ML24284A007
| ML24284A007 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 10/22/2024 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| NRC-0042 | |
| Download: ML24284A007 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Public Meeting to Receive Comments on the Draft Perry Plant EIS Docket Number:
(n/a)
Location:
teleconference Date:
Tuesday, October 1, 2024 Work Order No.:
NRC-0042 Pages 1-63 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 TO RECEIVE COMMENTS ON THE DRAFT PERRY PLANT ENVIRONMENTAL IMPACT STATEMENT
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- TUESDAY, OCTOBER 1, 2024
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The meeting was convened via Videoconference, at 1:00 p.m. EDT, Lance Rakovan, Facilitator, presiding.
PRESENT:
LANCE RAKOVAN, Facilitator, NMSS SCOTT BURNELL, OPA STEVE KOENICK, NMSS KAREN LOOMIS, NMSS LEAH PARKS, NMSS VAUGHN THOMAS, NRR
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 ALSO PRESENT:
JAN BOUDART DIANE D'ARRIGO DAVID HUGHES MICHAEL KEEGAN CONNIE KLINE PAT MARIDA KALENE WALKER JULIE WEATHERINGTON-RICE
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 P-R-O-C-E-E-D-I-N-G-S 1:01 p.m.
MR. RAKOVAN: Welcome, everyone. My name is Lance Rakovan. And I am the senior environmental project manager for Perry Nuclear Power Plant License Renewal.
I wanted to draw your attention to a few things on this slide. So a point of contact if you run into any technical problems during our meeting today is Karen Loomis. That's karen.loomis@nrc.gov.
If you have not found the information on this meeting, you can find it on our public meeting schedule which is on NRC.gov.
The link here or the specific meeting number that you'll be looking for is 20241113. And you can find our meeting slides on that page. Or you can also find them in our ADAMS system under the Accession No. ML24256A167. So with that, we'll go ahead and get started with our meeting.
So again, welcome, everyone, to our public meeting today. We are here to give a preliminary understanding of our results from the environmental impact statement or Perry Plant renewal and also to listen to your comments and to solicit your comments on a draft environmental impact statement. This is
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 one of two meetings that we will be doing for this purpose. The next meeting will be tomorrow at 6:00 p.m. Eastern Time and we'll also be virtual.
So here's our agenda for today. After some introductions and opening remarks, I will be providing a brief presentation again involving our environmental review processes and the preliminary findings that you can find in the draft environmental impact statement or EIS.
We'll take a short time to see if anyone has any clarifying questions on the presentation. And after that, we'll get to the most important part of why we're here today and that's to open the floor to receive your comments. And I'll let you know how you can provide your comments when we get to that part of the meeting.
For those of you on the phone, I'm moving on to slide 3. So this is a comment gathering meeting by NRC's definition which means that our primary purpose here today is to listen to you, specifically again to collect your comments on the draft Perry Plant license renewal environmental impact statement.
We appreciate your patience in terms of the presentation, but we want to make sure that everyone who is joining us today has at least a basic
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 understanding of the document, our processes, and again, our preliminary findings in the EIS.
Please note that we are recording and transcribing today's meeting so the NRC 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 comments session or again when we do a quick check to see if there's 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 4.
So with us today are numerous NRC staff including Vaughn Thomas who is the safety review lead from our Office of Nuclear Reactor Regulation. Again, I'm Lance Rakovan. I am the environmental review lead. My home office is the Office of Nuclear Material Safety and Safeguards. And we also have Steve Koenick. He is my branch chief, the chief of the Environmental Project Management Branch 1 in NMSS.
Unfortunately, John Moses was not able to join us today. But I will go ahead and ask Steve if he could give us some opening remarks. Steve, are you there?
MR. KOENICK: Yes. Okay. Well, thank you, Lance. And before we move on to today's
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 presentation -- next. Yes, before we move on to today's presentation, I would like to briefly introduce you to the NRC.
The NRC regulates commercial nuclear power plants, research test reactors and training reactors and nuclear fuel cycle facilities 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 promotional body which became the Department of Energy.
You can scan the QR code on the slide to access the NRC's current strategic plan. If you have some free time, I encourage you to take a look. The plan's three strategic goals are key to the agency's successful fulfilling of its mission. The goals are ensure the safe and secure use of radioactive materials, continue to help to foster a healthy organization, and to inspire stakeholder confidence in the NRC.
For the third
- goal, stakeholder confidence, we use meetings like this to involve you in the regulatory process. We learned during the pandemic that webinars or virtual meetings make our
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 work accessible to a broad audience. As we continue learning about conducting these types of meetings, we've heard that holding meetings during work hours may limit attendance.
As a result to increase access and participation, we have scheduled two meetings for the Perry's DEIS. The first meeting is virtual and is being held now. And the second meeting is scheduled also virtually and it's scheduled for tomorrow evening.
I look forward to hearing from you, your insights and feedback on the Perry DEIS. Thank you in advance for your participation. With that, I turn it back to Lance.
MR. RAKOVAN: Thanks, Steve. So moving on to slide 6. Here's some background information on Perry Plant licensing history. Perry Plant Unit 1 was first licensed in November 1986. The current renewed license expires in November of 2026. If a license renewal is granted, we're looking at a 20-year period of relicensing for the plant. Slide 7.
In terms of our environmental reviews, the NRC has a generic environmental impact statement, or GEIS, for license renewal or more completely LR GEIS which addresses environmental issues that are common
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 to all plants or a distinct subset of plants.
These are referred to as Category 1 issues. For this environmental impact statement, the NRC relied on the license renewal GEIS and sought to identify any new and significant information on Category 1 or more generic issues but found essentially none. Additionally, the NRC completed site specific evaluations, so more in-depth evaluations for Category 2 issues or site specific issues. Moving on to slide 8.
So this graphic just kind of demonstrates some of the topics we look at as part of our environmental review including surface and groundwater use and quality, radiation protection, postulated accidents, air quality, and meteorology, et cetera. So we try to do a pretty large spectrum and look at a large spectrum of different environmental issues as part of our assessments. Slide 9.
So in general, the way that you'll see the impacts defined in the environmental impact statement is using this methodology, small, moderate, and large.
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
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 are sufficient to noticeably alter but not to destabilize important attributes of a resource. And finally, large effects are clearly noticeable and are sufficient to destabilize important attributes of a particular resource.
So again, the vast majority of topics that we'll look at as part of this environmental impact statement and our review will follow this methodology.
Slide 10.
There's a number of special topics that don't follow along that categorization of small, moderate, and large. So those would include historic and cultural resources. I'm sorry. I moved ahead to a slide.
Federally listed species in critical habitats under the Endangered Species Act, the criteria that we use for those is that there's going to be no effect, may affect but is not likely to adversely affect, or may affect and is likely to adversely affect.
And again, this mirrors pretty well our small, moderate, and large three categories. But it's slightly different language. For essential fish habitat, we mirror the language of the Magnuson-Stevens Act which in this case has four as opposed to
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 three categorical definitions for impacts, no adverse impacts, minimal adverse impacts, more than minimal, but less than substantial adverse effects, and substantial adverse impact.
So again, those are a few of the special labels that we'll use for a few of the categories.
Slide 11. Continuing on with a few more of the special cases. Impacts on historic and cultural resources mirror 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. So that is two categories. And an example of historic and cultural resources would be historic properties.
And then for environmental justice, those impacts use the language of 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. So again, both of these categories use only two labels.
Moving to slide 12.
So just kind of diving into the draft EIS, again, these are our preliminary findings. You'll see a large list here that designates that the impacts
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 were determined to be small. They include air quality and noise, both ground and surface water resources, socioeconomics, human health, et cetera.
So again, you can see that at least from our preliminary assessment all of these impacts of the continued operation of Perry Plant for an initial 20 years would have a small impact on the environment.
Moving to slide 13.
Again, going into some of the more specialized topics that use different categories we covered just a few moments ago for historic and cultural resources. Our preliminary finding is that the license renewal would not adversely known historic properties.
For environmental justice, there is no disproportionately high and adverse human health or environmental effects on minority and low income populations as a result of the proposed actions. And for cumulative impacts, this one is a little more complicated. So we don't necessarily just want to slap a label on it. We ask that if you are interested in cumulative impacts, you go ahead and you look at Section 4.13 in the draft EIS to get the full understanding of that.
Going to special species, special status
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 species and habitats, the ratings that we have here may affect but it is not likely to adversely affect a number of species, including the northern long-eared bat, the piping plover, and the monarch butterfly.
And we saw no effect on designated critical habitats or essential fish habitat or National Marine Sanctuaries which do not occur within the area. Slide
- 15.
For alternatives, no new and significant information was identified regarding the alternatives in which power replacement was looked at as part of this EIS and assessment. We always take into account the no action alternative, assuming if the plant were to stop operation, what the impact of that action would be in terms of energy production.
And what I'd like to stress at this point is that, again, the NRC regulates nuclear power, we do not have the ability to control what energy decision makers do with the information. So we do include an alternatives analysis as part of our work. But it is not our responsibility or our ability to make a decision when it comes to whether a nuclear plant should be relicensed, whether new solar or wind should come on.
We just do the assessment to discuss the
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 environmental impacts of what we believe would happen for an additional 20 years of operation of this plant.
So slide 16, this brings us to our preliminary recommendation that you'll find in the draft EIS, that the adverse environmental impacts of license renewal for Perry Plant -- and I apologize, a subsequent did squeak in there -- for Perry Plant for an additional 20 years beyond the current expiration date are not so great at preserving the option of license renewal for energy-planning decision makers would be unreasonable.
So in simpler terms, what this slide says is that the analysis from NRC staff performed, there's no environmental reason that energy-planning decision makers should not allow the plant to operate for an additional 20 years. We did not see the impact of the plant continuing operation great enough that we would say that they should not at least consider it. Again, it's not the NRC's decision, we can only provide this information to decision makers, and they make up their minds. And again, I apologize that we did not update this slide to get rid of the subsequent.
Slide 17, let's go through some of the milestones here and our processes. The draft EIS was published on August 30th. And the comment period
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 officially began on September 6th with the publication of a Federal Register notice by the Environmental Protection Agency. That day, there was also a Federal Register notice by the NRC announcing availability of the draft document.
We've got our public meetings today and tomorrow where we're hoping to collect your comments.
But please note that all comments are due. There's a 45-day comment period again starting on that September 6th date. That puts us approximately so that the comment period ends on October 21st.
So please try to get your comments in by then. And I'll go through in a moment the various ways that you can do that. And we are looking to publish our final environmental impact statement in April of next year.
Slide 18, so a couple ways that you can find the EIS if you're looking for it. If you'd like to look at a hard copy of the document, one is available at the Perry Public Library which is where we had our in-person scoping meeting -- environmental scoping meeting. That's at 3753 Main Street in Perry.
You can go to the Perry Plant Project public website which you can find the link here. Or you can take a look at it in our Agency Documents
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 Access and Management System or ADAMS using the Accession No. ML24241A256. So that's just a couple ways that you can find it.
You can also look in the Federal Register and look for those two Federal Register notices, one from the NRC, one from the EPA which were issued on September 6th. Both of those will have links to the document. Or as I'll go through in a minute, you can go to regulations.gov and you can find links to it there if you are going to provide comments.
Slide 19, just have a little bit of additional information here that you can find if you're looking for some information on Perry Plant.
There's a little bit of -- there's a link here that is the project public website along with another link that you can find just correspondence related to Perry in general.
Slide 20. So getting down to how you provide your comment outside of today's meeting, you can always provide them in hard copy to our Office of Administration. That's at Mailstop TWFN-7-A60M.
That's at U.S.
Nuclear Regulatory Commission, Washington, D.C. 20555. If you go to the website, regulations.gov, you can search for Docket ID NRC-2023-0136. And that will take you to a place which,
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 again, you will find information such as a link to the draft EIS as well as the ability to provide your comments.
You can send an email to PerryEnvironmental, that's one
- word, PerryEnvironment@nrc.gov. And again, we ask that you submit your comments by October 21st of this year.
Any comments that we receive after that, we will do our best to consider as part of our processes, but if you provide them by that date, then we will certainly use them and take them into account.
There will also be an appendix that is included in our final EIS that, again, we are looking to publish by April of next year where we will acknowledge the comments that we received and provide at least a summary response to all the comments. So again, try to get those comments in by October 21st if at all possible.
Okay. So let's go ahead and move on to public participation. What I'd like to do before we get to comments on the draft EIS is to just see if anyone has any clarifying questions about my presentation today. If you would like to raise your hand at this point to ask a question, if you're on MS Teams, use the raise my hand button.
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 If you're on the phone, you can press *5.
And that will make it so that I can see that you have your hand raised. I will go person by person in terms of the order that I see them. And I will activate your audio.
You will still need to unmute. So once I activate your audio, please either use the -- click on the mic button to unmute yourself. Or if you're on your phone, you can use the unmute button or possibly
- 6 to unmute.
So
- again, we'll move the comments momentarily. But I just wanted to give a quick chance to see if anyone had any questions on my presentation.
So the first hand I have is Connie Kline. Connie, you should be able to unmute.
MS. KLINE: Can you hear me?
MR. RAKOVAN: Yes, please go ahead.
MS. KLINE: Okay. Thank you. Just to clarify, I want to make sure I heard this correctly.
There will not be a summary as it were of any of the comments until -- did you say until the final EIS is issued in April?
MR. RAKOVAN: So we will be issuing a summary and a transcript of this meeting and tomorrow's meeting as well. So those will go out
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 there. But in terms of any reactions that are shared, those will not come until the final EIS. I apologize if that wasn't clear.
MS. KLINE: Okay, gotcha. Thank you.
MR. RAKOVAN: Sure. I see we also have Diane. You should be able to unmute. Did we lose you? Okay. I think we lost Diane. All right. I'm going to go ahead and move to commenting then. Again, same process. If you could just raise your hand. Oh, Diane is back. Let's see. Diane, are you with us?
MS. D'ARRIGO: Yeah, I guess when I tried to unmute, I hung up.
MR. RAKOVAN: You should be able to unmute.
MS. D'ARRIGO: Can you hear me?
MR. RAKOVAN: There you are.
MS. D'ARRIGO: Yeah, I tried --
MR. RAKOVAN: Yes, that's okay. I do that all the time.
MS. D'ARRIGO: -- to unmute before and it cut me off.
MR. RAKOVAN: Yeah, yeah. I do that all the time.
MS. D'ARRIGO: I just wondered if it's at all possible to see who all is participating in the
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 meeting. If there's a way to see what other people are here just instead of just the initials, or is that not possible the way this is set up?
MR. RAKOVAN: I don't know if there's an easy way for me to do that in real time. As part of the meeting summary, we will provide a list of attendees. That's usually attached to all of our meeting summaries. But I don't know if there's a simple way for me to do that in real time. I apologize.
MS. D'ARRIGO: And the meeting summary again comes out when?
MR. RAKOVAN: We try to get those out within 30 days of the meeting. It usually takes about a week for us to get the transcripts and then we need to review that for accuracy.
MS. D'ARRIGO: Would it be possible tomorrow --
MR. RAKOVAN: So I would say --
MS. D'ARRIGO: -- to have it so that people's names are on?
MR. RAKOVAN: I'm trying to think about how we could.
MS. D'ARRIGO: I'd just be interested on what NRC people are there and what other concerned
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 public members are present.
MR. RAKOVAN: Sure, understand. I will think about if there's an easy way for us to do that.
MS. D'ARRIGO: Thanks.
MR. RAKOVAN: Sure.
MR. BURNELL: Lance, if I could just jump in for just a moment.
MR. RAKOVAN: Yes, please, Scott.
MR. BURNELL: Good afternoon, everyone. My name is Scott Burnell. I'm one of the agency's spokespeople at our Maryland headquarters. Diane, in teams, I'm not sure if you're using an app or the browser, along the top of the window, there are a number of buttons.
MS. D'ARRIGO: Uh-huh.
MR. BURNELL: Have you clicked on people?
If you click on people, you should get a list of everyone who is currently in the meeting.
MS. D'ARRIGO: Oh, thank you. Thank you, Scott. Yeah, I'm not --
MR. BURNELL: You're welcome.
MS. D'ARRIGO: -- as familiar on this.
But that's helpful. Thank you very much.
MR. BURNELL: You're welcome.
MR. RAKOVAN: Thanks for stepping in,
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 Scott. I wasn't sure if that was available to them.
Okay. So I've got one other hand right now, Michael Keegan. Michael, do you have a quick question?
MR. KEEGAN: No, I had a quick answer and Scott just answered it. Yeah, it's the people button.
There's 44 people on the call and all the NRC upper echelon are there too. Thank you.
MR. RAKOVAN: Thanks, Michael. Okay. I'm going to go ahead and move on to comments. Again, we'll take hands as I see them in the order and activate microphones. Hopefully, you'll all be able to unmute.
If not, there's a few tricks that we can try. Again, looking specifically for comments on the draft EIS document. If you would like to provide a comment, please use the raise my hand button.
If you're on the phone, that is *5. Once we activate your audio, you'll still need to unmute.
So just click it on the mic button for those of you on Microsoft Teams. Or for those of you on the phone, that's *6.
So I'll pause for a moment to see if we have any takers. Mr. Keegan, please. You should be able to unmute and provide your comments at this time.
MR. KEEGAN: Okay. Thank you. Well,
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 sorry I missed the very opening of the meeting. But I was troubled way back during the scoping process when the NRC said they're not going to consider the impact that climate has on the nuclear power plant.
It's all the impact of the nuclear power plant has on the climate. This is during a time when we're seeing atmospheric rivers that are dumping literally feet of water in the surrounding areas, Pennsylvania, New York. There's been a bunch of it.
To a nuclear power plant at Perry that sits up on a bluff, elevated and unstable geologic formation. Adjacent communities have fallen into the lake. There are water problems, drainage problems on both sides of Perry.
And yet none of this can ever enter into an analysis. You literally are in a state of denial when you refuse to consider the impact that the environment is going to have on the nuclear power plant. So that's a fundamental problem.
There's such a move -- such a great move towards categorical exclusion to exclude everything and no consideration. This whole process is a farce because you're ignoring the obvious. There's an elephant in the room, and you're not addressing it.
Thank you.
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 MR. RAKOVAN: All right. The next hand that I see is Julie Weatherington. Julie, you should be able to unmute and provide your comment at this time.
MS. WEATHERINGTON-RICE: Hello, can you hear me?
MR. RAKOVAN: Yes, yes, we can. Please proceed.
MS. WEATHERINGTON-RICE: Yes, this is Dr.
Julie Weatherington-Rice. I'm an earth scientist.
And I am going to expand on the comments that were just made.
We're noting that geologic limitations and impacts are slight. I want to go on the record to remind you that before this facility was ever sited and built, the Ohio Department of Natural Resources Division of Geological Survey told you people do not build it there because it is an unstable location.
Your engineers chose to commit the hubris of assuming that the geologists of Ohio didn't know what they were talking about, and you went ahead and built it there on the bluff.
Now as we have noted, climate change has changed. Lake Erie does not go under ice in the winter like it used to. Last year, we only had two
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 weeks of ice cover.
And as the winter storms come barreling down the lake, we had wave action over 60 feet high measured in Cleveland just up the lake from you. Your bluffs are not over 60 feet high. So whether you think your site is going to impact the environment is one question. But I can assure you the environment and the geology are impacting you. Thank you.
MR. RAKOVAN: Thank you. The next hand that I see is Daryl Davis. Daryl, you should be able to unmute and provide your comment at this time.
Daryl Davis, are you with us? Try one more thing.
Again, looking, Daryl Davis.
Okay. This is why I have this slide. If you run into any issues, if you are attempting to unmute -- oh, there you go. I see you're unmuted now.
MS. DAVIS: I finally figured it out.
MR. RAKOVAN: There we go. Okay.
MS. DAVIS: In last October at the public scoping meeting at the library in Perry, I spoke about my concerns and since then have learned a lot more.
One of the other people, only two of us spoke at that meeting with our concerns about the Perry Plant relicensing. One of the other people there who seemed to know what he was talking about in terms of having
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 been on the site said that there was much radioactivity to be cleaned up and that he would not -
- although he was pro-nuke, he would not agree to relicensing until it was cleaned up. Can you tell me more about that? I assume he's talking about tritium because that's the biggest leaking problem over there.
MR. RAKOVAN: So his comments were specifically involved in some of the ponds that they have there. We did take his comments into account and expanded some of the reviews that we were doing. And I think -- yeah, the sediment ponds. Leah, do you want to step in real quick and address this one since I know that was your field of expertise?
MS. PARKS: Yes. Are you able to hear me?
This is Leah Parks. I'm an environmental --
MR. RAKOVAN: Yes, please.
MS. PARKS: -- scientist with the NRC.
MR. RAKOVAN: Thank you, Leah.
MS. PARKS: Yes, this comment was collected during scoping. And we did research into that comment and covered that during our audit. And there is a discussion of it within the draft environmental impact statement. I'm not sure if you wanted me to elaborate more, but there is a summary of it in the draft environmental impact statement.
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 MS. DAVIS: It would be nice to hear a little more.
MR. RAKOVAN: Leah, can you give just, like, a couple minutes?
MS. PARKS: Yeah, sure. This was the result of the licensee having to remove slightly contaminated sediment and debris from the forebay area. And they had to store it. So they stored it in what's known as the chemical cleaning lagoon. And there are technical specifications and requirements in their offsite dose calculation manual, also known as the ODCM for sampling that they need to do and other surveillance requirements in order to assure that they are meeting the Part 20 dose limits. There are also environmental monitoring locations where they regularly sample to check for any leaks as well as groundwater monitoring locations where they sample to ensure that it is not entering the groundwater.
MR. RAKOVAN: Thanks, Leah.
MS.
PARKS:
It's very slightly contaminated material. And we have more information about it in the draft environmental impact statement.
MR. RAKOVAN: Thanks for that. Daryl, did you have any comments about the draft EIS?
MS. DAVIS: No, just I was concerned 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 that might not have been addressed. But the tritium leaking and releasing is a very big concern for all of us who drink the water and who breathe the air and who might possibly be buying vegetables and produce produced in the area where it come in contact with this radioactive material. So that's about what I have to say on that.
MR. RAKOVAN: Okay. All right. Let's go ahead and go next to Connie Kline. Connie, you should be able to unmute.
MS. KLINE: Can you hear me?
MR. RAKOVAN: Yes, please.
MS. KLINE: I have one question that occurred to me in response to the previous speaker's question. When you talk about ponds, are these open?
MR. RAKOVAN: Are you asking if they're open air ponds?
MS. KLINE: Right.
MR. RAKOVAN: For the most part, yes.
MS. KLINE: And I don't know if you're going to be able to answer this. But can you give me an idea on site in relation to a particular building or area where they're located.
MR. RAKOVAN: I don't have maps prepared to provide that information right now, Connie. We can
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 certainly try to get that information if you like.
But I can tell you that those kinds of things are in the draft environmental impact statement. You can find that information there.
MS. KLINE: Okay, yes. I read the DEIS, although I read it when it first came out. And I know there are some maps in there. But I honestly don't recall a delineation of these ponds. So that's kind of my question. And then I have --
MR.
RAKOVAN:
- Leah, if you have information you'd like to step in briefly, please go ahead.
MS. PARKS: Yes, I just wanted to say that they are -- the chemical cleaning lagoon is the name that it's referred to. And there's also the Unit 2 circulating water system pump house flume area. So these are both located within the protected area. And if you look kind of near where the Unit 2 cooling tower is, it's sort of close to that.
MS. KLINE: Okay.
MS. PARKS: There's a description in the DEIS.
MS. KLINE: Yeah, I think I vaguely remember a description. But I don't remember it being delineated on a map. But that's okay. I'll go back
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 into it.
I do have another question, and I don't know if you're going to be able to answer this. There is another erosion control project. And in the scoping material, it said that the project would be completed this year.
And then I had written and inquired whether, in fact, it was completed. I wanted to see copies of state agencies permission or their analyses to precede on this. I never did get that. But what I was told was that the project was not going to start until fall. So my question is, does anyone know whether the project has started, whether it's been completed, what the status of that is?
MR. RAKOVAN: I think that's one of those that we definitely have to get back to you on, Connie.
The focus of the folks that are here is primarily on the extended operation of the plant were we to relicense it for an additional 20 years. A project like that, I don't know that we would have in depth information about. So that's something, I think, we would have to get back to you on.
MS. KLINE: Well, yeah, that's okay. It is definitely an environmental issue and it definitely
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 MR. RAKOVAN: Sure.
MS. KLINE: -- impacts -- I mean, erosion definitely impacts continued operation. And my last concern is that the coverage of seismic issues in earthquakes in particular. And Dr. Weatherington-Rice certainly can address with more authority than I can.
But pretty much the 1986 earthquake which was a magnitude 5 is ignored. I know that the NRC only considers earthquakes above a magnitude of 3, I believe it is. But subsequent to that 1986 earthquake, there have been many earthquakes within approximately a 10 mile radius of the plant.
Some of them actually the epicenter is in the lake. Some of them, the epicenter is on land.
Some of them have been in the range of 4.2 to 4.5 magnitude.
My concern is and my comment is that I think the '86 earthquake is so minimized that it's virtually ignored in your considerations. I mean, this is a seismically active area. So that kind of does it for me.
MR. RAKOVAN: All right. Thank you very much for your comments. I see our next speaker is Pat Marida. Pat, you should be able to unmute.
MS. MARIDA: I think I'm unmuted.
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 MR. RAKOVAN: There you go. We can hear you. Please proceed.
MS. MARIDA: I see that Dr. Weatherington-Rice is on this webinar. And so I really don't want to necessarily steal all her words. But I did want to say a lot about what she said in her 54-page declaration that was put in with the Ohio Nuclear Free Network and Beyond Nuclear's contentions to intervene on the relicensing of Perry.
And her report was devastating. And Dr.
Rice is one of the foremost geologists certainly in the state of Ohio, if not in the United States. And she said that the geological problems are particularly frightening. A lot is known now that was not available at the time of construction.
And much even at that time was not considered or was even just deliberately overlooked.
So we think that Nuclear Regulatory Commission must take into consideration the environmental effects of a landslide that would involve the plant. She says that
-- Dr. Rice -- I'm pretty much quoting from her report that you should have a copy of.
The predominate soil is Missouri. And this large area that underlies the facility has an engineering rating of very limited for dwellings with
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 or without basements and small commercial buildings.
Therefore, from a soils limitation, this site should not have been considered for the Perry renewal application.
So the bluff areas would be considered unstable and subject to erosion from wave action and landslides. So the soils range from loams to loamy fine sands, part of that underneath Perry Plant.
There are leaks from the wet and dry storage containment systems.
The irradiated water would move quickly through the secondary fractures to the underlying glacial materials and bedrock and then out to the lake. This is of particular concern and the release of tritium is considered. It's not advisable to use the lake as a contamination sink.
Therefore, it is imperative at all times that absolutely no contaminants leave the site. So were these factors considered when Perry was built?
No, they were not.
So there's approximately 60 feet of unconsolidated material under the plant. So unless the structures are more than 60 feet deep, they are in unconsolidated materials. And she shows a map polygon in her report that the static groundwater levels in
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 the unconsolidated material, the groundwater is 5 to 15 feet below the surface.
So there's a good possibility that the wet storage pools, if they're dug to any depth at all, they're sitting in saturated conditions at least part of the year. And so then also a part of the bedrock under there is Ohio shale. This is considered an oil shale which generates methane and radon gas in extra considerable amounts.
And that would enter the plant. So that's a -- methane, of course, could be a fire hazard and radon is radioactive. The facility must institute an ongoing investigation to ensure that the stray waste heat is not reaching the Ohio shale on the site.
So the stray waste heat from the plant because that heat could expand the shale and that could structurally undermine the facilities at the site. And so last, I'll talk about the bluff, the 60-foot bluff that Perry sits on overlooking the lake.
We questioned why the plant was not built father back from the edge of the bluff.
That's an engineering mystery. But the plant has a good view of the lake. So it's not clear how much consideration was made for the active process of shoreline erosion either.
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 Over the years, whole sections, a whole park fell into the lake. And communities have ended up falling into the lake. So flooding in the high water table at the top of the bluff, then it seeps out in the center of the bluff which creates sort of a screen you would say where the water table meets the air.
And finally, you have the shoreline erosion. And any of these could give way. And so I'll let Dr. Rice speak for herself if she does today.
But she expects that the entire bluff will eventually disintegrate and fall into the lake.
And the armoring won't be any use to retain it. So this could happen sooner rather than later more likely. And as mentioned before, earthquakes can weaken the already radioactively riddled steel and concrete.
And there's a lot of detail in her report about how the quakes are caused by tectonic movement many miles away. That a movement 100 miles away can affect then if it's going under -- if it's going --
one are is going beneath another area, then way at the other end there's also a geologic effect. So I'll just say that the report is 54 pages and maybe Dr.
Rice will talk more about this. I do want to say that
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 at some point I will submit our fact sheet on the Perry reactor which goes into a lot of other issues as well. Thank you.
MR. RAKOVAN: Okay. Thank you. The next hand that I see is Michael Keegan. Michael, you should be able to -- hold on.
MR. KEEGAN: Hello, hello?
MR. RAKOVAN: Yeah.
MR. KEEGAN: You got me?
MR. RAKOVAN: I got you.
MR. KEEGAN: Can you hear me?
MR. RAKOVAN: Yes.
MR. KEEGAN: Hello, I'm Michael Keegan. I share Lake Erie with you. And I'm very concerned about algal blooms and the impact of the thermal pollution on the algae.
And I am very familiar with the Fermi Nuclear Power Plant which is comparable in size to Perry. At Fermi, over 40 million gallons per day will go out the discharge at up to 96 degrees. And also going out those outfalls (phonetic) will be phosphorous, both considered drivers of algal blooms.
And I love my Lake Erie. And that's over in Cleveland region on Lake Erie. So the thermal pollution and the impact of 40 million gallons per day
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 coming out at 96 degrees is a pretty considerable thing.
In addition, at Fermi, about 12,000 gallons per minute of the water is evaporated. It goes out the cooling stacks. These are greenhouse gases, and they persist.
This water vapor lasts for about 9 to 11 days. But it's trapping heat on Lake Erie. As I mentioned previously, Lake Erie is not freezing over.
So the algae takes its breeding time all year long and seems to do so. Comes earlier in the spring. Leaves later in the fall around the nukes.
So this needs to be taken into consideration. There need to be some thermal limits placed upon the Perry plant and measured. And I'm concerned about the persistent toxic chemicals coming out to flush the plant of molluscicides and biocides.
So you're creating -- there's a potential for creation of microclimates when you have this kind of thermal pollution. And I'm not seeing that taken into consideration. And that's going to have a very negative impact on the health of the public. And so please make that -- address that in the process.
Thank you.
MR. BURNELL: You're muted, Lance.
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 MR. RAKOVAN: Yeah, it happens once a meeting. Julie Weatherington-Rice, you should be able to unmute and provide your comment.
MS. WEATHERINGTON-RICE: Can you hear me?
MR. RAKOVAN: We can. Please proceed.
MS. WEATHERINGTON-RICE: All right. I just want to clarify Connie's and Pat's comments.
First of all -- and you have a previous report from me and you will be getting another one about the earthquakes. They started in earnest about 2018.
They're deep. Well, they're relatively deep.
They're in the pre-cambrian and they appear to be related to an earlier plate edge. There were 40 last year through early July of this year.
There were another 20.
They are becoming much more common. They are not triggered by any land use such as injection wells which we do see in other places in Ohio in shallower zones. These are deeper.
And they are not manmade. Therefore, we can't change anything we're doing to control them.
Something has woken up down there. We don't really know what.
But the Ohio Department of Natural Resources are watching them carefully. Their seismic
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 network is recording them. And they are writing about them each year in their annual reports.
And they are concerned enough about what we're seeing in the area around Lake County to have these be written up as a special set of commentaries.
So we don't know when they'll stop. We don't know how they'll stop.
But we do know that when you're dealing with deep pre-cambrian age edges that when you do get a significant set of earthquakes, they continue. And all you have to do is look back to the New Madrid earthquakes of the 1811, 1812 in Missouri to understand how traumatic these can become. Those quakes literally brought down chimneys in Cincinnati and rang church bells in Boston.
So is it possible that you can have a catastrophic earthquake on this fault? Yeah, it is.
Do we know when it's going to happen? No. Do we know if it's going to happen? The only answer to that is maybe.
But we do know that fault is now active.
And we don't know why it's active, but we know it's active. So to assume that earthquakes are not an issue at this point would be unrealistic.
The other point I wanted to make was that
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 the question about whether your bluff is going to fail is not a question of what I think. It's documented information that's available online through the website of Ohio Department of Natural Resources geological survey. And if you'll go to their website and look for geological hazards information and look at all the information that they have provided, you will understand why your bluff is not stable and how armoring at the base is not going to solve your whole problem.
And I will just leave it at that. This is not my interpretation. This is the interpretation of some of the best geologists that have every lives.
Ohio geological survey is just as good or better than any group of geologists I have ever known in my life.
So I would pay attention to them for a change. Thank you.
MR. RAKOVAN: Okay. The next hand I have is Jan Boudart. Jan, you should be able to unmute and provide your comment at this time. Jan Boudart, are you with us? I can try one more thing if it's not working.
MS. BOUDART: Okay. Maybe I unmuted it now. Can you hear me?
MR. RAKOVAN: Yes, we can hear you.
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 MS. BOUDART: Oh, okay. Another nuclear power plant that is seeking a relicense or in the end point and the NRC is going to do a rulemaking for that. The comments on the rulemaking for the Indian Point Plant are due on December 3rd. And I just wondered if there's going to be any sort of a rulemaking for what's different at Perry and the NRC might be making a -- doing a rulemaking for Perry itself.
And the second thing I'm wondering which is not exactly related to this question today is when is the NRC going to have a rulemaking project for the effect of climate change on nuclear power plants?
This is a really big problem at Oconee and many other nuclear power plants. I mean, there was -- oh, my gosh. I can't think of the name of it.
Well, anyway, Fort Calhoun. The NRC needs to pay attention to climate change, the effect it's having on nuclear power plants. Do a specific study of the different ones that will be affected and how they will be affected.
Presumably, of course, you can't tell exactly. And the NRC should be really paying attention to climate change and developing a protocol or at least a strategic for dealing with climate
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 change around the country. And then I had a very small contribution to the seismic discussion that's going on right now.
And I have a theory that all of the glacial melting that is happening around the world is lifting a great deal of weight off of the parts of tectonic -- well, I'm not even going to have the right vocabulary that when Greenland loses many, many, many tons of weight, the area underneath Greenland is going to rise. And I feel that this is going to affect seismic stuff that's going on all over the world. And I don't know how useful that comment is. It's just an idea. So that's all I have to say, and I'd like to mute myself again.
MR. RAKOVAN: Okay. Thank you. And just to let you know, there's no planned rulemaking specifically involving Perry just to address that portion of your comment. Diane D'Arrigo. Diane, you should be able to unmute and provide your comment.
MS. D'ARRIGO: Hi, this is Diane D'Arrigo with Nuclear Information and Resource Service. A lot of the people who are concerned about what happens with this extension and our organization and others intervened in the NRC's -- it was the original waste confidence rule. And then it became the continued
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 storage rule.
And by the NRC approving its continued storage rule, you're basically taking off the table for any discussion as I understand it the fact that this reactor will continue to generate high level radioactive waste for which there's no known way to isolate. So as the amount of waste builds up at reactors around the country and we hear calls from communities that we need to get this out of these communities, what's happening here with this community is that the amount of high level waste, irradiated fuel that is generated will routinely -- will increase constantly for the whole time that it would continue to operate for the 20 years. And we end up with millions of year hazardous waste sitting -- more of it sitting on the shores of Lake Erie affecting people downwind, downstream, and in the community itself.
And despite the continued storage rule which the NRC concludes that irradiated fuel, spent fuel, high level waste will be taken care of within 60 years of the closure of the last reactor. We still will have radioactive waste building up, continuing to build up with no solution. We also had the only attempt at reprocessing, also a site that drains into Lake Erie at West Valley, New York.
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 And the idea of, quote, recycling or reprocessing this waste has led to in the past -- this is for waste from the '60s and '70s from nuclear power then. It is still an unresolved problem and a threat to Lake Erie and a potential 10 billion dollar or more cleanup from just the small amount of waste that had been generated in the '60s and '70s. So I raise this issue despite the potential of it being, quote, out of scope, as a consideration that the public, the community around the site needs to address.
If this reactor continues to operate, it is becoming a larger, potentially permanent storage site for high level radioactive waste into perpetuity.
That's it for today. I will be providing additional comments.
But the fact that we've got high level waste being generated now that we've got no solutions for isolating it and that we would blindly proceed to make more for 20 more years is unconscionable. And there are alternatives to this power. Thanks.
MR. RAKOVAN: Okay. The next hand that I see is David Hughes. David, you should be able to unmute and provide your comment at this time. David Hughes.
MR. HUGHES: Okay, Lance. Can you hear
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 me?
MR. RAKOVAN: We can. Please proceed.
MR. HUGHES: Great, thank you. I haven't seen the list completely of everybody who's here today. But I believe I'm the only one who lives right on the shore of Lake Erie because I live on the beach in Madison, Ohio.
Our family had the house there since 1947.
And I'm an old man now. So the reason I wanted to be here was because I just heard Dr. Rice and I've read all her reports about the lake and the land and the shale under Perry. And I know that shale and that bank under Perry and under everything else on the lake.
People have lost property due to that shale sliding into the lake. And I've seen it with my own eyes. I've seen my neighbor pound steel with a machine into the shale -- three feet into the shale.
And two weeks later after spending $15,000 on that shale, those pilings fell over flat.
And you can still see them on a clear day if you're lucky and the algae is not there. You can still see those pilings laying on the bottom of the lake in front of his cottage. But they were pile driven three feet into the shale, and they just fell
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 over.
I know for a fact by boating up and down the lake right in front of the beach that people have lost whole lake fronts sliding into the lake. You should see it. It looks like a war zone, the amount of concrete -- tents with concrete forms to protect their bank like we have in Madison.
And it's amazing how much land has been lost. And I don't see -- I think Dr. Rice is perfectly right. Probably the same thing is going to happen at the Perry Plant because it's the same exact structure.
And the worst thing I think is that the people in northeastern Ohio know nothing about what's going on with Perry or this extension for 20 years of operation because nobody is telling them. Guess what?
Nobody is reporting on what the NRC is doing. And the public should know what's going on. Thank you very much.
MR. RAKOVAN: All right. Let's go back to Connie Kline. Connie, you should be able to unmute.
Provide your comment at this time.
MS. KLINE: Okay. Can you hear me?
MR. RAKOVAN: Please, yes.
MS. KLINE: Okay. Thank you. A couple of
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 things. Let me start with what I think might be the simplest. It has to do with emergency planning. I don't understand how the NRC could agree to an exemption for the Perry Plant to roll back aspects of emergency planning, including eliminating shift positions, increasing response time, eliminating certain emergency planning information contained in implementing procedures.
If you're going to grant a license extension to operate a plant for 60 years that never was really intended to operate in 40 years, I don't understand how something like this could be issued to reduce emergency planning. If anything, it should be increased and reinforced. So that's one comment.
And I've got another comment about tritium leaks. The older a plant is -- and this is very well established. The older a plant is, the more likely there are increasingly serious tritium leaks.
I'm going to read short couple of sentences, excuse me, from the license renewal application. The issue of inadvertent radionuclide release is relevant to license renewal because all commercial nuclear power plants routinely release radioactive gaseous and liquid materials into the environment. There have been numerous events at
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 nuclear power reactor sites that involve unknown, uncontrolled, and unmonitored releases of radioactive liquids into groundwater, the majority of which involve tritium.
Other radioactive isotopes such as cesium and strontium have also been inadvertently released into groundwater. The types of events include leakage from spent fuel pools, buried piping, and failed pressure relief values and an effluent discharge line.
Now that's a general observation made by the applicant, made by Energy Harbor at the time that the LRA was written. Excuse me.
Well, I also wanted to mention that the Perry Plant has a mercury discharge because they can't
-- I'll report this again. They cannot meet the 30-day average permit limit. And they've also demonstrated that there's no readily apparent means to complying without constructing prohibitively expensive end of pipe controls for mercury.
That's, again, the applicant who requests the extension of the mercury variance in describing additional controls is prohibitively expensive. I don't expect you to answer these now, and I will follow up with written -- or maybe somebody -- maybe there is somebody there that can give a quick answer
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 regarding tritium releases. I'd like to know what time period elapses before -- in general before tritium leaks are discovered.
Is it an instantaneous discovery by the monitoring alarms? And also what period of time elapses between the discovery of a leak and ultimate release into Lake Erie? So those are two questions.
And then the other concern that I have, I think the NRC has been extremely negligent in the matter of tritium since it's so widespread among nuclear power plants. I don't understand why there isn't a rulemaking that makes reporting mandatory rather than voluntary as it currently is. And why there hasn't been -- why the NRC hasn't contracted to commission studies on the synergistic -- particularly the synergistic effects of mercury given that Lake Erie, for example, it's the shallowest of the Great Lakes.
I also live in Lake County and not that far from Lake Erie. And it's the shallowest of the Great Lakes. It's knowingly polluted with heavy metals that just describe the mercury variance.
Pesticides, herbicides, the biocides that the plant uses to attempt to keep the intake and discharge tunnels clear. I'd like to know what it
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 would take or what the procedure would be to commission a study on -- there's a dearth of study of tritium as it is. But particularly, synergistic effects on the ecosystem when tritium is released into already polluted water. So that's all for right now.
If there's anybody that can deal with the issue of tritium or the emergency planning exclusion that was granted, I'd appreciate it. Otherwise, I'll put it in writing. Thank you.
MR. RAKOVAN: Connie, I think it would be easiest for you to put those in writing. We have a few individuals that might be able to answer certain aspects of your questions. But a lot of them involve a lot of speculation or a lot of knowledge that's related to like other plants and such.
And I don't want to shortchange you just by giving you a simple answer to a complex issue. So it would be helpful if you could put those in writing and we can get back to you with a more fulsome response. Okay. I see that Julie Weatherington-Rice has her hand up again. You should be able to unmute and provide your comment.
MS. WEATHERINGTON-RICE: Yeah, I just want to clarify a couple of comments that were made. The question about the glacial ice coming off of
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 Greenland, I don't know that that's affecting the earthquake situation. But what she's talking about is something known as isostatic rebound.
And what essentially happens is as ice is unloaded off of an area, you then get uplifting from the area that was pushed down by the way of the ice.
The last round of glaciation in Wisconsin melted out of Niagara Falls about 10,000 years ago. And Ohio is still experiencing isostatic rebound from the removal of the last round of glacial ice.
So the area underneath Perry is continuing to uplift slowly but surely as the land forms respond and rebound from the weight of the ice that is gone.
So I just wanted to clarify that. The question about radon gas, we in our community also live on top of the Ohio shale.
The Ohio shale is notorious for having radon gas escape from it and into enclosed areas. My son's house just had to have a radon extraction system put in because as they sealed up their basement better, the radon gas built up. So we commonly, those of us who live on the Ohio shale, experience the problems with radon gas building up.
So radon gas building up in the plant, especially in the lower levels, is a very real
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 probability. And it needs to be addressed. And I haven't seen it addressed anywhere.
My current concern is the holding of the spent fuel rods and the fuel rods to be used on site.
The half-life for the spent fuel rods is approximately 24,000 years for the decay of radiation of the spent fuel rods. And it has to go through a number of decay chains before or decay amounts before it's going to be safe for the public.
Twenty-four thousand years ago, the Perry Plant was under one to two miles of ice. That's when the ice was here. Now we are going through global warming and climate change.
But as we get to the final end of that, things turn around and get cold again. So you can't leave those spent fuel rods there forever. You're going to have to move them.
If you want to know how long the new rods have for a half-life, uranium 235 has a half-life of 700 million years. Seven hundred million years ago, we were in the pre-cambrian and we were looking unicellular life. So we're dealing with materials that literally are radioactive forever.
And with the activity of repeated ice sheets coming out of Canada, across Ohio, we have to
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 move those materials off of that site as soon as we possibly can. And frankly, I don't know where you're going to put them because there's no place on earth that's been stable as long in the past as what we're talking about needing to be stable for the future. So radioactivity is a real concern, and you can't leave those rods there, the spent ones or the good ones.
And you're going to have to pack everything up and move it away. And I want to know where you're going to move it to. Thank you.
MR. RAKOVAN: All right. I'll pause for just one moment to see if anyone else would like to provide comments. It looks like Jan Boudart. Jan, you should be able to unmute and provide your comment at this time.
MS. BOUDART: Okay. I would like permission to make an announcement that is related to Dr. Rice's last comment. But it's an announcement.
It's not directed at Perry.
MR. RAKOVAN: I'm not sure what your announcement is, so I'm not sure how to address that.
MS. BOUDART: There's going to be a talk called the New Radium Girls. Now radium is the first progeny of the decay of radon. And it is also the isotope that Marie Curie discovered, and it caused her
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 enormous trouble because she didn't realize that keeping it in her pocket was going to cause her to become quite sick.
And the radium girls literally glowed because they were using radium. Radium is very dangerous. And this talk will be the Thursday before Halloween in October at 7:00 p.m.
My organization, the Nuclear Energy -- I can't remember. Okay. NEIS, Nuclear Energy Information System. The Nuclear Energy Information System will be sponsoring this talk at 7:00 o'clock Central Time.
And the speaker will be a person who wrote a book called Petroleum 238 because it's a book about the radiation coming from shale oil, gas, and the cleanup of these petroleum things. And I wanted to --
because radium is so closely related to radon. And it's really impossible for me not to tell people that this is going to be happening on the last Thursday before Halloween.
We're not doing it on Halloween. It will be the Thursday before. And I do apologize for this off topic comment. Everybody who knows me knows I just don't stay on the topic anyway. And I'll try to do better. Thank you.
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 MR. RAKOVAN: All right. Let's go to Kalene Walker. Kalene, you should be able to unmute and provide your comment. Kalene Walker. Oh, you unmuted for a second. I saw you pop up.
MS. WALKER: Okay. Got it. Thanks.
MR. RAKOVAN: There you are.
MS. WALKER: Actually, I was wondering about those settling radioactive ponds. I'm wondering what radiological elements you test for. Is that in the report? Because there's a lot of different elements and it can be really complex to really identify the whole inventory. So I'm wondering if that information is available and how you test for it.
What kind of monitoring do you use?
MR. RAKOVAN: Leah, are you still with us?
Do you want to address that very briefly?
MS. PARKS: I am. Are you able to hear me?
MR. RAKOVAN: Please.
MS. PARKS: Yes, in the ODCM, the offsite dose calculation manual, you will find all the requirements for the sampling and analysis that they do to ensure that they are meeting the Part 20 limits for that chemical cleaning pond or lagoon.
MS. WALKER: Because a lot of times, the
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 discharge waters will -- they'll just have micro rem or something count. But we don't really know what the content is, right? Would that be a fair statement, that you give a radiological count but you don't necessarily give the inventory?
MS. PARKS: The offsite dose calculation manual will indicate which radionuclides are tested for, whether it's gross alpha, gross beta as well as other specific radionuclides. There are requirements.
They're all laid out in the ODCM.
MS. WALKER: Okay, thanks. And then I just wanted to follow on regarding the spent fuel waste which a couple of people have commented on. And the idea that this is a problem 1,000 years down the line is really to miss the point that the NRC by not following its own federal regulations in 10 CFR Part 72 for spent fuel storage, the NRC makes exemptions to very fundamental regulations such as being able to retrieve the fuel.
So the fuel at Perry and all across the country is being stored in welded shut canisters. But you can't retrieve the fuel. Therefore, you can't even inspect the fuel.
The fuel degradation continues in storage.
The NRC seems to be ignoring this or certainly not
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 acknowledging it. But the nuclear waste review board, there's been a lot of presentations on fuel degradation in storage.
And then, of course, we just have the canister degradation which is really difficult to determine. But we know that the intergranular, microscopic cracking from chloride induced stress causing cracking, that's ongoing pretty much with all the canisters. The NRC doesn't really have any way or the industry doesn't have any way to actually identify that cracking.
They can identify precursors, but not the actual cracking. And they only inspect maybe one canister, two canisters every five years. So in my opinion, and this is a now problem as far as what --
and there's no way to retrieve the fuel.
There's not even a hot cell in the country capable of taking fuel out of a degrading canister.
So I know that's off topic. But since -- I think it's off topic. But since other people are commenting, I just wanted to -- people are educated in a lot of different fields just within this one call.
And I know it's hard for someone in the NRC to move out of their silo of study. But there's a lot of serious concerns with prolonging an aging
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 nuclear power plant. Thank you.
MR. RAKOVAN: All right. So Connie, I'm going to give you one last shot at the microphone. Do you have any comments on the draft EIS?
MS. KLINE: I have a couple more questions.
Sometimes somebody else triggers something. I'd like to know where I can find the monitoring procedures, like, how often the dry casks are monitored for potential air leakage of radionuclides. So is that something else I should put in writing?
MR. RAKOVAN: That would be the best.
MS. KLINE: Okay. And then the last thing I just want to mention, I think you're going to tell me this is out of scope. But several years ago in 2022, I attended an NRC meeting about harvesting and analyzing parts. I know that if the application is divided into two parts, one is aging mechanisms and one is environmental, although I don't see how the two can really be separated.
I mean, they're integrally interwoven as far as I'm concerned. At that meeting, they said there have not been parts harvested from any GE Mark III boiling water reactors at Perry. I'm curious of that is still the case.
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 I mean, to me, that seems like the most accurate way to determine what's going on with the plant. And I'm also curious to why the NRC hasn't promulgated a rule to require harvesting and analysis of parts and components. At that meeting, they said that oftentimes when a plant is decommissioned, the parts are -- use the word discarded.
But they're sent away as waste. It's a valuable -- it's probably the most valuable way to determine exactly what is going on inside of these claims. A number of areas are. Okay. I'm done.
MR. RAKOVAN: All right. Connie, again, you're going into a topic that I'm not sure we can address. So again, I'm going to ask that you put your questions in writing and we'll try to get the information collected and get back to you. All right.
I'm going to go ahead and move forward, talk a little bit about next steps.
We will be putting together a meeting summary. That will include a participant list, our presentation, and the transcript of the meeting. If you'll like a copy of that and/or if you'd like a copy of the final EIS, you can go ahead and reach out to me at lance.rakovan@nrc.gov.
And I see we've got a couple more hands
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 coming up. All right. I'm going to take these hands, and then we're going to go ahead and move to close.
Pat Marida. Pat, you should be able to unmute.
MS. MARIDA: Yes, hello. Okay. So I just want to make a -- one more comment about someone else mentioned cutting corners on nuclear maintenance. And the Ohio Nuclear Free Network of which I am one of the coordinators, we have a linked paper that outlines 30-plus requests that were made or granted by the NRC for waivers and inspections, on standards, on maintenance, on repairs and upgrades and other regulations covering both Perry and Davis-Besse nuclear reactors.
So Perry, again, was granted exemptions due to planned closure in 2021. But these exemptions all continue. If you have any of the exemptions that don't continue, I would like to have an answer to that question.
Other than that, that is our comment. And I can provide a link to that paper. And that paper certainly does not cover all of the exemptions. Thank you.
MR. RAKOVAN: Thank you. We'll go ahead and take one more comment. Jodi Arends. Jodi, you should -- or I'm sorry, Joni Arends. Joni, you should be able to unmute and provide your comment on the
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 draft EIS.
Joni, are you with us? I'll try one thing. Joni Arends, you should be able to unmute, provide your comment. I see you've unmuted. Are you with us?
Sorry to say that we can't hear you if you are speaking. I'll go ahead and say you might want to check your Teams. You go under More and choose Settings and look at your device settings.
It's possible that maybe you've got a headset or microphone that it's defaulted to that you're not using. Or again, you could potentially try to drop off and call back in on the phone line. Don't forget that we are having a public meeting tomorrow as well at 6:00.
I'll go ahead and go through that again.
You can provide your comments in writing to our Office of Administration through the website regulations.gov looking for Docket ID NRC-2023-0136. Or you can send an email with your comments to PerryEnvironmental, one word, PerryEnvironmental@nrc.gov.
And again, we ask that you try to get your comments in by October 21st. Again, Joni, I see you're unmuted. We just can't hear you unfortunately.
All right. Well, I apologize for that. I'm not sure
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 what the issue is.
Ill go ahead and leave your line unmuted.
If you're able to get through, please go ahead. But in the meantime, I think we're going to go ahead and move to close. So Steve, do you want to provide some closing remarks?
MR. KOENICK: Yeah, thank you, Lance. And on behalf of the staff, I want to thank everyone for taking the time today to attend the virtual public meeting to hear your questions and comments. Lance previously discussed next steps. I'll quickly summarize.
We are currently about halfway through the comment period. And we'll accept your input until October 21st. Our team will gather the comments we heard today as well as the comments that we're going to hear in tomorrow's virtual meeting as well as any other comments received by various methods on the screen, what Lance talked about.
And then we will compile the comments, evaluate them, and disposition them in the appendices to the final environmental impact statement.
Currently, the schedule for that is in April 2025.
You can access the final -- you can access the draft by visiting the website, signing up on listserv,
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 searching in the agency ADAMS, and providing your contact information to Lance. Again, thank you for your comments, questions, and for taking the time to attend today's meeting. With that, have a pleasant afternoon.
(Simultaneous speaking.)
MR. RAKOVAN: Hold on, Steve. Just one more thing I want to -- I want to give Joni one more shot. Joni, are you able to unmute? Unfortunately, I've done about everything I can to help her out.
MR. KOENICK: And Lance, what time is the meeting tomorrow you mentioned?
MR. RAKOVAN: The meeting tomorrow is at 6:00 p.m. Eastern Time. And again, the details on that meeting can be found on our public meeting schedule.
MR. KOENICK: And if people had made comments today, they do not necessarily have to repeat those because we will be taking all of the information on both transcripts and collecting all of them, correct?
MR. RAKOVAN: Correct. And it will be the same presentation. So if you're expecting a different presentation, it will be essentially the same presentation. All right. Well, I think with that we
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 are closed. Thank you, everyone, for your time today and we might see some of you tomorrow. Have a good evening.
(Whereupon, the above-entitled matter went off the record at 2:40 p.m.)