ML20252A171
| ML20252A171 | |
| Person / Time | |
|---|---|
| Site: | HI-STORE |
| Issue date: | 09/02/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| Caverly J | |
| References | |
| NRC-1033 | |
| Download: ML20252A171 (142) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Online Webinar Docket Number: N/A Location: Teleconference Date: September 2, 2020 Work Order No.: NRC-1033 Pages 1-133 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PUBLIC ONLINE WEBINAR FOR THE DRAFT ENVIRONMENTAL 5 IMPACT STATEMENT FOR THE PROPOSED HOLTEC HI-STORE 6 CONSOLIDATED INTERIM STORAGE FACILITY 7 + + + + +
8 WEDNESDAY, 9 SEPTEMBER 2, 2020 10 + + + + +
11 TELECONFERENCE 12 + + + + +
13 The Webinar was convened via 14 Teleconference, at 11:00 a.m. EDT, Chip Cameron, 15 facilitating.
16 17 NRC STAFF PRESENT:
18 CHIP CAMERON, Facilitator 19 KEVIN COYNE, Deputy Director, Rulemaking, 20 Environmental and Financial Support, NRC 21 JILL CAVERLY, Environmental Review Project Manager, 22 Environmental Review Branch, NMSS 23 STACEY IMBODEN, Co-Environmental Review Project 24 Manager, Environmental Review Branch, NMSS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1
2 JOSE CUADRADO, Licensing and Safety Review Project 3 Manager, Spent Fuel Licensing Branch, NMSS 4 JOHN McKIRGAN, Chief, Storage and Transportation 5 Licensing Branch, NMSS 6 JESSIE QUINTERO, Acting Branch Chief, Environmental 7 Review and Materials Branch, 8 ANGEL MORENO, Congressional Affairs Officer, Office 9 of Congressional Affairs 10 KELLEE JAMERSON 11 12 ALSO PRESENT:
13 MIRIAM HOLLADAY JUCKETT, Southwest Research 14 Institute 15 MARLA MORALES, Southwest Research Institute 16 17 18 19 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 C O N T E N T S 2 Page 3 Opening Remarks and Introductions..................4 4 Spanish Introduction and Instructions..............9 5 Welcome by Senior NRC Official Kevin Coyne.........9 6 NRC's Review Process..............................13 7 Safety Review...............................17 8 Environmental Review........................18 9 Overview of Holtec's License Application..........19 10 Public Scoping Comments...........................23 11 NRC's Environmental Review Results................24 12 Information Resources and Ways to Comment.........28 13 Public Comment....................................29 14 Closing Comments.................................132 15 Adjourn..........................................133 16 17 18 19 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 11:02 a.m.
3 MR. CAMERON: Good morning everyone. My 4 name is Chip Cameron. And I'd like to welcome you to 5 the Nuclear Regulatory Commission meeting to listen 6 to comments from the public on the draft 7 Environmental Impact Statement the NRC has prepared 8 to help the Agency evaluate a license application 9 submitted by Holtec International to build and 10 operate a consolidated interim storage facility in 11 southeastern New Mexico.
12 The EIS is one key part of the NRC 13 evaluation of whether to grant the license. Another 14 key part of the evaluation is a public health and 15 safety review that will be embodied in something 16 called a Safety Evaluation Review.
17 The EIS is done under the authority of 18 the National Environmental Policy Act. The Safety 19 Evaluation Review is done under the authority of the 20 Atomic Energy Act.
21 Now, this is the last scheduled virtual 22 public meeting on the draft EIS. And the NRC staff 23 is looking forward to hearing from you about any 24 issues you disagree with, issues you might agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 with, issues that haven't been addressed at all in 2 the EIS, and any supporting documents that you might 3 want to submit to help the NRC in preparing the final 4 Environmental Impact Statement.
5 Now, we have staff in the room here at 6 NRC Headquarters, not only from the Environmental 7 staff, but also from the Technical Safety Evaluation 8 staff. And as you'll hear Jill explain later on, 9 there were some issues that were raised that were 10 quote, out of scope, unquote for the Environmental 11 Impact Statement, because they were going to be 12 covered in the Safety Evaluation Report that the 13 Technical staff is doing.
14 I thought I'd give you a pictorial 15 introduction today of the people with me and on the 16 phone. And we're in a conference room at NRC 17 Headquarters.
18 And it's a horseshoe-shaped table, very 19 appropriate at this time of the year. I'm in the 20 center at the bottom of the horseshoe.
21 Three seats to my right is Jill Caverly.
22 Now Jill is the Project Manager for the preparation 23 of the Environmental Impact Statement. And You're 24 going to hear her summary of the draft EIS in a few NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 minutes.
2 To Jill's right is Jose Cuadrado. Now 3 Jose is the Project Manager for the Health and Safety 4 Review.
5 And you'll also hear from him shortly.
6 He's going to offer assistance to Spanish-speaking 7 members of the public who might be with us today.
8 To Jose's right is Kevin Coyne. Kevin is 9 the Deputy Director of the Division of Rulemaking, 10 Environmental, and Financial Support here at the NRC.
11 His division is responsible for the draft EIS.
12 And to Kevin's right we have John 13 McKirgan. He's at the top of the right part of the 14 horseshoe.
15 And John is the Chief of the Storage and 16 Transportation Branch at NRC. And that's where the 17 Safety Evaluation Report will be produced.
18 Now, going across the top of the 19 horseshoe is Jessie Quintero. She's at the top left 20 of the horseshoe.
21 And Jessie is the Acting Branch Chief of 22 the Environmental Materials Review Branch at the NRC.
23 That's where Jill does her work. And it's in Kevin's 24 division.
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7 1 Now, we also have some expert 2 environmental scientists who are helping the NRC to 3 prepare the Environmental Impact Statement. And to 4 my immediate left is Marla Morales from the Southwest 5 Research Institute in San Antonio, Texas.
6 On the phone we also have Miriam Juckett.
7 She's the Manager of Environmental Programs at 8 Southwest Research Institute.
9 We have Kellee Jamerson, and Kellee is 10 who helps us with all the technology, including 11 Webex. And we have Angel Moreno. He's from our 12 Office of Congressional Affairs.
13 Stacey Imboden, is Jill Caverly's Co-14 Project Manager on this draft EIS. And he's not here 15 today, because he's having a procedure.
16 Dave McIntyre -- Kellee, can we -- there 17 he is. He'll be back soon. And if any of you in the 18 media need to talk to an NRC contract about media 19 information, there's Dave's contact information.
20 Okay. We're in a virtual setting today, 21 which means we're going to be hearing from you by 22 phone. You can also see the slides on Webex. And 23 Kellee is going to put a slide up on Webex for you.
24 You can also go to the chat box on Webex NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 and post a comment if you're having any technical 2 difficulties hearing any of the NRC speakers or 3 anything else.
4 The NRC is not going to finalize this 5 draft EIS or use it in any decision making on the 6 Holtec license application until it evaluates your 7 comment on the draft EIS.
8 Now the NRC's not going to be responding 9 to comments you make tonight. But they will carefully 10 evaluate those in preparing the final EIS.
11 So, as I said, we're in a virtual 12 setting. And we have Olin (phonetic) for our Operator 13 today. And later we'll have Erin, a new Operator, 14 join us.
15 But, they are going to instruct you on 16 how to sign up to speak. How to put you on to talk 17 to the NRC staff.
18 And like the other meetings, this is 19 going to be a first come, first serve to speak. And 20 we're scheduled from 11:00 a.m. Eastern to 2:00 p.m.
21 Eastern.
22 And we have a little bit more 23 flexibility, I think, today with the length of your 24 comments. But, right now I'm going to ask you to go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 for, you don't have to go for six or seven minutes.
2 But I'm going to not cut you off at four minutes like 3 we had to do in the past.
4 And we're taking a transcript tonight, as 5 usual. The transcripts from the other virtual 6 meetings will be available. And Jill will tell you 7 about that.
8 But Brandon is our Court Reporter. And 9 he'll be taking the transcript for you. And that 10 will be available in approximately ten days.
11 Okay. So, when Olin or Erin puts you on 12 the phone, please introduce yourself, give an 13 affiliation, if you would like to do so.
14 I'm going to ask Jose to say a few words 15 in Spanish. If anybody needs help with Spanish 16 translation, Jose Cuadrado.
17 MR. CUADRADO: Thank you, Chip. Good 18 morning everyone attending the meeting. My name is 19 Jose Cuadrado.
20 And I'm going to read a brief message in 21 Spanish for any Spanish speaking attendees today to 22 our meeting.
23 (Introduction and directions provided in 24 Spanish)
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10 1 MR. CAMERON: Okay, thank you. Thank you 2 very much, Jose. And we're going to go to Kevin Coyne 3 now, who's our Senior NRC Official, to give the public 4 a welcome. Kevin?
5 MR. COYNE: Thanks Chip. Good morning.
6 I'm Kevin Coyne and I'm the Deputy Director for the 7 Division of Rulemaking, Environmental and Financial 8 Support, which is the group responsible for the 9 development of the draft Environmental Impact 10 Statement.
11 The draft Environmental Impact Statement 12 is the result of the NRC staff's evaluation of the 13 environmental impact associated with Holtec 14 International's proposal to construct and operate an 15 interim storage facility. And today, we are asking 16 for your comments on that report.
17 It's important to note that any comments 18 received in this webinar forum are handled in the 19 same manner as those comments received at an in-20 person meeting. Your comments presented here today 21 are recorded and transcribed.
22 Our staff will review and analyze the 23 comments, and update the final EIS report as 24 appropriate. Comments received during this webinar NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 will be made available in a transcript of today's 2 meeting that will be posted to the NRC's Holtec review 3 website shortly after the meeting.
4 The NRC staff in its commitment to 5 openness in this licensing review had planned for 6 five in-person public meetings. Unfortunately, we're 7 sorry that under the current public health emergency, 8 these meetings cannot be held as planned.
9 We are adhering to the New Mexico 10 Governor's guidelines for public gatherings, and are 11 following similar guidance from the State to its own 12 agencies for converting in-person meetings to a 13 virtual format.
14 Our staff is disappointed that we won't 15 be able to meet with you face to face and host open 16 houses prior to the meetings.
17 Over the course of conducting webinars 18 during the public health emergency, we have learned 19 that using video puts an extra burden on our servers 20 and may limit the functionality of the webinar for 21 participants.
22 Therefore, while you will not be able to 23 see us via video, please note that our review team is 24 attending this webinar and are hearing your comments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 and perspectives.
2 Further, the webinar is only being used 3 to share the presentation materials. And these 4 materials are available on the NRC's Holtec 5 application review web page.
6 You can download those materials and 7 review them, or follow along with the presentation 8 over the telephone.
9 There are several recurring remarks at 10 our earlier webinars that I would like to address.
11 The first of those is that the NRC is rushing through 12 the licensing process. The comment period for the 13 draft Environmental Impact Statement has been 14 extended to a total of 180 days. And this provides 15 ample opportunity for people to comment.
16 This meeting is also being held 20 days 17 before the comment closing period to provide 18 additional time to submit comments in writing.
19 If you need any assistance in accessing 20 the application materials, the draft Environmental 21 Impact Statement, or submitting a comment, please 22 contact Jill Caverly for assistance.
23 Secondly, it was our intention to conduct 24 in-person meetings during the public comment period.
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13 1 But as we continue to monitor the public health 2 emergency, the limitations associated with the 3 response to the emergency has made these in-person 4 meetings impossible at this time.
5 Finally, we've received several comments 6 that the NRC is breaking the law by not coming to New 7 Mexico. We take our applications under NEPA very 8 seriously.
9 And NEPA requires federal agencies to 10 provide a 45-day comment period for the draft 11 Environmental Impact Statement. Neither NEPA nor our 12 regulations in 10 CFR, Part 51 require public 13 meetings or in-person meetings.
14 However, the NRC has offered in-person 15 public meetings in the past because it was our 16 practice, not a requirement. We understand that many 17 of the NRC's licensing actions are important to the 18 community, and we like to talk with you about them 19 face to face whenever possible.
20 Again, thank you for your time today, and 21 I'll turn it over to Jill to present the NRC staff's 22 draft Environmental Impact Statement results.
23 MS. CAVERLY: Okay, thanks Kevin. So, 24 good morning. Today I'm here to collect your comments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 on the NRC's draft Environmental Impact Statement.
2 And the majority of our meeting today 3 will be dedicated to that. And as Chip mentioned, I 4 have this short presentation.
5 I'm going to begin with an overview of 6 the application process, including the differences 7 between the environmental review and the safety 8 review.
9 Next, I'm going to move onto an overview 10 of the application submitted to NRC. I'm then going 11 to summarize the results of the staff's analysis.
12 I'll cover some of the public comments 13 received during the scoping process, and the 14 environmental evaluation and the results.
15 And finally, I'm going to end with 16 information on how you can access the report and make 17 comments on the draft Environmental Impact Statement.
18 So, as I go through my presentation, I 19 will use the term facility and proposed project 20 interchangeably. The abbreviation CISF stands for 21 consolidated interim storage facility.
22 Also, I may interchange the applicant and 23 Holtec, which is short for Holtec International.
24 Environmental Impact Statement will be abbreviated to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 EIS.
2 And finally, staff and NRC staff will be 3 referring to the staff of the Nuclear Regulatory 4 Commission. Next slide, please. Next slide, please.
5 Okay. So, as we mentioned the purpose of 6 this meeting is to receive your comments on the draft 7 Environmental Impact Statement, or EIS for a 8 consolidated interim storage facility, CISF.
9 And the NRC is requesting that you review 10 the draft EIS document and provide comments that are 11 pertinent to the current licensing action and the 12 draft EIS report. You have access to the report at 13 the NRC's website, where it can be downloaded and 14 read.
15 There are also three ways to comment.
16 Either by mail, website, or by email. Information 17 and methods to comment are going to be summarized at 18 the end of my presentation.
19 As Kevin said, any comments you make in 20 this forum, as well as through the three other methods 21 I just identified, will be recorded and entered into 22 the public docket for this licensing action. Next 23 slide, please.
24 So, we're going to talk a little bit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 about the review process for a license application 2 for a CISF. Next slide, please.
3 So, this is just to clarify NRC's role.
4 As an independent regulator, the NRC determines 5 whether it is safe to build and operate a storage 6 facility at the proposed site in Lea County, New 7 Mexico.
8 The NRC evaluates an application for a 9 facility and determines if a license can be issued.
10 The NRC does not promote or build nuclear facilities.
11 Also, the NRC doesn't own or operate 12 nuclear facilities. Our mission and our regulations 13 are designed to protect the public, workers, and the 14 environment.
15 Holtec International, or the applicant, 16 has proposed the location for the interim storage 17 facility in its application. So, in its role as a 18 regulator, NRC staff will perform both a safety 19 evaluation and an environmental review on that 20 application. Next slide, please.
21 So, this slide is a familiar looking 22 slide. We often show it in our scoping meetings.
23 But, it's a schematic of the NRC's licensing decision 24 process.
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17 1 And it's here to show you that the NRC 2 has concurrent reviews occurring during its 3 evaluation process. You can see from the slide that 4 the process of licensing is based on three 5 foundational activities, the environmental review, 6 the safety review, and the adjudicatory process.
7 The safety review results in a Safety 8 Evaluation Report. And is based on the Atomic Energy 9 Act and regulations in the Code of Federal 10 Regulations. These regulations must be met in order 11 for a license to be granted.
12 The environmental review results in an 13 Environmental Impact Statement. This action is taken 14 because issuing a license is considered a federal 15 action under NEPA, the National Environmental Policy 16 Act. NEPA requires federal agencies to evaluate and 17 disclose environmental impacts of federal actions.
18 And the middle process in this slide is 19 the adjudication process. And that's a legal process 20 used for a dispute. Okay, next slide, please.
21 So to look at the safety side of the 22 review a little bit more. This slide shows you many 23 of the areas of the safety review, which are required 24 by the NRC to assure that a design can be constructed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 and operated while protecting human health.
2 The NRC's safety staff will evaluate the 3 design of the CISF and the characteristics of the 4 construction site to ensure that it will be built and 5 operated safely. That it will be protective, be 6 protected from manmade and natural hazards.
7 And that it will protect the public 8 health and safety. The NRC staff evaluates the 9 physical security practices to assure that the 10 facility is protected from intrusion, theft, and 11 sabotage.
12 The design of structures at the facility 13 is evaluated to verify it's integrity and ability to 14 withstand accidents. Other areas such as financial 15 qualification are reviewed to ensure it meets NRC 16 standards before a facility can be licensed.
17 In addition, the staff will evaluate that 18 the facility is capable of withstanding external 19 hazards, which include things like extreme 20 temperatures, floods, tornados, and earthquakes.
21 So the safety evaluation determines 22 whether the facility can be constructed and operated 23 to protect human health.
24 And you could say that the safety review NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 in part evaluates how the environment will impact the 2 design, and whether that design is capable of 3 providing protection in safely storing spent fuel.
4 All right, next slide, please.
5 So on the other hand, the parallel 6 environmental review evaluates what the project will 7 do to the environment. The environmental review 8 starts with the current environmental conditions as 9 its baseline.
10 In the EIS we call this the affected 11 environment. Each of the resources you see listed 12 here will be evaluated for impacts to that baseline.
13 So using the baseline data, the staff 14 will evaluate the changes or impacts to each of the 15 listed resource areas should the facility be 16 constructed and operate.
17 So that delta or that change to the 18 resource, is evaluated. And that change is called 19 the impact to the resource. And that's what's 20 disclosed in our Environmental Impact Statement.
21 Next slide, please.
22 So in order to quantify the impacts, the 23 NRC uses the definitions of significant levels for 24 environmental impacts, small, moderate, and large.
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20 1 And this scale rises based on the 2 destabling influence to the resource. These 3 definitions are from NRC's staff guidance. Next 4 slide, please.
5 Okay. So now we're going to talk a little 6 bit about the details of the application. Next slide, 7 please.
8 The proposed project is located half way 9 between the towns of Carlsbad and Hobbs in New Mexico.
10 Holtec's project includes the storage facility, 11 related buildings and a rail line.
12 A portion of the rail line is shown on 13 the diagram on the right. And is the loop that you 14 see on the east side of the facility.
15 This rail line continues off the diagram 16 to the south. And then turns to the west and 17 continues for approximately five miles to tie into an 18 existing rail line.
19 The area of the rail line not shown on 20 this diagram is on the Bureau of Land Management 21 controlled area, controlled land. So Holtec is 22 seeking a permit for that action to the Bureau of 23 Land Management as a cooperating agency with the NRC 24 on the development of this EIS.
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21 1 In addition, the New Mexico Environment 2 Department worked as a cooperating agency with NRC on 3 surface and groundwater resources for their 4 expertise. Next slide, please.
5 So, on the left side of this slide is an 6 artist rendering of the proposed action. And on the 7 right side is a diagram. It's the same diagram that 8 I showed you on the last slide.
9 The picture on the left is the area 10 circled in red on the diagram on the right, represents 11 the current licensing action, which is to build Phase 12 1 of the spent fuel storage facility.
13 So, if licensed, Holtec would be granted 14 a license to build and store five hundred canisters 15 of spent fuel. The additional support buildings, 16 transfer facilities, and rail line are also included 17 in Phase 1 of the impact analysis.
18 However, Holtec has stated its intention 19 to apply for amendments for up to 20 phases, which is 20 represented by these, the rectangular boxes in the 21 diagram.
22 So, at full build-out for all 20 phases, 23 the area would cover 330 acres. Next slide. Okay.
24 Next slide, please.
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22 1 So as I mentioned, the proposed project 2 would be an in-ground, low profile design. On the 3 right is a similar design used for spent fuel to give 4 you some perspective.
5 The proposed project would use a HI-STORE 6 Umax system for the storage of spent fuel. HI-STORE 7 Umax stands for Holtec International Storage Module 8 Underground Maximum Capacity.
9 Each one of these modules will hold one 10 canister of spent fuel. Next slide, please.
11 Okay. So, to give you some perspective, 12 we're looking again at an artist rendering of Phase 13 1 or the proposed licensing action.
14 So, this would include the five hundred 15 canisters of spent fuel stored in the underground 16 system using the Umax canisters. The Umax canister 17 however, is an engineered canister.
18 It's designed to passively cool and store 19 spent fuel for long periods of time. It's constructed 20 from stainless steel, and has been certified by the 21 NRC for storage of spent fuel at power reactor sites.
22 So this means that the manufacturing and 23 the design of the canister is engineered to meet NRC 24 requirements for safety. Those include structural NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 integrity, material integrity, and longevity.
2 The canisters contain spent fuel rods.
3 There's no liquid inside the canisters that could 4 leak into the environment.
5 The thickness and internal 6 characteristics are designed to prevent radioactive 7 material from escaping under normal and accident 8 scenarios. And that's achieved by using redundant 9 welded steel and a robust structural design.
10 The Hi-Store design, which is being 11 proposed in the current license application will 12 store the Umax canisters for an initial license term 13 of 40 years.
14 This means that the NRC is currently 15 evaluating the design for the facility to ensure that 16 the facility meets those requirements. Next slide, 17 please.
18 So, I've added this slide to help clarify 19 how we broke out the project in our analysis. And as 20 I mentioned earlier, the proposed action is Phase 1 21 or five hundred canisters of spent fuel.
22 As stated earlier, the applicant has made 23 it known that it has an intention, its intention to 24 request up to 19 additional phases in license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 amendments. These are referred to in our EIS as the 2 full build-out or Phase 2 through 20.
3 So the staff in its discretion decided to 4 evaluate all 20 phases of the project in its 5 Environmental Impact Statement. It's important to 6 understand the NRC is not licensing all 20 phases.
7 The decision to evaluate all 20 phases 8 was made by NRC staff to provide additional 9 perspective to the environmental impact.
10 Finally, the staff evaluated the project 11 in stages, construction, operation, decommissioning.
12 And that's because each of these stages has unique 13 environmental impacts.
14 So when appropriate, the staff evaluated 15 the maximum impact for combined stages for different 16 phases of a project.
17 So for example, the staff may have 18 evaluated the construction stage for Phase 2 in 19 conjunction with the operation stage of Phase 1, 20 because this would represent the peak impact to a 21 particular resource. Okay, next slide, please.
22 We can just go and cover some of the 23 public scoping comments. Next slide, please.
24 NRC opened the scoping period in March NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 2018. And during that time, held one webinar and 2 five in-person meetings.
3 We received 66, almost 67 hundred pieces 4 of correspondence and 39 hundred unique comments.
5 After the scoping period ended, we did review all of 6 those comments and document them, and responded to 7 those.
8 And that scoping report is available on 9 the NRC's docket and website. Next slide, please.
10 So, a lot of the comments we received 11 during the scoping process had to do with 12 transportation, location, geology, the volume of 13 material, water resources, socioeconomic, the EJ, and 14 of course, external events, flood and fire.
15 We also received comments on items like 16 potential flooding, compatibility of the Umax system, 17 design of structural elements, potential for extreme 18 hazards.
19 And now as you can see from the earlier 20 slide, these are out of scope from the environmental 21 review, but our safety reviewers are evaluating the 22 facility for many of these issues. Okay. Next slide, 23 please.
24 So, now we're just going to talk a little NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 bit about the results of the NRC's environmental 2 review and the draft EIS. Next slide, please.
3 So staff evaluated a 40 year licensing 4 term. And the spec -- so, with the assumption that 5 the spent fuel would be removed before any 6 decommissioning stage would begin.
7 The staff impact analy -- evaluation 8 characterized the groundwater at the facility and 9 evaluated storm water overflow or runoff to nearby 10 playas or lakes. Next slide, please.
11 For transportation and accident, the 12 staff evaluated traffic and road degradation from 13 workers and construction vehicles during all stages 14 and phases of the project.
15 Staff evaluated the movement of the 16 entire 20 phases of material, or 10 thousand casks 17 using conservative, representative routes.
18 Radiological doses and health effects to the public 19 and workers along the route were conservatively 20 estimated, and found to be low relative to background 21 radiation and expected baseline cancer risk.
22 Impacts from transportation accidents 23 evaluated doses to first responders, workers, and 24 members of the public. NRC rules require spent fuel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 transportation canisters to withstand severe accident 2 conditions.
3 So, an assumption of no release during 4 accidents was used during staff's analysis. Previous 5 NRC technical analyses involving spent fuel in 6 canisters support this no release assumption.
7 Land use at the location of the facility 8 was also evaluated by staff. The location of the 9 facility was proposed by the applicant, but the staff 10 evaluated the applicant's site selection process.
11 It also evaluated the land use within a 12 six mile radius of the facility. Next slide, please.
13 So, there's a typo on this slide. And 14 it's the last bullet. And it should be 15 disproportionately high and adversely affected by, 16 dash. And so on the left side, there's a typo there.
17 So the environmental justice impact 18 evaluated the impact on human health and the 19 environment using well-known guidance from the 20 Council on Environmental Quality, the Federal 21 Interagency Working Group on Environmental Justice 22 and NEPA, and NRC's Guidance and Policy Statements.
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28 1 that include between six hundred and three thousand 2 people. And those are within the ten counties that 3 fall either completely or partially within a 50 mile 4 radius of the CISF.
5 So staff identified potentially affected 6 minority and low income populations, and performed 7 the relevant comparisons to the broader geographical 8 regions.
9 Socioeconomic impacts were evaluated 10 based on workers, tax revenues, and resource 11 availability for the community.
12 Tax revenues and economic growth from the 13 proposed project and from the additional workers in 14 the area, were evaluated for impact, including use of 15 public services, schools, housing demands, and that's 16 all due to the increase pop -- the increased 17 population in the region. Next slide, please.
18 Okay. So, the next two slides tabulate 19 the results of the environmental review and the draft 20 EIS. We summarized it as the proposed action of Phase 21 1 or five hundred canisters.
22 And separately, the additional phases 23 that maybe requested in amendments going forward.
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29 1 they're identified as additional Phases.
2 On this slide you can see that most of 3 the impacts are small except for ecology. Next slide, 4 please.
5 So this is a continuation of the summary 6 of the impacts. And here you can also see that most 7 of the impacts are small except for in waste 8 management, they're small to moderate and 9 socioeconomic.
10 And those are -- this is just a summary 11 of the details from the EIS. Okay. Next slide, 12 please.
13 So, this is where you can go to get 14 information. The draft Environmental Impact 15 Statement is available online.
16 There's also readers' guides that are 17 available in Spanish and English. Those are about 20 18 page summary documents. It's a place to start.
19 And if you want to explore all of the 20 application material, you should go to the NRC's 21 project website. And that has all of the information.
22 That's where the transcripts will be posted. And has 23 all the safety information.
24 I should mention that the transcript from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 the last two meetings will be posted on that website 2 probably by tomorrow. But they're also, they're 3 already available publically on the NRC's ADAMS.
4 So, I think Jose, you -- can you post the 5 number for ADAMS?
6 MR. CUADRADO: Yeah. Sure.
7 MS. CAVERLY: Okay. Okay, so next slide, 8 please. Okay. So how to comment. Today we're 9 recording your comments.
10 We have a court reporter on the line. So 11 we will, it gives us comments in the transcript, and 12 we will evaluate all the comments provided here.
13 You can also make your comments at the 14 Federal Rulemaking Website, Regulations.gov. You can 15 mail the comments to the NRC through regular mail, or 16 you can email comments to Holtec-CISFEIS@nrc.gov.
17 So, the comment period is ending in about 18 20 days. So, we ask that you provide your comments 19 in the next three weeks, two -- three weeks, almost 20 three weeks, so that we can address them in the final 21 EIS.
22 So with that, I think I'm finished. And 23 we can move onto the public comment portion.
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31 1 much, Jill.
2 And Olin, we're ready to hear from the 3 public. So, if you could, you could put the first 4 speaker on for us, please?
5 OPERATOR: Thank you. For the question 6 and answer session, I want to give a quick reminder.
7 If you'd like to ask a question, please 8 press star one, unmute your phone, and record your 9 name clearly. Your name is required to introduce 10 your question.
11 If you need to withdraw your question, 12 you may press star two. Again, to ask a question, 13 please press star one.
14 Our first question is going to be coming 15 from Jack Edlow. Mr. Edlow, your line is now open.
16 MR. EDLOW: Thank you very much. And 17 good morning to all. First of all, I would like to 18 say that I support the draft EIS.
19 And I am going to discuss transportation 20 issues since that's my business. I'm involved in the 21 transportation of radioactive cargos worldwide.
22 Now, there are lots of different kinds of 23 hazardous materials in the world. Thousands and 24 thousands of items.
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32 1 They range from Classes 1 through 9. For 2 instance, Class 1 is explosives. Class 2 is gases.
3 A Class 3 is flammable liquids.
4 Well, Class 7 is for radioactive 5 materials. And in that class there are many forms of 6 radioactive materials as well. Things like empty 7 packages, things like fissile materials, things like 8 natural materials.
9 And of course spent nuclear fuel as well, 10 is one type of radioactive material within the 11 framework of the general hazardous materials.
12 So, there are lots and lots of shipments 13 of hazardous materials. All kinds of things on road, 14 and rail, and air, and sea, and also by pipeline.
15 And there's lots of forms of radioactive 16 material. Many, many, many shipments every day.
17 Millions a year, and most are for radiopharmaceutical 18 use.
19 But, spent nuclear fuel also has a lot of 20 experience. And, I think, based on a lot of the 21 comments I've heard in last calls, I'm not sure it's 22 quite understood how much experience has been 23 obtained in the United States for shipping spent 24 nuclear fuel.
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33 1 So in the United States, I'm certainly 2 aware that it's been shipped as far back as 1963, 3 because that's the first year that my father, Sam 4 Edlow, made a shipment, which came from Sweden.
5 It was an Atoms for Peace return shipment 6 from Sweden via the Port of Savannah. And then by 7 rail to the Atomic Energy Commission facility in 8 Idaho.
9 And so since that time, there's been 10 many, many other shipments to reprocessing plants 11 that operated at West Valley, New York, and Morris, 12 Illinois also received many shipments.
13 There were utilities made intra-utility 14 shipments between power plants for a variety of 15 reasons. Many, many, many research reactors at 16 universities all around the country have made 17 shipments back to the Department of Energy.
18 The Navy of course has had a major 19 nuclear program and has moved fuel around coming off 20 their vessels, back to storage and disposal in Idaho.
21 And of course, 40 or 50 research reactors 22 around the world under Atoms for Peace have returned 23 spent nuclear fuel to the United States.
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34 1 other shipments. Japan had large numbers of 2 shipments to France and to England.
3 And within France there were daily 4 shipments. Within the UK there were daily shipments 5 for many years. And you know, other nuclear nations 6 also make spent fuel shipments.
7 So, there have been many thousands of 8 shipments over 60 years. And in the United States 9 now, we probably ship spent nuclear fuel on a weekly 10 basis.
11 Last, in the last two years, Edlow has 12 made approximately 100 shipments. Not always on a 13 weekly basis. Sometimes multiple times in a week.
14 But, there have been large experience here.
15 So, the routes that we use are planned in 16 conjunction with the Department of Transportation, 17 with NRC, and under state guidance as well. So, this 18 is not done without the knowledge and consent of the 19 state, and advice of the state.
20 And of course the states are informed 21 prior to every shipment of spent nuclear fuel. So, 22 they are aware of what's going on.
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35 1 exist.
2 They are changed. They are flexible.
3 They have to deal with the various items, and kinds, 4 and situations that occur.
5 So, my summary, I would say, I believe 6 that the transportation of spent nuclear fuel to the 7 proposed Holtec facility can be managed within the 8 United States both safely and securely.
9 And for that reason, I thus, I support 10 the draft EIS. Thank you very much.
11 MR. CAMERON: Thank you, Jack. That was 12 a helpful, a helpful tutorial.
13 And we're going to go onto the next 14 speaker. Olin, who do we have next?
15 OPERATOR: Our next is Cynthia Wheeler.
16 Ms. Wheeler, your line is now open.
17 MS. WHEELER: Hello. Can you hear me?
18 MR. CAMERON: Yes. We can Cynthia.
19 MS. WHEELER: Thank you. My name is 20 Cynthia Wheeler. I am from Santa Fe and grew up in 21 Roswell. I'm again making these comments under 22 protest.
23 The Agency has run them ineptly. There's 24 one thing that's done very effectively though and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 that is to make the public feel that it's talking 2 into a void. Sometimes I imagine NRC staffers 3 listening to the call in their offices while 4 leisurely painting their nails. Now understand that 5 I'm not accusing anyone of doing that, but the point 6 is I'll never know. You've lost my trust.
7 We have detailed many times the 8 following: We don't consent to burying this waste in 9 New Mexico. Our governor and congressional 10 delegation join us in that. The DEIS is amiss in 11 every category it addresses. Most of the impacts are 12 small, only if nothing goes wrong. And I fail to see 13 how the NRC could simply assume that nothing could go 14 wrong.
15 The geology is unstable for this kind of 16 long-term storage. It doesn't protect the Ogallala 17 and other water sources. It will have a negative 18 effect on the economy. No one wants to live near a 19 nuclear waste dump. Cattle and dairy growers, chili 20 and pecan growers, they all have a long history of 21 using this land. One accident will destroy that.
22 Transportation is the greatest hazard in 23 this plan and it is addressed almost not at all. A 24 recent study by a radioactive waste specialist NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 details all the hazards of using rails to move this 2 waste and you should pay close attention to it.
3 To respond to the first speaker just 4 before me, I need to say that Dr. Bob Alvarez, an 5 expert in dealing with nuclear waste systems, has 6 studied the shipment of high-level nuclear waste and 7 unequivocally states that we are not ready for 8 anything on this scale.
9 Holtec is a compromised company with 10 indictments for bribery and lying on applications 11 when asked if it had ever been banned from working 12 with government agencies, which it has. There is 13 some evidence that the bid for this job was arranged 14 so that Holtec was the only company that submitted a 15 bid.
16 And finally there's no compelling reason 17 except to accommodate Holtec for these meetings to be 18 rushed during the pandemic.
19 In response to the speaker at the 20 beginning of the meeting with the NRC, the solution 21 to a pandemic is not to hold the meetings virtually, 22 but to wait to hold the meetings when it is safer.
23 My parents' generation made this waste.
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38 1 proceeded with the incredibly foolish idea that 2 future technologies would find a way to store it.
3 One generation should never lay that burden on 4 another. Now my generation is doing the same thing 5 and no one has acknowledged the simple fact that no 6 new technology can change the laws of the physics of 7 radioactive decay occurring on a planet that moves 8 things around over long time scales. And it matters.
9 For example, one of the substances you 10 want to bury here is plutonium-239, half-life of 11 24,000 years. In 10 half-lives, which is about what 12 it takes for most of that substance to be decayed, 13 that's a quarter of a million years. But that's not 14 the end because plutonium decays into uranium-235 15 with a half-life of 700 million years. Ten of those 16 half- lives work out to 7 billion years, and the 17 planet hasn't even existed that long.
18 Now I'm sure you know that because it's 19 your job to know it, but we have to remember geology 20 101 which tells us that the earth is in constant 21 motion over long stretches of time. But if there's 22 one thing you can count on it's that the earth will 23 move, and the continents and oceans that we know have 24 moved dramatically. Lee County in Southeastern New NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 Mexico where Holtec wants to bury this waste is an 2 arid desert, but 250,000 years ago it was covered by 3 a shallow sea. No one can adequately explain how 4 deadly and toxic radioactive waste can be securely 5 and safely kept out of the environment we depend on 6 when it lasts so long that the environment will have 7 drastically changed while it's still deadly and 8 toxic.
9 The bottom line is that you don't want 10 inept companies and indifferent agencies handling 11 nuclear waste. I hope those who work at the NRC 12 realize that their job is different from every other 13 job, that the burden that they carry to protect the 14 public from this waste is heavy and that they not 15 forget it. And once again to quote Dr. Jonas Salk 16 who invented the polio vaccine, our greatest 17 responsibility is to be good ancestors. Thank you.
18 MR. CAMERON: Okay. Thank you for 19 joining us again, Cynthia, and for that quote from 20 Dr. Salk.
21 And, Olin, who do we have next?
22 OPERATOR: Our next is Jan Lundgar.
23 Ms. Jan, your line is now open.
24 MS. BOUDART: Is it -- are you talking to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 me? Is it my line?
2 OPERATOR: Yes, ma'am.
3 MR. CAMERON: I think it is.
4 MS. BOUDART: Oh, it's Boudart. B-O-U-5 D-A-R-T. Jan Boudart. And I would like a very short 6 response to Jack Edlow and to Cynthia Wheeler.
7 The first response to Mr. Edlow is that 8 his -- he deserves congratulations with his company 9 for -- oh, I've got this written down because I wrote 10 it for last time. I got the impression that Edlow 11 Nuclear Transportation Services is self-regulating, 12 and I think he showed that today. This seems to have 13 worked okay which is certainly a wildly improbable 14 exception, so he deserves to be congratulated. With 15 self-regulation commercial enterprises like Boeing 16 and Energy Harbor in --
17 MR. CAMERON: Jan, we seem to have lost 18 you.
19 (No audible response.)
20 MR. CAMERON: Oland, is there something 21 wrong with Jan's line or anything we could do?
22 OPERATOR: Unfortunately her line just 23 disconnected.
24 MR. CAMERON: Okay. Well, we'll see -- if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 she comes back on, please put her on so we could let 2 her finish her comments, but in the meantime can we 3 go to the next speaker?
4 OPERATOR: Absolutely. We have Elaine 5 Walker.
6 Ms. Walker, your line is open.
7 MS. WALKER: Hello. Is that me?
8 MR. CAMERON: Yes.
9 MS. WALKER: Okay.
10 MR. CAMERON: We hear you.
11 MS. WALKER: It's Kalene. Kalene Walker.
12 Let's see. Regarding the transportation, 13 these are -- never has this quantity of radioactive 14 isotopes been transported in one package. These are 15 -- there's a Chernobyl disaster worth of radiation in 16 each canister.
17 I make this comment with great -- I'm 18 greatly discouraged by the ability of the NRC to -- I 19 don't believe that they can properly manage the 20 nuclear industry, the combination of ISGs. Where 21 they can make Interim Staff Guidance regulation Title 22 X Part 72, Part 71 has been completely stripped of 23 their power through the process of ISGs, exemptions, 24 amendments and the 72.48 process. If you look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 what's happened at San Onofre with the Holtec system, 2 with Holtec loading the Holtec system, you'll see 3 what we have going on here.
4 I don't have my thoughts together well 5 enough to speak right now, but the NRC has only been 6 analyzing this for 40 years. This is like hundreds 7 of years you should be analyzing. Where is your 8 ability to repackage this stuff? When are you going 9 to require a hot cell? These canisters, they can 10 have leaking helium. There's no contingency plan if 11 a canister drops and the fuel is damaged. There's no 12 facility in the United States capable of handling 13 this.
14 The fact that Holtec is not even thinking 15 that that's a requirement, the whole thing is so 16 egregiously irresponsible. I'm wondering what is the 17 mentality, what is the reason? Do people think that 18 the nuclear waste likes to be stored all clustered 19 together, that all the canisters want to be stored 20 together? Why would you move all of this stuff across 21 the country so it can all be clustered together?
22 There's absolutely no need for such a massive 23 dangerous project. There is -- the lack of 24 responsible oversight on this is egregious and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 dangerous. Period. Thank you.
2 MR. CAMERON: Thank you, Kalene.
3 Olin, who is next?
4 OPERATOR: We have Rose Gardner.
5 Ms. Gardner, your line is now open.
6 MS. GARDNER: Thank you. I am Rose 7 Gardner from Eunice, New Mexico. I'm with the 8 Alliance for Environmental Strategies. I am making 9 comments under protest today. The Alliance for 10 Environmental Strategies strenuously opposes the 11 Holtec International Project for CIS. The National 12 Waste Policy Act does not allow for this license to 13 be issued to any privately-owned corporation to take 14 the high-level waste from commercial reactors.
15 The failure of the NRC to satisfy the 16 public with these poorly-run and moderated webinars 17 are an example of government waste, as usual.
18 I would like to invoke my friend's name.
19 His name is Noel Marquez. He is from Artesia, New 20 Mexico. He is a co-founder of the Alliance for 21 Environmental Strategies. He is a well-known 22 community artist and activist. He was instrumental 23 in helping pass the Lake Arthur, New Mexico 24 resolution against Holtec.
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44 1 The last time I saw Noel speak in public 2 was at the NRC scoping meeting in Carlsbad. He was 3 rudely interrupted by the moderator Chip Cameron. He 4 was not allowed to finish his comments. Fortunately 5 people opted to give him their time so he could finish 6 his comments. Well, folks, he can't speak anymore.
7 He can't speak against Holtec. He is physically 8 unable to do so. So I will speak for him.
9 He opposes this Holtec project and is 10 against the process which targets our Hispanic 11 community with disgraceful and dangerous projects 12 like WIPP, Holtec, Urenco, Waste Control ISP, and 13 others. I would ask that the NRC give one minute of 14 silence and recognize those that are unable to speak 15 and to comment to you today or any day, like my friend 16 Noel. Thank you.
17 MR. CAMERON: Thank you, Rose. Sorry to 18 hear about Noel, and we will gladly give one minute 19 of silence to anybody who is unfortunate to have a 20 physical malady such as Noel. So we're going to start 21 one minute now. And I'll time it and then I'll go 22 back to the operator.
23 (Moment of silence.)
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45 1 you.
2 Thank you, Rose.
3 And, Olin, who do we have next?
4 OPERATOR: Our next Paul Blanch.
5 Mr. Blanch, your line is now open.
6 MR. BLANCH: Good morning. Can you hear 7 me?
8 MR. CAMERON: Yes. Hi, Paul.
9 MR. BLANCH: Hi. Is that Chip Cameron I 10 hear?
11 MR. CAMERON: That is. That's me. That's 12 correct.
13 MR. BLANCH: God, I haven't seen you for 14 a long time.
15 Anyway, my name is Paul Blanch. I reside 16 in West Hartford, Connecticut. I have more than 50 17 years nuclear experience. I'm a registered 18 professional engineer. I am an expert, a system 19 expert for a group, public interest group surrounding 20 the San Onofre Nuclear Power Plant. I have studied 21 extensively not only the regulations, but also the 22 technical details associated with the Holtec UMAX 23 canisters, and I have worked with headquarters, with 24 Andrea Koch and other people.
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46 1 We have petitions submitted, FOIA 2 requests submitted. But I thought this was an 3 opportune time to get two of my concerns on the 4 record. And these are concerns that have never been 5 raised before that I am aware of. And this involves 6 not only the environmental impact, but also the 7 safety aspects of the Holtec system design as it may 8 impact the storage in New Mexico. And I've been 9 through this time and time again. I was through it 10 this morning in a report I got that was posted to 11 part of this meeting.
12 And that concern, my first concern is 13 helium. Inside the multipurpose canister, which is 14 half-inch to five-eighth-inch thick stainless steel 15 -- it contains fuel up to somewhere around 37 to 45 16 kilowatts of heat being generated and is surrounded 17 by helium pressure, and that pressure is in the range 18 of anywhere from 45 to 100 pounds depending on the 19 temperature.
20 I have researched -- the concern that 21 many of us have is what is the impact of helium 22 leakage? Helium is used to isolate the fuel, to 23 prevent corrosion, but also it's a heat transfer 24 medium to allow the heat transfer from the fuel to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 the environment. So I ask myself the question what 2 happens if we lose helium pressure?
3 Now this is only five-eighths of an inch 4 thick max. If we remember many years ago where six 5 inches carbon steel hole eroded through the head of 6 a reactor. We know these things age. Being an ex-7 Navy person I'm familiar with the Thresher and the 8 Scorpion. We know those reactor vessels, even though 9 they're six inches thick stainless steel, they have 10 been breached.
11 Now when I go through the licensing 12 documentation, I come upon the most incredible 13 statement that I think I've seen in licensing 14 documents, and I ask myself and I ask the NRC what 15 happens if we lose helium? What happens to the 16 radioactive releases? What happens to the fuel 17 temperature?
18 As I review those documents in many 19 places, including the document that we're talking 20 about today, it says that helium leakage is a non-21 credible event. What this is saying is the NRC 22 somehow has determined that it's impossible for 23 helium to leak out.
24 Now it takes me to Interim Staff Guidance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 No. 18, which is helium leak rate testing, which only 2 tests the welding at the top of the canister to make 3 sure that weld has high integrity. The fact that the 4 NRC somehow has determined that five-eighth-inch of 5 stainless steel leakage is incredible given the 6 experiences we've had with materials and six-inch 7 reactor vessels and so on and so forth, the fact that 8 is incredible, and they claim that issue is addressed 9 in ISG-18, it is not. The NRC is not being 10 forthcoming in their statements.
11 I have asked Andrea Koch for the basis 12 for the NRC to determine -- and Holtec to determine 13 that this is an incredible event, not possible, not 14 possible in a million years with a million canisters.
15 This is ludicrous from a practical standpoint, from 16 an engineering standpoint and I wouldn't want to be 17 around these when we don't even consider the breach 18 of a canister. Not only that, we don't know what the 19 temperature of the fuel will be and we don't know 20 what the radioactive releases will be; not if, but 21 when these canisters are breached.
22 That is a very, very serious issue. To 23 my knowledge it has never been brought up before. I 24 obviously am pursuing it. This will impact every NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 canister whether it be the UMAX canister or above-2 ground canisters. There is an impact if you lose 3 helium.
4 My second issue is a little more subtle 5 and that has to do with the location. If I look back 6 at some of the NRC licensing documents, which I have 7 in front of me on my computer, has to do with natural 8 gas pipeline hazard risk determination. This is a 9 study that is done by -- let me get it here 10 -- Framatone ANP. I have a document number. I don't 11 have the ML number. But basically -- and I have a 12 lot of experience with gas lines in the proximity of 13 nuclear facilities.
14 What this study states -- and this is 15 discussed also in the application. But this study 16 states here; and I'll gladly provide the NRC with a 17 copy of it, that a 16-inch gas line located 1.8 miles 18 away from a nuclear enrichment facility, which is a 19 low radioactive material containment, is 20 unacceptable. Now we have many gas lines where this 21 new facility is being proposed, and there are some 22 analysis within the FSAR and Environmental Impact 23 Statement.
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50 1 have an NRC approved study that says it's 2 unacceptable and all of a sudden because of the need 3 it becomes acceptable. It's just incredible to me.
4 And we've had a recent Inspector General report on 5 this gas line issue. It was issued in February of 6 this year. And now the NRC has put out false 7 information, to me.
8 So those are my two comments and I'd like 9 to have them formally considered. I will continue 10 working with headquarters in Region IV on those 11 issues, but I want this issue on the table. And again 12 I am a professional engineer and Chip Cameron and I 13 have known one another and have a mutual respect for 14 one another, and I'm sure that Chip will assure that 15 we get a resolution to this. Thank you very much.
16 MR. CAMERON: Thank you. Thank you, 17 Paul. And I just want to just affirm that mutual 18 respect. And thank you for those specifics. And if 19 there's some documents that you could submit on this 20 to the NRC, that would be great. And I hope you're 21 well.
22 MR. BLANCH: I am very well. I've never 23 been better, Chip.
24 MR. CAMERON: Fantastic. Fantastic.
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51 1 Olin, who is our next speaker?
2 OPERATOR: We have Barbara Warren.
3 Ms. Warren, your line is now open.
4 MS. WARREN: Good afternoon. My name is 5 Barbara Warren. I'm a registered nurse with a 6 master's degree in environmental health science and 7 Executive Director of Citizens' Environmental 8 Coalition, which is based in the State of New York.
9 Our organization and our members are very concerned 10 about the weak plans for consolidated interim storage 11 as well as the fact that required transportation has 12 not been adequately studied.
13 Today I want to discuss a particular 14 topic. We will be providing detailed comments later 15 on before the 22nd, but today I want to discuss 16 entropy.
17 NRC has concluded that there will 18 primarily be small impacts associated with the Holtec 19 CIS proposal. The law of entropy or the second law 20 of thermodynamics along with the first of 21 thermodynamics comprised the most fundamental laws of 22 physics. Entropy is the subject of the second law 23 and energy is the subject of the first law and their 24 relationship are fundamental to an understanding not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 just of physics but of life. The law of entropy tells 2 us that disorder always increases. It tells us that 3 anything and everything will always move from order 4 to disorder.
5 Significant energy is required as a 6 result to maintain the order that is absolutely 7 necessary to prevent the dispersal of long-lived 8 radionuclides into the environment and into human 9 beings. Human and organizational failings, 10 inadequate budgets and other priorities always limit 11 our collective ability to successfully contain 12 radioactivity and prevent public exposure. Effects 13 on future generations are an example of 14 intergenerational injustice.
15 As a nation we have failed at achieving 16 the required isolation and are paying the price at 17 many nuclear facilities around the country. WIPP, 18 Hanford and Savannah River are just a few of the 19 hundreds of sites that collective need thousands of 20 years of work just to temporarily contain and limit 21 the dangerous disorder that the law of entropy 22 guarantees at these sites.
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53 1 nuclear fuel, one of the most hazardous substances on 2 earth according to the U.S. Government Accountability 3 Office. Unfortunately NRC has thus far demonstrated 4 that will only offer weak requirements and oversight 5 of a very dangerous and potentially catastrophic plan 6 for large quantities of spent nuclear fuel. We are 7 collectively very afraid. Thank you.
8 MR. CAMERON: Okay. Thank you, Barbara.
9 Very interesting about entropy. Thank you for 10 bringing that up.
11 And, Olin, can you put the next speaker 12 on, please?
13 OPERATOR: Absolutely. Michelle Lee.
14 Ms. Lee, your line is now open.
15 MS. LEE: Am I now being heard?
16 MR. CAMERON: Yes.
17 MS. LEE: Okay. Great. So I'd like to 18 just talk briefly on a personal level and then bounce 19 off some of the notes that Paul Blanch raised. And 20 I'm glad he gave me the intro there.
21 But on the personal level, I really never 22 paid attention to nuclear as an issue even after I 23 was in the Soviet Union four years after Chernobyl 24 and spoke to people there. Now that might have given NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 me pause, but I had such confidence in the American 2 regulatory system.
3 I spent my first decade professionally as 4 a litigator and did Pentagon procurement fraud cases, 5 so I have very deep understanding of the frailties of 6 human beings and what you -- is nicely called the 7 human factor. And as astonishing as it always was to 8 me that corporations would engage in deceit and fraud 9 and neglect when it came to the lives of American 10 service men and women, I still believed very much 11 that the regulatory system in this country was 12 robust.
13 I then went for an advanced degree and 14 became an investigator. After 9/11 I took a three-15 month leave of absence to work on issues relating to 16 Indian Point and never went back because; and that's 17 the only reason, because my absolute astonishment of 18 how abysmal the regulatory scheme is and frankly how 19 influenced the NRC is.
20 And when I talk about influence, I'm 21 really talking about the political appointee level, 22 but that percolates down to every single level of the 23 NRC. And it's not an issue of -- it's something we've 24 seen in many, many other areas, but the difference is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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55 1 when you're talking about nuclear power and nuclear 2 waste, the consequences of undue influence are 3 drastic and potentially catastrophic.
4 There are I know -- I have spoken to many 5 people over the years at the NRC. There are many of 6 you who are working as hard as you can to protect the 7 public and to press against the pressure that you're 8 getting from the industry. I am going to implore you 9 to press harder. Do it internally, but press harder 10 because this whole scheme of nuclear waste 11 transportation and storage in states that are full of 12 gas pipelines and other gas/fossil infrastructure, as 13 well as how being incredibly vulnerable to wildfire, 14 heat wave, drought -- it's absolute sheer insanity.
15 Going to the second point and to build 16 upon more of what Paul said, over the years looking 17 and going -- I went very much in depth into the 18 background literature involving this Holtec site in 19 New Mexico. Much of what the NRC relies upon is 20 outdated. It's outdated standards. It's ASME 21 guidelines that were around decades ago.
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56 1 Mexico and Texas with this enormous amount of extra 2 heat, the potential for dust storms, potential for 3 out-of-control wildfires, the potential for first 4 responders to not be able to mitigate an event. And 5 of course those kinds of risks are attendant all over 6 the country in the transportation scheme which is 7 variable -- a wide variety of weather events, a wide 8 variety of natural disasters and the idea that this 9 massive transportation of material that can 10 absolutely wipe out the vitality of a large region 11 overnight.
12 And again, I go back to my experience in 13 the Soviet Union after Chernobyl. The ability that 14 -- that that risk is not taken into consideration, 15 all the unknowns are not taken into consideration, 16 that future terrorists is not being taken into 17 consideration, that human error, gross human error 18 and frailty is not taken into consideration I find 19 astonishing and I again beg those of you within the 20 Agency to not allow this to happen. Do whatever you 21 can. Press -- push back. Thank you.
22 MR. CAMERON: Okay. Thank you. Thank 23 you, Michelle. Thank you for that encouragement.
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57 1 please?
2 OPERATOR: Absolutely. We have Jan 3 Boudart.
4 The line is now open.
5 MR. CAMERON: Oh, good.
6 MS. BOUDART: Hi.
7 MR. CAMERON: Welcome back, Jan. Welcome 8 back.
9 MS. BOUDART: Thank you. I don't know 10 where I dropped out. I very enthusiastically gave my 11 report and then realized that I was no longer being 12 heard. And is there any possibility that the person 13 who is doing the recording could let me know where I 14 dropped out?
15 MS. CAVERLY: Can we do it from the start 16 again?
17 MR. CAMERON: Well, you know what, in 18 order to have some context here, you didn't -- you 19 weren't on very long when you dropped off, so, Jan, 20 would you mind just go from the start and take your 21 time and then we'll get the whole coherent piece in.
22 Okay?
23 MS. BOUDART: Okay. So I'm trying to 24 reconstruct it. I was making a comment on Section NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 3.12.3, the radiation protection standards in the 2 IES. And I jumped -- I had something to quote from 3 that part of the IES, but I was afraid it would take 4 me too long if I tried to quote everything. So I 5 jumped to line 14 on page 3-97, Exposures to Radiation 6 Present an Additional Risk of Cancer or a Severe 7 Hereditary Effect. And I added -- that is a quote.
8 And my own part is or heart, lung, kidney, stomach, 9 intestine, cataract, arthritis, hearing loss, nerve 10 damage, capillary damage, et cetera. The failure to 11 acknowledge other than cancer diseases is a major 12 omission from this section.
13 And then on line 15 of the same page, I'm 14 quoting, the annual dose limit of the International 15 Atomic Energy Agency as well as the NRC set to protect 16 members of the public from the harmful effects of 17 radiation is one millisievert, which is 100 millirem, 18 period. The additional risk of fatal cancer 19 associated with a dose of one millisievert calculated 20 using the scientific methods of the International 21 Commission on Radiological Protection.
22 And I interrupted that sentence with my 23 own response, which is this is the biggest testimony 24 that we should stop making rad waste and this project NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 is designed to justify our not ceasing to produce 2 spent fuel.
3 My response to Mr. Edlow, because that 4 was -- I missed Paul's -- most of Paul's, which I'm 5 very sorry about, but I'll pick it up in the 6 transcript. I had a response to Edlow and Wheeler 7 today. More information on the ICRP protection 8 analysis should be given. The ICRP from 2007 is 9 referenced, but I looked up the ICRP from 2000 and 10 found much material including what I was looking for, 11 but a major omission of internal dose.
12 Internal dose is a problem rarely treated 13 and much more serious consideration than external 14 dose. Internal dose is measured by monitoring the 15 body itself and is often given in a different unit, 16 the becquerel per kilogram body weight, a reference 17 to other diseases and references to non-reference man 18 individuals like fetuses and pregnant women. And I 19 got this from the ICRP, quote, reference animals and 20 plants.
21 So they don't mention reference man, but 22 there was this quotation on page 56: Quote, the 23 strongest statistical evidence for the induction of 24 these non-cancer effects at affected doses of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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60 1 order of one sievert derived from the most recent 2 mortality analysis of the Japanese atomic bomb 3 survivors followed after 1968. And there's a 4 reference. That study has strengthened the 5 statistical evidence for an association with dose 6 particularly for heart disease, stroke, digestive 7 disorders and respiratory disease.
8 A few lines later we get this: Quote, it 9 is also unclear what forms of cellular and tissue 10 mechanisms might underlie such a diverse set of non-11 cancer disorders. While recognizing the potential 12 importance of the observation of non-cancer diseases, 13 the Commission; and I guess that's the ICRP, judges 14 that the data available do not allow for their 15 inclusion in the estimation of detriment following 16 low-radiation doses less than about 100 17 millisieverts.
18 A millisievert is one one-thousandth of 19 a sievert, and 100 of those is one-tenth of a sievert.
20 This agrees with the conclusion of UNSCEAR of 2008 21 which found little evidence of any excess risk below 22 one gray. End of quote.
23 Okay. Do you want to look up their new 24 unit and try to visualize the relationship between a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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61 1 gray and a sievert, a millirem or a millisievert? My 2 point -- I've done this. I've tried to figure this 3 out and it is really an imbroglio to try to go into 4 these units and decide what the heck they're talking 5 about.
6 My point, the nature of the EIS is so dry 7 it is devoid of real caring about the subject who 8 will be given low-dose, long-lasting radiation. I 9 feel this way about Mr. Edlow of Edlow Nuclear 10 Transportation Services' testimony from August 26th.
11 He emphasized the success of his company, the lack of 12 accidents and the NRC has adequately -- and said the 13 NRC has adequately addressed the transportation 14 issue. There was no acknowledgement of the effects 15 of low-level, long-term radiation.
16 In addition, I got the impression that 17 Edlow Nuclear Transportation Services is self-18 regulating. This seems to have worked okay, which is 19 certainly a wildly improbable exception, so he 20 deserves to be congratulated with self-regulation of 21 commercial enterprises through Boeing, Energy Harbor 22 in Ohio, Exelon in Illinois or any nuclear utility.
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62 1 unknown results for self-regulation.
2 So my basic point -- well, let's see.
3 The ICRP 2000 applying a linear no-threshold dose 4 response assumption is on the order of one in 20,000.
5 Oh, here's what I wanted to day. This 6 -- they say that one in 20,000 people will get a 7 cancer, and 500 of those will get a fatal cancer.
8 Now I'm assuming that they're talking 9 about reference man. If you take this reference man 10 at that time and place and you take 10 -- you take 11 little boys at the same time and place, for every two 12 reference man who gets a cancer, five of those little 13 boys will get a cancer. I had this wrong the last 14 time I testified, and I do apologize. I had doubled 15 it.
16 But for two reference men getting a 17 cancer five little boys will get a cancer. And for 18 two reference men getting a cancer 10 little girls 19 will get a cancer. Nobody knows the number of 20 stillbirths or fetuses born with hereditary problems 21 or just problems in their own little bodies. These 22 things are not really measurable, but we know they 23 are a lot. So this small increase in lifetime risk 24 can be compared to the baseline lifetime risk of one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 in three for anyone developing cancer and one in five 2 for anyone developing a fatal cancer.
3 Okay. Let's see. I think that's about 4 all I have to say about the inadequacy of Section 5 3.12.3. And of course my basic point, and I think 6 everybody who is looking at this understands we have 7 to stop making high-level radioactive waste. We have 8 to stop making spent fuel because the interim storage 9 facility in New Mexico is a method where we can get 10 it out of sight and continue making it. We need a 11 different solution that includes the end of the 12 production of spent fuel.
13 Are you still hearing me?
14 MR. CAMERON: Yes, Jan. And I just want 15 to thank you for all of that very complicated 16 -- explaining what seems very complicated. But thank 17 you for coming back on and talking to us. And we're 18 going to go --
19 MS. BOUDART: Before I go I want to thank 20 you for letting me back on. I just didn't -- I did 21 this whole thing and then I realized nobody could 22 hear me. So anyway, I'm very glad that you let me do 23 it. Thank you.
24 MR. CAMERON: Thank you.
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64 1 Olin?
2 OPERATOR: Our next caller is going to be 3 Ed Hughes.
4 MR. HUGHES: Hello? Can you hear me?
5 MR. CAMERON: Yes.
6 MR. HUGHES: Good morning. Well, it's 7 still morning here. I guess it's afternoon there.
8 I want to -- I have spoken at each one of 9 these -- this is the fourth of a series of -- I've 10 made comments, different comments at each one. I 11 have -- I want to make a comment basically addressed 12 -- that has been addressed by the New Mexico 13 Environmental Department. I'm quoting a letter, 14 parts of a letter, May 18th, 2020. This is actually 15 through the National Nuclear Security Administration.
16 It's not the Nuclear Regulatory Commission. But it's 17 from James Kenney, Cabinet Secretary of the New 18 Mexico Environmental Department.
19 But parts of this letter, it's talking 20 about the Environmental Impact Statement for a 21 statement of pit production. That's not this topic 22 of today, but this letter very much addresses the 23 Environmental Impact Statement there and I know the 24 Environmental Department made some of the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 comments concerning the EIS we're speaking about 2 today.
3 First of all I would like to say I just 4 wholeheartedly support the comments that have been 5 made thus far concerning opposition and problems with 6 the EIS. These are issues that have been discussed 7 among many of us to various degrees and I really 8 appreciate those who have come on and very adroitly 9 addressed these things thus -- so far today.
10 As far as the transportation issue which 11 is supposedly out of scope by the slides that were 12 shown this -- earlier, that's very much part of this 13 environment -- possible impacts and I -- there's 14 nothing in the scope that is being proposed by Holtec 15 that's ever been done about any nuclear materials. I 16 heard the -- everything else has been much, much 17 smaller, a much smaller scale. This is just orders 18 or magnitude.
19 But I want to go to this letter from the 20 Environmental Department, point 4. If there's given 21 a disproportionate burden of public health and 22 environmental risk that the State of New Mexico bears 23 related to nuclear energy and weapons programs. This 24 is being addressed -- this is somewhat historical, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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66 1 but it very much pertains to what we're talking about.
2 Goes onto say: Uranium mining and 3 milling, legacy contamination at national 4 laboratories, disposal of Defense waste at WIPP and 5 the proposed indefinite storage of commercial spent 6 nuclear fuel has long created risks to public health 7 and the environment in the State of New Mexico that 8 are disproportionate greater than such risks to the 9 general population of the United States. And I think 10 that this proposal just magnifies the risk that is 11 being put upon the state.
12 Part of this, there was -- in the slides 13 that were shown it was shown that the -- as far as 14 socioeconomics that there was low risk, all that sort 15 of -- stating that it's low doesn't make it so, but 16 health risks are part of that. And part of that has 17 to do with the demographic data.
18 I want to -- in the United States 19 Hispanic or Latino populations average about 18 20 percent; in New Mexico, 49 percent. American Indian 21 in the United States about 1.3 percent; in New Mexico, 22 10.9 percent. Persons in poverty 11.8 percent; New 23 Mexico 19.5 percent, almost 20 percent. There is a 24 process that goes on that's called pollution shopping NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 and it has to do with agencies or people who have 2 high polluting industries or products such as 3 -- nuclear waste is probably the most deadly -- and 4 go to areas that are high demographics and 5 populations such as Latino or Indian or persons in 6 poverty. They think they're more vulnerable, which 7 in fact they are, to these kinds of things. And 8 that's part of what's going on here in Southeastern 9 New Mexico.
10 And I want to go on -- talk about draft 11 -- the letter goes on to talk about failure to 12 demonstrate that the proposed action will achieve 13 environmental justice for the high percentage of 14 minority and low-income populations in the State of 15 New Mexico. They've already suffered 16 disproportionately high adverse human health and 17 environmental effects of the U.S. Department of 18 Energy programs.
19 Environmental justice deficiencies in 20 the Draft EIS. And this pertains to this EIS as well.
21 Failure to identify and evaluate the cumulative 22 history of adverse human health and environmental 23 effects on New Mexico's vulnerable populations.
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68 1 back to the Trinity site. It was -- it has been 2 documented that after the Trinity test in New Mexico 3 that death in the womb and infant mortality had a 4 very significant increase for the following year or 5 two. And that's not even talking about the impacts 6 of mining and all of the other things that have been 7 going on in New Mexico since that time.
8 There's also a failure to evaluate 9 release scenarios from the proposed action such as 10 transportation or storage that might adversely affect 11 vulnerable populations in New Mexico. Just from the 12 fact that this Environmental Impact Statement only 13 evaluated, quote, normal operation, which had no 14 -- nothing about cask failure or transportation 15 issues or human error, as has been so very well 16 brought up, makes this a laughable document in my 17 opinion.
18 To go on, there's also repeated yet 19 unsubstantiated assertions that cumulative 20 environmental impacts from the proposed action would 21 be either not notable or not expected. Saying that 22 that is the case does not make it true. And I think 23 that has already been pointed up today as well as in 24 earlier times that this action is ludicrous. This NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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69 1 -- what is being proposed is ludicrous.
2 I recently retired after 40-plus years in 3 the Federal Government and I know from my experience 4 that bureaucracies as such have no conscience. And 5 it's been stated at the very beginning of this that 6 there's already been -- the comment period has 7 already been extended once or twice or three times, 8 which clearly shows that this is purely 9 administrative. It can be extended again. It can be 10 put off until this 11 -- and to say that the COVID thing we're under right 12 now just kind of overrides any other consideration, 13 it's going to be very short is ludicrous.
14 Administratively you certainly -- the 15 Nuclear Regulatory Commission certainly has the 16 authority and the power to extend this comment period 17 as far as needed until we're past this crisis, until 18 we can have the in-person meetings, until we can do 19 the things that are -- that have been earlier agreed 20 to by NRC and have since been set aside.
21 So again I speak in opposition to what's 22 happening. This -- we have been pulled into this 23 game and it seems that it was stacked against us in 24 a very real way, those that oppose this.
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70 1 I just want to say too that it's been 2 mentioned -- I've been to not only the scoping hearing 3 a couple years ago, but been listening in on these 4 current hearings as well. I've talked about the 5 -- just the thing that New Mexico needs to do this 6 just out of supporting and out of just being a good 7 state. You know, we have paid our dues 8 in New Mexico. We have -- as has been stated by this 9 letter from the Environmental Impact Department, New 10 Mexicans; and I'm a third generation New Mexican and 11 my wife and I were both born and raised in New Mexico 12 -- we have paid our dues, more so, disproportionately 13 high than the rest of the country. So I think the 14 idea that the rest of the country, every other state 15 is adamant in getting rid of this waste, why in world 16 should we take the risk?
17 And how do you justify New Mexicans 18 taking the risk of all of this coming to New Mexico 19 on a, quote, interim storage, which Rick Perry when 20 he was Secretary of Energy said it's quite likely 21 going to be permanent storage, not built to the 22 specifications of Yucca Mountain, but an at-surface 23 interim storage, who is actual -- according to 24 Holtec's guarantee the casks themselves are only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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71 1 guaranteed for 25 years, and yet we're licensing for 2 40 and has -- we could go on and on, but this whole 3 process is extremely, extremely immoral in my 4 opinion.
5 And while bureaucrat -- the bureaucracy 6 doesn't have a conscience, I'm assuming as has been 7 spoken earlier by Jan, that many of you within the 8 NRC very much do. Push back. This needs to be 9 stopped by A real Environmental Impact Statement that 10 takes in all of the risks including that of failure 11 of many kinds needs to be analyzed. Thank you.
12 MR. CAMERON: Okay. Thank you very much, 13 Ed. And I hope you can submit that letter that you 14 mentioned from the New Mexico Environmental 15 Department to the NRC as part of --
16 MR. HUGHES: I'd be glad --
17 MR. CAMERON: -- your comments. Okay.
18 Thank you.
19 Olin, who do we have next?
20 OPERATOR: Next caller is Kevin Kamps.
21 Mr. Camps, your line is open.
22 MR. KAMPS: Thank you. Can you hear me?
23 MR. CAMERON: Yes, we can.
24 MR. KAMPS: Thanks. This is Kevin Camps, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 radioactive waste specialist at Beyond Nuclear and 2 Board of Directors member with Don't Waste Michigan, 3 and I am commenting on something that took place in 4 the last of these public comment webinar call-in 5 sessions. It was on August 26th, 2020. A commenter 6 named Nick Maxwell of We the Fourth in Hobbs, New 7 Mexico, who is a long-time Holtec CISF opponent, and 8 ELEA watchdog, raised an allegation of bribery 9 associated with this scheme, bribery and kickback.
10 Before allowing Nick Maxwell a second 11 opportunity to submit verbal public comments towards 12 the very end of the hours-long session, NRC meeting 13 facilitator Chip Cameron warned Maxwell that he and 14 presumably the rest of the assembled NRC staff did 15 not want to hear any more about bribery allegations.
16 As a Federal Government official Chip 17 Cameron had no right to censor Nick Maxwell's free 18 speech. This not only violated Nick Maxwell's First 19 Amendment free speech rights, but it also violated 20 Nick's rights under the National Environmental Policy 21 Act to submit any public comments regarding the 22 Holtec ELEA CISF scheme that he chose to make.
23 After all, Nick Maxwell's allegations of 24 bribery are bolstered by dozens of articles in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 media over the past couple years. And of course it 2 goes without saying the NRC's flippant lack of 3 concern about Holtec's and allegedly also ELEA's 4 penchant for engaging in bribery and kickback schemes 5 is shocking and outrageous.
6 After all, how can NRC fulfill its 7 mandate to protect public health, safety and the 8 environment when it looks the other way as its own 9 licensees engage in such serious criminal wrongdoing 10 as bribery and kickback schemes, not to mention 11 providing false information; that is, lying under 12 oath as has taken place in New Jersey by Holtec's CEO 13 Krishna Singh?
14 How can a company that behaves in this 15 way be entrusted with the storage and transportation 16 of forever-deadly, highly radioactive commercial 17 irradiated nuclear fuel and greater than Class C, so-18 called low-level radioactive waste?
19 Incredibly despite Beyond Nuclear's and 20 Mining Awareness' raising of these issues of Holtec's 21 penchant for engaging in bribery and kickback schemes 22 in their July 2018 public comments during NRC's 23 environmental scoping phase regarding this CISF, and 24 despite the extensive media coverage from 2019 to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 2020, the words bribe and bribery do not even appear 2 in the 488-page NRC Holtec CISF Draft EIS published 3 by NRC in March 2020, but again the Agency is behaving 4 as if the bribery conviction in which Holtec was 5 involved and additional allegations of Holtec 6 attempting bribery and kickback schemes simply never 7 took place.
8 And so to clarify for the record what I'm 9 referring to, back in 2018 during environmental 10 scoping myself as well as Mining Awareness documented 11 a conviction for bribery in Alabama at the Tennessee 12 Valley Authority's Browns Ferry Nuclear Power Plant 13 in which Holtec's CEO Krishna Singh was implicated.
14 And then as I mentioned when Krishna Singh then 15 applied for a $260 million tax break in New Jersey, 16 the money used to build Holtec's current headquarters 17 for fabrication of the very containers that would be 18 used in this particular scheme, that has all been 19 well-documented by major media coverage.
20 Despite raising these allegations the 21 U.S. Nuclear Regulatory Commission then delivered an 22 early Christmas present to Holtec International on 23 December 20th of 2018. NRC decided that, quote, NRC 24 regulations do not specifically address bribery, end NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 quote. The shocking statement came after an NRC 2 official investigation that lasted nearly five 3 months, and the closure letter was barely a page long.
4 Are concerned citizens and watchdog 5 groups like ours supposed to activate the U.S.
6 Department of Justice to investigate these bribery 7 allegations since NRC has flippantly washed its hands 8 of the matter? NRC has done this despite Holtec's 9 involvement in a bribery scheme that led to a 10 conviction. NRC is behaving like that bribery 11 conviction never took place.
12 Specifically Holtec's CEO Krishna Singh 13 attempted to bribe industry -- in addition Holtec's 14 CEO Krishna Singh also attempted to bribe industry 15 whistleblower Oscar Shirani of Commonwealth Edison, 16 Exelon, as well as NRC's own dry cask storage 17 inspector Dr. Ross Landsman into silence regarding 18 widespread serious quality assurance violations in 19 the design and fabrication of Holtec containers for 20 high-level radioactive waste storage and transport 21 used extensively throughout the U.S. power industry, 22 nuclear power industry.
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76 1 disbarment for doing business with the Tennessee 2 Valley Authority, and that disbarment was the very 3 subject matter of the Krishna Singh then lied about 4 under oath when he applied for that massive New Jersey 5 tax break.
6 And so I will be submitting for this 7 record the 20 news articles that document all this.
8 And what it boils down to is that NRC in its own 9 regulations has corporate character and corporate 10 integrity regulations that would also apply not only 11 to Holtec International, but to its CEO Krishna 12 Singh. And it is my conclusion that NRC is 13 essentially waiving these regulation requirements in 14 allowing this applicant to get this far in this 15 proceeding. Thank you.
16 MR. CAMERON: Okay. Thank you, Kevin. I 17 think the facts will show that I gave Mr. Maxwell six 18 minutes of uninterrupted time to talk about bribery, 19 racketeering and whatever, and because we had extra 20 time I allowed people to come back on again. And all 21 I was saying to Mr. Maxwell was we've heard enough 22 about racketeering and bribery. Do you have anything 23 else? And that is on the transcript.
24 And, Olin, who's next?
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77 1 MR. KAMPS: I disagree with your analysis 2 there, Chip.
3 OPERATOR: We have Becky Halpin.
4 Ms. Halpin, your line is open.
5 MS. HALPIN: Thank you. Can you hear me?
6 MR. CAMERON: Yes.
7 MS. HALPIN: Great. Hello and good 8 morning. I'm Becky Halpin and I would certainly hope 9 that people would be able to talk as much as they 10 want to about any topic including bribery. Thank 11 you.
12 I also protest the unjust format of this 13 meeting requiring access to the Internet and phone 14 connection at the same time. This requirement makes 15 it impossible for many people who might want to 16 participate to be heard. Voices are being silenced.
17 I would also like to note that robust 18 virtual meeting platforms are widely available and 19 used all around the world. If the NRC cannot figure 20 out how to acquire and use a platform that would give 21 video access to the Commissioners without stressing 22 their server makes me wonder how they are equipped to 23 manage this highly technical review process. And I 24 think that's a very fair observation in today's day NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 and the way that we all handle business today. It's 2 an easy thing to do.
3 True and appropriate public hearings need 4 to be held in person when the COVID crisis is passed.
5 It constitutes abuse of regulatory power to certify 6 something as safe that is obviously and blatantly 7 extremely dangerous. The risk to population centers 8 all across the nation as this highly radioactive 9 material is transported in these five-eighth-inch 10 thick flimsy containers is astronomical should any 11 accident or incident occur.
12 There is likely a 100 percent probability 13 that an accident or incident will occur that spills 14 this radioactivity into a community over the many 15 years and thousands of trips these dangerous 16 materials will make through our cities. Given the 17 inadequate state of our rail lines to transport these 18 overweight railcars carrying this radioactive 19 material and the large number of rail accidents we 20 currently see every year, we have a clear recipe for 21 radiologic disaster.
22 The world is awash in weapons of war such 23 as shoulder-fired rockets that could easily pierce or 24 explode these transportation containers. There is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 large and very active black market for shoulder-fired 2 rockets. Additionally ammunition from legally-3 acquired rifles and weapons could pierce these 4 containers.
5 It is irresponsible not to assume from 6 the get-go from the very outset that these 7 transportation containers would become every 8 terrorist's dream. These containers, these canisters 9 on railcars would be especially inviting terrorist 10 targets when the canister is moving through or parked 11 in urban population centers, in a port, next to a 12 military installation or close to critical 13 infrastructure of any sort. Radioactive 14 contamination of an entire city is not just possible, 15 but probable under the naive and dismissive planning 16 put forth in this application. Saying that 17 something is safe in no way renders it so.
18 Transportation of this material across the country in 19 these thin inadequate and easily identifiable 20 canisters is an offering to the gods of chaos. This 21 deadly radioactive material should stay where it has 22 been generated until there is a plan to entomb it in 23 an appropriate facility for the millennium that it 24 will be radioactive. We should not be dragging it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 across our nation endangering millions of people in 2 the process until we have a final solution.
3 Dumping this dangerous waste in the 4 desert in containers that will deteriorate and leak 5 radiation with no effective plan other than in 25 or 6 40 years or so we'll think of something is a testament 7 to how desperately nuclear plant operators want to 8 just get rid of this stuff regardless of the fact 9 that there is no safe place to put it. There is no 10 plan to park this waste anywhere but here in the 11 desert in New Mexico and across state lines in Texas.
12 This permit is not really for temporary 13 storage and should be denied. Thank you very much.
14 MR. CAMERON: Okay. Thank you, Becky.
15 Olin, can we go to the next person?
16 OPERATOR: We have Patricia Marida.
17 I apologize if I mispronounced the name, but, 18 Patricia, your line is open.
19 MS. MARIDA: Hi. Can you hear me?
20 MR. CAMERON: Yes, we can hear you, 21 Patricia. And we did get your last name correct, 22 Margarita?
23 MS. MARIDA: I say Marida.
24 MR. CAMERON: Okay.
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81 1 MS. MARIDA: I'm for Columbus, Ohio, and 2 I just want to say that I'm submitting the comments 3 under protest because we can't verify that the NRC 4 decision makers are receiving them. And I want to 5 say that you need to include New Mexico's 6 congressional delegation or staff so that they can 7 verify the validity of the hearing format. And the 8 comment period should be extended until after the 9 COVID emergency has ended and it's safe to have mass 10 gatherings, and then they should be conducted in 11 person in several locations in New Mexico like it was 12 originally promised by the Nuclear Regulatory 13 Commission. And then I want to say that there's no 14 compelling reason for these meetings to be rushed.
15 And they -- this waste needs to stay 16 where it is and be stored much more safely right now 17 where it is. Moving it is just all kinds of problems 18 and trouble. It's insanity warmed over. The idea of 19 an interim and centralized is unnecessary and 20 dangerous. So either the waste must be moved again 21 or it is a permanent site. So those aren't viable 22 choices. Moving the waste for no reason 23 with the inevitable accidents would take decades and 24 overload NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 -- of course you've heard enough -- I think should 2 have heard a lot about the nation's D-plus rated 3 infrastructure, rated in 2017 by the American Society 4 of Civil Engineers. And I think it's gone downhill 5 since then. And it's been stated by numerous 6 authorities that it's absolutely unsatisfactory, the 7 -- our nation's infrastructure system. So mostly 8 -- it was mostly below standard.
9 And then I just want to add in conclusion 10 that the influence of the industry and of Holtec's 11 -- and the money that they are making and the money 12 they are willing to spread around in order to 13 influence decision making is very concerning to me.
14 So that's 15 -- I wanted to conclude my statement by saying that.
16 MR. CAMERON: Okay. Thank you for 17 joining us, Patricia, for those comments.
18 Olin, who is next?
19 OPERATOR: We have Lon Bonald.
20 Mr. Bonald, your line is open.
21 MR. BURNAM: Can you hear me?
22 MR. CAMERON: Yes, we can, Lon.
23 MR. BURNAM: Okay. Just for the record 24 the name is Lon Burnam, B-U-R-N-A-M, and I am NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 participating today, Chip, under protest. I finally 2 buckled down and recognized that I had an ethical and 3 moral responsibility to represent the Lone Star 4 Chapter of the Sierra Club in these fraudulent 5 proceedings, but you know, we've been around the horn 6 enough to know that in the first place it's not even 7 a legal request.
8 In the second place to be dismissive of 9 the fact that they are under any number of areas of 10 scrutiny because of their illegal activities and to 11 be dismissive of this concern is just absurd to me.
12 And then in third place to artificially 13 bifurcate this project and pretend that it doesn't 14 have a negative impact on Texas is simply the most 15 egregious attack on the whole Environmental Impact 16 Statement I've seen in a long time.
17 And, Chip, as you well know I was in the 18 Texas legislature for 18 years, so I saw a lot of 19 egregious attacks on process and I saw a lot of 20 agencies that -- performing and behaving as if they 21 were captains of the industry. And of course I've 22 long ago begun to assume that that's the case with 23 the NRC.
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84 1 out not that I'm authorized to speak on behalf of the 2 League of Women Voters, but this whole fast-track 3 streamlined inappropriate approach to citizen 4 participation is an insult to the democratic 5 processes that this country has come to expect. And 6 from the Sierra Club's standpoint this division of 7 environmental concerns should and will be challenged 8 in the courts. I agree with every previous speaker 9 and their comments that they had to be -- had to make, 10 but on behalf of the Lone Star Chapter of the Sierra 11 Club, frankly, I spent enough time wasting my breath 12 with you guys. I'll submit my letter in writing.
13 MR. CAMERON: Okay. Good, Lon. We'll 14 look forward to that writing and it's nice to see 15 that you're still on the job, too. So thank you.
16 Olin, do we have another speaker?
17 OPERATOR: We do. Patty Hughes, your 18 line is now open.
19 MS. HUGHES: Thank you. Can you hear me?
20 Hello?
21 MR. CAMERON: Yes.
22 MS. HUGHES: Okay.
23 MR. CAMERON: Yes, we can hear you.
24 MS. HUGHES: First of all, I'm making my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 comments under protest for the reasons that you've 2 been hearing.
3 One of your officials said at the 4 beginning of the meeting that the NRC had a commitment 5 to openness, and I just want to make the observation 6 if you had input from a state's national delegation 7 and person after person giving you reasons why in New 8 Mexico webinars are not adequate. This process is 9 not open, so your commitment to openness is at best 10 inadequate.
11 At the first webinar that we've had in 12 these last two weeks an NRC official signaled that 13 despite the protest about the webinars that you would 14 not be impacted by our concerns and announced at the 15 end of that meeting that you would proceed with the 16 webinars. So I think at that point we saw the writing 17 on the wall and saw it as disrespectful.
18 I have a question: How is it that this 19 facility is called interim when as other speakers 20 have said, even the Secretary of Energy says that 21 it's not?
22 You say that -- to another point you say 23 that you will ensure that the Holtec facility will be 24 built and operated safely, but you are ignoring data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 from a New Mexico Environment Department that you 2 called earlier a cooperating agency. That is in exact 3 conflict with your assertions that you made in the 4 EIS concerning the existence of standing water and 5 groundwater at the Holtec site.
6 My question is -- well, actually a state 7 official told me that your own data shows that there 8 is shallow groundwater at this site. Do New Mexico 9 citizens have to wait for an accident or our 10 Environment Department to be proved right?
11 Next you assert that the socioeconomic 12 impact is small to moderate, and it's moderate due to 13 positive impact on the economy. Again, information 14 that you have gotten -- the expert on the New Mexico 15 economy is our governor. I would ask you to read her 16 letter which doesn't agree with you that is again in 17 exact conflict with the statement that you made. So 18 our governor doesn't agree that the socioeconomic 19 impacts of this would be small to moderate. Neither 20 would the governors of South Carolina, Illinois or 21 any other state agree that the impacts would be small 22 to moderate. It's not that impacts are small. It's 23 because in your eyes New Mexico and its citizens are 24 small. And you are the ones who have made that clear.
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87 1 Lastly, does the NRC have any internal 2 checks for -- or standards for when they have so 3 disproportionately burdened a state with the nation's 4 nuclear waste that they have broken it?
5 And in my opinion, my husband and I went 6 through an ordeal three years ago where the DOE tried 7 to drill a bore hole on a ranch adjoining our ranch.
8 We saw our property values go to zero. We saw the 9 banks react. We saw families who had been there for 10 five and six generations see that if that happened 11 that they would have to pull up stakes and go 12 somewhere else. Our experience was that storing 13 high-level nuclear waste was not economic 14 development. It was economic replacement of a 15 sustained economy with the most polluting economy on 16 the face of the earth. Unfortunately Eddy-Lea 17 Alliance has purported to speak for New Mexico when 18 they sent -- telling the world that New Mexico wants 19 its waste. Obviously that isn't true.
20 An earlier caller asked why move the 21 waste? The answer to that is that there's national 22 pressure to get it out of other states. And a DOE 23 contractor told us on the bore hole project in a 24 public meeting in Clovis, New Mexico, that New Mexico NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 has a target on its back that has been perpetuated by 2 the Department of Energy, by the NRC and by private 3 companies that think that we're a viable site for 4 -- to be eternally polluted.
5 I would urge you rather than -- this is 6 the fourth time I've seen this slide presentation.
7 At least two of your slides are in direct conflict 8 with statements that you have received from the State 9 of New Mexico. I would ask you to consider that most 10 expert testimony -- and when you describe the impacts 11 to us, you describe them in a truthful manner. Thank 12 you.
13 MR. CAMERON: Okay. Thank you, Patty.
14 And, Olin, we're going to go to the next 15 speaker.
16 OPERATOR: Michael Keegan.
17 Michael, your line is now open.
18 MR. KEEGAN: Thank you. Can you hear me?
19 MR. CAMERON: Yes, we can hear you, 20 Michael.
21 MR. KEEGAN: Thank you. I'd like to 22 discuss the pedigree of the environmental report and 23 the DEIS, and ultimately the final EIS.
24 We go back to the GNEP program and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 work done there in the 2007-2008 era, being done by 2 Tetra Tech, the parent company, who's been heavily 3 implicated in fraudulent schemes and falsification of 4 documentation at Hunters Point and Treasure Island.
5 A 2.206 petition was brought forward and a multitude 6 of documents were placed into the record showing from 7 top to bottom Tetra Tech falsification criminality, 8 people-went-to-prison-kind of situation. And yet 9 there the parent company has a spinoff which 10 developed the GNEP environmental review report, so on 11 and so forth. And so here comes Holtec a decade later 12 and picks up and utilizes those GNEP reports and 13 employs them in their environmental review.
14 So the pedigree of the environmental 15 review, environmental report, the DEIS and the EIS I 16 call into question because criminality was involved 17 way back when. And so I -- it speaks of collusion 18 and racketeering between agency and a proposal 19 proponent, Holtec. So really an investigation needs 20 to be done there.
21 I'm in the Detroit area and I'm very much 22 concerned about transportation. And there have been 23 no public hearings, no public education put forth on 24 this and yet we would be very much impacted because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 we're on the roads.
2 As I review the record I see these 3 multiple amendments, modifications being made to the 4 casks that are going to be used. Everything is very 5 fragile in that when it comes to the crucial 6 information needed it's withheld. All these pieces 7 are supposed to fit together. What I believe is 8 needed is a programmatic Environmental Impact 9 Statement process because there are -- so many moving 10 pieces that go into place are initiated by the Holtec 11 proposal. And so do not do it piecemeal. We need to 12 know from top to bottom in every which way so a 13 programmatic Environmental Impact Statement is called 14 for.
15 I have concerns about foreign nuclear 16 waste coming into the U.S. A hundred and seventy-17 three megatons -- hundred and seventy-three thousand; 18 I'm sorry, metric tons are designated for Holtec. Is 19 there going to be foreign nuclear waste coming in?
20 Is Canadian nuclear waste going to be coming in? Why 21 is the NRC reviewing Canadian cask systems? Why is 22 that of our interest? Why is the DOE And the NRC 23 engaged in mock exercises that come from Europe of 24 freighter, barge, how have you, rail to mid-section NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 Denver area and call that a successful mock operation 2 of transfer of spent nuclear fuel?
3 I have concerns about foreign ownership.
4 I have concerns about disclosure of a private company 5 at -- LLCs at every level. We don't know. You're 6 dealing with what I believe to be a criminal operation 7 and you are aiding and abetting the situation. That 8 would be a racketeering. So please put the brakes on 9 this.
10 Reflecting on the gentleman's comments on 11 a moral obligation to speak out, I certainly feel a 12 moral obligation to speak out and I want public 13 hearings in Detroit area, in Chicago area, in New 14 York area. Everyone's going to be impacted. So 15 please bring us into the conversation. Thank you.
16 I'm with Don't Waste Michigan. Michael Keegan.
17 MR. CAMERON: Okay. Thank you and thank 18 Don't Waste Michigan. Thank you, Michael.
19 And, Olin, can we go to the next speaker, 20 please?
21 OPERATOR: Absolutely. We have Bruce 22 Montgomery.
23 Mr. Montgomery, your line is now open.
24 MR. MONTGOMERY: Yes, thank you, Oland.
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92 1 I appreciate the opportunity to speak.
2 My name is Bruce Montgomery. I am the 3 Director of the Used Fuel and Decommissioning of the 4 Nuclear Energy Institute and we represent over 300 5 members, companies, universities, laboratories both 6 in the U.S. and abroad involved in the nuclear 7 enterprise.
8 My personal experience is over 40 years 9 in the nuclear industry. I've been the chief engineer 10 at a couple of different nuclear power plants that 11 have been operating in excess of 40 years, providing 12 electricity to their communities.
13 Now I've heard a lot of discussion around 14 rushed discussions or meetings, or public review for 15 the Draft EIS. I don't think there's anything that's 16 rushed about this. The opportunities have been 17 extended at least a couple of times. I believe that 18 the number of webinars offered the public an 19 opportunity to comment on this has been probably more 20 than I've ever seen before for similar activities.
21 I would like to speak in support of the 22 NRC in issuing this EIS in final form. We speak in 23 favor of the consolidated interim storage that Holtec 24 is requesting a license for. We think that this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 an eloquent and proper solution for commercial 2 interim storage of used fuel.
3 My personal experience includes 4 independent spent fuel storage facility installation, 5 design, construction and operation at a couple of 6 different nuclear power plants. The one I'm most 7 familiar with is the one that's located in Maryland 8 on the Calvert Cliffs site. It's been operating for 9 over 26 years. It's a very innocuous thing to look 10 at it. It incorporates the same types of designs 11 that we'll be seeing -- as we have seen across the 12 country including the one that's proposed for the 13 Holtec site in New Mexico.
14 But I think that today's discussion of 15 the three webinars that I have participated has been 16 a most fulsome discussion of the things that are 17 directly relevant to the environmental effects that 18 interim storage would pose to the folks and the 19 environment around the proposed site in New Mexico.
20 I'm especially encouraged that folks are paying 21 attention, that there have been some good discussions 22 around the socioeconomic impacts of the site.
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94 1 submitted to the NRC will be taken into consideration 2 adequately by the NRC reviewers.
3 I think that with regard to the safety 4 discussions that have been held today -- I think 5 those, although they're out of scope for today's 6 discussion, I believe they'll be more than adequately 7 discussed as part of the Safety Evaluation Report 8 that the NRC is working on as we speak for the CIS 9 site in New Mexico.
10 But even though they're out of scope I 11 think there's a couple of things I'd like to point 12 out. I think with particular regard to the comments 13 made by Mr. Paul Blanch, he mentioned that, yes, these 14 are one-half to five-inch thick stainless steel 15 canisters that are welded, that they're under 100 16 -- up to 100 pounds pressure of helium internal to 17 the canisters. While that's all true, Paul then 18 conflated potential for degradation of these 19 canisters with what happened at Davis-Besse where 20 boric acid leakage from the reactor vessel basically 21 wasted away the three to six inches of carbon steel 22 on top of the reactor vessel.
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95 1 stainless steel that was holding up against over 2 2,000 pounds pressure for the better part of a two-3 year operating cycle.
4 So again, you have evidence that's 5 contrary to what Paul was presenting that shows that 6 these canisters are extremely robust and aren't in 7 the environment that they will be in and have been 8 and across the country really not susceptible to any 9 sort of accelerated degradation. And the comment 10 that there's a certainty of degradation is really 11 -- from an engineering perspective is just not 12 correct. These will be addressed during the Safety 13 Evaluation Report and have already been addressed by 14 the licenses that have been issued by the NRC for 15 these canisters across the country already.
16 But anyway I'd like to close by saying 17 that I believe that contrary to a lot that has been 18 said; and I know I'm kind of speaking alone today, is 19 that nuclear is the most environmentally-friendly 20 technology for the production of electricity that 21 there has ever been and may be for a long, long time.
22 I'd like to congratulate NRC's Kevin 23 Coyne's group in putting together a very 24 comprehensive and thorough Environmental Impact NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 Statement Draft Report and I expect that by the time 2 they get to the point of issuing a final report it 3 will exist in pretty much its current state, 4 hopefully enhanced by some of the comments received 5 today and in the webinars that preceded this.
6 So thank you very much for the 7 opportunity for this open discussion. I think this 8 sort of discussion is really unique to this country 9 that we live in and we should congratulate the NRC 10 and the infrastructure that we have for this kind of 11 discussion. So thank you very much.
12 MR. CAMERON: Okay. Thank you, Bruce, 13 for those comments.
14 And, Olin, who do we have next on the 15 phone to talk to us?
16 OPERATOR: We have Karen Hadden.
17 Ms. Hadden, your line is now open.
18 MS. HADDEN: Hi. Can you hear me?
19 MR. CAMERON: Yes, we can, Karen.
20 MS. HADDEN: Hi. Good afternoon.
21 And I would like to start by saying that 22 these comments today are, likewise, under protest.
23 As others have discussed, I feel like this process is 24 inadequate and undemocratic and unfair.
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97 1 I would like to say that I wholeheartedly 2 concur with comments made by Kevin Camps, Becky 3 Halpin, Pat Marida, Lon Burnam, Patty Hughes, and 4 Michael Keegan. I did not hear the speakers before 5 that. But they all did a really excellent job of 6 laying out some of the problems that we're facing 7 with this license application.
8 I'm very, very concerned with the Draft 9 Environmental Impact Statement as inadequate. It 10 fails to adequately acknowledge the risks of the 11 Holtec site and the long transportation routes 12 throughout the country.
13 And I want to read to you a statement 14 that comes straight from an NRC website about the 15 dangers of high-level radioactive waste. And it 16 says, "High-level wastes are hazardous because they 17 produce fatal radiation doses during short periods of 18 direct exposure. For example, 10 years after removal 19 from a reactor, the surface dose rate for a typical 20 spent fuel assembly exceeds 10,000 rems per hour, far 21 greater than the fatal whole body dose for humans of 22 about 500 rems received all at once. If isotopes 23 from these high-level wastes get into groundwater or 24 rivers, they may enter food chains. The dose produced NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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98 1 through this indirect exposure would be much smaller 2 than the direct exposure dose, but a much larger 3 population could be exposed." That is directly from 4 the NRC website.
5 So, we have a Draft Environmental Impact 6 Statement that comes out with conclusions of small 7 impacts on numerous categories. It's really hard to 8 take apart this DEIS and enumerate the many things 9 wrong with it. I think it's a good compilation of 10 facts, but with almost no real analysis. And it needs 11 to be done over. It's inadequate as a document. It's 12 inaccurate. It fails to address the very real dangers 13 that are involved that risk the health of the public, 14 that risk our economy, that risk the environment.
15 The whole process is illegal and it should be done 16 over when the time is right.
17 The public hearings should be held after 18 the risks of COVID are over, and this proceeding 19 should not be moving forward until it is legal to 20 develop a consolidated interim storage site. I don't 21 favor the development of any consolidated interim 22 storage site at any point in time, but, certainly, 23 right now it is illegal under the Nuclear Waste Policy 24 Act.
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99 1 Thank you very much.
2 MR. CAMERON: Okay. Thank you, Karen.
3 Thank you very much.
4 Olin, who do we have on next to talk with 5 us?
6 OPERATOR: We have Diane D'Arrigo.
7 Miss Darrigo, your line is open.
8 MS. D'ARRIGO: Hi. Thanks.
9 MR. CAMERON: D'Arrigo, Diane D'Arrigo.
10 MS. D'ARRIGO: Hi. Thanks. Diane 11 D'Arrigo, Nuclear Information and Research Service.
12 I am also testifying under protest. As 13 was stated, previous calls and other callers have, 14 other commenters have stated, the call is for in-15 person meetings after the COVID crisis is over. And 16 there is a chance that this COVID crisis will end.
17 Some people think it won't, but it will. And it's 18 just not fair and it's just not equitable to expect 19 people, the average person who could be impacted by 20 all of this, to put everything aside and go through 21 hundreds of pages of technical documents, which I 22 believe they would do after the crisis is over.
23 So, the decision that's being made here 24 by the NRC, although the claim is that it's for a 40-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 year license, it's an irreversible decision. Whether 2 the site is actually really only temporary, which is 3 highly question, or whether it is de facto permanent, 4 the site itself is being sacrificed to the Nuclear 5 Age. And if that's what people want, then that's 6 what's going to happen. I do not believe that the 7 people in New Mexico and along the route do want that.
8 It's an irreversible decision for the 9 community, for the region, and for the whole 10 ecosystem. And yet, the NRC is assuming that, presto, 11 in 40 years there will be no more waste there. It's 12 going to take more than 40 years to get the waste 13 there.
14 And also, along the way, in the 15 Environmental Impact Statement, the assumption is 16 made that there will be no released of radioactivity, 17 and that is, again, as others have mentioned, not a 18 credible assumption.
19 I believe that within each of the 20 categories that were given below, or whatever 21 category of concern that the NRC has in the EIS, yes, 22 there are tricks in the calculations and their 23 assumptions that need to be questioned.
24 And the issue of the kind of waste, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 1 application itself does not envision taking high 2 burnup fuel. It does not envision taking damaged 3 fuel. So, if such fuel would arrive, rather than 4 managing it, because it's not licensed to manage it, 5 supposedly, that kind of material would be sent back.
6 And I don't think that that's a credible option, to 7 take damaged fuel or high burnup fuel, and then, send 8 it back to the reactors from which it came.
9 I think where it is at the reactors is of 10 major concern, and that a lot more effort needs to be 11 put into safer storage wherever it is and move it 12 away from high sea level rise areas. But it needs to 13 be managed as close as possible to where it's 14 generated and not moved back and forth across the 15 country, with the promise of getting rid of it, when, 16 in fact, it's actually being spread.
17 I believe that this application is a foot 18 in the door for actually taking high burnup fuel and 19 damaged fuel, and that there is no -- at neither of 20 the sites is there a facility envisioned to 21 recontainerize the fuel or remove it or fix 22 canisters. There's no dry or wet fuel transfer 23 facility with good shielding, so that workers could 24 actually work on the capability of the canister.
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102 1 So, a major assumption that's being made 2 is that all of the containers are going to be 3 perfectly fine for the whole time that the waste 4 exists at the site. And at which stage would the NRC 5 eventually require some kind of dry transfer or wet 6 transfer, some kind of shielded facility to 7 recontainerize and manage the fuel?
8 The containers are only licensed for 9 limited time periods, 20, 30, 40, 50 years, and as I 10 said, the facility's underlying application is only 11 for 40. So, we're able to suspend this belief to do 12 this application, be very focused and narrow and not 13 face the reality; that's the opposition and the 14 concern that we in the general public have, is that 15 there are some very unrealistic assumptions in the 16 Environmental Impact Statement. And we would like 17 additional time, so that we can help the NRC identify 18 these and improve this document and this analysis, 19 and perhaps come to a conclusion that there's a better 20 alternative all the way around.
21 So, that's some levels of opposition that 22 I wanted to express at this point and a concern.
23 Okay.
24 MR. CAMERON: Okay. Thanks. Thank you.
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103 1 Thank you, Diane.
2 And, Olin, who is the next speaker?
3 OPERATOR: We have State Senator Jeff 4 Steinborn.
5 MR. CAMERON: Oh, good.
6 OPERATOR: Your line is now open, sir.
7 MR. STEINBORN: Thank you. Good morning, 8 everybody.
9 MR. CAMERON: Good morning.
10 MR. STEINBORN: Or good afternoon. Thank 11 you.
12 So, I am State Senator Jeff Steinborn, 13 past Chairman of the New Mexico Legislative Interim 14 Radioactive and Hazardous Materials Committee, which 15 is a joint Senate-House committee that meets round 16 the year. And I am the current Vice Chair of that 17 Committee.
18 And we had many hearings on the Holtec 19 proposal and have taken a deeper dive into many of 20 the issues. And I just have to say -- and I'm going 21 to reiterate some of what I have said before -- but, 22 No. 1, I find the EIS, by definition -- well, not by 23 definition, but, unfortunately, in practice, 24 deficient and not acceptable, frankly, in terms of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 covering the range of issues that are considered 2 here.
3 And to New Mexicans and a lot of the 4 people calling in, the transportation issue which is 5 not part of this, is one of the 900-pound gorillas in 6 the room because all this waste will come through all 7 sides of New Mexico and put New Mexicans, give New 8 Mexicans particular exposure. And that is not 9 considered at all, and the arguments we've heard of, 10 "Oh, we will do that later" -- no, transportation 11 should not be an afterthought. And I think, given 12 the significance of this proposal, this is a 13 deficiency that's a fatal flaw in this plan that 14 should preclude it from moving forward until all 15 issues have been considered.
16 Beyond that, other deficiencies within 17 the EIS, obviously, the social justice aspects are 18 huge. I don't know that a proposal of this scale -- I 19 know it's difficult to do the kind of work that would 20 be required to do the due diligence on that, but, as 21 the NRC previously has said, New Mexicans have not 22 been proactively reached out to, educated about this 23 proposal, in a level that could remotely conclude 24 that their interests, that their considerations, have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 been listened to, have been considered. And yet, as 2 Ed Hughes, a New Mexican, said earlier in this call, 3 New Mexicans continue, time and again, to pay a 4 disproportionate price to meet the high cost, the 5 social cost, of the country's nuclear legacy.
6 Furthermore, you know, during this 7 pandemic, it is hard to participate. And one of the 8 disappointing and troubling aspects of the pandemic 9 I've seen in public life is how it really puts 10 everybody in a silo. It's hard to engage. People 11 don't hear about issues unless you have internet 12 access. And, you know, we definitely in this State 13 have a digital divide in the same communities where 14 we're going to be shipping waste through.
15 And yet, I, myself, I hopped onto the 16 call, and I didn't realize I had to press *1, for 17 example. And thankfully, others said, "Hey, you have 18 to do this to be able to speak." So, there are 19 technological challenges there.
20 And I would hope, and I'll ask again for 21 the NRC to push this off until or continue it until 22 the pandemic over, so that we can recognize those 23 inherent limitations of what's going on in the 24 pandemic. It's a matter of basic fairness to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 State of New Mexico.
2 I would point out, also, that -- and I 3 think it needs to be repeated -- that communities in 4 the State of New Mexico, including the Governor, but 5 communities, comprising almost 50 percent of the 6 State's population, have passed ordinances opposing 7 this transportation through the State. And in the 8 State of Texas, a great I think 5 million Texans have 9 letters of opposition.
10 Now, you know, in contrast to the level 11 of cooperation we've seen from the federal government 12 on the west side of the State, what have we seen with 13 Holtec? We've seen a company that has repeatedly 14 tried to, as far as I'm concerned, mislead the NRC as 15 to the level of support with the State of New Mexico, 16 once even claiming that a resolution passed by a 17 committee, my committee, that was nothing more than 18 a number of members signing onto a statement, that 19 they tried to claim that we had passed a resolution, 20 which we had not. And I immediately contacted the 21 NRC.
22 This last January, they hired a team of 23 lobbyists to oppose legislation that was making its 24 way through the Legislature to simply have the State NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 do an evaluation, agnostic of the results, to do an 2 evaluation of any private high-level facility in the 3 State of New Mexico, simply to protect its own 4 citizens. And Holtec hired a team of lobbyists to 5 oppose that. This is a company that, aside from its 6 lobbyists, doesn't have any employees living in the 7 State of New Mexico. So, obviously, you know, that 8 does not produce trust. In fact, it produces a lot 9 of mistrust.
10 And finally -- and my time is probably 11 almost out -- I wanted to say that, you know, New 12 Mexico is being made to be the guinea pig in all of 13 this. We're considering a proposal with a lifespan 14 beyond the lifespan of dry cask storage or 15 experience. There is no federal permanent 16 repository. Obviously, New Mexico communities and 17 the State has all the exposure when it comes to any 18 accident that should occur.
19 And so, this is a proposal, frankly, 20 driven by industry, not driven by real national 21 energy policy, and it's of a level that I recognize 22 the NRC, the staff, may feel like, well, it is not 23 your position to consider is it a wise policy 24 decision; you have a proposal. But I think there, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 inherently, is the great fundamental flaw of the 2 whole thing, that states don't have consent; that a 3 company and a few individuals can trigger this onto 4 a state and onto a nation.
5 And I think the NRC needs to take 6 seriously, and humbled, about its impact of what it's 7 considering for the residents of our State and the 8 nation in terms of their transportation risk, and, 9 you know, expand the scope of this EIS. Frankly, 10 start over -- I think that would be good -- and 11 consider that and many more citizens' points of view, 12 and also, delay this beyond the pandemic.
13 And further, I call on Congress to adopt 14 a real consent-based approach to this. This is a sad 15 excuse for a national energy policy.
16 So, thank you all for listening today.
17 MR. CAMERON: Okay. Thank you, Senator, 18 for those serious comments. Thank you.
19 And, Olin, we're going to try to see if 20 we can get people who have not addressed us to come 21 on. So, I think (telephonic interference) about the 22 *1. Let's make sure that the people know that they 23 have to press *1 to come on to speak. But we're just 24 going to wait here and see if we get persons who have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 not spoken tonight lined up to speak.
2 OPERATOR: Understood.
3 So, again, as a reminder, if you would 4 like to ask a comment or pose a question, that is 5 going to be *1 to get in the queue. Again, *1 to 6 enter the queue for questions or comments.
7 (Pause.)
8 Our next question comes from Jerry Lodge.
9 Mr. Lodge, your line is now open.
10 MR. CAMERON: Hi, Jerry. Jerry, are you 11 on?
12 Is it Jerry or Gary. Terry?
13 (No response.)
14 OPERATOR: We seem to be having a 15 technical issue with that. One moment. I'll get the 16 next question up.
17 MR. CAMERON: Okay.
18 OPERATOR: Next, we have Linda Lewison.
19 Ms. Lewison, your line is open.
20 MS. LEWISON: Thank you.
21 My name is Linda Lewison. I'm with 22 Sierra Club Nuclear Free Campaign National Task Force 23 and Nuclear Energy Information Service in Illinois, 24 watchdog on the nuclear industry for the past almost NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1 40 years.
2 I am giving this testimony under protest 3 that these hearings should wait until after COVID in 4 six more months, and I support the details of that 5 that were mentioned before on this call. There's no 6 reason that they cannot be held safely and in person, 7 and the Nuclear Regulatory Commission itself has said 8 that the radioactive waste can be safely stored 9 onsite for 120 years.
10 We oppose this plan, as does Sierra Club 11 policy. I would like to cite three points.
12 President Singh of Holtec had said that 13 he can't guarantee that the casks that they're making 14 will be safe in these circumstances. There is no 15 backup for if something goes wrong with these casks.
16 The Nuclear Waste Technical Review Board, in 2019, 17 has also said that there is no safe way to transport 18 and store the waste, either short-term or long-term, 19 at this time. And in my written testimony, I'll give 20 the citations for these quotes.
21 It is also important to note that Holtec, 22 the company itself, is being investigated for 23 criminal activities in three states. This litigation 24 is ongoing. So, we are already in a compromised and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 corrupted process.
2 There is a conflict of interest of the 3 NRC, an agency that profits from extending licenses 4 to these companies. That is, your fees are what 5 creates much of the budget of the NRC. One has to 6 ask, since we're discussing environmental impact, 7 what is the "actual environmental impact," in quotes, 8 of doing business with such an applicant who is under 9 investigation in the first place? There is a lack of 10 trust on the integrity of what Holtec is doing, and 11 that continues to put the public and the environment 12 at further risk.
13 In closing, please note that Senator 14 Bingaman from New Mexico has in the past refused to 15 endorse any form of interim storage at all, unless, 16 according to federal law, there is a provision for a 17 permanent repository that is actually selected and in 18 place as a physical actuality in the first place prior 19 to any other plan being put forward.
20 Thank you very much.
21 MR. CAMERON: Okay. Thank you again, 22 Linda.
23 And, Olin, do we have someone else that 24 hasn't spoken yet?
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112 1 OPERATOR: We do. Janet Greenwald.
2 Ms. Greenwald, your line is now open.
3 MS. GREENWALD: Thank you for this 4 opportunity to speak.
5 I'm Janet Greenwald, and I'm Coordinator 6 of Citizens for Alternatives to Radioactive Dumping, 7 which is an old organization first formed by citizens 8 in southeastern New Mexico in 1978.
9 I would like to address several comments 10 that were made earlier. I was pretty shocked to find 11 out that Nick Maxwell's testimony was cut off. And 12 Nick is the person that probably lives the closest to 13 the proposed high-level waste site. He's a young 14 computer consultant, and he has taken a lot of time 15 and put in a lot of energy into monitoring his local 16 government. And his testimony has to be very, very 17 valuable because he is actually there at the meetings 18 when a lot of these decisions were made to move 19 forward with Holtec International and to go forward 20 with this project. So, I was shocked to hear that.
21 And also, the remarks made about nuclear 22 power, that how safe it is, I mean, that kind of 23 defies common sense at this point, since we've gone 24 through Chernobyl and Fukushima. Also, it sounds NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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113 1 like this person hasn't looked into the studies that 2 have been done in Europe in which children that lived 3 close to nuclear power plants had been shown to have 4 higher cancer rates.
5 As far as this whole process with this 6 webinar goes, it's been very frustrating to deal 7 with. For one thing, in NRC announcements, they do 8 not say anywhere -- and I have looked over these 9 announcements over and over again -- that you have to 10 press *1 in order to speak. So, how many people have 11 just stayed on the line waiting for their turn to 12 speak and have not been able to because they didn't 13 do that? I tried to speak in the first webinar, and 14 I did not know about *1. Other people called me and 15 said they had thought that they were in line to speak 16 and that they couldn't speak. So, I know that this 17 is the reality, and it's an incredible misstep.
18 This whole webinar process leaves so many 19 people out in so many different ways. The older 20 people that I have talked to who have definite 21 opinions on the subject really can't face talking to 22 people they can't see or cannot even identify. There 23 is no way that I can reassure them that these are the 24 right people that they will be speaking to. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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114 1 there's a big gap there. As we know, trust in 2 government is not real high. So, making the process 3 so difficult for them, for older people and people 4 that are computer-illiterate, people who don't have 5 computers, is a little crazy. I think that it's a 6 great misunderstanding of whoever decided on these 7 formats that New Mexicans who have a low median 8 income, are largely rural, that they could 9 participate fairly in a webinar process.
10 I would ask you to extend the comment 11 period until we can have face-to-face meetings with 12 proper outreach to people. I have talked to a lot of 13 people who have never heard of these webinars. And 14 once they hear of them, they don't really feel 15 confident that they can participate.
16 When we consider environmental justice, 17 and we only consider 50 miles from the site as 18 appropriate to consider environmental justice, I 19 believe a great injustice is being done. This project 20 will affect all of us. And as we know, New Mexico is 21 a minority-majority state and it has a low median 22 income. It's last in its ability to care for its 23 children. And yet, time after time, the nuclear 24 industry targets New Mexico.
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115 1 To think that because some business 2 people in Carlsbad, and a few other people who will 3 profit from this project, want this project to come 4 to New Mexico, is a form of consent is a great 5 misunderstanding. The State as a whole has had enough 6 as far as nuclear projects go.
7 I mean, I live downwind from Los Alamos, 8 where, until a short time ago, there was a support 9 group here for contaminated Los Alamos workers, until 10 the leader of that group became too sick to continue 11 his leadership. We have the downwinders in Tularosa.
12 And unless you really dig into that subject, you might 13 think that it's spurious, but those people have 14 suffered so much from the nuclear industry, and they 15 have not been given the same consideration as people 16 in other states.
17 And that's true of New Mexico in regard 18 to many aspects of the nuclear industry. The attitude 19 seems to be, well, we've dumped this kind of waste 20 there; we're doing this kind of dangerous nuclear 21 project there; we've done the nuclear testing there; 22 we're making the nuclear bombs there. And even though 23 people have been contaminated and people are 24 suffering, we, obviously, can do more dumping because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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116 1 the State is too poor or too weak to resist.
2 I'm just hoping that this time that is 3 not true, because it's a true violation of 4 environmental justice to take a beleaguered minority, 5 low-resource state and, then, dump everything you can 6 on it, as if these people, our people, don't count.
7 So, speaking a little bit about the 8 siting, the latest USGS maps show, as the older ones 9 did, that the site, the proposed Holtec site, is in 10 the middle of one of the largest karstlands in the 11 United States. And karst is a form of geology where 12 the surface cannot hold rainfall or any other water.
13 And so, the water percolates down to where the rock 14 can hold it. Then, it runs along that rock in 15 discrete channels. In order to find karst, you have 16 to look for it, and that hasn't been done, or it 17 certainly hasn't been documented as being done in the 18 EIS.
19 So, we have to do some kind of, oh, 20 electronic resonancing where we look down into the 21 top layers of soil to see what -- down to 500 feet, 22 let's say -- to see what is going on there. It's 23 really not a very difficult process. It's fairly 24 cheap to do, but that hasn't been done at the Holtec NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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117 1 site.
2 The whole EIS, you know, certainly when 3 it comes to environmental justice and to geological 4 formations, shows very cursory consideration. It 5 makes me feel, once again, like New Mexicans don't 6 count. They're people of color. They're poor. What 7 does it matter what happens there?
8 So, I feel that the comment period needs 9 to be extended and people need to be told about this 10 process. They don't really know at this time.
11 And we do not consent. You know, my 12 husband and I went to the Blue Ribbon Commission 13 studies and meetings in Tempe, Arizona. Those were 14 the closest ones to New Mexico. And there were lots 15 of ideas bandied about, but, certainly, people felt 16 that consent should be at least statewide, not a small 17 group of people in one community, that that would be 18 consent. So, consent was never defined by the Blue 19 Ribbon Commission.
20 A lot of money and energy was put into 21 that project because, as you know, billions of 22 dollars were put into siting a nuclear waste 23 repository in Nevada, and all that money was wasted 24 because the people there didn't consent. Well, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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118 1 people here don't consent, either.
2 And so, maybe it looked like the easy 3 thing to do to just bring the waste here to New Mexico 4 with all the other waste and nuclear projects that 5 are here, that this is already a nuclear sacrifice 6 area. But the nuclear industry, and Holtec in 7 particular, might be surprised. I think New Mexico 8 is ready to finally fight back for this unfair 9 treatment.
10 I want to thank you for this opportunity 11 to speak once again, and I hope that you truly listen 12 to these comments and don't just put them in the round 13 file, where most public comment goes. Thank you.
14 MR. CAMERON: Okay. Thank you. thank 15 you, Janet. And knowing the NRC staff here that's 16 with me in the room, they are going to consider these 17 comments and not just throw them in the round file.
18 So, thank you for talking to us.
19 And, Olin, if you could just, I guess 20 just remind people, we're going to limit the rest of 21 this to people who haven't spoken already tonight.
22 And if you could just remind people that they need to 23 hit *1.
24 And if you could put the next person for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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119 1 us that hasn't spoken yet?
2 OPERATOR: Absolutely.
3 As you said, if you would like to ask a 4 question or a comment, it is *1 to get in the queue.
5 You will be required to state your name for the 6 recording. Again, if you'd like to get in the queue, 7 that's *1.
8 Our next speaker is Tami Thatcher.
9 Miss Thatcher, your line is now open.
10 MS. THATCHER: Hi. Can you hear me?
11 MR. CAMERON: Yes, we can, Tami.
12 MS. THATCHER: Thank you.
13 I'm Tami Thatcher from Idaho. And, well, 14 I was an advisory engineer at a Department of Energy 15 nuclear reactor. And, you know, we had stainless 16 steel piping for the reactor's primary coolant system 17 and very careful chemistry control of the water, so 18 that it had no chlorides. Because it's long known 19 that stainless steel is susceptible to chloride-20 induced stress corrosion cracking.
21 But we did have our water systems 22 connected to this primary piping, our water being 23 groundwater, which was actually high in chlorides.
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120 1 have chlorides. You can have groundwater that has a 2 significant chloride amount, enough to be a serious 3 risk to stainless steel.
4 And at the plant I worked for, the well 5 water was isolated by check valves, but they leaked 6 by, enough for our water that our stainless steel 7 piping had to be replaced. It had, through wall 8 stress, corrosion cracking.
9 So, when we're talking about exposure to 10 chloride, sometimes primary coolant piping that's 11 stainless steel is protected from that exposure. You 12 try to protect it from that exposure. Canisters, 13 however, that have already been packaged maybe 20 14 years ago already can be exposed to salt air water.
15 They can be exposed to groundwater sprays. There are 16 plenty of ways they can have chloride exposure, and 17 it is proven, and the NRC knows, that you can have 18 through-wall cracking progress within 20 years.
19 So, I want people to understand that.
20 So, when the gentleman from NEI, when Bruce 21 Montgomery from NEI, says there's no accelerated 22 degradation of the canisters, and he obviously has 23 the years of experience to know what he's talking 24 about, he's not being truthful, I suppose. Based on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 what I've seen at the NEI website, so many assertions 2 on that website are completely bogus. I would 3 recommend to the NRC, when NEI says it's raining 4 outside, you should assume it's sunny and it's not 5 raining. Basically, assume the opposite. If NEI 6 says this is safe, there is no accelerated 7 degradation, then the fact is it's not safe and there 8 is accelerated degradation.
9 What the NRC accepted from Holtec's 10 application was a risk assessment that had stipulated 11 that it would not include any age-related mechanisms.
12 So, you had a risk assessment that just said we're 13 simply not going to include age-related mechanisms in 14 calculating the risk of a canister leak, you know, 15 cracking through a wall.
16 So, it's completely bogus. People need 17 to understand the NRC, the NEI, are trying to hide 18 this problem. They allowed the design of these 19 canisters, thin-walled canisters that are stainless 20 steel. Yes, it's good stuff, but you're exposing it 21 to chlorides. It has all the conditions for through-22 wall stress corrosion cracking. Yes, it may take 15 23 to 20 years for the cracking to go through, but you 24 need to understand that, once they go through, you're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 going to have airborne particulate release from the 2 canisters. You're going to have trouble shipping 3 them to a permanent repository, if you did happen to 4 find one. You have no hot cells for taking the fuel 5 out of a compromised canister. That is not any part 6 of the Holtec design.
7 The NRC's monitoring of that airborne 8 particulate that would be released from these 9 canisters will be modified to whatever extent needed, 10 so that they can say, you know, "We can hardly detect 11 much. The doses are low. Don't worry about it."
12 So, I have to say that's what I think of 13 your treatment of the canisters and your stipulating 14 that leaking canisters are outside the scope of your 15 EIS, when that's going to fundamentally be leaking 16 radionuclides airborne and affecting your criticality 17 risk if you do have water involved in potential 18 leaking into a canister, and criticality concerns.
19 So, I wanted to give those comments, so 20 that people understand what NEI and what the NRC and 21 what Holtec are really trying to pull over on you.
22 So, thank you for this opportunity to 23 comment.
24 MR. CAMERON: Okay. Thank you again for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 commenting, Tami.
2 And, Olin, do we have someone else who 3 hasn't spoken before on the line?
4 OPERATOR: We do. We have Steven 5 Sondheim.
6 Steven, your line is open, sir.
7 MR. SONDHEIM: Thank you. Thank you.
8 Yes, that name is mispronounced a lot.
9 It's Steven Sondheim. Yes, thank you. I'm a member 10 of the Sierra Club. I'm part of a subcommittee called 11 the Nuclear Free Campaign.
12 And I want to agree with everybody that 13 all this needs to be consent-based, consent-based for 14 the people in the community, for the people in New 15 Mexico, for the people in Texas, and, also, for all 16 the people along the routes. I live in Chicago now, 17 which would be a major route. I used to live in 18 Memphis, which would be a major route.
19 I want to mention this problem that Bruce 20 Montgomery from NEI stated, that -- and I want to 21 refer, actually, to Davis-Besse, where my wife's 22 family lives. They can see it out their window.
23 Davis-Besse and its stainless steel thing wasn't 24 discovered -- in fact, they say it was hidden until NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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124 1 it was finally discovered, and it was almost too late.
2 And the parallel to these casks is that there is no 3 way to inspect them, to monitor them, to see if 4 they're leaking, or once they do start to leak, to 5 remove the waste or to repair them. So, it's blind.
6 That's just totally unacceptable.
7 As the previous speaker mentioned, there 8 are corrosive processes, and they wouldn't know if it 9 happened. That's got to be shored up. In fact, they 10 say that there are better cask systems that are 11 thicker and that are also inspectable, monitorable, 12 and where the problem can be found and fixed or 13 removed.
14 Those other comments, most of the germane 15 comments have been made so far. Obviously, we're 16 against moving all this waste across the country.
17 Obviously, these casks need to be better. And 18 obviously, there needs to be public hearings, you 19 know, face to face, and also, where some of these 20 technical things that we're challenging you with are 21 explained, either explained to the satisfaction or 22 back to the drawing board to be explained.
23 Okay. Well, thank you very much.
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125 1 Steven, for those comments from Chicago.
2 And, Olin, I wondered if Terry, if you 3 ever heard back from, I think it was Terry Lodge who 4 could not get on.
5 OPERATOR: We do actually have Terry 6 Lodge up now.
7 MR. CAMERON: Oh, good. Good.
8 Hey, Terry.
9 MR. LODGE: Good afternoon. Can you hear 10 me?
11 MR. CAMERON: Good afternoon. Yes, we 12 can.
13 MR. LODGE: I'd like to talk 14 about -- first of all, thank you.
15 I want to join the objections that other 16 people have been making as to the timing and the lack 17 of personal attendance to New Mexico by 18 representatives of the NRC to get comments.
19 This project is years away from becoming 20 operative, and there's plenty of time, and this is a 21 decision for the ages because of this possibility 22 that Holtec could become the substitute for a deep 23 geological repository. So, this is an incredibly 24 important decision. It's a national decision. At NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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126 1 least 215 million people presently live, recreate, or 2 work within 50 miles of the (telephonic 3 interference). It's absurd and I'm very tired of the 4 excuse that the NRC is minimally complying with their 5 clearance NEPA and, also, has to observe New Mexico's 6 requirements regarding COVID. There's plenty of 7 time. You could do this in a year, a year and a half, 8 maybe sooner, if there were any genuine leadership on 9 resolving the COVID crisis.
10 My comments are these: one of the 11 glaring absences from the DEIS is recognition and 12 discussion of the official policy of the Department 13 of Energy right now regarding the deep geological 14 repository. They announced, in 2006, that the 15 intention, the official federal government's 16 intention, is to require a standardized disposal 17 canister to be used at whatever repository ultimately 18 would be chosen. That design has never been 19 finalized. It is estimated, however, that if you 20 take the 173,000 metric tons expected there volume 21 for Holtec, you're taught that, instead of 10,000 22 deliveries, 10,000 cargoes traveling literally 23 millions of miles, ultimately, on rail in the United 24 States, there would be as many as 80,000. And that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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127 1 depends on a bunch of unanswered questions.
2 There are 12 or more closed reactor sites 3 right now that do not have any capability to unload 4 or reload or do anything to remediate the canisters 5 that they presently possess. That means that they 6 can't even be loaded into transport canisters of any 7 type to be shipped to Holtec. So, there is a need 8 for some high-tech hot cell type of capability, even 9 to get that waste out of those sites.
10 (Telephonic interference), here they 11 made it clear in 2006 that they do not accept at the 12 repository site, basically, the waste that's put 13 there and they will not repackage it. It will have 14 to be done upstream, as you know, of the project.
15 That means either the reactor sites or at Holtec.
16 And yet, Holtec refuses to permit, and the NRC is not 17 holding them to require, onsite dry transfer storage 18 or other means technologically of handling and 19 reloading the spent nuclear fuel into standardized 20 disposal canisters.
21 It's also a question mentioned, and 22 talked about considerably, that for the first 40 23 years or so -- actually, for the first 24 century -- Holtec doesn't plan on having the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 capability or having DTS onsite. They don't plan?
2 They don't intend to have any accidents or problems, 3 storage leakage crises of a radiological sort happen, 4 which requires a fantasy thought, which is certainly 5 a characteristic of this entire proposal.
6 So, you have this problem of possibly 7 having to break the overall volume down into 8 thousands more canisters, as I say, as many as 80,000, 9 certainly many hundred thousands, or you have the 10 problem of Holtec becoming a reloading facility. And 11 that implicates Holtec's predictions of how much low-12 level radioactive waste will be generated at the 13 site. If Holtec is the locus where the unloading and 14 reloading into standardized canisters occurs, then 15 there is going to be literally thousands of 16 cans -- radioactive material, in other 17 words -- generated as waste.
18 And presently, the DEIS states a very 19 minimal amount of low-level radioactive waste, 20 basically, a few thousand tons over decades. That's 21 a ridiculous underestimate in any event, but it's 22 certainly a ridiculous underestimate if Holtec 23 actually has to repackage all of this material from 24 the canisters and casks in which the waste arrived, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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129 1 and has to, basically, try to meet the disposing of 2 the material that they had not planned on.
3 Another complicating factor is that 4 presently pending before the NRC is a rulemaking by 5 another name, a rule, whereby the agency proposes to 6 re-deregulate what may very likely be low-level 7 radioactive waste, deregulate as in allowing, 8 essentially, anybody who wants to develop a landfill, 9 even one that doesn't comport with state sanitary 10 landfill requirements, that anybody can open a 11 landfill and accept radioactive material with zero 12 follow up, regulation, or oversight by the Nuclear 13 Regulatory Commission. I think that the effects and 14 implications of that rulemaking reinterpretation, 15 whatever the NRC is calling it this week, is --
16 MR. CAMERON: Olin, I think we lost Terry 17 again for some reason.
18 OPERATOR: I am seeing that on my end 19 here as well. I do apologize. Stand by just a 20 moment.
21 MR. CAMERON: Okay.
22 (Pause.)
23 OPERATOR: Mr. Lodge, if you can hear 24 me -- this is the operator again -- go ahead and press NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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130 1 *1 again, so I can reopen your line.
2 (Pause.)
3 MR. LODGE: Hello?
4 MR. CAMERON: Hello. Is that Terry?
5 MR. LODGE: Yes.
6 OPERATOR: Yes, it is.
7 MR. CAMERON: Okay. Terry, why don't you 8 finish up with your comments for us? We lost you 9 there for a while.
10 MR. LODGE: I don't suppose anyone knows 11 what I was saying when you lost me.
12 MR. CAMERON: Yes, we couldn't hear you 13 there for a while. You were talking about the NRC 14 regulation that would address what's called very low-15 level waste.
16 MR. LODGE: Ah, very good. Fine. Thank 17 you.
18 I believe that the requirements of NEPA 19 obligate the agency to take into account the proposed 20 very low-level waste reinterpretation and analyze it 21 within the context of the Holtec application, because 22 of the fact that it well could mean that there must 23 be more serious attention given to the commitments 24 for where, and in what manner, low-level radioactive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 waste is disposed of, especially given the fact that 2 it is highly likely -- in fact, it's 3 inevitable -- that there will be thousands of tons 4 more low-level radioactive waste generated by the 5 project than the applicant and the NRC are presently 6 acknowledging.
7 Thank you.
8 MR. CAMERON: Okay. Thank you for 9 bringing that to our attention, Terry.
10 And, Olin, do we have anybody on who 11 hasn't spoken to us yet?
12 OPERATOR: Unfortunately, when the mishap 13 happened with Mr. Lodge, we lost two participants, 14 Ethel and, then, I had another name, but, 15 unfortunately, I don't have what it is. But if you 16 give me a moment, I'll get another question queue 17 back up for you.
18 MR. CAMERON: Okay. Great. We look 19 forward to Ethel.
20 OPERATOR: We have a Karen Berdine.
21 Miss Karen, your line is now open.
22 MS. BONINE: Bonine. Yes?
23 MR. CAMERON: Hi, Karen.
24 MS. BONINE: Hi. It's Bonine, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 B-O-N-I-N-E. Chip knows how to say it.
2 MR. CAMERON: Okay. We got it. We got 3 it.
4 MS. BONINE: All right. Yes. The one 5 word or the two words I really want to repeat: we 6 need stronger casks, or canisters rather, stronger 7 canisters. If Germany can build them, why can't 8 Holtec, or perhaps a more reputable company, a more 9 believable company?
10 In Japan, during the tsunami at 11 Fukushima, the canisters and casks that they had 12 there withstood the incredible, unimaginable force of 13 the tsunami and the earthquake that accompanied it or 14 preceded it. It is possible to make canisters or 15 casks that can withstand immense forces. And we know 16 that immense forces can and do happen in nature, such 17 as earthquakes, such as tornadoes, such as 18 hurricanes, incredible forces, not to mention the 19 possibility of a terrorist attack on a highly visible 20 storage facility that is projected to have neatly 21 arrayed, partially above-ground storage units that 22 anybody could see from the sky from miles away.
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133 1 trigger, even in just one cask, a criticality 2 incident; could create enough energy to trigger 3 breakdowns of many, if not all, of the other canisters 4 or casks in the array. I think this is just 5 foolishness.
6 And it's also illegal because, under 7 federal law, there cannot be a temporary storage 8 facility until a permanent repository has been 9 located and approved.
10 That's all I have to say. Thank you very 11 much.
12 Did you hear me?
13 MR. CAMERON: Okay. Thank you. Yes, 14 yes. Thank you very much, Karen, and we did hear 15 you.
16 And I think we have a new operator. Is 17 it Sarah?
18 OPERATOR: That is correct, sir.
19 MR. CAMERON: Okay. Sarah, we're only 20 taking people who haven't spoken to us before, and I 21 don't know if there's anybody on the list. But there 22 was one person when Olin was with us, a woman, I'm 23 assuming a woman, named Ethel. We didn't get a last 24 name. And he couldn't get her on the line.
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134 1 Can you just tell people to press *1 if 2 they want to talk to us? So, we're not taking people 3 who we've already heard from.
4 OPERATOR: Thank you, sir.
5 Ethel, if you could at this time press 6 *1, we can open up your line, so you may speak.
7 (Pause.)
8 MR. CAMERON: We've given --
9 OPERATOR: And it is -- I'm sorry, 10 sir -- it is Ethel Rivera.
11 MR. CAMERON: Oh, good. Ethel Rivera.
12 Okay, Ethel.
13 MS. RIVERA: Thank you very much.
14 I would like to just take a moment to 15 express my heartfelt regrets that, once again, the 16 State of New Mexico and the environment are being 17 used as a trash dump for the trash of the United 18 States that no one else wants to have.
19 I want to express my protest of these 20 webinars which the majority of the American people 21 that would be affected by these actions that are being 22 proposed have no idea that this is going on.
23 I live in southeastern Michigan, not too 24 far from the route that the transport of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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135 1 materials would be taking over. This whole idea 2 reminds me of the not-too-long-ago event that 3 affected the area that I live in, including all of 4 the Great Lakes, when the Canadian nuclear industry 5 wanted to have a deep underground dump under the 6 shores of Lake Huron, not far from our own Michigan 7 cities. And it took years and many, many protests, 8 many, many hearings, all of which were widely 9 disseminated to the people of both the United States 10 and Canada and all of the surrounding areas that would 11 be affected. We finally were able to, on behalf 12 primarily of the Native Americans who were able to 13 intervene, finally put a stop to that idea.
14 But this is a very similar attempt to 15 have something of immense -- immense -- proportions 16 and immense degradation of our entire environment 17 come before an agency that has immense 18 responsibility, but seems to have abandoned its 19 responsibility to make sure that the citizens of this 20 country are kept in the dark as to what is going on.
21 I applaud the efforts of so many beyond 22 nuclear, Diane D'Arrigo and her organization, and 23 many others, the Sierra Club Nuc Free, and others, 24 but, most importantly, the people of New Mexico, who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 for years have been taken advantage of, who have 2 suffered immense -- immense -- degradation of their 3 land, of their people, of their society, and once 4 again, are being cited as a good location for 5 continued degradation and poisoning of their land and 6 their people and their degradation of their society.
7 It is just ludicrous that we are 8 continuing these efforts to do these kinds of things 9 in the dark. These webinars are not widely known to 10 even exist. Why does the NRC and its cohorts pursue 11 these efforts to do these things in the dark?
12 And in today's COVID situation, it is 13 ludicrous to think that they are being held. They 14 should be held off until the pandemic has been evaded.
15 They should be restarted. All the issues with regard 16 to the unanswered questions that have been noted in 17 today's and previous webinars/discussions should be 18 addressed. And they should be addressed in open 19 public meetings held across this country, but, 20 primarily, along the routes of the transportation 21 lanes that have been proposed and, of course, widely 22 across the entire State of New Mexico and the adjacent 23 areas of Texas that would be affected.
24 It is, to me, another example of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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137 1 corruption between private industry and businesses, 2 along with government entities, that are seeking not 3 to improve the lives of the American people, but to 4 continue to enrich their pocketbooks, and without the 5 responsibilities that go along with them.
6 Furthermore, that the NRC and the other 7 agencies involved would even consider doing business 8 with such an organization as Holtec, given the 9 allegations and the situation that the CEO and others 10 in that corporation are under scrutiny for, is just 11 another signal that we are not doing our best to serve 12 the country with the responsibilities that they have 13 sworn to undertake.
14 Thank you very much for your time.
15 MR. CAMERON: And thank you. Thank you, 16 Ethel.
17 And, Sarah, do we have one more that we 18 haven't heard from yet?
19 OPERATOR: We do. Thank you.
20 Diane Turko, your line is open.
21 MS. TURKO: Oh, hi. Hi.
22 MR. CAMERON: Hi.
23 MS. TURKO: I'm Diane Turko. Hi. I'm 24 Director of the Cape Downwinders on Cape Cod in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 Massachusetts, and we are watchdogs for the Pilgrim 2 Nuclear Reactor. We have members all across the Cape 3 and across the State.
4 And I am presenting this testimony under 5 protest. We stand in solidarity with the New Mexicans 6 who are demanding the NRC stop the Holtec license 7 application process until it is safe to hold in-8 person public meetings in New Mexico. We also support 9 the demand for the NRC to hold public meetings in 10 Texas and, also, the 44 impacted states, including my 11 home State of Massachusetts.
12 This proposed Holtec CIS is no better 13 solution for storing nuclear waste than what is 14 already in place across the United States. It's just 15 a complete failure.
16 That the NRC has concluded that impacts 17 from transportation accidents, and its assumption of 18 no release during accidents, is completely 19 irresponsible. You're making it sound like, oh, this 20 is, you know, it's going to pack the stuff up and 21 move it across the country, and don't worry about it.
22 So, the NRC is just kicking the dangerous 23 nuclear waste can down the American highways and 24 rails to dump in the minority communities. This is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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139 1 clearly social and environmental injustice. We find 2 this unacceptable and you do not have our consent.
3 Cape Downwinders will be submitting 4 written comments with many more details.
5 So, thank you for this time, and I really 6 hope that you listen to the people and wait until 7 there can be in-person meetings and hold them across 8 the United States, where all these communities will 9 be impacted.
10 Thank you.
11 MR. CAMERON: Okay. Thank you. Thank 12 you very much, Diane.
13 And I'd like to thank everybody who 14 commented today. And we're over the time. So, we're 15 going to close the meeting out now.
16 And, Sarah, I'm going to go to Kevin 17 Coyne to close the meeting. He's our senior agency 18 official. And after that, we'll be adjourned.
19 So, Kevin?
20 MR. COYNE: Thanks, Chip.
21 I just want to take a moment to thank 22 everyone again for your participation in today's 23 meeting. I think we had over 130 folks participating, 24 and we very much appreciated the comments and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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140 1 perspectives that you provided today.
2 All your comments will be captured in the 3 transcript. And we will review and analyze those 4 comments as we prepare the Final Environmental Impact 5 Statement for Holtec International's application.
6 I also want to note that the NRC takes 7 these meetings very seriously. Your comments provide 8 an important piece of information for our 9 environmental review. And to that end, from our side, 10 our environmental safety front-line supervisors and 11 management team actively participate in these 12 meetings.
13 And as Chip pointed out at the beginning 14 of the meeting, many of us are in this room now 15 actively listening to your comments, and we 16 appreciate those comments and the time that you've 17 taken out of your day to provide them.
18 Just a reminder that we ask for your 19 comments on the Draft Environmental Impact Statement 20 by September 22nd.
21 And with that, thank you very much.
22 MR. CAMERON: Okay. Thank you.
23 And, Sarah, thank you, and thank Olin for 24 the assistance, too, today.
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141 1 (Whereupon, the above-entitled matter 2 went off the record at 2:25 p.m.)
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