ML20057E187
| ML20057E187 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 08/04/1993 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML20057E183 | List: |
| References | |
| NUDOCS 9310080067 | |
| Download: ML20057E187 (61) | |
Text
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OFFICIALTRANSCRIPT OF PROCEEDINGS l
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Agency:
Nuclear Regulatory Cornuission Telephone Conference with the Ylde:
Nuclear Regulatory Conunission and the Ci.tizen's Awareness Network to Hear Their Concerns i
. Docket No.
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1 IQCA210N:
Rockville, Maryland l
l DC:
Wednesday, August 4,.'io?
1 - 61 t
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ANN RILEY& ASSOCIATES, LTD.
1612 KSt.N.W,Suke 300 I
Mahington, D.C 20006
.(202) 295-3950 93100B0067 930927 i
PDR-ADOCK 05000029 T
PDR.
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1 TELEPHONE CONFERENCE WITH l
2 THE NUCLEAR REGULATORY COMMISSION l
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AND THE CITIZENS AWARENESS NETWORK l
4 TO HEAR THEIR CONCERNS l
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Wednesday, August 4, 1993 7
8 U.S. Nuclear Regulatory Commission 9
One White Flint North 10 Rockville, Maryland 11 The above-entitled conference commenced at 2:00 l
12 p.m.
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14 15 t
16 17 1B 19 20 21 22 23 1
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1 25 ANN RILEY & ASSOCIATES, LTD.
Court Reporters 1612 K Street, N.W.,
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PARTICIPANTS:
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NRC Attendees:
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Richard Dudley, NRRD Commissioning Section Chief 4
Morton Fairtile, Yankee Rowe Project Manager 5
Robert Wood, Office of Nuclear Reactor Regulation 6
Ed Reis, Office of General Counsel 7
Richard Emch, Radiation Protection Branch, Office i
8 of Nuclear Reactor Regulation 9
Shlomo S. Yaniv, Office of Research t
10 Jack Barrett, Office of Nuclear Material Safety 11 and Safeguard, Decommissioning Section l
12 NRC Region I Attendees:
13 Tom Shedlosky, NRC Section Chief l
14 Marie Miller State Liaison Officer 15 Joseph Nick, Regional Health Physics Inspector 16 Assigned to Yankee Rowe 17 Paul Harris, Yankee Rowe Inspector 18 Citizens Awareness Network Attendees:
19 Fred Katz 20 Debbie Katz, Health Coordinator 21 Jean Ferris 22 Nuclear Information and Resource Service Attendees:
23 Paul Gunter 24 25
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7.NN RILEY & ASSOCIATES, LTD.
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1 PROCEEDINGS 2
[2 :00 p.m.]
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MR. FAIRTILE:
Good afternoon.
I would like to 4
say is if you want to jump in after they finish, that is 5
fine, but do give your last name.
Now, I want everyone to 6
introduce themselves.
And we'll start here in Rockville.
7 Mr. Wood.
l 8
MR. WOOD:
Yes.
I am Robert Wood.
I am in the l
9 Office of Nuclear Reactor Regulation.
I handle financial j
10 matters that come before the Commission.
]
1 11 MR. REIS:
I am Ed Reis in the Office of General 12 Counsel.
13 MR. EMCH:
I am Richard Emch.
I'm in the 14 Radiation Protection Branch in'the Office of Nuclear Reactor 15 Regulation.
16 DR. YANIV:
I am Dr. Yaniv.
I am with the Office 17 of Research, and I deal with radiation health effects.
18 MR. BARRETT:
I am Jack Barrett.
And I am in the 19 Office of Nuclear Material Safety and Safeguard, 20 Decommissioning Section.
21 MR. DUDLEY:
I am Richard Dudley.
I am the NRRD 22 Commissioning Section Chief.
23 MR. FAIRTILE:
I am Mark Fairtile, the Yankee Rowe 1
24 Project Manager.
And I also want to put Mr. Thompson on, he 25 is the court reporter, so you will know his voice.
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L, 1
THE REPORTER:
My name is Cliff-Thompson, and I l
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will be recording today's session.
Can you hear me all 3
right?
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4 MS. KATZ:
Yes.
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5 MR. FAIRTILE:
Next, I'd like to have introduced 6
the NRC people in Region I that are on the line.
)
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MR. SHEDLOSKY:
Good afternoon.
This is. Tom 1
8 Shedlosky, I am acting for Jean Kelly,_NRC Section Chief for:
9 the Yankee Rowe Plant.
]
10 MS. MILLER:
My name is Marie Miller, I am 11 Regional State Liaison in Region I.
i 12 THE REPORTER:
You'll have to say your name again.
1 i
13 I couldn't hear you.
i 14 MR. FAIRTILE:
Marie', do you want to repeat your l
l 15 name, please?
16 THE REPORTER:
Slowly, please.
~
17 MS. MILLER:
Marie Miller, M-i-1-1-e-r.
i 18 THE REPORTER:
Okay.
j l
19 MS. MILLER:
State Liaison. Officer.
.]
20 MR. FAIRTILE:
Joe.are you on?
21 MR. NICK:
Yes.
Joseph Nick, N-i-c-k.
I am the 22 Regional Health Physics Inspector' assigned to Yankee Rowe.
23
.MR.
FAIRTILE:
Paul,'are_you on the line?
24 All right, there may.be another NRC person comeL 25 on, Paul Harris, who is the inspector for Yankee Rowe.
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1 Apparently, he has not signed in yet.
2 All right.
Could the C.A.N and C.A.N.-affiliated-3 people, please introduce themselves.
4 MR. KATZ:
I am with the C.A.N. group, Katz, Fred.
5 Greetings to you all.
Welcome to this meeting.
6 THE REPORTER:
I'm sorry.
You were cutting out.
1 7
Would you repeat that slowly?
8 MR. KATZ:
My name is Katz.
Fred Kata, from the j
9 C.A.N. group, the Citizens Awareness Network.
i 10 MR. FAIRTILE:
Okay.
11 MS. KATZ:
My name is Debbie Katz.
I am with 1
12 Citizens Awareness Network.
I am the health coordinator.
13 THE REPORTER:
Is the last name K-a-t-z?
14 MR. KATZ:
Yes.
15 MR. FAIRTILE:
Okay.
Next.
16 MS. FERRIS:
My name is Jean Ferris.
I am the
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17 parent of a seven-year old child with Down's syndrome.
And i
18 I am a member of the health committee of'C.A.N.
19 THE REPORTER:
Jean, would you spell your last 20 name, please?
l 21 MS. FERRIS:
F-e-r-r-i-s.
22 MR. FAIRTILE:
Okay.
Thank you.
23 MR. GUNTER:
My name is Paul Gunter.
I am with 24 Nuclear Information and Resource Service in Washington, D.C.
25 And I am being plugged into this conference call through.
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Mississippi right now.
2 MR. FAIRTILE:
Thank you, Paul.
3 Anyone else?
Okay.
Let's get started then.
4 MR. FAIRTILE:
All right.
Ladies;and gentlemen, l
5 the purpose of this conference call, first of all, it was'at' l
6 the request of the Citizens Awareness Network, in order for i
l 7
the NRC to hear concerns that they haveLregarding the B
component removal program at the Yankee Nuclear Power 9
Station.
10 And these are concerns that have arisen since'we 11 had our June.9th meeting at the high school near Rowe.-
So,-
j 12 I would like to turn this over to whoever wants to actras l
13 spokesman for C.A.N.
Please.say your name each' time until 14 we get accustomed to it.
Remember that,, preference all your.
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15 remarks with your last name.
l 16 MR. KATZ:
This is Katz.
I wanted to preference j
i 17 this presentation with a few comments which-I think may or j
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18 may not be rel*3vant or even important.
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19 But, I think, I would like to say that we don't 20 want this meeting to be construed as satisfy' [ telephone 21 interference). and it was for a publicLadjudicatory hearing, 22 Also,.that the meeting seems to have come out'from.
23 questions that I brought to Mark Fairtile, and whether in j
J 24 fact-the meeting is due to ourJrequest or the NRC's. requests R25 may or may not be important.
And-I'm not.certain as to
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I whether it is due to our request. -But it may not.be 2
important.
3 We still demand an adjudicatory public hearing, L'
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4 and we still welcome this meeting.
So I'will attempt now to 5
begin.
i 6
Atomic power is inherently dangerous, and because i
7 of this, an elaborate system of controls and regulations 8
have-evolved.
Various stages,in reactor status are defined 9
in detail such as the possession only license, or operat'ing i
i 10 license,.or a decommissioning license, orLin fact, a i
11 decommissioning' option; all of which require licensing.with; j
i 12 each stage having. specific definitions and requirements:
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13 hearing rights of citizens, rights of' access to information,,
j 14 et cetera.
- 1 15 What we see here at the Yankee Atomic Electric l
1 16 Company. site at Rowe, is that the utility is proceeding in a i
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17 component removal project which will mobilize and transport
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18 90 percent of the non-fuel residual activity existing there 5
19 between July and October of this year, before a l
20 decommissioning plan has been submitted.
21 Since the potential risk lies in the radioactivity
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22 of the materials to be handled,.what we are looking at is.90 23 percent of the task of decommissioning, including the 24 problematic elements in'the short-lived cobalt and cesium 25 removal' accomplished without the' safety. factor of the ANN RILEY & ASSOCIATES, LTD.
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elaborate system of controls and regulations engaged.
And
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2 though all the hearing process is scheduled to begin after l
3 the component removal project is a fait accompli.
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4 For the purpose of expediting the component 5
removal process, the NRC has. assented in a process of I
6 disengaging these processes from their regulatory.
7 requirements by making specific definitions, licensing i
8 stages, controls unclear.
9 This very speedyLprocess is inconsistent with the
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4 10 ALARA principle, since, for instance, the occupational ~
11 radiation dose for additional chemica1' decontamination is i
I 12 relatively small, compared to.the dose _ associated with 13 installing temporary: shielding.
14 Thus,'the licensee is granted exemptions to 15 requirements that are permitted ~under the possession-only 16 license status, access to decommissioning _ funds, and l
17 legitimate decommissioning status appropriate'to be J
18 legitimate decommissioning status.
They areLgranted t
i 19 permission to remove components under a licensing to.
20 operate.
21 The ability to define decommissioning. alternatives 22 is granted, dependent upon the short-term financial climate-23 of the utility.
Thus, decontamination for the component 24 removal is defined as maintenance, which will then switch to 25 safe store for-an unspecified period, which will-be ANN RILEY & ASSOCIATES, LTD.
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determined by the opportunity to dispose of wastes.
2 Presumably, it will switch back to decom.
3 For the electric company to proceed in this 4
experimental regulatory climate, is an unreviewed safety-5 issue as it circumvents scientific, citizen, and state 6
agency oversight; hearing rights of citizens, which, in 7
fact, if there were hearings, would permit the possibility 8
of such a review.
9 We, therefore, demand that the NRC halt this 10 process until this process is subjected to an evidentiary j,.[
11 hearing process, and the submission of.a detailed plan which 12 would make possible comment on its safety. issues available.
13 Now, we are also today going to bring up health c:
l 14 issues.
The component removal project, whether it is to be i
l 15 regarded as an operating procedure, or as reactor 16 maintenance, or legitimate decommissioning, is permitted as 17 having satisfied the NRC's assessment of Yankee Atomic 18 Electric Company's environmental report in 1987 that the i
i 19 reactor had operated for more than 27 years with no j
l 20 significant environmental impact.
i It is based on an environmental report which had 21 22 addressed all important aspects of operation.
Since'there L '; h 1s; 23 has never been an epidemiological health study of the c.
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24 impacted population in proximity to the reactor, and along 25 side the effluent pathway, there can be no basis for an I
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environmental. report or a review of such a report.
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2 The assessment by the NRC granting license to 3
continue operation back in 1988, or to make any review f
4 allowing the licensee to engage in the component removal 5
project, or in fact, to grant the utility an opportunity to a
6 utilize decommissioning funds, which also requires an 7
environmental report, and a review of such a report, 8
presents a situation in which these processes are being 1
9 allowed to proceed with no basis for an environmental 10 report.
j 11 The assessment by the NRC granting license to' 12 continue operation, or any review of. allowing the licensee 1
i 13 to engage, is therefore'quite. unfounded.
14 We, therefore, ask that the NRC order the licensee v'
i 15 to cease in the component removal project until such time-as 16 a scientific basis for an environmental-report is 17 established, and the NRC staff can complete an effective 18 review.
19 At this time, our group, the C.A.N. group, along 20 with other interested citizens, under the direction of.Dr.
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' Sidney Cobb, and in cooperation with the Massachusetts 22 Department of Public Health, have assembled statistics-which 23 are quite -- which give evidence that are quite in contrary 24 to any assessment that' Yankee Atomic has been operating
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'without any significant environmental impact.
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1 And, in fact, we protest the granting of the f
2 licensee's ability to utilize decommissioning funds under
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3 that same environmental report which declares that it-has no j
4 environmental impact, is incompetent, as.it is unreviewable,-
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as there exists no data or study which can be reviewed.
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6 Now, at this point, Debbie Katz will' continue'with i
7 this presentation.
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MS. KATZ:
Unless there are any questions.
Do you 9
want to --
10 MR. KATZ:
Well, I thought.thatlwhat we could do j
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12 MS. KATZ:
-- just go. ahead?.
j 13 MR. FAIRTILE:
Remember, give:your: names.
l 14 MR. KATZ:
-- is that present'our. materials and i
i 15 operate under the assumption that'the staff that is I
i 16 assembled hearing this is there for the purpose of 1
i 17 clarifying our concerns through.their' questioning, which can
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18 take place after Debbie Katz presents'this' material.
19 MS. KATZ:
Okay.- Katz, Debbie.
I just-wanted to 20 read something into the record that we had.sent to Mr.
21 Fairtile in terms of our needs for the - E we sent 22 information in.
I 23 Enclosed is information relative to our' meeting on 24 August 4th.
They help to provide the grounds of. material 1
25-for our concerns.
We, expect that these documents will be.
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Court Reporters 1612 K Street, N.W.,-Suite 300 Washington, D.C.
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1 included in the transcript sent to the PDR.
In addition, we 2
want the bibliography to be an open file which can receive 3
additional scientific data as it becomes available.
1 4
MR. FAIRTILE:
Well, pardon me --
l 5
MS. KATZ:
The material presented may take more 1
6 than one meeting between Citizens Awareness Network and the i
7 NRC to complete.
We, therefore, want the opportunity to set 8
up subsequent meetings in the event that it is necessary.
9 We also have -- this is not in the letter --
l 10 additional information that we could not send in to you at i
i 11 that point, but there will be a letter from Dr. Knorr, who 12 is the Deputy Director of the Environmental Health j
13 Assessment Unit of the Massachusetts Department of Health.
14 And we have been in 'a preliminary investigation 15 with Dr. Knorr for about a year and a half about the health 16 concerns that we have around Rowe.
There will also be a 17 statement from Harvard environmental graduate school in l
18 terms of a meteorological review that they did for us.
19 And also a review by Shearson Lehman of the issues 20 of decommissioning and what they feel should be done in 21 terms of nuclear power stations.
22 I am a little nervous, so please give me -- I may 23 stumble a little.
24 The issues of health around Rowe are of deep 25 concern to us.
So we feel that there are a number of things ANN RILEY & ASSOCIATES, LTD.
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that are important in terms of the Rowe reactor.
And I will 2
just state them first, and then I will go back to attempt to 3
go into detail.
4 One is, we want the NRC to fund an effluent L/
5 pathway study of the Rowe reactor, in which an independent 6
group of scientists would be set up to do the study.
We 7
feel that it is important in terms of understanding the i
8 environmental impact of this reactor to do that.
9 We feel, too, that in the reevaluation of the k
10 conceptual framework, is to determine the standard set for 11 the NRC, has to take place in terms of dose response l
12 assumptions, in terms of issues such as organ dose, and l
t 13 reevaluation of this concept in the light of Tritium, and l
l 14 the scientific research that has been going on.
l 15 We also feel there has to be a reevaluation of the f
i i
16 concept of radiation protection, and what that constitutes 17 given what they can place at Rowe.
18 We understand'that Rowe is an experiment, and that 19 in a certain way, we have been part of that experiment.
The l
20 use of a river for an effluent discharge, which has actually i
l 21 been used by probably 500,000 people a year to swim, boat, 22 and fish in, [ telephone interference) which has been used to 23 dump [ telephone interference] material in on a regular 24 basis.
25 I want to also raise the issues of worker health ANN RILEY & ASSOCIATES, LTD.
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and health studies, and the growing data that is coming out 2
in terms of workers' exposure, increases in cancer, and the 3
increases, also, of cancer to children of workers.
l 4
And I also want to raise the issue of prior P/'
l l
5 notification, that we feel that this has to become part of 6
any plan by the NRC to allow Yankee to do any work around 7
here, is prior notification of any effluent releases, 8
whether they are into the water, or into the air.
9 Prior notification of transport; prior V
10 notification of routes, so that we can make the choice to 11 protect ourselves.
We could not [ telephone interference]
l 12 enter into this experiment.
13 We were really ignorant of its potential when it 14 began.
But I feel we should be afforded [ telephone 15 interference] since we have suffered this assault 16 Now, I would like to go back over the issues of 17 our health concerns because they are very serious to us.
We 18 went to Dr. Cobb when, at the time Yankee was struggling 19 with the issue of [ telephone interference), because we were i
i 20 concerned about increases in health problems in this area; j
l 21 increases in sterility, miscarriage among people who lived 22 in a relatively pristine environment, who lived very healthy 1
23 lives, who seemed to have excessive amounts of disease.
I 24 And Dr. Cobb enabled us to get information on --or 25 how to go about getting information, some of which he has 2
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utilized in what I sent to you, and some of which we also 2
gathered from the PDR in terms of the releases into the 3
river by Yankee Atomic.
4 There were large Tritium releases into the 5
Deerfield River, always within the accepted standards of the 7
6 NRC, but large amounts into a small river, that was used for 7
recreational purposes in the 1960s and 1970s.
8 We did not have any statistics before 1965, 9
because Tritium was not clocked before that time.
But we 10 know after 1965 into the 1970s, they were having problems 11 with their fuel rods, and relatively large amounts of 12 tritium went into that water.
13 There was an EPA study that was done -- we can k'
14 send you a copy of that as wel'1, if you would like_-- that 15 showed amounts of tritium in the water that was-a concern to 16 them, and they asked that a study be done.
And a study was 17 not done at that time.
i 18 Now, they changed the fuel rods.
Yankee improved 19 their ability not to put radioactive nuclides into the 20 water, but there were those releases, and tritium was 21 continued to be released into that river, until the time 22 Yankee closed.
i 23 Now, in terms of the increases of disease, we have i
i 24 had:
We have nine children born with Down's syndrome -- I'm 25 sorry, this always makes me upset --
between the 1980s and ANN RILEY & ASSOCIATES, LTD.
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the 1990s who basically lived in a three-mile radius of each 2
other.
3 We have potentially another seven children born in 4
the 1970s that we have not yet been able to gain information 5
on.
We have approximately five to six children conceived in 6
the 1980s to 1990s who were chromosomally damaged, non-7 hereditary, 8
Only one of these children was born and lives 9
within this radius.
These other families live within this i
10 radius basically.
l 11 There is statistical significance in Down's j
12 syndrome that there have been approximately -- and I want to 13 make it clear that this 2.5 mile radius is not filled with 1
14 shopping centers and large housing complexes.
This is a 15 small rural community with hardly anyone living in it.
i 16 Down's syndrome should occur between one and 700 per one in 17 1000 live births.
We have had approximately -- I don't have i
18 the exact figures -- 2,000 live births in the last 20 years.
19 This is a very serious concern to us.
l 20 Dr. Cobb has found a 50 percent increase in five I
I 21 different cancers.
He has found a 40 percent increase in 22 heart disease.
He has found a 110 percent increase in 23 infectious diseases leading to mortality -- certain 24 infectious disease, and a 70 percent increase in infectious
)
l 25 disease leading to mortality was found.
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17 1
These are very serious to us, and he in fact, 2
raises the issue that there is an epidemic of disease taking 3
place in that valley.
4 These children, or rather their parents -- the 5
parents of these Down's syndrome children, all lived near 6
the river, or had extensive contact during their pregnancies 7
and before their pregnancies.
8 We feel that we are part of an experiment that has 9
taken place, and that we have to be studied as such.
The 10 Massachusetts Department of Health has been involved in-a 11 preliminary investigation ~with us, in which they in fact 12 found statistical significance in certain cancers in this 13 region.
~
14 We are a small community.
I will say that again.
15 We should not even have statistical significance.
There-16 were five -- there was statistical significance in five 17 different cancers in Greenfield.
18 We do not have large industry.
We should have 19
[ telephone interference) up here, and we don't.
The 20 Massachusetts Department of Health has in fact made a 21 commitment to attempt to get funding to investigate these 22 issues.
23 But we are still left with these issues to deal 24 with.
And we feel that it is incumbent upon, in some ways, 25 Yankee Atomic and the NRC, to help us to understand what ANN RILEY & ASSOCIATES, LTD.
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part radiation may have played in this health hazard we are 2
living.
3 Let's continue.
4 Now, one of the issues that we have and that -- I 5
read at the beginning, was the reevaluation the conceptual 6
framework used to determine the standards set by the NRC.
7 one of our concerns is the issue of [ telephone interference]
8 which has gone into this river, and lot of the scientific --
9 I wanted to go back a second, because I realize I want to go 10 back over the issues of [ telephone interference] because 11 there are number of studies that, in fact, link the issue of 12 cancer.
13 There is [ telephone interference] ; there is Roman 14 and Steve Wing, which I will g'o into in terms of nuclear 15 workers, had workers exposed -- found workers exposed to --
16 100 millirads [ telephone interference] life-time doses.
And 17 they had a 63 percent increase in risk of leukemia, and a 33 18 percent risk in terme of other cancers.
19 There have been a number of studies in terms of 20 Down's syndrome which have linked exposure to X-rays and 21 Down's syndrome.
The [ telephone interference] itself, has 22 said that there is no threshold for exposure to radiation 23 and Down's syndrome.
24 There have been background studies that were done, 25 which the background is approximately 400 millirads, and i
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19 1
that there were large increases in Down's syndrome and other 1
2 birth defects [ telephone interference] has also found 3
background radiation exposures, and increases in birth 4
defects and Down's syndrome.
5 There is epidemiological matter which demonstrates 6
the correlation between Down's syndrome and radiation.
7 There have also been studies, broad studies, that links 8
radiation exposure to X-rays and heart disease.
l 9
There are many, studies that'are beginning to raise 10 the issue of radiation exposure, low-dose radiation exposure 1
11 and cancer.
i 12 Goodhead, and there are other' scientists who say-13 there may be no threshold below which radiation -- let'me l
l 14 try to say that again.
15 The issue that Goodhead has raised is that the 16 body may be able to ascertain that it is being affected by 17 radiation at higher doses, but not at lower doses, that in 18 fact, low-dose radiation may not set off an alarm to the i
19 repair system in the body to repair within the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> that l
20 it needs to do, the lesions that are created by exposure to 21 low-level radiation, and that you can be exposed to a gray 22 field of very low-level radiation without knowing it -- the 23 body knowing it -- and in fact, it potentially causes l
l 24 cancer.
i l
25 And I think these issues, which could not be seen j
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when nuclear power started, or ten years ago. or 20 years 2
ago, can only be seen as Steven Wing has shown, at 25 years 3
and up, when the health effects begin to be seen.
4 I mean, there was work done by Betastock with the 5
illuminizer dial workers which, in a certain way is a low-i 6
dose study, because women were exposed to very low doses I
7 every day, and should have been able to repair -- their 8
bodies should have been able to repair the effects of the 9
radiation, and yet were not, and there was statistical 10 significance in terms of cancer, breast cancer, to these 11 women.
12 There are many studies -- they are in fact in the 13 bibliography, and there are many more -- in terms of the 14 issues of low-dose radiation. -
15 And I think it is incumbent upon the NRC to begin 16 to look at this issue at this point.
And this is not a new 17 issue that has been raised to the NRC.
But I think in light 18 of the tragedy that is taking place around Rowe, that it is
[
19 incumbent upon you to do so.
20 And it has been your responsibility to protect us.
- 21 And I think we have been left unprotected, not because 22 anyone has wanted to, but because nobody knew, or had the 23 scientific evidence to justify it.
And I think the 24 scientific evidence is beginning to accumulate.
25 And what I'd like to do is talk a little about ANN RILEY & ASSOCIATES, LTD.
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21 1
tritium and the issues of tritium which were, in fact, not 1
2 well understood, because, as I have seen in the literature, 3
that tritium was, in fact, seen as a relatively benign 4
radionuclide, that it passed through everything, and you 5
didn't have to worry about it.
6 And this view has really been changing with the 7
research that has been done, especially around Rowe, with a i
8 pressurized reactor vessel.
And what is released into the 9
water from a pressurized reactor vessel,. is large amounts of 10 tritium.
11 And so the issue of tritium, I think, is a very 12 important issue to look at.
Not just in terms of Rowe, but 13 in terms of all reactors; in terms of the health effects; 14 and the underestimation of those health effects.
i 15 The Lawrence Livermore Laboratories did a study of 16 the health effects in exposure to tritium in 1991, in which 17 they found that the effects were underestimated in terms of 18 carcinogenic effects by one and a half times; that it was 19 underestimated two to five times in terms of mutagenic 20 effects; and that it was underestimated two times in terms 21 of tetragenic effects.
22 This has very serious ramifications on people who 23 have been exposed to tritium, especially in a situation such 24 as that river where we swam, boated and fished, and had 25 wells along that river.
1 1
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There was a school that got its well water right 2
by that river.
It still does.
This is a deep concern, and 3
the inadequacy of the standards that have been set gravely 4
affect us.
5 I mean, one of the issues that comes up in terms 6
of the issue of tritium -- there are two issues.
One is 7
that the whole conceptual framework of organ dose cannot 8
work for tritium, because tritium does not affect an organ, 9
it affects the cell.
10 And if you don't do microdose symmetry in terms 11 of understanding what tritium is doing, then you miss it 12 completely.
And that if tritium affects a cermatic cell, 13 that you will have carcinogenic effects, and if it affects a 14 fetus, then you will have mutagenic effects, and if it 15 affects a germ cell, then you will have tetragenic effects.
16 And this has not been looked at.
And there is 17 growing evidence in terms of tritium from many, many 18 sources.
I sent you a selection of that, but there are many 19 more in terms of it in terms of the genetic effects from 20 exposure, much of it is in terms of mice, but there are also 21 studies.
22 The study around the Pinkering Reactor in Canada 23 is.a study of tritium.
That's what was released.
And they 24 didn't find a direct correlation.
25 The Canadian Government -- didn't find one, but I
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1 Lambert and McArthur raise issues in terms.of:it.
And in i
l 2
fact, there was an 86 percent increase of Down's syndrome.
f 3
around that reactor.
t i
4 The work of' Patricia Sheehan at the: Girls School-
- i 5
in England in which the girls at that school were radiated 6
during a fire at a reprocessing plant across the_ Irish Sea, l
7 what was released from that reprocessing plant was-tritium..
i 8
And there was -- of the.120 women in that school, l
9 50 of them participated ~in the study,.the others didn't.
Of
{
l 10 the ones that didn't, two of those women had Down's syndrome i
11 children.
I j
12 Of the women who participated, only 30.had gotten-1 l
13 married and had children.
Of-that, there were six Down's l
14 syndrome children.
There.were, in all, 30 birth
(
15 abnormalities including six sterile women.
l 16 These issues are of great concern, and the issues j
17 in Gardner's work in England in terms of' exposure of workers 18 is in terms of tritium.
And I think it really has.to be.
19 looked at and that the issue of protecting.us has to be done l
20 in terms of reevaluating the way.we look at it.
21 One of the issues that is coming up in terms of-22 tritium, is also that it has an effect that is similar to 23 soft X-rays..And they have'found that soft X-rays, in fact, 24 have a much greater impact.on humans, than regular X-rays.
25 And there is the issue with tritium, not just in ANN RILEY & ASSOCIATES, LTD.
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24 1
terms of its radiational effect.
There are two other issues 2
which --
one is this organically-bound tritium, that in the 3
process of taking tritium, and if it is taken -- if you take l
4 it in a drinking water, in tritiated water -- it leaves the 5
body in approximately 12 days.
6 But once it unites with carbon, which it does if 7
it's on vegetation, if it goes into fish, if it goes into i
8 animals, if it even goes into-the human' body, it stays in
)
9 the body for at least 450 to 650 days, and it actually is 10 taken up in the cell, in the protein precursors, in 11 different ways of those, and it then has a transformational 12 effect in which a chemical change takes place, which~is also 13 mutagenic, so that it has more of an impact just'than in 14 terms of its radiational effect, but also in terms of its 15 transmutational effect.
I 16 And none of this has been looked into.
And I i
17 understand that in some way that it couldn't be looked into.
18 But, you know, one of the issues around the Rowe reactor is i
19 that there is farm land ~along there; there are cattle being 20 raised along there; that people have gardens along there; 21 that people have eaten food that has been contaminated with 22 organically-bound tritium.
l 23 There is some kind of nuclear reactor in Arizona 24 in which people were dosed with amounts of tritium, and 25 there was a school across the street from the place, and it l
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25 literally got into the food stuff.
It was incorporated into 1
2 the bread, that sat outside the school, because of the 3
process of evaporation.
4 Well, in the work that we had Dr. Spangler do at i
5 Harvard, there isn't even yet an understanding of the 6
effects of air soliziation or evaporation in terms of what 7
takes place.
8 But they found that there was 1,000 times more 9
concentration of tritium along that effluent pathway in the 10 river than anywhere else, that also in terms of that 11 effluent pathway, there are air inversions 30 percent of the 12 time, so that the air along that river is locked in there 13 under massive banks of clouds and moisture in which the 14 tritium was locked in there ef'fectively.
15 So I really feel-that a reevaluation of the whole 16 conceptual framework of tritium and it effects people is
)
17 incumbent of the NRC to do, for any kind of radiation 18 protection to take place or for any kind of environmental 19 report to take place.
20 And a whole different conceptual framework of 21 where effluent is dumped, has to take place.
There was some 22 kind of idea that the Deerfield River wasn't used, and this 23 was a complete misconception, since it's used.
Even in 24 drought, they suck up water from the river to spray crops 25 with.
But we were spraying our crops with tritiated water.
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This is terrifying to us.
i 2
Now I would like to also turn to the issue of 3
worker health in this.
Because I think that's very 4
important, because the issue of this early component removal 5
is also of the workers being exposed to larger amounts of 6
radiation than need be.
And I think that this is really 1
7 important in terms of the -- and -- just one second.
l 8
I mean, one of our concerns in terms of the issue l
l 9
of the prior notification is that we are not put in a 10 position again where there are -- there is tritium -- there 11 is chemicals or anything else dumped in that river, and we l
12 are ingesting it, and we don't know it.
13 Even at the NRC meeting, there was a disclosure 14 that there was releases into the river at the point that 15 none of us thought anything was going on anymore, and people 16 were still swimming in that water.
i 17 And since there is this whole question of 18 evaluation that has to take place of how much tritium, or 19 how much low-dose radiation affects us, then it's really l
20 important 'or us to know what's taking place, and the issue l
21 of fishing as well in terms of it.
That river is used for 22 fishing.
And the fishermen don't know that they've been 23 tritiated.
24 In the situation in Arizona, they were finding 2S that workers, the remains of tritium in their bodies for ten ANN RILEY & ASSOCIATES, LTD.
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years.
Ten years, that's a long time.
]
2 Now I want to go into the issue -- I want to just 1
3 into the issue of worker health, because there are studies 4
that raise the whole issue of workers being exposed to l
5 radiation and the problems in terms of it.
j 6
Because there have been a number of studies that i
7 really raise the fact that workers who have been. exposed to 1
l 8
low doses of radiation, that in fact, their children have 9
increased risk of leukemia and cancer.
1r And these are studies by Shorehan,-Roman.
11 Gardener has c ne a lot of work with this around --
l l
12 Shellyfield -- in which there were increases of leukemia and 13 lymphoma in children in that area.
i 14 There were also, the issues -- that Forman found 15 the increases of cancer near a nuclear installation, 16 especially around Shellyfield, and in certain areas in 17 Ireland.
18 Steven Wing, as I mentioned in doing a study of i
l 19 Oakridge workers, found workers who had been exposed to 140 i
20 millirads life-time doses, had a 63 percent increase in risk 21 of leukemia after 25 years.
22 It's only after 25 years that these effects began 23 to be seen.
The Neal information that is now coming up l
24 around Hanford in the sensitivity of workers who are older, 25 to low doses of radiation, and. check { telephone l
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i 28 1
interference) work 2n which most workers were exposed to two 2
rems of radiation -- life-time doses in which they had, I i
3 think it was, increases in thyroid cancer and statistical t
4 significance in leukemia.
5 There have also been studies by Sever arcu ad the 6
Hanford area, in exposures to low-level radiation and 7
congenital malformations, and Ste:rn did a study arouni' the 8
Plymouth Shipyard workers who had a 40 percent increase in-I 9
leukemia, having been exposed to under, I think it was, it 10 may have been two rems or four rems of radiation.
11 Now, these are small amounts of radiation.
But j
12 there are studies around nuclear weapons tests, and there is i
13 also studies that check the background radiation that come 14 up as well in terms of X-rays and storage work finding that 15 fetuses exposed to X-rays had a 50 percent increase in 16 cancer and McManus, and that there have been many studies --
17 or there are studies coming up.
18 I understand there are a lot of studies that show 19 the opposite.
But this is something that is coming up.
And 20 given the issues of low-dose radiation and, specifically, of l
21 tritium that are coming up, it is very important that it be 22 looked at in terms of -- so that I think the issue of 23 allowing theea workers to be exposed to a hot reactor is 24 unconscionable.
25 It is unnecessary to have that happen at this l
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point.
And the reason it's happening is because Yankee-2 Atomic wants to get things out really fast, and they feel it 3
is cheap and expeditious to do it this way.
4 But they don't have concern for the workers who 5
are being exposed.
And they don't have concern for the 6
lives of the community who may be exposed.
I-understand 7
that in decommissioning, the major issue of exposure is in 8
terms of workers.
9 But I don't want to see them exposed to any more 10 radiation than is necessary.
And it's incumbent on the NRC 11 to set standards in terms of it.
12 Now, I liked to raise the issue of prior 13 notification, because I think that's really.important, 14 because, in a certain sense, we feel we've really been 15 assaulted by all of this, you know, in a way, in which we 16 never gave our consent.
17 And that may have come through our ignorance and 18 stupidity of not really knowing the effects, and I think 19 part of it is also, for us as well as for you, that the 20 effects were not known, that Rowe was an experiment.
21 And in a certain way, it's still an experiment.
22 And it's now in a decommissioning experiment.
And we don't 23 want to be a party to that experiment unless we have some i
24 voice in it; unless we can protect ourselves in some way, i
25 from the issues of radiation; and to make choices that we l
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4 F
l i
i 30 j
i
-)
1 weren't given during this process, that we are now in an l
2 epidemic of disease possibly over.
l
)
~
3 We don't want that that to happen again.
And so 4
it's very important to us.that prior notification be given 5
to us, and to people in this area, so they could now make' 6
the choice about whether they want to swim in a' river that 7
had radionuclides in it; whether they want to expose their l
8 children, who are, as we know,umuch more sensitive to the
!a i
9 effects of radiation.
10 And seme of these exposures.to background I
11 radiation which had increases in cancer to children were of'
.l 12 20 millirems; 20 millirads background exposure created these f
13 increases.
f I
14 And I don't.think it's worth the risk to us.
I I
15 would like the NRC to be-extremely conservative;for a. change 16 in what they allow.
And I think prior notification is part 17 of that conservatism.
i 18 And your responsibility to the community,'.not just 19 to the reactor, that we know of releases,.whether to the air 20 or to the water; that we know of sectioning and cutting and 21 whatever they're going to do in'their dismantlement; that we 22 know the route so that we can make a choice not'to.be there; 23 that we know the times of transportation, so we can make the 24 choice not to be there.
These are very, very important 25 concerns to us.
And we want them_to be important to you.
1 ANN RILEY & ASSOCIATES, LTD.
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i 1
We realize that up until now, you may not have had the.
]
2 awareness, in certain ways, because of the lack of evidence,.
3 to protect us.
]
j l
i 4
But given the-body of evidence'that is beginning 5
to grow upon us, at this point, we feel it is your i
L i
6 responsibility to' investigate this, and to take a much l
l 7
stronger stance to protect us.
i 8
And I realize that as I'm saying1this, you're-9 taking less of stance to protect anyone.
And it really'.
10' outrages me.
I have two young children.
l
~
l 11 I live five miles from that. reactor.
And1I'm-12 really concerned, not just for their welfare, but for the
'i 13 welfare of all the children in this. area who may develop.
f
~
14 higher rates of. cancer, or who may have~ children with birth 15 defects.
16 Because, of course, the issues of tritium are l
i 17 really cumulative, so it can show up -- not in our j
18 generation, we can be asymptomatic -- but in.the next l
1 19 generation, and the generation after that.
20 And I would like you to take these issues,~and.our 21 concerns seriously.
And I really demand an answer to them.
i i
22 MR. DUDLEY:
Thank you.
Debbie, this is Richard l
23 Dudley of the NRC.
I would like to try to summarize your.
J 24 concerns into a number of issues, if I could.
25 But before I do that, I would like to start with a ANN-RILEY & ASSOCIATES, LTD.
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question.
When you began, you referred to,.I believe, a l
2 letter, or information, that you said you had submitted to 3
the NRC regarding health effects at Yankee.
l l
4 MS. KATZ:
Yes.
5 MR. DUDLEY:
I am not aware of that reference, or 6
we are not aware of having received that.
Can you elaborate l
7 on to whom you submitted it, and what was in it --
8 MS. KATZ:
Right.
9 MR. DUDLEY:
-- when that submittal was made?
10 MS. KATZ:
We sent it out to you on, I think, it 11 was Monday or Tuesday, overnight mail, so that you would 12 have it before the meeting -- that was our hope -- to Morton 13 Fairtile.
l l
14 MR. FAIRTILE:
Okay.' This is Fairtile.
It hasn't l
15 hit my mailbox yet, but it may be there now.
Thank you.
16 MS. KATZ:
And what was in it is Dr. Cobb's 17 analysis, his rough analysis.
It also has the bibliography.
i 18 I'm sorry you don't have this ir. formation.
19 MR. FAIRTILE:
This is Fairtile.
We will have it, 20 Debbie.
It's probably, as I said, in my mailbox, and I'll 21 have it today or tomorrow.
22 MS. KATZ:
Okay.
23 MR. DUDLEY:
Debbie, this is Richard Dudley.
24 Would it be fair to say that the information you submitted 25 to us in this overnight package, when we receive it, would ANN RILEY & ASSOCIATES, LTD.
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represent a written documentation of the health concerns 2
that you discussed with us just now in the general sense?
i 3
Is that as a detailed assessment of the concerns that you 4
have described to us today in a general sense, is that 5
correct?
6 MS. KATZ:
It is.
Although, that's why we wanted 7
-- I mentioned sending Dr. Knorr's letter and Dr. Spangler's 8
information as well, because [ telephone interference) and we i
9 couldn't get it into that packet, but it is coming to us, 10 and it can further give you an understanding.
11 MR. DUDLEY:
Okay.
This is Richard Dudley again.
l 12 So you will provide us Dr. Knorr and Dr. Spangler's 13 information.
i 14 MS. KATZ:
Yes, I will.
15 MR. DUDLEY:
Okay.
Fine.
I would like to then go 16 back and try to summarize the issues that you raised so that 17 we don't miss any of them.
18 MS. KATZ:
Debbie Katz.
Okay.
19 MR. DUDLEY:
Okay.
This is Richard Dudley.
You j
i 20 stated that you would like for the NRC to fund a i
i 21 radiological effluent pathway study in the area of the Rowe i
22 reactor.
23 MS. KATZ:.That is right.
It's very important 24 that it be an effluent pathway study.
What has been done 25 until now is basically concentric circle studies, which I
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t 34 l
-1 dilute the information needed to understand what has 2
happened to people in the effluent pathway.
.l 3
The issues are not generalized.
There are certain
~
4 people who get doses that are.much greater, and they fall-l 5
into this effluent pathway.
And there are people who get 6
much lower doses, and they should not be included, j
7 We feel that giving up this concentric ring system 8
is very important in understanding the effects of low-level 9
radiation, and the effects of any nuclear reactor or-i 10 reprocessing plant on the citizens living around it..
'~
{]l+)
11 MR. DUDLEY:
Your second' concern -- this is Dudley-12 again -- was that the NRC reevaluate the NRC radiation _ dose 13 and radiation dose protection standards.
1
~
14 MS. KATZ:
Yes.
Katz.
Especially in light of 15 tritium, that the focus is in light of. tritium, and the i
16 issue of microdose symmetry, that your' conceptual framework 17 will not pick up the issues of the_ effects.of. tritium which j
18 are cellular, rather than organ.
19 MR..DUDLEY:
So the reevaluation of NRC dose 20 standards would only be with respect to tritium.
l 21 MS. KATZ:
They should be for low-level radiation, 22 but specifically for tritium in terms of what has happened 23 to us around here.
24 MR. DUDLEY:
Okay.
25 MS. KATZ:
Major effluents-released from.that-ANN RILEY & ASSOCIATES, LTD.
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reactor and from pressurized reactor vessels into the water i
2 is tritium.
So our understanding of tritium is exceedingly i
3 important in determining what we have been exposed to, and 4
the conceptual framework for dealing with tritium is i
5 completely inadequate.
l 6
MR. DUDLEY:
Okay.
You.also cited a concern with 7
increases in cancer and various other illnesses that you i
1 8
feel that could be linked to effluence from the Yankee 9
facility.
3 10 My understanding is that the information that we i
i 11 shall be getting soon from you includes the additional
,[
1 12 information we would need to look at to' evaluate those 13 potential increases.
1 14 Is that a fair characterization of what I would 15 call your third issue?
16 MS. KATZ:
They would help.
They would help 17 evaluate those issues.
They're not all of it, because this 18 is rough data.
That's why an effluent pathway study needs 19 to be done, because we don't have the answers to it.
l 20 But we feel that it is incumbent that this study 1
21 be done to understand the effecte of tritium on the citizen i
22 population livang in an effluent pathway, or we may find out l
23 it has no effect, and we'll be all immensely relieved.
l 24 MR. DUDLEY:
I understand.
What I would call your I
V 25 fourth issue, then, will be the issue of prior notification, i
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and that you have requested the NRC to implement some sort 2
of prior notification of the pub 3ic before all releases of 3
liquid or airborne radionuclides,'and before all l
1 l
4 transportation of radioactive waste.
j 5
Is that a proper characterization of your concern i
6 and request?
7 MS. KATZ:
Also, I want the transport lines, so we 8
have a sense of where it's going to be going, so we can make 9
the choice there.
So it's in terms of that, as well in l
10 terms of the decommissioning process.
11 I just want to go back to three, because it's also 12 in terms of worker health.
[ Telephone interference] left 13 only, and the issues in some ways of ALARA, and the 14 exposures to workers unnecessarily to larger doses of I
l 15 radiation in terms of working on that hot reactor at this I
16 point, than need be if the reactor was into safe store l
17 for 50 or 60 years.
l l
18 MR. DUDLEY:
Okay.
And in that light, I'll say l
T";.
19 that your fifth concern was regarding the increase in 3/
s 20 occupational radiation exposure to workers at the Yankee 21 facility, caused by the licensee's early component removal 22 program.
l 23 MS. KATZ:
The concern we have, during the 24 process, that if Yankee continues to go in and out of safe 25 store, and is able to work on this hot reactor, because in l
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10 or 15 years, there isn't a very big difference -- or 2
seven years -- in terms'of how hot that reactor is.
3 In 50 years, there will be a big difference.
I 4
mean, that's one of the issues that was raised by Shearson 5
Lehman in their report, that they feel that reactors should 6
wait 50 to 60 years before they dismantle.
j i
7 MR. DUDLEY:
Well, have you submitted, or will you i
8 submit to us, the Shearson Lehman report that you are l
9 referring to?
I 10 MS. KATZ:
Yes, I will.
It's being sent to us.
i 11 MR. DUDLEY:
Okay.
Or, if you could give us~the 12 reference, it may be that we already have that report.
13 MS. KATZ:
Okay.
When I have it, we will send 14 that information on to you.
]
15 MR. DUDLEY:
Okay.
Fine.
So, do you think I have 16 summarized your five concerns accurately, or should I go 17 back and go over them again?
18 MS. KATZ:
I somehow think we should'go over it 19 again if it doesn't drive everyone crazy, because we added 20 to it.
21 MR. DUDLEY:
Okay.
This is Richard Dudley.
The 22 first issue that I have from you, Debbie, is that the NRC i
23 should fund an effluent pathway study'of releases from the 24 Rowe facility.
25 The second concern was that the NRC should ANN RILEY & ASSOCIATES, LTD.
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38 1
generically reevaluate NRC radiation protection or dose 2
standards for low-level exposure to low-level radiation, and 3
specifically considering the different. aspects of exposure 4
to tritium that you will providing us information on.
5 MS. KATZ:
Yes.
And the issue of microdose i
6 symmetry.
7 MR. DUDLEY:
I understand.
The third issue is l
8 that the NRC should look at the potential increases in 9
cancer and other health issues that may be caused by
{
10 releases from Yankee.
11 And this would be that we would evaluate data that i
l 12 you will be providing us and that we should get shortly via 13 courier.
14 The fourth issue tha't I have is the request for i
15 prior notification of the public for all effluents to be 16 released from Yankee, and all transport and the routes of 17 transport of all low-level radioactive waste from Yankee.
j 18 And the final issue was the concern about 19 increased exposure to -- occupational exposure to radiation
)
i 20
-- workers due to the early component removal program, 21 compared to removal of those components had they been left 22 in safe store for 30 or 40 years.
23 MS. KATZ:
Sixty.
j 24 MR. DUDLEY:
Sixty.
Okay.
l 25 MS. KATZ:
That's good.
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1 MS. FERRIS:
I'd like to speak.
Jean Ferris.
2 MR. DUDLEY:
Please go ahead.
3 MS. FERRIS:
The only thing that I wanted to add 4
to that was, in number three, in the third issue, I'd like 5
to just have it stated for the record that it would be to 6
study the ill health effects of high cancer rates, as well 7
as Down's syndrome and other chromosomal damage.
8 MS. KATZ:
Good, Jean.
Thank you for clarifying l
9 it.
10 MR. DUDLEY:
Yes.
Fine.
We have that.
11 MS. FERRIS:
Okay.
12 MR. DUDLEY:
The information that you will be 13 providing to us also includes the information on Down's 14 syndrome incidents, is that correct?
15 MS. KATZ:
Provides some of it.
We can provide 1
16 some more information.
The bibliography, in fact, has l
l 17 references to Down's syndrome, and.the letter from Dr.
18 Knorr, which I haven't received yet, should also have 19 information on that.
And you can also contact him, and Dr.
20 Cobb, for more information.
21 MR. DUDLEY:
Can you tell us when we might receive l
22 the additional information from those two doctors, and could 23 you also spell their names?
We would be guessing as to how 24 to spell their names.
25 MS. KATZ:
There's Sydney Cobb, C-o-b-b and it's l
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Dr. Robert Knorr,fK-n-o-r-r.
j
'l l-2 MR. DUDLEY:
Okay.
And when might we expect to
{
3 receive that~information?
j l
4 MS. ~ KATZ:
I:am waiting for the letter from Dr.
'j 5
Knorr to come in the mail.
It's been delayed.
.So once I j
6 get it, it should come sometime this_ week, an' I'should be d
7 able to send it out to you.
8 MR. DUDLEY:- So we should get that in:a week or' l
9 two.
10 MS. KATZ:
'[No response.]~
11 MR. DUDLEY:
So we-should expect that information-l 22 in a week'or two, is that correct?
i 13 MS. KATZ:
Yes, you can expect-it in a week-or 14 two.
)
15 MR. DUDLEY:
Thank you.
{
16 MS.lKATZ:
Okay.
17 MR. DUDLEY:
I'd like to back up and try to l
18 summarize the issues raised by Fred Katz -.this is Richard 1
j 19 Dudley again -- in the initial discussion.
I 20 Fred, is that okay with you?
l i
l 21 MR. KATZ:.Yes.
i I
22 MR. DUDLEY:
Fred, the notes I took on your l-23 statement were that you had two concerns.
The first was
( l'.
24 that since there was no epidemiological study done of the
-/
25 Deerfield River Valley, that.you feel the 1987-1988 1
l ANN RILEY & ASSOCIATES, LTD.
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-i 41 1
environmental report done by the licensee for operation of~
2 the Yankee facility was invalid, and because of that, j
i
-1 3
reliance by, perhaps, the NRC and the licensee'on 4
information in that report, to review decommissioning 5
environmental impacts, you feel thatLreview of_the 6
decommissioning environmental impacts would.also be invalid.
1 7
And because of that, your issue that you raised
[
8 was that the plant should be ordered to terminate the
[
- i l
9 component removal activities until a complete adjudicatory L
10 hearing was completed.
i 11 Is that a fair characterization of the first l
12 concern?
i 13 MR. KATZ:- Well, it doesn'tEexclude the issue of r
14 access to decommissioning funds, which are also dependent 15 upon a review of the safety issues, and also, are, in; fact, 16 going ahead without a competent environmental report which' 17 is required for access to these funds.
18 MR. DUDLEY:
This is Dudley. 'So'the plant should l
19 be ordered to terminate component removal and suspend all I
20 use of decommissioning trust funds until a complete hearing 21 is held.
22 Is that a better characterization?
23 MR. KATZ:
Yes.
That's our concern.
24
'MR. DUDLEY:
Just one moment with me, while I take 25 a note on that.
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l 42 l
l.
1 The second concern that you raised, Mr. Katz, was q
i 2
that Dr. Sydney Cobb of the Massachusetts Department of J
3 Health had data on environmental impact of Yankee during its 4
past operation.
l 5
And that appears to be an issue that was i
6 elaborated upon further in detail by Debbie Katz.
So is it 7
fair to say that her characterization of that issue 8
supercedes, or is a more detailed presentation of what your 9
concern was?
10 MR. KATZ:
Katz.
Yes.
Yes.
11 MR. DUDLEY:
Okay.
This is Dudley again.
So, 12 Fred Katz, I just have then the one issue that you raised, t
13 that we have talked about before, with the understanding
~
14 that your second issue was superceded by the detailed 15 information and discussion that was provided later by Debbie
)
1 16 Katz.
i i
l 17 MR. KATZ:
That's right, that the environmental 18 report is not a competent report on which to base operation, 19 or component removal, or access to funds, and she went into 20 these health concerns that have been unreviewed.
21 MR. DUDLEY:
This is Richard Dudley.
Are there 22 any additional concerns or statements that the members of 23 the Citizens Awareness group, or any other members of the 24 public on this conference call, that they would like to make 25 regarding the Yankee Rowe activities at this time?
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43 I
l 1
MR. GUNTER:
Yes.
This is Paul Gunter, Nuclear i
2 Information and Resource Service.
Yankee is currently 3
proposing this component removal under 10 C.F.R. 5059.
l 4
And they're basically saying, and I believe the l
I 5
NRC has agreed, that this component removal does not result t
6 in any unreviewed safety issues.
7 I'm wondering if_the NRC will supply for us the 8
citations where the component removals that are being 9
constituted here in Yankee's proposal have been duplicated, 10 to the degree that Yankee is proposing to conduct this 11 procedure, and as it's been pointed out, results in 90 12 percent of the non-fuel activity.
13 MR. DUDLEY:
This is Richard Dudley.
Paul, I 14 don't believe I followed your request or your question.
15 Could you restate what it is that you would like to 16 determine if it was duplicated?
I didn't quite understand.
17 If you would restate your comment or request, please.
18 MR. GUNTER:
I'll try to put it in simple 19 language.
Yankee has basically presented that they can 20 proceed under 10 C.F.R. 5059 for the' component removal of 21 four steam generators, pressurizer, and reactor internals, 22 as part of this operation maintenance rule, which will 23 constitute 90 percent of the non-fuel activity at the 24 reactor site.
25 And they are being permitted to conduct this ANN RILEY & ASSOCIATES, LTD.
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component removal.with the proviso that it does not j
t 2
constitute unreviewed safety issues.
What I would like from i
3 the NRC or from Yankee, are the citations where these' issues 4
have come.up before; where is the documentation that l
5 constitutes that this component removal-has'-- safety issues-6 raised in this component. removal -- have been addressed.
7 Does that make it clearer?
i l
8 MR. F.AIRTILE:
Paul, this'is Mort Fairtile.
I 9
think what you are referring to are the safety evaluations 10 prepared by Yankee to support their.doing this work.
- Is
. i i
11 that what you mean?
i 12 MR. GUNTER:
Okay.
This is'Gunter.- As I l
13 understand, they are proceeding.on the' component removal j
14 under 10 C.F.R. 5059, is that ' correct?
15 MR. DUDLEY:
Yes.
That is correct.
16 MR. GUNTER:
Okay.
And that the provision.that i
17 they are being granted to proceed on the component. removal l
18 under 10 C.F.R. 5059 is, that it does not constitute-19 unreviewed safety issues.
Am I correct?
?
20 MR. DUDLEY:
That is correct.
21 MR. GUNTER:
Okay.
It seems to us, I mean, from 22 our position, that this the removal of 90 percentfof-the 23 component -- that this component removal representing 90 24 percent of the non-fuel activity on site -- constitutes an L
25 unprecedented procedure.
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And we would like to see the body of works that 2
establishes that all safety issues raised by the removal of i
3 this material, by the transport of this material, have been r
i 4
addressed in prior operations, or if in fact this has not 5
been reviewed before.
6 MR. DUDLEY:
This is Richard Dudley.
So your
)
7 request is to have access to the analysis that indicates
[
B that there are no unreviewed safety issues associated with j
l 9
these early component removal activities.
f l
10 MR. GUNTER:
This is Gunter.
I think what we 11 would like is a clarification of whether these are in fact 12 issues that are addressed through probablistic risk 13 assessment, or whether they have been addressed through 14 actual experiential work, or if in fact these are basically 15 computer models.
l i
16 I think that, at least from our position, and from l
17 public concern's position, there is a difference.
And we i
18 just want to know which is what.
19 MR. FAIRTILE:
This is Fairtile.
They did it on 20 an engineering basis.
There was no probablistic risk i
21 assessments performed for this work.
22 It was done on an engineering basis, and it is 23 based partially on other plants that have done similar work, q
24 and it is based partially on our generic environmental 25 impact statement, which I think is New Reg. 0578.
t ANN RILEY & ASSOCIATES, LTD.
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1 And that-particular document establishes a certain 2
envelop that you can work within.
This envelop deals with 3
the impact on the environment, radiation effects, things 4
like that.
5 So they did an internal engineering study along 6
these lines looking at the safety aspects, the radiation 7
aspects, the transportation, and all of that sort of thing.
8 And the whole purpose of 5059 is that the licensee
)
9 performs this analysis and makes a determination that he i
i 10 needs not come in to NRC to get our prior approval.
We 11 wrote him a letter dated July 15th, I believe it was, saying 12 that we had no objection, because he met certain criteria 13 that we established for his doing this work.
"his is Gunter.
What I think 14 MR. GJNTER:
Okay.
T 15 is it raises a question for us, and what we would like, i
16 would be for you to provide us with information for 17 clarification purposes, that basically can provide us with 18 assurances that the procedures that Yankee is conducting do j
19 not -- I mean in the proportions that they're proposing here 20
-- do not constitute unreviewed safety issues.
21 For example, we would like to see the specific 22 references to plants where the -- I can understand for a 23 steam generator -- or the steam generator issues -- and I 24 think that there is evidence of that.
25 We would like to see the documentation for reactor ANN RILEY & ASSOCIATES, LTD.
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internals as well, and as well as instances for, you know, j
l 2
for the reactor pressurizer.
3 MR. FAIRTILE:
Okay.
The reactor internals, they 4
are only going to ship those internals that are below class i
5 C which is a class, a level of radiation that is acceptable 6
at low-level waste disposal sites.
l 7
And that will be shipped in casts, and that has l
8 been done at everyone of the 100 reactors in operation.
9 There is nothing unique or unusual about that.
10 I don't know of any other pressurizer that has i
11 ever been shipped'out.
But the curie burden of their j
12 pressurizer is below that of their steam generator.
So
(
i 13 their steam generator shipments would envelop their I
14 pressurizer shipment.
~
i 15 MR. GUNTER:
Okay.
This Gunter.
Can we get that-16 material?
17 MR. DUDLEY:
This is Richard Dudley.
That 18 material has been reviewed and evaluated by the NRC in an l
19 inspection, and the results of our evaluation will be put 20 forward in an inspection report.
21 We will raise the issue to our management of to 22 what extent we can go, and perhaps potentially copy this 23 material that is the property right now of the licensee, and 24 decide whether it is acceptable to provide that information l
t i
25 to you.
We will look into that issue..
l l
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-l s
j 48 j
l l'
MR. FAIRTILE:
This is Fairtile..
We' don't-require 2
a licensee to submit its 5059 safety analyses to us.
And I 3
think Mr. Dudley.gave you the right response..~We do audit-4 them.
We do inspect them.
5 In fact, we did inspect these particular safety
(
6 analyses, and the inspection report Mr. Dudley mentioned
-i 7
will be issued in late August.
And I can even give you.the 8
inspection report number.
It will be 93-05.
9 Paul Harris, are you on the line?
l l
10 MR. HARRIS:
Yes, I am.
l 11 MR. FAIRTILE:
Did I misspeak?
]
l 12 MR. HARRIS:
You did not.
The end of.the l
13 inspection period is July 31st.
And during this month,.the 14 report should be issued.
15 MR. GUNTER:
This.is Gunter.' 'Could-I get the l
l t
16 inspection report number again, please?
17 MR. FAIRTILE:
Yes.
The full' number is i
~
18 50-29/93-05.
And'it should be coming out in two to'three 19 weeks.
Mr. Harris would probably have a better feel for 20 that.
l 21 MR. GUNTER:
This is Gunter.
This would be under 22 the Rowe docket.
l 23 MR. FAIRTILE:
Correct.
This is Fairtile.
50-l 24 29, right.
1 25 MR. GUNTER:
This is Gunter again.
I still have
. ANN RILEY & ASSOCIATES, LTD.
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49 1
concerns with regard to the fact that the safety analysis 2
from Rowe on this component removal -- the review by NRC is 3
not required.
4 I mean, how can the NRC basically take the 5
utility's word that the processes that they are reviewing, j
6 or that they're proposing, did not constitute unreviewed 1
7 safety issues?
j 8
MR. FAIRTILE:
This is Fairtile.
While we don't 9
review 50-59 analyses, we do have the ability to audit them.
10 The licensees, you know, do maybe a 1,000 of these a year, l
11 or maybe more.
We look at all the important ones.
Anytime 12 a licensee does any, you know, large analysis of this type, 13 we inspect them.
We audit them.
14 MR. DUDLEY:
This is Richard Dudley.
So in this l
15 case, although the NRC did not review and give the licensee i
l 16 prior approval to undertake these activities, the NRC did, 17 in the form of an inspection, audit these reviews performed 18 by the licensee by. reviewing these records at the licensee's 19 facility, and our evaluation of that inspection will be 20 published in the inspection report number that we have-given 21 you.
22 But Mr. Gunter, I still have as.an issue that you 23 raised, a request for us to provide you with the licensee's 24 actual analyses.
Is that a fair characterization of the l
25 issue you raised?
i l
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Court Reporters 1612 K Street, N W.,
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MR. GUNTER:
This is Gunter.
I think that what we 2
are looking for is a level -- to establish a level of i
3 confidence that processes that are being proposed by Yankee 4
Rowe removal do not constitute unreviewed safety issues.
5 We would like any information that can l
6 establish that the reactor internals in question -- I think, l
7 see, when we're told that 90 percent of the non-fuel 8
activity is being removed, that must be more than class C 9
waste.
I i
10 And so, consequently, we would like see that 90 11 percent broken down, and to have established that in fact it-i 12 does not constitute unreviewed safety issues.
Because it 13 appears to us that in fact the process at this stage f
14 represents a precedent.
l l
15 And that raises a number of concerns for us, and 16 all we are really asking for you is to establish a level of 17 confidence that in fact these issues.have been reviewed.
18 MR. DUDLEY:
This is Richard Dudley.
So in 19 response to your concern, we have stated that the NRC has 20 inspected and audited these evaluations, and will document 21 our results of that in the inspection report number that we 22 have given you.
23 And we will evaluate, raise the issue with higher wh'ther we could provide to you, or, I 24 levels of management, e
25 guess, put on the docket, these evaluations done by the ANN RILEY & ASSOCIATES, LTD.
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51 1
licensee that we inspected.
l
~
1 2
Does that appear to respond to your concern?
-l 1
3 MR. GUNTER:
This is Gunter.
Yes.
I believe this l
4 would be a start.
What my second question is, is thatlwith j
i 5
regard to the timetables for the removal ofLthe components,-
i L
i 6
where does that fit in with the issuance of the. inspection l
t 7
report?
l l
B And, see, again,.it raises the whole question of l
9 providing some opportunity for the public to see'what's i
10 actually being removed here, and you know,_the whole concern l
11 that in fact the issuance of these; reports represents j
12 nothing more than hindsight to the-public.
-i 13 lMR. FAIRTILE:
This is Fairtile.
.The' program,'the' l
.i l
14 licensee has been involved in. component' removal;for_many-'
15 months.
He has not yet. reached -- he:has done' things like 16 asbestos removal, preparation of:the plant,1 building of-i l
17 scaffolds, things like that.-
18 He hasn't yet started'any of the= critical items 19 like cutting pipe. -That will probably start in late August.
20 He'll start cutting pipe maybe the third. week in' August, and 21 actually start shipping steam generators intoJthe fall.
~
22 I believe he plans on taking a break during the 23 winter months, and resuming _ shipments again next spring, and-24 having them all completed by the end of-June.
I can't give 25 you firm dates, because'the licensee.doesn't have firm ANN RILEY & ASSOCIATES, LTD.
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dates. All these jobs are interrelated.
l' 2
They are very complex, an usually there are l
3 unplanned delays in these things, due to weather, having the 4
right people at the right time, and things like that.
But i
5 the actual cutting, which would signify the real beginning 6
of the job would start, I would say,-the second or third i
7 week of this month -- within a week or two from today.
8 MS. KATZ:
This is Katz.
Are we going to be given
~
4 9
prior notification of the beginning to cuts?
10 MR. FAIRTILE:
This is Fairtile.
That is --
11 MR. DUDLEY:
This is Richard Dudley.
We have that 12 listed as an issue that you have raised.
We can't respond 13 to that now.
The licensee has certain notification 14 requirements under existing federal regulations that we will 15 make certain that they comply with, but the extent as to 16 which releases and the level of notification for various 17 releases, probably does not go to the level that you have j
requested that notification be done.
But we have that noted 18 l
19 as an issue that you have raised that we will peruse.
20 MS. KATZ:
Thank you.
We have attempted to 21 pressure Yankee to give us prior notification, and the 22 Department of Health in Massachusetts has asked Yankee to j
23 give prior notification, and they have refused.
24 MR. DUDLEY:
This is Richard Dudley.
Are there i
l 25 any other statements or comments from members of the l
l l
l ANN RILEY & ASSOCIATES, LTD.
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53 1
Citizens Awareness group at this time?
2 MR.- KATZ:
Yes.
Yes.
3 MR. DUDLEY:
Please go ahead.
4 MR. KATZ:
This is Katz.
I actually have-two.
l 5
One of them is that in the correspondence between me and the l
6 NRC, include a lot'of information-and statements 1in regards 7
to [ telephone interference].
And, in fact, the NRC is 8
giving permission.to dismantle now, and in fact, [ telephone 9
interference) to me on the-telephone, because it would l
10 really represent a savings.of a~1ot of money.
11 But in fact, the Shearson Lehman report says that 12 it is in fact more' costly.in that respect,.and~we would like 13 a response to that in your response.
l l
l 14 And in addition,_the entire technique and i
i 15 procedure for beginning the decommissioning. process seems to-
)
16 us to be a violation of the ALARA -- the principle of ALARA, I
(
17 because, in fact, the NRC documents'themselves show'that 4
J l
18 there is a vastly different. exposure experience potentially 19 in the various kinds of decommissioning options' chosen.
[ Telephone interference] nuclide inventory from l
21 the site. [ telephone interference).
A~ situation where the j
22 task of decommissioning higher exposure Itelephone 1
23 interference) for workers, and the public.
And I.would like 24 this, what'seems to be really contradictory process to be 25 addressed.
i s
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MR. DUDLEY:
Fred, let me try to restate yourg 2
concern.
This is Richard Dudley.
Your concern -- it's two
-l i
3 concerns.
One was that Shearson Lehman says that a safe j
i 4
store decommissioning,.according tc what you say -- the i
5 report that as you read it -- Shearson Lehman says that safe 6
store is more costly, so why --
l 7
MR. KATZ:
Less --
8 MR'. DUDLEY:
I'm sorry -- is less costly, and-I 9
therefore, why does the NRC allow-the licensee to proceed 10 with another alternative, even though the licensee says that i
.)
11 for them, that other alternatives would save money.
.i l
12 Is that a characterization of.your issue?.
I 13 MR.- KATZ:.Katz here.
Yes.
Well, yes,.I mean the 14 licensee is always bringing up the issue of costs, and'the l
15 NRC never says to'them:
Listen, don't talk to us about t
l 16 costs.
Talk to your banker or?your stockholders.
17 But they seem to receive these communications and l
18 I assume that they're relevant to your concerns.
And you 19 never exclude them from these communications.
So that, in 20 view of that, the Shearson Lehman analysis is.very relevant, 21 and should be, therefore, addressed.
22 MR. DUDLEY:
This is Dudley.
Your second concern 23 was on occupational radiation exposure.
But I think that is
)
24 duplicative of another concern that we had raised by Debbie 25 Katz, so I'm not going to address that one separately.
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MR. KATZ:
Well, I don't know whether it was --
2 Katz here -- in terms of the principle of ALARA.
I think 3
she raised it in terms of some generalize humanitarian 4
concerns.
5 So I would like it specifically to be addressed in 6
the terms of the principle of ALARA, which I am completely 7
confounded by [ telephone interference] what the experience B
we're having right now.
9 MR. DUDLEY:
Are there any additional comments, 10 questions, or concerns at this time?
11 MR. KATZ:
I don't believe there are at this time.
i 12 MS. KATZ:
What I would like to know is what 13 process is going to take place, and how what's going to 14 happen to what we have raised; how it will get worked on and l
15 how we will continue working on it.
Debbie Katz.
16 MR. DUDLEY:
This is Richard Dudley.
We have a 17 transcript that has been made of this discussion.
We have 18 attempted to summarize the issues that you have presented, 19 and to the ones that we have reiterated during the meeting l
20 we will -- I guess, a good way to proceed would be for us to i
l 21 issue a written summary of the issues, and then we will, I 6
22 believe, take these issues and treat them in the form of an l
23 allegation -- consider these, perhaps, as having been -- we 24 will investigate as to whether the allegation process is how 25 these issues should be handled on the short-term basis, but ANN RILEY & ASSOCIATES, LTD.
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l 56 s
1 we will deal with these issues, and give you, I guess a t
2 docketed response on all of them, which was an agreement 3
that we made earlier with Fred Katz.
4 MR. GUNTER:
This is Gunter.
When you say that it l
5 will be treated as an allegation, are your referencing 10 6
C.R.F.
10.206?
I 7
MR. DUDLEY:
No.
Let me restate my position on j
8 that.
We will first investigate the transcript to see if l
9 there are any issues raised that would fall under the 10 category of allegations.
And there may not be.
11 At this point, it looks like there might not be 12 any issues that come to that level, but we have already --
13 we have previously agreed with Fred Katz that we will 14 respond to him'with formal written' responses to all of the 15 issues.
16 And that was the reason that I was summarizing for 17 the purposes of the record -- a summary of the issues'that l
18 were raised.
19 Are there any more issues or concerns at this 20 point?
j 21 MS. KATZ:
So that -- I'm a little confused.
The 22 next communication we may get from you, is it a PDLR?
Is 23 that it? -Are we gcing to talk to you guys again, or, is
- i 24 this it?
I just wonder.
I don't know the process.
I'm 25 sort of a novice at this it.
So I would just like some more ANN RILEY & ASSOCIATES, LTD.
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v
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=57 1
clarification of the step after, you know, you're going take i
2 their concerns, and then you're going to' review them, and 3
then what happens?
4 MR. DUDLEY:
We will--- it's possible that.the 5
next response you get from us will be our written response.
6 Or, if necessary, we might contact you if we need additional 7
information in various areas.
8 But first, when we get your first submittal that
{
9 you have transmitted,-and we get the two additional packets l
10 of information that you have promised, we will evaluate that
.j 11 information with respect to the issues that we.have j
12 summarized here.
13 And then if we need additional information, wei i
14 will contact you, if we do not, we will respond to-you on-1 15 these issues formally in writing.
And I guess we would sent-l 16 the correspondence to the address that we have for the 17 Citizens Awareness Network.
l 18 MR. FAIRTALE:
This is Fairtile.
Is that still a 19 valid address'that we.have on our service list, and if not, 20 could you please give me one over the phone right now?
I 21 MR. KATZ:
The address forLthe Citizens Awareness i
1 l
22 Network remains the same. :It's Box 83, Shelborne Falls.
l.
23 MR. FAIRTILE:
Okay.
That's the one we-have.
24 Right.
25 MR. GUNTER:
This is Gunter' I would like to add ANN RILEY & ASSOCIATES, LTD.
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Nuclear Information and Resource Service, 1424 16th Street, 2
N.W.,
Suite 601, Washington, D.C.,
20036.
3 MR. DUDLEY:
This is Richard Dudley.
At this i
l 4
point, I would prefer that the Citizens Awareness Network i
5 provide you that response, if they would commit to do so.
6 MR. GUNTER:
This is Gunter.
We are raising the 7
question with regard to the unreviewed safety issues on the 1
i 8
50-59, for our own concern, and we'd like to have that
)
9 addressed directly.
l 10 MR. DUDLEY:
Mr. Gunter, we have our legal counsel 11 here, and perhaps --
)
12 MR. REIS:
Mr. Gunter, you were invited by C.A.N.
13 And we think that it would be better if any communication l
I l
14 went through them.
This was a C.A.N. meeting, a meeting i
15 with C.A.N.
and us.
As a courtesy, you were invited to be l
16 here.
At this point, we will respond to you through C.A.N.
17 MR. GUNTER:
Thank you.
What does C.A.N.
have to 18 say about that?
19 MR. KATZ:
What can we do'in response?
We could 20 only protest to our colleagues that they have their concerns i
21 addressed directly.
I don't I ie any grenade launcher so j
i 22 that what can I say except that I protest.
)
23 That's all we've been able to do, is protest.
24
{ telephone interference) have a hearing, an adjudicatory 25 hearing, wnich would make all your work a lot easier than ANN RILEY & ASSOCIATES, LTD.
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this informal, illegal, chaotic process that we refuse to i
2 agree, will replace a legal, decent way of going about
{
3 dealina with these life and death --
4 MR. DUDLEY:
Hello?
Okay.
This is Richard 5
Dudley.
We can send this one response to the Nuclear 6
Information and Research Service.
We will do that.
7 MR. GUNTER:
Okay.
Thank you.
This is Gunter.
8 MR. FAIRTILE:
We need your address again.
9 MR. DUDLEY:
Would you give us the address again, i
l 10 slowly, to make sure we have it correctly in the record?
l j
11 MR. GUNTER:
Okay.
This is Gunter.
It's Nuclear i
12 Information and R.esource Service, 1424 16th Street, N.W.,
13 Suite 601, Washington, D.C.,
20036; 202-328-0002.
And to my j
14 attention, please, Paul Gunter, G-u-n-t-e-r.
1 l
15 MR. DUDLEY:
Are there any more comments at this 1
l 16 moment?
l 17 MS. KATZ:
I would just like to get a sense of the 18 time line.
Will we get a response to this before they begin 19 to cut?
20 MR. DUDLEY:
I highly doubt it.
We will likely 21 not have received all the information from Citizens 22 Awareness Network to begin'our look by that time, but we l
23 will respond in a timely fashion as soon we get the 24 information that we need to look into these things.
25 MS. KATZ:
Debbie Katz.
I guess there is nothing ANN RILEY & ASSOCIATES, LTD.
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t 60 1
we can oc about that.
Would you put off their cutting until 2
these issues are addressed?
3 MR. DUDLEY:
That was Debbie Katz.
We have heard 4
no information at this point that would cause us to order 5
the licensee to terminate these early component removal 6
activities.
i 7
But we will review the additional information that 8
you plan to provide us.
But at this point, we have heard no 9
information that would cause us to order that these 10 activities be stopped.
11 MR. KATZ:
Well, unfortunately, you have no 12 information to review [ telephone interference] allow them to 13 proceed, and now you're telling us you have no information 14 to review to order them to stop.
[ Telephone interference]
15 illegal, illogical, and chaotic, and we need to have a 16 hearing.
17 I would like to say it again, and I think I stand 18 in the same place that the chairman of your commission 19 stands, and we would like to support him, as a matter of 20 fact, and we would like to give him our appreciation for his 21 input into this at this time.
And I don't think there's 22 anything more we can say.
23 MR. DUDLEY:
Okay.
Thank you very much.
24 THE REPORTER:
Was that Debbie Katz that spoke?
25 MR. KATZ:
That was Debbie Katz, the Chairman of ANN RILEY & ASSOCIATES, LTD.
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~
1 the Health Committee.
2 MR. DUDLEY:
You said that that was Debbie Katz.
3 MR. KATZ:
Yes.
4 MR. DUDLEY:
Okay.
Thank you very much.
5 MS. KATZ:
Thank you.
6 MR. KATZ:
Thank you.
Good afternoon.
7
[Whereupon, the conference was concluded.]
8 9
10 11 12 13 14 15 16 j
17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.
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.l i
REPORTER'S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
NAME OF PROCEEDING:
NRC Telecon with Citizens e
Awareness Network I
DOCKET NUMBER:
}
PLACE OF PROCEEDING:
Rockville, MD were held as herein appears, and that.this is the original transcript.thereof for the file of the
+
United States Nuclear Regulatory. Commission taken by me and thereafter reduced.to typewriting by me j
or under the direction of the court reporting-company, and that the transcript-is a true and accurate record of-the foregoing proceedings.
CfAs-u official
- Reporter I=
Ann Riley & Associates, Ltd.
I l
l