an easement dating from the 1960s which granted 20 the owners the right to build and operate a power plant 21 on the facility.
22 So as we talk about completing 23 decommissioning, we're committed to unrestricted, you 24 know, release for unrestricted use, and you've heard 25
56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 some of what that implies earlier, but ultimately the 1
end use will be determined by the Department of the Navy.
2 So we have some work to do with the 3
Department of the Navy to finalize exactly what their 4
end use is, exactly what condition they would like to 5
leave the -- use to leave the site in.
6 For example, most facilities that have been 7
decommissioned don't necessarily remove every 8
below-grade structure once the radiological 9
decommissioning is complete.
10 So that's something that is up to the 11 Department of the Navy. When I talk about the cost 12 estimate, I'll tell you we've conservatively assumed we 13 remove it all until they specify differently.
14 So this is what the completion then of the 15 site restoration -- you see at the far end the ISFSI 16 demolition.
17 Again, after the fuel is removed from the 18 site by the Department of Energy, the remaining step 19 will be the radiological clean-up of the spent fuel 20 storage installation, followed by the demolition, and 21 then a second licence-termination period.
22 That's a brief summary of what's in the 23 Post-Shutdown Decommissioning Activities Report, I 24 really encourage you go to songscommunity.com and take 25
57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a look at it.
1 We've shared it extensively with the 2
Community Engagement Panel and other interested members 3
of the public, but it's available to everybody.
4 Our Irradiated Fuel Management Plan, it was 5
mentioned that this is not a PSDAR document itself, 6
although it is summarized in the PSDAR and the Cost 7
Estimate. But it's another important submittal.
8 Excuse me.
9 So the current dry fuel storage situation 10 in San Onofre, we already have 50 canisters loaded with 11 fuel. As was mentioned earlier, we have the horizontal 12 NUHOMS systems by AREVA TRANSNUCLEAR -- 50 canisters of 13 fuel, I have one canister of what's called greater than 14 Class C waste from the Unit 1 decommissioning. This is 15 the internals of the reactor vessel.
16 On the upper left, you see a picture of the 17 site, and to the upper left of that, you see a 18 rectangular box. That's where the facility is located.
19 And then on the lower right you see a 20 close-up of the above-ground horizontal system that is 21 currently in use.
22 Our current state on spent fuel storage, on 23 the left side, we have 2,668 fuel assemblies in the two 24 spent fuel pools, roughly 50/50 between Unit 2 and Unit 25
58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 3, right.
1 Below that, you see existing dry fuel 2
storage pad, it has Unit 1, 2, and 3 fuel in 50 canisters, 3
1,187 assemblies.
4 What has to happen, the 2,668 assemblies in 5
the pools called wet storage will be transferred into 6
approximately 100 canisters. The exact number of 7
canisters will be determined once we finalize our 8
decision on which canister design to go with.
9 Those of you who have been at the Community 10 Engagement Panel meetings know that we're looking at a 11 couple alternatives.
12 That's an approximate number of canisters, 13 the number of fuel assemblies is accurate. It also 14 includes 1,115 high burnup assemblies, and you've just 15 heard a bit about high burnup fuel for storage and 16 transportation.
17 So ultimately, we will have roughly 125 to 18 150 canisters, again, depending on the final design, on 19 the independent spent fuel storage pad by mid-2019, 20 awaiting removal by DOE offsite.
21 The Irradiated Fuel Management Plan itself 22 is required by 10 CFR 50.54(bb). Again, there is a 23 specific NRC format, specific NRC content guidelines.
24 It provides a
written notification 25
59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 discussing the plan that's required within two years 1
following permanent cessation of operation, we filed 2
that September 23.
3 It describes the program by which we will 4
manage fuel and funding until the Department of Energy 5
picks it up.
6 Our program is wet storage until 2019, 7
followed by dry storage.
8 I've already given you these numbers --
9 2,668 assemblies in the pools, an assumed start date of 10 Department of Energy taking fuel from the industry of 11 2024, our target removal date from all our fuel off site 12 is 2049.
13 We demonstrate that we have adequate funds 14 already collected and invested in our trust fund for 15 spent fuel management for this period.
16 And it also describes how we're going to 17 maintain the spent fuel pools while they are in service.
18 Moving on to the third NRC document we 19 submitted, it's the Site-Specific Decommissioning Cost 20 Estimate.
21 And you've heard this alluded to, so I just 22 want to summarize this.
23 Again, it's a required filing. This needs 24 to demonstrate that we have adequate funding, 25
60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 principally for radiological decommissioning.
1 Think of this as a companion, then, with the 2
Irradiated Fuel Management Plan that discusses adequate 3
funding for spent fuel management.
4 It also discusses the funding we have 5
available for the non-radiological decommissioning.
6 The NRC's focus is radiological decommissioning, and 7
separately, spent fuel management. Our focus is that 8
as well as site restoration.
9 So the plan discusses the decommissioning 10 plan, describes funding, breaks down costs by the 11 periods that I just showed you briefly, summarizes the 12 things like the cost of services, undistributed cost, 13 and outlines the cost for license termination, spent 14 fuel management, and site restoration.
15 There are some key assumptions. We have 16 developed a very conservative decommissioning cost 17 estimate.
18 And I just want to highlight a couple 19 things, for example, substructure excavation. This 20 gets back to what the Department of the Navy will 21 require.
22 For the cost estimate, we have assumed all 23 the structure has to come out. So we've estimated the 24 cost to assure we have adequate funds if the Navy would 25
61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 like us to remove all the structures in accordance with 1
the amendment, the current easement, we have adequate 2
money to do that.
3 We've assumed the ocean conduits, these are 4
the large pipes that bring intake water and discharge 5
water from the plant into the ocean, that they are 6
removed, and the cost of that is in the cost estimate.
7 For the Unit 1 decommissioning, the State 8
Lands Commission approved a plan to abandon the 9
horizontal conduits in place as more -- a more 10 preferable alternative, as opposed to removing them, 11 form an environmental standpoint.
12 I expect we will have the same treatment for 13 Unit 2 and 3, from a more preferable alternative, but 14 I have not assumed that for cost purposes. I have 15 assumed the cost of removing them completely.
16 And you see some other things in terms of 17 low level waste burial escalation, cost -- consumer 18 price index for the D&D period followed by a higher 19 escalation rate until we demolish the ISFSI.
20 So the real picture here, in 2014 dollars, 21 the total cost estimate down at the lower right is about 22
$4.4 billion, to decommission San Onofre completely, 23 manage spent fuel through 2052 and decommission the 24 independent spent fuel storage installation, and 25
62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 remediate the site in accordance with the current 1
direction of the Department of the Navy.
2 You see the breakdown. The green is 3
actually the radiological decommissioning portion, 4
$2.1 billion.
5 Down at the lower left, the yellow would be 6
$1.276 billion. That is spent fuel management through 7
2052.
8 And then $1 billion for site restoration, 9
the non-radiological cleanup of the site and removal of 10 buildings.
11 As I
mentioned in the stewardship 12 principle, the trust fund is really rate payer money 13 that we have collected and we have invested, and through 14 prudent investment, the fund has grown significantly.
15 We are adequately and fully funded today.
16 Oversight of the trust fund -- it's overseen by a five 17 member committee, two of whom are internal to company, 18 three external, nominated by management, confirmed by 19 the Edison board, and the three external members 20 approved by the PUC.
21 So the fund has good oversight with 22 independence from the PUC, from a regulatory oversight.
23 The NRC, the second bullet, regulates all radiological 24 decommissioning, and the NRC regulates used fuel 25
63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 management.
1 I cannot -- I am limited as to what I can 2
spend on the decommissioning fund from an NRC 3
perspective until the documents we have just filed are 4
reviewed, the 90 day period is elapsed to allow them time 5
to review and comment on it.
6 However, probably more fundamentally, the 7
Public Utility Commission regulates the fund closely.
8 So before monies can be withdrawn out of the fund and 9
used for decommissioning, not only do we satisfy the NRC 10 requirements, we have a Public Utilities Commission 11 process to satisfy as well.
12 And both groups, the NRC and the PUC, will 13 be involved in an ongoing basis in the -- ensuring the 14 fund remains adequate, and then the PUC, making sure the 15 fund is spent prudently.
16 In terms of open communication, public 17 engagement, and education, there is a lot of things 18 we're doing -- I have mentioned the Community Engagement 19 Panel, and everything I have just covered, we have 20 covered in multiple Community Engagement Panel 21 meetings, and it has been posted on the website.
22 We really want this information available 23 to the public, we really welcome questions.
24 We have held decommissioning education 25
64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 fairs. We have had one in the local area. We've got 1
another one coming up in the evening, where members of 2
the public can come in and we talk about 3
decommissioning.
4 We have public walking tours. We have now 5
held two tours, open to the public to sign up, typically 6
ten people.
7 We welcome anybody to come walk through the 8
plant. We stay outside of the protected area, but you 9
get a good view of the plant, and our staff explains our 10 decommissioning plan and the decommissioning process.
11 Private tours for key stakeholders, be they 12 elected officials or other interested parties, as well 13 as a robust website with all this information and more 14
-- and again, we want to make sure we're doing everything 15 we can to communicate openly and listen actively.
16 And with that, I'll close and turn it back 17 to the NRC.
18 FACILITATOR CAMERON: Thank you, Tom.
19 And there's a lot of information, and we're 20 going to go out to you now.
21 And there were some sign-in sheets when you 22 came in. I am going to try to follow those, but you may 23 have a question, you didn't sign up that you wanted to 24 speak, but there is going to be a meeting summary 25
65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 prepared by the NRC that will be on the website, and 1
there will also be the webcast.
2 So let's hear from a few people, and then 3
you've been sitting for a long time, so we'll take a 4
short break then, but you've heard the Community 5
Engagement Panel mentioned, and we have several members 6
here from the Community Engagement Panel.
7 But I am going to go to Dan Stetson first, 8
for some comments from the Panel.
9 MR. STETSON: Thank you very much. My 10 name is Dan Stetson, and I am the secretary for the 11 Community Engagement Panel.
12 I want to once again compliment SONGS, 13 Southern California Edison, for putting it together.
14 We've had quite a number of public meetings where you've 15 been able to come and ask questions, and we welcome 16 those.
17 We've even had continuing workshops at the 18 Ocean Institute where I work on an ongoing basis.
19 A couple of us had the opportunity to come 20 and meet this morning -- David Victor, who is chairman 21 of the CEP, Tim Brown, myself, and we were able to meet 22 with some members of the NRC, and I just wanted to share 23 with you just a couple quick takeaways from that 24 meeting.
25
66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Number one, a big takeaway for me was that 1
the NRC is not going away. They are here with us every 2
step of the way. [Theyre our]There are eyes, [theyre 3
ourthere are] ears, [theyre our]there are inspectors, 4
and they're the ones that are really going to walk us 5
through this entire
- process, through the 6
decommissioning and then also through the continued 7
storage of the fuel there on site.
8 So that process is going to be very 9
important, and we are really looking to them to manage 10 this.
11 Also, as I looked out in that room this 12 morning, I couldn't help but be impressed with the depth 13 of experience of the folks that are there.
14 Quite honestly, they are different than you 15 and I. We think we all speak English, but so much of 16 it comes across as Greek. But I want to thank them for 17 trying to bring it to a level, even this evening, 18 something that we can all really understand.
19 But no matter what, I think we're all really 20 interested in one thing, and that's the ongoing safety 21 for this storage.
22 We know that the fuel is going to be there 23 for an extended period of time. We don't really know 24 how long. We want it out of there as soon as possible.
25
67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 But as Al was saying, none of our cars are 1
going to last for 100 years, and something is going to 2
need to be done if something comes up, so all of us are 3
interested, if the worst case happens, do we have the 4
plan and the resources to take care of us?
5 All of us want to trust, but we need the NRC 6
to validate our trust. Thank you.
7 FACILITATOR CAMERON: Thank you, Dan.
8 Another organization that started very soon after the 9
decision was made to shut the plants down was the 10 Coalition to Decommission San Onofre, and we're going 11 to go to Gene Stone.
12 MR. STONE: Hi. I am Gene Stone from 13 Residents Organized for a Safe Environment. I am also 14 a member of the California Edison CEP, and I am happy 15 to do that and happy to be here tonight.
16 I would like to thank the NRC for hearing 17 our comments today, and I am happy to see so many friends 18 that are here to support this whole process and the 19 environment.
20 I must say that I am not really happy 21 because I no longer believe that California Edison is 22 considering doing the state-of-the-art decommissioning 23 that they promised at the first Community Engagement 24 Panel, nor do I believe that the NRC will demand or 25
68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 require that of them, but, unfortunately, a more 1
standard approach to decommissioning.
2 The NRC should have a more proactive 3
approach to California's PSDAR. The fact that the NRC 4
does not approve or disapprove this minimalist approach 5
to the safe storage of nuclear waste is very 6
disappointing and alarming to me.
7 Going forward with a plan that uses 8
canisters that were designed for short-term storage 9
does not make sense. It seems that we would be better 10 served if the NRC would take a stronger approach in 11 leading the industry into developing a much more robust 12 canister system with defense in depth, not just talking 13 about defense in depth, but real action items that the 14 public can see that will help us in any situation that 15 might arise.
16 Thank you very much.
17 (Applause.)
18 FACILITATOR CAMERON: Okay, thank you.
19 Okay. And we're going to try to get to you, as many of 20 you, as possible.
21 And unfortunately, it is just going to be 22 one bite at the apple, so to speak, okay.
23 And if you have a question, you may want --
24 we can give you a follow-up on that, and the NRC has also 25
69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 told me that besides the comments that are going to come 1
in, the written comments, that if you send a question 2
into them, that they will try to answer that question.
3 So if you don't get a chance tonight, we'll 4
do that. And let's go to Donna Gilmore. Donna?
5 MS. GILMORE: Hi. I have been studying 6
the issue, and what Gene said is correct.
7 We do not have a defense in depth system.
8 We have 5/8s inch thick stainless steel that's the only 9
thing keeping us from having a radiological accident 10 that could result in us evacuating.
11 The canisters are subject to something 12 called stress corrosion cracking. We do not know, of 13 any of the canisters that are currently at San Onofre, 14 we don't know if they have corrosion on them, we don't 15 know if they have stress corrosion cracking, because 16 they haven't looked at any of them, it's too dangerous 17 for the workers to do that.
18 The canisters cannot be repaired. We're 19 looking at potentially replacing canisters. There's 20 no money in the decommissioning fund for replacing 21 canisters.
22 There are canisters used in Europe and 23 other countries that are much thicker, up to 20 inches 24 thick, that were designed for maintenance, that were 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 designed to be able to replace them, when and if they 1
wear out, and the ones we have are welded, weren't 2
designed being opened.
3 Their part of the plan is to get rid of the 4
pools. If we needed to replace a canister, we need the 5
pools, but the NRC plans to allow them to get rid of them.
6 So yeah, I am not happy with this plan. I 7
have got a website, sanonofresafety.org, and I have been 8
keeping track of this. Everything is resourced with 9
technical documents.
10 There was a lot of misinformation in the 11 presentations, a
lot of half-truths in the 12 presentations, so I encourage you to check the 13 sanonofresafety website to learn the part that was left 14 out of this meeting. Thank you.
15 (Applause.)
16 FACILITATOR CAMERON: Thank you, thank you 17 Donna. Let's go to Rochelle, Rochelle Becker.
18 MS. BECKER: I'd like to frame my comments 19 on several NRC regulations that you pointed out that 20 you're going to follow in this process.
21 The problem with you pointing out that you 22 have NRC regulations, policies, processes, is a recent 23 OIG report that said that didn't work when you replaced 24 the steam generators.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So I have no idea why we're supposed to 1
trust you with the back end of the nuclear industry.
2 You didn't do the job right. You didn't 3
require a license amendment request. We are sitting in 4
the Public Utilities Commission trying to decide how 5
much Edison gets, how much rate payers get back.
6 Rate payers are disgusted with this 7
process. When the NRC fails, it is my wallet that this 8
money comes out of, not yours.
9 When Edison fails, they try to argue that 10 shareholders deserve more money than rate payers. Rate 11 payers have very little input in this process. Rate 12 payers pay virtually every penny of this process.
13 We are very tired of you telling us you have 14 a policy, a procedure, a process that works. You don't.
15 And we don't know that until it fails, and when it fails, 16 we pay, and we're tired of doing so.
17 (Applause.)
18 FACILITATOR CAMERON:
And Marnie 19 (phonetic)?
20 MS. MAGDAGLICKMAN: Thank you, I don't 21 even know where to begin.
22 I have the Environmental Impact Report here 23 that hasn't even been talked about, that anyone who 24 reads it knows that it has to be old information. It 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 can't possibly be what we know today about the hazards 1
for San Onofre becoming a long-term nuclear waste dump.
2 I am asking so much that you, both in Edison 3
and our Nuclear Regulatory Commission, actually get 4
involved with not passing the buck, not saying it's not 5
our fault, we just have to stick to what we have as our 6
possibilities.
7 I see that the regulation on the 8
re-licensing these casks that now can't even possibly 9
last with salt corrosion on the ocean as long as you're 10 going to allow them to stay there, even if it's the 11 minimum of 40 years.
12 It's not until spring that your 1927 13 regulation is going to talk about how we even take care 14 of the process of checking these. We know now we don't 15 have a way to.
16 I am asking for leadership at all levels and 17 changes of the law. We can't leave that fuel on the 18 ocean. It has to be moved. The fact that this plan is 19 backwards, it is decommissioning the contamination that 20 most of us could survive first, with our $2 billion.
21 They've changed even the term so that it 22 seems like it's more important. None of us care if 23 those domes go away.
24 We've gotten used to seeing them. We're 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 not going near them. Leave them and leave the money in 1
the rate payers trust fund until all the fuel is off of 2
location, somewhere away from the ocean. It is 3
dangerous every day.
4 We have both security that I ask you to look 5
for. You say you can't approve, but you do get to 6
choose, you get to give waivers. Don't reduce the 7
security.
8 Force an inspection of the 50 casks already 9
there. Don't change the rate payer trust fund 10 priority. Leave all $4 billion until all the fuel is 11 gone.
12 And please, make sure that we don't lose 13 priority in the government, DOE, coming to get our fuel 14 by some way of Edison and the DOE changing the priority.
15 We need your help. We need our 16 legislators' help. Let's get it moved to a place in the 17 desert, away from the ocean, having the DoD help us get 18 it there now, tomorrow. Thank you.
19 (Applause.)
20 FACILITATOR CAMERON: Thank you, Marnie.
21 We're going to go to Cathy Allen.
22 MS. ALLEN: Good evening. My name is 23 Cathy Allen. I work at Age Well Senior Services in 24 south Orange County.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We serve approximately 400,000 seniors 1
annually in south Orange County, and I have -- on behalf 2
of them, I have a two part question for the NRC.
3 What is the NRC's process over time that 4
there are enough funds available to maintain the dry 5
cask storage on site indefinitely until the DOE resolves 6
the regulatory issue?
7 What frequency do you perform an analysis, 8
and what is the level of effort?
9 Thank you.
10 FACILITATOR CAMERON: When you say "level 11 of effort," can you just explain that a little bit?
12 MS. ALLEN: The level of effort for your 13 analysis.
14 FACILITATOR CAMERON: Okay. Do you 15 understand the question, Larry?
16 MR. CAMPER: I was just going to say, is it 17 financial analysis?
18 FACILITATOR CAMERON: Okay. So we're 19 talking about finances. Can we -- who wants to give a 20
-- okay, this is Mike Dusaniwskyj. Mike?
21 MR. DUSANIWSKYJ: Good evening. My name 22 is Michael Dusaniwskyj. I am an economist with the 23 Nuclear Regulatory Commission, and I am charged with 24 making sure that the kind of question that the last 25
75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 question raised is my responsibility and my team's 1
responsibility, to ascertain the reasonableness that 2
there will be enough funds to decommission and to take 3
care of spent nuclear fuel for the foreseeable future.
4 The point that must be remembered is that 5
the spent fuel is really the property of the Department 6
of Energy.
7 Once it leaves the San Onofre Nuclear 8
Generating Station's footprint, it is no longer in the 9
custody of the licensee.
10 Until that time, there is enough funds to 11 take care of the foreseeable future. Now, as far as 12 what the lady is asking, is what happens beyond a certain 13 period of time, I will be frank and honest with you.
14 Whatever possibilities may happen into the 15 future, which all of us can postulate their own 16 possibilities, we have to reason only with what is 17 reasonable to what is required by the regulations, and 18 what the Department of Energy's foreseeable future is 19 in stake.
20 I am going to have to say something you are 21 not going to like, and that is the fact that if you 22 postulate some possibilities that the funds do run out, 23 the solutions will not be popular. The financial 24 solutions will not be popular.
25
76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 But the point that must be remembered is 1
that the NRC does not regulate commerce. That is under 2
the jurisdiction of the state Public Utility 3
Commission, and it is our responsibility to make sure 4
that all activities are done safely and completely.
5 And we recognize that safety takes money.
6 Therefore, the NRC will not compromise on any level the 7
safety of taking care of the decommissioning and the 8
spent fuel nuclear -- excuse me, the spent fuel that's 9
on site.
10 As far as how often we do the analysis, by 11 regulation the licensees have to submit to us certain 12 financial information that we look at to make sure that 13 the foreseeable forecast is reasonable.
14 We want to make sure that the money is used 15 exclusively for decommissioning. We check this once a 16 year.
17 We also check on how much money is left. We 18 keep checking on this until the license is terminated.
19 FACILITATOR CAMERON: Okay, thank you.
20 Thank you for that question.
21 I am going to go to this gentleman here, 22 this gentleman here, and then to Ace and Sharon Hoffman, 23 and then we're going to take a break and come back. Yes, 24 sir.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 PARTICIPANT: Thank you. In regards to 1
the economic analysis you're performing, I want to know 2
if the NRC, and you specifically sir that just answered 3
the question, have you taken into account that recently 4
at Diablo Canyon, you found the conditions for stress 5
corrosion cracking after only two years in the task?
6 And you certified these, the NRC certified 7
these, that they would be good for 30 years.
8 Now, my guess is, sir, that that two years 9
takes your analysis and puts it on its head. And I want 10 to know if you've considered that.
11 Furthermore, Tom, you've got some stones, 12 talking about the California Public Utility Commission 13 with all the news in the paper today about how they're 14 under investigation, and how they're submitting all 15 their paperwork. Really?
16 Now, as far as the car analysis goes, the 17 casks that you guys are considering won't crack for --
18 excuse me, the casks that you won't consider won't crack 19 in a marine environment.
20 Again, the casks that you guys are refusing 21 to consider have the ability to be repaired. Everybody 22 wants to repair their car. We also want the casks to 23 be repaired.
24 The casks that you are not considering do 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 not have the ability to inspect the exterior of the 1
canister.
2 You're saying that the industry has to come 3
up with the solution in five years, but the NRC has given 4
time and time again extensions to these kinds of rules.
5 We want it done now before it is approved.
6 You guys, or the NRC, excuse me -- the casks that you 7
guys are not considering do not have an early warning 8
system before a radiation leak, i.e., you have no oil 9
light for your car.
10 That's a major problem. You're expecting 11 the public to accept the fact that you're going to go 12 around and kick the tires on the car to ensure that 13 there's some sort of integrity. That's a joke.
14 FACILITATOR CAMERON: I am going to have to 15 ask you to finish up, sir.
16 PARTICIPANT: Thank you.
17 (Applause.)
18 FACILITATOR CAMERON: All right. Let me 19
-- is Val (phonetic) here?
20 Oh, good, Val tries to keep control of Local 21
- 89.
22 MR. MACEDO: Thank you, sir.
23 Yes, that is not a hard task to do, is take 24 care of Local 89. Local 89 has been taking care of the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 power plant for many years.
1 Local 89 was involved in the process since 2
day one. Unit 1, Unit 2 -- decommissioning of Unit 1 3
as
- well, and then the building before the 4
decommissioning of Unit 1 of the Units 2 and 3.
5 With that being said, I just want to start 6
off by saying thank you for allowing me to be a part of 7
the Community Engagement Panel, it's been an education 8
for me to better represent my members.
9 I hate to use the word my members -- Local 10 89's membership, because I've heard different opinions 11 from both sides, and I respect everybody, and I've heard 12 a lot of safety concerns come into play.
13 My background, in the early 90s I was 14 involved in the decommissioning of a uranium enriched 15
-- U-235 enriched uranium processing plant in Sorrento 16 Valley.
17 Of course, NRC was involved, Bechtel was 18 the contract at the time.
19 So I'm very familiar with the 20 decommissioning process at that scale. This is a much 21 larger scale. I am thankful to be a part of the CEP 22 panel.
23 I want to disclose something here. For 24 years, for years, Southern California Edison has a huge 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 amount of respect for me, for the safety that has been 1
put in place for our membership, for allowing me to be 2
a part of the CEP panel -- it goes beyond that, as far 3
as safety goes.
4 Local 89 has engaged in training. A lot of 5
the members here, that are here today, don't have orange 6
shirts on. There is no need to try to control the 7
membership.
8 They are honest people. They are rate 9
payers that built the power plant, that have the same 10 voice as other people, and we're going to continue to 11 respect everybody.
12 Those members that have been laid off, lost 13 their jobs, because of the power plant going down, it's 14 understandable.
15 But make no mistake, these members have 16 gone through a serious curriculum in terms of training, 17 on a daily basis, we have a large training facility, we 18 have mobile sites, for not only Southern California 19 Edison San Onofre decommissioning, but other 20 contractors and other sectors of the market as well.
21 And I just want to say that I'm very 22 thankful for the professionals to put all the 23 information together, for allowing us to be a part of 24 the process.
25
81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And let's give these members back their 1
jobs. These professionals are disclosing full-on 2
information that's beneficial to the safety and the 3
decommissioning of this project, and I ask that you vote 4
and get this thing going, and let's put these people back 5
to work.
6 And let's continue to have SCE allow 7
whichever vendor, whichever contractor steps up to the 8
plate and becomes the awarding body for the 9
decommissioning project to follow the safety process 10 that it's had for years and make sure that all of our 11 members, and anybody else that joins whichever union 12 that goes into the decommissioning of this project, that 13 allows them to go home safe to their families.
14 I thank you for the opportunity to speak.
15 (Applause.)
16 FACILITATOR CAMERON: Thank you, Val.
17 And thank you very much, and we're going to 18 hear from Gary Headrick. We're going to go to Ace and 19 Sharon. And we're going to take a break quick for ten 20 minutes, and we're going to keep going. Gary?
21 MR. HEADRICK: Thank you. Can you hear 22 me? There we go. My name is Gary Headrick, founder of 23 San Clemente Green, and we've been concerned about our 24 safety ever since being contacted by some of the great 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 workers at San Onofre, who we have a lot of respect and 1
concern for.
2 Just one note about Val, I -- you know, we 3
had a conversation shortly after the plant was announced 4
to be shut down, and Val was concerned that the NR --
5 that he was being reassigned to fight fires when he 6
hadn't been trained to do that in a radiological 7
environment, but I think he's since been trained, so I 8
am glad that's happened.
9 But the point I want to make about what I've 10 heard tonight is, actually, the most encouraging words 11 I've heard is that you're trying to keep ahead of this.
12 You are recognizing that you are not ahead 13 of this issue about how we are going to deal with the 14 nuclear waste on site, and deal with it safely, and I 15 appreciate that.
16 But the problem is, we're still rushing 17 ahead to this -- expedite this decommissioning thing, 18 which we all want to see happen as quick as possible, 19 but we all agree that it has to be as safe as possible.
20 And I believe that you need to seriously 21 look at this problem longer, and not play word games 22 about whether you approve it or not.
23 You are the regulators. You make the 24 regulations. And you're also guilty of making 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 exemptions for regulations whenever the industry wants 1
it, and that's a real problem you have to get over if 2
you want to earn the public's trust.
3 So I'm appealing to Tom Palmisano, who I 4
appreciate and respect in depth. I think Edison is the 5
one who we can thank for having shut down the nuclear 6
power plant and done the responsible thing when the NRC 7
did not step in and do -- prevent them from restarting 8
a broken reactor without fixing it first.
9 You know, so Tom, please, give us some time.
10 Let's look at that more sturdy cask system. Let's not 11 rush into this, regardless of what the NRC decides.
12 We need you to do the right thing, and we're 13 putting a lot of faith in you. We've got to get this 14 right. Thank you.
15 (Applause.)
16 FACILITATOR CAMERON: Thanks, Gary.
17 And Ace, why don't you come here so that 18 they can get you on the camera? Okay, go ahead.
19 MR. HOFFMAN: I agree that the people who 20 worked at that plant were good all along.
21 I've been fighting them for 20 years. I've 22 never had a problem at any of these meetings. Nobody 23 has ever come up to me and said anything nasty or mean.
24 I think you're all good people.
25
84 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And if we decommission that plant right 1
now, one of them is going to die, on average, because 2
of the difference in the amount of radiation that 3
they're going to be exposed to. And I wonder if they're 4
ready to pick which one of them it's going to be, or 5
whether it's going to be a multitude of them that are 6
going to get some kind of cancer.
7 Now that is what is going to happen, because 8
the NRC's own statistics say that there's going to be 9
a couple hundred rem dosage if we do it now, and it's 10 only going to be a couple dozen rem if we do it later.
11 So I'd like to see us wait. But what I'd 12 really like to talk about is that 5/8ths inch thick 13 protection against a -- that's the radiological barrier 14 for the next 60 years, is that 5/8ths inch stainless 15 steel.
16 The 3 to 5 inches of concrete is virtually 17 irrelevant because it's designed with vents, so if 18 something gets in there and damages the casks, we are 19 going to have a problem.
20 ISIS is training six year old kids to be 21 suicidal terrorists. ISIS is interested in a 22 multi-generational attack against America. ISIS is 23 producing videos in which they are recruiting people in 24 order to attack America.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Now, Tom, I am sure that you are aware that 1
there are many, many weapons that can go through 5/8ths 2
inches of steel. This is a multitude of them.
3 We have to protect that plant better. We 4
can't pretend that this -- that just because we're no 5
longer a nuclear power plant, that we're no longer a 6
target.
7 We are most definitely a target because of 8
where we are and who we are, and because of our freedoms, 9
and because we can have a meeting like this. This makes 10 us vulnerable.
11 So you have to consider not just the things 12 that they tell you to consider, but everything that your 13 heart tells you to consider.
14 That's really all I have to say, this is 15 practically the last meeting that we're going to need 16 to attend here.
17 And I want to thank all of the workers at 18 San Onofre. I don't believe any one of them did a bad 19 job.
20 (Applause.)
21 FACILITATOR CAMERON: Thanks Ace, and last 22 commenter before the break is Sharon.
23 MS. HOFFMAN: Good evening everybody, and 24 thank you for giving me an opportunity to speak tonight.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I have a few questions.
1 The first question is really kind of 2
simple. Does anybody have the ability to say no? In 3
a business environment, there's a big difference 4
between the people who can say yes and the people who 5
can say no.
6 And I didn't hear anybody from the NRC say 7
I am the guy, I can say no, I can say stop, I can say 8
we need more information.
9 And I think that's important. Somebody 10 should be able to say no.
11 I also want to say to the gentleman who 12 spoke about the finances that realistically, assuming 13 that the DOE is going to take all the fuel from San Onofre 14 by 2052 is not realistic.
15 If you look back to 1988, say, we would have 16 said all that fuel that has already been accumulated 17 would be gone by now. And it's not. So let's be more 18 realistic than that.
19 And last but not least, let's not be in a 20 rush to put this fuel into casks. It -- keeping it in 21 the pools gives us an opportunity to observe it, gives 22 us -- gives SCE and the NRC the opportunity to learn 23 something about the aging of casks.
24 We're talking about leaving fuel in casks 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 for hundreds if not thousands of years, and we have no 1
experience in that. So what's the rush? Thank you.
2 (Applause.)
3 FACILITATOR CAMERON: Okay, thank you, 4
Sharon. Let's come back around, let's come back around 5
five to 8:00, that's like seven or eight minutes, and 6
we'll get started down here, okay, and we'll keep going.
7 Thank you.
8 (Whereupon, the meeting went off the record 9
at 7:48 and resumed shortly thereafter.)
10 FACILITATOR CAMERON: All right. Are you 11 ready, are you ready to go? And please introduce 12 yourself.
13 MS. JOHNSTON: Hello. My name is Chris 14 Johnston. I thank you all for coming, and I want to 15 believe that your safety recommendation is number one.
16 And I'm concerned about our community, I'm 17 concerned about eight and a half million people.
18 I would not want to be sitting in your 19 shoes. You have a very grave responsibility before 20 you.
21 I have concerns about the canisters, as 22 other people have expressed -- the NUHOMS canister 23 that's 5/8ths inch thick, that you have done some salt 24 spray testing on at Diablo Canyon, and found stress 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 corrosion cracking.
1 And we are talking about atmospheric 2
corrosion here at San Onofre. So deeply concerned that 3
these casks, these canisters, are not going to withstand 4
atmospheric pressure.
5 And beyond that, I'm also wondering, and I 6
believe this is a question for Al, regarding the seismic 7
rating for cracked canisters. Can you answer that?
8 MR. CSONTOS: Can you hear me?
9 MS. JOHNSTON: Yes.
10 MR. CSONTOS: All right, first of all, let 11 me get to your -- one point you mentioned about seeing 12 stress corrosion cracking at Diablo, it has not 13 happened, okay?
14 MS. JOHNSTON: It has the potentiality to 15 happen.
16 MR. CSONTOS: There are chlorides there, 17 okay?
18 MS. JOHNSTON: Yes.
19 MR. CSONTOS: There were chlorides that 20 were found at Calvert Cliffs, there were chlorides that 21 were found at Hope Creek, as well.
22 They were on brackish water. Diablo is 23 right there, that's the coast.
24 That's one of the reasons why the EPRI went 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 ahead and did that analysis, or went ahead and had 1
volunteer sites -- these three were volunteers, okay.
2 They didn't need to do it, they weren't required to do 3
it, they just volunteered to do it, okay?
4 So that showed a lot of stewardship on their 5
part, to do that.
6 Now, about two weeks ago -- all right, so 7
about July, we held a public meeting. We went out there 8
and showed our cards, and we said, this is the Aging 9
Management Program that we want for stainless steel 10 canisters, period, okay?
11 That required inspections, that required 12 operational experience evaluations, that inquired --
13 that required corrective actions, quality assurance, 14 all that, okay?
15 Two, let's see here, about -- that meeting 16 was, after that meeting there was another meeting on 17 chloride stress corrosion cracking. And I know several 18 folks were on that phone call, okay?
19 That meeting went very long. We were 20 kicked out of the room because we had so many questions, 21 which is great.
22 I talked to Donna after that meeting about 23 these issues. That meeting was the prelude to the 24 report that EPRI was about to provide. Now that report 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 was published two weeks ago.
1 MS. JOHNSTON: I read it, yes.
2 MR. CSONTOS: No, that's a different one, 3
I think it -- the Flaw Evaluation and Growth 4
Calculations, have you heard of that one?
5 MS. JOHNSTON: No.
6 MR. CSONTOS: Let me give that to you. You 7
can go to the EPRI's website, and I am going to pull that 8
up here.
9 Oh, it's back here. It's report number 10 3002002785. Do you want me to repeat that?
11 MS. JOHNSTON: Yes. I, I, yes, it's okay, 12 I will be watching the -- she's got it.
13 MR. CSONTOS: So -- so in that report they 14 did a calculation, a much more sophisticated 15 calculation than what we had intended to do, where we 16 just did a quick calc, okay, for Calvert in specific.
17 Now what they evaluated is they looked at 18 all the conditions, they went to the Camp Pendleton --
19 is it Pendleton? -- Pendleton site here, and they pulled 20 out all the information on the atmospherics, the 21 weather, and everything.
22 Pulled out some of the calcs that they did, 23 were very, were very sophisticated based on that.
24 Their worst case scenario, okay, this is --
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there's two, you've got to remember, there's two, two 1
-- two stages of stress corrosion cracking for 2
3 There's the incubation period, where you 4
get all the environments, you get all the conditions 5
that could start cracking, okay.
6 Then you have the actual crack growth.
7 Okay, there's two stages -- incubation plus initiation, 8
and then crack growth.
9 They just only looked at crack growth.
10 They did not look at how long it would take to get to 11 that stage, because just having chlorides there is not 12 sufficient to have cracking to start, okay?
13 You need to be in a relative humidity 14 environment, you need to have the material conditions, 15 you need to have a lot of things that have to play out 16 to get this to start cracking.
17 We raised this issue nearly nine, ten years 18 ago. We're at the stage now where we're trying to act 19 on it.
20 The calcs that came out, okay, and I'm going 21 to give these numbers to you -- for ambient plus 15 22 degrees, that means 70 degrees plus 15 degrees Celsius, 23 so that's about what, 20, 25 degrees Fahrenheit, roughly 24
-- to get a 50 percent through-wall crack, this is just 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 not assuming how long it takes to start, to get the 1
incubation period to begin, that could take years to 2
decades, okay -- you have 18.2 years, okay, by their 3
calcs, to go through-wall of a half-inch thick canister.
4 To go through-wall, completely 5
through-wall, it's 60 years, over 60 years, okay. To 6
go 75 percent through-wall it's about 40 years.
7 Okay, now if you take it to the 5/8ths inch 8
canister, you're talking about, worst case now, worst 9
case, 28 years to go halfway through wall, and to go full 10 through wall, over 86 years.
11 So I want you to understand that this is the 12
-- we're, we're trying to get ahead of this. That is 13 what I am trying to say.
14 MS. JOHNSTON: What is your defense in 15 depth, in that case, if it does happen?
16 MR. CSONTOS: If it does happen, you know, 17 this is why we're doing the inspections, okay?
18 MS. JOHNSTON: How can you inspect 19 canisters that can't be inspected?
20 MR. CSONTOS: Well, you mentioned that 21 they already did inspections at Diablo, and I mentioned 22 Hope Creek, and I mentioned the volunteer inspections 23 there.
24 There are also Calvert Cliffs, the 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inspection for their license renewal, Oconee and Surry 1
did as well. Those are visual exams --
2 MS. JOHNSTON: Okay, you're saying you can 3
go all around the canisters and you can see everything, 4
every potential crack?
5 MR. CSONTOS: So -- part of what, well, 6
what we do here, and that's where in the meeting that 7
we had that was back in that July time frame, we talked 8
about a Koeberg plant, that was a South African plant, 9
Donna, you showed me that slide that I showed you 10 earlier, or that we had at that meeting.
11 The Koeberg plant had cracking in a 304 tank 12 and a pipe, okay?
13 And they went ahead and inspected, and they 14 repaired it. So there are repair technologies, and we 15 have seen inspection technologies that are out there, 16 okay?
17 MS. JOHNSTON: Okay, now back to the final 18 question, is the seismic -- the seismic rating for 19 cracked canisters back to --
20 MR. CSONTOS: So we did a calc on that --
21 FACILITATOR CAMERON: Thank you, Chris.
22 Seismic.
23 MR. CSONTOS: -- so let me talk about the 24 calc on seismic, all right.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 What San Onofre did is they analyzed to six 1
G's, which is ten times what their design basis was for 2
for this 1029 system.
3 We went ahead and analyzed for the loads 4
that would occur for the six G's, so that's ten times 5
what a earthquake would be here for, what the 6
design-basis earthquake, okay, ten times that.
7 You would have to lose over 80 percent of 8
the entire canister thickness, the entire canister 9
thickness, before you would have any issues, okay, for 10 a ten time seismic.
11 That's the robustness in this design.
12 That is what I am trying to get across, that this design 13 and these systems are so over-designed for these types 14 of conditions.
15 Now, yes, you know, we don't want to ever 16 get to a crack that is 75 percent through-wall.
17 That's why we're doing this inspection.
18 That's why we're doing these aging management plans.
19 That's why we're trying to get ahead of this, okay?
20 The first -- the renewal for San Onofre will 21 be in 2023, okay? 2023 is right around the corner.
22 At that time, we will inspect, probably the 23 worst -- the worst, in terms of our environmental, our, 24 you know, evaluation.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 EPRI, that's the Electric Power Research 1
Institute, that did this Flaw Evaluation Study, is doing 2
a compendium that's coming out this year sometime.
3 That's looking at the environmental 4
factors, the prioritization. And from that, we're 5
going to prioritize which canisters, how we can focus 6
our inspections on a specific canister, okay?
7 At that time, that's what we're going to be 8
doing for -- by the time that San Onofre comes around, 9
this technology will have been used.
10 We have put into the Calvert Cliffs 11 renewal, we have put in there what they need to be able 12 to inspect, okay, within the three years.
13 FACILITATOR CAMERON: Okay, thank you.
14 And we did get an extension until 20 after 9:00, okay, 15 so we have some more time, but one other suggestion is, 16 and this all depends on Al's goodwill and schedule and 17 all that stuff, but we need to be out of this room by 18 20 after 9:00, but there's no reason why you can't have 19 an informal conference with Al out there somewhere, 20 okay?
21 So I am glad you are not listening, Al, 22 because I got you committed. Okay, great.
23 Let's go to Kevin, Kevin Blanch, back here, 24 and then we're going to spend some time here, go to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Richard McPherson, we'll go over that side of the room.
1 Kevin, go ahead.
2 MR. BLANCH: Well, I want to first say that 3
the NRC, which I call you guys the Nuclear Rallying 4
Cheerleaders, I don't want any of you to take this 5
personal, what I'm about to say.
6 I would be more than happy, I am staying at 7
the hotel, to sit down and have a beer with any one of 8
you, and I'll even buy, because we always buy.
9 I have been fighting San Onofre since I was 10 a little boy. I was given two months to live three years 11 ago. My father was nuked to death in the Nevada test 12 site from Pendleton. I have been anti-nuclear.
13 I want to ask this simple question to the 14 NRC, and again, do not take this personally, I call you 15 the Nuclear Rallying Cheerleaders.
16 You have no Congressional powers 17 whatsoever, none. You are the Nuclear Regulatory 18 Commission. You are not the executive branch, you are 19 not the legislative branch, you are not the judicial 20 branch, none of the above.
21 Congress makes law, not you. And when you 22 come out and slide in and say oh, we're turning America 23 into America Toxic. We are going to take every one of 24 these catastrophes, which is the biggest mistake in 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 human history called nuclearism and turn them into 1
official nuclear waste dump sites.
2 Only Congress has that ability to do that, 3
not you. Not the NRC. I know Allison. I am glad 4
Allison resigned, and hopefully on November 4th, maybe 5
Harry Reid, who is protected from putting this monster 6
in Yucca Mountain, which Congress was promised to put 7
in Yucca Mountain.
8 I sat right here in the 60s and listened to 9
these same ridiculous conversations about what we're 10 going to do with the waste, where we're going to put it.
11 That stuff needs to come off that cliff 12 yesterday. San Onofre is the poster-child for 13 everything wrong with the nuclear industry. It is a 14 catastrophe, and if it was up to the Nuclear Rallying 15 Cheerleaders, it was all the grassrooters.
16 And I would like to say thank you, and get 17 this into the public domain, to the grassroot activists 18 in Southern California.
19 I live in Utah, which you parked the 20 generator in my backyard, illegally.
21 I would like to say thanks to Gene, Ace, all 22 these people that have fought this tooth and nail. It 23 was us as grassrooters that exposed the lies that was 24 going on by PG&E, the great crimes against humanity.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 You protected them. The lie on the 1
exchange of the generator, these crimes against 2
humanity that were taking place -- you are not Congress.
3 Yucca Mountain is a bad idea. Shooting it 4
into space is a bad idea. But I'll tell you what's 5
really a bad idea. Nuclear. Building a nuclear site 6
on a cliff, on the most beautiful beach in the world, 7
on a cliff, and then storing the waste there for 40 years 8
when it's not built to dispose of the waste.
9 Dry cask is a catastrophe, it's a pathetic, 10 stupid idea. Yes, Yucca Mountain is pathetic, but 11 Congress passed Yucca Mountain. You're not Congress.
12 Ship it to Yucca Mountain. Yeah, I know 13 that's a horrible debate and Congress can't get anything 14 done, but we still have a Constitution. And it was 15 approved and passed to be in Yucca Mountain decades ago.
16 And Harry Reid blocks it. Yeah, I 17 understand. Born and raised at Yucca Mountain, he has 18 to get elected, his power.
19 But again, don't take this, any of it, 20 personally, but I consider the NRC to be nothing but a 21 group of criminals who protect other criminals.
22 San Onofre are criminals, period, period.
23 What they pulled on the exchange, the crimes against 24 humanity -- nuclear fallout is leukemia. My father 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 died of it, and now I'm fighting for my life with it.
1 So many are.
2 That stuff needs to come off that cliff 3
before we get an earthquake. Dry cask, whatever you 4
will -- not stay there. It is a catastrophe, ticking 5
time bomb. Thank you.
6 (Applause.)
7 FACILITATOR CAMERON: Okay, Kevin.
8 We're going to go to Alan.
9 MR. WOO: My name is Alan Woo. I am with 10 the Asian Pacific Planning Council of Orange County.
11 I used to be chair of the Low Income 12 Oversight Board with the CPUC. So I understand a little 13 about the rate payer and what regulatory agencies kind 14 of look at.
15 I could kind of appreciate Southern 16 California Edison though, in making a decision to stop 17 operation.
18 They did that voluntary. There might have 19 been some encouragement, but nevertheless, here we are, 20 right? We're closed, we shut it down, we're trying to 21 come up with a plan to contain it, store it, and then 22 go forward as those policies that the federal government 23 has to yet come into place.
24 Something has to be done now because I did 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a calculation when 2052 would be, that's 38 years from 1
now.
2 I may not be around, and maybe most of you 3
guys are not going to be around, and most of the 4
activists here won't be around too, but we leave in place 5
what we start today.
6 And I could appreciate that you thought 7
about inspections, you thought about containment, you 8
thought about storage, you thought about all these 9
things, and that each one of you pledged that you are 10 going to become good stewards in terms of making sure 11 of the future.
12 So at least now, I could see the faces of 13 people who are committed to doing something to 14 decommissioning it in a responsible way, to contain this 15 situation that we have, and to move forward.
16 I don't know what's going to happen in 38, 17 40 years, who may be sitting up there, if there is 18 anyone, whether anyone cares in Washington, or 19 whatever.
20 But I know today, you know, there's people 21 in the community that cares.
22 I know that we have a utility company that 23 cares and has been transparent, and has been talking to 24 us in the community about the impact on us, and you had 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a lot of workers here who need to go back to work who 1
know and care how to clean up this thing.
2 So that's all I'd like to say, I just think 3
that you presented a large plan here, it covers every 4
area including environmental impact, we just got to see, 5
if we don't start now, and we postpone it, you know, you 6
are just postponing a problem and you're not getting 7
started.
8 FACILITATOR CAMERON: Thank you, Alan.
9 Donia?
10 MS. MOORE: Good evening. My name is 11 Donia Moore, I am with the San Clemente Chamber of 12 Commerce.
13 I'd like to thank the NRC and Edison for 14 having this forum and allowing us to speak here.
15 I am aware, of course, as you've discussed 16 often tonight, that the NRC gave Edison 60 years to do 17 the decommissioning process, and they voluntarily 18 decided to do it on a 20 year timeline, which I think 19 is very commendable.
20 And I understand the need to remove the 21 waste that's being stored currently at San Onofre.
22 However, I have a question, and that is that 23 one of the things that hasn't really come up much is 24 that, as I understand it, it's actually the federal 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 government that is the body that is giving permission 1
to remove the waste, and as where to put it, and there's 2
no repository at this moment.
3 And I haven't heard anything about when 4
there will be a repository to remove the waste to, so 5
it's great to talk about removing the nuclear waste, but 6
how are we going to do that if we don't have any place 7
to store it?
8 And as I understand it, that's up to the 9
federal government, is that correct?
10 FACILITATOR CAMERON: Should we go to 11 Keith McConnell for a little bit of history on this?
12 This is Keith McConnell, who is the Director of the Waste 13 Confidence Directorate who did the Environmental Impact 14 Statement and Rulemaking called Continued Storage.
15 But Keith, do you want to provide some 16 information to Donia on that?
17 MR. MCCONNELL: Yes, it is the Department 18 of Energy's responsibility to manage the disposition of 19 spent nuclear fuel from all the power plants across the 20 country.
21 The Department of Energy's most recent 22 issuance in terms of a repository was put out in January 23 of 2013.
24 What they envisioned at that time was a 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 stage process where there would be a pilot effort to take 1
the spent fuel to a centralized interim storage 2
facility, and then there would be a full scale interim 3
storage fuel facility in the 2020, mid-2020s time frame.
4 And then a process where they would go 5
through and solicit interest in development of a 6
geological repository other than Yucca Mountain.
7 And that's all in this strategy that they 8
issued in 2013. Now there is legislation required to 9
allow that strategy to proceed, and it also depends on 10 community involvement and state involvement in terms of 11 looking for a repository.
12 But that repository would not be available 13 until the 2048 time frame, and that ties into the 14 presentation that San Onofre gave today.
15 Does that help?
16 MS. MOORE: Yes, thank you, it does.
17 FACILITATOR CAMERON: Thank you, Keith.
18 And let's go to Heather and Steve, and then we're going 19 to go to Richard, and then we'll go over to Ray and 20 everybody over there. Heather?
21 MS. JOHNSTON: My name is Heather 22 Johnston, I am the Executive Director of the Dana Point 23 Chamber of Commerce.
24 And I am interested in more of the process, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 so my question is, is what will be the daily 1
responsibilities of the NRC resident inspector? How 2
are their activities changed as the project progresses?
3 And how are you going to communicate that to the 4
community and to our local businesses?
5 MR. KELLAR: I think that's probably a 6
question for me.
7 There is currently a senior resident on 8
site. That person stayed on site after San Onofre had 9
shut down.
10 Long-term, that position will not be there, 11 day-to-day, but will be a regional-based inspector that 12 will be in concert, or not in concert, but in contact 13 with the licensee, and they will be aware of any of the 14 higher risk activities as well as the activities that 15 the licensee is undertaking.
16 So the resident inspector will not be 17 there, but the inspector from the region, the teams and 18 the individuals will be going out and performing the 19 inspections, particularly based on the higher-risk 20 activities.
21 Now, what I mean by that is, as the licensee 22 prepares to move the fuel from the spent fuel pool to 23 the ISFSI, that would be a higher-risk activity. Some 24 of the dismantlement of the different systems that had 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 radiation and radioactivity would also be a higher risk 1
activity.
2 So we would have inspectors that would be 3
there and watch those higher risk activities, as well 4
as, I tried to explain during the presentation, there 5
are certain aspects of the day-to-day operations that 6
also are inspected on a routine basis, such as the 7
organization of the licensee, how they maintain the 8
business, how they perform their audits, how they 9
perform their self-evaluations.
10 All those are looked at, and they're 11 planned in advance, and the inspection teams would go 12 out and inspect those, as well as the higher-risk 13 activities.
14 MS. JOHNSTON: Thank you.
15 MR. KELLAR: You're welcome.
16 FACILITATOR CAMERON: Okay. Is this 17 Laurie (phonetic)? Okay, why don't we stop here. Go 18 ahead.
19 PARTICIPANT: Hi. I would like to ask the 20 question of this gentleman on the end here, okay.
21 The gentleman on the end here made a 22 statement about dose rates, and you said that you 23 compared it to background radiation in certain areas of 24 the world.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And I just wanted to state that what's in 1
the casks there at San Onofre is not background 2
radiation, it's the most dangerous manmade 3
radionuclides in the world. And you can't compare that 4
to background.
5 And if the rest of the NRC stands behind 6
that statement, then that's a criminal act.
7 FACILITATOR CAMERON: And you're talking 8
about Mr. Camper on the end? Larry, do you want to 9
clarify anything on that one?
10 MR. CAMPER: Yes, I will. Thank you for 11 the question.
12 What I was trying to do was to draw a 13 comparison as to what it means in our standard that we 14 require.
15 When that site is ultimately 16 decommissioned, it has to meet that dose standard to be 17 released, and that's 25 millirem and ALARA.
18 What I was trying to give some perspective 19 on what is 25 millirem, because a lot of folks look at 20 that and they say, well, what is 25 millirem?
21 So I was trying to draw a comparison. If 22 you get on an airplane and you fly to New York, it's three 23 millirem. The natural background radiation in the 24 United States, as I said, is 300 to 600 millirem, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 depending on where you are.
1 I agree -- I beg your pardon?
2 PARTICIPANT:
That's not massive 3
radiation.
4 MR. CAMPER: Oh, I agree with that, I agree 5
with your point fully. If you're saying that there's 6
a dose -- I'm sorry?
7 PARTICIPANT: The problem at San Onofre is 8
not the background radiation.
9 MR. CAMPER: Oh, I agree with you fully, 10 it's not background radiation. Of course it's not.
11 FACILITATOR CAMERON: Okay. Sounds like 12 there's some agreement here, but let's let Larry finish, 13 and then we're going to go to some other people, thank 14 you, Laurie. Larry?
15 MR. CAMPER: No, I agree with you that it's 16 not background radiation. I was simply trying to draw 17 some reference to what 25 millirem meant when that site 18 is decommissioned to satisfy that dose standard.
19 FACILITATOR CAMERON: Okay. Steve?
20 MR. ADAMS: I am Steve Adams (phonetic), a 21 resident in Laguna Niguel.
22 And reading through the report, I had a 23 question, couple of questions.
24 The term "islanding" of the pool, the spent 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 fuel pools, was used, and I'm not clear on what islanding 1
would be in those pools.
2 And then my next question is based on 3
listening to some of the previous commentations. Is it 4
safer for the spent fuel to be in pools, or is it safer 5
for it to be in the casks that are proposed right now?
6 FACILITATOR CAMERON: Well those are good 7
questions. And who would like to take the islanding on?
8 MR. PALMISANO: So let me take that on, 9
because I think that came off our slides.
10 FACILITATOR CAMERON: Okay.
11 MR. PALMISANO: That is a term that refers 12 to taking the current spent fuel pool cooling system 13 which are installed plant equipment that will be taken 14 out of service.
15 When we say "islanding," that means putting 16 in dedicated standalone cooling systems for the spent 17 fuel pools. So we essentially island it and separate 18 it from, disconnect it from the rest of the installed 19 plant equipment. That's what the term islanding means.
20 FACILITATOR CAMERON: Okay. And does 21 anybody want to talk to the question that's been 22 percolating for a while now about is it safer in pools 23 or dry storage? Doug?
24 MR. BROADDUS: So, the -- our requirements 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 are that both processes have to be safe, and so we 1
consider them, and we've looked at them in the past, you 2
know, to see, is there benefits one way or the other?
3 And there was recent -- there was a recent 4
study that was actually put up to the Commission, to our 5
Commission, to see whether there was a need for 6
theretheir to be an expedited transfer of fuel from the 7
spent fuel pools to dry cask storage.
8 And the determination was that there is no 9
real benefit from that standpoint to do it in an 10 expedited manner, so to get in there sooner.
11 In some cases, you can't actually take the 12 fuel and put it into spent -- in dry cask storage, within 13
-- until after a certain amount of time, because it just 14 can't get into the casks, the casks can't handle the 15 amount of heat that's going to be generated by that, so 16 it has to stay in the spent fuel pools.
17 But the spent fuel pools are builtbuild to 18 be very -- very rugged structures that are going to 19 withstand the same seismic types of loads and such that 20 the casks would have to be able to withstand as well, 21 to be able to dissipate the heat in the same manner as 22 the casks would, but just through a different process.
23 They're dissipating it through the water 24 that they're in, whereas the casks are dissipating it 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 through the transfer into the air, or the atmosphere 1
that's within the casks themselves. So it's a 2
different process.
3 (Off mic question.)
4 FACILITATOR CAMERON: Let me -- let me 5
just, this will be the last question, but go ahead.
6 MR. ADAMS: No, I was referring to the 7
comment that was made about, like, a terrorist attack.
8 Is it being in a pool, is that safer than being encased 9
in stainless steel and concrete?
10 MR. BROADDUS: All right, so, from the 11 standpoint of terrorist attacks, obviously with -- you 12 can't quantify, it's very difficult to quantify what 13 type of a terrorist attack has to occur.
14 So what we've tried to do, and what we've 15 done, is establish what's called a design-basis threat, 16 and that's a threat that has been established to provide 17 assurance, very high assurance, of that they're going 18 to be able to, the licensee would be able to thwart an 19 adversary coming in to, and then attacking it.
20 So that's what the -- from a terrorist 21 standpoint, our defense in depth is to ensure that they 22 have a good strong security program to ensure that the 23 terrorists are not going to be successful in whatever 24 attack that they would do.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 FACILITATOR CAMERON: Okay, thank you, 1
thank you for that. Richard McPherson.
2 MR. MCPHERSON: Good evening. I hear a 3
lot of negative information, about 90 percent of the 4
people are talking negatively about nuclear power, 5
something they don't really know about.
6 50 years ago, I suited up in NICs (phonetic) 7 for the first time, and I participated in a defueling 8
of a reactor and a refueling of a reactor.
9 And I have been involved in that process 10 ever since. I was even selected to represent the United 11 States at the International Atomic Energy Agency for 12 four years on something called Nuclear Fuel Cycle 13 Facilities, which is the front end and the back end, the 14 environment and public opinion.
15 And I have now been involved for almost 51 16 years in nuclear power. I have little or no concerns 17 over what you are presenting here because I've seen it 18 presented so many times, and I've seen it be successful.
19 It's unfortunate that there's so much 20 misinformation out there and there's so much 21 misinformation that's generated on purpose to cause 22 fear in people.
23 But as an operator of five nuclear power 24 plants, and I've been involved in refuelings and been 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 involved in the back end of the fuel cycle since, a lot, 1
since 1992, I appreciate everything you are saying and 2
doing and I think we're going to be safe.
3 Thank you very much.
4 (Applause.)
5 FACILITATOR CAMERON: Yes, sir.
6 MR. GARDNER: Yeah. GoodGod evening, I'm 7
Richard Gardner (phonetic) from Capistrano Beach.
8 I feel that the process is in place to lead 9
us to a safe condition, even though I think I agree with 10 everyone that getting the spent fuel out of the, off the 11 site and in a permanent repository would probably be the 12 long-term benefit, and that's not in your hands.
13 What I am here to suggest is that the San 14 Onofre Nuclear Generating Station should be re-purposed 15 into a reverse osmosis drinking water facility, at least 16 for the intake structures and the turbine buildings.
17 And I believe that, you know, without 18 actually doing the, you know, preliminary design, that 19 it would be easy to have 50 million gallons a day, or 20 100 million gallons a day.
21 And that water would be provided, and it 22 would be adequate supplies for the Marine Corps that 23 live on the base, and also it would satisfy the demands 24 of at least 25 percent of south Orange County, which 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 goes, which covers a great distance.
1 So I think that's a much higher and more 2
important use, considering if this drought does not --
3 if we don't get some rain pretty soon, we could be 4
drawing Lake Mead down, and we may be in a position where 5
we would have hundreds of thousands, if not millions, 6
of people dependent on a water source that isn't there.
7 So that's why I think it would be best if 8
there was a planning, a planning facility where we would 9
look at a contingency of converting or re-purposing the 10 plant, and doing it in a way that the transition could 11 occur, to whoever the third party is, and it could be 12 Southern Cal Edison but it could be anyone else, and that 13 the discussions with the Navy happen immediately so that 14 we could save Southern Cal Edison over $130 million for 15 the demo of the turbine buildings alone, and we would 16 save the water authority another $100 million for the 17 new facilities.
18 And you know, the plant here in Carlsbad is 19 costing $1 billion for an RO plant to produce 50 million 20 gallons a day.
21 So we could have that, and I think we should 22 begin to focus on that's more important than many of the 23 things that we are now concerned about that are 24 hypothetical.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So if anyone can figure out how to get 1
through the right departments within the federal 2
government and in the state, to think about how it 3
affects Southern Cal Edison's planning process, I would 4
like to be actively involved. Thank you.
5 FACILITATOR CAMERON: Okay, thank you.
6 Let's go over here to, let's go to Ray. And then we'll 7
go to --
8 MR. LUTZ: Okay, hello, my name is Ray 9
Lutz, I am with citizensoversight.org.
10 I wanted to bring up some of the things that 11 concern the public about the process and where we are 12 today.
13 I am one of those that are very happy that 14 the plant is shut down. I don't think that nuclear 15 power is a good idea, I don't think that it's safe to 16 have all this waste around.
17 That's the definition, the non-definition 18 of green. If you have a whole bunch of waste at the end, 19 it's not green energy.
20 And we have a whole bunch, 3.2 million 21 pounds of highly radioactive waste that we've got to 22 deal with now.
23 The problem is that it almost seems like 24 we're seat-of-the-pants operation here. Almost 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 nothing has been really planned ahead -- you say, we've 1
decommissioned all these other plants, but we really 2
don't really have a solution for this fuel, still.
3 It's really not a good plan yet. And no one 4
is sitting here saying, here is our plan for the next 5
ten, twenty, thirty years. There is no plan. All we 6
got is here. That's the end of the plan, a foreseeable 7
future.
8 You say, for the foreseeable -- what the 9
hell is that? What is a foreseeable future? Ten 10 years? Is that it? Is that the foreseeable future for 11 the NRC? 20 years? I mean, what is foreseeable?
12 Because right now the only plan is leave it 13 here on the coast. Edison doesn't have a plan for the 14 next ten years, the next place. Everybody is pointing 15 fingers. The Department of Energy's responsibility, 16 not us.
17 NRC, we don't even have to approve the damn 18 plan. It's not our responsibility. If it goes south, 19 eh, we didn't approve it. That was their problem, 20 because we have a way out, we've covered our butts. We 21 don't have to approve the plan.
22 Who came up with this? Who came up with the 23 fact that the actual license amendment process is at the 24 very end? When everything is done, we finally talk 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 about whether we should approve it.
1 Like, in 50 years from now, we're going to 2
talk about what we did was 50 years ago, was okay.
3 The NRC is all backwards. You have the 4
license amendment for the termination at the very, very 5
end, instead of doing it -- why did they do that? And 6
it's because they said, oh, there's going to be some 7
activists that are going to be out there and they're 8
going to put blocks in what we're doing, so I'll tell 9
you what, let's put the license termination plan at the 10 very end, so that no one can block it.
11 That's where we are now. The NRC doesn't 12 even have to approve it.
13 Seat-of-the-pants operation, no approval, 14 no long-term or even 10, 20 year plan. These are all 15 big problems in our minds.
16 The fact that the license termination is at 17 the very end of the process. It should have been now.
18 And you're saying we don't have to approve it.
19 My proposal is, you are going to have to 20 work around this system. Stop pointing fingers at the 21 Department of Energy.
22 Southern California Edison, thank you for 23 shutting it down. Now you need to do your part by 24 planning, here is what we are going to do with the fuel 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 over the next twenty, thirty years. Make a plan. It's 1
not going to be perfect, but at least get it started.
2 NRC, do your part by approving this plan.
3 I don't care if they say it's not your, you can't approve 4
it -- do it anyway. Say, we are approving this, and 5
you're putting your butt on the line.
6 And I expect you to be able to say we're not 7
approving it, and Southern California Edison will 8
cooperate. And they'll say, you know what, you guys 9
haven't approved it yet, there are some problems?
10 We're going to fix those. I know Tom Palmisano would 11 love to do that. He would love to fix any problems that 12 you've got.
13 So don't say, oh, it's the end of the clock 14
-- we're not done yet, but go ahead. Make sure that 15 everything is done, all the i's are dotted and all the 16 t's are crossed.
17 I think it's right. You know, this thing 18 about the fuel pools, the guy just asked, he's not here 19 anymore. That study that you said, oh, it's the 20 expediting the fuel out of the fuel pools into the dry 21 casks -- the only reason they said that was because of 22 cost.
23 That wasn't because of a safety issue, and 24 the whole system that you guys use at the NRC is screwed 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 up because you start with the cost analysis before 1
you've ever gotten done with the first, the safety 2
analysis. They jump right away into the -- whether it's 3
cost effective or not.
4 And so that's why they came up with that.
5 It probably is better to put them in the dry casks.
6 Let's face it. If you have a terrorist attack, the fuel 7
pools are not as safe as a dry cask. And that should 8
be the answer.
9 Sir, you answered that? Your answer 10 should be, the fuel pools are not as safe as a dry cask 11 in a terrorist attack.
12 You know, you've got to say something -- you 13 think they're just equally as safe? Is there an answer?
14 MR. BROADDUS: I explained that it's the 15 design-basis threat, and the licensee has to protect 16 against the design-basis threat, and regardless of 17 whether they are attacking the spent fuel pools or 18 they're attacking the casks, they have to be able to 19 thwart, they have to be able to thwart the adversary --
20 FACILITATOR CAMERON: Okay.
21 MR. BROADDUS: So it -- and prevent the 22 attack from being successful --
23 FACILITATOR CAMERON: Thank you.
24 MR. BROADDUS: -- so it doesn't matter 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 where they attack.
1 FACILITATOR CAMERON: All right. Ed.
2 DR. SIEGEL: Yeah, hi, my name is Dr.
3 Edward Siegel (phonetic), a graduate of Berkeley, 4
Michigan, Michigan State, MIT, Westinghouse Combustion 5
Engineering GE, PSEG, and the IAEA, many years. Son of 6
Sidney Siegel, co-director of Oak Ridge in the 7
beginning.
8 What I heard today is summarized best by a 9
Harry Belafonte lyric, "It was clear as mud but it 10 covered the ground."
11 One of the problems that occurs is in this 12 document, which I just got from someone here, which I 13 presume is available, my goodness, people at Southwest 14 Research Institute found that alloy composition 15 dominates things. That's in the scientific literature 16 from the 50s.
17 People like Sidney Siegel, or, you know, my 18 father, Alvin Weinberg, director of Oak Ridge, fired for 19 doubting allow safety, embrittlement in nuclear plants, 20 around 1970.
21 What is San Onofre? It's a crime scene.
22 What's the crime? Well, if I ripped off one of you for 23
$5.3 billion, I'd be in prison forever, even after I was 24 dead.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So the question that has to be asked is what 1
happened? The surfers at San Onofre, which I'm too fat 2
and old to be one of, for thirty years wanted the 3
reactors removed.
4 So what's the rush? And by the way, what 5
happened in San Onofre isn't the worst thing. There's 6
an old paperback about a meltdown, like Fukushima --
7 that would mean evacuation of Riverside, San Diego, and 8
Orange County for centuries. It would bankrupt the 9
United States if no one is killed, and that's a big "if."
10 Who did it? Well, I don't know.
11 Certainly Southern California Edison had something to 12 do with it -- they crushed EPRI, EPRI is their public 13 relations arm. I was interviewed by Chauncey Starr 14 (phonetic) and Ed Zebrowski (phonetic), and when they 15 heard about alloy 182 weld embrittlement, they were 16 horrified, I was on an interview.
17 They didn't hire me. I worked for a nasty 18 Jewish P-R-I-C-K named Hyman Rickober (phonetic) -- he 19 wasn't just afraid of Soviets, he was afraid of 20 everyone, he was paranoid schizophrenic. He knew what 21 he was doing. He won the Cold War from us, as this 22 fellow from the nuclear Navy can attest.
23 I have two books I'd just like to bring to 24 people's attention, and by the way, if you want to find 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 out about me, Google "A-N-N-A Mayo, If Leaks Could 1
Kill," and if you want to find an article by me, go to 2
flickr.com and put in the word "giant 3
magneto-resistance read page 312."
4 This is a book on fractography. What you 5
do is you look at things with a microscope, just like 6
a crime scene where someone is murdered, and you see what 7
you see.
8 Once it's put away in Idaho, they'll never 9
find it again. It has to be examined here. Why?
10 Because there's $5.3 billion in bills we're going to 11 have to pay. Who is going to pay them?
12 My feeling about nuclear fuel is that 13 people who produce it should eat it for dinner, and the 14 Securities and Exchange Commission is watching very 15 carefully.
16 Lastly, in closing, a very interesting book 17 which you all can buy online -- it's called De re 18 metallica, I'll show you the front page, you can buy it 19 from Dover for 30 dollars, by Georgius Agricola, it's 20 the first book on metallurgy.
21 It talks about why Roman -- you see, there's 22 nothing needed, you don't need anything hard in a 23 nuclear reactor, any woman knows this, your cuticles 24 when you're skiing -- hard things are brittle, they 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 breakbrink.
1 You're not machining with a nuclear 2
reactor, or nuclear weapons, or jet engines.
3 De re metallica, translated by Herbert 4
Clark Hoover, President of the United States --
5 publication date is interesting, 1550, half a 6
millennium ago. Hard things break. Roman swords 7
which stab through Hebrew and bronze shields, and Greek, 8
broke, because they were brittle.
9 Why doesn't DOE, where the sins come from 10
-- NRC shouldn't be badly blamed -- I'm, my thinking is 11 Soviet sabotage, when I was a little boy.
12 Not my father or Alvin Weinberg, not Eugene 13 Wigner who founded it -- I have some names, I've been 14 looking at this for 40 years.
15 How come the NRC, but especially DOE, the 16 only person doing anything in the DOE is Lofaro, look 17 up anything by Robert Lofaro, alloy embrittlement 18 mitigation -- and what happened at San Onofre may have 19 saved us from a much worse thing, core meltdown.
20 But why should we pay for it? If someone 21 would like to pay my part of the stranded costs, I'll 22 give you my name, if anyone wants to give me a business 23 card, I can email you lots of stuff. Thank you.
24 FACILITATOR CAMERON: Okay, thank you.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Thank you, Ed.
1 (Applause.)
2 Yes, sir.
3 MR. JOHNSON: Thank you. Roger Johnson, 4
San Clemente.
5 Earlier this evening you showed a slide, I 6
think it was slide 20, on which you listed the reasons 7
why this plan should be denied.
8 One of the reasons was that it would 9
endanger public health and safety. And I think this 10 plan does endanger public health and safety.
11 And I think a lot of other people do too, 12 and one of the things that has been ignored in your 13 report, and it's been touched on here briefly, I'd like 14 to focus on this, is terrorism.
15 The National Academy of Sciences was very 16 concerned about this. In 2006, they wrote a report 17 called Safety and Security of Commercial Spent Nuclear 18 Fuel Storage, and they addressed the whole report on 19 that.
20 I noticed on slide 38, you ignored 21 terrorism. You listed all the possible things that 22 could go wrong, and you ignored terrorism.
23 One of the first things that the National 24 Academy of Sciences said is that nearly all the studies 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on the dangers of nuclear power plants focus on 1
accidents related to equipment failure, and they 2
completely ignore some of the other ones.
3 So after 9/11, terrorism became a reality.
4 So here are a few things that they said. They say, 5
attacks, this is page 35, attacks by a knowledgeable 6
terrorist with access to advanced weapons might cause 7
considerable physical damage to spent nuclear plants.
8 Then they go on to point out the U.S.
9 commercial nuclear power plants are not required by the 10 NRC to defend against air attacks, that's page 31.
11 They go on to say that nuclear power plants 12 are not designed to resist external terror attacks.
13 There are currently no requirements in place to defend 14 against large-scale terrorist attacks.
15 Then they go on to say, this committee, the 16 National Academy of Sciences, judges that some attacks 17 involving aircraft would be feasible and could be 18 carried out, and a zirconium cladding fire would melt 19 the fuel pellets, could release some of the 20 radionuclides in the atmosphere, and could be 21 transported hundreds of miles downwind.
22 Some of the other observations about dry 23 casks. Dry casks were designed to ensure storage, they 24 were not designed to resist terrorist attacks.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 And when they talk about fuel pools, they 1
said, "This Commission concludes that there are 2
scenarios that could lead to partial failure of the 3
spent fuel pool walls, thereby resulting in partial or 4
complete loss of fuel pool coolant."
5 So it goes on and on, and the one other thing 6
they noticed is that a problem with terrorism is they're 7
site specific, and the NRC has come up with this generic 8
plan, which means that all plants are equal.
9 So it does not recognize that you have 10 chosen to store waste on earthquake faults in a tsunami 11 zone, in the middle of metropolitan areas, and in an area 12 which is easily accessible by terrorists, it's two or 13 three hundred feet from public highways, any truck bomb 14 could go in there.
15 The Commission also said that to defend 16 against truck bombs, you needed to have at least 400 feet 17 of setback. Old Pacific Highway is 300 feet, anybody 18 can drive and park there and blow up a truck bomb.
19 There's hardly a day in the week when truck bombs don't 20 go off somewhere in the world.
21 So this is a very dangerous site that you've 22 chosen, and I think one thing that you should -- should 23 be considered, and is not being considered, is that this 24 is meant to be a temporary long-term, an oxymoron, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 storage facility, and if you're going to store it 1
long-term temporary, let's store it long-term temporary 2
somewhere else, like in a remote region where it's safe.
3 You don't need a permanent solution.
4 (Applause.)
5 FACILITATOR CAMERON: Thank you, thank you 6
Roger. We're going to go over to this side of the room, 7
and we'll be coming back to you.
8 But let's -- let's go to Dan. Dan?
9 MR. DOMINGUEZ: My name is Daniel 10 Dominguez, I am the Chief Officer for the local union 11 that represents the maintenance and operators at the 12 plant.
13 I'll keep my statements short. I have 14 worked at the plant for 32 years, 25 years as a reactor 15 operator, and of those 32 years, my primary goal was to 16 operate -- was to protect the health and safety of the 17 public, and in the process, generate electricity for the 18 benefit of society.
19 There has been a lot of talk. I want to 20 cover one point is that in my 32 years, I have had lots 21 and lots of interaction with the NRC.
22 And in my interactions, I've always found 23 them very professional, and I've always found them that 24 they had the same goal that I had, which was to protect 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the health and safety of the public.
1 When the gentleman, I forget who it was that 2
said they put no price on safety, they do not put a price 3
on safety. I can attest to that. That's been my 4
experience.
5 And finally, the question about whether 6
it's safer in the pool or safer in the ISFSI. For the 7
last 15 years I've monitored the ISFSI pad, and it is 8
safer in the ISFSI. Thank you.
9 FACILITATOR CAMERON: Okay, thanks Dan.
10 We're going to go to Patricia and Reuben, and Carlos, 11 we're coming back to you, I didn't forget.
12 MS. BORCHMANN: Thank you. My name is 13 Patricia Borchmann, I live in Escondido.
14 I am concerned about the safety of this 15 proposed decommissioning plan that Edison has prepared, 16 and they are trying to expedite, and, you know, make it 17 appear as if it's no, not going to be any problem, or 18 nothing has been overlooked, or nothing has -- there are 19 no unforeseen risks.
20 I disagree. I think that a lot of the 21 technical comments that have been made are very 22 credible, and I think -- well, I think arguments on both 23 sides have been made that are very technical and very 24 credible, so if I understand there's a dilemma, and, you 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 know, the job is not finished.
1 But what I would like to emphasize is that 2
you have the authority right now, there's nothing 3
holding you back -- you don't have to wait 90 days to 4
-- until this 90 day limit is up, to ask for additional 5
information. You have that authority right now.
6 And I think that based on the concerns that 7
have been presented at your Community Engagement Panel 8
through the series of public meetings held by Southern 9
California Edison and their technical experts, there 10 has been plenty of technical, highly technical, 11 incredible concerns raised that aren't covered in 12 Edison's plan.
13 Edison -- you know, NRC, you are saying, as 14 a lot of people have said, they put no -- there is no 15 cost placed, there is no price limit placed on safety.
16 I agree with that, because Edison, Edison 17 is supposed to be the one absorbing the cost issues, and 18 they're not. This plan they prepared is the shortcut, 19 walk-away, cheapest possible method. And it's not good 20 enough for southern California.
21 And there's no reason that -- I don't think 22 people realize, you know, they have better options, that 23 are used internationally, that provide the kind of 24 protections that this densely populated area deserves.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Thank you.
1 (Applause.)
2 FACILITATOR CAMERON: Thanks, Patricia.
3 And Reuben?
4 MR. FRANCO: Thanks, Chip.
5 Thank you all for letting me speak here 6
today. I am Reuben Franco, I am the President and CEO 7
of the Orange County Hispanic Chamber of Commerce, and 8
I live in south Orange County.
9 Given that we have a lack of leadership in 10 Washington for any long-term solution to the problem of 11 long-term storage, it's my belief that moving the spent 12 fuel like the plan suggests, from the fuel -- from the 13 pool to the cask storage, would be a lot better solution, 14 a lot safer solution, and hopefully we can move down that 15 road.
16 So I'd like to thank Edison and the NRC and 17 the employees there for doing their part and trying to 18 come to a solution to this and a resolution, so thank 19 you.
20 (Applause.)
21 FACILITATOR CAMERON: Thank you, Reuben.
22 And let's go to this gentleman right here, 23 and then we'll go over to Carlos, and then I'm going to 24 see if I can find some people.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. ALDINGER: Thank you.
1 Hi, my name is Karl Aldinger. I am a 2
concerned citizen from Fallbrook.
3 My question is, will there be a contingency 4
plan for when, inevitably, a cask cracks or fractured?
5 I know Mr. Csontos, you mentioned the 6
ability to weld them. It appears to me that that's the 7
way these are formed in the first place. You create the 8
container, insert the fuel, weld it, so naturally, you 9
should be able to weld up any problems you have.
10 Has the commission planning process 11 considered having additional storage containers 12 manufactured ahead of time so if we do have a 13 catastrophic failure, you're not standing there looking 14 around for who is going to create this thing that could 15 take five years to create?
16 We've seen, in the past, it takes an 17 enormous amount of time to build stuff that you guys 18 require.
19 Our steam generators took five, seven 20 years, and I don't expect these containers to take that 21 long, but who knows what situation we're in 40 years from 22 now. It may not be that easy for us to get more of those, 23 and so it may make sense to try to procure those now.
24 I wanted to point out that Hanford and WIPP 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 both indicate that a failure to plan for contingency 1
creates a toxic mess that's very hard, if not 2
impossible, to attend to quickly.
3 So I hope that, in your thinking, that it's 4
not we build the casks, we build the cement surrounding, 5
and then we pray. I hope that there's an easy way to 6
clean up any problem that you do determine, that there 7
is made with a cask -- that you've thought about this 8
ahead of time and said, it's okay, we've got this.
9 We're not going to send in troops for four or seven 10 months to go slowly clean up a mess.
11 In talking about the desalination plant, 12 it's worth noting that the Western hemisphere's largest 13 desalination plant is currently being constructed five 14 miles from this room we are standing in.
15 That plant will provide human drinking 16 water to many sitting in this building. And unlike 17 Japanese officials, who have been very slow at lying 18 through their teeth about the amount of emissions their 19 ongoing nuclear disaster is leaking directly into the 20 Pacific Ocean three and one half years after the 21 earthquake and tsunami, we will not be so polite if and 22 when an accident at San Onofre spent fuel storage 23 poisons our drinking water.
24 The reverse osmosis system being built 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there is not designed to and is not likely capable of 1
filtering out radionuclides. Thank you.
2 (Applause.)
3 FACILITATOR CAMERON: Okay, thank you.
4 So do you want to offer anything about what happens if 5
a cask breaks, Al?
6 MR. CSONTOS: Sure. So first, what we're 7
trying to do in these aging management programs is to 8
set up the guidelines, or the guidance, that says, you 9
know, this much and no further, okay, in terms of 10 degradation and what is acceptable, okay?
11 That's first. Second is, is that 12 stainless steel repairs have been done in the nuclear 13 industry for decades, probably longer than I've been 14 alive.
15 And it has -- they've had thousands, in the 16 80s and 90s, thousands of welds that have had cracking 17 in the reactor system, the stainless steel, same 18 stainless steel that these are made out of and others 19 are made out of, that have been repaired.
20 Overlays have been done for decades. So 21 there are technologies out there. When there are 22 unique issues, like what happened, and I've been 23 bringing up Koeberg, that's a plant that had, that's 24 right near the coast, breaking waves right next to it, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 in South Africa, that had this same issue.
1 And their tank was very thinthing, so the 2
typical methods of doing repairs was not appropriate, 3
okay?
4 So they went off and they did some quick R&D 5
and got repairs done very quickly. It was an overlay, 6
okay, but it was a unique overlay.
7 So the capabilities out there are, they're 8
there. They're there now, okay?
9 Just bringing it to bear to this side of the 10 house, which is the dry cask storage side, is not that 11 big of a deal, in my opinion.
12 FACILITATOR CAMERON: Okay.
13 MR. CSONTOS: But, and then the other issue 14 was, you said, for casks that have been damaged beyond 15 our threshold, or to a point where, you know, we need 16 to do something.
17 We have casks that are transfer casks, as 18 well as transportation casks, that are at different 19 sites that we could pull together, or, you know, 20 sometimes they are on individual site-specific sites --
21 site-specific licensees will tend to have them right 22 there on their site, and they can be stored within them 23 and held and stopped, if we're having any issues.
24 FACILITATOR CAMERON: All right. Thank 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 you, thank you Al. Carlos?
1 MR. OLVERA: Thank you. I'll try to make 2
this short.
3 I am referring to off-site emergency 4
planning. My name is Carlos Olvera (phonetic) from the 5
city of Dana Point.
6 When we became a city in 1989, Southern 7
California Edison installed an emergency response 8
center at city hall. We have not had to use that for 9
San Onofre, but we did use it a couple years ago when 10 we had a tsunami. It only measured six inches, but 11 nevertheless, it was nice to have it.
12 So I would just ask you, will that facility 13 be maintained throughout decommissioning?
14 MR. PALMISANO: Let me speak to that.
15 We've submitted a defueled emergency plan 16 for, you know, that is based on the scenarios that can 17 occur in decommissioning plants.
18 We will, we have some offsite facilities 19 the utility maintains. The offsite facilities that the 20 counties and cities maintain will really be up to them 21 in the future.
22 We've talked to the Interjurisdictional 23 Planning Commission, which is the agency which 24 coordinates all offsite emergency planning, not just 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 for nuclear issues, but for all hazards, and that 1
question really is for them.
2 They are certainly going to keep their 3
emergency capabilities in place while the fuel pools are 4
in service.
5 FACILITATOR CAMERON: Okay, and we do have 6
someone from FEMA, but -- the Interjurisdictional 7
Planning Committee, they couldn't be here tonight, but 8
they did give me something that they wanted me to read 9
into the record, very short.
10 "The members of the SONGS 11 Interjurisdictional Planning Committee have committed 12 to maintaining emergency response capabilities related 13 to nuclear preparedness throughout the SONGS 14 decommissioning
- process, and to continue our 15 multi-agency partnership to accomplish this goal."
16 And I'll read more of this if we have time, 17 but I just wanted to get that on the record, and if you 18 could just introduce yourself to us.
19 MR. GRUNDSTROM: My name is Richard 20 Grundstrom, and I am the Technological Hazards Branch 21 Chief for FEMA Region IX.
22 And part of what we do is we oversee the 23 radiological emergency preparedness program around the 24 offsite agencies around the nuclear power plants.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The IPC, all the Interjurisdictional 1
Planning Committee and all the local communities, have 2
a very, very robust emergency response plan, and it's 3
been exercised for years in its -- in a transition over 4
the period of time, like the gentleman mentioned, it was 5
activated for the tsunami. It's now becoming an 6
all-hazards plan.
7 Just because the San Onofre Nuclear Power 8
Plant is going to shut down, the plan is going to remain 9
in place. They are still going to have the robust EOC 10 (phonetic), and they're still going to have the planning 11 efforts that they do now.
12 FACILITATOR CAMERON: Okay. And we're 13 going to go to Jacqueline Woo (phonetic), and I'll just 14 read more of the Interjurisdictional Planning Committee 15 as I'm walking over there.
16 "As a part of our ongoing emergency 17 planning, we will retain the ability to receive 18 information, independently monitor and assess 19 conditions, and take actions to protect our residents, 20 visitors, and emergency workers." This is Jacqueline.
21 MS. WOO: Thank you.
22 I have been following the San Onofre whole 23 spectacle through the news, and it's really eye-opening 24 to come here and to hear form all these different 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 perspectives, especially from those who actually work 1
onsite, who put their lives on the line.
2 My question is, is there a list of other 3
agencies that we're working in collaboration with for 4
the decommissioning effort, and if so, how can the 5
public participate, will there be any public hearings?
6 FACILITATOR CAMERON: Okay. Anybody want 7
to take that on?
8 I think it was a pretty straightforward 9
question. Do you understand it up there?
10 MR. BROADDUS: When you're talking about 11 other -- other agencies, are you talking about federal 12 agencies, state agencies?
13 I mean, what -- ?
14 FACILITATOR CAMERON: I think any, any 15 other agencies that might be involved.
16 MR. PALMISANO: Let me just make one quick 17 comment.
18 We've focused our discussions tonight on 19 NRC requirements for decommissioning and the 20 Post-Shutdown Decommissioning Activities Report, the 21 Irradiated Fuel Management Plan.
22 Realize also, the state of California, 23 through the California Environmental Quality Act, also 24 has some permitting reviews they will do, similar to 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 what we did on Unit 1 activities in some cases.
1 So there will be some state agencies 2
involved. That is, you know, starting in the near 3
future.
4 I don't have a list per se. But if you pay 5
attention to our songscommunity.com website as we 6
proceed through the state permitting process for 7
decommissioning activities, that information would be 8
available.
9 FACILITATOR CAMERON: Yes, and FEMA, FEMA 10 obviously, right. Go ahead, Larry.
11 MR. CAMPER: No, I was going to say that, 12 for example, Department of Transportation regulations 13 that apply to the waste that will be leaving the site 14 when decommissioning is going on, we actually enforce 15 those regulations, but they are Department of 16 Transportation regulations.
17 There are also certain EPA considerations 18 that we carry out as part of our regulatory process.
19 With regards to the hearing question part 20 of it, I mentioned that when the License Termination 21 Plan is submitted, there is an opportunity for a 22 hearing. And if a body, if a group or an individual 23 seeks a hearing and is granted standing, then it goes 24 to an adjudicatory process. But that's an actual legal 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 hearing.
1 FACILITATOR CAMERON: Okay.
2 MR. CAMPER: It's not a public exchange of 3
information, it's an adjudicatory hearing.
4 FACILITATOR CAMERON: As opposed to a 5
meeting. Thank you, Larry.
6 MR. BROADDUS: Yes, if I could --
7 FACILITATOR CAMERON: Let's go -- go 8
ahead, Doug.
9 MR. BROADDUS: -- if I could say one other 10 thing, which is just that for any of the other licensing 11 amendments that San Onofre has submitted to us for 12 review as well, it's just like with the License 13 Termination Plan, there's an opportunity for a hearing 14 provided on each of those as well.
15 So anyone who is interested or, you know, 16 wants to participate in that can make their request for 17 those as well, such as the emergency plan that Mr.
18 Palmisano talked about previously, that's one of the 19 licensing actions that are under review right now.
20 FACILITATOR CAMERON: Okay, thank you.
21 Thank you, Doug.
22 And we're going to go to this gentleman 23 here, but I wondered, is Steve Adams, Francis Bauer 24 (phonetic), or Dave Peiser still here?
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Okay, Dave?
1 MR. PEISER: I am Dave Peiser, and I am 2
running for Congress right here in the 49th District, 3
and San Onofre is obviously part of this District, and 4
I am running against Darrell Issa, in case you wanted 5
to know that.
6 So the first thing I want to say is thank 7
you for all your hard work to make sure that -- to make 8
sure of the safety and well-being of our District, with 9
all the actions that you are taking, and I want to thank 10 everybody who is in this audience, too, to bring your 11 concerns.
12 And the one concern of mine is that, 13 according to the timeline, the Department of Energy is 14 going to take this fuel offsite, and I'm concerned that 15 that's never going to happen, considering the history 16 that has been going on so far with trying to find a 17 permanent site for nuclear spent fuel.
18 So for that reason I have two points. One 19 is I have, because of my serious concerns, I'd really 20 like to see us put a plan in place to get the fuel offsite 21 as soon as possible.
22 And number two, if you cannot figure out a 23 way to do that, I really think we should look at a longer 24 term containment strategy with the cast iron type casks, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 something more permanent and durable that's going to 1
last longer than the timeline that you've put together.
2 Thanks.
3 (Applause.)
4 FACILITATOR CAMERON: Okay, thank you.
5 And let's go to Ted, Ted Quinn.
6 MR. QUINN: Hi, I am Ted Quinn, and also a 7
CEP member, like Dan, and Gene Stone, I think.
8 I'd like to thank the NRC for sponsoring 9
this meeting. It's a pleasure to see the factual data, 10 and I'm going to emphasize the word factual data, being 11 presented.
12 In the CEP we've had multiple meetings, two 13 workshops, to foster public and plant owner exchanges 14 on key issues, and it's continued tonight, even though 15 this isn't a CEP meeting.
16 The public interactions have been great to 17 see, particularly the ones that are on a factual basis.
18 I would just like to comment, if Dr. Siegel 19 is still here, there's a good book about threats called 20 One Second After by William Forstchen on the loss of 21 electricity in a North Carolina town, that I think is 22 quite an interesting read.
23 Thank you.
24 FACILITATOR CAMERON: Okay. Thank you, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Ted.
1 Francis Bauer? Steve Adams?
2 Okay, and Alice has left. Do you want to 3
ask that question, Sharon?
4 Okay, we have a request for clarification 5
from Sharon on a couple of dates. Go ahead.
6 MS. HOFFMAN: The gentleman who spoke 7
about the DOE and the waste confidence gave a date of 8
2048 for building an interim facility, and yet Mr.
9 Palmisano talks about all the waste being removed by 10 2049.
11 There is something wrong with those dates.
12 And I would just like somebody to clarify how those two 13 dates work together.
14 FACILITATOR CAMERON: Okay, and I think --
15 I think Keith's 2048 was based on what DOE actually 16 stated, they thought a repository would be ready in 17 2048.
18 So why don't you talk, and then we'll ask 19 20 MR. MCCONNELL: The distinction is that 21 there were two facilities in DOE's strategy.
22 The first was a centralized interim storage 23 facility. That would be located somewhere in the U.S.
24 And that would occur in the 2020s, so the fuel would be 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 removed from the reactor facilities to this centralized 1
facility.
2 That would then be staged for a repository 3
that would be available in 2048 for the final 4
disposition of spent fuel.
5 FACILITATOR CAMERON: Okay, and Tom, do 6
you want to add anything?
7 MR. PALMISANO: No, I think that clarifies 8
it.
9 The dates we're working from are based on 10 Department of Energy information for the interim 11 facility, so for a planning basis, that's what we're 12 using at this point.
13 We're obviously monitoring the situation.
14 The 2048 is a permanent repository. So our goal, quite 15 frankly, is for the fuel to be removed as soon as DOE 16 can remove it to an interim facility, and that's what 17 our dates are based on.
18 FACILITATOR CAMERON: Okay. And I just 19 wanted to thank all of you, you've been a tremendous, 20 tremendous group, and I am going to turn this over to 21 the senior NRC official, Larry Camper, to close the 22 meeting out for us.
23 Al Csontos will be held hostage after the 24 meeting, okay?
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 So go ahead, Larry.
1 MR. CAMPER: Thank you, Chip.
2 Before I make my closing comments and 3
observations, I do want to ask Duane [White](phonetic),
4 who is in our Office of Nuclear Security Incident 5
Response --- [because] several times terrorism has come 6
up.
7 And I asked Duane to say something about a 8
concept called safeguards. We have other ways than 9
environmental impact statements or safety reviews for 10 addressing terrorism, and it's under the umbrella of 11 safeguards.
12 So Duane, would you make a few comments 13 about that to clarify for people how that works, without 14 getting into the details you can't get into?
15
[MR. WHITE]DUANE: Yes, I'll try to.
16 That's one thing about security, a little bit more 17 sensitive subject, so we don't talk about it as much.
18 But one thing that's been mentioned a lot 19 during our discussions is that security is going to go 20 away, or go down -- so I do want to let you know that 21 NRC does have a process, and so security will remain in 22 place.
23 We have a high -- we require high assurance 24 that security -- that all of the sites, from operating, 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 as it starts off operating, to decommissioning through 1
the ISFSI, that they maintain a specific level [of 2
security] to go against what we call our design-basis 3
threat.
4 And so that design-basis threat is 5
basically scenarios that have been made up of different 6
types of
- threats, and each
- reactor, each 7
decommissioning site, has to make sure they maintain 8
those -- their security at that level.
9 When we say that security is being changed, 10 basically what we're saying is because the operations 11 of the facility from an operating facility to a 12 decommissioning facility changes.
13 You reduce the area, because, for example, 14 you no longer have the reactor, you no longer have the 15 auxiliary equipment that protects the reactor, so of 16 course you don't have as much area to have to secure, 17 so it's not that security goes away, it's just that it 18 changes the [security structure]instructions so that we 19 can maintain that same level of security.
20 So we wanted to make sure it was clear that 21 security is going to be there. The NRC does a very good 22 job, we have a whole office dedicated to ensuring that 23 different plants, including SONGS, will maintain their 24 security even as they make changes -- they have to submit 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 those changes to us, and we do review those changes to 1
make sure that they still have that high level of 2
assurance.
3 So I just wanted to make that point so that 4
it's clear that the site will still be protected, and 5
that's what, also, Doug was saying in regards to the 6
difference between spent fuel pool and the dry 7
canisters, and that the plant itself will be still 8
secured. So that's why it wouldn't matter.
9 So I hope that helps.
10 MR. CAMPER: Great.
11 FACILITATOR CAMERON: Thank you.
12 MR. CAMPER: Thank you, thank you.
13 FACILITATOR CAMERON: And Larry.
14 MR. CAMPER: Okay, thank you.
15 First of all, let me thank everyone for all 16 the comments -- very insightful comments, and let me 17 assure you that the meeting is being transcribed. The 18 staff will review the transcript as we go through our 19 review process, you know, tracking against the 90 day 20 clock that's been mentioned several times over the 21 evening.
22 The staff will caucus following this 23 meeting and discuss the various things that we heard, 24 and we'll caucus as we look at the transcript, and your 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 comments will in fact be considered as we conduct our 1
review.
2 The second thing I want to mention is, and 3
I'll go back to the term who can say no? Who can say 4
no? We can say no.
5 It is correct that we do not approve the 6
PSDAR, consistent with the existing Commission policy.
7 Why is the policy that way? Because in 1996-1997, the 8
Commission determined that the activities that are 9
conducted during decommissioning are bounded by the 10 operations and safety considerations that take place 11 during an operating reactor, there's nothing that is 12 taking place during decommissioning that is 13 extraordinary as compared to the safety and 14 environmental considerations of an operating reactor.
15 And therefore the Commission put in place 16 the process that we have today, whereby the PSDAR would 17 be submitted, certain information would be provided in 18 that PSDAR, and you've seen the contents of that in some 19 of the slides today -- and then the emphasis is put then 20 upon the ultimate end state of the site.
21 What does the site look like from a 22 radiological standpoint when that license is prepared 23 to be terminated?
24 Now, one can criticize that process, I 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 understand that. I am merely offering an explanation 1
as to why it is the way that it is.
2 Now we ask questions, we have asked 3
questions, of other PSDARs in the past that have been 4
submitted. We may find ourselves asking questions 5
about this PSDAR.
6 But I want to point out that the reason we 7
ask the questions, and the reason that we review the 8
PSDAR, is to ensure that our regulations are in fact met.
9 We have the authority to stop this 10 decommissioning or any other decommissioning at the 11 PSDAR state if we can't get answers to the questions that 12 lead us to believe that our regulations would be 13 complied with. We have regulatory tools that would let 14 us do that.
15 So we have the authority to say no, even 16 though we don't approve the PSDAR as such, for the 17 reasons I've just explained.
18 So do understand that we do have that 19 authority to say no.
20 There's been a great deal of talk about 21 moving the fuel. I think we all think that that's a very 22 legitimate concern. Our country, our -- we do not have 23 a national policy at this point in place that leads to 24 moving of the fuel to another location from the coast 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 here.
1 I think we all prefer, would prefer, that 2
we did. But that's a national policy decision. It's 3
not a decision that SCE can make, it's not a decision 4
that we can make, it's a national policy issue.
5 What we have to do is make sure that this 6
decommissioning takes place in a safe manner, and that 7
the fuel that remains in dry cask storage on the pad is 8
done safely and in a way that will protect public health 9
and safety.
10 I hear a great deal of interest in the cask 11 of choice, in the cask performance considerations.
12 Those are very fair questions, those are very fair 13 concerns. And we'll do everything that we can to 14 continue to put information on our website that will 15 enunciate the various studies and things that we're 16 working on that Al commented on in his presentation as 17 he answered questions.
18 Why exemptions? Another fair question.
19 The reason that we grant exemptions for things such as 20 emergency preparedness and certain security 21 considerations, operator qualifications when reactors 22 move into decommissioning, is because our regulations 23 currently in Part 50 are designed around an operating 24 reactor.
25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 We have not yet put in place a set of 1
regulations that would be appropriate once the reactor 2
had gone from operations into decommissioning.
3 The reason that we haven't is in the year 4
2000 the staff started down the pathway of a Rule that 5
would articulate specifically what are the conditions 6
that the reactors must be in when in a decommissioning 7
mode. That Rulemaking was put on the back burner, it 8
was postponed, by the Commission, because at the time, 9
it was determined that we had higher priority 10 Rulemakings to work on that dealt with security in a 11 post-9/11 environment.
12 So, I'll stop there. I think there has 13 been some excellent comments. We thank you for those.
14 We will consider them. And we'll look forward to 15 communicating with you more as we go through the 16 process.
17 FACILITATOR CAMERON: Okay. And thank 18 you, Larry.
19 And here's where you can submit email 20 comments or hard comments, hard copy comments, right 21 there. That will remain up there, and there are copies 22 of the Post-Shutdown Report, compact disks out on the 23 table there. So, thank you.
24 (Whereupon, the meeting went off the record 25
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