ML24150A294
| ML24150A294 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 05/08/2024 |
| From: | NRC/NMSS/DREFS/ELRB |
| To: | |
| References | |
| NRC-2813 | |
| Download: ML24150A294 (70) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting on Monticello Generating Plant Subsequent License Renewal Docket Number:
(n/a)
Location:
videoconference Date:
Wednesday, May 8, 2024 Work Order No.:
NRC-2813 Pages 1-69 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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PUBLIC MEETING ON MONTICELLO GENERATING PLANT SUBSEQUENT LICENSE RENEWAL
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WEDNESDAY, MAY 8, 2024
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The meeting was convened via Videoconference, at 2:00 p.m. EST, Lance Rakovan, Facilitator, presiding.
PRESENT:
LANCE RAKOVAN, Facilitator SCOTT BURNELL, Spokesperson, NRC Office of Public Affairs JOHN MOSES, Deputy Director, NRC Rulemaking Environment and Financial Services Division JESSICA UMANA, Environmental Review Lead, NRC ALSO PRESENT:
JOHN, Public Attendee PAUL GUNTER, Public Attendee PHILLIP H., Public Attendee JOHN LAFORGE, Public Attendee
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com KELLY LUNDEEN, Public Attendee ERIC MEYER, Public Attendee LINDSAY POTTER, Public Attendee
3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com AGENDA Opening Remarks Introduce and Purpose.............................
Environmental Impact Statement Preliminary Findings Public Questions on Presentation...................
Public Comments on Environmental Impact Statement Close
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com P-R-O-C-E-E-D-I-N-G-S 2:00 p.m.
MR. RAKOVAN: All right, let's go ahead and get started.
Hello, everyone, my name is Lance Rakovan and it's my pleasure to facilitate today's meeting hosted by the U.S. Nuclear Regulatory Commission, or NRC, involving Monticello, or Monticello, not really sure and always get confused on how to pronounce it, Nuclear Generating Plant Subsequent License Renewal.
My colleague, Jessica Umana, will be our main presenter.
Our goals today are to, one, provide you with an overview of the NRC's preliminary findings and our draft Monticello Power Plant License Renewal Environmental Impact Statement, or EIS.
And two, to solicit your comments on the draft EIS.
If we could go to slide three, please?
Here's our agenda today.
After some opening remarks and some introductions, we'll move on to a brief presentation involving the preliminary findings of the draft EIS and our processes.
We'll take a short moment to see if anyone
5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com has clarifying questions on the presentation.
And after that, comes the final and most important part of this webinar where we will open the floor to receive your comments on the draft EIS.
Let me repeat that, our focus today is to receive your comments on the Draft Environmental Impact Statement.
So, if you have questions that are outside the scope of that discussion, we will most likely ask that you provide your question by email so we can get back to you at a later date.
We may attempt to address your question on a kind of short level, if you will. But we don't want to distract from the time in terms of receiving your comments.
For those of you on the phone, I'm moving on to slide four.
So, this is a comment gathering meeting by NRC's definition, which means our primary purpose here today is to listen to you.
Again, specifically to collect your comments on the draft Monticello License Renewal Environmental Impact Statement.
So, again, we appreciate your patience in terms of the presentation that we're going to give,
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com but we want to make sure that everyone who is joining us today has at least a basic understanding of the document, including its preliminary findings as well as our processes.
Please note that we are recording and transcribing today's meeting so the NRC staff can be sure to get a full accounting of the comments that you provide.
Participants will be in listen only mode until we get to the comment session, or again, when we ask to see if there are any clarifying questions on our presentation.
And I'd like to stress that no regulatory decisions will be made during today's meeting.
Moving on to slide five, please?
We have a number of staff with -- okay, I think we got -- can we go back a slide? We want the -
- there we go.
We have a number of NRC staff with us today, including Marieliz Johnson who is our safety review lead for Monticello License Renewal.
Jessica Umana who, again, I said will be our primary speaker who is the environmental review lead.
And John Moses who is our Deputy Director
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com of the Division of Rulemaking, Environmental, and Financial Support.
And in fact, I'd like to turn things over to John at this point to provide some opening remarks.
And then, we'll hand things over to Jessica.
So, if you would, John?
MR. MOSES: Thanks, Lance.
Good afternoon, everyone.
As Lance said, my name is John Moses and I'm the Deputy Director of the Rulemaking Environmental Financial Services Division at the NRC.
And I'd like to welcome you to our first public meeting on the Draft Environmental Impact Statement, or DEIS, for the Monticello Nuclear Generating Plant Subsequent License Renewal Application.
The purpose of today's meeting is to inform you about the results of the staff's environmental review and to seek your input on that Draft Environmental Impact Statement.
This is -- this first meeting will be virtual and the second meeting will be the evening next week at Monticello.
We -- I believe the library.
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com As you can see on this slide, I'd like to talk to you a little bit about how we do our work.
So, NRC's mission is to regulate commercial nuclear power plants, research, test, and training reactors, the nuclear fuel cycle, and the use of radioactive materials in medical, academic, and industrial settings.
The NRC was created by the Energy Reorganization Act of 1974 which separated the former Atomic Energy Commission into a regulatory body, the NRC, and a promotion research body which became the Department of Energy.
You can scan the QR code on this slide to access the NRC's current strategic plan.
If you have some free time, we encourage you to take a look.
The plant's three strategic goals are key to the agency successfully fulfilling it's mission.
Specifically, the goals are, one, to ensure the safe and secure use of radioactive materials.
- Two, continue to foster healthy organization.
And
- three, to inspire stakeholder confidence in the NRC.
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com For the third
- goal, stakeholder confidence, we use meetings like this one to involve you in the process.
We learned during the pandemic that webinars or virtual meetings like this make our work accessible to a broad audience.
Also, we learned that holding meetings only during working hours may limit attendance.
So, to increase public access and participation, we scheduled two different meetings on two different time schedules.
Today's will be virtual and during the day. And next meeting will be in person and during the evening.
I look forward to your insights and feedback on Monticello's DEIS.
Thank you in advance for your participation.
With that, I'll turn to Jessica Umana.
MS. UMANA: Hi, everyone.
Just wanted to greet everybody personally, I guess.
But I'm going to jump right into the presentation.
I'm going to turn the camera off.
10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com So, we should be on slide seven now.
Here's some background information on Monticello's license and history.
Monticello is a one unit plant.
The first license was issued in September 1970 and was granted initial renewed license in 2006.
The current renewed license expires in September 2030. And if the license renewal is granted, we are looking at a 20 year period of relicensing for the plant.
Next slide, please?
In terms of our environmental review, we have a Generic Environmental Impact Statement, or a GEIS, which addresses environmental issues that are common to all plants or a distinct subset of plants.
Previous reviews for subsequent license renewal used the GEIS to take a softer look at generic topics while a deeper dive into Category 2, or site specific topics was conducted.
That all changed with the issuance of Commission orders issued in 2022.
And so, what we've done is created a site specific Environmental Impact Statement for Monticello which does a full assessment of all Category 1 issues, or generic issues, and Category 2 issues, which are
11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com site specific issues.
So, again, what you'll see here in this draft EIS is the full evaluation of all site specific issues.
Slide nine, please?
All right, and here's -- this is the graphic that shows some of the topic or resource areas that we look at as part of our environmental review, including surface and groundwater use and quality, radiation protection and postulated accidents, and air quality and meteorology.
Slide ten?
In general, the impacts that we look at are defined as either small, moderate, or large in the EIS.
A small impact would be effects that are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of a particular resource.
Moderate effects are sufficient to noticeably alter, but not to destabilize, important attributes of the resource.
And finally, large would be effects are clearly noticeable and are sufficient to destabilize important attributes of a particular resource.
12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Next slide, please?
We should be on slide 11 for those following along.
There are some special topics that don't follow the categorization of small, moderate, or large for defining impacts.
For federally listed species and critical habitats, we use the language of the Endangered Species Act which, again, is similar in that it has three categorical definitions for impacts.
The first one being no effect.
The second one may affect but is not likely to adversely affect.
And finally, may affect and is likely to adversely affect.
So, again, three categories.
For essential fish habitat, we use the language of the Magnuson-Stevens Act, which in this case, has four categorical definitions for impacts.
One being no adverse impacts.
The second one being minimal adverse impacts.
The third, more than minimal, but less than substantial adverse impacts.
And fourth, substantial adverse impacts.
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Slide 12?
The impacts on historic and cultural resources use the language of the National Historic Preservation Act to define impacts as either there would be no adverse effect or there would be an adverse effect.
An example of a historic and cultural resource would be historic properties.
And then, for environmental justice, those impacts use the language of the executive -- the Executive Order 12898 to make a determination whether said impacts, if any, have high and adverse human health or environmental effects on minority populations and low income populations.
Slide 13?
This slide shows a list of resource areas where the impact was determined to be small for the environmental review for Monticello.
You can see they include air quality and
- noise, terrestrial and aquatic resources, socioeconomics, waste management, and so on.
For the most part, we found that the impacts on the various resource areas due to the 20 additional years of operation for Monticello, we would estimate as being small on the environment.
14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Slide 14?
Going into some of the more specialized topics that use different categorizations as we just covered a few slides ago, for historic and cultural resources, our preliminary finding is that subsequent license renewal would not adversely affect known historic properties.
For environmental justice, there are no disproportionately high and adverse human health and environmental effects on minority and low populations as a result of the proposed action to renew the license.
And for cumulative impacts, this one is a little more complicated, so we don't necessarily just slap one kind of a concise label on it, we ask that you go ahead and take a look at Section 3.15 in the Draft Environmental Impact Statement if you're interested specifically in cumulative impacts which considers the continued operation fo the plant along with the operation of other things going on in the general vicinity of the plant.
Slide 15?
So, more of these specialized categories.
For special status species and habitats, we have to limit -- we have a preliminary finding that
15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com the proposed action may affect, but is not likely to adversely affect the critters that you see listed here, the Northern log-eared bat, tricolored bat, the whooping crane, and the Monarch butterfly.
No effect is seen on designated critical habitats or essential fish habitat or National Marine Sanctuaries.
Slide 16?
For alternatives, no new and significant information was identified regarding the following alternatives in which power replace includes natural gas and renewables, renewables and storage, and new nuclear.
Also, in all NEPA evaluations, we have a no action alternative. Essentially, if the plant were to stop operation, what the impact of that action would be in terms of energy production.
Slide 17?
This brings us to our preliminary recommendation.
The adverse environmental impacts of subsequent license renewal for Monticello for an additional 20 years beyond the current expiration dates are not so great that preserving the option of subsequent license renewal for energy planning
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com decisionmakers would be unreasonable.
This is not plain English and it's not plain language. It's not very direct.
So, honestly we don't -- we aren't particular fans of this language, so, in simpler terms, what this slide -- what we're trying to say in this slide is that, from the analysis that the staff performed, there is not an environmental reason for energy planning decisionmakers to not allow the plant to continue operations for an additional 20 years.
Given the impacts on the environment, we don't see a great enough that we would say, hey, you need to close these down or you shouldn't consider keeping them operating.
Again, the NRC does not make this decision. We can only provide the analysis and a recommendation and it is up to the energy planning decisionmakers and others to decide whether they wish to continue to operate the plant or not.
Slide 18?
This covers some of the milestones in our review.
Our comment period for the Draft Environmental Impact Statement started on April 19th with the publication of the Federal Register Notice by
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com the EPA.
The draft was published by the NRC in the Federal Register on April 24th with their comment period closing 45 days from the NRC publication date, which is June 10th.
If you provide your comments after the June 10th date, we will do what we can to include your comments as we deliberate and work towards the final environmental impact statement, but we can't guarantee that you will be to -- that we will be able to accept your comments and process them if they are received after June 10th.
Again, as you heard earlier, we do have an in person public meeting scheduled for next week in the evening at the Monticello Community Center. That would be Wednesday, May 15th.
We have an open house at 5:00 p.m. And that's Central Time.
Our goal is to issue the Final Environmental Impact Statement by October.
So, if you're in the Monticello area and would like to drop in in person next week, we welcome you to do so.
Slide 19?
Now, if you want to look or -- look at or
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com obtain a copy of the Draft Environmental Impact Statement, I'll have a few copies available next week when I show up in person but we also -- I'm also going to provide the Monticello Regional Library with a copy of copies.
So, if you wish to look at a hard copy of the document, you can find the two copies there. Just ask the front desk for its location.
If you wish to take a look at an electronic version, you can to the project public website for this, which you can find here, that's provided in the second bullet on the slide.
Or you can also look at the Draft Environmental Impact Statement in our agency document access and management system, and you'll need this reference number that's listed here right next to --
it's on the last bullet right there, Draft EIS accession number.
Slide 20?
So, here's just a little more information on the project.
Again, the project website is listed here and that is where we try to put links or information in general about the work we are doing involving Monticello Subsequent License Renewal.
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com You can find links to all sorts of documents such as the Subsequent License Renewal Application, including the environmental report, our current schedule, and of course, the project manager's information such as Marieliz Johnson, who is the Safety Project Manager, and myself, the Environment Lead Project Manager.
You can also just look in terms of Monticello correspondence given in the last link provided here.
Slide 21?
Now, for submitting comments on the Draft Environmental Impact Statement, we'll go ahead and --
I'm sorry --
So, to submit comments, you can either do it by mail at the address listed here.
Your second option is to go to regulations dot gov (regulations.gov) and use the reference Docket ID Number provided here. That needs to be corrected.
For the record, that is Docket ID NRC-2023-0031.
So, I do apologize for the incorrect Docket ID number referenced here.
You can also provide your comments via email to our resource mailbox listed here at
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Monticello Environmental at NRC dot gov (MonticelloEnvironmental@nrc.gov).
And just a reminder, if you want your comments to be considered, please do so before June 10th. After that, we will do our best to include your comments or address your comments.
So, Slide 22?
Also, if you send an email to me at Jessica dot umana at NRC dot gov (jessica.umana@nrc.gov), that's Jessica, J-E-S-S-I-C-A, dot, U-M-A-N-A at NRC dot gov.
Once we gather this information together, you can ask to receive a copy of the meeting summary which has participants listed, the presentation, and transcription of the meeting.
And if you'd like, I can also help provide either a hard copy or a link to the Final Environmental Impact Statement.
Okay, so, with that, this concludes the presentation.
Lance?
MR. RAKOVAN: Thank you, Jessica.
We'd like to go ahead and move to any clarifying questions folks have on Jessica's presentation.
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Again, if you're on MS Teams, you can use your raise your hand button.
If you're on the phone, you can press start five and that will essentially have the same outcome and I will see your hand raised.
Once I activate your audio, you'll still need to unmute.
So, again, on MS Teams, it's just the unmute button.
On the phone, you can try pressing star six or unmuting.
And if we have some fumbling or if we have some technical issues with Teams as we sometimes do, we'll do our best to try a few tricks on that.
So, I saw that Mr. LaForge had raised his hand a short time ago, but we wanted to finish the presentation.
So, John, you should be able to unmute yourself and ask your question at this time.
MR. LAFORGE: Thank you, can you hear me well enough?
MR. RAKOVAN: Yes, we can hear you well enough, but if speak up, that would probably be helpful. But yes, we can hear you.
MR. LAFORGE: All right.
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com I have a question. Are you also taking comments at this time?
MR. RAKOVAN: I'd like to do quick run just on questions and then, we'll go ahead and go back and allow comments because I have another hand at this point.
And so, I'd just -- I'd like to focus on questions in the short term, if that's okay.
MR. LAFORGE: All right, that's fine.
Jessica pointed out that the draft EIS dropped on the 19th, it was made public on the 24th.
Now that Nuclear Regulator Commission initially said the draft would drop in February 2024 at a time schedule public meetings for May.
Now the draft was obviously quite late, not dropping for another two months.
But it hasn't delayed these public hearings.
So, my question is, will the NRC now extend the comment period beyond June 10th because of the extreme delay in the issuance of the draft EIS?
Hello?
MR. RAKOVAN: We're here.
I can go ahead and address that at least preliminarily.
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And then, if anyone else wants to step in.
I can tell you that we typically try to have our public meetings at some point around the mid point of the commenting period for our documents.
So, even though there was a delay in getting the EIS issued in this case, we still proceeded to have the meetings in May, which again, falls in the commenting period.
And you know, there's no specific time line of, you know, we have the meetings and then, there's a certain amount of time until the comment period ends.
So, that's kind of a long answer to say that, no, I don't believe we have any intent to extend the commenting period.
But again, keep in mind that this is not the only time that you'll have to provide your comments. You can do so in several other manners.
So, again, a bit of a long winded answer.
I don't know if anybody else wants to step in to provide some additional information, but that's basically the long answer.
MR. LAFORGE: Thank you.
I wonder, is it the policy of the NRC to extend the comment period, in this case beyond June
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 10th, if enough people or commenters request that NRC do so?
MR. RAKOVAN: So, we do not infrequently get requests to extend. And it doesn't necessarily hinge upon the number of people who send in requests.
It usually primarily depends on the reasons for those requests.
So, again, if there was a timing issue or there's, you know, a particular reason that a comment period extension would be necessary for folks to provide their input, then that would certainly get consideration.
I'm not sure it hinges on the number of requests we receive.
MR. LAFORGE: All right, thank you very much.
I would just reiterate the fact and that the February drop did not happen. So, at the end of April, the 422 page draft becomes available.
I'm just saying a long draft like that does need to be considered.
And so, without extending the comment period, I do believe it's rather unfair to the general public.
And so, I recommend that, in this case,
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com the NRC do extend the period.
MR. RAKOVAN: Okay.
I believe the process to formally request it is to send -- and someone correct me if I'm wrong here -- is to send a correspondence, either a letter or an email to SECY.
Is that the -- can someone correct me or help me out here?
(NO AUDIBLE RESPONSE)
MR. RAKOVAN: Nobody wants to help me out here.
MR. BURNELL: I'll help you out.
If I can, Jessica, this is Scott Burnell.
I'm one of the agency spokespeople at headquarters.
Lance is correct, formal requests to extend the comment period, in this case for a draft EIS, should be sent to the Office of the Secretary at the Commission headquarters.
If you need specific instructions on what addresses or email addresses to use, please send me an email S-C-O-T-T, dot, B-U-R-N-E-L-L at NRC dot gov (scott.burnell@nrc.gov).
Thank you.
MR. RAKOVAN: All right, John, did you have any other questions at this time?
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Again, I want to make sure that we handle all the questions before we move on to commenting and I've got two other hands.
So, just real quick before I move on to the next hand, did you have any other questions?
MS. UMANA: Lance, I just want to make one comment, too, for Mr. LaForge.
We do do our best to try to consider comments that come in after the June 10th date.
So, not implying anything, but if you anticipate your comments coming in shortly after the June 10th date, then, you know, we -- if you reach out to me, you know, I can let you know whether or not, hey, you -- we will consider it.
If it's longer than that, then maybe requesting an extension -- the comment extension period would be a good idea.
MR. LAFORGE: Am I back in? Hello?
MR. RAKOVAN: John, we can hear you.
MR. LAFORGE: Okay.
Are there other questions? Otherwise, I could --
MR. RAKOVAN: I've got two more hands, so let me loop around to those hands and then, we'll go ahead and take your comments after that.
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. LAFORGE: Okay.
MR. RAKOVAN: So, the next hand that I have is Kelly Lundeen.
Kelly, you should be able to unmute.
MS. LUNDEEN: Yes, can you hear me?
MR. RAKOVAN: We can, please proceed with your question.
MS. LUNDEEN: Okay.
Just wanted to make sure, Jessica, earlier you said in the slides that the Docket Number is incorrect, I just wanted to make sure that in your --
in the Federal Register page and the other NRC page about the subsequent license renewal application, are the Docket numbers correct there?
MS. UMANA: Is it in a slide? Are you referring to something I presented in the slides?
MS.
LUNDEEN:
- Yes, you were just apologizing that the Docket number was incorrect.
MS. UMANA: Angela, can you go back to that slide, please?
MR. RAKOVAN: Yes, I think she's referring to the fact that we've got NRC's there.
MS. LUNDEEN: Okay.
MS. UMANA: Yes, so, it's -- I don't have it committed to memory yet, where is it?
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. RAKOVAN: There it is, right there.
MS. UMANA: There it is, yes.
So, if you go to regulations dot gov (regulations.gov), the Docket ID you want to use is NRC-2023-0031.
MS. LUNDEEN: Okay, thank you.
MS. UMANA: Yes.
MS. LUNDEEN: Also, when we called earlier, you had said that, if we email you our comments, we should also attach them as a PDF in addition to the email we send?
MS. UMANA: Oh, no, this goes back to the gentleman that called me yesterday.
No, so, what I explained to him was, so he wanted to email me his comments directly, which is fine.
But I also ask, because we have an internal process that we follow so that we capture all of these comments is for him to address his comments, if he's going to send them via email to Monticello Environmental at NRC dot gov (MonticelloEnvironmental@nrc.gov) and he cc me.
My request to him was more of a favor, is to not include any visuals or graphics or any fancy signature blocks that could be captured as graphics
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com because it complicates things for us to try to get it into ADAMS.
Again, it's a favor, but if you insist on including a nice signature block or graphics, then we'll work around it.
It just makes it easier to get it into our document management system.
MS. LUNDEEN: Okay, thank you.
So, all of the -- so, that was just in regards to emailing you.
But the instructions on the Federal Register Notice page, those are the best way to submit comments?
MS. UMANA: Absolutely, yes.
MS. LUNDEEN: Okay, thank you.
MR. RAKOVAN: All right, I do have one additional hand up.
It's just a first name, John.
John, you should be able to unmute and ask your question.
JOHN: Yes, this is John, I'm a resident at -- living right next to the power plant.
And I just wanted to reiterate what was spoken earlier that, given the late release of the draft EIS, it only seems fair to extend the deadline
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com for public comments.
I also wanted, you know, emphasize the fact that this should be a common practice to extend the comment period since your draft was late without formal requests.
So, I opposed the request that we should only request this.
This would be a demonstration of your fiduciary responsibility to ensure the public has sufficient time for informed input.
I also want to emphasize, you asked for reasons why.
I think another reason is the delay in the release of the draft EIS raises questions about commitment to transparency, especially since we've had a leak.
And one of the major concerns, this happened multiple times, is the lack of transparency and the delay of information to the public.
People live right next to this power plant.
And so, I think that extending the comment deadline would demonstrate a willingness to prioritize public input and public safety as well as personal safety, which I didn't see on your list.
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com I saw environmental safety, but I didn't also see the safety of the public next to this plant.
So, I really ask that you take the correct decision and really consider extending the deadline as fiduciary responsibility and as a mission that you guys say you have as opposed to having to formally organize and request formally that you've submitted.
Thank you.
MR. RAKOVAN: All right, we've kind of shifted already into it, but let's go ahead, John, yes, John, why don't go ahead and unmute and provide your comments at this time.
John LaForge?
MR. LAFORGE: Thank you very much.
The draft EIS under Section Local and Regional Hydrology at page 3-28, line number 4, it says, the Minnesota water works reservoir also is supplied from the Mississippi River with its intake located approximately 37 miles or 59 and a half kilometers downstream from Monticello, end quote.
This notice --
MR. RAKOVAN: Mr. LaForge, did we lose you?
MR. LAFORGE: Hello?
MR. RAKOVAN: Yes, we can hear you.
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. LAFORGE: I'm sorry, why did you interrupt?
MR. RAKOVAN: You -- at least, I couldn't hear you for a moment. I don't know if that was everyone, but you went dark for a short time.
MR. LAFORGE: Okay, all right, thanks.
I'll start the sentence over.
This notice of the downstream waterworks of Minneapolis, while hardly given any weight in the draft EIS is the principle matter of fact regarding Monticello's radioactive contamination of groundwater under the facility which feeds and interchanges with the Mississippi River.
As the draft EIS notes, under 2022 Tritium Released Groundwater section on page 3-46, line number 1, under normal site hydraulic conditions, groundwater flow is toward the Mississippi River, end quote.
On March 18th of 2023, soon after MSP Minnesota Xcel publically acknowledged the massive
- leak, the Associated Press interviewed NRC spokesperson Viktoria Mytling, and reported, quote, Mytling said there is no pathway for the tritium to get into drinking water, end quote.
This alarming error is contradicted by the Northern States Power Xcel's own 2022 Annual
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Radioactive Effluent Release Report of May 10th, 2023, which states, quote, there are several mechanisms that can result in doses to members of the public, including ingestion of radionuclides in food or water, end quote.
Public misinformation by the Nuclear Regulatory Commission's Mytling is flatly contradicted as well by the NRC's own draft EIS which states,
- quote, tritium detections in wells near the Mississippi River Bank in 2023 indicate tritium impacted groundwater likely discharged to the river.
I would like to note, in particular, that the NRC's draft EIS makes light of the fact that Minneapolis, St. Paul, and surrounding suburbs all get their drinking water from the Mississippi River.
That tritium interchanges, leaked tritium from the plant, 829,000 gallons of it, evidentially, interchanges with the Mississippi River water, as explained very much in detail in the draft EIS on a regular basis.
So, the fact is, this tritium of a major leak in 2022 and 2023 has reached the intake systems for our drinking for Minneapolis, St. Paul, and the suburbs and puts those people at risk, especially women, children, and infants.
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Because we know now that tritium passes the placenta and directly puts at risk the infants or the babies in the womb.
So, I want to urge the NRC to end its public misinformation about the fact that drinking water is not at risk, when, in fact, it very much is.
Thank you.
MR. RAKOVAN: Okay, let's go to the next hand that I have.
It is Lindsay Potter.
Lindsay Potter, you should be able to unmute and provide your comments at this time.
MS. POTTER: Hello, thank you for holding this meeting.
Can you hear me?
MR. RAKOVAN: We can, please proceed.
MS. POTTER: Okay.
Well, I'd like to preface my comment by also reiterating the point that has been made now by several others.
That I really believe that, in order to do justice and in fairness to the stated intent of the NRC to solicit a full public comment on the EIS, that the NRC really must extend the comment period.
It's a 422 page document.
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com I know you said you're having two meetings, one virtual and one in person.
But I couldn't help but notice that, for those people who don't necessarily live in Monticello, the only virtual meeting that's an option falls within working hours.
So, if I'm a 9:00 to 5:00 worker or if I'm a parent who has a young child at home, I may not be able to attend this meeting.
And I also may not have had, over the course of three short weeks, a chance to read the 422 page document.
And I agree with the point, I was following the calendar schedule that the NRC posts online and couldn't help but notice that the EIS was promised to be released in February and the meeting was promised to take place in May.
And yet, the EIS was released at the end of April and the meeting was still being held in May.
And I think that that's really an injustice to people who would like to have the time, not only to review your documents, but also to be able to plan to make themselves available to comment.
And lastly, on that point, I did notice even just now on Jessica Umana's slides that the 45
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com day comment period began five days prior to the release -- the public release in the Register of the EIS.
So, how should those five days be accounted for them if the very short time period being given is to be begin before most people even have access to the document?
That seems unjust as well.
So, given that aspect of the comment, I'll move on to talk about my response to the EIS.
I think that there is a big reason for the general public to be concerned about the safety of their drinking water.
I notice both in the EIS and in the meeting that the NRC hosted last night in Monticello and virtually regarding the safety evaluation for the plant, there was a lot of emphasis put on the fact that there are not private drinking wells on the site of the Monticello plant and there are not private drinking wells within the plume of the released 829,000 gallons of tritiated radioactive water.
That may be true, however, the EIS illustrates very
- clearly, including in some pictographics, that show there are two monitoring wells 37A and 37B that sit directly adjacent to the
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com river, the Mississippi River.
So, that's one of our nation's largest waterways. And it's the source of drinking water for some 20 million people.
And those wells have detected tritium in quantities greater than 20,000 picocuries per liter which is the EPA's standard for safe drinking water.
So, the EIS admits that this tritiated water in levels beyond what the EPA deems is safe has made its way to the river and is likely to be in the river.
And yet, the fact that that river is drinking water for so many people seems to be really ignored and brushed aside because the NRC says, oh, well, it's not a private drinking well.
And I would like to, on that point, just also note that, in 2005, I think, there was tritiated water found in a much smaller quantity, just 1,400 picocuries per liter, that's compared to 20,000 picocuries per liter, were found in a private drinking well of a farmer in Bradwell in Illinois.
And that farmer successfully sued Exelon, the owner and operator of the plant, with the backing and full support of two of the U.S. Representatives, two Senators.
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And at that time, a then Senator, President Obama called for a full-scale review in the NRC of practices around tritium.
And the NRC called for that study.
And yet, it seems to be minimizing this spill, which is many orders of magnitude greater and does, in fact, affect drinking water, whether or not that drinking water's being taken from a private well.
So, I was really shocked to find that minimized here in the EIS, and hardly mentioned at all. In fact, more time was given to the discussion of aquatic life such as fish who are living in that water, which is an important fact.
But I thought the people drinking that water should be given some recognition as well.
And something else that I found to be really amiss was at the safety meeting last night, the NRC representatives said that they followed their own standard for determining doses of radiation that are safe for the public and that that standard allows for up to 100 millirem dose per year.
But the EPA standard allows for only a 4 millirem dose.
Now, 100 millirem dose would be the equivalent of getting 10 chest x-rays in a year.
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And if there are pregnant women, for example, drinking this water out of the Mississippi River, which may be filtered, but by the way, the tritium can't be taken out, if they are drinking that water, then that's the equivalent of those pregnant women receiving 10 chest x-rays in a single year.
And no medical professional would advise that that were safe.
I think most pregnant women are advised to receive no chest x-rays while they're pregnant.
So, I feel like it's really frightening to me that a representative from the NRC would sit in a public meeting last night and tell me that they are going to promote the safety of a dose of 100 millirems in a year.
And beyond that, I think it's really important for the public to know that, while the EPA has these standards in place for drinking water with only 20,000 picocuries per liter, the NRC claims that within the boundary of a plant, an operating plant, they are the only ones who can set the regulatory limits for what is safe and what is hazardous to the public in terms of dose of radiation.
And so, the NRC may draw a line in the sand and say, within this boundary, we are going to
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com make up what we think is a safe dose.
But even if it doesn't match the EPA's dose, but the NRC simultaneously recognizes in this EIS that, at certain periods of time, especially in the spring surrounding snow melts, the river actually reverses its flow because there's such a greater volume of water in the river, and it actually flows back towards the plant and joins with the groundwater.
The two waters become inseparable. They are one.
And so, that river water is merging with whatever tritiated groundwater is sitting beneath the plant.
And then, it flows back into the river.
And so, I think there's no way that the NRC can accurately and honestly claim that, on one side or other of a really arbitrary boundary that the water is no longer subject to the oversight of the Environmental Protection Agency.
To me, that seems to suggest that there's really no job or purpose for the Environmental Protection Agency as far as trying to keep our waterways and our drinking water safe.
And I would add that just above and beyond the seeming ridiculousness of the NRC's adjusting that
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 25 times the dose recommended by the EPA could be safe, there are more than 10 other countries globally who have a recommended dose that is 7 times smaller than the EPA's.
So, I think that there is a lot of consensus internationally around the fact that drinking tritiated water is not safe.
And the NRC continues to put out this claim that there is absolutely no hazard to the public.
And when I asked a question last night at the safety review, that's the first thing the gentleman said after he'd heard my question. He didn't give me any answer but he said, there's no harm to the public. The public's not at risk.
And I did not see once in the EIS an explanation from the NRC about how they determined the public is not at risk.
I didn't see anything that told me which test indicated to them that there's no risk, which research on tritium indicated to them that there's no risk.
And so, it seems that the NRC is setting their own standards, really based on what is easiest to comply with for the operators and it is not being
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com monitored by any other federal agency.
And I just don't see how that is advocating for public safety.
And so, yes, I think that I would really ask for more transparency from the NRC.
And I would like the NRC to also release tests of where they're testing river water and what they're finding in the river water.
Thank you.
MR. RAKOVAN: Okay, thank you.
Jess, did you want to take a moment to talk about the timing of the release of documents and the start of the commenting period?
MS. UMANA: Yes, I do, actually.
Hi, Lindsay, this is Jessica Umana.
So, we have some processes that we follow and we do our best to try to align the issuance of our Federal Register which announces the draft EIS along with EPA.
EPA published their Federal Register a few days before us. So, they published their Federal Register announcing the availability of the draft EIS on April 19th.
And their comment period, the 45 day comment period would have closed on June 3rd.
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com We went out with our Federal Register on April 24th, and we didn't want to short change the public on the 45 day comment period from when we issued the draft.
So, went back to EPA and requested an extension on their comment period to end on June 10th which aligns with our 45 day comment period.
Additionally, let me see, there was -- I don't now that -- I don't know how you would have known this, but we did make the Draft Environmental Impact Statement was available publically through ADAMS on April 12th.
But unless you're actively looking for it, I don't know if, you know, you would have known that.
So, I did want -- just wanted to provide that clarification that we weren't trying to short change the public five days on the comment period. We actually went to EPA and requested an extension so that our comment period -- their comment period would align with our comment period.
MR. RAKOVAN: Thanks, Jess.
The next hand I have is Paul Gunter.
Paul, you should be able to unmute.
MR. GUNTER: Hello, can you hear me?
MR. RAKOVAN: We can, please proceed.
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. GUNTER: Okay, thank you.
My name is Paul Gunter. I'm on staff with Beyond Nuclear here in Takoma Park, Maryland.
We're currently petitioning the NRC to intervene at two other nuclear power stations in the United States, North Anna Nuclear Power Station in Mineral, Virginia and the Oconee Nuclear Power Stations in South Carolina.
And, you know, we have a number of contentions that we're raising.
But I did want to talk about a common denominator for all of these reactors that are making these extreme license renewal applications such as Monticello now who joins this fleet that's looking to operate up to 60 to 80 years.
And the draft site specific Environmental impact statement for this particular license renewal and the others is contemplating noncompliance with the National Environmental Policy Act, that's NEPA.
And also in violation of NRC regulations governing the license renewal process.
Specifically, in the Monticello Draft Environmental Impact Statement, Chapter 3, Affected Environment, Environment Consequences, and Mitigating Actions at Section 3.14.3.3, Climate Change
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Projections at page 3-220.
The NRC states, quote, the effects of climate change on Monticello's structures, systems, and components are outside the scope of the NRC staff's subsequent license renewal environmental review.
Think a minute here, it goes on to say that the environmental review describes the potential effects of continued nuclear power plant operation on the environment. Not the reverse, but the nuclear power plant operation on the environment.
It goes on to
- say, site specific environmental conditions are considered when siting nuclear power plants, this includes the consideration of meteorological, hydrological siting criteria as set forth in 10 -- Chapter 10 Code of Federal Regulation Part 100, Reactor Site Criteria.
NRC regulations require that plant structures, systems, and components important to safety be designed to withstand the effect of natural phenomenon such as flooding without loss of capability to perform safety functions.
It goes on to say, quote, if new information about changing environmental conditions such as rising sea levels or potential flooding that
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com threaten safe operating conditions or challenge compliance with the plant's technical specifications become available, the NRC will evaluate the new information to determine whether any safety related changes are needed at licensed nuclear power plants, unquote.
Now, you know, this is, you know, when you
-- when we're considering the environmental impacts of nuclear power being projected its operations out, you know, to 2060 and beyond in some of these cases, you know, we need to be careful about, you know, what you're going to limit the scope on.
And what I think is very important here is that on April 2nd, 2024, the United States Government Accountability
- Office, that's the
- GAO, an investigative arm of Congress, received requests from Congress on the -- asking them to do a hard look at the resilience of nuclear power plant into license extensions.
And on April 2nd, the GAO presented such new information.
It's not in your draft report which means that the draft report itself is insufficient, inadequate, and what it's suggesting likely illegal.
Specifically, the GAO staff published GAO
47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Report 24-106326, quote, nuclear power plants, NRC should take action to fully consider the potential impacts of climate change.
The GAO report, in particular, has Appendix 3, which talks about site specific exposure to selected natural hazards and for Monticello, flooding is considered high.
So, contrary to what the draft site specific environmental impact statement for Monticello suggesting now that those risks are too small to consider, the GAO, in its investigation, says that it's high.
And, you know, there was the Yale School of Environment in an April 23rd, 2024 follow up article by James Dinneen, Can Aging U.S. Nuclear Power Plants Withstand More Extreme Weather?
James quotes a discussion with a member of, I believe it was with the Office of Public Affairs, but it quotes, in response to GAO report, the NRC said, while its licensing process does not currently consider climate
- change, existing protections are so conservative that they are sufficient to keep the reactor -- the country's reactors protected from any plausible natural hazard in combinations at a site for a licensed operational
48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com lifetime of the reactor including those that could result in climate change.
But an NRC spokesman told Yale Environment 360, the agency now plans to review the U.S. nuclear safety in light of climate hazards identified in the recent national climate assessment, which could affect decisions on licensing, unquote.
So, you know, recognizing the official investigative arm of Commerce through the GAO report out in early April and the quote of the Office of Public Affairs on questioning in the Yale School environment magazine, it has raised a significant amount of uncertainty about the current adequacy of this draft report.
And, you know, I would, you know, our concern, given what we've seen is actually universal across -- I mean, if a licensee puts an application in to extend its licensing process out to 60 to 80 years, right now, it's almost a given that climate change is going to be considered inconsequential on the effects of flooding, drought, extreme heat, extreme cold, and including sea level rise for those coastal reactors to not be worthy of taking the hard look that's required under the National Environmental Policy Act.
And we suggest that rather subject the,
49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com you know, the entire fleet that you send into this tar pit that you consider that you at least do your due process on doing the environmental qualification for such extreme license renewals.
Thank you.
MR. RAKOVAN: Thanks, Paul.
The next hand that I see is Kelly Lundeen.
Kelly, you should be able to unmute.
MS. LUNDEEN: Okay, thank you.
Thank you for taking our comments and listening to the public today.
Just to summarize, I have four points.
One is, I am requesting that the comment period be extended, not just so that I can make sure I have clear public comments myself, but in order to truly notify the public.
I know that Jessica Umana, you did give the extra five days, which we appreciate.
But as you also mentioned, it's pretty impossible to find these documents. And when they are released, and we did actually have people looking for it, but it appears to be almost deliberately difficult for the public to get information about what's going on, even when the public is supposed to be involved.
So, all right, so, that was my comment on
50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com just extending the comment period.
Other than that, I want to say that tritium is not safe and there was a safety impact to the public during the leak.
The EIS does not address health impacts of tritium released during routine releases nor the drinking water downstream that was exposed during the accident.
And the pipe inspection plan is insufficient.
So, now, I will go into some more details.
The tritium has been described, even by the NRC on your website, on your page Radiation Exposure and Cancer, it says that the -- as the dose increases, there's an incremental increase in risk.
You're following the linear no threshold model dose response which says that any increase in dose to exposure to radioactivity results in an increase in risk to cancer.
So, I just want to make sure that the facts are clear and what we are considering a health impact.
Tritium is not something that -- it's described as low energy, but it's actually low range.
And it's emissions are concentrated in a small space.
51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com It can be eight times more biologically damaging than other types of radiation if ingested or inhaled.
And can even incorporate into DNA molecules which will affect the chromosomes.
It is a -- it replaces hydrogen atoms in water molecules. So, when it gets into the groundwater, the water itself is radioactive. It has a chemical change. It is tritiated water. It is hydrogen tritium oxygen instead of hydrogen, hydrogen oxygen atoms.
Once it's part of the water, it follows the water cycle, traveling through the groundwater.
It's absorbed the roots of plants, into our food or evaporated into the atmosphere and returned to the earth through precipitation.
Human
- bodies, animal bodies cannot distinguish clean water from tritiated water which is something that makes it even more dangerous than other radionuclides.
It's capacity to be exchanged with hydrogen, the tritium with hydrogen, makes it -- kind of gives it a special ability to bind with organic materials and plants, food, and animals.
As hydrogen is one of the basic building
52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com blocks of the human body, and all of life, for that matter, we need to take it into special consideration.
Humans are made of 60 percent water.
Tritium, when it gets disguised as hydrogen, is more dangerous due to its similarity to hydrogen and not less dangerous.
So, when a fetus is growing, the tissue collects tritium at twice the concentration of material tissue.
So, around nuclear power facilities, the children and those in utero are the ones who suffer the most. They are about one and a half times more likely to be born with embryonal cancer. That mean they have cancer when they are born and have over the double the likelihood of childhood leukemia.
And that's just caused by standard operation alone. That does not include the accidents like the one you had in November 2022 and March 2023.
It is said that tritium radiation doesn't travel very far in air and can't penetrate the skin.
However, soil, plants, and food grown near reactors have been found to be contaminated up to 60 miles from reactor sites.
In the case of Monticello, this includes the entire Minneapolis, St. Paul metro area, a
53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com population of 4 million people. This is only routine releases I'm talking about, not about the accident.
While tritium may not be able to penetrate the skin, there are other points of exposure that make a protective layer of skin irrelevant.
Tritium is released legally by the regular operation in the form of radioactive water vapor.
But as long as people are living around the reactor and they breathe, that tritium will be inhaled easily bypassing the skin.
It can also be ingested through consumption of food grown around the reactor.
As you have admitted in the EIS, like the tritium leak likely discharged into the river, and one thing I have not been able to find anywhere, and even as I have asked questions, we have not heard where in the river is the water being tested.
Is it being tested at the surface of the river?
Is it being tested underground where the groundwater, the tritiated groundwater entered the river?
So, I am concerned that the health impacts to the public and the public that drink the drinking water that comes in through the Mississippi River
54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com downstream that has not been taken into account in the DEIS.
I also want to comment on the pipes.
So, Xcel had written a letter to the NRC November 9th, 2023, quote, the visual examination of the removed piping sections show that both of the CRD, which means control rod drive, pipes experienced severe corrosion of the external surfaces in the regions exposed in the groundwater and presents -
present between the buildings.
And, quote, both CRD pipes were replaced with uncoated stainless steel piping, end quote.
The letter also says that Xcel had reported on its plan for inspecting the thousands of underground pipes which may be miles long, and stating that, at the plant, they will be inspected every ten years after this initial phase of the accident that was so recent.
Which really seems insufficient if you're
-- it's 2024, you have a license to run six more years currently. So, all we have to inspect every ten years.
The accidents at this reactor are only likely to increase at this point.
The functioning of a reactor, it often, at
55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com the beginning of the life of a reactor, they have more accidents at the beginning because they're just getting going.
Kind of in the middle stage of the operation of the years going by, they become a little more stable.
But at the end, there's increase of accidents.
These are also going to increase with climate change.
So, those are my comments.
Thank you.
MR. RAKOVAN: Thank you.
The next hand that I have is Phillip H.
Phillip, you should be able to unmute and provide your comments.
PHILLIP H.: Good afternoon.
I trust that you're all well this afternoon and you can hear me.
MR. RAKOVAN: Please proceed.
PHILLIP H.: I just want to thank the NRC for holding this meeting and letting the public participate.
I share the sentiment of many of the other callers that, it's important to make sure that members
56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com of the public can meaningfully interact with this review process.
But I also recognize that part of this balance of this public regulatory interaction is to ensure that there is not undue delay or creep of the scope of the purpose of this particular process.
So, as an individual who tries to follow a lot of environmental issues, it makes it much more difficult for me to be effective in my participation when I have time lines that are actually changing and the addition of discussion of events or situations outside the scope of what was advertised within the regulatory process.
So, I appreciate that the NRC, in its presentation and its document, is continuing to recognize that this environmental impact study reviews the impacts of this particular license extension and would ask that they continue to do so.
And, yes, just appreciate that good work.
And I also think it's important to note that the -- also appreciate that the NRC has reached and taken more seriously the no alternative approach or the no action alternative consideration.
I think it's also very important when we look at issues of climate change and environmental
57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com justice.
So, thank you.
MR. RAKOVAN: Thank you.
Again, if you have a comment, you can use the raise my hand button if you are participating on Teams.
If you're on the phone, you can hit star five and that will raise your hand on my screen.
When it's your turn, I will activate your audio, but you'll still need to unmute.
For those of you on MS Teams, that's just the unmute button.
For those of you on the phone, it's either the unmute button or star six.
The next hand I have is Erik Meyer.
Erik, you should be able to unmute and provide your comment at this time.
(NO AUDIBLE RESPONSE)
MR. RAKOVAN: Erik, are you with us?
(NO AUDIBLE RESPONSE)
MR. RAKOVAN: All right, let me try one more thing.
MR. MEYER: Here we go, can you hear me?
MR. RAKOVAN: We can, please proceed.
MR. MEYER: All right, very good.
58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Yes, my name is Erik Meyer. I live in Fountain Heights, Minnesota where I serve on the City Council here.
And when, I'm not doing that, I run a nonprofit organization called Generation Atomic which is focused on building literacy around nuclear energy and our energy system.
And so, as such, very much interested in these proceedings.
And felt the need to comment on a few things I heard earlier from some other commenters who, no doubt, have quite a bit of passion about this topic and certainly have, you know, hearts in the right places for protecting public health and safety.
So, first of all, there was, you know, a question floated on whether there is consensus on the safety of water with tritium in it, tritiated water in the drinking water supply.
I would offer that perhaps there isn't when, you know, we are in the U.S., 20,000 picocuries per liter is our limit here.
But in other places like Finland, Japan, I think Japan's at something like 60,000 and Australia is much, much higher in the low millions.
I think it would be inaccurate to say
59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com there is consensus that this is a dangerous pollutant.
It, you know, has very short biological half life and it's only a beta particle and it's 18,000 electron volts.
Whereas, the potassium 40, that's, you know, naturally occurring in all potassium and in our bodies, it's beta decay is 1.3 million electron volts of energy. So, about 70 times the energy of a tritium decay.
And that's, you know, that's just our dietary potassium going on at all times.
I did do a little bit of math when the leak came out in the news to see what we're dealing with.
And the number that was recorded from the drinking well number -- or sorry, monitoring well number 9 was about 5 million picocuries per liter.
And this amount, if you were to drink directly from this leak, so, assuming the water was not diluted by an entire river's worth of water, drinking a cup of this directly from the leak would be the equivalent to flying for 15 minutes or simply just existing for a little under two days and receiving the 4,600 decay events per second that you get from the potassium 40 in your body on average.
60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com So, we're -- I think we're a little bit, you know, making a little bit of a mountain out of a molehill here in terms of radiological risk.
This, you know, to get, I think the number, 100 millirems was quoted here, to get that, you would have to drink something like 82 gallons of the water, which is quite a lot, of course.
And this is, you know, directly from the leak.
And that would give you, of course, a 100 millirems.
But from the studies we do have on connection between radiation and cancer, we see that, like the atomic bomb survivor study and a few others that the lowest dose where you'd start to see a loose linkage between radiation exposure and cancer increase is about a 100 times higher than that, that 10,000 millirems of a 100 millisieverts if you live in the rest of the world.
So, you know, it's important to keep this stuff in perspective when we have fossil fuels causing millions of deaths every year.
You know, we've seen what happens in other states when nuclear plants are shutdown early.
In New York, when they shutdown Indian
61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Point, two new gas plants had to be built to replace it.
And there was a third that was mostly item right in Queens and upwind from some lower income housing projects. And that had been barely running, and now, it's Raven's Wood Plant that's having a much higher capacity factor in putting out, you know, nitrous and sulfur dioxide into the air.
So, it's -- I think there's a -- it's clear that there's no conclusive evidence that these ultra low doses of radiation that we're talking about here present a public health danger.
But we do have plenty of evidence that the fear of nuclear energy does.
And I just appreciate the NRC for taking this very thorough and scientifically grounded approach to evaluating the license extension.
You know, I haven't read through the entire document yet, but from I've seen it's very strong work and you know, considering the impacts.
So, thank you, again, for this proceeding and I'll end my comments there.
MR. RAKOVAN: Very good.
This is the last hand that I currently have raised.
62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com So, again, I will remind people, if you have a comment that you wish to make, you can use the raise my hand button on Teams.
On the phone, if you could press star five, that will effectively do the same thing.
And again, once your audio is activated, you'll still need to unmute.
So, that's the unmute button Teams or the unmute button or star six on your phone.
Angela, if you could back up or go to the page that let's the -- that goes through how folks can provide their comments outside of this meeting, if you will. I think it's a slide or two back.
There you go, thank you.
So, again, outside of this meeting, if you wish to provide your comments, there's the meeting next week, of course.
You can submit them by mail to our Office of Administration. That's the U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
And you can go to the website regulations dot gov (regulations.gov) and search for Docket ID NRC-2023-0031.
Or you can send an email to Monticello Environmental, one word, Monticello Environmental, at
63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com NRC dot gov (MonticelloEnvironmental@nrc.gov).
Again, we're asking that your comments be submitted by June 10th.
Any comments that we receive after that, we'll attempt to do the best we can to incorporate them into our processes, but cannot guarantee it.
So, again, I'll pause for a sec to see if anyone has any comments that they would like to make.
Again, please raise your hand, or if you're on the phone, it's star five.
I'll pause for a moment.
MS. UMANA: Lance?
MR. RAKOVAN: Jessica?
MS. UMANA: Hi, I just wanted to make a note of out listserv. I don't know if members of the public are aware of this, but there's a link so you can sign up for listserv and this will help you get any operating reactor correspondence.
Is there -- the chat's not open, right?
So, if I drop it in the chat, they're not going to see it?
MR. RAKOVAN: That is correct.
MS. UMANA: Okay.
Lindsay?
I think Lindsay has her hand raised,
64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com Lance.
MR. RAKOVAN: Yes, Lindsay?
MS. POTTER: Hi, yes.
Thank you, I know I did already present a comment earlier.
And I don't want to beleaguer this call here, I'm not sure that it's really this space for having this conversation, but I do feel that one of the presenter who just spoke was really not hiding the fact that he was directly addressing some of the things that I had presented in my comment.
And I think that by presenting what that speaker is saying as being scientifically grounded doesn't really do justice to the fact that there are, in each of these instances, two sides to the coin.
So, you know, just I think that that speaker and I are really looking at the same list of countries.
I would say there's a greater number, in fact, ten or more countries that have stricter limitations on the quantities of tritium in drinking water.
Whereas, that speaker referenced the three or four countries that have a greater allowance for tritium.
65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And in referencing the fact that -- in referencing the reactors that were shutdown in New York, that speaker failed to reference the fact that Germany has now shutdown all of its nuclear power plants and has not had to see a rise in reliance on fossil fuels.
However, they did have to supply a greater amount of liquid natural gas to France because France, though they have something like 70 nuclear reactors running and are one of 54, I guess, at this point, sorry, 54, and they're one of the countries who are most dependent on nuclear power, yet, because of the severe droughts and the climate change incidents, which, again, that speaker pointed out may not be relevant to this reactor.
However, I would argue that given the massive wildfires we saw just north of here that climate caused natural disasters should definitely be a point of concern, especially when meltdown at reactor such as what we saw at Fukushima with the same design reactor can really lead to catastrophic environmental incidents.
But anyway, France, because of all of the droughts, had trouble cooling several of their reactors and I think that that ended up causing them
66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com to have a greater reliance on fossil fuels in order to make up for that.
So, I just -- I feel like, you know, a lot of what's going on here with the NRC and amongst the commenters, and in the general public, is that there's promulgation of a lot of different information.
And I know it's probably hard for people to parse through that, but I would really encourage people to consider that what's being said here, and honestly, what's being put forward in the DSE IES does not seem to be a complete picture of all of the information that is out there.
And so, whether or not there's consensus around it, it is not the point.
I think that that is true to say that there's not consensus.
And I think that there needs to be more research done.
But I
think that there is enough information to make the threat posed by this radioactive water that's been leaked from this reactor and is much, you know, it becomes increasingly more likely to happen again as the reactor ages with its miles of underground pipes going into, you know, 80 years of operation when it was originally designed to
67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com operate for 40 years.
I believe that that risk needs to be taken more seriously than it appears to be currently.
Thank you.
MR. RAKOVAN: All right, very good.
I think with that, I'm going to go ahead and see if John Moses has any closing remarks.
John, do you want to go ahead and take the stage?
MR. MOSES: Yes, thanks, Lance, I really appreciate that.
Well, on behalf of all the staff, I'd like to thank all of you for taking the time to attend today's virtual public meeting and for your questions and comments.
As was mentioned in the discussion, if you'd like to sign up to receive documents and alerts of new documents from the NRC, please reach out to some of the folks who are listed in this presentation like Jessica Umana and she will help you figure out how to sign up for the NRC's listserv.
Next, I'd like to just summarize some of our next steps.
We are currently about halfway through the period where we're accepting your comments.
68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com And we have right now until June 10th, 2024.
And our team will gather those comments that we heard today as well as comments that we hear next week at the in person meeting at the Monticello Library, as well as comments received from www regulations dot gov (www.regulations.gov), you'll want to search Docket ID NRC-2023-0031.
Also, your emails or your postal mail letters.
We will compile all those comments, evaluate them, disposition them in the appendices in the Final Environmental Impact Statement.
We anticipate issuing the Final Environmental Impact Statement in October 2024.
And once again, to reiterate, you can access the Final Environmental Impact Statement by vising the NRC's website, signing up for the listserv, searching the agency's ADAMS system or providing your contact information to Jessica.
Once again, thank you for your comments, questions, and for taking the time to attend today's meeting.
I hope you have a wonderful day.
Thank you.
69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com MR. RAKOVAN: Jessica, are you trying to get a hand up before we end?
MS. UMANA: Yes, yes.
Sorry, John, I just wanted to correct you, we're meeting at the Monticello Community Center.
MR. MOSES: Oh, sorry about that.
MS. UMANA: That's okay, it's okay, I've done it, too.
So, I just want to clarify, it's at the community center. I believe the library's probably close by.
So, just to make sure, for those that want to attend in person next week, it's 5:00 p.m. Central Time at the Monticello Community Center.
MR. MOSES: Thanks for the correction.
MR. RAKOVAN: Thanks, Jess.
All right, now, with that, I believe we are closed.
Thank you, everyone.
(Whereupon, the above-entitled matter went off the record at 3:24 p.m.)