ML19031B825
| ML19031B825 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 02/07/2019 |
| From: | John Lamb Special Projects and Process Branch |
| To: | |
| Lamb J, NRR/DORL/LSPB, 301-415-3100 | |
| References | |
| EPID L-2018-LLL-0031, NRC-0051 | |
| Download: ML19031B825 (129) | |
Text
MEMORANDUM TO:
FROM:
SUBJECT:
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 7, 2019 File John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation I.' I :~;7/~~
I TRANSCRIPT FOR PUBLIC MEETING At:LD ON JANUARY 15, 2019, IN PLYMOUTH, MASSACHUSETTS R~f3ARD1NG SEABROOK NUCLEAR POWER STATION POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT AND LICENSE TRANSFER APPLICATION (EPID L-2018-LLL-0031)
The purpose of this memorandum is to provide, and make available to the public, a corrected transcript associated with the public meeting held on January 15, 2019, in Plymouth, Massachusetts regarding the Pilgrim Nuclear Power Station (Pilgrim) Post-Shutdown Decommissioning Activities Report (PSDAR) and license transfer application (LTA). The original transcript is contained in Agencywide Documents Access and Management System Accession No. ML19029A025.
The enclosure contains the corrected transcript from the public Pilgrim PSDAR and L TA meeting. The transcript has been corrected based on review by the U.S. Nuclear Regulatory Commission staff. Areas where corrections were made to the original transcript are marked in square brackets and highlighted, with errors marked with strikethrough.
Docket No. 50-293
Enclosure:
Transcript of Public Meeting regarding Pilgrim PSDAR and L TA
Official Transcript of Proceedings NUCLEAR REGULATORY'COMMISSION
Title:
Public Meeting on Pilgrim Post-Shutdown Decommissioning Activities Report Docket Number:
(n/a) [50-293]
Location:
Plymouth, Massachusetts Date:
Tuesday, January 15, 2019 Work Order No.:
NRC-0051 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C.
20005 (202) 234-4433 Pages 1-122
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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PUBLIC MEETING ON PILGRIM POST-SHUTDOWN DECOMMISSIONING ACTIVITIES REPORT
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- TUESDAY, JANUARY 15, 2019
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PLYMOUTH, MASSACHUSETTS
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1 The meeting was convened in Room A, Hotel 1620, 18 Water Street, Plymouth, MA, at 6:00 p.m.,
Bruce Watson, chairman, presiding.
C STAFF:
DONNA JANDA, Facilitator BRETT KLUKAN, Facilitator JOHN LAMB, Office of Nuclear Reactor Regulation BRUCE WATSON, Office of Nuclear Material Safety and Safeguards LSO PRESENT:
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2 CONTENTS Opening Remarks................. 3 Bruce Watson Decommissioning Experience................. 5 Bruce Watson Pilgrim Decommissioning John Lamb................................... 8 Mandy Halter............................... 14 Andrea S terdi s............................. 2 O Comments from Elected Officials, Representatives of Elected Officials, or Representatives of Federally-Recognized Tribes Jessica Wong............................... 27 Rory Clark................................. 2 8 Michael Jackman............................ 33 Seth Schofield............................. 36 Mary Lampert............................... 40 Jim Lampert................................ 43 Rebecca Chin............................... 4 5 Sheila Lynch-Benttinin..................... 46 Public Comments.................................. 52 Closing Remarks djourn (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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P R O C E E D I N G S 6:02 p.m.
MR.
WATSON:
Good evening.
I'm Bruce Watson, Chief of the Reactor Decommissioning Branch in the Division of Decommissioning, Uranium Recovery, and Waste Programs, and will be chairing tonight's session.
Our purpose is to obtain your comments on the Entergy Post-Shutdown Decommissioning Activities Report [PSDAR] and the Holtec license application and the related Post-Shutdown Decommissioning Report associated with it.
I would like to highlight [U.S. Nuclear Regulatory Commission]
NRC's mission to protect ublic health and safety, promote the common defense and security, and protect the environment, and our current work related to the regulatory requirements during the decommissioning of power plants.
I would like to introduce a few of the C staff who will be here to listen to your comments.
d hopefully, we, the staff, can collectively answer questions on the decommissioning process.
If we can't, we'll do our best to get back to you.
Counselor, (202) 234-4433 So, you've met
- Brett, our Region I
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eeting, along with Donna Janda, also from Region I.
lso in attendance is John Lamb, the current Project for Pilgrim.
Amy Snyder is here, who will e the Decommissioning Project Manager when the plant shuts down and is transferred over to our organization.
Also in attendance is Mike Dusaniwsky, our Senior Economist; Jason Piotter, Senior Engineer in our Spent Fuel Management Group; Jessie Quintero, our Environmental Review Specialist, and Ray Powell, our Region I Branch Chief that will be inspecting the lant during the decommissioning process.
We also have some additional folks in the audience that, if we need to, we can call on them to help us with comments or questions.
Next slide, please.
This is an NRC Category 3 public meeting to obtain comments on the Entergy PSD [A] R a:q.d the Holtec application and their supplemental PSD [A] R that's with it.
These documents were made publicly available for comment.
The meeting is being transcribed and will be made available for the public to review.
There will also be a meeting summary published for the eeting.
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We have a planned short presentation by John Lamb, who will discuss the PSD[A]R process and the license review process.
Then, Entergy and Holtec will be giving short presentations.
Speaking for Entergy tonight is Mandy Halter - - she is the Director of Nuclear Licensing and Andrea Sterdis from
- Holtec, who from also the Comprehensive Decommissioning International, who is a
Vice President of Regulatory Programs, Environment and Safety.
After those presentations, we will turn the meeting over to Brett and Donna, who will begin the process to allow speakers to provide comments.
It is my full intention, if we can, to end this eeting at 9:00 p.m.
I also want to emphasize that this eeting is to discuss the upcoming permanent shutdown of the Pilgrim Plant and the decommissioning process associated with it.
Next slide, please.
Now I want to just discuss a little bit of our decommissioning experience.
We have many years of decommissioning experience.
We have over 21 years' experience with our current decommissioning regulations and have completed over 80 complex (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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aterial decommissionings and terminated those They have all been released for nrestricted use by the owner.
So, they can be used for any future purpose.
And included in that 80 is 10 nuclear power plants.
Next slide, please.
On this slide is a picture of Yankee Rowe.
It's located here in Rowe, Massachusetts.
It's one of the 10 plants that was decommissioned.
We terminated the license in 2007.
Pictured on the left is the plant when it was in operation.
Pictured on the right is where the plant was greenfielded by the utility associated with the requirements set up with the State.
The NRC does not require site restoration as part of our process.
One of the things that I want to point out to you is that, on the picture on the right there is a hydroelectric dam that's been there for over 100 ears.
As you note, the nuclear plant operated, was decommissioned, and is gone.
However, on the hill in the center there is a picture of the dry fuel storage facility that is still located on their site and under license, and will continue to be inspected by our inspectors.
Of course, the spent fuel is there awaiting the final disposition of the high-(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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level waste
- disposal, either interim or final repository, here in the U.S.
Next slide, please.
I wanted to just briefly discuss the two decommissioning options discussed in the November 20~[1]8 submittals.
Regardless of the option chosen, reparation of the decommissioning takes about one to two years to remove the radioactive waste st.ored
- onsite, remove filters, resins; drain systems to allow the dismantling to begin and be done safely or laced in storage.
After the decommissioning reparation period, the licensee can go into either DECON or SAFSTOR.
DECON, or a prompt decommissioning, the licensee begins the decommissioning activities and usually transfer the spent fuel to dry storage.
Past experience has shown that decommissioning typically takes seven to ten years to complete.
With SAFSTOR, the plant is placed in storage we like to call it, it's cold and dark -- until the licensee decides to dismantle and decommission the plant.
In SAFSTOR, the NRC will continue to inspect the plants at least annually and ore frequently when decommissioning activities are erformed.
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- chosen, Regardless of the decommissioning option the NRC regulations require that the decommissioning be completed in 60 years.
Next slide, please.
A few reminders.
We are here to listen to your comments on the Pilgrim decommissioning*.
This is part of the process we've set up and it's intended to hear your comments, so we can consider those in our review of both the PSD[A]R from Entergy and, also, the license application and the PSD[A]R that supplements it from Holtec.
The meeting, again, is being transcribed, and the transcript will be publicly available.
A eeting summary will be published and would be ublicly available.
And we will do our best to answer your questions, where we can.
There's going to be ossibly some that we can't answer, but we do our best to get back to you.
I'm going to introduce John.
is going to sit down and speak.
MR. LAMB:
Yes.
MR. WATSON:
Okay.
Thank you.
MR.
LAMB:
Hi.
Good evening.
John Lamb My name is John Lamb.
I am the Project Manager for Pilgrim (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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at NRC Headquarters in Rockville.
I've been working for the NRC for 19 years, and prior to that, I worked 15 years in the power plant.
Next slide, please.
In accordance with the NRC regulations, a Post-Shutdown Decommissioning Activities Report, or PSDAR, must be submitted to the NRC, and a copy to the Commonwealth of Massachusetts, prior to or within two years following the permanent cessation of operations of Pilgrim.
Entergy submitted the Pilgrim PSDAR on November 16th, 2018.
A PSDAR must contain a description of the lanned decommissioning activities, along with a schedule for their accomplishment and a site-specific decommissioning cost
- estimate, including the rejected cost of managing irradiated fuel.
The NRC staff uses a Regulatory Guide that provides guidance on the content and format of PSDARs.
The Regulatory Guide is available to the ublic as noted on this slide.
Decommissioning activities must not endanger the public health and safety or result in significant environmental impacts not previously reviewed.
(202) 234-4433 Next slide.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10 A PSDAR must contain a discussion that rovides the reasons for concluding that the environmental impacts associated with site-specific decommissioning activities will be bounded by appropriate previously-issued Environmental Impact Statements.
Therefore, during the environmental review of a PSDAR, the NRC uses various previous staff reports to determine whether the environmental impacts from decommissioning are bounded by these reports.
For instance, for Pilgrim, the NRC staff will use a generic Environmental Impact Statement regarding decommissioning and will also look at revious Environmental Impact Statements developed specifically for Pilgrim, such as the Environmental Impact Statement developed for the renewal of the Pilgrim operating license.
The NRC staff will also rely on findings from its inspection program.
Next slide, please.
The request for comment and meeting notice for the Pilgrim PSDAR was published in The Federal Register on December 21st, 2018.
The 90-day comment period ends on March 21st, 2019.
The NRC staff will notify the licensee if the staff needs additional information to support its review of the PSDAR.
The NRC staff will document its (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 PSDAR review in a letter to the licensee and will address the comments received during the comment eriod.
After the submission of the Pilgrim PSDAR, the NRC regulations require that Entergy shall notify the NRC in writing and send a copy to the Commonwealth of Massachusetts before performing any decommissioning activity inconsistent with or making a significant schedule change from those actions and schedules described in the PSDAR.
Next slide, please.
By letter dated November 16 [t] h, 2018, Entergy and Holtec submitted a license transfer application requesting that the license for Pilgrim e transferred from Entergy to Holtec.
Before this transfer may be completed, the NRC must determine that Holtec is qualified to be the holder of the Pilgrim license.
In order to make this determination, the C
staff reviews the following five areas:
financial qualifications; decommissioning funding assurance; foreign ownership,
- control, and domination; technical qualifications, and insurance and indemnity.
If the NRC finds that Holtec is qualified in these areas, then it would approve the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 license transfer by an order and issue a conforming license amendment.
Next slide, please.
License transfer applications are noticed in The Federal Register, and the public can request a hearing and/ or provide comments on the application.
The program [Pilgrim] license transfer application is ready for publication in The Federal Register.
However, The Federal Register is currently impacted by the partial federal government shutdown.
Therefore, the Pilgrim license transfer federal registration notification will not be published until after the partial federal government shutdown ends.
Once this Federal Register notice is published, there will be a 20-day hearing period, and then, a 30-day comment period.
License transfer applications typically contain proprietary information.
A
- redacted, Pilgrim license nonproprietary version of the transfer application is available to the public and can be found online through the NRC' s electronic library called ADAMS.
The proprietary version can be requested using a process that will be described in The Federal Register notice.
(202) 234-4433 Next slide, please.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 By letter dated November 16th,
- 2018, Holtec submitted a
proposed revised PSDAR for Pilgrim.
The Holtec PSDAR is a supplement to the license transfer application, and therefore, is part of the license transfer application action, and not art of the Entergy PSDAR action.
The Holtec PSDAR is contingent upon the approval of the licensed transfer application and the equity sale closure.
For purposes of this public meeting, the NRC will be accepting comments on both the Entergy PSDAR action and the license transfer application, which includes the proposed Holtec PSDAR.
Next slide, please.
Holtec also submitted a request for an exemption from the NRC's Decommissioning Trust Fund requirements in an enclosure to the license transfer application.
If this request were to be granted, then Holtec would be allowed to use the Pilgrim Decommissioning Trust Fund not only for radiological decommissioning expenses, but also for expenses related to spent fuel management activities and site restoration activities.
Like the Holtec PSDAR, this exemption request is contingent upon the approval of the license transfer application and the equity sale closure.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 14 Next slide, please.
Comments regarding the Entergy PSDAR can be submitted on regulations.gov website under Docket ID NRC-2018-0286 until March 21st, 2019.
Comments regarding the license transfer application can be submitted during tonight's public meeting.
Once the license transfer application is noticed in The Federal Register, then comments can be submitted on the regulations.gov website under Docket ID C-2018-0279 for a period of 30 days for comments, and a hearing can be requested for a period of 20 days.
Next slide, please.
This slide shows where to mail comments regarding Entergy PSDAR or the license transfer application.
Please remember to use the Docket ID associated with each application.
That concludes my presentation.
I'll turn it back over to Bruce.
MR. WATSON:
Okay.
Our next speaker is Mandy Halter from Entergy.
MS.
HALTER:
Good evening.
My name is Mandy
- Halter, and I'm the Director of Nuclear Licensing for Entergy Nuclear.
With me tonight is Mike Twomey, the Vice President of External Affairs (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 for Entergy Wholesale Commodities.
I appreciate the opportunity to be here tonight to provide you information on Entergy' s plans to decommission the Pilgrim Nuclear Power Station.
2019 is a significant year for Entergy, for Pilgrim, and for this area.
On May 31st of this
- year, Pilgrim will permanently cease power operations.
In June, we will certify to the NRC that the reactor is permanently shut down and defueled.
lso in June, Pilgrim will complete its first staffing reduction, as we transition the organizational structure to support Pilgrim's SAFSTOR decommissioning plan.
Throughout the final months of plant operation, and as we transition to decommissioning, we remain committed to safety, health, and security of the plant, its employees, and you, the public.
Next slide.
Next slide, please.
Thank you.
The Entergy Post-Shutdown Decommissioning Activities Report, or PSDAR, was submitted to the NRC on November 16th, 2018, and outlines our plan to use the SAFSTOR decommissioning strategy.
- experts, (202) 234-4433 Our PSDAR was prepared by a team of in accordance with regulations, NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 guidance, and a thorough review of PSDARs submitted to the NRC by plants in decommissioning.
The Pilgrim PSDAR contains a description of our planned decommissioning activities as well as a schedule for their completion, an estimate of the cost, and a discussion of the environmental impacts of these activities.
And I
will provide more information in the following slides.
Next slide, please.
The majority of the dormancy period of our SAFSTOR plan will involve all spent fuel in dry fuel storage.
This slide shows our plan to achieve the dry fuel storage [dormancy] storm and sea state y the end of 2022.
Along the way, Pilgrim will make adjustments to its staffing levels and the emergency
- lan, in accordance with appropriate regulatory approvals, based on the status of the fuel and the corresponding decreasing risk of offsite radiological consequences from an accident.
Next slide, please.
Under the SAFSTOR methodology, we will aintain and monitor Pilgrim in a dormancy period to allow for the radioactive decay of the plant, followed by the dismantlement and decontamination to ermit NRC license termination within 60 years, as (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 required by regulations.
Under Entergy's plan, radiological decontamination and dismantlement will occur safely by the year 2079.
We plan to restore the site following license termination.
Next slide, please.
In accordance with regulations, we developed a site-specific estimate of the costs for the planned SAFSTOR decommissioning activities at Pilgrim.
This cost estimate was developed by a leading expert using up-to-date and best available data.
In addition to estimating the costs associated with license termination, we also estimated the cost associated with spent fuel management and site restoration.
Our SAFSTOR decommissioning cost estimate for Pilgrim is included as an attachment to the Entergy PSDAR.
Next slide, please.
The site-specific decommissioning cost estimate submitted to the NRC in November 2018 was reported using 2018 dollars and up-to-date 2018 ricing information.
The total estimated cost associated with license termination as well as spent fuel management and site restoration for Pilgrim is
$1.66 billion.
We will periodically update the decommissioning cost estimate throughout the SAFSTOR (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 eriod, in accordance with regulations.
It is very important to note that we are required by regulation, as the owner of the plant, to demonstrate reasonable assurance that there are adequate funds available to cover the cost of license termination.
We provide this funding for Pilgrim through a Nuclear Decommissioning Trust Fund, which, as reported to the NRC and the PSDAR, was funded at
$1.05 billion at the end of October 2018.
Accounting for the growth of these funds over time, as permitted by NRC methodology, the Pilgrim nuclear decommissioning trust balance does not provide financial assurance for the decommissioning costs of our SAFSTOR plan.
Next slide, please.
We have concluded that the environmental impacts associated with planned SAFSTOR decommissioning activities at Pilgrim are less than, and are bounded by, impacts addressed in previously-issued Environmental Impact Statements.
A more detailed discussion of the reasons for our conclusion is included in the PSDAR.
Next slide, please.
In November 2018, we filed an updated Pilgrim Spent Fuel Management Plan with the NRC which (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 outlines our intent to store all spent fuel on a new, larger, independent spent fuel storage installation ad which will be located at a higher elevation on the program site.
This pad, which we plan to construct by the end of 2020, will store a total of 61 casks,
inc 1 uding the 1 7 casks that are on the current pad, as well as 44 additional casks which are needed to store the fuel that is currently in the reactor vessel and the spent fuel pool.
Next slide, please.
In November
- 2018, Entergy and Holtec submitted a request to the NRC to transfer the control of Pilgrim's plant and
[Independent Spent Fuel Storage Installation] ISFSI licenses from Entergy to Holtec.
If approved by the NRC, the license transfer will allow for prompt decommissioning under Holtec's
- lan, which is different than Entergy's plan.
Specifically, Holtec plans to decommission Pilgrim using a DECON or immediate dismantlement strategy by approximately 2024.
Additionally, Holtec intends to ove all spent fuel to dry fuel storage on the new ad by the end of 2021.
Following this presentation, drea Sterdis will provide more information on Holtec's decommissioning plans for Pilgrim.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 20 Hol tee's plan is that it will allow for earlier release of portions of the Pilgrim site for reuse.
We have requested that the NRC review and approve the license transfer application by May 31st of this year.
We know that this is an aggressive review schedule for the staff and we are certain that the C will conduct a very diligent review, and we expect nothing less.
The intent behind this requested timeline is to provide certainty to the plant employees and to the citizens of Plymouth and the surrounding areas on plant ownership as well as the decommissioning plan and timeline following plant shutdown.
Next slide, please.
More information about Pilgrim's plans for decommissioning as well as our related submittals that we have provided to the NRC are publicly available on our website, www.pilgrimpower.com.
I thank you for your time.
And a number of us are here from Entergy, and we look forward to answering your questions later in the evening.
Thank you.
MR.
WATSON:
Thank you for your resentation.
Our next presentation is by Andrea (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21 Sterdis from Holtec International and CDI, I believe it's called.
MS. STERDIS:
Thank you, Bruce.
Good evening.
I really appreciate the opportunity to provide you all with a brief overview of the Post-Shutdown Decommissioning Activities Report that has been prepared to show the Holtec plan for initiating plant decommissioning following NRC approval of the license transfer application, execution of the license transfers, and completion of the sale closure.
Next slide, please.
On this slide, you can see that I am up here providing the presentation.
I'm Andrea Sterdis.
I'm the Vice President for Regulatory Programs, Environment and Safety for
[De]Commissioning International.
Comprehensive I
am joined tonight by Joy Russell, Senior Vice President for Holtec International.
Next slide.
On November 16th, 2018, Holtec submitted a revised Post-Shutdown Decommissioning Activities Report, or PSDAR, based on their plan to initiate rompt DECON.
Our PSDAR for DECON includes a
description of the planned activities, specifically (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 22 the activities that are required to initiate that rompt DECON and complete it.
It also includes a lanned DECON decommissioning schedule and a cost estimate reflecting that schedule and the DECON plan.
Lastly, it includes a discussion of the environmental impacts for the specific activities that will be erformed during the execution of the dismantlement and the waste removal from the site to complete the radiological decommissioning.
The PSDAR was prepared in accordance with C regulations and addresses NRC guidance.
It was repared by a team that is experienced in planning, estimating, and executing nuclear power plant decommissioning.
It was also informed by a review of previously-submitted
- PSDARs, as well as articularly a review and an alignment with the assumptions that were provided and used in the Entergy SAFSTOR PSDAR. The DECON PSDAR is contingent upon NRC approval of the license transfer, execution of the transfers of the license, and completion of the sale.
Next slide, please.
The DECON PSDAR reflects Holtec's plan to romptly start decommissioning activities following the license transfer and sales closure.
The schedule (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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The decommissioning cost estimate reflects DECON activities and schedule for completing radiological decommissioning, managing the spent fuel, and completing site restoration activities.
The environmental evaluation considers the DECON activities and provides evidence that those activities are bounded by the existing Environmental Impact Statements that are applicable to the Pilgrim site, including the NRC generic Environmental Impact Statement for Decommissioning as well as the Pilgrim Site License Renewal Environmental Impact Statement.
If you look at the SAFSTOR PSDAR and compare the decommissioning cost estimate with that rovided in our PSDAR for DECON, you will see some differences.
Those differences are primarily driven by two reasons.
First, the core business for Entergy in the current time is to provide and generate ewer/electricity.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 24 decommissioning, resulting in a difference in the decommissioning cost.
In addition, the DECON plan eliminates the transition to the dormant state, maintaining that lant dormant state for almost 40 years, and the transition to reactivate the plant and complete the dismantlement and waste removal activities about 40 years down the road.
It's important to note that the SAFSTOR dismantlement and waste removal schedule and the DECON dismantlement and waste removal schedule are similar in duration.
The difference is the prompt DECON one modeled in our PSDAR is initiated immediately after license transfer in 2019 and completes in approximately five years.
On the next slide, please.
The schedule provided in the DECON PSDAR assumes that the NRC will approve the license transfer application in time to support a July 31st transfer of the licenses and sale closure.
This slide provides some key assumptions that drove the schedule that's included in that PSDAR, starting with the fact that we've assumed an initiation of decontamination and dismantlement activities in 2019 following the license transfer.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 the newest ISFSI pad construction is completed and the pad is available for use in 2020.
It assumes that the offloading of the spent fuel transitioning the site from a combined wet and dry spent fuel storage site to a dry fuel storage site only occurs y the fourth quarter of 2021.
Similar to the SAFSTOR PSDAR schedule submitted by Entergy, our DECON PSDAR schedule assumes that the [Department of Energy] DOE completes the spent fuel removal from the site in the 2062 time eriod.
The DECON PSDAR schedule shows radiological decommission, except for the independent spent fuel storage installation, ISFSI, is accomplished within approximately five years following the l'icense transfer and sale closure.
It also assumes that site restoration activities, which are not required for the partial site release approval by the NRC, are continuing beyond that approximately one year.
Next slide, please.
The Holtec DCE, or decommissioning cost estimate, that's included in the DECON PSDAR results in approximately $1.134 billion cost in 2018 dollars.
The Nuclear Decommissioning Trust Fund for Pilgrim is currently valued at $1.05 billion as of October 31st, 2018.
The cash flow analyses that were submitted as (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 art of the license transfer application as well as the DECON PSDAR and decommissioning cost estimate demonstrate that the Pilgrim Nuclear Decommissioning Trust Fund contains sufficient funds to cover our for radiological decommissioning, spent fuel anagement, and site restoration.
It's important to note that, pursuant to C
regulations, we will be
- required, as the licensee, to prepare and submit an annual report that rovides the Nuclear Decommissioning Trust [NDT] Fund status, including expenses and activities executed in the previous year, the remaining NDT balance, and showing financial assurance that the balance can address and cover the remaining costs of all the activities required to complete the license termination.
This is a public report and is made available each year by the NRC.
With that, I'd like to thank you for your time, and I'd like to thank the NRC for this meeting.
Thank you.
MR. WATSON:
Thank you, Andrea.
Before I turn the meeting over to Brett and Donna to facilitate the comment session, I would like to invite any elected officials or their representatives or any Native American (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 representations to make statements if you're available now.
So, if you would, those that are interested, please come up to the microphone and state your name for the record.
MR.
KLUKAN:
So, we actually have a couple who have preregistered with us, and we are going to go down through that list.
And then, we'll open it up to those who did not preregister.
So, first up, we' re going to have Ms.
Jessica Wong from the Off ice of Senator Elizabeth Warren.
MS. WONG:
Good Evening.
Thank you.
As Brad said, my name is Jessica.
I am from Senator Elizabeth Warren's office, and I'm her Regional Director.
So, Senator Warren reiterates her deep concerns with the consistently poor public safety record at Pilgrim Nuclear Power Station and the uclear Regulatory Commission's pattern of ignoring critical discrepancies in Entergy's safety measures that put Massachusetts residents at risk.
This cannot continue, especially as the NRC reviews the license transfer for the decommissioning from Entergy to Holtec International.
To date, she has sent six letters to the NRC expressing these concerns, most (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 28 recently in
- October, following the reports of unplanned shutdowns due to problems with equipment.
Entergy cannot continue to use the summer's planned shutdown as an excuse to avoid much-needed safety upgrades that protect our communities.
Senator Warren urges the company to prioritize the eople of rofits.
southeastern Massachusetts over its Similarly, the NRC can no longer shirk its responsibilities to establish and enforce proper safety standards.
The Senator, once again, calls on the NRC to require Entergy to immediately comply with federal safety standards, and if they refuse to do so, then the NRC must take necessary steps to shut down the plant.
Thank you.
MR. KLUKAN:
Thank you very much.
Next, we will have Ms. Rory Clark from the Office of Senator Ed Markey.
MS. CLARK:
Thank you for having me.
As you said, I'm Rory Clark.
I'm Senator Markey' s Regional Director.
I'll be reading a statement on Senator Markey's behalf.
"I've long been concerned about Pilgrim's safety and operating record and its management's (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 29 history of cutting corners at the expense of increased risk to Massachusetts residents.
As we turn our attention now to the details of the Post-Shutdown Decommissioning Activities Reports submitted by Entergy and Holtec International, I must remind the Nuclear Regulatory Commission, Entergy, and Holtec that the people of Massachusetts will settle for nothing less than the most stringent safety measures.
"As the federal regulatory body overseeing the decommissioning process, we all expect the NRC will review both Entergy and Holtec's reposed decommissioning plans with the utmost of care and caution.
The safety of Massachusetts residents demands this thorough review.
"Plans for the ownership and decommissioning of Pilgrim must prioritize safety aHS
[and] security.
The NRC must evaluate both Entergy and Holtec's PSDARs to ensure that each provides a comprehensive accounting of how that owner will assume responsibility for safe operations, improve upon the abysmal safety record at Pilgrim, and finance the complete decommissioning process.
"I understand that it's common practice for the NRC to issue exemptions that would limit the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 30 required emergency planning zone when the plant begins the decommissioning process, but I must urge the NRC to require Pilgrim's owner, be it Entergy or Holtec, to work with local communities to maintain and fund the significant emergency planning zone and ensure that local communities are prepared for any eventuality.
"Last year I was proud to cosponsor the Safe and Secure Decommissioning Act which would rohibit the NRC from issuing waivers or granting exemptions from complying with safety and emergency reparedness regulations put forth in the Atomic Energy Act of 1954 until nuclear fuel had been transferred to spent nuclear fuel dry casks.
I will continue to push for all parties involved in the decommissioning of Pilgrim to abide by such standards.
"As we are all aware, this region is home to fierce nor'easter storms and rising tides, posing safety concerns that other nuclear facilities around the country do not have to contend with.
Especially given this region's harsh environmental conditions, the NRC should ensure the completion of a full ational Environmental Policy Act analysis that would exam the effect of the proposed decommissioning plans (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 on the environment and allow for additional public involvement.
"Furthermore, any Pilgrim licensee should provide thorough plans for communicating regularly with the public and local stakeholders throughout the decommissioning process.
This communication is essential to ensure that all members of the community understand how Pilgrim will be safely decommissioned and foster confidence that security measures satisfy federal safety standards and community expectations.
"I was proud to be an original cosponsor of additional legislation in 2018 entitled 'The uclear Plant Decommissioning Act,'
which would the states and local communities have a
eaningful role in the crafting and preparation of decommissioning plans for retired nuclear plants located in our community.
This bill also requires the NRC to publicly and transparently approve or reject every proposed decommissioning plan, which it currently is not required to do.
"I will be introducing the Dry Cask Storage Act this session, which would ensure every nuclear reactor operator must be compelled to comply with an NRC-approved plan that would require the safe (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 removal of spent nuclear fuel from spent nuclear fuel ools and placed that fuel into dry cask storage within seven years of the time that the plan is submitted to the NRC.
This bill would further rovide funding to help reactor licensees implement these plans and would expand the emergency planning zone for all noncompliant reactor operators to 50 iles.
"As we consider tonight the shutdown rocess for Pilgrim, Entergy and Holtec must provide conclusive proof that there are sufficient funds available in the Nuclear Decommissioning Trust to decommission Pilgrim in a safe and secure manner.
It will be unacceptable for Entergy or Holtec to demand additional money from Massachusetts ratepayers to complete the decommissioning process at Pilgrim.
There can be no second chances here.
"Historical data and NRC guidelines indicate that the decommissioning costs are likely to increase faster~ [than] inflation.
Entergy and Holtec must each account for that fact or find a way to clearly rebut it.
Given the amount currently available in the Trust Fund, the NRC must carefully assess if the proposed decommissioning timeline is achievable in a safe and secure manner and require (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 there is reasonable public assurance of available funds for the totality of the process.
Additionally, as the proposed license transfer will further strain the NRC's resources, it is imperative that the NRC assign additional staff to work on these issues and charge the licensees for their salaries.
"In the recent
- past, I
have also expressed my concerns to the NRC regarding the draft decommissioning rule currently awaiting review, which is intended to provide clear guidelines for all lants that are undergoing the decommissioning rocess.
This proposal falls far short of the NRC's stated goals of providing for a safe, effective, and efficient decommissioning process for nuclear plants.
In its current
- form, this fails to propose a
comprehensive set of decommissioning and cleanup regulations, would result in the automatic approval of facilities' exemptions from safety, security, and emergency planning regulations, and would continue to rubbers tamp the industry's Post-Shutdown Decommissioning Activities Report.
I continue to urge the NRC to reject this draft and, instead, write a
rule that will affirmatively guide plants and communities through the decommissioning process.
(202) 234-4433 "Thank you."
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34 MR. KLUKAN:
Thank you very much.
Next, we will have Mr. Michael Jackman of the Office of Congressman Bill Keating.
MR. JACKMAN:
Thank you.
I do have a
statement from the Congressman I'd like to read, but before I do that, I have just some housekeeping questions.
The slide resentations that were made
- tonight, are those available online or will they be available online?
MR.
KLUKAN:
For the record, yes, they will be available online on the NRC's website.
MR.
JACKMAN:
Okay.
Only because I
think if people want to make comments both on the PSDAR and the license transfer, there's a lot of good information in there.
Thank you.
"Thank you for the opportunity to address you at tonight's public meeting.
Unfortunately, the House voting schedule prevents me from being here in erson, but I wanted to restate my opinion that, as we draw closer to the cessation of operations at Pilgrim, the rigorous scrutiny of the operations at the plant must continue.
Entergy must not be allowed to languish in column 4, representing the minimum level of operational safety for the remainder of its life as a power generating plant.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 "In addition, the NRC must scrutinize Entergy's and Holtec's Post-Shutdown Decommissioning ctivities Reports to ensure that the health and safety of Massachusetts residents is not at risk.
The NRC must enforce its regulations and require the licensee to adhere to the most stringent standards for facility security, cybersecurity for all the lant systems, structural integrity of the onsite dry cask storage system, and mitigation of environmental hazards.
"In addition, decommissioning activities ust be fully funded by the licensee, and the NRC ust do all it can to ensure that taxpayers, be they residents of
- Plymouth, the Commonwealth of Massachusetts, or the United States of America, are not left to shoulder the burden of the cost of the cleanup of the Pilgrim site.
"Given the real prospect of ongoing nuclear waste storage here in Plymouth, it is incumbent upon all levels of government to work together to ensure the safety of our residents.
It is imperative that those residents and residents of all affected communities in Plymouth County, the Cape, and the islands are included in the discussion and decisions involved with the decommissioning (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 36 rocess.
"The Plymouth Town Select Board, the State legislative delegation, the Nuclear Decommissioning Citizens Advisory Panel, private groups like Pilgrim Watch and Cape Downwinders, and any other concerned individuals and groups, all have been engaged in this vital discussion over the years, and they all deserve to have their input heard and incorporated into the decisionmaking process.
I am roud to have cosponsored legislation, which I've already referred to, the Nuclear Plant Decommissioning Act, that will do just that.
"I applaud all those preset tonight for sharing their perspectives, and I will continue to fight to make sure that your voices are heard.
Thank you."
MR. KLUKAN:
Thank you very much.
- Next, we will have Mr. Seth Schofield from the Massachusetts Attorney General's Office.
MR. SCHOFIELD:
Thank you, Brett.
Good evening.
I'm Seth Schofield, Senior Appellate Counsel and Assistant Attorney General in the Energy and Environment Bureau of the Office of Attorney General Maura Healey.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 37 Regulatory Commission for coming to Plymouth tonight, so that the public has an opportunity to voice their thoughts and concerns about the power plant and the reposed plans to decommission the plant following its shutdown this spring.
From the Attorney General's perspective, the proposed sale of Pilgrim and the related transfer of Pilgrim's operating license from Entergy to a Holtec subsidiary raise significant health, safety, environmental, and financial concerns for the Commonwealth and its citizens.
We appreciate the otential benefits of accelerated decommissioning that forms the basis for the sale and license transfer application, but we currently have serious concerns about whether Pilgrim's Decommissioning Trust Fund contains sufficient funds to cover the performance of all necessary decommissioning, site restoration, and spent fuel management activities on an indefinite basis.
As currently proposed, neither Holtec,
- Pilgrim, LLC, the proposed licensee, nor Holtec Decommissioning International,
- LLC, the proposed licensed operator, will generate any revenue or bring with them any new assets that could be used to fund and complete site decommissioning, restoration, and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 38 spent fuel management activities at the site.
Instead, Holtec-Pilgrim and Holtec Decommissioning International's only planned source of funds are the funds currently existing in the Pilgrim Trust Fund, and as currently proposed, there exists no guaranteed add to the parent company of those two single-purpose limited liability companies to compensate for any funding shortfall in the Trust Funds.
If there are insufficient funds in the Trust Fund, Holtec would likely default on its obligation and likely leave the Commonwealth and its taxpayers with those obligations, both as the payer of last resort and the arty responsible for protecting public safety and the environment for an indefinite period.
Based on our preliminary review of the license transfer application and the revised Post-Shutdown Decommissioning Activities Report, we have reason to believe that a Trust Fund shortfall could very well occur.
For example, Holtec's estimate of what it will cost to decommission,
- restore, and anage spent fuel at the site is only $3.615 million less than the total amount of money expected to be in the trust.
That means there would be insufficient funds to cover any cost overrun in excess of $3.6 illion.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 Past experience,
- however, including decommissioning experience at other sites in New England, demonstrates that the potential discovery of reviously unidentified radiological and non-radiological contamination, potential unanticipated work delays, and other potential problematic events could well reliminary estimates.
drive costs post-shutdown significantly beyond decommissioning cost For
- example, the discovery of strontium-90 during decommissioning at Connecticut Yankee doubled the anticipated decommissioning cost there.
The discovery of highly contaminated groundwater during decommissioning at Maine Yankee also increased costs beyond those anticipated to decommission that site.
And the discovery of
[polychlorinated bi phenyl]
PCB contamination/radiological groundwater contamination during decommissioning at Yankee Rowe, similarly, caused significant and unanticipated cost increases.
Holtec and its partner, SNC-Lavalin, have oor track records on other projects at other sites around the
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40 imperil public safety and our environment, while at the same time enhancing the risk of a Trust Fund shortfall that would make matters even worse.
For example, the NRC just recently issued a Notice of iolation related to Holtec's mishandling of dry cask loading and transfer operations at San Onofre Nuclear Generation Station in California, and its failure to timely report that matter to the NRC.
Because of the significant risk to the Commonwealth embodied by the pending license transfer roposal, we implore the NRC to join us in closing
[closely]
scrutinizing the proposal's terms and ensure that substantial financial assurances exist to ensure that those risks are fully addressed.
To that end, the Attorney General intends, on behalf of the Commonwealth of Massachusetts, to intervene in the ending license transfer proceeding to articulate these and other concerns for evaluation by the Commission and the imposition of protective safeguards and other conditions with respect to any license transfer.
Thank you.
MR. KLUKAN:
Thank you very*much.
Next up, we have several authorized representatives from the Board of Selectmen of the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 Town of Duxbury.
MS. M. LAMPERT:
Good evening.
I'm Mary Lampert, speaking tonight on behalf of the Duxbury Board of Selectmen.
The town is very concerned the site will not be properly cleaned up due to reliance on a
[Generic Environmental Impact Statement] GEIS written in 2002 and an [Supplemental Environmental Impact Statement] SEIS written in 2006 that are outdated, incomplete, and ignore new and significant information, and the failure of NRC to require a
[National Environmental Policy Act] NEPA analysis, as required by federal law and legal precedent, into insufficient funds in the
[Decommissioning Trust Fund] DTF.
With respect to the GEIS and
- SEIS, Duxbury sees no rational basis for NRC to assume that the environmental impacts are bounded by these documents, nor that environmental impacts will be small or that the site is essentially clean.
not.
A few examples:
It is The SEIS incorrectly denies that the ational Academy's Biological Effects of Radiation Report, 2006, denies to provide new and significant information from the 1990 report.
The 2 0 0 6 report (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 found mortality rates for women exposed to radiation was 37.5 percent higher than its 1990 report and the impact of allowable radiation standards on workers was twice that estimated in 1990.
Therefore, allowable doses need to be reduced from the 25 illirem a year to less than 10 millirem a year, as the State has requested, and reduction in allowable doses to workers.
You are obligated to follow the latest scientific information, not go back to 1990.
updated.
shovel.
- Second, contamination onsite must be In the GEIS and SEIS, NRC didn't lift a You just relied on the licensees' reports.
Their conclusions cannot be relied upon.
Pilgrim opened with bad fuel and no off-gas treatment system, and blew its filters in 1982.
Where did the contamination go?
Hazardous waste is buried onsite, including on the roperty off the access road.
Construction has occurred at the site and the soil buried.
What's in that soil?
There's a crack in the reactor's torus floor.
Soil outside the reactor, beneath it, must be analyzed.
The source of tritium levels of onitoring wells is unknown.
Other slower-moving radionuclides also are likely to be there, not yet icked up by the monitoring wells.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 43 leaked from seismic gaps and the condensate system?
gain, who knows?
It's not in the 2002 report.
It's not in the SEIS written in 2006.
NRC' s 2014 continued storage rule that the waste may be stored onsite indefinitely has to be considered.
The PSDAR's assumptions that spent fuel will be offsite by 2062 cannot be accepted by NRC.
Entergy relied on DOE for its projections, but DOE qualified its projections.
Entergy and Hol tee did not.
PSDAR cost estimates and plans to ensure the long-term integrity of the casks must be revised to provide a contingency fund for long-term storage.
C's Mark Lombard stated that there is no technology to find cracks in Hol tee casks.
They' re made of steel and subject to corrosion.
Dr. Kris Singh, the President of Holtec, said that it's not feasible to repair Holtec's sealed canisters.
These facts cannot be ignored.
Casks ust be better protected, monitored for heat, helium, and temperature, and funds for mitigation included in cost estimates because the fuel, as NRC has said, could remain here indefinitely in an environment subject to corrosion, moisture, and salt.
The GEIS and SEIS found socioeconomic (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44 impacts small.
Again, not so.
A University of assachusetts Amherst study commissioned by the Town of Plymouth found that the economic impact on Plymouth alone would be almost $500 million and that there would be more than $100 million impact on the rest of the region, including Duxbury.
==
Conclusion:==
therefore, it's clear that the GEIS and SEIS are totally inadequate and do not bound the environmental impact.
The NRC must require oth a comprehensive environmental analysis that includes shovels and testing, made public, quite obviously, at the beginning of the decommissioning rocess and a NEPA analysis.
This is a major federal reaction.
You cannot pretend it is mere oversight to wiggle your way out of the requirement.
You gave the license and you will terminate the licenses.
That is a major federal action.
And thank you very much.
MR. KLUKAN:
Thank you.
MR. J. LAMPERT:
I'm Jim Lampert, and I am also here representing the Duxbury Board of Selectmen.
And I'd like to speak briefly on just one aspect.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 45 serious concerns about the financial aspects of decommissioning.
You heard Senator Markey's representative, Senator Warren's representative, Representative Keating's representative, and the ttorney General's Office refer to these.
Holtec's
- PSDAR, like Entergy's, says there is enough money in the Decommissioning Trust Fund to accomplish the job.
Putting aside all of the things the PSDAR doesn't talk about, and Mrs. Lampert just listed, that assumption by Entergy and Holtec rests on a further assumption that future costs in decommissioning will not be more than future increases in general inflation.
That assumption is highly questionable.
According to Callan Associates that annually puts together a report on decommissioning costs for the nuclear industry, decommissioning costs increased at an annual rate of about 5. 8 percent between 2008 and 2016.
This increase in cost is about 4.5 percent above inflation.
For a benchmark, the NRC and the PSDARs assume that the Trust Fund will grow at a rate of only 2 percent of the general inflation.
The NRC' s own questions and answers on decommissioning financial assurance say that, over a (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 46 20-year period, there will be an annual increase in decommissioning costs of between 5 and 9 percent.
gain, well over both inflation and 2 percent above inflation.
If the NRC's statements are correct, and if Callan's reports of actual past history are correct, it seems highly unlikely that there's going to be enough money in the fund to accomplish the job.
Which leads me to a fundamental question of the Board of Selectmen:
if there is not enough oney, what law or regulation requires a licensee, articularly a limited liability corporation like Holtec-Pilgrim, or any of its parent or associated entities, to pay the shortfall?
Can you tell me if there is such a regulation?
And if so, tell me what it is.
And if you cannot do now, can I ask that you tell us all tomorrow night at the decommissioning anel meeting to give you the time to get the answer?
MR. KLUKAN:
Thank you.
MS. CHIN:
Rebecca Chin for the Town of Duxbury.
The Selectmen asked me to speak on public safety this evening.
And we urge you to retain the current offsite emergency planning funded by the licensee until the spent fuel pool is emptied and continue licensee-funded offsite emergency planning on a
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 47 reduced level until all the fuel leaves the site.
Entergy has currently filed for a license exemption to end offsite and reduce onsite funding, and this should be denied by the NRC.
You cannot expect mutual aid with no funding.
The second is on monitoring.
Mass Department of Public Health should continue to expand offsite radiological monitoring and onsite tritium onitoring.
The licensee should continue to provide Mass Department of Public Health with its funding.
It needs to be required of the licensee.
Thank you.
MR. KLUKAN:
Thank you.
MS.
LYNCH-BENTTININ:
Sheila Lynch-Benttinin in Duxbury, speaking on behalf of the Board of Selectmen.
I would like to address one issue.
Forty years ago when community safety was being addressed, telephone poles and speakers were the technology of the time.
Currently, in our Town of Duxbury, which is within the 5-mile zone of Pilgrim, we have an Old Colony network, digital network, of public safety addresses.
I would like Holtec, if they are going to start next July, to engage the regional fire departments and the Old Colony system of current (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48 digital notification to be engaged in community safety and planning during the three very important
- years, especially after what just happened in California with the accident.
If there's an accident during the Holtec time, if they're given the license, and you're not up-to-date with the current fire department technologies in the region, it will be a very tragic day.
So, I encourage Holtec, if they're given the license in July, to reach out to the regional fire departments and the emergency notification system, which has been greatly upgraded since 40 years ago.
Thank you.
MR. KLUKAN:
Thank you very much.
Are there any other elected officials or representatives of elected officials or representatives of federally-recognized tribes who would like to introduce themselves this evening before we move on to the public comment portion?
(No response. )
All right.
Hearing none, I would like to' introduce Donna Janda, and we will proceed with the public comment portion.
(202) 234-4433 MS. JANDA:
Thanks, Brett.
Good evening, everyone.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
WASHINGTON, D.C. 20005-3701 As Brett said, (202) 234-4433
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 49 y name is Donna Janda, and I 1 11 be facilitating tonight's meeting along with Brett.
For those of you who registered to speak, you should have received a ticket, the other half of which Brett has in a container over here.
And the speaking order is going to be determined by the numbers that are pulled from the container.
And the intent of this is so that the speaker order is just random.
So, I do want to emphasize there is no rohibition against donating your ticket to others.
You are free to do so.
However, both individuals should be present at the time that number is called, and the donation must be announced at that time.
In addition, if an individual has already spoken during the meeting as a result of someone donating their ticket, and then, that individual's ticket is called, that individual may not use that ticket, but they can donate it to someone else.
This is just to give opportunity to everyone to be able to speak.
So, when your number is called, please queue up to the microphone that's in the aisle, in the center aisle right there.
And if you need to have a microphone brought to you, just let us know, (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.* N.W.
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Just so you have some advanced warning of when it's your turn to speak, Brett's posting the numbers right now as I'm speaking, and we're going to just go down them in sequential order there.
In an effort to give everybody the opportunity to speak tonight, please limit yourselves to three minutes when we speaking.
We do have a clock here on this table in the center here, in front of the podium, and we' 11 count down those three inutes.
And after the three-minute mark, I'll olitely ask you to conclude your remarks.
For your awareness, the meeting tonight is being recorded, and there is a transcript that will generated after the meeting.
Both the audio and the transcript will be posted to the NRC website.
So, in light of that, I would ask, when it's your turn to speak, that you please identify yourself.
d I
would also ask, for the sake of the audio recording, that people not speak over each other.
I would also ask that we keep this area clear in front of the stage.
If there is something you would like to give to the NRC staff, you can give that to Brett and he'll take care of that.
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While recognizing many of you have strongly-held opinions concerning the matters that were discussed tonight, I ask that you, nonetheless, adhere to civil decorum, that you respect each other.
So, please do not disrupt each other.
Just as you wouldn't want to be interrupted during your three inutes at the microphone, please respect the speaking time of others.
Any threatening gestures or statements will under no circumstances be tolerated and will be cause for immediate ejection from the meeting.
If you feel you've been threatened, please let me know or please tell one of the NRC security personnel or olice officers in the room, and we will try and address that.
The one thing that I do want to also note -- and I haven't heard any tonight -- but please ake sure you silence your cell phones, so that doesn't disrupt the meeting.
And I think we are ready to go at that.
So, the first number on the list is No. 2.
PARTICIPANT:
I've already spoken.
MS.
JANDA:
Okay.
Would you like to donate that ticket to somebody else to speak?
(202) 234-4433 MR. KLUKAN:
Would anyone who didn't sign NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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(No response. )
52 All right.
So, let's break this down.
This system is designed I
actually just experienced this at a Westinghouse meeting in South Carolina where we didn't have that many numbers.
So, this is everyone.
This is everyone who signed up to speak.
So, we have 14 people who signed up to speak.
There will likely be some opportunity at the end, after these individuals have spoken, if you haven't signed up to speak, or if you decide after hearing comments to speak then.
So, the plan is just to move through these numbers, and then, again, open it up after that.
I'm still going to keep people to the three minutes.
d then, if people have additional things to say after that, once we've gotten through the list, and whether there's any additional people who would like to speak, then we can add on a second round, as time ermits.
Okay?
So, did anyone want to use the No.
2 ticket?
ticket.
(202) 234-4433 (No response. )
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All right.
are making this evening.
Look at the time we (Laughter.)
The No. 1 ticket.
Do you want to go?
MS. LAMPERT:
Yes.
MR. KLUKAN:
All right, go.
All right.
MS.
LAMPERT:
Mary Lampert for Pilgrim Watch.
I just want to amplify the concern of our town and other speakers of maintaining licensee responsibility for offsite emergency planning in full force, as it is now, whatever it is, until the pool is emptied, and then, ratcheted-down until fuel leaves the site.
What is not properly considered by NRC or the licensees is our acts of malice.
We know there is a heightened threat environment, and we know that the spent fuel pool is a vulnerable target, as demonstrated by an expert for our Attorney General, Dr. Gordon Thompson, during relicensing.
We know, also, that even in a cask they are vulnerable to acts of malice by a shoulder-launch issile, for example, and then, in the hole, putting in an explosive.
This is described in excruciating detail, again by Dr. Thompson, both in hearings in (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 54 the United States, recent ones, and in Canada.
So, you have to consider it.
The fact that the probability may be low, you can take an arithmetic view to it because of the consequences being so great as they are.
And consider also, we are very glad the ISFSI pad has been moved to higher ground.
- However, unfortunately, it wasn't moved to the Manomet side.
It was moved more towards, I'd say, the Duxbury side.
d it is very, very close to Rocky Hill Road.
So, we have gained a great deal by not having it subject to climate change effects, but we have lost on security.
Therefore, we need a
reinforced barrier or some measure, a building or something, to provide the security we need, because the threat is not going away and each cask contains over half the cesium-137 released in Chernobyl.
- 3.
Thank you.
MR. KLUKAN:
Thank you very much.
MS.
JANDA:
And the next number is No.
PARTICIPANT:
Pass.
PARTICIPANT:
I'll take it.
MR. KLUKAN:
It's important to hold the hysical copy of the ticket.
I'm just kidding.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 55 Could you state your name for the record?
MR. WOLFE:
My name is Dan Wolfe.
I'm from Harwich on Cape Cod, and I also serve on the uclear Decommissioning Citizens Advisory Panel.
see you all tomorrow night, and I appreciate our being here.
In case there are people that can't be there tomorrow night that are here tonight, we have heard expressed by numerous folks from our legislative delegation, the Attorney General ' s Office, a real concern that there isn't sufficient funds.
And we could go back and forth on that.
It's conjecture.
It's based on certain assumptions relative to economic returns on what's in the Trust Fund.
So, I
guess I have a really specific question.
And that is, what happens if there isn't?
What happens if there is not specific funds?
Where does the burden go?
MR. KLUKAN:
Thank you.
MR.
WATSON:
The short answer is the licensee remains responsible for completing the decommissioning and providing the funds that are necessary to do that.
So, that would be a
responsibility that, if we were to grant the license (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 56 transfer to Holtec, they would be responsible for and for complying with the requirements.
MR.
WOLFE:
Could I
ask a followup question to that, please?
MR.
KLUKAN:
Sure.
You have like two inutes left.
MR. WOLFE:
Okay.
Thanks.
So, I guess question would be, is there any precedent or is there an ability to hold the original licensee liable in addition to Holtec?
There are layers of sort of corporate creation here that I think limit and insulate from liability.
So, I question would be, is there a mechanism, is there a
precedent, is there a
way to keep Entergy otentially liable or the investors in Entergy otentially liable if the funds are insufficient?
Because our concern is it goes to that entity, and, of course, the well is dry.
And by the way, that is by design.
That is by corporate design as far as how this is being constructed.
Thank you very much.
MR. KLUKAN:
Thank you again.
MR.
WATSON:
To the best of knowledge, we don't have any precedent.
We have had some sites go bankrupt, and we've worked with the trustee of the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 Trust Fund to complete the decommissioning.
So, there's no -- once we complete our review, and if we were to transfer the license, there would be no going ack to Entergy for the funds.
So, it's either they're going to be qualified to do that and accept that responsibility or not.
MS. JANDA:
The next speaker will be No.
- 4.
MS.
TURCO:
Diane Turco with Cape Downwinders.
Being a good neighbor means taking care of each other and making decisions for the common good.
Entergy has advertised itself as a corporation that is a good neighbor -- as long as there is money to be made.
Now the plug will be pulled in June and the coffers will dry up.
Entergy is running for the exit door and leaving their legacy mess behind.
Entergy's PDS[A]R calls for
- SAFSTOR, aking Pilgrim a radioactive holding tank for 60 ears.
Holtec for DECON, prompt decommissioning sing the Decommissioning Trust Fund with exemptions.
What is best for the community should be the priority of both their plans, but it is not.
We all agree that prompt decommissioning is the best, but it must be done responsibly and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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The following are our standards to meet the good neighbor requirements:
With the ISFSI holding tons of radioactive waste, there's still a potential for offsite release.
The PSD[A]R must include emergency lans based on low-probability, high-consequence incidents, such as terrorists
- attacks, and be included in the Environmental Impact Statement.
Location of the ISFSI pad must consider a
technically-defensible onsite storage location.
That's not what we have now.
Dry cask must be improved with quality and be able to be inspected, monitored, repaired, and are retrievable.
Procedures must be in place for transfer of waste from any cracked or damaged canisters or casks which may mean keeping the pool.
Procedures and training for fuel transfer with certification of completion by the NRC prior to oving any fuel from the pool.
Residual radiation levels must match
[Environmental Protection Agency] EPA standards and inclusion of independent oversight.
Office]
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As
[Limited Liability Corporations]
- LLCs, this looks like a house of cards with no guarantee that available funds will be available to complete the job.
The citizens of Massachusetts must have clear assurance that the taxpayers will not be left aying off the mess Entergy has left behind.
Looking at Holtec 's record from recent events at San Onofre near San Diego, confidence in their ability to make decisions based on protection of the public is questionable.
An NRC special inspection report of a near drop of a full canister cited poor
- training, equipment
- problems, not following procedures, and mismanagement.
Sound familiar?
Poor management, poor training, poor rocedures, et cetera, has kept Entergy's operation at Pilgrim as the least safe in the U.S. still.
This is like going from the frying pan into the fire.
We don't need another corporation here with a poor safety culture that puts profit over public safety.
We are concerned neighbors and will support a responsible and safe decommissioning plan that protects our communities.
If Holtec is setting the standard at
- SONGS, Cape Downwinders cannot support the transfer of license from Entergy at this (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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You need to go back to the drawing board and do better for our communities.
MR. KLUKAN:
Thank you very much.
MS. JANDA:
The next speaker will be No.
- 9.
MR.
ROTHSTEIN:
Good evening.
Richard Rothstein, Town of Plymouth resident and a new member of the State Nuclear Decommissioning Citizens dvisory Panel.
I asked the question during last week's webinar regarding Entergy's PSDAR for SAFSTOR about the anticipated timeline for when the NRC would allow the onsite meteorological towers to get dismantled during the decommissioning process under SAFSTOR.
The NRC couldn't answer that question, only because it's a little bit too early in the process.
So, I just wanted to rephrase my question.
Why is it important to have the onsite eteorological towers?
They're important because of emergency planning purposes.
In the event of a radiological emergency with the plant still operating or once the plant is permanently shut down, but spent fuel in the pool, before it gets transferred, and even with the dry casks onsi te, if there were a (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 radiological emergency, a
- release, emergency responders would need to have that information to be able to make determinations of shelter in place versus emergency evacuation determinations there.
This need doesn't disappear simply just because the lant is permanently shutting down.
So, to rephrase my question from last
- week, I'd be interested in learning about other lants that have decommissioned or are in the process of decommissioning, most using SAFSTOR, but some are robably going to use DECON, and when the NRC allowed a licensee to dismantle the onsite meteorological towers.
I don't expect you would have an answer tonight, but certainly in the next few weeks I'd be ery interested in learning more about that history, so we can see what circumstances did NRC require those towers to stay up longer or other circumstances where they allowed a licensee to dismantle them sooner than later.
Thank you.
MS. JANDA:
All right.
Thank you.
The next speaker will be No. 10.
MR.
WALLEN:
Hello.
My name is Stan Wallen, a resident of the Town of Plymouth.
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I have one simple question for Hol tee.
Based on the numbers you put up on the board, where are you going to make $89 million in five years?
You need 1.54 billion to decommission in your timeline.
You have 105 now.
If you're in the business to make oney, where are you going to get an additional almost 90 million?
MR. KLUKAN:
One moment.
MS. STERDIS:
This is Andrea Sterdis.
And the cash flow analysis that are included in both the license transfer application as well as the PSDAR for DECON demonstrate that the costs will be distributed over time, and it does accurately reflect the regulations regarding the Trust Fund increases over time.
MR. WALLEN:
I see.
So, I'll just quote a former presidential candidate, that we're working with, "voodoo economics".
- Secondly, this whole situation here almost looks like it's down pat that Holtec will get a license transfer.
What is the consequence of the C not approving a license transfer?
We' re going to have Entergy try to decommission and take 60 years.
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Are we stuck with that if the license transfer is not approved?
An NRC question.
MR.
WATSON:
Okay.
Yes, first of all, we are in the process of reviewing the Holtec application and the associated financial and technical information that has been provided.
So, there's been no conclusion on that.
Should we deny the application and not allow the transfer to take place, yes, Entergy would remain the licensee and be responsible for aintaining the plant in a safe condition.
So, we would continue to inspect as we will if the license were transferred the facility to ensure it's aintained safely, and regardless of the DECON option or SAFSTOR option they choose.
But the bottom line here is the licensee would be, continue to be Entergy, and their requirement is that they have to complete the decommissioning in 60 years.
MR. WALLEN:
Thank you.
MR. KLUKAN:
Thank you very much.
Would it be beneficial to people if we ut back up the slide with one of the numbers instead of just looking at "Thank you," which I'm sure is very useful to all of you?
Maybe either the Pilgrim (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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Okay.
Thanks for doing that.
MS. JANDA:
Okay.
The next speaker will be No. 14.
MS. CONSETINO:
Good evening, everybody.
I'm Henrietta Consetino, resident of Plymouth and, also, Chair of the League of Women Voters Nuclear Committee.
And I thank you for coming tonight.
appreciate it. It's very important.
We I also want to say I appreciate greatly the speakers who came from the offices of our elected officials.
It was very helpful to have their comments.
last.
I have a question, but I'll save it for My first is just a comment in total laymen terms.
We have two possibilities right now.
On the one hand, we have Holtec proposing to decommission in a very short amount of time, and for cheap, and henomenally.
It just sounds too good to be true, articularly if you start to pay attention to the nature of the dry casks that are being proposed and the fact that these very same dry casks have been tremendously troublesome at San Onofre and probably in other places, too, all of them scratched, being (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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At least in San Onofre, the plan was it's now suspended for a time, but the plan was to put these faulty casks in a vaulted system.
Here in
- Plymouth, there is no proposal for any kind of aulting, any kind of hard cover for these very vulnerable casks that could be subject to terrorism.
We appreciate the moving of the ISFSI, and that was important to us, but there is much more that needs to be done if Holtec is to have the license.
It's also very disturbing that Holtec is requesting waivers for a
certain amount of regulations, just as Entergy has been granted waivers for the computer security that was required for all of their plants in the wake of Fukushima, waiver from the kind of hard valves that would make it safer.
So, this is disturbing.
On the other hand, if we go with so-
- called, grotesquely-called
- SAFSTOR, 60 years of decommissioning, this is surreal.
We will all be gone 60 years from now, every single one of us in this room, unless there is a very young person.
And any of our children will be gone, too.
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Have I reached my limit?
Okay.
there then.
I stop MR. KLUKAN:
Thank you very much.
MS. JANDA:
The next speaker will be No.
8.
MR. GARLEY:
Hi.
I'm John Garley.
I'm from Hingham.
I have an NRC Information Notice 2012-20 [Potential Chloride-Induced Stress Corrosion Cracking of ustenitic Stainless Steel and Maintenance of Dry Cask Storage System Canisters, dated November 14, 2012 (ML12319A440)] that says that chloride-induced stress corrosion cracking of austenitic -- right?
You got the right word? -- stainless steel in dry cask storage systems.
And there's a couple of times that it happened in San Onofre, St. Lucie uclear Power Plant, Turkey Point, and through the wall at Koeberg Nuclear Power Station.
Are these casks made out of this austenitic steel? That's a question for Holtec.
Austenitic.
Are you going to answer the question or?
PARTICIPANT:
Austenitic.
MR.
GARLEY:
Austenitic?
re these casks made out of that?
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Because this (202) 234-4433
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Do you need to hit a button or something (referring to microphone)?
MR. KLUKAN:
I 'm just going to phrase it.
Would someone from either Entergy or Holtec like to answer that question?
MR. GARLEY:
Well, my concern is that the
[Chief Executive Officer] CEO says that, if there is a crack, you couldn't fix it, right?
And you might ot be able to find it.
But if there's no fuel pool, what do you do with that cask?
So, that's a question for Holtec.
Do we have a solution if there's a cask leak, and what are you going to do with it?
MS. J. RUSSELL:
My name is Joy Russell.
I think that Andrea did introduce me at the very eginning.
- First, I
would like to say that your information about canisters is incorrect.
There are no leaking canisters in the United States.
Holtec's canisters do not leak.
There has been no --
I have --
(202) 234-4433 MR. GARLEY:
The steel has corroded.
MS. J. RUSSELL:
That is incorrect, sir.
MR. GARLEY:
Okay.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 68 information docket number.
So, you might want to check with them.
I'm just going by what they have.
MS.
J.
RUSSELL:
Okay.
Holtec's canisters have no evidence of stress corrosion cracking.
MR. GARLEY:
Really?
All right.
- Well, you might want to talk to them because they' re put ting stuff online that says they do.
All right?
And then, the Sierra Club put a letter to the NRC as well -- it's Event No. 51134 [event date June 6, 2015 -
https://www.nrc.gov/reading-rm/doc-collections/event-status/event/2015/20150610en.html]
that Holtec filled the Diablo Canyon canisters incorrectly in half of them.
Is that incorrect as well?
Because there's stuff online you might want to cancel.
MS. J. RUSSELL:
Sir, I beg to differ with you; that is also incorrect.
MR. GARLEY:
Again?
Okay.
MS.
J.
RUSSELL:
The Diablo Canyon canisters, which were loaded by Holtec on behalf of Pacific Gas and Electric, were all loaded correctly in accordance with our Certificate of Compliance.
MR. GARLEY:
Okay.
Well, somebody's got some bad -- and the last thing is with NRC.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 considering deep isolation technology as
- well, esides just Holtec's stuff?
Because, I mean, we're getting one option here or two that sound pretty bad to me.
MR. WATSON:
Well, let me just state that there is MR.
GARLEY:
It just stopped my number (referring to the tickets for order of speakers).
MR.
WATSON:
There is a need in the country for permanent repository of the spent fuel.
MR. GARLEY:
Uh-hum.
MR. WATSON:
The Department of Energy is responsible for developing and finding that site and using the proper technology.
So, it's really up to our policymakers in Washington to fund those activities and to allow them to do their work in identifying and developing a
site and what technologies will be used with that.
I think everybody is aware that there was some work-in-progress at the Yucca Mountain site in evada.
And so, that came to a halt.
And so now, it's up to the policymakers to reinstate the need or the promise they made for disposing of this material.
MR. GARLEY:
Okay.
And my last question for Holtec is that you have sent an application to (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 70 the NRC for interim storage in Lea County, New Mexico.
Does that mean you want to move this waste to New Mexico?
Is that on your plan?
MS. J. RUSSELL:
Sir, you' re correct, Holtec has submitted a license application to the uclear Regulatory Commission to license a
consolidated interim storage facility in southeast ew Mexico.
And if the facility is constructed, it is the possibility of moving the fuel from here to that facility in New Mexico.
That is correct.
MR. GARLEY:
All right.
So, the DOE says there's 5,000 train car incidents a year.
Do you think that could be dangerous with stuff that's corroded from the ocean?
MS. J. RUSSELL:
your question correctly, Sir, if I understand you're asking for my opinion --
MR. GARLEY:
Yes.
MS.
J.
RUSSELL:
if I
think transportation of spent nuclear fuel.is safe.
- Yes, I do.
The industry does it on a regular basis.
We ave transported more than 1380 shipments by rail,
- safely, without any release of radioactive aterial.
(202) 234-4433 MR. GARLEY:
Okay.
Thank you.
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Thank you.
MR. KLUKAN:
Thank you very much.
Before we move, since we do have some
- time, we kind of left that hanging there, that question.
So, just to clarify, so the members of the ublic don't go away potentially confused on this.
Are the casks made out of this kind of steel, or if they're not, could we just state that for the record?
Because we kind of moved on to the second question without answering the first.
I just want to make sure, because it seemed like there was some confusion about that amongst the crowd.
MS. J. RUSSELL:
Yes, the canisters are ade out of austenitic stainless steel.
MR.
KLUKAN:
All right.
Thank you.
I appreciate that.
- 11.
Miller.
Center.
MS. JANDA:
The next speaker will be No.
MS. MILLER:
Hello.
My name is Claire I'm the lead organizer with Toxics Action We' re a public heal th and environmental nonprofit founded in 1987.
And while I don't consider myself to be an extremely young person, it is conceivable that I could live to 93.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 72 And I'm a community organizer, but I also happened to grow up Duxbury, Massachusetts.
I was born and raised in And so, I want to speak a little bit more from the heart tonight.
At Toxics Action Center we've really seen over our history that corporations go to very great lengths to avoid cleaning up their messes.
And as a
- teenager, I
have a lot of memories hearing about Pilgrim Nuclear Power Plant.
It's not every childhood that you learn your home could be in a nuclear meltdown.
My father is a curious man.
He took tours of the nuclear power plant before they stopped doing that after 9/11.
He told me stories about how the folks would say, "Oh, don't stand there.
That spot's hot."
We also had a family friend who worked at like a landscaping company.
And I remember my father and them joking about, you
- know, how the site was -- there are hidden mysteries.
And my distinct impression was that they weren't kidding, even though they were talking in a funny manner.
So, it really disturbs me that this isn't roceeding with extreme care to the data.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 73 there's a comprehensive environmental analysis done on the entire site.
We have to know really what's there.
The second piece here is that, as corny as it may sound, we're in Hotel 1620.
I am actually descended from a pilgrim, and that's 15 generations of my family.
And I have an intention to do well by this place.
You know, my descendants haven't always done well by this land, and I'd like to see 15 more generations.
But that's only possible if we do an extremely good job.
So, it's very important to me that we honor the Commonwealth's desire for a cleanup standard of no less than 10.
And the third thing that I am really sitting on as we're here is really around drinking water.
It's so precious.
And once it's contaminated, it's extremely difficult to fix.
Toxics Action Center is working with countless communities across the region who don't have access to clean drinking water.
And so, as this continues, as the NRC oversees the future of the site, we have to ensure that there's clean drinking water and we must meet the EPA's own standard of no less than 4 for the drinking water.
(202) 234-4433 Thank you.
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- 74 MR. KLUKAN:
Thank you very much.
MS. JANDA:
The next speaker will be No.
MS. CORRIGAN:
Hi.
Joanne Corrigan.
I live in Plymouth.
lant.
I can ride my bike to the power I've got a couple of questions.
First of all, that beautiful slide they showed of Yankee
- Rowe, how pastoral it looked after the decommissioning, where are the spent fuel casks?
Is that airbrushed or Photoshopped?
(Laughter.)
MR.
WATSON:
No, that's an actual icture.
The dry fuel storage facility is located above the river there on the hill.
MS.
CORRIGAN:
Because Plymouth will never look like that.
First of all, we have that nasty jetty that's ripped the sand off Priscilla Beach.
And apparently, that's staying there, even though the slides are saying how it goes back to the atural state in the environment.
Is that right?
Isn't Holtec going to leave the jetty there?
After the reactor cools, I know answer.
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75 MS. STERDIS:
It is our plan to leave the MS.
CORRIGAN:
Okay.
My other question -- and I agree 100 percent with Mary Lampert that you're moving the casks now.
Finally you figured out it's too close to the ocean.
You didn't need a study.
Just come down to Priscilla Beach during a full moon when there's a nor' easter, and ou'll see the waves come crashing onto the street.
hy they put those first ones so close is beyond me.
Now where they' re going to move them, they' re right out in the open of Rocky Hill Road.
d what's to prevent, say, a dump truck with about with RPGs or AR-15s with armor-piercing from stopping there, jumping up, and not shooting at 100 casks, shooting at one cask?
What's the chance of that being compromised and breached and releasing radiation?
dvisory MS. J. RUSSELL:
Again, Joy Russell.
In November, we presented at the Citizens Panel
[1] a very lengthy discussion --
I personally did that with one of my colleagues - -
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In that discussion, which you can go back and I believe see it online, I
resented a long discussion about the casks' ability to withstand even an aircraft crash
ltec%20Cask%20Design%20NDCAP%20Nov%2028th.pdf.
So, the system is very robust and it can withstand what you have just described as beyond-design-basis scenarios.
MS.
CORRIGAN:
I see.
Well, my third comment is, when Pilgrim was up and running and actually made money, Entergy still couldn't get them out of the column 4 degraded column, didn't want to spend the money, didn't have the expertise, didn't have the enthusiasm, all of the above.
What makes you think we are going to elieve, after the NRC gives them a pass on the cybersecurity, the everything, that now, all of a sudden, they' re off 1 ine, they' re not making money, and they're going to put in the resource of the money to keep us safe?
I don't believe that for a minute.
- 5.
(202) 234-4433 Thank you.
MR. KLUKAN:
Thank you.
MS. JANDA:
The next speaker will be No.
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CONSETINO:
Now I'll finish my comment, but I'll make it very quick.
I wanted to follow up on the comments -- I'm sorry.
Henrietta Consetino.
MS. JANDA:
Thank you.
MS.
CONSETINO:
Plymouth
- resident, League of Women Voters.
I wanted to follow up on the many questions about
- finances, and go back to Jim Lampert' s question.
Where is the regulation that actually holds the licensee responsible, should the fund, the Decommissioning Trust Fund, be inadequate?
d along the way, what happens if the stock market crashes, and 1.05 billion turns into 900 million, or something of that sort?
What happens then?
What is the state of the Trust Fund right now?
MR. KLUKAN:
Thank you.
MR.
TWOMEY:
Mike Twomey, on behalf of Entergy.
We provide a periodic update on the value of the Trust Fund, and we do not have an up-to-date number available this evening.
MR.
KLUKAN:
Just to follow up, so we don't leave it like that, when do you provide these?
So, October was the last one.
When would you provide (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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MR. TWOMEY:
Well, we at least provide a number in March of every year as part of our annual disclosure to the NRC.
I don't know if we will be roviding one before March.
And it's actually a number.
I think it actually comes out in MR. KLUKAN:
Okay.
Thank you.
MS.
CONSETINO:
It's worrisome because we've had some very serious major plummets in the arket since October.
But I
want to go back to the first question and make sure you don't forget that Jim originally asked, is there a regulation that holds the licensee to its financial responsibilities?
And if so, what is that regulation?
MR. KLUKAN:
Again, thank you.
MR. WATSON:
Let me respond.
I'm sorry.
The regulations for the decommissioning funding are spelled out in 50. 82.
The actual requirement, if you're going to accept or apply for a license with the NRC, means that the licensee will be responsible for providing the decommissioning funds to restore the site and have the license terminated.
Those are in, I think it's 50.2.
When a licensee applies for (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- license, there's something called the Common Defense Clause, which means you are accepting that responsibility when you apply for a license, and that ou will be radiologically and environmentally responsible for cleaning up the site when you've completed the work.
PARTICIPANT:
What if they go bankrupt?
MR.
WATSON:
They' re still responsible for providing the funding, and that would be part of the process we would go through for getting the assets of the company and continuing the completion of the decommissioning.
MR.
WATSml
[KLUKAN] :
We have two more, and then, we can potentially do a second round.
But the question that was posed on the floor, to which Bruce responded,
- was, what happens if they go bankrupt?
I just wanted to make sure we capture that for the transcript.
So, next up will be No. 13.
MR. GUSTAFSON:
Good evening.
My name's Scott Gustafson.
I'm a Plymouth resident.
I'm happy to hear tonight that Holtec is lanning on going with the DECON process and the expedited process.
I'm here to support the license transfer to Holtec because of their technical (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 80 expertise.
As a
representative of the Laborers' International Union of North America, our union has worked extensively with Holtec and their subsidiaries around the
- country, successfully,
- safely, efficiently.
I don't know if some of the references to Holtec tonight are accurate, because we've always worked closely with them.
It's always been safe.
It's always been very efficient.
I have a brother and sister who are working down at Pilgrim now, or have worked on the last two projects with Holtec down there.
I don't hear anything about unsafe conditions.
I hear that the job is going great; they' re moving the fuel correctly, and they're very comfortable, and they're aking a great living while they're doing it.
The lant has always been an economic benefit to our town, and decommissioning this way will also be a strong economic benefit.
I also want to say that Hol tee works extensively with our International Union and has helped us develop a
state-of-the-art rad worker training program, and we train workers in our state-of-the-art facilities here in New
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 81 Hopkinton, in Pomfret, Connecticut.
And over the years, our members have decommissioned Maine Yankee, Connecticut Yankee, and the Yankee Rowe Plant, which I actually go rafting up there, tubing up there in that river.
It's a beautiful site.
I go up there every year.
It doesn't bother me at all.
I'm happy that it's going to be the expedited decommissioning and return that site back to its beauty that it once was for the Town of Plymouth.
So, thank you very much.
MR. KLUKAN:
Thank you.
MS. JANDA:
And the last speaker on the list will be No. 6.
MS.
CARPENTER:
My name is Susan Carpenter with the Cape Downwinders, and I live in South Dennis on the Cape.
I have a comment, and then, I have two questions.
At one of the Nuclear Decommissioning Citizens Advisory Panel meetings, Holtec spoke and said that they have an impeccable safety record.
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My questions are:
is it a conflict of interest for Holtec to buy Holtec casks to store the nuclear waste?
MR. WATSON:
I guess that's a commercial thing that the NRC would not get into, but I don't see any real issue with it. It is what their product line is and what they're offering.
And I assume that they will use that, do the work safely and compliantly with the license requirements for the Certificate of Compliance.
And we'll be there to inspect to make sure that they are.
MS.
CARPENTER:
Okay.
And my other question was:
how many sites has Holtec decommissioned?
And by that, I don't mean as a contractor.
Excluding that, how many sites has Holtec decommissioned?
MS.
J. RUSSELL:
Holtec International has not decommissioned any sites.
However, that
- said, we have hired Comprehensive Decommissioning International, CDI, which is a company that includes SNC-Lavalin, and they have a
rich history of decommissioning nuclear plants and other nuclear facilities.
(202) 234-4433 MS. CARPENTER:
Thank you.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 83 MR. KLUKAN:
Again, that was Joy Russell of Holtec, just for the purposes of the transcript.
All right.
We've now exhausted, as you can see -- this is really good handwriting for me.
I'm going to pat myself on the back for this.
We've now opened it up -- whatever, I'll take what I can get to people who have not yet spoken this evening.
So, we don't have an established order, ut I think Pine raised her hand first.
And then, we'll just go around.
Okay?
So, again, we'll do three minutes apiece, and then, if we have enough time left over, people ay get to do a second round.
But let's go first with people who have not yet had an opportunity to speak.
So, I turn it over to you.
MS. DUBOIS:
Thank you, and thank you all for being here.
I want to state clearly that I hope Holtec succeeds.
I hope Entergy is happy, and I hope the NRC finally wraps its head around sea-level rise, which you are not doing, and that is pretty plain with your reliance on the 8-+/-EG [SEIS] and the GE-Ht
[GEIS].
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 84 There is no basis at all for you to accept Entergy's proposal to wait 60 years to clean up the site.
That's plainly a fraud.
Take a
look at the Fourth National Climate Assessment that was released in late October-ovember.
You will be chapter 18 in the Northeast.
You will see that our worst-case scenario is, by 2100, we have sea-level rise of
- 11. 5 feet
That's the new
- estimate, but daily things are changing so fast and the scientists are learning so uch, that that adjustment continues.
It is important to the public trust that ou regulators and you contractors and Entergy -- oh, Lord -- takes care of us and looks at that.
Cleaning p the site does not mean letting it wash into Cape Cod Bay, and in 60 years that's what's going to happen.
Even if there's not inundation on the site, the groundwater level will be so high that you will not be able to safely and effectively get the contamination out of the ground.
If it goes into the environment, the NRC is failing in its mission to rotect the environment and the people.
Holtec, as a reputable company, I will say.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 85 Entergy, as a reputable company.
You need to address this.
The PSDAR for Entergy does not.
The Holtec PSDAR does not.
And if they run out of money and the cleanup is delayed, we're all in a stew.
So, please, NRC, take another look at our regulations.
Give it a try at updating that.
Call in those scientists that work for the government that wrote that report, and get on the reality page.
e*ve living with it here.
Stick around on Sunday.
Sunday, Monday, Tuesday, stay here.
Go down to the lant then and see what happens.
Thank you very much.
MR. KLUKAN:
Thank you.
Again, that was Pine duBois.
Just please state your name for the record before you begin.
MS.
DUBOIS:
Pine duBois with
[Commonwealth of Massachusetts Nuclear Decommissioning Citizens Advisory Panel] NDCAP.
MR. KLUKAN:
So, Pine duBois with NDCAP.
Thank you.
MR.
E.
RUSSELL:
I'm Ed Russell, an elected town meeting member in Plymouth.
When businesses as well as governmental agencies engage in big contracts, they usually see to (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 86 it that there's a bond produced that will guarantee the performance of the contract.
And so, I'd like to know why that isn't possible here.
MR. WATSON:
Performance bonds are used frequently.
If we deem that there's sufficient funds to do the decommissioning, we have no need to require them.
I think in the recent
[Vermont Yankee]
VY transfer, Vermont Yankee sale, asset sale and license transfer, one of the conditions we put on -- or the agreement that we got from Northstar was to provide additional financial assurance.
I think it was along the lines of $30 million to make sure there was sufficient funds.
If it's not required, then they're not required.
So, it's up to the agreement between the sales, also, to come up with the proper financial information and guarantees.
MR. E. RUSSELL:
That's your version of risk assessment, but we citizens here have a
different assessment of the risk.
And when you do have a contract that's just barely enough to cover, and could well exceed the funds available, I would say a prudent entity would look for a bond.
And if there is, as you say, a low risk, then the bond should not be that expensive.
So, I'd like to see that happen.
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Thank you.
MR.
KELLERMAN:
So, my name is Bruce Kellerman.
I have a question.
What happens to the 1200-acre site?
Who owns it and are there plans for development?
And if so, where can we find those and what are their elaborate schemes?
MR.
TWOMEY:
This is Mike Twomey, on ehalf of Entergy.
When you say the 1200 acres, I assume you ean the 1200 acres of undeveloped property across Rocky Hill Road, correct?
MR. KELLERMAN:
Yes.
MR.
TWOMEY:
That property currently is owned by Entergy.
It is included in the sale to Holtec.
And if the license transfer application is approved and the transaction closes, Hol tee will become the owner of the 1200 acres.
And I have not heard about any specific plans for development of that site at this time, but they would be the owner of the land after the transaction closes, if it closes.
MR.
KELLERMAN:
Does Hol tee have plans for the development of the site?
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MS. STERDIS:
No specific plans for that roperty have been defined at this time.
And, yes, we will be paying the appropriate property taxes on that site.
MR.
KLUKAN:
Thank you for your questions.
MR.
DELAFIELD:
- Yes, I'm Lawrence Delafield.
I'm a resident of the Town of Plymouth, a town meeting member, and the President of the Six Ponds Association, which is a local organization very close to the site.
And of course, my concern is this:
we live in an area that will be in danger until this aterial is totally removed from the site.
Why do we have to wait that long?
How can we possibly get that moved up, so that it's removed quicker, or at least provide a major incentive to remove all items from the site?
Because we will not be safe until that happens.
MR. KLUKAN:
Thank you.
Okay.
Is there anyone else who has not yet spoken who would like to speak this evening?
(No response.)
(202) 234-4433 Going once, going twice.
All right.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 89 Is there anyone who has spoken this evening who would like to speak again?
MR.
LAMPERT:
Jim Lampert, resident of Duxbury.
I'd just like to spend a moment on comments, and if I'm wrong, I would ask that the NRC, Entergy, and Holtec correct me.
My understanding of the transaction, as described in the license transfer application, is that Holtec-Pilgrim will be the owner of the site and will be the one who owns the Decommissioning Trust Fund.
In Holtec 's license transfer and PSDAR applications, it says that, quote, "The existing Decommissioning Trust Funds provide the appropriate basis for the financial qualifications of Holtec-Pilgrim."
It also says that Holtec, quote, "Holtec-Pilgrim will be required to pay for HDI 's cost of ost-shutdown operations, including all decommissioning costs at Pilgrim."
Close quote.
It seemed very clear from that that the only potential financial responsibility of Holtec-Pilgrim -- and that is the only one we need to focus on because they are the only licensee depends entirely on the Decommissioning Trust Fund.
It also seems clear, listening to Mr.
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- Watson, that a statement in a regulation that a licensee that, frankly, has no money and is bankrupt is,
- quote, "responsible,"
close quote, provides absolutely no assurance that that licensee will pay.
It, frankly, doesn't have any money.
And that, unless I
missed something that Mr.
Watson has said -- and I asked the question earlier -- there is absolutely nothing in NRC rules, regulations, or ertinent law that would permit the NRC to enforce licensees' and their parents' responsibility to ay for what they caused.
Am I correct?
MR.
WATSON:
I will try and respond a little bit here.
We owe you a response to your question on the ownership.
The only comment I can really make at this point, we will be responsible with the responsible regulations.
I have to go to our Office of General Counsel for that.
MR. LAMPERT:
No, no, I would appreciate your doing that, though.
MR.
WATSON:
Yes.
No, we have to do that.
The other issue is that we are currently reviewing the license application or plan to start on that very soon.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 91 and the general requirements for the decommissioning funding and how they would apply to the license transfer.
It's we're still doing our review.
So, we haven't concluded anything.
And so, your comments are valid to that review.
And so, I'm sure the staff will take that into account.
MR. LAMPERT:
Yes, and I would ask that, if in the review or in further conversations with Holtec, the NRC or its staff discovers any way in which there, in fact, is an enforceable commitment or an agreement, that people who have the money will set that money up to pay for the shortfall.
I would like to hear about it, and it's quite clear that the assachusetts Attorney General would also like to hear about it.
MR. KLUKAN:
Thank you again.
MR. TWOMEY:
Yes, if I may briefly, Mr.
Lampert introduced his remarks by saying that, if we didn't say anything, it meant that we agreed with him.
And I can't agree to that, just at least on ehalf of Entergy.
On behalf of Entergy.
MR. KLUKAN:
Okay.
MR. ROTHSTEIN:
Richard Rothstein.
Two questions.
One for Br. [Mr.] Watson and one for our Holtec representative, Joy.
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~
[Mr.] Watson, can you qualitatively explain or define, for purposes of releasing the site
- license, site restoration, what basically is included; what would not be included in the case of the Entergy site?
So that people don't get false expectations one way or the other.
MR.
WATSON:
Yes.
The Decommissioning Fund requirements from the NRC are for the radiological decommissioning.
So, once we would terminate the license after verifying the radiological conditions of the site - -
we have an independent contractor we use in many cases to help us with the surveys and verify the radiological residual radioactive levels at the site --
we would terminate the license.
If the site restoration is not in the requirements by NRC, because there' s a number of approaches you can take to decommissioning - - many of them take into account removing the buildings and turning it back into greenfield.
If they submit that to us in their license termination plan, then that's the plan they follow because it's a license amendment.
If they choose to do things which some of the other power plants have done, such as Trojan or Rancho
- Seco, where they actually terminate the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- license, but 93 leave buildings and stuff still remaining on the site, that's their choice.
And after that, it's up to the owner of the facility or the licensee -- and at that point they're no longer the licensee, but the owner of the property --
and the state, to determine when and where they should do the final decommissioning and site --
I should say final site restoration and what those requirements are.
MR. ROTHSTEIN:
Okay.
Thank you.
I had the pleasure of sitting in the Holtec predecisional enforcement conference last
- ednesday, I believe it was, the four-hour - -
and ore nuts and bolts were discussed than I could fit in my car.
But I wanted to commend Holtec on its dry cask presentation to the NDCAP last fall.
I thought it was very informative, and I believe it's on the CAP website.
Just expanding upon Ms. Lampert's comment earlier about cracks not being able to be fixed in the multipurpose canister at this day and age, one thing I was envisioning, given that premise, has Holtec, for purposes of future design considerations to remedy that kind of unsolvable problem at the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 94 oment, considered constructing a larger multipurpose cask there to go over the cracked cask?
And then, of course, that slightly larger cask could be filled with helium gas as a coolant and sealed.
And then, that larger cask would then or that larger ultipurpose cask with the cracked inside of the other cask, multipurpose cask, getting to a larger overpack, if it need be, with the air vents, too.
So, is that a possible design solution that may be on the drawing board from Holtec?
MS.
J.
RUSSELL:
That's a
very explanation.
It's very close to what we've actually designed for recovery of a canister in the event the inspections were to show that there has been a degradation.
So, indeed, that is the approach, is to put it into another overpack, but an overpack, not necessarily the canister as you've described.
So, you're on the right track, sir.
It is definitely an additional overpack that we are going to use.
MR.
ROTHSTEIN:
I'm glad to hear that.
Can you tell me who I write to at Holtec to get some royalties?
(Laughter. )
MS. J. RUSSELL:
Right.
to get on the patent.
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M.
LAMPERT:
Can a
canister be shipped under current regulations?
MR. KLUKAN:
Ma'am, are you asking, just so we get it on the transcript, are you asking whether the current canister or the overpack can be shipped?
MS. M. LAMPERT:
(Off microphone.)
MR.
KLUKAN:
Okay.
I just have just given you the microphone.
So, essentially, can a cylinder which has been or a canister which has been compromised or degraded, do the regulations allow it to be shipped, is the question that was posed by Ms. Lampert.
MS. J. RUSSELL:
The regulation question I defer to the NRC.
MR. WATSON:
I ask Jason Piotter, who is our Senior Engineer for Spent Fuel Safety, to come up and give you an answer for that.
MR.
PIOTTER:
The regulations are erformance-based.
And so, if you had a canister that had a demonstrated flaw like you' re talking about, there would have to be an engineering analysis that was done to determine what the best way to itigate that particular flaw would be.
I can't answer the question right now whether or not it would be allowed to be shipped because we don't have any (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 96 scenarios where there are flaws such as you describe.
So, it's a case-by-case basis, depending upon what the situation is for the canister that you're talking about.
But it would have to be evaluated prior to transport.
I couldn't just be put into a transport overpack and sent.
So, it would have to be an engineering analysis prior to that activity.
MR. KLUKAN:
Thank you.
MS. TURCO:
I just want to go back to the Holtec in San Onofre because it could be our future.
Diane Turco with Cape Downwinders.
At San Onofre, they've been loading, Holtec has been loading canisters in underground aults on the beach.
The sea-level rise is eventually going to leak into the bottom of those vaults.
They have been loading them and scratching them.
And there was a special inspection by the uclear Regulatory Commission
[3]and it sounded almost like Entergy's special inspection report, pretty much the same.
So, I want to know.
And the people in California have said, "Let them know the public in (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 97 Southern California is asking the Holtec System to be recalled."
It's a
- lemon, and Holtec is making loading errors due to mismanagement and bad engineering design that the NRC admits it cannot fix.
So, that's what's happening out in California.
So, I have two questions.
No. 1, how can you come to the NDCAP meeting and say that Holtec has an impeccable safety record when this was all exposed by a whistleblower?
And No.
2, would you conduct an environmental impact study, including sea-level rise and acts of malfeasance on the spent fuel pad?
MS. J. RUSSELL:
Can you repeat the first question again?
MS. TURCO:
Let me try it this way:
how could you with a straight face tell the NDCAP that Holtec has an impeccable safety record when we know what's going on at San Onofre?
MS.
J.
RUSSELL:
I appreciate the question.
I understand your concern.
Let me just state, Holtec does have an impeccable safety record.
And the issue that happened at San Onofre, which was reported by the licensee who is the Southern California Edison uclear Plant, they went through their process.
So, (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 I
absolutely can emphatically say that.
MS.
TURCO:
Did Southern Edison report this incident when it happened to the NRC?
MS.
J.
RUSSELL:
Those questions are best --
MS. TURCO:
Okay.
No, they did not.
MS.
J.
RUSSELL:
to the Southern California MS. TURCO:
And you can look up on the record they did not.
No.
- Actually, the NRC initiated the special inspection, right, Mr. Watson?
MR. WATSON:
From what I understand, the licensee was a little late in responding to --
MS. TURCO:
Yes.
MR.
WATSON:
the requirements.
And so, based on that, we escalated our inspections to --
MS. TURCO:
Thank you.
MR. WATSON:
-- evaluate the situation.
MS.
TURCO:
Thank you.
It was a
histleblower.
MR.
WATSON:
But it was not a
whistleblower that submitted the complaint.
MR.
TWOMEY:
This is Mike Twomey, on behalf of Entergy.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 One thing, I think, just to clear up any confusion for those who don't know as much about the issues as some of the recent speakers.
One thing that's important to note here is that, if Entergy remains the owner of the facility, we will be using the Holtec dry fuel storage system.
If Holtec becomes the owner, they will be using the Holtec dry fuel storage system.
So, the license transfer will have no impact on what system is used at Pilgrim for storing spent nuclear fuel.
It will be the Holtec dry fuel storage system that we use or they use.
And I don't know how that relates to the scope of this particular proceeding, but I do want to ake sure that people understand that it's not an "either/or".
It's not like, if Holtec becomes the owner, that's the only circumstance under which the Holtec system will be used.
That very same system will be used if we remain the owner.
I just wanted to clear that up for anybody who may not understand that.
MS.
TURCO:
Right.
Yes.
Thank you.
Right.
Because the point is it's both mismanagement, oor equipment, ongoing problems.
But the second question was, would an environmental impact study include sea-level rise and (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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MS.
J.
RUSSELL:
- First, I
want to emphatically state that the system that's in use at San Onofre is markedly different than the one that's in use at Pilgrim.
You're comparing apples to oranges.
It is correct.
It's an above-ground system ersus an underground system.
question.
system.
MS. TURCO:
Oh, no, no.
That's not my MS. J. RUSSELL:
And not the dry storage MS. TURCO:
That's not my question.
MS. J. RUSSELL:
And therefore --
MS. TURCO:
That's not my question.
MS.
J.
RUSSELL:
there isn't a
robabili ty of an issue as you have at San Onofre with water collection in the bottom of the system.
MS. TURCO:
Okay.
MS. J. RUSSELL:
It can't happen because they are two different systems.
MS. TURCO:
Right.
But what I'm asking is, would you include sea-level rise for the roperty, as Pine spoke about, and storm surges, and acts of malfeasance?
That's my question.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 systems are licensed under Part 72, and they're deployed under Part 72 currently.
And they're already being deployed in accordance with the regulatory requirements.
There's no additional investigation or analyses that need to be performed for the dry storage systems.
MR. KLUKAN:
I gave the women a back-and-forth.
But, if you know you're going to keep
- talking, just, for the sake of our poor transcriptionist he is not the object of your concern.
So, let's make his life easier.
So, just speak into the microphone when you're asking questions.
Okay?
And the
- question there was, would you include sea-level risk and acts of malfeasance in an environmental assessment or impact statement?
MS.
J.
RUSSELL:
We'll meet the regulations.
The dry spent fuel storage system is already deployed and it will continue to be deployed, no matter whether this license transfer application occurs or not.
I don't understand the question of the need for additional environmental studies related to dry storage.
MS. TURCO:
You're building a new storage facility there, a brand-new storage facility.
Right (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 now, you can drive onto the property, pass the "no trespassing" signs, and eyeball the dry casks.
Now you' re moving them closer to Rocky Hill Road.
We need to be assured that there's going to be some increased security there.
So, that's just a
question.
Are you going to be looking at acts of alfeasance when you do the new pad?
MS.
J.
RUSSELL:
The security that's already at the nuclear plant, I allow Entergy to talk to.
The security of the dry storage system, under the license under Part 72, has already been established.
There's no additional requirements that need to be addressed.
MS.
HALTER:
This is Mandy Halter, on behalf of Entergy.
The independent spent fuel storage installation facilities are required to be secure.
d with the newly-located pad, there will continue to be a
physical barrier behind an intrusion detection
- system, and monitored 24/7 by armed security.
And that's correct; that's all I can talk about, due to safeguards.
MS.
LYNCH-BENTTININ:
Benttinin, Duxbury.
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103 I have a question about regional public In the last 40-plus years, Entergy was required to do a regional public safety plan, and they've applied with their PSDAR to abandon that regional planning.
And we are concerned about Holtec taking over.
What is your plans for notifying regional safety folks, like firemen, et cetera, on safety, particularly with the expedited four-year lan that you presented tonight?
MS. STERDIS:
This is Andrea Sterdis.
We will continue to comply with all NRC regulation.
And I want to emphasize that it is Holtec 's top priority to maintain the health and safety of the public.
MS.
LYNCH-BENTTININ:
But what I'm asking, in particular, is, what is your plan to reach out to regional safety folks, like firemen and regional coordinators, as your expedited four-year lan is ongoing?
MS. STERDIS:
And again, I will emphasize that we will maintain the health and safety of the
- ublic, and we will be complying with all regulations.
MS.
LYNCH-BENTTININ:
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 104 of regional safety outreach to public safety officials?
MR.
WATSON:
If I
understand your question correctly, there's no need to add anything.
Because the site is still going to maintain an emergency plan and emergency response capabilities, along with security response plans, which have those communication tools in them that they're required to have.
So, they' re going to continue those things ntil the decommissioning is complete.
really no need to change those plans.
So, there's Now I
can't specifically talk to the regional plan.
I'm not familiar with it. It was not an NRC requirement that I know of.
But there are requirements for notification and security/police support; also, fire protection and fire response, edical emergencies and medical responses to the site.
And so, those things all stay in place.
MS.
LYNCH-BENTTININ:
But Entergy has requested that they be discontinued in the regional capacity.
MR. WATSON:
All I know is they have to eet the minimum requirements for the NRC, which eans they will maintain the ability to talk with, get notification of the response capabilities from (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 105 local and state law enforcement.
They will continue to deal
- with, communicate with the local fire departments and rescue squads.
MS.
LYNCH-BENTTININ:
Would they be required to coordinate --
MR. WATSON:
The regional, there's no NRC requirement for a regional response plan.
MS. LYNCH-BENTTININ:
Okay.
MR.
WATSON:
There is one for the immediate location around the plant.
MS. LYNCH-BENTTININ:
Thank you.
MS.
MILLER:
Claire Miller from Toxics ction Center.
I'm getting really agitated because this really matters a lot to me.
And if I understand what Diane is bringing up correctly, and your response, Ms. Russell -- it's kind of hard to read your name tag from here; sorry if I got that wrong -- it's that we have rapidly upchanging data on climate change, the impacts of sea-level rise that are getting worse every time they're updated.
We have someone in the hite House who's changing world politics and dynamics rapidly, and we are living in an age in which terrorism is ever present.
And we want to know, are you willing to go above and beyond, if necessary, or (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 are you only willing to do as much as - - like the floor of what's required?
Because what I hear Diane asking is, are you willing to go above and beyond to protect our health, our community?
And what I hear you saying ack is, "We're doing with it what's written.
We're going to do what's necessary, what the law is."
m I understanding correctly?
You're committing to the floor?
MR.
WATSON:
I just want to respond to that, and that the NRC regulations fully provide for safety for the people working at the plant, the ublic, and the environment.
And so, complying with is one demonstration that the plant is aintained safe, and we'll continue to inspect that lant against those requirements.
MS. MILLER:
I have no doubt that the NRC is doing the best that it can to protect the health and safety of my community.
I also know that we're in a rapidly-changing world.
And I am interested to know if Holtec is committing to the floor of what the C -- like where we're at the last time those laws
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 107 ever-present, fast-changing world of climate change and terrorism.
MS.
J. RUSSELL:
I think what you' re asking me is, am I confident that our dry spent fuel storage system is safe.
MS.
MILLER:
No, that's not what I'm asking you at all.
It's not what I'm asking you at all.
MS.
J.
RUSSELL:
I am personally convinced I am a nuclear engineer.
I am part of the design team that designed this dry storage system.
And I am confident in its robustness.
I'm confident that we have gone above and beyond to ensure that we selected materials MS. MILLER:
I am MS. J. RUSSELL:
-- that we've selected the methodologies, and we have done the absolute utmost we can to ensure the health and safety.
MS. MILLER:
I have no doubt that you're sincere MS. J. RUSSELL:
May I please finish?
I live by these nuclear plants as well, and I am confident that, when I go to visit these lants --
I live by these plants; I live by where our dry storage systems are deployed --
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 108 confident that my company has done everything it can to go above and beyond.
And the ref ore, I
have answered your question.
MS. MILLER:
That wasn't my question in the slightest.
I do believe you' re 100 percent sincere when you say that.
I also believe that the engineers who worked on Chernobyl, Three Mile Island, and Fukushima were also really sincere in believing that their plants were safe as well.
I just want to say for the record you didn't answer my question.
MR.
KELLERMAN:
So, Bruce Kellerman again.
My question is to Holtec.
understand the fund, it can go up and down.
As I
It's like a 40l(k), right?
It's an investment vehicle.
What happens if it goes down?
And also, could you, would you sue the Department of Energy, as others have done, for failing to take the waste offsite?
Would you plan to do that?
Are you?
MR. WATSON:
Well, let me respond to the first part.
Yes, there are market changes.
The Trust Fund is in an independent trust with an independent trustee.
Most of them are with Mellon Bank of New York.
So, the trustee has certain (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 109 requirements on them to make conservative investments to protect the fund.
Secondly, all the licensees that are storing fuel - - I' 11 say broadly "everyone" - -
has the ability to request or sue, if they have to, the Department of Energy to get the cost back for the storage of the nuclear fuel.
So, I'm sure Entergy has done that in the past for their plants.
I'm sure Holtec will do the same to recoup the costs.
Those costs are, then, available for doing other activities at the sites.
And so, that's part of the agreement with the federal government.
exemptions.
MR. KELLERMAN:
Thank you.
MS. LAMPERT:
Two points.
NRC is giving So, the DTF can be used for spent fuel anagement costs.
Now go back.
The Decommissioning Trust Fund was established when we were a utility structure ratepayers.
investments.
Boston Edison was the owner --
by Since that
- time, it's grown from Entergy didn't put a dime in it.
Holtec won't put a dime in it.
Okay?
Then, they will sue DOE to recoup what they've spent on spent fuel management costs, okay, what they've spent by taking it out of the Decommissioning Trust Fund.
But, then, when they get (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 110 the money out of DOE, there's no requirement to put it back.
If there is, please correct me and give me the regulation.
- Instead, they put it in their And that's, you know, if I were Holtec, I'd "I'm going to make a pile of money doing this."
d that's part of the incentive to take over the license.
It would seem to me that the NRC would get on the stick and make some sort of requirement/regulation that it goes back into the Decommissioning Trust Fund to refurbish what they have taken out.
Because there 's no requirement?
Correct that.
And then, I just want to sum up by saying, the points brought forward on sea-level rise, the oints brought forward on the increased risk of terrorism, of cyberattack - - now that's a big one when you think of the spent fuel pool.
All these new and significant information that you should be responsible, NRC require that they do a NEPA review, and then, not say what is blatant foolish.
It's a lie to say the 2002 Generic Environmental Impact Statement and the 2006 Impact Statement done during relicensing bound environmental impact, so we can all skip along and say it's a clean site; we've done our (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 111 job.
So, they really don't have to spend a dime, and all the stuff can go in Cape Cod Bay.
Dilution is the solution.
MR. KLUKAN:
Thank you.
MR.
WATSON:
I just want to make one
- comment, that the Decommissioning Funds that are -- or excuse me -- the spent fuel funds that are recuperated from the Department of Energy, I think it's 50.82, Mike, in the regulations, the fund.
The oney goes back into the fund.
No?
It doesn't?
Okay.
PARTICIPANT:
It goes to the company.
MS. LAMPERT:
No, it's a good thing for them to make money.
MR. WATSON:
Okay.
Well, I'm sorry.
I appreciate the comment then.
We have to look at that.
MR. KLUKAN:
Before you begin, is there anyone else in the audience who has not yet had an opportunity to speak who would like to do so?
(No response. )
Okay, please.
Would you mind letting her go first?
Okay.
Thank you, sir.
(202) 234-4433 Your name for the record, please.
MS. GARRY:
Joanne Garry.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 from the plant.
I've been here since I was 16.
So, I saw it built by people that shouldn't be building it.
But that's not my question.
My question is twofold.
First of all, Entergy owns it, correct?
Got the license.
Owns all the property.
How much is it worth?
What's the roperty worth?
What did Entergy get or might get from Holtec, the cost, the dollars?
Are you selling it for money?
So, there's no money exchange?
Entergy walks away.
Holtec, if it gets the license, walks in, correct?
So, why does Holtec want this?
- Well, that's my question.
Why does Holtec want this really orrible thing to fix?
We've got thousands of people on the line.
So, what's the deal?
Why are you doing this?
No answer?
MS. STERDIS:
This is Andrea Sterdis, and I will make this a personal response.
As a
mother of two children and a
grandmother of four children, I am committed to us doing in this industry what is right.
And that is to take care of our plants when they're past their operational life expectancy and to turn that property back into a useful piece of property in the community.
So, that is my personal reason for being involved in (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113 this project.
MS. GARRY:
But it's in it for the money.
So, the money, you' re going to own 12,000 acres.
Twelve hundred acres.
You've got a big hill there that hasn't been developed.
Why not move all this terrible spent fuel to the top of the hill? If you' re going to move it; move it, move it away from the ocean or bury it in the hill --
I don't know --
a better solution than moving it next to Rocky Hill Road, which I go by every day.
So, I mean, it just seems simple solution.
If you can't move it away, move in a safer area.
But, again, you're going to be making big bucks here.
So, we want to be safe.
That's all I have to say.
MR. KLUKAN:
Before we begin, because we do have -- I'm sorry for interrupting you again, sir.
Just because we do have extra time -- I don't usually intervene like this, but I
think there's some confusion out there regarding what's the financial arrangement between -- and I'm not asking in specific terms but what's the financial relationship between Holtec and Entergy?
And I think the question was asked like, how would Holtec benefit from this transaction?
And (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114 I think if we could answer that, that would go a long way to clearing up some of the confusion in the audience.
MR.
TWOMEY:
This is Mike Twomey for Entergy.
I'll address the specific question of the way the transaction is structured.
Entergy is receiving only nominal consideration.
And I have to say I don't have the number in front of me.
We just recently closed the ermont Yankee transaction, and the nominal consideration there was a thousand dollars.
And we receive nominal consideration.
Holtec receives title to the plant or they're actually buying Entergy Nuclear Generation Company through an equity sale.
They get that company which owns the plant, has the Decommissioning Trust Fund and the liability for the decommissioning.
So, what Entergy gets out of the transaction is a thousand dollars.
And we are no longer involved in the decommissioning of the plant, in the same way that Boston Edison is not involved in the decommissioning of the plant.
All right.
We're going to transfer that responsibility to Holtec, and Holtec will receive the project, the plant, the Decommissioning Trust Fund, and the work associated (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 115 with it.
And I' 11 let Holtec describe why they would be willing to take this work on, as other companies have taken it on in other parts of the country.
MS.
J.
RUSSELL:
- Again, this is Joy Russell from Holtec.
Holtec is, and has been for 30 years, an industry leader in safe and secure storage of spent nuclear fuel.
We also have other business endeavors such as designing a small modular reactor.
And as we've pointed out this
- evening, we also have submitted an application to establish a consolidated interim storage facility in southeast New Mexico.
Holtec is committed to the nuclear industry.
And unfortunately, part of that also includes the safe decommissioning of nuclear power lants.
We recently built our third manufacturing facility here in the United States.
We now have 1.4 illion square feet of manufacturing here in the United States.
We're the largest exporter of nuclear roducts.
And again, that's a demonstration of our commitment to the nuclear industry.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 116 the next step and to acquire shuttered nuclear plants and to safely decommission those; and to take the ownership of the spent nuclear fuel, which is also our core expertise, and to manage that as it remains either onsite or is moved to New Mexico.
MR. KLUKAN:
Thank you.
And thank you, sir, for indulging me for that minute.
MR. ROTHSTEIN:
I've got all the time in the world.
A final question for Br-:-
[Mr.] Watson.
I was hoping that NRC's proposed revised decommissioning regulations were going to come out last November, as originally envisioned, and that final promulgation would have taken place sometime in the first half of this year.
Notwithstanding the current government shutdown, what is NRC's [estimated time of arrival]
ETA for when it was envisioning getting these proposed and final regulations out?
And a second question is, licensees who have submitted their PSDARs, even if they're in the rocess of being evaluated, or the NRC said, okay, they're good
- enough, so you can start the decommissioning process once the plant is permanently shut
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 117 circumstances get grandfathered separate from the new regulations for decommissioning?
Or would it be like, for example, a post-Fukushima, where the NRC says, okay, we've come up with this and the new regulations; therefore, all licensees must do blank, blank, blank for decommissioning, regardless of what was in your PSDAR?
MR.
WATSON:
Let me respond to the rulemaking schedule.
The proposed decommissioning rulemaking that's been in progress over the last few years, the staff made its scheduled requirement to submit to the Commission the proposed rules and the asis for those proposed rules back in May.
As many of you may know, we also had two new Commissioners appointed by the Administration.
And based on that, they've been taking care of the backlog of information or voting issues that they have on their late.
So, the staff is waiting for the Commission to do their job.
So, it's the Commission's priority to address their work at their own schedule.
So, the staff is waiting for the Commission to vote on it.
We have not received a schedule of when that vote is to take place.
And so, we are basically at the mercy of the Commission for (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 118 eeting the time limit requirements they had originally placed on us to have these rules in place y
the end of 2019
So, we will, hopefully, resolve the issue with a Commission vote.
That will give us the direction on how we are to proceed with the proposed rules.
One of the proposed evaluations was looking at the PSDARs.
If there is a change in the regulations that the Commission wants concerning the PSDARs, then we will issue the regulations and the guidance with that.
And anybody that would come out in the future would have to comply with the new regulations.
Since the plants that are already in decommission have submitted their PSDAR, if they were to revise that, we would believe they would have to, at least I would believe that they would have to comply with the new requirements.
So, I think I answered both questions.
But we're at the mercy of the Commission and their vote scheduling.
And apparently, they have more ressing issues than the decommissioning rulemaking.
(202) 234-4433 MR. LAMPERT:
Jim Lampert, Duxbury.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119 I've spent a lot of time thinking and trying to figure out the answer to the question why would Holtec get into this.
And in addition to the fact that it's your business, I think the obvious answer is they expect to make a profit.
And if you ask yourself on what basis do they expect to make this profit, a number of things that I think are fairly clear, if you look at the whole picture,. come to mind.
And to the extent anybody, Holtec disagrees with me, and you think you can, consistent with the limitations of what you can say, correct me; please do so.
The first is they obviously think they're a great deal more efficient at doing this type of thing than Entergy ever will be.
The second is they want to get the decommissioning done early to avoid the risk of drastically-increasing costs that could be -- "destructive" is a nice word if they waited the period of that Entergy was planning to wait.
The third is that I was told by a Holtec representative that their profit is included in the costs you see in their PSDAR.
And last, just talking to various people in the industry, my understanding is that, before (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 120 someone will get into something like this, they really need a fairly clear path to what they see as.
a 25-to 35-percent profit.
MR. KLUKAN:
Thank you.
MS.
CARPENTER:
Susan Carpenter with Cape Downwinders.
This has nothing to do with money, but it has to do with ethics.
Recently, I know that Holtec changed the design of its casks for San Onofre and did not notify anyone, and that it really took Southern California Edison and Entergy by surprise.
d I'm wondering if Holtec, having basically gotten away with it because it was eventually approved, if they feel that they can do that here or if there's a likelihood they'll do that in the future, and we'll end up with something different than what we've negotiated for.
MS. J. RUSSELL:
The statements that you just made I
need to disagree with.
They're incorrect. I'll correct them.
The design of the system was not changed for San Onofre
[5].
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 121 Actually, the amount of time it would take me to actually correct all of your statements is going to exceed the time we have, and I would hate to do that, so that other speakers to have an opportunity to speak.
I'd recommend that you go and listen to the NRC's [pre-decisional enforcement conference] PEC Conference that was held last Wednesday, the 9th of January.
It explains the entire process.
But you've incorrectly characterized that.
MS.
CARPENTER:
May I
send you the article where I got the information?
MS. J. RUSSELL:
I didn't hear what she said.
MR. KLUKAN:
May she send you the article where she learned of this information?
MS. J. RUSSELL:
Absolutely.
MS.
JANDA:
Just to clarify for the transcript, the PEC video --
I hope I'm not restating this --
is available on the NRC website.
I think it's video.nrc.gov, will be the quickest way of getting there [6].
MS. CARPENTER:
This is the Orange County Register.
The title is, "NRC and Holtec to Face Off Publicly Over Redesign of Spent Fuel Canisters at San (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 Onofre Plant".
I wonder if, are they wrong in their eadline?
MS. J. RUSSELL:
I'm sorry, re-read the headline again?
MS.
CARPENTER:
"NRC and Holtec to Face Off Publicly Over Redesign of Spent Fuel Canisters at San Onofre Plant"
[7].
MS.
J.
RUSSELL:
The headline is isleading.
We didn't redesign the canister for San Onofre.
And again, it's a lengthy discussion, and it's all captured in a video from the PEC Conference on January 9th, where Holtec had a meeting at the NRC Headquarters.
MS.
CARPENTER:
From what I understood, they have a difference in the canisters.
But it was aware of, down at the bottom there were bolts added, and that design was only discovered when one of the bolts was loose in the canister.
MS. J. RUSSELL:
Again, you' re making isstatements, and we could go back and forth all evening on this.
I recommend that you get your facts (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 123 from this PEC video from the January 9th meeting.
MS.
CARPENTER:
Okay.
And I
will recheck with the newspaper as well.
Thank you.
MR. KLUKAN:
Thank you.
MR.
DELAFIELD:
This is Lawrence Delafield again.
I didn't really get an answer to my question.
So, I'd like to restate it in a slightly different way.
The question
-- and it was a
question -- is there any way at this point in this recess that we could require that the material be removed and put in a secure facility someplace else, such as you're talking about doing in New Mexico, and get it away from the community?
Because we will not be safe until that happens.
Or, if that's not the case, is there any way to give an incentive so that it gets removed faster and moved to another location?
I did not receive an answer to that.
So, I'd appreciate getting an answer.
Thank you.
MR.
TWOMEY:
This is Mike Twomey, on behalf of Entergy.
I'll answer that because we're the current owner of the facility.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 124 I believe what your question is when you talk about the material, you' re ref erring to the spent nuclear fuel.
And the answer to that is, the United States Federal Government is responsible for removing the spent nuclear fuels from the Pilgrim site and every other nuclear site in the country.
d the federal government has repeatedly breached its obligation to do so.
And many of us have been
- required, not personally, but Entergy has been required to sue the federal government for failing to fulfill its obligation.
that So, the only answer I can give you is I know there were some representatives of some federal Congressmen here tonight - -
it is to talk to them about when the federal government is going to fulfill its obligation to remove spent nuclear fuel from the Pilgrim site as well as the other sites in the U.S.
MR. KLUKAN:
All right.
So, it's 8:47.
We're scheduled to go to 9:00 p.m.
Is there anyone who would like, who has not yet spoken who would like to make any additional comments before we close this out?
(No response.)
Going once, going twice.
All right.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 125 Before I turn it over to Bruce to close out the meeting, I would just like to thank all of you for attending, personally from the facilitators, and to say, out on the registration table there are feedback forms.
Donna and I would greatly appreciate you filling those out.
We use your feedback in trying to make these meetings better in terms of ublic process. So, please take a couple of minutes to do so.
And with that, I 1 11 turn it over to Bruce.
Thank you.
MR. WATSON:
Well, the first thing I want to thank you for is coming out tonight.
I know this is an important issue to many of you.
Your comments will inform the staff on the NRC' s review of the PSDAR.
I heard some very good comments for our consideration.
And then, when we. look at the license transfer request and the application and its PSDAR, those comments can also be taken into account there.
As a reminder, you could provide written comments, I believe it's through March 21st.
We will be publishing The Federal Register notice on the license transfer when the rest of the federal (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 11 12 13 14 15 16 17 18 126 government goes back to work.
The comment period, again, is going to be 30 days for that and 20 days for hearings.
So, you' re hearing about it early before the notice is published.
So, we look forward to your comments.
- Again, I
want to thank you for your comments and questions.
We will be, at least I will e, and a couple of the other NRC will be, at the Nuclear Decommissioning Citizens dvisory Panel tomorrow evening.
So, I'm sure we'll be having some more discussions on the topic.
So, with
- that, I
would thank our anelists and our presenters for their presentations and in answering questions where we could.
With that, I would adjourn the meeting.
Thank you very much.
adjourned.)
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