ML19029A025
| ML19029A025 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 01/15/2019 |
| From: | John Lamb Special Projects and Process Branch |
| To: | Brian Sullivan Entergy Nuclear Operations |
| Lamb J, NRR/DORL/LSPB, 301-415-3100 | |
| References | |
| NRC-0051 | |
| Download: ML19029A025 (123) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting on Pilgrim Post-Shutdown Decommissioning Activities Report Docket Number: (n/a)
Location: Plymouth, Massachusetts Date: Tuesday, January 15, 2019 Work Order No.: NRC-0051 Pages 1-122 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PUBLIC MEETING ON PILGRIM POST-SHUTDOWN 5 DECOMMISSIONING ACTIVITIES REPORT 6 + + + + +
7 TUESDAY, 8 JANUARY 15, 2019 9 + + + + +
10 PLYMOUTH, MASSACHUSETTS 11 + + + + +
12 The meeting was convened in Room A, Hotel 13 1620, 18 Water Street, Plymouth, MA, at 6:00 p.m.,
14 Bruce Watson, chairman, presiding.
15 NRC STAFF:
16 DONNA JANDA, Facilitator 17 BRETT KLUKAN, Facilitator 18 JOHN LAMB, Office of Nuclear Reactor Regulation 19 BRUCE WATSON, Office of Nuclear Material Safety and 20 Safeguards 21 22 ALSO PRESENT:
23 ANNETTE VIETTI-COOK, Secretary of the Commission 24 MARIAN ZOBLER, General Counsel 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 CONTENTS 2 Call to Order and Opening Remarks . . . . . . . . 3 3 Bruce Watson 4 NRC's Decommissioning Experience . . . . . . . . 5 5 Bruce Watson 6 Pilgrim Decommissioning 7 John Lamb . . . . . . . . . . . . . . . . . 8 8 Mandy Halter . . . . . . . . . . . . . . . 14 9 Andrea Sterdis . . . . . . . . . . . . . . 20 10 Comments from Elected Officials, 11 Representatives of Elected Officials, or 12 Representatives of Federally-Recognized Tribes 13 Jessica Wong . . . . . . . . . . . . . . . 27 14 Rory Clark . . . . . . . . . . . . . . . . 28 15 Michael Jackman . . . . . . . . . . . . . . 33 16 Seth Schofield . . . . . . . . . . . . . . 36 17 Mary Lampert . . . . . . . . . . . . . . . 40 18 Jim Lampert . . . . . . . . . . . . . . . . 43 19 Rebecca Chin . . . . . . . . . . . . . . . 45 20 Sheila Lynch-Benttinin . . . . . . . . . . 46 21 Public Comments . . . . . . . . . . . . . . . . . 52 22 Closing Remarks . . . . . . . . . . . . . . . . 121 23 Adjourn . . . . . . . . . . . . . . . . . . . . 122 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 P R O C E E D I N G S 2 6:02 p.m.
3 MR. WATSON: Good evening. I'm Bruce 4 Watson, Chief of the Reactor Decommissioning Branch in 5 the Division of Decommissioning, Uranium Recovery, and 6 Waste Programs, and will be chairing tonight's 7 session.
8 Our purpose is to obtain your comments on 9 the Entergy Post-Shutdown Decommissioning Activities 10 Report and the Holtec license application and the 11 related Post-Shutdown Decommissioning Report 12 associated with it.
13 I would like to highlight NRC's mission to 14 protect public health and safety, promote the common 15 defense and security, and protect the environment, and 16 our current work related to the regulatory 17 requirements during the decommissioning of power 18 plants.
19 I would like to introduce a few of the NRC 20 staff who will be here to listen to your comments.
21 And hopefully, we, the staff, can collectively answer 22 questions on the decommissioning process. If we 23 can't, we'll do our best to get back to you.
24 So, you've met Brett, our Region I 25 Counselor, who will be facilitating tonight's meeting, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 along with Donna Janda, also from Region I. Also in 2 attendance is John Lamb, the current Project Manager 3 for Pilgrim. Amy Snyder is here, who will be the 4 Decommissioning Project Manager when the plant shuts 5 down and is transferred over to our organization.
6 Also in attendance is Mike Dusaniwsky, our 7 Senior Economist; Jason Piotter, Senior Engineer in 8 our Spent Fuel Management Group; Jessie Quintero, our 9 Environmental Review Specialist, and Ray Powell, our 10 Region I Branch Chief that will be inspecting the 11 plant during the decommissioning process. We also 12 have some additional folks in the audience that, if we 13 need to, we can call on them to help us with comments 14 or questions.
15 Next slide, please.
16 This is an NRC Category 3 public meeting 17 to obtain comments on the Entergy PSDR and the Holtec 18 application and their supplemental PSDR that's with 19 it. These documents were made publicly available for 20 comment.
21 The meeting is being transcribed and will 22 be made available for the public to review. There 23 will also be a meeting summary published for the 24 meeting.
25 We have a planned short presentation by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 John Lamb, who will discuss the PSDR process and the 2 license review process. Then, Entergy and Holtec will 3 be giving short presentations. Speaking for Entergy 4 tonight is Mandy Halter -- she is the Director of 5 Nuclear Licensing -- and Andrea Sterdis from Holtec, 6 who from also the Comprehensive Decommissioning 7 International, who is a Vice President of Regulatory 8 Programs, Environment and Safety.
9 After those presentations, we will turn 10 the meeting over to Brett and Donna, who will begin 11 the process to allow speakers to provide comments. It 12 is my full intention, if we can, to end this meeting 13 at 9:00 p.m.
14 I also want to emphasize that this meeting 15 is to discuss the upcoming permanent shutdown of the 16 Pilgrim Plant and the decommissioning process 17 associated with it.
18 Next slide, please.
19 Now I want to just discuss a little bit of 20 our decommissioning experience. We have many years of 21 decommissioning experience. We have over 21 years' 22 experience with our current decommissioning 23 regulations and have completed over 80 complex 24 material decommissionings and terminated those 25 licenses. They have all been released for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 unrestricted use by the owner. So, they can be used 2 for any future purpose. And included in that 80 is 10 3 nuclear power plants.
4 Next slide, please.
5 On this slide is a picture of Yankee Rowe.
6 It's located here in Rowe, Massachusetts. It's one of 7 the 10 plants that was decommissioned. We terminated 8 the license in 2007. Pictured on the left is the 9 plant when it was in operation. Pictured on the right 10 is where the plant was greenfielded by the utility 11 associated with the requirements set up with the 12 State. The NRC does not require site restoration as 13 part of our process.
14 One of the things that I want to point out 15 to you is that, on the picture on the right there is 16 a hydroelectric dam that's been there for over 100 17 years. As you note, the nuclear plant operated, was 18 decommissioned, and is gone. However, on the hill in 19 the center there is a picture of the dry fuel storage 20 facility that is still located on their site and under 21 license, and will continue to be inspected by our 22 inspectors. Of course, the spent fuel is there 23 awaiting the final disposition of the high-level waste 24 disposal, either interim or final repository, here in 25 the U.S.
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7 1 Next slide, please.
2 I wanted to just briefly discuss the two 3 decommissioning options discussed in the November 2008 4 submittals. Regardless of the option chosen, 5 preparation of the decommissioning takes about one to 6 two years to remove the radioactive waste stored 7 onsite, remove filters, resins; drain systems to allow 8 the dismantling to begin and be done safely or placed 9 in storage. After the decommissioning preparation 10 period, the licensee can go into either DECON or 11 SAFSTOR.
12 DECON, or a prompt decommissioning, the 13 licensee begins the decommissioning activities and 14 usually transfer the spent fuel to dry storage. Past 15 experience has shown that decommissioning typically 16 takes seven to ten years to complete.
17 With SAFSTOR, the plant is placed in 18 storage -- we like to call it, it's cold and dark 19 -- until the licensee decides to dismantle and 20 decommission the plant. In SAFSTOR, the NRC will 21 continue to inspect the plants at least annually and 22 more frequently when decommissioning activities are 23 performed.
24 Regardless of the decommissioning option 25 chosen, the NRC regulations require that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 decommissioning be completed in 60 years.
2 Next slide, please.
3 A few reminders. We are here to listen to 4 your comments on the Pilgrim decommissioning. This is 5 part of the process we've set up and it's intended to 6 hear your comments, so we can consider those in our 7 review of both the PSDR from Entergy and, also, the 8 license application and the PSDR that supplements it 9 from Holtec.
10 The meeting, again, is being transcribed, 11 and the transcript will be publicly available. A 12 meeting summary will be published and would be 13 publicly available.
14 And we will do our best to answer your 15 questions, where we can. There's going to be possibly 16 some that we can't answer, but we do our best to get 17 back to you.
18 I'm going to introduce John. John Lamb is 19 going to sit down and speak.
20 MR. LAMB: Yes.
21 MR. WATSON: Okay. Thank you.
22 MR. LAMB: Hi. Good evening. My name is 23 John Lamb. I am the Project Manager for Pilgrim at 24 NRC Headquarters in Rockville. I've been working for 25 the NRC for 19 years, and prior to that, I worked 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 years in the power plant.
2 Next slide, please.
3 In accordance with the NRC regulations, a 4 Post-Shutdown Decommissioning Activities Report, or 5 PSDAR, must be submitted to the NRC, and a copy to the 6 Commonwealth of Massachusetts, prior to or within two 7 years following the permanent cessation of operations 8 of Pilgrim. Entergy submitted the Pilgrim PSDAR on 9 November 16th, 2018.
10 A PSDAR must contain a description of the 11 planned decommissioning activities, along with a 12 schedule for their accomplishment and a site-specific 13 decommissioning cost estimate, including the projected 14 cost of managing irradiated fuel.
15 The NRC staff uses a Regulatory Guide that 16 provides guidance on the content and format of PSDARs.
17 The Regulatory Guide is available to the public as 18 noted on this slide.
19 Decommissioning activities must not 20 endanger the public health and safety or result in 21 significant environmental impacts not previously 22 reviewed.
23 Next slide.
24 A PSDAR must contain a discussion that 25 provides the reasons for concluding that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 environmental impacts associated with site-specific 2 decommissioning activities will be bounded by 3 appropriate previously-issued Environmental Impact 4 Statements. Therefore, during the environmental 5 review of a PSDAR, the NRC uses various previous staff 6 reports to determine whether the environmental impacts 7 from decommissioning are bounded by these reports.
8 For instance, for Pilgrim, the NRC staff will use a 9 generic Environmental Impact Statement regarding 10 decommissioning and will also look at previous 11 Environmental Impact Statements developed specifically 12 for Pilgrim, such as the Environmental Impact 13 Statement developed for the renewal of the Pilgrim 14 operating license. The NRC staff will also rely on 15 findings from its inspection program.
16 Next slide, please.
17 The request for comment and meeting notice 18 for the Pilgrim PSDAR was published in The Federal 19 Register on December 21st, 2018. The 90-day comment 20 period ends on March 21st, 2019.
21 The NRC staff will notify the licensee if 22 the staff needs additional information to support its 23 review of the PSDAR. The NRC staff will document its 24 PSDAR review in a letter to the licensee and will 25 address the comments received during the comment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 period.
2 After the submission of the Pilgrim PSDAR, 3 the NRC regulations require that Entergy shall notify 4 the NRC in writing and send a copy to the Commonwealth 5 of Massachusetts before performing any decommissioning 6 activity inconsistent with or making a significant 7 schedule change from those actions and schedules 8 described in the PSDAR.
9 Next slide, please.
10 By letter dated November 16h, 2018, 11 Entergy and Holtec submitted a license transfer 12 application requesting that the license for Pilgrim be 13 transferred from Entergy to Holtec. Before this 14 transfer may be completed, the NRC must determine that 15 Holtec is qualified to be the holder of the Pilgrim 16 license.
17 In order to make this determination, the 18 NRC staff reviews the following five areas: financial 19 qualifications; decommissioning funding assurance; 20 foreign ownership, control, and domination; technical 21 qualifications, and insurance and indemnity. If the 22 NRC finds that Holtec is qualified in these areas, 23 then it would approve the license transfer by an order 24 and issue a conforming license amendment.
25 Next slide, please.
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12 1 License transfer applications are noticed 2 in The Federal Register, and the public can request a 3 hearing and/or provide comments on the application.
4 The program license transfer application is ready for 5 publication in The Federal Register. However, The 6 Federal Register is currently impacted by the partial 7 federal government shutdown. Therefore, the Pilgrim 8 license transfer federal registration notification 9 will not be published until after the partial federal 10 government shutdown ends. Once this Federal Register 11 notice is published, there will be a 20-day hearing 12 period, and then, a 30-day comment period.
13 License transfer applications typically 14 contain proprietary information. A redacted, 15 nonproprietary version of the Pilgrim license transfer 16 application is available to the public and can be 17 found online through the NRC's electronic library 18 called ADAMS. The proprietary version can be 19 requested using a process that will be described in 20 The Federal Register notice.
21 Next slide, please.
22 By letter dated November 16th, 2018, 23 Holtec submitted a proposed revised PSDAR for Pilgrim.
24 The Holtec PSDAR is a supplement to the license 25 transfer application, and therefore, is part of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 license transfer application action, and not part of 2 the Entergy PSDAR action. The Holtec PSDAR is 3 contingent upon the approval of the licensed transfer 4 application and the equity sale closure. For purposes 5 of this public meeting, the NRC will be accepting 6 comments on both the Entergy PSDAR action and the 7 license transfer application, which includes the 8 proposed Holtec PSDAR.
9 Next slide, please.
10 Holtec also submitted a request for an 11 exemption from the NRC's Decommissioning Trust Fund 12 requirements in an enclosure to the license transfer 13 application. If this request were to be granted, then 14 Holtec would be allowed to use the Pilgrim 15 Decommissioning Trust Fund not only for radiological 16 decommissioning expenses, but also for expenses 17 related to spent fuel management activities and site 18 restoration activities. Like the Holtec PSDAR, this 19 exemption request is contingent upon the approval of 20 the license transfer application and the equity sale 21 closure.
22 Next slide, please.
23 Comments regarding the Entergy PSDAR can 24 be submitted on regulations.gov website under Docket 25 ID NRC-2018-0286 until March 21st, 2019. Comments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 regarding the license transfer application can be 2 submitted during tonight's public meeting. Once the 3 license transfer application is noticed in The Federal 4 Register, then comments can be submitted on the 5 regulations.gov website under Docket ID NRC-2018-0279 6 for a period of 30 days for comments, and a hearing 7 can be requested for a period of 20 days.
8 Next slide, please.
9 This slide shows where to mail comments 10 regarding Entergy PSDAR or the license transfer 11 application. Please remember to use the Docket ID 12 associated with each application.
13 That concludes my presentation. I'll turn 14 it back over to Bruce.
15 MR. WATSON: Okay. Our next speaker is 16 Mandy Halter from Entergy.
17 MS. HALTER: Good evening. My name is 18 Mandy Halter, and I'm the Director of Nuclear 19 Licensing for Entergy Nuclear. With me tonight is 20 Mike Twomey, the Vice President of External Affairs 21 for Entergy Wholesale Commodities. I appreciate the 22 opportunity to be here tonight to provide you 23 information on Entergy's plans to decommission the 24 Pilgrim Nuclear Power Station.
25 2019 is a significant year for Entergy, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 for Pilgrim, and for this area. On May 31st of this 2 year, Pilgrim will permanently cease power operations.
3 In June, we will certify to the NRC that the reactor 4 is permanently shut down and defueled. Also in June, 5 Pilgrim will complete its first staffing reduction, as 6 we transition the organizational structure to support 7 Pilgrim's SAFSTOR decommissioning plan. Throughout 8 the final months of plant operation, and as we 9 transition to decommissioning, we remain committed to 10 safety, health, and security of the plant, its 11 employees, and you, the public.
12 Next slide. Next slide, please. Thank 13 you.
14 The Entergy Post-Shutdown Decommissioning 15 Activities Report, or PSDAR, was submitted to the NRC 16 on November 16th, 2018, and outlines our plan to use 17 the SAFSTOR decommissioning strategy. Our PSDAR was 18 prepared by a team of experts, in accordance with 19 regulations, NRC guidance, and a thorough review of 20 PSDARs submitted to the NRC by plants in 21 decommissioning.
22 The Pilgrim PSDAR contains a description 23 of our planned decommissioning activities as well as 24 a schedule for their completion, an estimate of the 25 cost, and a discussion of the environmental impacts of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 these activities. And I will provide more information 2 in the following slides.
3 Next slide, please.
4 The majority of the dormancy period of our 5 SAFSTOR plan will involve all spent fuel in dry fuel 6 storage. This slide shows our plan to achieve the dry 7 fuel storage storm and sea state by the end of 2022.
8 Along the way, Pilgrim will make adjustments to its 9 staffing levels and the emergency plan, in accordance 10 with appropriate regulatory approvals, based on the 11 status of the fuel and the corresponding decreasing 12 risk of offsite radiological consequences from an 13 accident.
14 Next slide, please.
15 Under the SAFSTOR methodology, we will 16 maintain and monitor Pilgrim in a dormancy period to 17 allow for the radioactive decay of the plant, followed 18 by the dismantlement and decontamination to permit NRC 19 license termination within 60 years, as required by 20 regulations. Under Entergy's plan, radiological 21 decontamination and dismantlement will occur safely by 22 the year 2079. We plan to restore the site following 23 license termination.
24 Next slide, please.
25 In accordance with regulations, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 developed a site-specific estimate of the costs for 2 the planned SAFSTOR decommissioning activities at 3 Pilgrim. This cost estimate was developed by a 4 leading expert using up-to-date and best available 5 data. In addition to estimating the costs associated 6 with license termination, we also estimated the cost 7 associated with spent fuel management and site 8 restoration. Our SAFSTOR decommissioning cost 9 estimate for Pilgrim is included as an attachment to 10 the Entergy PSDAR.
11 Next slide, please.
12 The site-specific decommissioning cost 13 estimate submitted to the NRC in November 2018 was 14 reported using 2018 dollars and up-to-date 2018 15 pricing information. The total estimated cost 16 associated with license termination as well as spent 17 fuel management and site restoration for Pilgrim is 18 $1.66 billion. We will periodically update the 19 decommissioning cost estimate throughout the SAFSTOR 20 period, in accordance with regulations.
21 It is very important to note that we are 22 required by regulation, as the owner of the plant, to 23 demonstrate reasonable assurance that there are 24 adequate funds available to cover the cost of license 25 termination. We provide this funding for Pilgrim NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 through a Nuclear Decommissioning Trust Fund, which, 2 as reported to the NRC and the PSDAR, was funded at 3 $1.05 billion at the end of October 2018. Accounting 4 for the growth of these funds over time, as permitted 5 by NRC methodology, the Pilgrim nuclear 6 decommissioning trust balance does not provide 7 financial assurance for the decommissioning costs of 8 our SAFSTOR plan.
9 Next slide, please.
10 We have concluded that the environmental 11 impacts associated with planned SAFSTOR 12 decommissioning activities at Pilgrim are less than, 13 and are bounded by, impacts addressed in previously-14 issued Environmental Impact Statements. A more 15 detailed discussion of the reasons for our conclusion 16 is included in the PSDAR.
17 Next slide, please.
18 In November 2018, we filed an updated 19 Pilgrim Spent Fuel Management Plan with the NRC which 20 outlines our intent to store all spent fuel on a new, 21 larger, independent spent fuel storage installation 22 pad which will be located at a higher elevation on the 23 program site. This pad, which we plan to construct by 24 the end of 2020, will store a total of 61 casks, 25 including the 17 casks that are on the current pad, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 well as 44 additional casks which are needed to store 2 the fuel that is currently in the reactor vessel and 3 the spent fuel pool.
4 Next slide, please.
5 In November 2018, Entergy and Holtec 6 submitted a request to the NRC to transfer the control 7 of Pilgrim's plant and ISFSI licenses from Entergy to 8 Holtec. If approved by the NRC, the license transfer 9 will allow for prompt decommissioning under Holtec's 10 plan, which is different than Entergy's plan.
11 Specifically, Holtec plans to decommission Pilgrim 12 using a DECON or immediate dismantlement strategy by 13 approximately 2024. Additionally, Holtec intends to 14 move all spent fuel to dry fuel storage on the new pad 15 by the end of 2021. Following this presentation, 16 Andrea Sterdis will provide more information on 17 Holtec's decommissioning plans for Pilgrim.
18 A major benefit of decommissioning under 19 Holtec's plan is that it will allow for earlier 20 release of portions of the Pilgrim site for reuse. We 21 have requested that the NRC review and approve the 22 license transfer application by May 31st of this year.
23 We know that this is an aggressive review schedule for 24 the staff and we are certain that the NRC will conduct 25 a very diligent review, and we expect nothing less.
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20 1 The intent behind this requested timeline is to 2 provide certainty to the plant employees and to the 3 citizens of Plymouth and the surrounding areas on 4 plant ownership as well as the decommissioning plan 5 and timeline following plant shutdown.
6 Next slide, please.
7 More information about Pilgrim's plans for 8 decommissioning as well as our related submittals that 9 we have provided to the NRC are publicly available on 10 our website, www.pilgrimpower.com.
11 I thank you for your time. And a number 12 of us are here from Entergy, and we look forward to 13 answering your questions later in the evening. Thank 14 you.
15 MR. WATSON: Thank you for your 16 presentation.
17 Our next presentation is by Andrea Sterdis 18 from Holtec International and CDI, I believe it's 19 called.
20 MS. STERDIS: Thank you, Bruce.
21 Good evening. I really appreciate the 22 opportunity to provide you all with a brief overview 23 of the Post-Shutdown Decommissioning Activities Report 24 that has been prepared to show the Holtec plan for 25 initiating plant decommissioning following NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 approval of the license transfer application, 2 execution of the license transfers, and completion of 3 the sale closure.
4 Next slide, please.
5 On this slide, you can see that I am up 6 here providing the presentation. I'm Andrea Sterdis.
7 I'm the Vice President for Regulatory Programs, 8 Environment and Safety for Comprehensive Commissioning 9 International. I am joined tonight by Joy Russell, 10 Senior Vice President for Holtec International.
11 Next slide.
12 On November 16th, 2018, Holtec submitted 13 a revised Post-Shutdown Decommissioning Activities 14 Report, or PSDAR, based on their plan to initiate 15 prompt DECON. Our PSDAR for DECON includes a 16 description of the planned activities, specifically 17 the activities that are required to initiate that 18 prompt DECON and complete it. It also includes a 19 planned DECON decommissioning schedule and a cost 20 estimate reflecting that schedule and the DECON plan.
21 Lastly, it includes a discussion of the environmental 22 impacts for the specific activities that will be 23 performed during the execution of the dismantlement 24 and the waste removal from the site to complete the 25 radiological decommissioning.
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22 1 The PSDAR was prepared in accordance with 2 NRC regulations and addresses NRC guidance. It was 3 prepared by a team that is experienced in planning, 4 estimating, and executing nuclear power plant 5 decommissioning. It was also informed by a review of 6 previously-submitted PSDARs, as well as particularly 7 a review and an alignment with the assumptions that 8 were provided and used in the Entergy SAFSTOR PSDAR.
9 The DECON PSDAR is contingent upon NRC approval of the 10 license transfer, execution of the transfers of the 11 license, and completion of the sale.
12 Next slide, please.
13 The DECON PSDAR reflects Holtec's plan to 14 promptly start decommissioning activities following 15 the license transfer and sales closure. The schedule 16 reflects the project goal to achieve partial site 17 release within eight years.
18 The decommissioning cost estimate reflects 19 DECON activities and schedule for completing 20 radiological decommissioning, managing the spent fuel, 21 and completing site restoration activities.
22 The environmental evaluation considers the 23 DECON activities and provides evidence that those 24 activities are bounded by the existing Environmental 25 Impact Statements that are applicable to the Pilgrim NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 site, including the NRC generic Environmental Impact 2 Statement for Decommissioning as well as the Pilgrim 3 Site License Renewal Environmental Impact Statement.
4 If you look at the SAFSTOR PSDAR and 5 compare the decommissioning cost estimate with that 6 provided in our PSDAR for DECON, you will see some 7 differences. Those differences are primarily driven 8 by two reasons. First, the core business for Entergy 9 in the current time is to provide and generate 10 power/electricity. The core business for Holtec, 11 including CDI, is managing spent fuel and executing 12 decommissioning projects. And therefore, the Holtec 13 team has the latest technology, the engineering 14 expertise, and the project management expertise to 15 apply cost- and time-effective methods for 16 decommissioning, resulting in a difference in the 17 decommissioning cost.
18 In addition, the DECON plan eliminates the 19 transition to the dormant state, maintaining that 20 plant dormant state for almost 40 years, and the 21 transition to reactivate the plant and complete the 22 dismantlement and waste removal activities about 40 23 years down the road.
24 It's important to note that the SAFSTOR 25 dismantlement and waste removal schedule and the DECON NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 dismantlement and waste removal schedule are similar 2 in duration. The difference is the prompt DECON one 3 modeled in our PSDAR is initiated immediately after 4 license transfer in 2019 and completes in 5 approximately five years.
6 On the next slide, please.
7 The schedule provided in the DECON PSDAR 8 assumes that the NRC will approve the license transfer 9 application in time to support a July 31st transfer of 10 the licenses and sale closure. This slide provides 11 some key assumptions that drove the schedule that's 12 included in that PSDAR, starting with the fact that 13 we've assumed an initiation of decontamination and 14 dismantlement activities in 2019 following the license 15 transfer. It also assumes that the newest ISFSI pad 16 construction is completed and the pad is available for 17 use in 2020. It assumes that the offloading of the 18 spent fuel transitioning the site from a combined wet 19 and dry spent fuel storage site to a dry fuel storage 20 site only occurs by the fourth quarter of 2021.
21 Similar to the SAFSTOR PSDAR schedule 22 submitted by Entergy, our DECON PSDAR schedule assumes 23 that the DOE completes the spent fuel removal from the 24 site in the 2062 time period. The DECON PSDAR 25 schedule shows radiological decommission, except for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 the independent spent fuel storage installation, 2 ISFSI, is accomplished within approximately five years 3 following the license transfer and sale closure. It 4 also assumes that site restoration activities, which 5 are not required for the partial site release approval 6 by the NRC, are continuing beyond that approximately 7 one year.
8 Next slide, please.
9 The Holtec DCE, or decommissioning cost 10 estimate, that's included in the DECON PSDAR results 11 in approximately $1.134 billion cost in 2018 dollars.
12 The Nuclear Decommissioning Trust Fund for Pilgrim is 13 currently valued at $1.05 billion as of October 31st, 14 2018. The cash flow analyses that were submitted as 15 part of the license transfer application as well as 16 the DECON PSDAR and decommissioning cost estimate 17 demonstrate that the Pilgrim Nuclear Decommissioning 18 Trust Fund contains sufficient funds to cover our plan 19 for radiological decommissioning, spent fuel 20 management, and site restoration.
21 It's important to note that, pursuant to 22 NRC regulations, we will be required, as the licensee, 23 to prepare and submit an annual report that provides 24 the Nuclear Decommissioning Trust Fund status, 25 including expenses and activities executed in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 previous year, the remaining NDT balance, and showing 2 financial assurance that the balance can address and 3 cover the remaining costs of all the activities 4 required to complete the license termination. This is 5 a public report and is made available each year by the 6 NRC.
7 With that, I'd like to thank you for your 8 time, and I'd like to thank the NRC for this meeting.
9 Thank you.
10 MR. WATSON: Thank you, Andrea.
11 Before I turn the meeting over to Brett 12 and Donna to facilitate the comment session, I would 13 like to invite any elected officials or their 14 representatives or any Native American tribe 15 representations to make statements if you're available 16 now. So, if you would, those that are interested, 17 please come up to the microphone and state your name 18 for the record.
19 MR. KLUKAN: So, we actually have a couple 20 who have preregistered with us, and we are going to go 21 down through that list. And then, we'll open it up to 22 those who did not preregister.
23 So, first up, we're going to have Ms.
24 Jessica Wong from the Office of Senator Elizabeth 25 Warren.
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27 1 MS. WONG: Good Evening. Thank you. As 2 Brad said, my name is Jessica. I am from Senator 3 Elizabeth Warren's office, and I'm her Regional 4 Director.
5 So, Senator Warren reiterates her deep 6 concerns with the consistently poor public safety 7 record at Pilgrim Nuclear Power Station and the 8 Nuclear Regulatory Commission's pattern of ignoring 9 critical discrepancies in Entergy's safety measures 10 that put Massachusetts residents at risk. This cannot 11 continue, especially as the NRC reviews the license 12 transfer for the decommissioning from Entergy to 13 Holtec International. To date, she has sent six 14 letters to the NRC expressing these concerns, most 15 recently in October, following the reports of 16 unplanned shutdowns due to problems with equipment.
17 Entergy cannot continue to use the 18 summer's planned shutdown as an excuse to avoid much-19 needed safety upgrades that protect our communities.
20 Senator Warren urges the company to prioritize the 21 people of southeastern Massachusetts over its profits.
22 Similarly, the NRC can no longer shirk its 23 responsibilities to establish and enforce proper 24 safety standards. The Senator, once again, calls on 25 the NRC to require Entergy to immediately comply with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 federal safety standards, and if they refuse to do so, 2 then the NRC must take necessary steps to shut down 3 the plant.
4 Thank you.
5 MR. KLUKAN: Thank you very much.
6 Next, we will have Ms. Rory Clark from the 7 Office of Senator Ed Markey.
8 MS. CLARK: Thank you for having me. As 9 you said, I'm Rory Clark. I'm Senator Markey's 10 Regional Director. I'll be reading a statement on 11 Senator Markey's behalf.
12 "I've long been concerned about Pilgrim's 13 safety and operating record and its management's 14 history of cutting corners at the expense of increased 15 risk to Massachusetts residents. As we turn our 16 attention now to the details of the Post-Shutdown 17 Decommissioning Activities Reports submitted by 18 Entergy and Holtec International, I must remind the 19 Nuclear Regulatory Commission, Entergy, and Holtec 20 that the people of Massachusetts will settle for 21 nothing less than the most stringent safety measures.
22 "As the federal regulatory body overseeing 23 the decommissioning process, we all expect the NRC 24 will review both Entergy and Holtec's proposed 25 decommissioning plans with the utmost of care and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 caution. The safety of Massachusetts residents 2 demands this thorough review.
3 "Plans for the ownership and 4 decommissioning of Pilgrim must prioritize safety ans 5 security. The NRC must evaluate both Entergy and 6 Holtec's PSDARs to ensure that each provides a 7 comprehensive accounting of how that owner will assume 8 responsibility for safe operations, improve upon the 9 abysmal safety record at Pilgrim, and finance the 10 complete decommissioning process.
11 "I understand that it's common practice 12 for the NRC to issue exemptions that would limit the 13 required emergency planning zone when the plant begins 14 the decommissioning process, but I must urge the NRC 15 to require Pilgrim's owner, be it Entergy or Holtec, 16 to work with local communities to maintain and fund 17 the significant emergency planning zone and ensure 18 that local communities are prepared for any 19 eventuality.
20 "Last year I was proud to cosponsor the 21 Safe and Secure Decommissioning Act which would 22 prohibit the NRC from issuing waivers or granting 23 exemptions from complying with safety and emergency 24 preparedness regulations put forth in the Atomic 25 Energy Act of 1954 until nuclear fuel had been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 transferred to spent nuclear fuel dry casks. I will 2 continue to push for all parties involved in the 3 decommissioning of Pilgrim to abide by such standards.
4 "As we are all aware, this region is home 5 to fierce nor'easter storms and rising tides, posing 6 safety concerns that other nuclear facilities around 7 the country do not have to contend with. Especially 8 given this region's harsh environmental conditions, 9 the NRC should ensure the completion of a full 10 National Environmental Policy Act analysis that would 11 exam the effect of the proposed decommissioning plans 12 on the environment and allow for additional public 13 involvement.
14 "Furthermore, any Pilgrim licensee should 15 provide thorough plans for communicating regularly 16 with the public and local stakeholders throughout the 17 decommissioning process. This communication is 18 essential to ensure that all members of the community 19 understand how Pilgrim will be safely decommissioned 20 and foster confidence that security measures satisfy 21 federal safety standards and community expectations.
22 "I was proud to be an original cosponsor 23 of additional legislation in 2018 entitled `The 24 Nuclear Plant Decommissioning Act,' which would ensure 25 the states and local communities have a meaningful NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 role in the crafting and preparation of 2 decommissioning plans for retired nuclear plants 3 located in our community. This bill also requires the 4 NRC to publicly and transparently approve or reject 5 every proposed decommissioning plan, which it 6 currently is not required to do.
7 "I will be introducing the Dry Cask 8 Storage Act this session, which would ensure every 9 nuclear reactor operator must be compelled to comply 10 with an NRC-approved plan that would require the safe 11 removal of spent nuclear fuel from spent nuclear fuel 12 pools and placed that fuel into dry cask storage 13 within seven years of the time that the plan is 14 submitted to the NRC. This bill would further provide 15 funding to help reactor licensees implement these 16 plans and would expand the emergency planning zone for 17 all noncompliant reactor operators to 50 miles.
18 "As we consider tonight the shutdown 19 process for Pilgrim, Entergy and Holtec must provide 20 conclusive proof that there are sufficient funds 21 available in the Nuclear Decommissioning Trust to 22 decommission Pilgrim in a safe and secure manner. It 23 will be unacceptable for Entergy or Holtec to demand 24 additional money from Massachusetts ratepayers to 25 complete the decommissioning process at Pilgrim.
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32 1 There can be no second chances here.
2 "Historical data and NRC guidelines 3 indicate that the decommissioning costs are likely to 4 increase faster that inflation. Entergy and Holtec 5 must each account for that fact or find a way to 6 clearly rebut it. Given the amount currently 7 available in the Trust Fund, the NRC must carefully 8 assess if the proposed decommissioning timeline is 9 achievable in a safe and secure manner and require 10 there is reasonable public assurance of available 11 funds for the totality of the process. Additionally, 12 as the proposed license transfer will further strain 13 the NRC's resources, it is imperative that the NRC 14 assign additional staff to work on these issues and 15 charge the licensees for their salaries.
16 "In the recent past, I have also expressed 17 my concerns to the NRC regarding the draft 18 decommissioning rule currently awaiting review, which 19 is intended to provide clear guidelines for all plants 20 that are undergoing the decommissioning process. This 21 proposal falls far short of the NRC's stated goals of 22 providing for a safe, effective, and efficient 23 decommissioning process for nuclear plants. In its 24 current form, this fails to propose a comprehensive 25 set of decommissioning and cleanup regulations, would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 result in the automatic approval of facilities' 2 exemptions from safety, security, and emergency 3 planning regulations, and would continue to 4 rubberstamp the industry's Post-Shutdown 5 Decommissioning Activities Report. I continue to urge 6 the NRC to reject this draft and, instead, write a 7 rule that will affirmatively guide plants and 8 communities through the decommissioning process.
9 "Thank you."
10 MR. KLUKAN: Thank you very much.
11 Next, we will have Mr. Michael Jackman of 12 the Office of Congressman Bill Keating.
13 MR. JACKMAN: Thank you.
14 I do have a statement from the Congressman 15 I'd like to read, but before I do that, I have just 16 some housekeeping questions. The slide presentations 17 that were made tonight, are those available online or 18 will they be available online?
19 MR. KLUKAN: For the record, yes, they 20 will be available online on the NRC's website.
21 MR. JACKMAN: Okay. Only because I think 22 if people want to make comments both on the PSDAR and 23 the license transfer, there's a lot of good 24 information in there. Thank you.
25 "Thank you for the opportunity to address NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 you at tonight's public meeting. Unfortunately, the 2 House voting schedule prevents me from being here in 3 person, but I wanted to restate my opinion that, as we 4 draw closer to the cessation of operations at Pilgrim, 5 the rigorous scrutiny of the operations at the plant 6 must continue. Entergy must not be allowed to 7 languish in column 4, representing the minimum level 8 of operational safety for the remainder of its life as 9 a power generating plant.
10 "In addition, the NRC must scrutinize 11 Entergy's and Holtec's Post-Shutdown Decommissioning 12 Activities Reports to ensure that the health and 13 safety of Massachusetts residents is not at risk. The 14 NRC must enforce its regulations and require the 15 licensee to adhere to the most stringent standards for 16 facility security, cybersecurity for all the plant 17 systems, structural integrity of the onsite dry cask 18 storage system, and mitigation of environmental 19 hazards.
20 "In addition, decommissioning activities 21 must be fully funded by the licensee, and the NRC must 22 do all it can to ensure that taxpayers, be they 23 residents of Plymouth, the Commonwealth of 24 Massachusetts, or the United States of America, are 25 not left to shoulder the burden of the cost of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 cleanup of the Pilgrim site.
2 "Given the real prospect of ongoing 3 nuclear waste storage here in Plymouth, it is 4 incumbent upon all levels of government to work 5 together to ensure the safety of our residents. It is 6 imperative that those residents and residents of all 7 affected communities in Plymouth County, the Cape, and 8 the islands are included in the discussion and 9 decisions involved with the decommissioning process.
10 "The Plymouth Town Select Board, the State 11 legislative delegation, the Nuclear Decommissioning 12 Citizens Advisory Panel, private groups like Pilgrim 13 Watch and Cape Downwinders, and many other concerned 14 individuals and groups, all have been engaged in this 15 vital discussion over the years, and they all deserve 16 to have their input heard and incorporated into the 17 decisionmaking process. I am proud to have 18 cosponsored legislation, which I've already referred 19 to, the Nuclear Plant Decommissioning Act, that will 20 do just that.
21 "I applaud all those preset tonight for 22 sharing their perspectives, and I will continue to 23 fight to make sure that your voices are heard. Thank 24 you."
25 MR. KLUKAN: Thank you very much.
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36 1 Next, we will have Mr. Seth Schofield from 2 the Massachusetts Attorney General's Office.
3 MR. SCHOFIELD: Thank you, Brett.
4 Good evening. I'm Seth Schofield, Senior 5 Appellate Counsel and Assistant Attorney General in 6 the Energy and Environment Bureau of the Office of 7 Attorney General Maura Healey.
8 First, I'd like to thank the Nuclear 9 Regulatory Commission for coming to Plymouth tonight, 10 so that the public has an opportunity to voice their 11 thoughts and concerns about the power plant and the 12 proposed plans to decommission the plant following its 13 shutdown this spring.
14 From the Attorney General's perspective, 15 the proposed sale of Pilgrim and the related transfer 16 of Pilgrim's operating license from Entergy to a 17 Holtec subsidiary raise significant health, safety, 18 environmental, and financial concerns for the 19 Commonwealth and its citizens. We appreciate the 20 potential benefits of accelerated decommissioning that 21 forms the basis for the sale and license transfer 22 application, but we currently have serious concerns 23 about whether Pilgrim's Decommissioning Trust Fund 24 contains sufficient funds to cover the performance of 25 all necessary decommissioning, site restoration, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 spent fuel management activities on an indefinite 2 basis.
3 As currently proposed, neither Holtec, 4 Pilgrim, LLC, the proposed licensee, nor Holtec 5 Decommissioning International, LLC, the proposed 6 licensed operator, will generate any revenue or bring 7 with them any new assets that could be used to fund 8 and complete site decommissioning, restoration, and 9 spent fuel management activities at the site.
10 Instead, Holtec-Pilgrim and Holtec Decommissioning 11 International's only planned source of funds are the 12 funds currently existing in the Pilgrim Trust Fund, 13 and as currently proposed, there exists no guaranteed 14 add to the parent company of those two single-purpose 15 limited liability companies to compensate for any 16 funding shortfall in the Trust Funds. If there are 17 insufficient funds in the Trust Fund, Holtec would 18 likely default on its obligation and likely leave the 19 Commonwealth and its taxpayers with those obligations, 20 both as the payer of last resort and the party 21 responsible for protecting public safety and the 22 environment for an indefinite period.
23 Based on our preliminary review of the 24 license transfer application and the revised Post-25 Shutdown Decommissioning Activities Report, we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 reason to believe that a Trust Fund shortfall could 2 very well occur. For example, Holtec's estimate of 3 what it will cost to decommission, restore, and manage 4 spent fuel at the site is only $3.615 million less 5 than the total amount of money expected to be in the 6 trust. That means there would be insufficient funds 7 to cover any cost overrun in excess of $3.6 million.
8 Past experience, however, including 9 decommissioning experience at other sites in New 10 England, demonstrates that the potential discovery of 11 previously unidentified radiological and non-12 radiological contamination, potential unanticipated 13 work delays, and other potential problematic events 14 could well drive costs significantly beyond 15 preliminary post-shutdown decommissioning cost 16 estimates.
17 For example, the discovery of strontium-90 18 during decommissioning at Connecticut Yankee doubled 19 the anticipated decommissioning cost there. The 20 discovery of highly contaminated groundwater during 21 decommissioning at Maine Yankee also increased costs 22 beyond those anticipated to decommission that site.
23 And the discovery of PCB contamination/radiological 24 groundwater contamination during decommissioning at 25 Yankee Rowe, similarly, caused significant and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 unanticipated cost increases.
2 Holtec and its partner, SNC-Lavalin, have 3 poor track records on other projects at other sites 4 around the country, which amplifies the Commonwealth's 5 concerns about the potential for cost overruns, 6 delays, and other issues that will both imperil public 7 safety and our environment, while at the same time 8 enhancing the risk of a Trust Fund shortfall that 9 would make matters even worse. For example, the NRC 10 just recently issued a Notice of Violation related to 11 Holtec's mishandling of dry cask loading and transfer 12 operations at San Onofre Nuclear Generation Station in 13 California, and its failure to timely report that 14 matter to the NRC.
15 Because of the significant risk to the 16 Commonwealth embodied by the pending license transfer 17 proposal, we implore the NRC to join us in closing 18 scrutinizing the proposal's terms and ensure that 19 substantial financial assurances exist to ensure that 20 those risks are fully addressed. To that end, the 21 Attorney General intends, on behalf of the 22 Commonwealth of Massachusetts, to intervene in the 23 pending license transfer proceeding to articulate 24 these and other concerns for evaluation by the 25 Commission and the imposition of protective safeguards NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 and other conditions with respect to any license 2 transfer.
3 Thank you.
4 MR. KLUKAN: Thank you very much.
5 Next up, we have several authorized 6 representatives from the Board of Selectmen of the 7 Town of Duxbury.
8 MS. M. LAMPERT: Good evening. I'm Mary 9 Lampert, speaking tonight on behalf of the Duxbury 10 Board of Selectmen.
11 The town is very concerned the site will 12 not be properly cleaned up due to reliance on a GEIS 13 written in 2002 and an SEIS written in 2006 that are 14 outdated, incomplete, and ignore new and significant 15 information, and the failure of NRC to require a NEPA 16 analysis, as required by federal law and legal 17 precedent, into insufficient funds in the DTF.
18 With respect to the GEIS and SEIS, Duxbury 19 sees no rational basis for NRC to assume that the 20 environmental impacts are bounded by these documents, 21 nor that environmental impacts will be small or that 22 the site is essentially clean. It is not. A few 23 examples:
24 The SEIS incorrectly denies that the 25 National Academy's Biological Effects of Radiation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 Report, 2006, denies to provide new and significant 2 information from the 1990 report. The 2006 report 3 found mortality rates for women exposed to radiation 4 was 37.5 percent higher than its 1990 report and the 5 impact of allowable radiation standards on workers was 6 twice that estimated in 1990. Therefore, allowable 7 doses need to be reduced from the 25 millirem a year 8 to less than 10 millirem a year, as the State has 9 requested, and reduction in allowable doses to 10 workers. You are obligated to follow the latest 11 scientific information, not go back to 1990.
12 Second, contamination onsite must be 13 updated. In the GEIS and SEIS, NRC didn't lift a 14 shovel. You just relied on the licensees' reports.
15 Their conclusions cannot be relied upon. Pilgrim 16 opened with bad fuel and no off-gas treatment system, 17 and blew its filters in 1982.
18 Where did the contamination go? Hazardous 19 waste is buried onsite, including on the property off 20 the access road. Construction has occurred at the 21 site and the soil buried. What's in that soil?
22 There's a crack in the reactor's torus floor. Soil 23 outside the reactor, beneath it, must be analyzed.
24 The source of tritium levels of monitoring wells is 25 unknown. Other slower-moving radionuclides also are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 likely to be there, not yet picked up by the 2 monitoring wells. Also, what is leaked from seismic 3 gaps and the condensate system? Again, who knows?
4 It's not in the 2002 report. It's not in the SEIS 5 written in 2006.
6 NRC's 2014 continued storage rule that the 7 waste may be stored onsite indefinitely has to be 8 considered. The PSDAR's assumptions that spent fuel 9 will be offsite by 2062 cannot be accepted by NRC.
10 Entergy relied on DOE for its projections, but DOE 11 qualified its projections. Entergy and Holtec did 12 not.
13 PSDAR cost estimates and plans to ensure 14 the long-term integrity of the casks must be revised 15 to provide a contingency fund for long-term storage.
16 NRC's Mark Lombard stated that there is no technology 17 to find cracks in Holtec casks. They're made of steel 18 and subject to corrosion. Dr. Kris Singh, the 19 President of Holtec, said that it's not feasible to 20 repair Holtec's sealed canisters.
21 These facts cannot be ignored. Casks must 22 be better protected, monitored for heat, helium, and 23 temperature, and funds for mitigation included in cost 24 estimates because the fuel, as NRC has said, could 25 remain here indefinitely in an environment subject to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 corrosion, moisture, and salt.
2 The GEIS and SEIS found socioeconomic 3 impacts small. Again, not so. A University of 4 Massachusetts Amherst study commissioned by the Town 5 of Plymouth found that the economic impact on Plymouth 6 alone would be almost $500 million and that there 7 would be more than $100 million impact on the rest of 8 the region, including Duxbury.
9
Conclusion:
therefore, it's clear that 10 the GEIS and SEIS are totally inadequate and do not 11 bound the environmental impact. The NRC must require 12 both a comprehensive environmental analysis that 13 includes shovels and testing, made public, quite 14 obviously, at the beginning of the decommissioning 15 process and a NEPA analysis.
16 This is a major federal reaction. You 17 cannot pretend it is mere oversight to wiggle your way 18 out of the requirement. You gave the license and you 19 will terminate the licenses. That is a major federal 20 action.
21 And thank you very much.
22 MR. KLUKAN: Thank you.
23 MR. J. LAMPERT: I'm Jim Lampert, and I am 24 also here representing the Duxbury Board of Selectmen.
25 And I'd like to speak briefly on just one aspect.
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44 1 The Selectmen in the Town of Duxbury have 2 serious concerns about the financial aspects of 3 decommissioning. You heard Senator Markey's 4 representative, Senator Warren's representative, 5 Representative Keating's representative, and the 6 Attorney General's Office refer to these.
7 Holtec's PSDAR, like Entergy's, says there 8 is enough money in the Decommissioning Trust Fund to 9 accomplish the job. Putting aside all of the things 10 the PSDAR doesn't talk about, and Mrs. Lampert just 11 listed, that assumption by Entergy and Holtec rests on 12 a further assumption that future costs in 13 decommissioning will not be more than future increases 14 in general inflation. That assumption is highly 15 questionable.
16 According to Callan Associates that 17 annually puts together a report on decommissioning 18 costs for the nuclear industry, decommissioning costs 19 increased at an annual rate of about 5.8 percent 20 between 2008 and 2016. This increase in cost is about 21 4.5 percent above inflation. For a benchmark, the NRC 22 and the PSDARs assume that the Trust Fund will grow at 23 a rate of only 2 percent of the general inflation.
24 The NRC's own questions and answers on 25 decommissioning financial assurance say that, over a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 20-year period, there will be an annual increase in 2 decommissioning costs of between 5 and 9 percent.
3 Again, well over both inflation and 2 percent above 4 inflation. If the NRC's statements are correct, and 5 if Callan's reports of actual past history are 6 correct, it seems highly unlikely that there's going 7 to be enough money in the fund to accomplish the job.
8 Which leads me to a fundamental question 9 of the Board of Selectmen: if there is not enough 10 money, what law or regulation requires a licensee, 11 particularly a limited liability corporation like 12 Holtec-Pilgrim, or any of its parent or associated 13 entities, to pay the shortfall? Can you tell me if 14 there is such a regulation? And if so, tell me what 15 it is. And if you cannot do now, can I ask that you 16 tell us all tomorrow night at the decommissioning 17 panel meeting to give you the time to get the answer?
18 MR. KLUKAN: Thank you.
19 MS. CHIN: Rebecca Chin for the Town of 20 Duxbury. The Selectmen asked me to speak on public 21 safety this evening.
22 And we urge you to retain the current 23 offsite emergency planning funded by the licensee 24 until the spent fuel pool is emptied and continue 25 licensee-funded offsite emergency planning on a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 reduced level until all the fuel leaves the site.
2 Entergy has currently filed for a license 3 exemption to end offsite and reduce onsite funding, 4 and this should be denied by the NRC. You cannot 5 expect mutual aid with no funding.
6 The second is on monitoring. Mass 7 Department of Public Health should continue to expand 8 offsite radiological monitoring and onsite tritium 9 monitoring. The licensee should continue to provide 10 Mass Department of Public Health with its funding. It 11 needs to be required of the licensee.
12 Thank you.
13 MR. KLUKAN: Thank you.
14 MS. LYNCH-BENTTININ: Sheila Lynch-15 Benttinin in Duxbury, speaking on behalf of the Board 16 of Selectmen.
17 I would like to address one issue. Forty 18 years ago when community safety was being addressed, 19 telephone poles and speakers were the technology of 20 the time. Currently, in our Town of Duxbury, which is 21 within the 5-mile zone of Pilgrim, we have an Old 22 Colony network, digital network, of public safety 23 addresses. I would like Holtec, if they are going to 24 start next July, to engage the regional fire 25 departments and the Old Colony system of current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 digital notification to be engaged in community safety 2 and planning during the three very important years, 3 especially after what just happened in California with 4 the accident. If there's an accident during the 5 Holtec time, if they're given the license, and you're 6 not up-to-date with the current fire department 7 technologies in the region, it will be a very tragic 8 day. So, I encourage Holtec, if they're given the 9 license in July, to reach out to the regional fire 10 departments and the emergency notification system, 11 which has been greatly upgraded since 40 years ago.
12 Thank you.
13 MR. KLUKAN: Thank you very much.
14 Are there any other elected officials or 15 representatives of elected officials or 16 representatives of federally-recognized tribes who 17 would like to introduce themselves this evening before 18 we move on to the public comment portion?
19 (No response.)
20 All right. Hearing none, I would like to 21 introduce Donna Janda, and we will proceed with the 22 public comment portion.
23 MS. JANDA: Thanks, Brett.
24 Good evening, everyone. As Brett said, my 25 name is Donna Janda, and I'll be facilitating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 tonight's meeting along with Brett.
2 For those of you who registered to speak, 3 you should have received a ticket, the other half of 4 which Brett has in a container over here. And the 5 speaking order is going to be determined by the 6 numbers that are pulled from the container. And the 7 intent of this is so that the speaker order is just 8 random.
9 So, I do want to emphasize there is no 10 prohibition against donating your ticket to others.
11 You are free to do so. However, both individuals 12 should be present at the time that number is called, 13 and the donation must be announced at that time.
14 In addition, if an individual has already 15 spoken during the meeting as a result of someone 16 donating their ticket, and then, that individual's 17 ticket is called, that individual may not use that 18 ticket, but they can donate it to someone else. This 19 is just to give opportunity to everyone to be able to 20 speak.
21 So, when your number is called, please 22 queue up to the microphone that's in the aisle, in the 23 center aisle right there. And if you need to have a 24 microphone brought to you, just let us know, and Brett 25 will take care of that for you.
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49 1 Just so you have some advanced warning of 2 when it's your turn to speak, Brett's posting the 3 numbers right now as I'm speaking, and we're going to 4 just go down them in sequential order there.
5 In an effort to give everybody the 6 opportunity to speak tonight, please limit yourselves 7 to three minutes when we speaking. We do have a clock 8 here on this table in the center here, in front of the 9 podium, and we'll count down those three minutes. And 10 after the three-minute mark, I'll politely ask you to 11 conclude your remarks.
12 For your awareness, the meeting tonight is 13 being recorded, and there is a transcript that will 14 generated after the meeting. Both the audio and the 15 transcript will be posted to the NRC website. So, in 16 light of that, I would ask, when it's your turn to 17 speak, that you please identify yourself. And I would 18 also ask, for the sake of the audio recording, that 19 people not speak over each other.
20 I would also ask that we keep this area 21 clear in front of the stage. If there is something 22 you would like to give to the NRC staff, you can give 23 that to Brett and he'll take care of that.
24 And now, just some basic groundrules to go 25 over. While recognizing many of you have strongly-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 1 held opinions concerning the matters that were 2 discussed tonight, I ask that you, nonetheless, adhere 3 to civil decorum, that you respect each other. So, 4 please do not disrupt each other. Just as you 5 wouldn't want to be interrupted during your three 6 minutes at the microphone, please respect the speaking 7 time of others.
8 Any threatening gestures or statements 9 will under no circumstances be tolerated and will be 10 cause for immediate ejection from the meeting. If you 11 feel you've been threatened, please let me know or 12 please tell one of the NRC security personnel or 13 police officers in the room, and we will try and 14 address that.
15 The one thing that I do want to also 16 note -- and I haven't heard any tonight -- but please 17 make sure you silence your cell phones, so that 18 doesn't disrupt the meeting.
19 And I think we are ready to go at that.
20 So, the first number on the list is No. 2.
21 PARTICIPANT: I've already spoken.
22 MS. JANDA: Okay. Would you like to 23 donate that ticket to somebody else to speak?
24 MR. KLUKAN: Would anyone who didn't sign 25 up yet to speak like to speak right now?
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51 1 (No response.)
2 All right. So, let's break this down.
3 This system is designed -- I actually just experienced 4 this at a Westinghouse meeting in South Carolina where 5 we didn't have that many numbers. So, this is 6 everyone. This is everyone who signed up to speak.
7 So, we have 14 people who signed up to speak. There 8 will likely be some opportunity at the end, after 9 these individuals have spoken, if you haven't signed 10 up to speak, or if you decide after hearing comments 11 to speak then.
12 So, the plan is just to move through these 13 numbers, and then, again, open it up after that. I'm 14 still going to keep people to the three minutes. And 15 then, if people have additional things to say after 16 that, once we've gotten through the list, and whether 17 there's any additional people who would like to speak, 18 then we can add on a second round, as time permits.
19 Okay?
20 So, did anyone want to use the No. 2 21 ticket?
22 (No response.)
23 If not, we will move on to the No. 12 24 ticket.
25 Pass? All right. Look at the time we are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 making this evening.
2 (Laughter.)
3 The No. 1 ticket. Do you want to go?
4 MS. LAMPERT: Yes.
5 MR. KLUKAN: All right, go. All right.
6 MS. LAMPERT: Mary Lampert for Pilgrim 7 Watch.
8 I just want to amplify the concern of our 9 town and other speakers of maintaining licensee 10 responsibility for offsite emergency planning in full 11 force, as it is now, whatever it is, until the pool is 12 emptied, and then, ratcheted-down until fuel leaves 13 the site.
14 What is not properly considered by NRC or 15 the licensees is our acts of malice. We know there is 16 a heightened threat environment, and we know that the 17 spent fuel pool is a vulnerable target, as 18 demonstrated by an expert for our Attorney General, 19 Dr. Gordon Thompson, during relicensing.
20 We know, also, that even in a cask they 21 are vulnerable to acts of malice by a shoulder-launch 22 missile, for example, and then, in the hole, putting 23 in an explosive. This is described in excruciating 24 detail, again by Dr. Thompson, both in hearings in the 25 United States, recent ones, and in Canada.
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53 1 So, you have to consider it. The fact 2 that the probability may be low, you can take an 3 arithmetic view to it because of the consequences 4 being so great as they are.
5 And consider also, we are very glad the 6 ISFSI pad has been moved to higher ground. However, 7 unfortunately, it wasn't moved to the Manomet side.
8 It was moved more towards, I'd say, the Duxbury side.
9 And it is very, very close to Rocky Hill Road.
10 So, we have gained a great deal by not 11 having it subject to climate change effects, but we 12 have lost on security. Therefore, we need a 13 reinforced barrier or some measure, a building or 14 something, to provide the security we need, because 15 the threat is not going away and each cask contains 16 over half the cesium-137 released in Chernobyl.
17 Thank you.
18 MR. KLUKAN: Thank you very much.
19 MS. JANDA: And the next number is No. 3.
20 PARTICIPANT: Pass.
21 PARTICIPANT: I'll take it.
22 MR. KLUKAN: It's important to hold the 23 physical copy of the ticket. I'm just kidding.
24 Could you state your name for the record?
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54 1 from Harwich on Cape Cod, and I also serve on the 2 Nuclear Decommissioning Citizens Advisory Panel. So, 3 I'll see you all tomorrow night, and I appreciate your 4 being here.
5 In case there are people that can't be 6 there tomorrow night that are here tonight, we have 7 heard expressed by numerous folks from our legislative 8 delegation, the Attorney General's Office, a real 9 concern that there isn't sufficient funds. And we 10 could go back and forth on that. It's conjecture.
11 It's based on certain assumptions relative to economic 12 returns on what's in the Trust Fund.
13 So, I guess I have a really specific 14 question. And that is, what happens if there isn't?
15 What happens if there is not specific funds? Where 16 does the burden go?
17 MR. KLUKAN: Thank you.
18 MR. WATSON: The short answer is the 19 licensee remains responsible for completing the 20 decommissioning and providing the funds that are 21 necessary to do that. So, that would be a 22 responsibility that, if we were to grant the license 23 transfer to Holtec, they would be responsible for and 24 for complying with the requirements.
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55 1 question to that, please?
2 MR. KLUKAN: Sure. You have like two 3 minutes left.
4 MR. WOLFE: Okay. Thanks.
5 So, I guess question would be, is there 6 any precedent or is there an ability to hold the 7 original licensee liable in addition to Holtec? There 8 are layers of sort of corporate creation here that I 9 think limit and insulate from liability. So, I 10 question would be, is there a mechanism, is there a 11 precedent, is there a way to keep Entergy potentially 12 liable or the investors in Entergy potentially liable 13 if the funds are insufficient?
14 Because our concern is it goes to that 15 entity, and, of course, the well is dry. And by the 16 way, that is by design. That is by corporate design 17 as far as how this is being constructed.
18 Thank you very much.
19 MR. KLUKAN: Thank you again.
20 MR. WATSON: To the best of knowledge, we 21 don't have any precedent. We have had some sites go 22 bankrupt, and we've worked with the trustee of the 23 Trust Fund to complete the decommissioning. So, 24 there's no -- once we complete our review, and if we 25 were to transfer the license, there would be no going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 back to Entergy for the funds. So, it's either 2 they're going to be qualified to do that and accept 3 that responsibility or not.
4 MS. JANDA: The next speaker will be No.
5 4.
6 MS. TURCO: Diane Turco with Cape 7 Downwinders.
8 Being a good neighbor means taking care of 9 each other and making decisions for the common good.
10 Entergy has advertised itself as a corporation that is 11 a good neighbor -- as long as there is money to be 12 made. Now the plug will be pulled in June and the 13 coffers will dry up. Entergy is running for the exit 14 door and leaving their legacy mess behind.
15 Entergy's PDSR calls for SAFSTOR, making 16 Pilgrim a radioactive holding tank for 60 years.
17 Holtec for DECON, prompt decommissioning using the 18 Decommissioning Trust Fund with exemptions. What is 19 best for the community should be the priority of both 20 their plans, but it is not.
21 We all agree that prompt decommissioning 22 is the best, but it must be done responsibly and 23 safely. The following are our standards to meet the 24 good neighbor requirements:
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57 1 waste, there's still a potential for offsite release.
2 The PSDR must include emergency plans based on low-3 probability, high-consequence incidents, such as 4 terrorists attacks, and be included in the 5 Environmental Impact Statement.
6 Location of the ISFSI pad must consider a 7 technically-defensible onsite storage location.
8 That's not what we have now.
9 Dry cask must be improved with quality and 10 be able to be inspected, monitored, repaired, and are 11 retrievable.
12 Procedures must be in place for transfer 13 of waste from any cracked or damaged canisters or 14 casks which may mean keeping the pool.
15 Procedures and training for fuel transfer 16 with certification of completion by the NRC prior to 17 moving any fuel from the pool.
18 Residual radiation levels must match EPA 19 standards and inclusion of independent oversight.
20 Finally, we ask for an AGO inspection into 21 Holtec and its subsidiaries before any license 22 transfer. As LLCs, this looks like a house of cards 23 with no guarantee that available funds will be 24 available to complete the job.
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58 1 clear assurance that the taxpayers will not be left 2 paying off the mess Entergy has left behind.
3 Looking at Holtec's record from recent 4 events at San Onofre near San Diego, confidence in 5 their ability to make decisions based on protection of 6 the public is questionable. An NRC special inspection 7 report of a near drop of a full canister cited poor 8 training, not following procedures, equipment 9 problems, and mismanagement. Sound familiar? Poor 10 management, poor training, poor procedures, et cetera, 11 has kept Entergy's operation at Pilgrim as the least 12 safe in the U.S. still. This is like going from the 13 frying pan into the fire. We don't need another 14 corporation here with a poor safety culture that puts 15 profit over public safety.
16 We are concerned neighbors and will 17 support a responsible and safe decommissioning plan 18 that protects our communities. If Holtec is setting 19 the standard at SONGS, Cape Downwinders cannot support 20 the transfer of license from Entergy at this time.
21 You need to go back to the drawing board 22 and do better for our communities.
23 MR. KLUKAN: Thank you very much.
24 MS. JANDA: The next speaker will be No.
25 9.
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59 1 MR. ROTHSTEIN: Good evening. Richard 2 Rothstein, Town of Plymouth resident and a new member 3 of the State Nuclear Decommissioning Citizens Advisory 4 Panel.
5 I asked the question during last week's 6 webinar regarding Entergy's PSDAR for SAFSTOR about 7 the anticipated timeline for when the NRC would allow 8 the onsite meteorological towers to get dismantled 9 during the decommissioning process under SAFSTOR. The 10 NRC couldn't answer that question, only because it's 11 a little bit too early in the process. So, I just 12 wanted to rephrase my question.
13 Why is it important to have the onsite 14 meteorological towers? They're important because of 15 emergency planning purposes. In the event of a 16 radiological emergency with the plant still operating 17 or once the plant is permanently shut down, but spent 18 fuel in the pool, before it gets transferred, and even 19 with the dry casks onsite, if there were a 20 radiological emergency, a release, emergency 21 responders would need to have that information to be 22 able to make determinations of shelter in place versus 23 emergency evacuation determinations there. This need 24 doesn't disappear simply just because the plant is 25 permanently shutting down.
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60 1 So, to rephrase my question from last 2 week, I'd be interested in learning about other plants 3 that have decommissioned or are in the process of 4 decommissioning, most using SAFSTOR, but some are 5 probably going to use DECON, and when the NRC allowed 6 a licensee to dismantle the onsite meteorological 7 towers. I don't expect you would have an answer 8 tonight, but certainly in the next few weeks I'd be 9 very interested in learning more about that history, 10 so we can see what circumstances did NRC require those 11 towers to stay up longer or other circumstances where 12 they allowed a licensee to dismantle them sooner than 13 later.
14 Thank you.
15 MS. JANDA: All right. Thank you.
16 The next speaker will be No. 10.
17 MR. WALLEN: Hello. My name is Stan 18 Wallen, a resident of the Town of Plymouth. And I'll 19 disclose that I'm a retiree of Pilgrim Nuclear Power 20 Station.
21 I have one simple question for Holtec.
22 Based on the numbers you put up on the board, where 23 are you going to make $89 million in five years? You 24 need 1.54 billion to decommission in your timeline.
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61 1 money, where are you going to get an additional almost 2 90 million?
3 MR. KLUKAN: One moment.
4 MS. STERDIS: This is Andrea Sterdis.
5 And the cash flow analysis that are 6 included in both the license transfer application as 7 well as the PSDAR for DECON demonstrate that the costs 8 will be distributed over time, and it does accurately 9 reflect the regulations regarding the Trust Fund 10 increases over time.
11 MR. WALLEN: I see. So, I'll just quote 12 a former presidential candidate, that we're working 13 with, "voodoo economics".
14 Secondly, this whole situation here almost 15 looks like it's down pat that Holtec will get a 16 license transfer. What is the consequence of the NRC 17 not approving a license transfer? We're going to have 18 Entergy try to decommission and take 60 years. Is 19 there a method or order or compulsion that can happen 20 to have Entergy accelerate the process? Are we stuck 21 with that if the license transfer is not approved? An 22 NRC question.
23 MR. WATSON: Okay. Yes, first of all, we 24 are in the process of reviewing the Holtec application 25 and the associated financial and technical information NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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62 1 that has been provided. So, there's been no 2 conclusion on that.
3 Should we deny the application and not 4 allow the transfer to take place, yes, Entergy would 5 remain the licensee and be responsible for maintaining 6 the plant in a safe condition. So, we would continue 7 to inspect as we will if the license were transferred 8 the facility to ensure it's maintained safely, and 9 regardless of the DECON option or SAFSTOR option they 10 choose. But the bottom line here is the licensee 11 would be, continue to be Entergy, and their 12 requirement is that they have to complete the 13 decommissioning in 60 years.
14 MR. WALLEN: Thank you.
15 MR. KLUKAN: Thank you very much.
16 Would it be beneficial to people if we put 17 back up the slide with one of the numbers instead of 18 just looking at "Thank you," which I'm sure is very 19 useful to all of you? Maybe either the Pilgrim 20 numbers, or the Entergy numbers or the Holtec number, 21 one of the two? Okay. Thanks for doing that.
22 MS. JANDA: Okay. The next speaker will 23 be No. 14.
24 MS. CONSETINO: Good evening, everybody.
25 I'm Henrietta Consetino, resident of Plymouth and, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 also, Chair of the League of Women Voters Nuclear 2 Committee.
3 And I thank you for coming tonight. We 4 appreciate it. It's very important.
5 I also want to say I appreciate greatly 6 the speakers who came from the offices of our elected 7 officials. It was very helpful to have their 8 comments.
9 I have a question, but I'll save it for 10 last. My first is just a comment in total laymen 11 terms. We have two possibilities right now. On the 12 one hand, we have Holtec proposing to decommission in 13 a very short amount of time, and for cheap, and 14 phenomenally. It just sounds too good to be true, 15 particularly if you start to pay attention to the 16 nature of the dry casks that are being proposed and 17 the fact that these very same dry casks have been 18 tremendously troublesome at San Onofre and probably in 19 other places, too, all of them scratched, being 20 subject to erosion from saltwater, being stored on the 21 beach.
22 At least in San Onofre, the plan was it's 23 now suspended for a time, but the plan was to put 24 these faulty casks in a vaulted system. Here in 25 Plymouth, there is no proposal for any kind of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 vaulting, any kind of hard cover for these very 2 vulnerable casks that could be subject to terrorism.
3 We appreciate the moving of the ISFSI, and 4 that was important to us, but there is much more that 5 needs to be done if Holtec is to have the license.
6 It's also very disturbing that Holtec is requesting 7 waivers for a certain amount of regulations, just as 8 Entergy has been granted waivers for the computer 9 security that was required for all of their plants in 10 the wake of Fukushima, waiver from the kind of hard 11 valves that would make it safer. So, this is 12 disturbing.
13 On the other hand, if we go with so-14 called, grotesquely-called SAFSTOR, 60 years of 15 decommissioning, this is surreal. We will all be gone 16 60 years from now, every single one of us in this 17 room, unless there is a very young person. And many 18 of our children will be gone, too. And I wonder who 19 exactly is going to be in charge, what they will have 20 been told, and so forth.
21 Have I reached my limit? Okay. I stop 22 there then.
23 MR. KLUKAN: Thank you very much.
24 MS. JANDA: The next speaker will be No.
25 8.
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65 1 MR. GARLEY: Hi. I'm John Garley. I'm 2 from Hingham.
3 I have an NRC Information Notice 2012-20 4 that says that chloride-induced stress corrosion 5 cracking of austenitic -- right? You got the right 6 word? -- stainless steel in dry cask storage systems.
7 And there's a couple of times that it happened in San 8 Onofre, St. Lucie Nuclear Power Plant, Turkey Point, 9 and through the wall at Koeberg Nuclear Power Station.
10 Are these casks made out of this austenitic steel?
11 That's a question for Holtec. Austenitic. Are you 12 going to answer the question or?
13 PARTICIPANT: Austenitic.
14 MR. GARLEY: Austenitic? Thank you. Are 15 these casks made out of that? Because this document 16 says that they're cracked from being near saltwater.
17 Do you need to hit a button or something 18 (referring to microphone)?
19 MR. KLUKAN: I'm just going to phrase it.
20 Would someone from either Entergy or Holtec like to 21 answer that question?
22 MR. GARLEY: Well, my concern is that the 23 CEO says that, if there is a crack, you couldn't fix 24 it, right? And you might not be able to find it. But 25 if there's no fuel pool, what do you do with that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 cask? So, that's a question for Holtec. Do we have 2 a solution if there's a cask leak, and what are you 3 going to do with it?
4 MS. J. RUSSELL: My name is Joy Russell.
5 I think that Andrea did introduce me at the very 6 beginning.
7 First, I would like to say that your 8 information about canisters is incorrect. There are 9 no leaking canisters in the United States. Holtec's 10 canisters do not leak. There has been no --
11 MR. GARLEY: The steel has corroded.
12 MS. J. RUSSELL: That is incorrect, sir.
13 I have --
14 MR. GARLEY: Okay. Well, that's an NRC 15 information docket number. So, you might want to 16 check with them. I'm just going by what they have.
17 MS. J. RUSSELL: Okay. Holtec's canisters 18 have no evidence of stress corrosion cracking.
19 MR. GARLEY: Really? All right. Well, 20 you might want to talk to them because they're putting 21 stuff online that says they do. All right?
22 And then, the Sierra Club put a letter to 23 the NRC as well -- it's Event No. 51134 -- that Holtec 24 filled the Diablo Canyon canisters incorrectly in half 25 of them. Is that incorrect as well? Because there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 stuff online you might want to cancel.
2 MS. J. RUSSELL: Sir, I beg to differ with 3 you; that is also incorrect.
4 MR. GARLEY: Again? Okay.
5 MS. J. RUSSELL: The Diablo Canyon 6 canisters, which were loaded by Holtec on behalf of 7 Pacific Gas and Electric, were all loaded correctly in 8 accordance with our Certificate of Compliance.
9 MR. GARLEY: Okay. Well, somebody's got 10 some bad -- and the last thing is with NRC. Are you 11 considering deep isolation technology as well, besides 12 just Holtec's stuff? Because, I mean, we're getting 13 one option here or two that sound pretty bad to me.
14 MR. WATSON: Well, let me just state that 15 there is --
16 MR. GARLEY: It just stopped my number 17 (referring to the tickets for order of speakers).
18 MR. WATSON: There is a need in the 19 country for permanent repository of the spent fuel.
20 MR. GARLEY: Uh-hum.
21 MR. WATSON: The Department of Energy is 22 responsible for developing and finding that site and 23 using the proper technology. So, it's really up to 24 our policymakers in Washington to fund those 25 activities and to allow them to do their work in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 identifying and developing a site and what 2 technologies will be used with that.
3 I think everybody is aware that there was 4 some work-in-progress at the Yucca Mountain site in 5 Nevada. And so, that came to a halt. And so now, 6 it's up to the policymakers to reinstate the need or 7 the promise they made for disposing of this material.
8 MR. GARLEY: Okay. And my last question 9 for Holtec is that you have sent an application to the 10 NRC for interim storage in Lea County, New Mexico.
11 Does that mean you want to move this waste to New 12 Mexico? Is that on your plan?
13 MS. J. RUSSELL: Sir, you're correct, 14 Holtec has submitted a license application to the 15 Nuclear Regulatory Commission to license a 16 consolidated interim storage facility in southeast New 17 Mexico. And if the facility is constructed, it is the 18 possibility of moving the fuel from here to that 19 facility in New Mexico. That is correct.
20 MR. GARLEY: All right. So, the DOE says 21 there's 5,000 train car incidents a year. Do you 22 think that could be dangerous with stuff that's 23 corroded from the ocean?
24 MS. J. RUSSELL: Sir, if I understand your 25 question correctly, you're asking for my opinion --
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69 1 MR. GARLEY: Yes.
2 MS. J. RUSSELL: -- if I think 3 transportation of spent nuclear fuel is safe. Yes, I 4 do. The industry does it on a regular basis. We have 5 transported more than 1380 shipments by rail, all 6 safely, without any release of radioactive material.
7 MR. GARLEY: Okay. Thank you.
8 MS. JANDA: Thank you.
9 MR. KLUKAN: Thank you very much.
10 Before we move, since we do have some 11 time, we kind of left that hanging there, that 12 question. So, just to clarify, so the members of the 13 public don't go away potentially confused on this.
14 Are the casks made out of this kind of 15 steel, or if they're not, could we just state that for 16 the record? Because we kind of moved on to the second 17 question without answering the first. I just want to 18 make sure, because it seemed like there was some 19 confusion about that amongst the crowd.
20 MS. J. RUSSELL: Yes, the canisters are 21 made out of austenitic stainless steel.
22 MR. KLUKAN: All right. Thank you. I 23 appreciate that.
24 MS. JANDA: The next speaker will be No.
25 11.
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70 1 MS. MILLER: Hello. My name is Claire 2 Miller. I'm the lead organizer with Toxics Action 3 Center. We're a public health and environmental 4 nonprofit founded in 1987.
5 And while I don't consider myself to be an 6 extremely young person, it is conceivable that I could 7 live to 93.
8 And I'm a community organizer, but I also 9 happened to grow up -- I was born and raised in 10 Duxbury, Massachusetts. And so, I want to speak a 11 little bit more from the heart tonight.
12 At Toxics Action Center we've really seen 13 over our history that corporations go to very great 14 lengths to avoid cleaning up their messes. And as a 15 teenager, I have a lot of memories hearing about 16 Pilgrim Nuclear Power Plant. It's not every childhood 17 that you learn your home could be in a nuclear 18 meltdown.
19 My father is a curious man. He took tours 20 of the nuclear power plant before they stopped doing 21 that after 9/11. He told me stories about how the 22 folks would say, "Oh, don't stand there. That spot's 23 hot."
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71 1 and them joking about, you know, how the site was --
2 there are hidden mysteries. And my distinct 3 impression was that they weren't kidding, even though 4 they were talking in a funny manner.
5 So, it really disturbs me that this isn't 6 proceeding with extreme care to the data. And I want 7 to say that it's extremely important to me that 8 there's a comprehensive environmental analysis done on 9 the entire site. We have to know really what's there.
10 The second piece here is that, as corny as 11 it may sound, we're in Hotel 1620. I am actually 12 descended from a pilgrim, and that's 15 generations of 13 my family. And I have an intention to do well by this 14 place. You know, my descendants haven't always done 15 well by this land, and I'd like to see 15 more 16 generations. But that's only possible if we do an 17 extremely good job. So, it's very important to me 18 that we honor the Commonwealth's desire for a cleanup 19 standard of no less than 10.
20 And the third thing that I am really 21 sitting on as we're here is really around drinking 22 water. It's so precious. And once it's contaminated, 23 it's extremely difficult to fix.
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72 1 access to clean drinking water. And so, as this 2 continues, as the NRC oversees the future of the site, 3 we have to ensure that there's clean drinking water 4 and we must meet the EPA's own standard of no less 5 than 4 for the drinking water.
6 Thank you.
7 MR. KLUKAN: Thank you very much.
8 MS. JANDA: The next speaker will be No.
9 7.
10 MS. CORRIGAN: Hi. Joanne Corrigan. I 11 live in Plymouth. I can ride my bike to the power 12 plant.
13 I've got a couple of questions. First of 14 all, that beautiful slide they showed of Yankee Rowe, 15 how pastoral it looked after the decommissioning, 16 where are the spent fuel casks? Is that airbrushed or 17 Photoshopped?
18 (Laughter.)
19 MR. WATSON: No, that's an actual picture.
20 The dry fuel storage facility is located above the 21 river there on the hill.
22 MS. CORRIGAN: Because Plymouth will never 23 look like that. First of all, we have that nasty 24 jetty that's ripped the sand off Priscilla Beach. And 25 apparently, that's staying there, even though the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 slides are saying how it goes back to the natural 2 state in the environment. Is that right? Isn't 3 Holtec going to leave the jetty there? After the 4 reactor cools, I know --
5 MR. WATSON: I guess Holtec can maybe 6 answer.
7 MS. STERDIS: It is our plan to leave the 8 jetty there.
9 MS. CORRIGAN: Okay. My other question --
10 and I agree 100 percent with Mary Lampert that you're 11 moving the casks now. Finally you figured out it's 12 too close to the ocean. You didn't need a study.
13 Just come down to Priscilla Beach during a full moon 14 when there's a nor'easter, and you'll see the waves 15 come crashing onto the street. Why they put those 16 first ones so close is beyond me.
17 Now where they're going to move them, 18 they're right out in the open of Rocky Hill Road. And 19 what's to prevent, say, a dump truck with about 10 20 terrorists with RPGs or AR-15s with armor-piercing 21 bullets from stopping there, jumping up, and not 22 shooting at 100 casks, shooting at one cask? What's 23 the chance of that being compromised and breached and 24 releasing radiation?
25 MS. J. RUSSELL: Again, Joy Russell.
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74 1 In November, we presented at the Citizens 2 Advisory Panel a very lengthy discussion -- I 3 personally did that with one of my colleagues -- about 4 the safety and security that's offered by the Holtec 5 HI-STORM 100 System that's in use at Pilgrim. In that 6 discussion, which you can go back and I believe see it 7 online, I presented a long discussion about the casks' 8 ability to withstand even an aircraft crash. So, the 9 system is very robust and it can withstand what you 10 have just described as beyond-design-basis scenarios.
11 MS. CORRIGAN: I see. Well, my third 12 comment is, when Pilgrim was up and running and 13 actually made money, Entergy still couldn't get them 14 out of the column 4 degraded column, didn't want to 15 spend the money, didn't have the expertise, didn't 16 have the enthusiasm, all of the above.
17 What makes you think we are going to 18 believe, after the NRC gives them a pass on the 19 cybersecurity, the everything, that now, all of a 20 sudden, they're offline, they're not making money, and 21 they're going to put in the resource of the money to 22 keep us safe? I don't believe that for a minute.
23 Thank you.
24 MR. KLUKAN: Thank you.
25 MS. JANDA: The next speaker will be No.
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75 1 5.
2 MS. CONSETINO: Now I'll finish my 3 comment, but I'll make it very quick.
4 I wanted to follow up on the comments 5 -- I'm sorry. Henrietta Consetino.
6 MS. JANDA: Thank you.
7 MS. CONSETINO: Plymouth resident, League 8 of Women Voters.
9 I wanted to follow up on the many 10 questions about finances, and go back to Jim Lampert's 11 question. Where is the regulation that actually holds 12 the licensee responsible, should the fund, the 13 Decommissioning Trust Fund, be inadequate? And along 14 the way, what happens if the stock market crashes, and 15 1.05 billion turns into 900 million, or something of 16 that sort? What happens then? What is the state of 17 the Trust Fund right now?
18 MR. KLUKAN: Thank you.
19 MR. TWOMEY: Mike Twomey, on behalf of 20 Entergy.
21 We provide a periodic update on the value 22 of the Trust Fund, and we do not have an up-to-date 23 number available this evening.
24 MR. KLUKAN: Just to follow up, so we 25 don't leave it like that, when do you provide these?
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76 1 So, October was the last one. When would you provide 2 the next one?
3 MR. TWOMEY: Well, we at least provide a 4 number in March of every year as part of our annual 5 disclosure to the NRC. I don't know if we will be 6 providing one before March. And it's actually a March 7 number. I think it actually comes out in April.
8 MR. KLUKAN: Okay. Thank you.
9 MS. CONSETINO: It's worrisome because 10 we've had some very serious major plummets in the 11 market since October.
12 But I want to go back to the first 13 question and make sure you don't forget that Jim 14 originally asked, is there a regulation that holds the 15 licensee to its financial responsibilities? And if 16 so, what is that regulation?
17 MR. KLUKAN: Again, thank you.
18 MR. WATSON: Let me respond. I'm sorry.
19 The regulations for the decommissioning funding are 20 spelled out in 50.82. The actual requirement, if 21 you're going to accept or apply for a license with the 22 NRC, means that the licensee will be responsible for 23 providing the decommissioning funds to restore the 24 site and have the license terminated. Those are in, 25 I think it's 50.2. When a licensee applies for a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 license, there's something called the Common Defense 2 Clause, which means you are accepting that 3 responsibility when you apply for a license, and that 4 you will be radiologically and environmentally 5 responsible for cleaning up the site when you've 6 completed the work.
7 PARTICIPANT: What if they go bankrupt?
8 MR. WATSON: They're still responsible for 9 providing the funding, and that would be part of the 10 process we would go through for getting the assets of 11 the company and continuing the completion of the 12 decommissioning.
13 MR. WATSON: We have two more, and then, 14 we can potentially do a second round. But the 15 question that was posed on the floor, to which Bruce 16 responded, was, what happens if they go bankrupt? I 17 just wanted to make sure we capture that for the 18 transcript.
19 So, next up will be No. 13.
20 MR. GUSTAFSON: Good evening. My name's 21 Scott Gustafson. I'm a Plymouth resident.
22 I'm happy to hear tonight that Holtec is 23 planning on going with the DECON process and the 24 expedited process. I'm here to support the license 25 transfer to Holtec because of their technical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 expertise.
2 As a representative of the Laborers' 3 International Union of North America, our union has 4 worked extensively with Holtec and their subsidiaries 5 around the country, successfully, safely, efficiently.
6 I don't know if some of the references to 7 Holtec tonight are accurate, because we've always 8 worked closely with them. It's always been safe.
9 It's always been very efficient.
10 I have a brother and sister who are 11 working down at Pilgrim now, or have worked on the 12 last two projects with Holtec down there. I don't 13 hear anything about unsafe conditions. I hear that 14 the job is going great; they're moving the fuel 15 correctly, and they're very comfortable, and they're 16 making a great living while they're doing it. The 17 plant has always been an economic benefit to our town, 18 and decommissioning this way will also be a strong 19 economic benefit.
20 I also want to say that Holtec works 21 extensively with our International Union and has 22 helped us develop a state-of-the-art rad worker 23 training program, and we train workers in our state-24 of-the-art facilities here in New England, in 25 Hopkinton, in Pomfret, Connecticut. And over the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 years, our members have decommissioned Maine Yankee, 2 Connecticut Yankee, and the Yankee Rowe Plant, which 3 I actually go rafting up there, tubing up there in 4 that river. It's a beautiful site. I go up there 5 every year. It doesn't bother me at all.
6 I'm happy that it's going to be the 7 expedited decommissioning and return that site back to 8 its beauty that it once was for the Town of Plymouth.
9 So, thank you very much.
10 MR. KLUKAN: Thank you.
11 MS. JANDA: And the last speaker on the 12 list will be No. 6.
13 MS. CARPENTER: My name is Susan Carpenter 14 with the Cape Downwinders, and I live in South Dennis 15 on the Cape.
16 I have a comment, and then, I have two 17 questions. At one of the Nuclear Decommissioning 18 Citizens Advisory Panel meetings, Holtec spoke and 19 said that they have an impeccable safety record. On 20 the other hand, the fact that that near-drop on the 21 West Coast occurred kind of defies their claim that 22 they have an impeccable record. And not only that, 23 but it was a whistleblower that brought this to public 24 attention.
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80 1 interest for Holtec to buy Holtec casks to store the 2 nuclear waste?
3 MR. WATSON: I guess that's a commercial 4 thing that the NRC would not get into, but I don't see 5 any real issue with it. It is what their product line 6 is and what they're offering. And I assume that they 7 will use that, do the work safely and compliantly with 8 the license requirements for the Certificate of 9 Compliance. And we'll be there to inspect to make 10 sure that they are.
11 MS. CARPENTER: Okay. And my other 12 question was: how many sites has Holtec 13 decommissioned? And by that, I don't mean as a 14 contractor. Excluding that, how many sites has Holtec 15 decommissioned?
16 MS. J. RUSSELL: Holtec International has 17 not decommissioned any sites. However, that said, we 18 have hired Comprehensive Decommissioning 19 International, CDI, which is a company that includes 20 SNC-Lavalin, and they have a rich history of 21 decommissioning nuclear plants and other nuclear 22 facilities.
23 MS. CARPENTER: Thank you.
24 MR. KLUKAN: Again, that was Joy Russell 25 of Holtec, just for the purposes of the transcript.
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81 1 All right. We've now exhausted, as you 2 can see -- this is really good handwriting for me.
3 I'm going to pat myself on the back for this. We've 4 now opened it up -- whatever, I'll take what I can get 5 -- to people who have not yet spoken this evening.
6 So, we don't have an established order, 7 but I think Pine raised her hand first. And then, 8 we'll just go around. Okay?
9 So, again, we'll do three minutes apiece, 10 and then, if we have enough time left over, people may 11 get to do a second round. But let's go first with 12 people who have not yet had an opportunity to speak.
13 So, I turn it over to you.
14 MS. DUBOIS: Thank you, and thank you all 15 for being here.
16 I want to state clearly that I hope Holtec 17 succeeds. I hope Entergy is happy, and I hope the NRC 18 finally wraps its head around sea-level rise, which 19 you are not doing, and that is pretty plain with your 20 reliance on the SIEC and the GEIR.
21 There is no basis at all for you to accept 22 Entergy's proposal to wait 60 years to clean up the 23 site. That's plainly a fraud.
24 Take a look at the Fourth National Climate 25 Assessment that was released in late October-November.
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82 1 You will be chapter 18 in the Northeast. You will see 2 that our worst-case scenario is, by 2100, we have sea-3 level rise of 11.5 feet. That's the new estimate, but 4 daily things are changing so fast and the scientists 5 are learning so much, that that adjustment continues.
6 It is important to the public trust that 7 you regulators and you contractors and Entergy -- oh, 8 Lord -- takes care of us and looks at that. Cleaning 9 up the site does not mean letting it wash into Cape 10 Cod Bay, and in 60 years that's what's going to 11 happen.
12 Even if there's not inundation on the 13 site, the groundwater level will be so high that you 14 will not be able to safely and effectively get the 15 contamination out of the ground. If it goes into the 16 environment, the NRC is failing in its mission to 17 protect the environment and the people. So is Holtec, 18 as a reputable company, I will say. So, is Entergy, 19 as a reputable company. You need to address this.
20 The PSDAR for Entergy does not. The Holtec PSDAR does 21 not. And if they run out of money and the cleanup is 22 delayed, we're all in a stew.
23 So, please, NRC, take another look at your 24 regulations. Give it a try at updating that. Call in 25 those scientists that work for the government that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 wrote that report, and get on the reality page. We've 2 living with it here. Stick around on Sunday. Sunday, 3 Monday, Tuesday, stay here. Go down to the plant then 4 and see what happens.
5 Thank you very much.
6 MR. KLUKAN: Thank you.
7 Again, that was Pine duBois.
8 Just please state your name for the record 9 before you begin.
10 MS. DUBOIS: Pine duBois with NDCAP.
11 MR. KLUKAN: So, Pine duBois with NDCAP.
12 Thank you.
13 MR. E. RUSSELL: I'm Ed Russell, an 14 elected town meeting member in Plymouth.
15 When businesses as well as governmental 16 agencies engage in big contracts, they usually see to 17 it that there's a bond produced that will guarantee 18 the performance of the contract. And so, I'd like to 19 know why that isn't possible here.
20 MR. WATSON: Performance bonds are used 21 frequently. If we deem that there's sufficient funds 22 to do the decommissioning, we have no need to require 23 them. I think in the recent VY transfer, Vermont 24 Yankee sale, asset sale and license transfer, one of 25 the conditions we put on -- or the agreement that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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84 1 got from NorthStar was to provide additional financial 2 assurance. I think it was along the lines of $30 3 million to make sure there was sufficient funds. If 4 it's not required, then they're not required. So, 5 it's up to the agreement between the sales, also, to 6 come up with the proper financial information and 7 guarantees.
8 MR. E. RUSSELL: That's your version of 9 risk assessment, but we citizens here have a different 10 assessment of the risk. And when you do have a 11 contract that's just barely enough to cover, and could 12 well exceed the funds available, I would say a prudent 13 entity would look for a bond. And if there is, as you 14 say, a low risk, then the bond should not be that 15 expensive. So, I'd like to see that happen.
16 MR. KLUKAN: Thank you.
17 MR. KELLERMAN: So, my name is Bruce 18 Kellerman.
19 I have a question. What happens to the 20 1200-acre site? Who owns it and are there plans for 21 development? And if so, where can we find those and 22 what are their elaborate schemes?
23 MR. TWOMEY: This is Mike Twomey, on 24 behalf of Entergy.
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85 1 mean the 1200 acres of undeveloped property across 2 Rocky Hill Road, correct?
3 MR. KELLERMAN: Yes.
4 MR. TWOMEY: That property currently is 5 owned by Entergy. It is included in the sale to 6 Holtec. And if the license transfer application is 7 approved and the transaction closes, Holtec will 8 become the owner of the 1200 acres. And I have not 9 heard about any specific plans for development of that 10 site at this time, but they would be the owner of the 11 land after the transaction closes, if it closes.
12 MR. KELLERMAN: Does Holtec have plans for 13 the development of the site? It will be paying -- I 14 assume it will be paying property taxes going forward.
15 MS. STERDIS: No specific plans for that 16 property have been defined at this time. And, yes, we 17 will be paying the appropriate property taxes on that 18 site.
19 MR. KLUKAN: Thank you for your questions.
20 MR. DELAFIELD: Yes, I'm Lawrence 21 Delafield. I'm a resident of the Town of Plymouth, a 22 town meeting member, and the President of the Six 23 Ponds Association, which is a local organization very 24 close to the site.
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86 1 live in an area that will be in danger until this 2 material is totally removed from the site. Why do we 3 have to wait that long? How can we possibly get that 4 moved up, so that it's removed quicker, or at least 5 provide a major incentive to remove all items from the 6 site? Because we will not be safe until that happens.
7 MR. KLUKAN: Thank you.
8 Okay. Is there anyone else who has not 9 yet spoken who would like to speak this evening?
10 (No response.)
11 Going once, going twice. All right.
12 Is there anyone who has spoken this 13 evening who would like to speak again?
14 MR. LAMPERT: Jim Lampert, resident of 15 Duxbury.
16 I'd just like to spend a moment on 17 comments, and if I'm wrong, I would ask that the NRC, 18 Entergy, and Holtec correct me. My understanding of 19 the transaction, as described in the license transfer 20 application, is that Holtec-Pilgrim will be the owner 21 of the site and will be the one who owns the 22 Decommissioning Trust Fund.
23 In Holtec's license transfer and PSDAR 24 applications, it says that, quote, "The existing 25 Decommissioning Trust Funds provide the appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 basis for the financial qualifications of Holtec-2 Pilgrim." It also says that Holtec, quote, "Holtec-3 Pilgrim will be required to pay for HDI's cost of 4 post-shutdown operations, including all 5 decommissioning costs at Pilgrim." Close quote.
6 It seemed very clear from that that the 7 only potential financial responsibility of Holtec-8 Pilgrim -- and that is the only one we need to focus 9 on because they are the only licensee -- depends 10 entirely on the Decommissioning Trust Fund.
11 It also seems clear, listening to Mr.
12 Watson, that a statement in a regulation that a 13 licensee that, frankly, has no money and is bankrupt 14 is, quote, "responsible," close quote, provides 15 absolutely no assurance that that licensee will pay.
16 It, frankly, doesn't have any money. And that, unless 17 I missed something that Mr. Watson has said -- and I 18 asked the question earlier -- there is absolutely 19 nothing in NRC rules, regulations, or pertinent law 20 that would permit the NRC to enforce the licensees' 21 and their parents' responsibility to pay for what they 22 caused. Am I correct?
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88 1 really make at this point, we will be responsible with 2 the responsible regulations. I have to go to our 3 Office of General Counsel for that.
4 MR. LAMPERT: No, no, I would appreciate 5 your doing that, though.
6 MR. WATSON: Yes. No, we have to do that.
7 The other issue is that we are currently 8 reviewing the license application or plan to start on 9 that very soon. So, we really can't pass any judgment 10 other than the general process we're using and the 11 general requirements for the decommissioning funding 12 and how they would apply to the license transfer.
13 It's we're still doing our review. So, we haven't 14 concluded anything. And so, your comments are valid 15 to that review. And so, I'm sure the staff will take 16 that into account.
17 MR. LAMPERT: Yes, and I would ask that, 18 if in the review or in further conversations with 19 Holtec, the NRC or its staff discovers any way in 20 which there, in fact, is an enforceable commitment or 21 an agreement, that people who have the money will set 22 that money up to pay for the shortfall. I would like 23 to hear about it, and it's quite clear that the 24 Massachusetts Attorney General would also like to hear 25 about it.
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89 1 MR. KLUKAN: Thank you again.
2 MR. TWOMEY: Yes, if I may briefly, Mr.
3 Lampert introduced his remarks by saying that, if we 4 didn't say anything, it meant that we agreed with him.
5 And I can't agree to that, just at least on behalf of 6 Entergy. On behalf of Entergy.
7 MR. KLUKAN: Okay.
8 MR. ROTHSTEIN: Richard Rothstein.
9 Two questions. One for Dr. Watson and one 10 for our Holtec representative, Joy.
11 Dr. Watson, can you qualitatively explain 12 or define, for purposes of releasing the site license, 13 site restoration, what basically is included; what 14 would not be included in the case of the Entergy site?
15 So that people don't get false expectations one way or 16 the other.
17 MR. WATSON: Yes. The Decommissioning 18 Fund requirements from the NRC are for the 19 radiological decommissioning. So, once we would 20 terminate the license after verifying the radiological 21 conditions of the site -- we have an independent 22 contractor we use in many cases to help us with the 23 surveys and verify the radiological residual 24 radioactive levels at the site -- we would terminate 25 the license. If the site restoration is not in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 requirements by NRC, because there's a number of 2 approaches you can take to decommissioning -- many of 3 them take into account removing the buildings and 4 turning it back into greenfield. If they submit that 5 to us in their license termination plan, then that's 6 the plan they follow because it's a license amendment.
7 If they choose to do things which some of 8 the other power plants have done, such as Trojan or 9 Rancho Seco, where they actually terminate the 10 license, but leave buildings and stuff still remaining 11 on the site, that's their choice. And after that, 12 it's up to the owner of the facility or the licensee 13 -- and at that point they're no longer the licensee, 14 but the owner of the property -- and the state, to 15 determine when and where they should do the final 16 decommissioning and site -- I should say final site 17 restoration and what those requirements are.
18 MR. ROTHSTEIN: Okay. Thank you.
19 I had the pleasure of sitting in the 20 Holtec predecisional enforcement conference last 21 Wednesday, I believe it was, the four-hour -- and more 22 nuts and bolts were discussed than I could fit in my 23 car.
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91 1 it was very informative, and I believe it's on the 2 NDCAP website.
3 Just expanding upon Ms. Lampert's comment 4 earlier about cracks not being able to be fixed in the 5 multipurpose canister at this day and age, one thing 6 I was envisioning, given that premise, has Holtec, for 7 purposes of future design considerations to remedy 8 that kind of unsolvable problem at the moment, 9 considered constructing a larger multipurpose cask 10 there to go over the cracked cask? And then, of 11 course, that slightly larger cask could be filled with 12 helium gas as a coolant and sealed. And then, that 13 larger cask would then -- or that larger multipurpose 14 cask with the cracked inside of the other cask, 15 multipurpose cask, getting to a larger overpack, if it 16 need be, with the air vents, too. So, is that a 17 possible design solution that may be on the drawing 18 board from Holtec?
19 MS. J. RUSSELL: That's a very 20 explanation. It's very close to what we've actually 21 designed for recovery of a canister in the event the 22 inspections were to show that there has been a 23 degradation. So, indeed, that is the approach, is to 24 put it into another overpack, but an overpack, not 25 necessarily the canister as you've described. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 you're on the right track, sir. It is definitely an 2 additional overpack that we are going to use.
3 MR. ROTHSTEIN: I'm glad to hear that.
4 Can you tell me who I write to at Holtec to get some 5 royalties?
6 (Laughter.)
7 MS. J. RUSSELL: Right. Royalties and to 8 get on the patent.
9 MS. M. LAMPERT: Can a canister be shipped 10 under current regulations?
11 MR. KLUKAN: Ma'am, are you asking, just 12 so we get it on the transcript, are you asking whether 13 the current canister or the overpack can be shipped?
14 MS. M. LAMPERT: (Off microphone.)
15 MR. KLUKAN: Okay. I just have just given 16 you the microphone.
17 So, essentially, can a cylinder which has 18 been or a canister which has been compromised or 19 degraded, do the regulations allow it to be shipped, 20 is the question that was posed by Ms. Lampert.
21 MS. J. RUSSELL: The regulation question 22 I defer to the NRC.
23 MR. WATSON: I ask Jason Piotter, who is 24 our Senior Engineer for Spent Fuel Safety, to come up 25 and give you an answer for that.
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93 1 MR. PIOTTER: The regulations are 2 performance-based. And so, if you had a canister that 3 had a demonstrated flaw like you're talking about, 4 there would have to be an engineering analysis that 5 was done to determine what the best way to mitigate 6 that particular flaw would be. I can't answer the 7 question right now whether or not it would be allowed 8 to be shipped because we don't have any scenarios 9 where there are flaws such as you describe. So, it's 10 a case-by-case basis, depending upon what the 11 situation is for the canister that you're talking 12 about. But it would have to be evaluated prior to 13 transport. I couldn't just be put into a transport 14 overpack and sent. So, it would have to be an 15 engineering analysis prior to that activity.
16 MR. KLUKAN: Thank you.
17 MS. TURCO: I just want to go back to the 18 Holtec in San Onofre because it could be our future.
19 Diane Turco with Cape Downwinders.
20 At San Onofre, they've been loading, 21 Holtec has been loading canisters in underground 22 vaults on the beach. The sea-level rise is eventually 23 going to leak into the bottom of those vaults. They 24 have been loading them and scratching them. And there 25 was a special inspection by the Nuclear Regulatory NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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94 1 Commission and it sounded almost like Entergy's 2 special inspection report, pretty much the same.
3 So, I want to know. And the people in 4 California have said, "Let them know the public in 5 Southern California is asking the Holtec System to be 6 recalled." It's a lemon, and Holtec is making loading 7 errors due to mismanagement and bad engineering design 8 that the NRC admits it cannot fix. So, that's what's 9 happening out in California.
10 So, I have two questions. No. 1, how can 11 you come to the NDCAP meeting and say that Holtec has 12 an impeccable safety record when this was all exposed 13 by a whistleblower?
14 And No. 2, would you conduct an 15 environmental impact study, including sea-level rise 16 and acts of malfeasance on the spent fuel pad?
17 MS. J. RUSSELL: Can you repeat the first 18 question again?
19 MS. TURCO: Let me try it this way: how 20 could you with a straight face tell the NDCAP that 21 Holtec has an impeccable safety record when we know 22 what's going on at San Onofre?
23 MS. J. RUSSELL: I appreciate the 24 question. I understand your concern.
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95 1 impeccable safety record. And the issue that happened 2 at San Onofre, which was reported by the licensee who 3 is the Southern California Edison Nuclear Plant, they 4 went through their process. So, Holtec does have an 5 impeccable safety record. I absolutely can 6 emphatically say that.
7 MS. TURCO: Did Southern Edison report 8 this incident when it happened to the NRC?
9 MS. J. RUSSELL: Those questions are 10 best --
11 MS. TURCO: Okay. No, they did not.
12 MS. J. RUSSELL: -- to the Southern 13 California --
14 MS. TURCO: And you can look up on the 15 record they did not. No. Actually, the NRC initiated 16 the special inspection, right, Mr. Watson?
17 MR. WATSON: From what I understand, the 18 licensee was a little late in responding to --
19 MS. TURCO: Yes.
20 MR. WATSON: -- the requirements. And so, 21 based on that, we escalated our inspections to --
22 MS. TURCO: Thank you.
23 MR. WATSON: -- evaluate the situation.
24 MS. TURCO: Thank you. It was a 25 whistleblower.
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96 1 MR. WATSON: But it was not a 2 whistleblower that submitted the complaint.
3 MR. TWOMEY: This is Mike Twomey, on 4 behalf of Entergy.
5 One thing, I think, just to clear up any 6 confusion for those who don't know as much about the 7 issues as some of the recent speakers. One thing 8 that's important to note here is that, if Entergy 9 remains the owner of the facility, we will be using 10 the Holtec dry fuel storage system. If Holtec becomes 11 the owner, they will be using the Holtec dry fuel 12 storage system. So, the license transfer will have no 13 impact on what system is used at Pilgrim for storing 14 spent nuclear fuel. It will be the Holtec dry fuel 15 storage system that we use or they use.
16 And I don't know how that relates to the 17 scope of this particular proceeding, but I do want to 18 make sure that people understand that it's not an 19 "either/or". It's not like, if Holtec becomes the 20 owner, that's the only circumstance under which the 21 Holtec system will be used. That very same system 22 will be used if we remain the owner.
23 I just wanted to clear that up for 24 anybody who may not understand that.
25 MS. TURCO: Right. Yes. Thank you.
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97 1 Right. Because the point is it's both mismanagement, 2 poor equipment, ongoing problems.
3 But the second question was, would an 4 environmental impact study include sea-level rise and 5 acts of malfeasance on the ISFSI pad?
6 MS. J. RUSSELL: First, I want to 7 emphatically state that the system that's in use at 8 San Onofre is markedly different than the one that's 9 in use at Pilgrim. You're comparing apples to 10 oranges. It is correct. It's an above-ground system 11 versus an underground system.
12 MS. TURCO: Oh, no, no. That's not my 13 question.
14 MS. J. RUSSELL: And not the dry storage 15 system.
16 MS. TURCO: That's not my question.
17 MS. J. RUSSELL: And therefore --
18 MS. TURCO: That's not my question.
19 MS. J. RUSSELL: -- there isn't a 20 probability of an issue as you have at San Onofre with 21 water collection in the bottom of the system.
22 MS. TURCO: Okay.
23 MS. J. RUSSELL: It can't happen because 24 they are two different systems.
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98 1 is, would you include sea-level rise for the property, 2 as Pine spoke about, and storm surges, and acts of 3 malfeasance? That's my question.
4 MS. J. RUSSELL: So, the dry storage 5 systems are licensed under Part 72, and they're 6 deployed under Part 72 currently. And they're already 7 being deployed in accordance with the regulatory 8 requirements. There's no additional investigation or 9 analyses that need to be performed for the dry storage 10 systems.
11 MR. KLUKAN: I gave the women a back-and-12 forth. But, if you know you're going to keep talking, 13 just, for the sake of our poor transcriptionist -- he 14 is not the object of your concern. So, let's make his 15 life easier. So, just speak into the microphone when 16 you're asking questions. Okay?
17 And the question there was, would you 18 include sea-level risk and acts of malfeasance in an 19 environmental assessment or impact statement?
20 MS. J. RUSSELL: We'll meet the 21 regulations. The dry spent fuel storage system is 22 already deployed and it will continue to be deployed, 23 no matter whether this license transfer application 24 occurs or not. I don't understand the question of the 25 need for additional environmental studies related to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 dry storage.
2 MS. TURCO: You're building a new storage 3 facility there, a brand-new storage facility. Right 4 now, you can drive onto the property, pass the "no 5 trespassing" signs, and eyeball the dry casks. Now 6 you're moving them closer to Rocky Hill Road. We need 7 to be assured that there's going to be some increased 8 security there. So, that's just a question. Are you 9 going to be looking at acts of malfeasance when you do 10 the new pad?
11 MS. J. RUSSELL: The security that's 12 already at the nuclear plant, I allow Entergy to talk 13 to. The security of the dry storage system, under the 14 license under Part 72, has already been established.
15 There's no additional requirements that need to be 16 addressed.
17 MS. HALTER: This is Mandy Halter, on 18 behalf of Entergy.
19 The independent spent fuel storage 20 installation facilities are required to be secure.
21 And with the newly-located pad, there will continue to 22 be a physical barrier behind an intrusion detection 23 system, and monitored 24/7 by armed security.
24 And that's correct; that's all I can talk 25 about, due to safeguards.
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100 1 MS. LYNCH-BENTTININ: Sheila Lynch 2 Benttinin, Duxbury.
3 I have a question about regional public 4 safety. In the last 40-plus years, Entergy was 5 required to do a regional public safety plan, and 6 they've applied with their PSDAR to abandon that 7 regional planning. And we are concerned about Holtec 8 taking over. What is your plans for notifying 9 regional safety folks, like firemen, et cetera, on 10 safety, particularly with the expedited four-year plan 11 that you presented tonight?
12 MS. STERDIS: This is Andrea Sterdis.
13 We will continue to comply with all NRC 14 regulation. And I want to emphasize that it is 15 Holtec's top priority to maintain the health and 16 safety of the public.
17 MS. LYNCH-BENTTININ: But what I'm asking, 18 in particular, is, what is your plan to reach out to 19 regional safety folks, like firemen and regional 20 coordinators, as your expedited four-year plan is 21 ongoing?
22 MS. STERDIS: And again, I will emphasize 23 that we will maintain the health and safety of the 24 public, and we will be complying with all regulations.
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101 1 question is, can NRC add to their PSDAR another level 2 of regional safety outreach to public safety 3 officials?
4 MR. WATSON: If I understand your question 5 correctly, there's no need to add anything. Because 6 the site is still going to maintain an emergency plan 7 and emergency response capabilities, along with 8 security response plans, which have those 9 communication tools in them that they're required to 10 have. So, they're going to continue those things 11 until the decommissioning is complete. So, there's 12 really no need to change those plans.
13 Now I can't specifically talk to the 14 regional plan. I'm not familiar with it. It was not 15 an NRC requirement that I know of. But there are 16 requirements for notification and security/police 17 support; also, fire protection and fire response, 18 medical emergencies and medical responses to the site.
19 And so, those things all stay in place.
20 MS. LYNCH-BENTTININ: But Entergy has 21 requested that they be discontinued in the regional 22 capacity.
23 MR. WATSON: All I know is they have to 24 meet the minimum requirements for the NRC, which means 25 they will maintain the ability to talk with, get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 notification of the response capabilities from local 2 and state law enforcement. They will continue to deal 3 with, communicate with the local fire departments and 4 rescue squads.
5 MS. LYNCH-BENTTININ: Would they be 6 required to coordinate --
7 MR. WATSON: The regional, there's no NRC 8 requirement for a regional response plan.
9 MS. LYNCH-BENTTININ: Okay.
10 MR. WATSON: There is one for the 11 immediate location around the plant.
12 MS. LYNCH-BENTTININ: Thank you.
13 MS. MILLER: Claire Miller from Toxics 14 Action Center.
15 I'm getting really agitated because this 16 really matters a lot to me. And if I understand what 17 Diane is bringing up correctly, and your response, Ms.
18 Russell -- it's kind of hard to read your name tag 19 from here; sorry if I got that wrong -- it's that we 20 have rapidly upchanging data on climate change, the 21 impacts of sea-level rise that are getting worse every 22 time they're updated. We have someone in the White 23 House who's changing world politics and dynamics 24 rapidly, and we are living in an age in which 25 terrorism is ever present. And we want to know, are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 you willing to go above and beyond, if necessary, or 2 are you only willing to do as much as -- like the 3 floor of what's required?
4 Because what I hear Diane asking is, are 5 you willing to go above and beyond to protect our 6 health, our community? And what I hear you saying 7 back is, "We're doing with it what's written. We're 8 just going to do what's necessary, what the law is."
9 Am I understanding correctly? You're committing to 10 the floor?
11 MR. WATSON: I just want to respond to 12 that, and that the NRC regulations fully provide for 13 safety for the people working at the plant, the 14 public, and the environment. And so, complying with 15 those is one demonstration that the plant is 16 maintained safe, and we'll continue to inspect that 17 plant against those requirements.
18 MS. MILLER: I have no doubt that the NRC 19 is doing the best that it can to protect the health 20 and safety of my community. I also know that we're in 21 a rapidly-changing world. And I am interested to know 22 if Holtec is committing to the floor of what the NRC 23 -- like where we're at the last time those laws were 24 passed, those statutes, those regulatory processes we 25 went through, those elaborate commenting periods, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 if they're committing to respond to an ever-present, 2 fast-changing world of climate change and terrorism.
3 MS. J. RUSSELL: I think what you're 4 asking me is, am I confident that our dry spent fuel 5 storage system is safe.
6 MS. MILLER: No, that's not what I'm 7 asking you at all. It's not what I'm asking you at 8 all.
9 MS. J. RUSSELL: I am personally convinced 10 -- I am a nuclear engineer. I am part of the design 11 team that designed this dry storage system. And I am 12 confident in its robustness. I'm confident that we 13 have gone above and beyond to ensure that we selected 14 materials --
15 MS. MILLER: I am --
16 MS. J. RUSSELL: -- that we've selected 17 the methodologies, and we have done the absolute 18 utmost we can to ensure the health and safety.
19 MS. MILLER: I have no doubt that you're 20 sincere --
21 MS. J. RUSSELL: May I please finish?
22 I live by these nuclear plants as well, 23 and I am confident that, when I go to visit these 24 plants -- I live by these plants; I live by where our 25 dry storage systems are deployed -- I am personally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 confident that my company has done everything it can 2 to go above and beyond. And therefore, I have 3 answered your question.
4 MS. MILLER: That wasn't my question in 5 the slightest. I do believe you're 100 percent 6 sincere when you say that. I also believe that the 7 engineers who worked on Chernobyl, Three Mile Island, 8 and Fukushima were also really sincere in believing 9 that their plants were safe as well.
10 I just want to say for the record you 11 didn't answer my question.
12 MR. KELLERMAN: So, Bruce Kellerman again.
13 My question is to Holtec. As I understand 14 the fund, it can go up and down. It's like a 401(k),
15 right? It's an investment vehicle. What happens if 16 it goes down? And also, could you, would you sue the 17 Department of Energy, as others have done, for failing 18 to take the waste offsite? Would you plan to do that?
19 Are you?
20 MR. WATSON: Well, let me respond to the 21 first part. Yes, there are market changes. The Trust 22 Fund is in an independent trust with an independent 23 trustee. Most of them are with Mellon Bank of New 24 York. So, the trustee has certain requirements on 25 them to make conservative investments to protect the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 fund.
2 Secondly, all the licensees that are 3 storing fuel -- I'll say broadly "everyone" -- has the 4 ability to request or sue, if they have to, the 5 Department of Energy to get the cost back for the 6 storage of the nuclear fuel. So, I'm sure Entergy has 7 done that in the past for their plants. I'm sure 8 Holtec will do the same to recoup the costs. Those 9 costs are, then, available for doing other activities 10 at the sites. And so, that's part of the agreement 11 with the federal government.
12 MR. KELLERMAN: Thank you.
13 MS. LAMPERT: Two points. NRC is giving 14 exemptions. So, the DTF can be used for spent fuel 15 management costs. Now go back. The Decommissioning 16 Trust Fund was established when we were a utility 17 structure -- Boston Edison was the owner -- by 18 ratepayers. Since that time, it's grown from 19 investments. Entergy didn't put a dime in it. Holtec 20 won't put a dime in it. Okay?
21 Then, they will sue DOE to recoup what 22 they've spent on spent fuel management costs, okay, 23 what they've spent by taking it out of the 24 Decommissioning Trust Fund. But, then, when they get 25 the money out of DOE, there's no requirement to put it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 back. If there is, please correct me and give me the 2 regulation. Instead, they put it in their pocket.
3 And that's, you know, if I were Holtec, I'd say, "I'm 4 going to make a pile of money doing this." And that's 5 part of the incentive to take over the license.
6 It would seem to me that the NRC would get 7 on the stick and make some sort of 8 requirement/regulation that it goes back into the 9 Decommissioning Trust Fund to refurbish what they have 10 taken out. Because there's no requirement? Correct 11 that.
12 And then, I just want to sum up by saying, 13 the points brought forward on sea-level rise, the 14 points brought forward on the increased risk of 15 terrorism, of cyberattack -- now that's a big one when 16 you think of the spent fuel pool. All these new and 17 significant information that you should be 18 responsible, NRC require that they do a NEPA review, 19 and then, not say what is blatant foolish. It's a lie 20 to say the 2002 Generic Environmental Impact Statement 21 and the 2006 Impact Statement done during relicensing 22 bound environmental impact, so we can all skip along 23 and say it's a clean site; we've done our job. So, 24 they really don't have to spend a dime, and all the 25 stuff can go in Cape Cod Bay. Dilution is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 solution.
2 MR. KLUKAN: Thank you.
3 MR. WATSON: I just want to make one 4 comment, that the Decommissioning Funds that are -- or 5 excuse me -- the spent fuel funds that are recuperated 6 from the Department of Energy, I think it's 50.82, 7 Mike, in the regulations, the fund. The money goes 8 back into the fund. No? It doesn't? Okay.
9 PARTICIPANT: It goes to the company.
10 MS. LAMPERT: No, it's a good thing for 11 them to make money.
12 MR. WATSON: Okay. Well, I'm sorry. I 13 appreciate the comment then. We have to look at that.
14 MR. KLUKAN: Before you begin, is there 15 anyone else in the audience who has not yet had an 16 opportunity to speak who would like to do so?
17 (No response.)
18 Okay, please. Would you mind letting her 19 go first? Okay. Thank you, sir.
20 Your name for the record, please.
21 MS. GARRY: Joanne Garry. I live a mile 22 from the plant. I've been here since I was 16. So, 23 I saw it built by people that shouldn't be building 24 it. But that's not my question.
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109 1 Entergy owns it, correct? Got the license. Owns all 2 the property. How much is it worth? What's the 3 property worth? What did Entergy get or might get 4 from Holtec, the cost, the dollars? Are you selling 5 it for money? So, there's no money exchange? Entergy 6 walks away. Holtec, if it gets the license, walks in, 7 correct?
8 So, why does Holtec want this? Well, 9 that's my question. Why does Holtec want this really 10 horrible thing to fix? We've got thousands of people 11 on the line. So, what's the deal? Why are you doing 12 this? No answer?
13 MS. STERDIS: This is Andrea Sterdis, and 14 I will make this a personal response.
15 As a mother of two children and a 16 grandmother of four children, I am committed to us 17 doing in this industry what is right. And that is to 18 take care of our plants when they're past their 19 operational life expectancy and to turn that property 20 back into a useful piece of property in the community.
21 So, that is my personal reason for being involved in 22 this project.
23 MS. GARRY: But it's in it for the money.
24 So, the money, you're going to own 12,000 acres.
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110 1 that hasn't been developed. Why not move all this 2 terrible spent fuel to the top of the hill? If you're 3 going to move it; move it, move it away from the ocean 4 or bury it in the hill -- I don't know -- a better 5 solution than moving it next to Rocky Hill Road, which 6 I go by every day. So, I mean, it just seems simple 7 solution. If you can't move it away, move in a safer 8 area.
9 But, again, you're going to be making big 10 bucks here. So, we want to be safe.
11 That's all I have to say.
12 MR. KLUKAN: Before we begin, because we 13 do have -- I'm sorry for interrupting you again, sir.
14 Just because we do have extra time -- I don't usually 15 intervene like this, but I think there's some 16 confusion out there regarding what's the financial 17 arrangement between -- and I'm not asking in specific 18 terms -- but what's the financial relationship between 19 Holtec and Entergy?
20 And I think the question was asked like, 21 how would Holtec benefit from this transaction? And 22 I think if we could answer that, that would go a long 23 way to clearing up some of the confusion in the 24 audience.
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111 1 Entergy. I'll address the specific question of the 2 way the transaction is structured.
3 Entergy is receiving only nominal 4 consideration. And I have to say I don't have the 5 number in front of me. We just recently closed the 6 Vermont Yankee transaction, and the nominal 7 consideration there was a thousand dollars.
8 And we receive nominal consideration.
9 Holtec receives title to the plant or they're actually 10 buying Entergy Nuclear Generation Company through an 11 equity sale. They get that company which owns the 12 plant, has the Decommissioning Trust Fund and the 13 liability for the decommissioning.
14 So, what Entergy gets out of the 15 transaction is a thousand dollars. And we are no 16 longer involved in the decommissioning of the plant, 17 in the same way that Boston Edison is not involved in 18 the decommissioning of the plant. All right. We're 19 going to transfer that responsibility to Holtec, and 20 Holtec will receive the project, the plant, the 21 Decommissioning Trust Fund, and the work associated 22 with it.
23 And I'll let Holtec describe why they 24 would be willing to take this work on, as other 25 companies have taken it on in other parts of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 country.
2 MS. J. RUSSELL: Again, this is Joy 3 Russell from Holtec.
4 Holtec is, and has been for 30 years, an 5 industry leader in safe and secure storage of spent 6 nuclear fuel. We also have other business endeavors 7 such as designing a small modular reactor. And as 8 we've pointed out this evening, we also have submitted 9 an application to establish a consolidated interim 10 storage facility in southeast New Mexico.
11 Holtec is committed to the nuclear 12 industry. And unfortunately, part of that also 13 includes the safe decommissioning of nuclear power 14 plants.
15 We recently built our third manufacturing 16 facility here in the United States. We now have 1.4 17 million square feet of manufacturing here in the 18 United States. We're the largest exporter of nuclear 19 products. And again, that's a demonstration of our 20 commitment to the nuclear industry.
21 So, that is Holtec's reason for taking the 22 next step and to acquire shuttered nuclear plants and 23 to safely decommission those; and to take the 24 ownership of the spent nuclear fuel, which is also our 25 core expertise, and to manage that as it remains NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 either onsite or is moved to New Mexico.
2 MR. KLUKAN: Thank you.
3 And thank you, sir, for indulging me for 4 that minute.
5 MR. ROTHSTEIN: I've got all the time in 6 the world.
7 A final question for Dr. Watson. I was 8 hoping that NRC's proposed revised decommissioning 9 regulations were going to come out last November, as 10 originally envisioned, and that final promulgation 11 would have taken place sometime in the first half of 12 this year. Notwithstanding the current government 13 shutdown, what is NRC's ETA for when it was 14 envisioning getting these proposed and final 15 regulations out?
16 And a second question is, licensees who 17 have submitted their PSDARs, even if they're in the 18 process of being evaluated, or the NRC said, okay, 19 they're good enough, so you can start the 20 decommissioning process once the plant is permanently 21 shut down, would existing licensees in those 22 circumstances get grandfathered separate from the new 23 regulations for decommissioning? Or would it be like, 24 for example, a post-Fukushima, where the NRC says, 25 okay, we've come up with this and the new regulations; NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 1 therefore, all licensees must do blank, blank, blank 2 for decommissioning, regardless of what was in your 3 PSDAR?
4 MR. WATSON: Let me respond to the 5 rulemaking schedule. The proposed decommissioning 6 rulemaking that's been in progress over the last few 7 years, the staff made its scheduled requirement to 8 submit to the Commission the proposed rules and the 9 basis for those proposed rules back in May. As many 10 of you may know, we also had two new Commissioners 11 appointed by the Administration. And based on that, 12 they've been taking care of the backlog of information 13 or voting issues that they have on their plate.
14 So, the staff is waiting for the 15 Commission to do their job. So, it's the Commission's 16 priority to address their work at their own schedule.
17 So, the staff is waiting for the Commission to vote on 18 it. We have not received a schedule of when that vote 19 is to take place. And so, we are basically at the 20 mercy of the Commission for meeting the time limit 21 requirements they had originally placed on us to have 22 these rules in place by the end of 2019.
23 So, we will, hopefully, resolve the issue 24 with a Commission vote. That will give us the 25 direction on how we are to proceed with the proposed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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115 1 rules.
2 One of the proposed evaluations was 3 looking at the PSDARs. If there is a change in the 4 regulations that the Commission wants concerning the 5 PSDARs, then we will issue the regulations and the 6 guidance with that. And anybody that would come out 7 in the future would have to comply with the new 8 regulations. Since the plants that are already in 9 decommission have submitted their PSDAR, if they were 10 to revise that, we would believe they would have to, 11 at least I would believe that they would have to 12 comply with the new requirements.
13 So, I think I answered both questions.
14 But we're at the mercy of the Commission and their 15 vote scheduling. And apparently, they have more 16 pressing issues than the decommissioning rulemaking.
17 MR. LAMPERT: Jim Lampert, Duxbury.
18 I've spent a lot of time thinking and 19 trying to figure out the answer to the question why 20 would Holtec get into this. And in addition to the 21 fact that it's your business, I think the obvious 22 answer is they expect to make a profit.
23 And if you ask yourself on what basis do 24 they expect to make this profit, a number of things 25 that I think are fairly clear, if you look at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 1 whole picture, come to mind. And to the extent 2 anybody, Holtec disagrees with me, and you think you 3 can, consistent with the limitations of what you can 4 say, correct me; please do so.
5 The first is they obviously think they're 6 a great deal more efficient at doing this type of 7 thing than Entergy ever will be.
8 The second is they want to get the 9 decommissioning done early to avoid the risk of 10 drastically-increasing costs that could be --
11 "destructive" is a nice word -- if they waited the 12 period of that Entergy was planning to wait.
13 The third is that I was told by a Holtec 14 representative that their profit is included in the 15 costs you see in their PSDAR.
16 And last, just talking to various people 17 in the industry, my understanding is that, before 18 someone will get into something like this, they really 19 need a fairly clear path to what they see as a 25- to 20 35-percent profit.
21 MR. KLUKAN: Thank you.
22 MS. CARPENTER: Susan Carpenter with Cape 23 Downwinders.
24 This has nothing to do with money, but it 25 has to do with ethics. Recently, I know that Holtec NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 changed the design of its casks for San Onofre and did 2 not notify anyone, and that it really took Southern 3 California Edison and Entergy by surprise. And I'm 4 wondering if Holtec, having basically gotten away with 5 it because it was eventually approved, if they feel 6 that they can do that here or if there's a likelihood 7 they'll do that in the future, and we'll end up with 8 something different than what we've negotiated for.
9 MS. J. RUSSELL: The statements that you 10 just made I need to disagree with. They're incorrect.
11 I'll correct them.
12 The design of the system was not changed 13 for San Onofre.
14 Actually, the amount of time it would take 15 me to actually correct all of your statements is going 16 to exceed the time we have, and I would hate to do 17 that, so that other speakers to have an opportunity to 18 speak.
19 I'd recommend that you go and listen to 20 the NRC's PEC Conference that was held last Wednesday, 21 the 9th of January. It explains the entire process.
22 But you've incorrectly characterized that.
23 MS. CARPENTER: May I send you the article 24 where I got the information?
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118 1 said.
2 MR. KLUKAN: May she send you the article 3 where she learned of this information?
4 MS. J. RUSSELL: Absolutely.
5 MS. JANDA: Just to clarify for the 6 transcript, the PEC video -- I hope I'm not restating 7 this -- is available on the NRC website. I think it's 8 video.nrc.gov, will be the quickest way of getting 9 there.
10 MS. CARPENTER: This is the Orange County 11 Register. The title is, "NRC and Holtec to Face Off 12 Publicly Over Redesign of Spent Fuel Canisters at San 13 Onofre Plant".
14 I wonder if, are they wrong in their 15 headline?
16 MS. J. RUSSELL: I'm sorry, re-read the 17 headline again?
18 MS. CARPENTER: "NRC and Holtec to Face 19 Off Publicly Over Redesign of Spent Fuel Canisters at 20 San Onofre Plant".
21 MS. J. RUSSELL: The headline is 22 misleading. We didn't redesign the canister for San 23 Onofre. And again, it's a lengthy discussion, and 24 it's all captured in a video from the PEC Conference 25 on January 9th, where Holtec had a meeting at the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 Headquarters.
2 MS. CARPENTER: From what I understood, 3 they have a difference in the canisters. But it was 4 aware of, down at the bottom there were bolts added, 5 and that design was only discovered when one of the 6 bolts was loose in the canister.
7 MS. J. RUSSELL: Again, you're making 8 misstatements, and we could go back and forth all 9 evening on this. I recommend that you get your facts 10 from this PEC video from the January 9th meeting.
11 MS. CARPENTER: Okay. And I will recheck 12 with the newspaper as well.
13 Thank you.
14 MR. KLUKAN: Thank you.
15 MR. DELAFIELD: This is Lawrence Delafield 16 again.
17 I didn't really get an answer to my 18 question. So, I'd like to restate it in a slightly 19 different way.
20 The question -- and it was a question --
21 is there any way at this point in this process that we 22 could require that the material be removed and put in 23 a secure facility someplace else, such as you're 24 talking about doing in New Mexico, and get it away 25 from the community? Because we will not be safe until NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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120 1 that happens. Or, if that's not the case, is there 2 any way to give an incentive so that it gets removed 3 faster and moved to another location? I did not 4 receive an answer to that. So, I'd appreciate getting 5 an answer.
6 Thank you.
7 MR. TWOMEY: This is Mike Twomey, on 8 behalf of Entergy. I'll answer that because we're the 9 current owner of the facility.
10 I believe what your question is when you 11 talk about the material, you're referring to the spent 12 nuclear fuel. And the answer to that is, the United 13 States Federal Government is responsible for removing 14 the spent nuclear fuels from the Pilgrim site and 15 every other nuclear site in the country. And the 16 federal government has repeatedly breached its 17 obligation to do so. And many of us have been 18 required, not personally, but Entergy has been 19 required to sue the federal government for failing to 20 fulfill its obligation.
21 So, the only answer I can give you is that 22 -- I know there were some representatives of some 23 federal Congressmen here tonight -- it is to talk to 24 them about when the federal government is going to 25 fulfill its obligation to remove spent nuclear fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 from the Pilgrim site as well as the other sites in 2 the U.S.
3 MR. KLUKAN: All right. So, it's 8:47.
4 We're scheduled to go to 9:00 p.m.
5 Is there anyone who would like, who has 6 not yet spoken who would like to make any additional 7 comments before we close this out?
8 (No response.)
9 Going once, going twice. All right.
10 Before I turn it over to Bruce to close 11 out the meeting, I would just like to thank all of you 12 for attending, personally from the facilitators, and 13 to say, out on the registration table there are 14 feedback forms. Donna and I would greatly appreciate 15 you filling those out. We use your feedback in trying 16 to make these meetings better in terms of public 17 process. So, please take a couple of minutes to do so.
18 And with that, I'll turn it over to Bruce.
19 Thank you.
20 MR. WATSON: Well, the first thing I want 21 to thank you for is coming out tonight. I know this 22 is an important issue to many of you.
23 Your comments will inform the staff on the 24 NRC's review of the PSDAR. I heard some very good 25 comments for our consideration. And then, when we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 look at the license transfer request and the 2 application and its PSDAR, those comments can also be 3 taken into account there.
4 As a reminder, you could provide written 5 comments, I believe it's through March 21st. We will 6 be publishing The Federal Register notice on the 7 license transfer when the rest of the federal 8 government goes back to work. The comment period, 9 again, is going to be 30 days for that and 20 days for 10 hearings. So, you're hearing about it early before 11 the notice is published. So, we look forward to your 12 comments.
13 Again, I want to thank you for your 14 comments and questions. We will be, at least I will 15 be, and a couple of the other NRC will be, at the 16 Massachusetts Nuclear Decommissioning Citizens 17 Advisory Panel tomorrow evening. So, I'm sure we'll 18 be having some more discussions on the topic.
19 So, with that, I would thank our panelists 20 and our presenters for their presentations and in 21 answering questions where we could.
22 With that, I would adjourn the meeting.
23 Thank you very much.
24 (Whereupon, at 8:49 p.m., the meeting was 25 adjourned.)
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