ML14112A380

Draft Environmental Impact Statement for Callaway Plant License Renewal Public Meeting - Afternoon Session

ML14112A380
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Site:	Callaway
Issue date:	03/19/2014
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Draft Environmental Impact Statement for Callaway Plant License Renewal Public Meeting - Afternoon Session Docket Number: 50-483 Location: Fulton, Missouri Date: Wednesday, March 19, 2014 Work Order No.: NRC-643 Pages 1-54 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 PUBLIC MEETING 5 ON THE DRAFT SUPPLEMENTAL ENVIRONMENTAL IMAPCT 6 STATEMENT FOR THE LICENSE RENEWAL 7 OF CALLAWAY PLANT, UNIT 1 8 + + + + +

9 AFTERNOON SESSION 10 + + + + +

11 March 19, 2014 12 2:00 p.m. - 3:30 p.m.

13 + + + + +

14 Fulton City Hall Council Chambers 15 18 East 4th Street 16 Fulton, Missouri 65251 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 P-R-O-C-E-E-D-I-N-G-S 2 MR. BURTON: I want to welcome everybody 3 to this afternoon's meeting. The purpose of this 4 meeting is to provide an opportunity for members of the 5 public to provide comments on the NRC's Staff's Draft 6 Supplemental Environmental Impact Statement prepared 7 by the staff as part of its review of Callaway's 8 application to [renew] its operating license for an 9 additional twenty years.

10 My name is William Burton. I am going to 11 be serving as your Facilitator today. My purpose is 12 to ensure that the meeting is productive and 13 informative. Now, I do need to let you guys know that 14 it is true that my name is William Burton, but I 15 generally go by Butch. William is my granddad, just 16 so you know that I prefer Butch.

17 This is a Category 3 public meeting to 18 encourage active participation and information 19 exchange with the public, so to take comments on the 20 Draft Supplemental EIS. You may hear it called the 21 DSEIS because we like to use acronyms a lot. Hopefully 22 everyone has signed in, received copies of the agenda, 23 the presentation slide and a feedback form. If you 24 have not signed in nor received any of these documents 25 you can find them at the registration desk.

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3 1 The agenda today includes several items, 2 including an overview of NRC's Staff's License Renewal 3 Process and a summary of the results of the staff's 4 environmental review, followed by a few minutes for you 5 to ask questions on anything that you've heard at that 6 point in the presentation. After that we will open it 7 up for the main purpose of the meeting, which is to get 8 your comments on the [DSEIS]. After that we will have 9 final remarks and then we will close the meeting. Any 10 questions on the agenda? Yes.

11 MR. SMITH: Are we allowed to address 12 questions to the Nuclear Regulatory Commission during 13 the public commenting period?

14 MR. BURTON: Well, the way we would prefer 15 to do this is if you have questions not specifically 16 related to the presentation; if you have another 17 question, we would like to have you do that during 18 the, -- what we call the Q and A session, which is 19 immediately following the main presentation. So if 20 you have those kinds of questions we'll entertain them.

21 MR. SMITH: Yeah, I have very specific 22 questions.

23 MR. BURTON: Okay. Well that will be the 24 time to ask them. And hopefully we will be able to 25 address them. Any other questions on the agenda?

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4 1 (No audible response) 2 MR. BURTON: Okay. Before we get into the 3 meat of the presentation I want to go over a few 4 logistics. This meeting is being transcribed so in 5 order to get a clean transcript we would ask you to 6 minimize the distractions. So anything that you have 7 that beeps, buzzes, talks back to you or that kind of 8 thing, if you would put them on mute or turn them off 9 we would appreciate it. Also we would like as much as 10 possible to minimize side conversations because they 11 do get picked up during the recording of the transcript.

12 For those of you who don't know, the 13 restrooms are out this main door; men's room to the 14 right, lady's room to the left. If we do need to 15 evacuate for some reason we will just follow the 16 directions from security or some of the folks who work 17 here. When speaking we prefer for you to use a mic, 18 again, so that we can pick it up on the transcription.

19 You can either come up to the podium to ask your question 20 or make your comment, or we do have a handheld mic that 21 I will bring to you if you would prefer to do that.

22 23 Finally, we are always looking to improve 24 our meetings. So one of the things that you picked up 25 when you came in was a feedback form. We would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 appreciate it if at the end of the meeting if you would 2 fill it out and drop it off and leave it with us today.

3 But if you want to think about it a little bit and give 4 your comments later, you can send it in. The postage 5 is free, but we really would like you to have feedback.

6 Comments on any of the logistics, -- any questions 7 there?

8 (No audible response) 9 MR. BURTON: All right, so let's get 10 started. Let me introduce to you some of the folks from 11 the NRC who are here today. First I will introduce Ms.

12 Carmen Fells. Ms. Fells serves as the lead Project 13 Manager overseeing the staff's environmental review 14 and development of the [DSEIS]. We also have Mr. Tom 15 Hartman, the Senior Resident Inspector at Callaway.

16 He serves as the NRC's eyes and ears on a daily basis 17 at the plant. In addition, we have Mr. Brian Wittick.

18 He is the Chief of the Projects Branch that manages the 19 environmental review. And finally we have Ms. Lara 20 Uselding, in the back. She is the Public Affairs 21 Officer from our Region IV Office in Dallas, Texas. So 22 these are some of the folks that we have brought with 23 us here. And with that I will turn it over to Carmen.

24 MS. FELLS: Thank you Butch.

25 I would like to reiterate that we will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 addressing questions related to the license renewal 2 process. Other questions may be submitted as a 3 comment. First, we will go over our presentation, then 4 we will go into questions and answers. Immediately 5 following, we will go into the comment session.

6 Thank you all for taking the time to come 7 to this meeting. My name again, is Carmen Fells. I 8 am the Project Manager for the environmental review of 9 the Callaway Plant, Unit 1 License Renewal Application.

10 I hope the information that we provide with this 11 presentation will help you to understand what we have 12 done so far, and the role you can play in helping us 13 make sure that the Final Environmental Impact Statement 14 is accurate and complete. However I would like to 15 emphasize that the environmental review is not yet 16 complete.

17 So now I will start off by briefly going 18 over the agenda for today's presentation.

19 OVERVIEW 20 I will discuss the NRC's regulatory role.

21 The preliminary findings of our environmental review 22 which address the impacts associated with extending the 23 operating license for Callaway for an additional twenty 24 years. I will also present the current schedule for 25 the remainder of the environmental review and how you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 can submit comments outside of this meeting.

2 At the end of the presentation there will 3 be time for questions and answers pertaining to the 4 environmental review process. And most importantly, 5 time for you to present your comments on the Draft 6 Supplemental Environmental Impact Statement or SEIS.

7 NRC'S REGULATORY OVERSIGHT 8 The NRC was established to regulate 9 civilian use of nuclear materials, including 10 facilities producing electric power. The NRC conducts 11 license renewal reviews for plants whose owners wish 12 to operate them beyond their initial licensing period.

13 The NRC license renewal review addresses safety issues 14 related to managing the effects of aging and 15 environmental issues related to an additional twenty 16 years of operation. In all aspects of the NRC's 17 regulations our mission is three-fold, to ensure 18 adequate protection of public health and safety; to 19 promote common defense and security and to protect the 20 environment.

21 ENVIRONMENTAL REVIEW 22 We are here today to discuss the potential 23 site-specific impacts of license renewal for the 24 Callaway Plant, Unit 1. The Generic Environmental 25 Impact Statement or the GEIS examines the possible NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 environmental impacts that could occur as a result of 2 renewing licenses of individual nuclear power plants 3 under 10 CFR, Part 54. The GEIS, to the extent 4 possible, establishes the bounds and significance of 5 these potential impacts. The analysis in the GEIS 6 encompasses all operating light water and power 7 reactors. For each type of environmental impact the 8 GEIS establishes generic findings covering as many 9 plants as possible. For some environmental issues 10 the GEIS found that a generic evaluation was not 11 sufficient and that a plant-specific analysis was 12 required.

13 The site-specific findings for Callaway 14 are contained in the Draft Supplemental Environmental 15 Impact Statement published in February of this year.

16 This document contains analyses of all applicable 17 site-specific issues, as well as a review of issues 18 covered by the GEIS to determine whether the 19 conclusions in the GEIS are valid for Callaway. In 20 this process the NRC staff also reviews the 21 environmental impacts of potential power generation 22 alternatives to license renewal to determine whether 23 the impacts expected from license renewals are 24 unreasonable.

25 For each environmental issue identified an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 impact level is defined. The NRC's standard of 2 significance for impacts was established through the 3 White House Council of Environmental Quality or CEQ's 4 terminology for significance.

5 HOW IMPACTS ARE QUANTIFIED 6 The NRC established three levels of 7 significance for potential impacts, SMALL, MODERATE 8 and LARGE, as defined on the slide.

9 For a SMALL impact the effects are not 10 detectable or are so minor that they will neither 11 destabilize nor noticeably altar any important 12 attribute of the resource. For a MODERATE impact the 13 effects are sufficient to alter noticeably, but not to 14 destabilize important attributes of the resource. And 15 for a LARGE impact the effects are clearly noticeable 16 and are sufficient to destabilize important attributes 17 of the resource.

18 SITE-SPECIFIC ENVIRONMENTAL REVIEW 19 OF CALLAWAY LICENSE RENEWAL 20 This slide lists the site-specific issues 21 the NRC staff reviewed for the continued operation of 22 Callaway during the proposed license renewal period.

23 Overall the direct and indirect impacts 24 for license renewal on all of these issues were found 25 to be SMALL, which means the effects are not detectable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 or are so minor that they will neither destabilize nor 2 noticeably alter any important attribute of the 3 resource.

4 CUMULATIVE IMPACTS 5 This slide provides a summary of our 6 findings with respect to cumulative impacts associated 7 with Callaway.

8 Cumulative impacts include the effects on 9 the environment from other past, present or reasonably 10 foreseeable future human actions. These effects not 11 only include the operation of Callaway, but also 12 impacts from activities unrelated to Callaway, such as 13 future urbanization, other energy producing facilities 14 in the area and climate change.

15 Past actions are those related to the 16 resources at the time of the power plant licensing and 17 construction.

18 Present actions are those related to the 19 resources at the time of current operation of the power 20 plant. And future actions are considered to be those 21 that are reasonably foreseeable through the end of the 22 plant operation, including the period of extended 23 operations.

24 Therefore, the analysis considers 25 potential impacts through the end of the current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 license term, as well as the twenty year renewal license 2 term. While the level of impact due to direct and 3 indirect impacts of Callaway on aquatic and terrestrial 4 resources are SMALL, the cumulative impacts when 5 combined with all other sources, such as increased 6 urbanization and climate change were SMALL to MODERATE 7 for terrestrial resources and LARGE for aquatic 8 resources. In other areas considered the staff 9 preliminary concluded that the impact was SMALL.

10 ALTERNATIVES 11 The National Environmental Policy Act or 12 NEPA mandates that each Environmental Impact Statement 13 consider alternatives to any proposed major federal 14 action. A major step in determining whether license 15 renewal is reasonable or not, is comparing the likely 16 impact of continued operations of a nuclear power plant 17 with the likely impacts of alternative means of power 18 generation.

19 Alternatives must provide an option that 20 allows for the power generation capability beyond the 21 term of the current nuclear power plant operating 22 license to meet future system generating needs. In the 23 Draft Supplement NRC staff initially considered 24 fifteen different alternatives. After this initial 25 consideration the staff then chose the most likely and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 analyzed these in depth.

2 The NRC staff considered what would happen 3 if no action was taken and Callaway shuts down at the 4 end of its current license without a specific 5 replacement alternative. This alternative would not 6 provide power generation capacity. Nor would it meet 7 the needs currently met by Callaway.

8 PRELIMINARY CONCLUSION 9 The NRC's preliminary conclusion is that 10 the environmental impacts of the renewal of the 11 operating licenses from Callaway would be smaller than 12 those feasible and commercially viable alternatives.

13 The no action alternative would have SMALL 14 environmental impact in most areas, with the exception 15 of socioeconomic impacts which would be SMALL to 16 MODERATE. Continued operation would have SMALL 17 environmental impacts in all areas. The staff 18 concluded that continued operation of Callaway is the 19 environmentally preferred alternative.

20 Based on our review of likely 21 environmental impacts from license renewal, as well as 22 potential environmental impacts of alternatives to 23 license renewal, the NRC's staff's preliminary 24 recommendation in the Draft SEIS is that the adverse 25 environmental impacts of license renewal for Callaway NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 are not great enough to deny the option of license 2 renewal for energy-planning decision-makers.

3 WASTE CONFIDENCE RULEMAKING 4 For a timeframe after the end of the 5 license term for operation of a nuclear reactor which 6 is beyond the twenty year period of extended 7 operations, and before disposal in a repository, the 8 NRC addresses the continued storage of spent nuclear 9 fuel or used fuel, in the Waste Confidence Decision and 10 Rule.

11 Previous license renewal Supplemental 12 EIS(s) noted that the environmental impacts of 13 temporary storage of the nuclear fuel for the period 14 following the reactor operating license term were 15 addressed by this rule.

16 This Draft Supplemental EIS does not 17 discuss potential environmental impacts of storing 18 spent fuel for an extended period after the plant shuts 19 down, that issue will be addressed in the NRC's Waste 20 Confidence Generic Environmental Impact Statement and 21 Rule.

22 The Draft Rule and GEIS were issued in the 23 fall of 2013, and the public had the opportunity to 24 provide comments. The Final Rule and the GEIS are 25 expected to be issued in the fall of 2014. Additional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 information on the Waste Confidence Rule and the GEIS 2 can be found on the NRC's public website accurately 3 listed on the slide.

4 In August of 2012 the Commission decided 5 that the Agency would not issue licenses dependent upon 6 the Waste Confidence Decision until the Waste 7 Confidence Rulemaking is completed. However, the 8 Commission directed the staff to proceed with licensing 9 reviews and proceedings.

10 If the results of the Waste Confidence GEIS 11 and Rule identify information that impacts the analysis 12 in the Supplemental EIS for Callaway, the NRC staff will 13 perform the appropriate review for those issues and may 14 supplement the SEIS before the NRC makes a final 15 licensing decision as to whether or not to renew 16 Callaway's license.

17 If no changes are required the NRC staff 18 will base its decision on the Final Supplemental EIS, 19 the Waste Confidence EIS and Rule, regional inspections 20 and the Safety Evaluation Report.

21 ENVIRONMENTAL REVIEW MILESTONES 22 I would like to reemphasize that the 23 environmental review is not yet complete. Your 24 comments today and all written comments received by the 25 end of the comment period on April 7th will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 considered by the NRC staff as we develop a Final SEIS 2 which we currently plan to issue in November of 2014.

3 Those comments that are within the scope of the 4 environmental review and provide new and significant 5 information can help to change the staff's findings.

6 The Final SEIS will contain staff's final 7 recommendation on the acceptability of license renewal 8 based on the work we have already performed and any new 9 and significant information we receive in the form of 10 comments during the comment period.

11 ADDITIONAL INFORMATION 12 As many of you know I am the primary contact 13 for the environmental review. John Daily is the 14 primary contact for the safety review.

15 Copies of the Draft SEIS are available on 16 CD in the back, to the left, and a few hardcopies are 17 also available here. In addition, the Callaway County 18 Public Library has agreed to make a hardcopy available 19 for review. You can also find electronic copies of the 20 Draft SEIS, along with other information about the 21 Callaway's License Renewal Review online.

22 SUBMITTING COMMENTS AFTER THE MEETING 23 The NRC staff will address written 24 comments in the same way we address spoken comments 25 received today. You can submit written comments NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 either online or via conventional mail. To submit 2 written comments online visit the website 3 regulations.gov., and search for docket ID:

4 nrc-2012-0001. And if you have written comments today 5 you may give them to any NRC staff member.

6 This concludes my presentation and I will 7 turn it back over to Butch.

8 QUESTION & ANSWER SESSION 9 MR. BURTON: All right, thanks Carmen.

10 That concludes the presentation of the staff's overview 11 of the license renewal process, as well as some of the 12 findings that are documented in the [DSEIS].

13 What we wanted to do next was to open it 14 up for questions that you may have on the process, 15 anything you've heard in terms of the findings. And 16 we will take a few minutes to do that and then get into 17 the formal comment period where you can actually 18 provide specific comments on the [DSEIS].

19 So with that is there anybody with any 20 questions on anything you've heard today or any other 21 issues?

22 (One hand raised.)

23 MR. BURTON: Okay, please. Again, you 24 can come up to the podium or I can bring you the 25 handheld. Please state your name and if you have an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 affiliation, and then state your question.

2 MR. SMITH: My name is Ed Smith. I am the 3 Safe Energy Director at the Missouri Coalition for the 4 Environment.

5 The question that we first have is that our 6 organization, along with thirty-three other 7 organizations from around the country submitted 8 petitions to the Nuclear Regulatory Commission on 9 February 18, 2014, regarding the spent fuel pools and 10 nuclear reactors. Specifically citing a study 11 conducted by the NRC at the Peach Bottom Nuclear Reactor 12 that said even a small fire at a reactor pool could be 13 roughly 9,000 square miles on an average, and displace 14 4 million people. And I am curious if the Nuclear 15 Regulatory Commission can offer an update on our 16 Rulemaking Petition? That's the first question. I 17 brought the petition with me as well so that you guys 18 can have it.

19 MR. BURTON: In response, okay, you know 20 we did not bring the entire staff. We really brought 21 the folks here who were really focused on the [DSEIS].

22 So I don't think we have the personnel here who can 23 directly address your question, -- Mr. Smith, right?

24 MR. SMITH: Uh-huh (positive utterance).

25 MR. BURTON: But what I will say, -- and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 this is true for anybody else who has questions that 2 we may not have the folks here who can answer them 3 directly, what we'll do is we'll get your contact 4 information and we will make sure that we do get an 5 answer for you in terms of the status of that.

6 MR. SMITH: All right. Well that takes 7 care of a few more questions that I had.

8 MS. FELLS: We have also provided 9 literature addressing FAQ(s) on the Waste Confidence 10 Decision. You can find them in the back.

11 MR. SMITH: Yeah. Well this is separate 12 from Waste Confidence.

13 This is a question. We are a very small 14 organization. We don't have the resources that our 15 utility here does. It is our understanding that the 16 Draft Supplemental License Renewal EIS for Callaway did 17 not address the environmental impacts of storing spent 18 fuel high-density storage pools during the license 19 renewal term. What assurances can you give us that the 20 NRC has taken a hard look, as required by the National 21 Environmental Policy Act, and then that the 22 environmental risks of a pool fire at Callaway 1, or 23 measures to avoid or mitigate those risks?

24 MR. WITTICK: My name is Brian Wittick. I 25 am a Branch Chief for the License Renewal Project NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 Management. The spent fuel pool, -- there is a number 2 of different issues that are being addressed here.

3 Spent fuel pool safety is a little bit different than 4 the Waste Confidence issue. It's just a little bit 5 different from the license renewal process. The spent 6 fuel pools, -- there is currently two papers before the 7 Commission to, -- SPF (phonetic) papers, that have 8 addressed spent fuel pool safety, being that, -- or a 9 current means of storage of spent fuel in either the 10 spent fuel pools or in the ISFSI; it's a safe means of 11 storage. The papers that are before the Commission are 12 currently in process with the Commission. And as a 13 consequence, -- I guess the primary message is that this 14 is an ongoing operating reactor issue that is not 15 specific to license renewal.

16 MR. SMITH: So the spent nuclear fuel 17 pool's integrity is not an issue during the license 18 renewal?

19 MR. WITTICK: The spent fuel pool 20 integrity is an issue during the period of operating 21 reactor safety for Callaway, whether it's in the near 22 term or in the long-term, correct.

23 MR. BURTON: I think one thing that I did 24 want to, -- I can't speak specifically to that, but I 25 think I can talk in general terms about some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 underlying regulatory tenets that underline the 2 License Renewal Program. And one of the things that 3 we try to do is we are committed to whatever the current 4 licensing basis is of the plant is going to be continued 5 on into that period of extended operation. So ongoing 6 issues, of which this is one, and there are others, 7 ultimately our current processes are going to 8 disposition those issues. And if there are changes 9 that ultimately are going to be required, plants are 10 going to institute whatever those new requirements may 11 be. So some of the insights with regard to the spent 12 fuel and stuff, as those get disposition the fixes will 13 become a part of all the plant's current licensing 14 bases. And as they go into the period of extended 15 operations those will be maintained, again, for a 16 license renewal with an emphasis on aging mechanisms 17 and management of aging degradations.

18 So I can say at a very high level that 19 anything that comes out of some of the spent fuel issues 20 will be vetted in disposition requirements as is 21 appropriate and the Commission decides to implement 22 will become a part of the current licensing basis and 23 carry-forward. So in that respect that is generally 24 how we do things. I don't know if that helps 25 specifically with your question, but if you have any, --

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21 1 MR. SMITH: I've got one more. Section 2 5.3 of the Draft's severe accidents, cites the 1996 GEIS 3 as the basis for the NRC's decision that the probability 4 weighted consequences of the atmospheric release 5 fallout onto open bodies of water releases to the ground 6 or the societal and economic impacts from severe 7 accidents are SMALL for all plants. However, 8 alternatives to mitigate severe accidents must be 9 considered for all plants that have not considered such 10 alternatives. It goes on to say that the staff ID'd 11 these issues and there is no real environmental or human 12 health threat if the license is extended. I guess I'm 13 just curious why is the NRC using the GEIS from 1996 14 pre-Fukushima, and not using more updated, and more 15 accurate risk-analysis for, -- it's my understanding 16 that there's a Draft GEIS done in 2009, and then I 17 believe it was made official in 2013. Why then, -- does 18 the NRC plan on looking back at this through the lens 19 of what will be more conservative issues related to the 20 ongoing operation of the Callaway Nuclear Reactor?

21 MR. BURTON: Anyone want to address that?

22 MS. FELLS: We used the 2013 GEIS to update 23 our current SEIS. I'm not sure if you want to submit 24 that as a comment on the docket so that we may address 25 it?

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22 1 MR. SMITH: Yeah. I came here today as 2 more of an opportunity to ask questions of the 3 regulators; to submit an online form later. But yeah, 4 clarity, -- so you are saying right now that the NRC 5 is using the 2013 GEIS? Will that be changed in the 6 documents moving forward? And will you reevaluate all 7 the information Ameren submitted based on the '96 GEIS?

8 MS. FELLS: Well we have already taken the 9 information that Ameren submitted and updated this SEIS 10 where it needed to be updated using the most current 11 information. If this section needed to be updated with 12 the new GEIS information and has not yet been updated, 13 then it should be updated in the final SEIS. If it has 14 not been updated, then the information from the former 15 GEIS is still valid and relevant to use in this SEIS.

16 So it might be better to take this as a comment and then 17 have our Severe Accident Mitigation Alternative staff 18 address it.

19 MR. SMITH: All right. I think that's it.

20 Thank you.

21 MR. BURTON: Thank you. Other folks who 22 have any questions on the license renewal process and 23 any of the findings that came out of the 24 [DSEIS], -- anyone?

25 (No audible response)

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23 1 MR. BURTON: All right. We appreciate 2 the questions, Mr. Smith. All right, so if there are 3 no more questions on Carmen's presentation I guess 4 we'll go right into the formal comments on the [DSEIS].

5 PUBLIC COMMENTS 6 MR. BURTON: When you came to register you 7 guys filled out little blue and yellow cards.

8 Hopefully everyone has filled out a blue card, but if 9 any of you wanted to actually come up and provide 10 comments on the DSEIS we asked you to fill out one of 11 these little yellow cards. At this point, if there is 12 anyone who would like to make a comment who did not fill 13 one of these out, there are a couple of things you can 14 do. You can go back to the registration table now and 15 fill it out or what I'll do is I'll ask those who did 16 fill it out already to come up and provide their 17 comments and then once those are done if anyone else 18 wants to that did not actually fill out a card can come 19 up at that point.

20 What I try to do, -- and I didn't get very 21 many, so I think we can generally take our time 22 expressing your comments. A lot of times if we have 23 a lot of comments we try to put a timeframe on it, but 24 since I just have a few we will kind of let you take 25 your time. So what I will do is I will call up the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 persons who have come to provide their comments, and 2 I'll give the names of the next couple of people so 3 you'll know when you are on deck.

4 Okay, so let's start with Ms. Rebecca 5 Wright, if you want to come up. And after Ms. Wright 6 we'll have Henry Robertson. And after Mr. Robertson 7 we'll have Kay Drey; I hope I'm pronouncing it right.

8 MS. FELLS: Drey.

9 MR. BURTON: Drey. Forgive me if I 10 mispronounced it. You can come up to the podium or if 11 you prefer for me to bring you the mic I can do that 12 too.

13 MS. WRIGHT: My name is Rebecca Wright and 14 I live in St. Louis, Missouri. I have family members 15 living in the Fulton area, and some in the Columbia 16 area, and I used to live in this area, so I have 17 concerns.

18 And two of my concerns are about the 19 relicensing of the Callaway Plant. I have questions 20 about potential large catastrophes that are considered 21 so unlikely that they are not planned for or not even 22 asked about. And actually one of them, there's 23 no, -- you know we have seen it happen, but not to the 24 extent that it would be called a catastrophic. And 25 that's loss of cooling water from the water in-take NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 structure of the Missouri River. And I'm not aware 2 that we have, -- the Callaway Plant has a functioning 3 on-site pond that is able to sustain the cooling of the 4 reactor and the spent fuel pool.

5 But in 2011 we all watched the waters rise 6 in the flood, and six of the dams on the Missouri River, 7 from the Fort Peck Dam in Montana, to the Gavins Point 8 Dam in South Dakota, each hold massive amounts of water 9 in their reservoirs, but the dams are old and the 10 reservoirs are really old. And stress could cause them 11 to liquefy or the water on top of the dams, and the way 12 the snow is when it opened, they could have failed and 13 eroded, -- just totally eroded in the containment. And 14 the failure of the Fort Peck Dam in Montana could have 15 set off a Domino effect creating like a tsunami down 16 the Missouri River, moving out and flooding everything 17 in its path. And the water in-take, or the cooling 18 water in-take at the Callaway Plant could have been 19 stripped away or at least over top, cutting off the 20 electricity and functioning of the pumps and causing 21 the loss of cooling water in the reactor core and could 22 result in a meltdown and also cutting off the cooling 23 water to the spent fuel pool. And the water is likely 24 to sit there and remain there for a long period of time, 25 kind of creating an embarrassment of fixes for them.

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26 1 So I think that's a really major concern and I'm not 2 sure that it is addressed. And also, in case of a 3 drought the water level could be very low and the water 4 could be too warm to effectively cool the reactor.

5 And then another concern of mine is the 6 failure of the electric power grid. And it could be 7 from any reason, and it could be you know massive or 8 regional. But one concern that has been raised is that 9 scientists have warned about the possible failure of 10 the Hydro power grid due to massive solar flares. And 11 there have been solar flares historically. And one 12 was on September 1st in 1859 before there was much of 13 an electric grid and it was called the Carrington Event.

14 And it set telegraph stations on fire and the networks 15 experienced major outages. A similar event today 16 could have catastrophic consequences, which is 17 probably going to take, -- scientists have said the 18 recovery could take an estimated four to ten years.

19 And that's according to a report from the National 20 Research Council. And I don't think there has ever 21 been any kind of, -- I've seen the question in the 22 literature, but I don't think that any EIS has ever 23 addressed this for the Callaway Plant or anything of 24 this kind. For as long as it would take to restore the 25 entire power if the entire power grid failed such loss NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 of power and cooling water may result not only in the 2 amount of the reactor coolant and loss of the cooling 3 water in the spent fuel pools, it could lead to 4 propagate a zirconium primer fire and result in the use 5 of large amounts of radioactive materials. So, I guess 6 I would like to know if there is any remedy other than 7 not having nuclear power, which is a good plan?

8 And then I have concerns about finances 9 that have already manifested in various regions of the 10 United States and other countries with their nuclear 11 power plants. Several financial predictors indicate 12 that nuclear power plants are becoming too expensive 13 to operate because of costly repairs. And some 14 companies operating nuclear plants decided to try to 15 recover their costs from customers or are begging for 16 other subsidies. I've seen huge ads in the Wall Street 17 Journal, and I've seen, -- even I guess the Callaway 18 Plant, they are trying to do what for a new plant would 19 be the cost of construction work in progress just to 20 kind of put in repair work, attaching it to the repairs 21 bills.

22 So other plants are on the verge of 23 shutting down. Other financial challenges arise from 24 a cheaper form and supply of electricity from renewable 25 or fossil fuels, such as gas. We think that like within NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 the next twenty years renewable energy will dominate 2 as much as it has in Germany or Portugal. At least 3 Germany is shutting down some of its plants and 4 replacing that with renewables, because of global 5 warming and the fear of nuclear power in the Fukushima 6 province. There is also a chance that another accident 7 at a nuclear plant could make nuclear power reviled more 8 than it already is to some people. The older this 9 generation of nuclear power plants become, the more 10 likely they will run into failure, or the continued 11 radioactive waste problems and the cost of storing them 12 forever will culminate and we'll simply just stop 13 making and denigrating these nuclear power plants.

14 Thank you.

15 MR. BURTON: Thank you, Ms. Wright. Next 16 we will have Mr. Robertson, followed by Kay, -- and I 17 guess it's Kay Drey. I apologize for the earlier 18 miscommunication. And then after that we'll have Ed 19 Smith.

20 MR. ROBERTSON: Thank you. My name is 21 Harry Robertson. I am an Attorney with the Great 22 Rivers Environmental Law Center in St. Louis.

23 I want to echo concerns about the spent fuel 24 storage problem. And we're told that Ameren will run 25 out of storage capacity by 2020, but they are expected NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 to build an interim storage facility, yet they have no 2 current license to do that. It would seem important 3 to know what exactly this will be. I would 4 assume, -- and I'm being told, that it includes dry-cast 5 storage, but when will it be done? 2020 is not far off.

6 What will it cost? All those questions are not 7 addressed in the DESIS.

8 And I would like to make some comments on 9 the way the [DSEIS] dismisses certain energy generation 10 alternatives. My peer phrased this as a question 11 earlier, but why does the [DSEIS] only consider wind 12 energy that is located in Missouri? While there is 13 wind energy in Missouri the investor-owned utilities, 14 like Ameren Missouri don't take any of that wind.

15 They get their wind energy from Kansas and Iowa. And 16 that is important because a graphically dispersed wind 17 is the more reliable wind. However the [DSEIS] does 18 not show that the State of Iowa presently gets almost 19 25 percent total electricity from wind. And so I don't 20 think it can be said that it is not a practical 21 alternative.

22 I see no indication in the [DSEIS] that the 23 NRC is aware of a project like Clean Line Energy 24 Partners, which is currently before the Missouri Public 25 Service Commission to build a direct current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 transmission line to carry wind energy from Kansas, 2 across Missouri, to Illinois and Indiana. With a 3 possibility, -- and not a certainty by any means, but 4 a possibility of dropping 500 megawatts of wind energy 5 off in the Ameren Missouri service territory which 6 would greatly increase Ameren's wind energy capacity.

7 The alternatives of the [DSEIS] consider 8 a strictly baseload generation from coal, nuclear and 9 natural gas. Well baseload, -- some of you were 10 talking about the missing baseload. What exactly is 11 baseload? The true source of reliability is not 12 individual power plants like Callaway 1, or any other, 13 it's the availability of energy on the coal 14 transmission grid. And certainly you are aware that 15 nuclear plants frequently have both planned and 16 unplanned outages. There are refueling outages every 17 eighteen months at Callaway 1. And in its lifetime 18 Callaway has had at least thirty-nine forced outages 19 lasting from a few hours to about a month and a half.

20 In 2011 and '12 there were sixty-seven 21 reactors worldwide, including of course, Fukushima 22 Daichi, and 18 percent of all the commercial light and 23 power reactors in the world had extended unplanned 24 outages. And at times like these it's electricity that 25 is available on the grid that picks up the slack. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 1 you cannot say that an individual power plant is crucial 2 to reliability.

3 Another alternative that is slighted by 4 the [DSEIS] is demand-side management, which means 5 utility energy efficiency programs. Ameren Missouri 6 is running some of these plans right now, but they 7 minimize the effectiveness of demand-side management 8 in substituting for generating capacity.

9 Missouri has a law called the Missouri Energy 10 Efficiency Investment Act that obligates and regulates 11 utilities like Ameren to achieve all cost-effective 12 demand-side savings. And according to the Public 13 Service Commission's rules if they meet these goals 14 then by the year 2020 they will be saving 9.9 percent 15 of the total annual energy replaced by efficiency. And 16 that will continue to grow by 1.9 percent per year after 17 that, Ameren, -- well, at least by Ameren's figures from 18 the Integrated Resource Plan for how much capacity it 19 thinks can be replaced by demand-side management. And 20 yet, in the proceedings that I am aware of from the 21 Missouri Public Service Commission Ameren has been 22 severely criticized by most of the parties, including 23 PSC staff and the Office of Public Council, the consumer 24 watchdog, that they have severely understated the 25 potential for saving energy in Missouri by demand-side NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 management compared to studies that have been done in 2 other states, and the results that have actually been 3 achieved in other states, and in potential studies with 4 other Missouri utilities. So I think that wind energy 5 and demand-side management deserve consideration as an 6 alternative to baseload generation for coal.

7 Just briefly I want to comment that the 8 cumulative effects on aquatic resources are rated 9 LARGE. The Missouri River is called a degraded 10 ecosystem close to or past the point of irreparable 11 damage, and yet nothing appears to be done about that.

12 I also wondered, -- I looked at the Final 13 Environmental Report by Ameren, and attached to 14 that, -- Attachment E, are helpful letters from the 15 Missouri Department of Natural Resources to Ameren 16 concerning the possibility of thermophilic pathogens 17 entering the Missouri River in cooling water 18 discharges. And then the DNR, -- Missouri DNR says 19 that it cannot rule out the presence of these pathogens 20 nor could it "conclude that this section of the Missouri 21 River does not pose a significant risk of waterborne 22 disease". So I think further assessment of that issue 23 is also warranted.

24 And I will conclude my comments there and 25 I'll offer a copy.

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33 1 MR. BURTON: Thank you, Mr. Robertson.

2 Next we are going to have Kay Drey, followed by Ed Smith, 3 and then Pamela Todorovich.

4 MS. DREY: My name is Kay Drey and I live 5 at 515 West Pointe in University City, Missouri.

6 Thank you for this opportunity to submit 7 comments to the Nuclear Regulatory Commission 8 regarding Ameren's request to extend its operating 9 license for the Callaway Nuclear Power Plant, and to 10 speak about the Generic EIS at Callaway. The effort 11 to have Ameren achieve another, -- or be granted another 12 twenty years is to me, very disturbing. I am here to 13 say that I hope the NRC will deny that request.

14 The first time I spoke publicly against 15 nuclear power was forty years ago. I am now eighty 16 years old and have spent much of the second half of my 17 life reading about nuclear power and radioactive waste, 18 and writing and speaking about their hazards. So true 19 to form I am here today to urge the Nuclear Regulatory 20 Commission to deny Ameren's request to extend the 21 Callaway Plant's forty year operating license for 22 another twenty years. I have had to delay my effort 23 to review the NRC's 450 page Generic Environmental 24 Statement on Callaway because I, and many other St.

25 Louisans have been working hard instead to give the U.S.

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34 1 Army Corps of Engineers the responsibility for the 2 radioactive waste that was illegally dumped in the West 3 Lake Landfill in St. Louis County. We need the Corps 4 to excavate and export some of the oldest radioactive 5 waste of the atomic age. The landfill is located in 6 the flood plain of the flood-prone Missouri River 7 upstream from two of St. Louis' major drinking water 8 treatment plants. As you may have read in the Wall 9 Street Journal those historic wastes are frighteningly 10 close to what has been called a "subterranean 11 smoldering event," that is in other words a fire.

12 To return to the subject of today's hearing 13 I will list only five of the topics that I believe were 14 inadequately discussed, -- addressed in the Generic EIS 15 supplement regarding Callaway. And I hope the NRC will 16 deny permission to Ameren to prolong the operation of 17 the Callaway reactor for another twenty years.

18 I believe that there is inadequate 19 attention to the potential for a very huge accident, 20 the kinds that our world has seen in Fukushima and 21 elsewhere. I am still concerned about problems during 22 construction of the Callaway Plant. There were 23 defective embedded steel plates with studs that just 24 fell off. They are supposed to be able to stay on to 25 the embedded plates even falling from an airplane, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 yet they fell off of the truss and so forth. And 2 although the NRC discounted the significance of these 3 embedded plates and the defective stud welding, I think 4 this is still a huge concern. They have even eroded 5 so far that one of the floors have collapsed. And I'm 6 also still concerned about the honeycomb they found in 7 the base mat. Due to mistakes in the construction of 8 the base mat there were huge holes in the base mat of 9 the reactor containment building.

10 One of the concerns I have most about the 11 Callaway Plant, and especially potentially extending 12 the operating duration is exposure to workers to 13 radiation. And the longer the plant operates the more 14 crud; which is one of the earliest technical words I 15 learned which has to do with the corrosion of products 16 that build up in pipes and other structures, and the 17 workers are getting badly exposed to high levels of 18 radiation. And I think that should be dealt with in 19 the Generis EIS.

20 I think also the fact that Callaway and 21 other reactors in this country, -- but also 22 specifically Callaway, is using higher burn-up fuel.

23 And the fuel is being kept in a spent fuel pool at 24 Callaway. And the pool is just being crowded with 25 more, and more, and more irradiated fuel products. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 there is still no permanent disposal site in the United 2 States for the fuel, so it is going to have to stay at 3 Callaway as far as we are concerned. Or maybe they will 4 send it, as they keep trying to, to the Native American 5 Tribal lands. But the spent fuel pool is vastly 6 overcrowded and they are using fuel that has a higher 7 concentration of Uranium-235. This higher burn-up 8 fuel will lead to greater degradation of the [plating],

9 the tubing that holds the fuel pellets. And because 10 of the higher degradation and the [plating] that they 11 have discovered there were higher releases of 12 radioactive isotopes into the liquid effluent of 13 gaseous releases.

14 And I guess my number one concern about 15 nuclear power plants is the routine releases of 16 radioactive gases into the air and radioactive 17 materials into the water, that in our case here in 18 Missouri is dumped into the Missouri River, and also 19 in streams in St. Louis and so forth. And I think that 20 the fact that Union Electric or Missouri Ameren is 21 seeking to operate the plant beyond the initial forty 22 years, for another twenty years, means more gaseous 23 releases and routine liquid releases will happen. And 24 I think that is really simply unacceptable.

25 So I think that's the conclusion of what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 I have to say, but I also brought a statement of a friend 2 that was not able to come. Do you want me to read that 3 now?

4 MR. BURTON: Sure.

5 MS. FELLS: You can read it or submit the 6 document.

7 MS. DREY: I do want to read it.

8 MS. FELLS: Okay, go ahead.

9 MS. DREY: But if want me to do it after 10 everyone else has spoken, --

11 MR. BURTON: You can go right ahead.

12 MS. FELLS: You might want to state the 13 person's name.

14 MS. DREY: Yeah. She's not here and I 15 will submit her typed comments. She said my name is 16 Arlene Sandler (phonetic). I live at 6947 Kirby Avenue 17 in University City, Missouri and I am unable to attend 18 this hearing today, although I am a complete cynic about 19 the value of citizen testimony in a process that has 20 historically been rubberstamped by the Nuclear 21 Regulatory Commission with its industry-friendly 22 regulations. I felt that I had to make a few comments 23 about a technology that I have proposed for decades.

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38 1 Electric to provide increased monitoring for 2 radioactive sludge from the Callaway Plant back in the 3 1980(s) I, Arlene Sandler, spent a lot of 4 time, -- excuse me, reading Incident Reports which were 5 required, --

6 MS. FELLS: Would you like a bottle of 7 water.

8 MS. DREY: I have water in the car, but 9 that doesn't help. I'm sorry. That's great.

10 MR. BURTON: Do you need to take a break 11 or, --

12 MS. DREY: That would be good if you don't 13 mind, as long as she's bringing water. That's great.

14 Thank you.

15 I might add that Arlene Sandler, who has 16 written this statement, is a member of the Board, and 17 has been for many years, of the Missouri Coalition for 18 the Environment. But to continue her statement, 19 during my involvement with the Missouri Coalition for 20 the Environment's efforts to compel Union Electric to 21 provide increased monitoring of radioactive sludge 22 from the Callaway Plant back in the 1980(s), I, Arlene 23 Sandler, spent a lot of time reading Incident Reports 24 which were required published announcements of 25 unexpected events at nuclear power plants. And as I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 read through many, many pages of examples of human error 2 and equipment malfunctions at nuclear power plants all 3 over the country I realized then that nuclear power was 4 a very risky way to generate electricity, and I am even 5 more convinced of that today.

6 We have been very lucky so far in the United 7 States, but catastrophic accidents at Chernobyl and 8 Fukushima have forced people from their homes, caused 9 deaths, disease and birth defects, and produced 10 contamination over a broad area. Radioactive water is 11 still leaking into the Pacific Ocean or Fukushima. And 12 one article I read reported that it would take one 13 hundred years to clean up the site of the disaster, and 14 there have been quite a few near misses. Pick up a 15 copy of We Almost Lost Detroit, at the library; Arlene 16 is a retired Librarian.

17 Some concerns and questions about 18 extending the Callaway license until 2044. (1) The 19 potential risk of contaminating water. Lake 20 Thunderbird, Lake Lochaweeno and Canyon Lake are within 21 a 6 mile radius of the plant. The longest river in 22 North America in Missouri is 5 miles away. I am 23 concerned about contamination not only from an 24 accident, but from routine releases during the daily 25 operation of the plant for an additional twenty years.

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40 1 Her second comment. Risks from an 2 indepted storage of high level radioactive waste 3 storage on site. There is no current repository for 4 spent fuel rods, so all of the rods that have ever been 5 removed from the Callaway reactor are in a pool which 6 will be filled to capacity by 2020. Ameren states in 7 the Callaway Environmental Facts-2011 "Spent nuclear 8 fuel consists of bundles of fuel rods called fuel 9 assemblies that have been removed from a nuclear 10 reactor when it can no longer sustain a nuclear 11 reaction". But crowded together over time in a pool 12 filled to capacity with barriers prone to corrosion 13 those assemblies can start a nuclear chain-reaction.

14 Just how dangerous are these rods? And 15 this is quoting from Bob Alvarez Institute for Policy 16 Studies, and this is called Spent Nuclear Fuel Pools 17 in the U.S.: Reducing the Deadly Risks of Storage.

18 "Spent fuel rods give off about 1 million rem (10,000 19 thousand sieverts) of radiation per hour at a distance 20 of 1 foot has enough radiation to kill people in a matter 21 of seconds." And I should say that I also have 22 something that Bob Alvarez wrote that I want to submit 23 as a part of my statement, if that's okay? I meant to 24 say that.

25 To continue, Arlene has written, does a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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41 1 specific plan exist right now for the design and the 2 construction of a new spent fuel pool at Callaway? (3) 3 It's all about the money. In Appendix F as in Frank, 4 of this GEIS draft, page F-2, Ameren reports that 5 "Sixteen potentially cost-beneficial SAMA, Severe 6 Accident Mitigation Alternatives, will be entered in 7 Callaway's long-range plan development process for 8 further consideration". Arlene asks why isn't the 9 plan for these mitigation alternatives a part of the 10 relicensing requirements right now? Are there 11 accident mitigation alternatives that are most costly 12 and therefore not being considered at all?

13 In its Executive Summary of the Draft the 14 NRC "Concluded that none of the potentially 15 cost-beneficial severe accident mitigation 16 alternatives related to adequately managing the 17 effects of aging during the period of extended 18 operation". I don't think she's talking about that.

19 "Therefore they may not be implemented as part of the 20 license renewal." What does this mean? Which severe 21 accident mitigation alternatives would be able to 22 manage the effects of plant aging? How many additional 23 sediment retention monitors will be needed as part of 24 the waste water treatment system if the Callaway 25 license were extended? What kind of monitoring would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 you have?

2 (4) Common sense. If there is no 3 location for the radioactive waste that has been 4 accumulating at nuclear power plants since they began 5 generating electricity, why would any rational person 6 want to continue to create more?

7 Nuclear power has some unique 8 characteristics that Amory Lovins, Chief Scientist of 9 the Rocky Mountain Institute describes as follows:

10 "Nuclear power is the only energy source where mishap 11 or malice can kill so many people so far away; the only 12 one whose ingredients can help make and hide nuclear 13 bombs; the only climate solution that substitutes 14 proliferation, accident and high level of radioactive 15 waste dangers."

16 Arlene's final paragraph; I would urge the 17 NRC not to rubberstamp this operating license request.

18 Let Callaway's license expire in 2024. Thank you for 19 the opportunity to comment, Arlene Sandler.

20 MR. BURTON: Thank you, Ms. Drey. I will 21 say that if you had not told us your age I don't think 22 any of us would have guessed. Next we are going to have 23 Ed Smith, followed by Ms. Pamela Todorovich.

24 MR. SMITH: Ed Smith, Missouri Coalition 25 for the Environment. This is again, from Section 5.3, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 1 Severe Accidents and Drafts. It says, "Severe 2 accidents initiated by external phenomenon's such as 3 tornadoes, floods, earthquakes, fires and sabotages 4 have not traditionally been discussed in quantitative 5 terms in FES(s) and were not specifically considered 6 for the Callaway site in the GEIS," again, referencing 7 the 1996 NRC document. "However the GEIS did evaluate 8 existing impact assessment performed by the NRC and by 9 the nuclear industry at forty-four nuclear plants in 10 the United States and concluded that the risk from 11 beyond design basis earthquakes at existing nuclear 12 plants is SMALL," small as in all capital letters.

13 "The GEIS for a license renewal performed a 14 discretionary analysis of terrorist acts in connection 15 with license renewals and concluded that the risks from 16 such acts would be no worse than an endogen release 17 expected from internally initiated events. In the 18 GEIS the Commission concludes that the risk from 19 sabotage and beyond design basis earthquakes in 20 existing nuclear power plants is SMALL. And 21 additionally, that the risks from other external events 22 are adequately addressed by the generic consideration 23 of internally initiated severe accidents," again 24 citing the 1996 GEIS, which I haven't revisited that 25 document recently, but I would imagine the threat of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 cyber security and cyber terrorism has escalated a bit 2 1996.

3 "Based on the information in the 4 GEIS", -- I read a little bit of that earlier so I'll 5 skip that. "The staff identified no new significant 6 information related to severe accidents during review 7 of the Applicant's Environmental Report, the Site Audit 8 Scoping Process or the evaluation of other available 9 information. Therefore there are no impacts related 10 to these issues beyond those discussed in the GEIS."

11 That is what the NRC had to say and here 12 is what the Coalition of the Environment wrote and will 13 be submitting later. "The Missouri Coalition of the 14 Environment believes that spent fuel storage risks are 15 one of the most serious unaddressed safety 16 environmental issues facing the NRC today. The 17 consequences of a pool fire are potentially 18 catastrophic, affecting millions of people and costing 19 millions of dollars. There is no excuse from posing 20 this potential colossal risk on the public," and that's 21 because we have the Price Anderson Act which caps 22 utility liability at 21 billion dollars which is paid 23 for by the nuclear utility customers to begin with.

24 Taxpayers pay for the rest as most of you already know.

25 Good luck getting that money from Congress these days.

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45 1 The only reason the risks exist is that the 2 Government and reactor licensees have not done a good 3 job of managing the waste generated by reactors. The 4 volumes of waste piling up in fuel pools at Callaway 5 and other reactors were never contemplated when these 6 reactors were issued their original licenses. The 7 Callaway nuclear reactor for example, has 2,363 fuel 8 assemblies in its fuel pool. I believe it was 9 originally licensed for right around 400. And we also 10 know now that Ameren's going to be moving those out of 11 its fuel pool.

12 We think the NRC has swept the issue of pool 13 fires under the rug for far too long, and many other 14 things, including waste storage. The NRC has never 15 made a comprehensive analysis of pool fire risks as it 16 did for reactor accidents with the Severe Accident 17 Study in NuReg-1150. The imposition of such great risks 18 on a public without careful study is inexcusable.

19 The Fukushima accident supposedly 20 inspired the NRC to take a closer look at the problem 21 in the expedited spent fuel transfer proceeding. But 22 the Consequence Study the NRC staff turned out in 2013 23 was extremely inadequate and a complete 24 disappointment. In spite of its inadequacies however, 25 the Consequence Study and the cost-benefit analysis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 that accompanied it, yielded new and significant 2 information about the risks of pool fires and the 3 benefits of reducing the density of fuel in the pools.

4 MCE participated in a Rulemaking Petition 5 submitted February 18, 2014, and resubmitted it again 6 today to the NRC Commission for context, seeking the 7 reopening of the license renewal GEIS to consider new 8 and significant information generated by the NRC's 9 proceeding on an expedited transfer of spent fuel.

10 In that expedited spent pool transfer 11 proceeding, the NRC staff found that if even a small 12 fraction of the inventory of the Peach Bottom reactor 13 pool was released to the environment in a severe spent 14 fuel pool accident an average area of 9400 square miles 15 will be rendered uninhabitable and 4.1 million people 16 would be displaced over the long term. This 17 information is new, because no EIS for reactor 18 licensing, GEIS for reactor relicensing or 19 environmental assessment for standardization design 20 certification has specified the size of the area that 21 could be contaminated or the number of people who could 22 be displaced for an extended period of time by a 23 high-density spent fuel pool fire. And high-density 24 is exactly what we have at the Callaway reactor.

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47 1 underlines the NRC's conclusion in environmental 2 studies such as the one being discussed today, for 3 reactor licensing and relicensing that the impacts of 4 spent fuel storage during reactor operation are 5 insignificant. Such widespread contamination and 6 long-term displacement of people can have enormous 7 socioeconomic impacts, as witnessed by the effects of 8 Fukushima; an accident where land contamination has 9 disrupted the lives of a large number of Japanese 10 citizens. It is estimated that over 100,000 Japanese 11 people are still displaced from their homes and 12 communities. The Japan Times recently cited a report 13 from local Fukushima prefecture authorities that found 14 more people have died from stress-related illnesses and 15 other health-related problems near the nuclear reactor 16 than who died from the disaster-related injuries.

17 This is just from the Fukushima prefecture and the areas 18 around it. It is not from the entirety of this tsunami 19 disaster. We saw some of these same things I would add 20 to that, after the [BP] oil disaster in the Gulf of 21 Mexico.

22 Real world nuclear disasters; surely the 23 impact on communities surrounding a nuclear reactor are 24 significant and therefore must be considered by the NRC 25 in a meaningful way. The Peach Bottom review the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 acknowledged, -- in the Peach Bottom review the NRC 2 acknowledged for the first time the potential 3 consequences of a pool fire severe enough to warrant 4 mitigation regardless of how low the probability 5 estimated by the NRC for such an accident. No EIS for 6 reactor licensing, GEIS for reactor 7 relicensing, -- I've said that already. Maybe I 8 didn't? Yes, I did. Sorry.

9 To ensure compliance with NEPA, The 10 National Environmental Policy Act in the consideration 11 of this new and significant information the Missouri 12 Coalition for the Environment and other Petitioners 13 request that the NRC take the following actions:

14 Suspend the effectiveness of Table B-1 of 15 10 CFR, Part 51, Subpart A of Appendix B, -- A1B-1, which 16 codifies the NRC's generic finding that spent fuel 17 storage in high-density reactor pools during the 18 license renewal term of operating reactors poses no 19 significant environmental impacts and therefore need 20 not be considered in individual reactor licensing 21 decisions.

22 Suspend the effectiveness, in any new 23 reactor licensing proceeding for reactors that employ 24 high-density pool storage of spent fuel, of all 25 regulations approving the standardized designs for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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49 1 those new reactors and all environmental assessments 2 approving severe accident mitigation design 3 alternatives. I wanted to make sure we pointed that 4 out, because Ameren Missouri has, for the last five or 5 so years, been interested in new nuclear power in 6 Missouri.

7 Third, republish for public comment the 8 following documents with respect to new and significant 9 information regarding the environmental impacts of 10 high-density spent fuel storage in reactor pools and 11 the costs and benefits of measures for avoiding or 12 mitigating those impacts, including the license 13 renewal Generic Environmental Impact Statement, 14 NuReg-1437, Revision 1, June 2013, and the 2013 Revised 15 License Renewal GEIS. Second, the EIS(s) from new 16 reactors, third, the EA(s) for all new certifications 17 for standardized reactor designs; again, because 18 Ameren is interested in building new nuclear reactors 19 in Missouri; duly modified NRC regulations that make 20 or rely on the findings regarding the environmental 21 impact for spent fuel storage during reactor operation, 22 including Table B-1, and all regulations approving 23 standardized reactor designs.

24 And lastly, suspend all the reactor 25 licensing decisions and license renewal decisions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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50 1 pending completion of the proceeding. I had a few more 2 questions and if there is time at the end maybe we can 3 talk some more, but thanks.

4 MR. BURTON: Okay. Thank you, Mr. Smith.

5 Right now I have our last commenter, Ms. Pamela 6 Todorovich. And after that, if there is anyone else 7 who would like to make any additional comments we will 8 allow that, okay?

9 MS. TODOROVICH: I just have a few 10 comments. My name is Pamela Todorovich. I live at 8 11 Fair Oaks, St. Louis, Missouri.

12 Concerns about the United State's aging 13 infrastructure has been in the news a lot lately, about 14 bridges and highways, and rails, and gas lines. But 15 an equally pressing issue is the aging nuclear plants.

16 There are many people in Callaway County and in the St.

17 Louis area that are very concerned about this. St.

18 Louis is only 60 air miles away. If there would be an 19 accident radioactive iodine would shallow on the 20 wind, -- a 30 mile an hour wind and get to St. Louis 21 in two hours. Could we be alerted? Would we have time 22 to take those pills to protect our thyroid?

23 Extending the license of the Ameren Nuclear Plant 24 would be akin to, -- in my opinion, akin to driving a 25 forty year old car. You know something is going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 1 happen. Pipes corrode. The crude that Kay mentioned 2 builds up. Nuclear radiation leaks out. The gamma 3 rays and Cobolt-60 are very dangerous, making 4 especially dangerous work for people who work in the 5 plant.

6 I was reading about another old plant.

7 In 2007 the Vermont Yankee Nuclear Plant had a partial 8 collapse of its cooling tower. And then again in 2010 9 the operators of that plant discovered that nearby 10 groundwater had been contaminated by radioactive 11 tritium, which apparently had leaked out from 12 underground pipes. And yet, despite these 13 transgressions the NRC extended Vermont Yankee's 14 license for operation the very next year.

15 We continue to see many examples of these 16 old plants releasing deadly nuclear isotopes into the 17 environment and ultimately into our bodies. I was 18 going to also mention, -- it occurred to me when I read 19 that the spent fuel pools only have about six years left 20 as far as the capacity. I would like to know what the 21 plan is then?

22 So as a mother, and a grandmother, and a 23 concerned citizen, I am urging the NRC to reject the 24 extension of this license and operation for the safety 25 and health of all Missourians.

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52 1 MR. BURTON: Thank you, Ms. Todorovich.

2 That was the last formal comment. Is there anyone else 3 who would like to make a comment?

4 (No audible response) 5 MR. BURTON: No? Okay, then with that we 6 are getting to the end of the meeting. Before we have 7 our closing remarks I wanted to encourage everyone 8 again to fill out the feedback form. If you don't 9 already have one there are copies at the administration 10 table. Getting your feedback on meeting is extremely 11 important to us and we really want to encourage you to 12 fill those out.

13 Also, I wanted to thank Ms. Deborah Carter 14 who is serving as our transcriber today. We really 15 appreciate that. And I think the next thing we will 16 doing is start closing remarks, and I'll turn it over 17 to Brian Wittick.

18 MR. WITTICK: Well thank you Butch, for 19 facilitating this session. And I would like to thank 20 everyone for coming out today. We understand that your 21 time is very valuable and we really appreciate all of 22 the insights, comments and questions that everyone has 23 provided today. It provides a lot of value to us in 24 our process. I can assure you from the person who sees 25 all the changes that occur as a result of these meetings NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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53 1 that we do in fact take your comments seriously and 2 factor them into the Environmental Impact Statements.

3 The public meetings are an important part of the NRC 4 process for openness and involvement of the public.

5 Lastly, just a couple of points, as Carmen 6 mentioned the comment period closes, so if you did not 7 get your comments in today or if you have any additional 8 comments that you want to make it closes on April 7th.

9 There are a couple of means that you have for submitting 10 comments. And as for today, at the close of the session 11 the NRC staff will be around if you would like to engage 12 in further discussions. We will be happy to facilitate 13 that. And will anyone from Ameren be around to, --

14 (Positive gesture) 15 MR. WITTICK: -- Ameren will be around as 16 well, if anyone would like to discuss some of your 17 questions and comments with them. With that, this 18 closes the session. Thank you.

19 (Whereupon, the public meeting was 20 concluded at 3:25 p.m.)

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