ML070530189

Draft Environmental Impact Statement Public Meeting, January 24, 2007, Afternoon Transcript-Corrected

ML070530189
Person / Time
Site:	Pilgrim
Issue date:	01/24/2007
From:	Cameron F NRC/OGC
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Download: ML070530189 (97)

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

4 5

6 ---- ----------------------------- x 7 IN THE MATTER OF:

8 PUBLIC MEETING TO DISCUSS THE 9 DRAFT SUPPLEMENTAL ENVIRONMENTAL 10 IMPACT STATEMENT FOR LICENSE 11 RENEWAL OF 12 PILGRIM NUCLEAR POWER STATION 13 -------------------------------- -x 14 Wednesday 15 January 24, 2007 16 17 Ballroom 18 Radisson Hotel Plymouth 19 180 Water Street 20 Plymouth, Massachusetts 21 22 The above-entitled matter was convened, 23 pursuant to Notice, at 1:32 p.m.

24 BEFORE: Francis "Chip" Cameron 25 FACILITATOR Neal R. Gross & Co., Inc.

Washington, D.C.

(202) 234-4433

• 2 I I N D E X 2 OPENING REMARKS: PAGE:

3 Chip Cameron 3 4 OVERVIEW OF LICENSE RENEWAL PROCESS 5 Alicia Williamson 8 6 RESULTS OF THE ENVORONMENTAL REVIEW 7 Bobbie Hurley 17 8 HOW COMMENTS CAN BE SUBMITTED 9 Alicia Williamson 31 10 PUBLIC COMMENT

11. Kelly Connerton 33 12 Lilias Cingolani 36 13 Mary Lampert 38 14 Joyce McMahon 47 15 Robert .Ruddock 53 16 Rebecca Chin 55 17 John Stobierski 64 18 Pine du Bois 67 19 Ben Morgan 72 20 Heidi Mayo 74 21 Arthur Gast 77 22 CLOSING REMARKS 23 Rani Franovich 96 24 25 Neal R. Gross & Co., Inc.

Washington, D.C.

(202) 234-4433

3 1 P R 0 C E E D I N G S 2 (1:32 p.m.)

3 MR. CAMERON: Good afternoon, everyone.

4 My name is Chip Cameron and I would like to welcome all 5 of you to the United States Nuclear Regulatory 6 Commission's public meeting today and we are going to 7 try to avoid using acronyms. One we will use though 8 will be NRC and the NRC public meeting, your meeting 9 today concerns the draft environmental impact statement 10 that the NRC has prepared as one part of its evaluation 11 of an application that we received from the Entergy 12 Corporation to renew the operating license for the 13 Pilgrim Nuclear Power Plant.

14 And it's my pleasure to serve as your 15 facilitator today and in that role I will try to help 16 all of you to have a productive meeting. I just want 17 to spend a couple of minutes on meeting process issues 18 so you know what to expect this afternoon and I would 19 like to talk about the format for the meeting and the 20 ground rules for the meeting.

21 In terms of the format for the meeting, 22 it's' basically going to be a two-part meeting. The 23 first part, we are going to do some relatively brief 24 presentations to give you some background on license 25 renewal, what we look at when we evaluate an ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

4 1 application to renew a license and, more importantly 2 perhaps today, we are going todiscuss the findings in 3 the draft environmental impact statement.

4 And I want to emphasize the word draft.

5 This environmental impact statement will not be 6 finalized until we hear and evaluate the comments that 7 you are going to give us today and possibly tonight, 8 plus the written comments that can be submitted on the 9 draft environmental impact statement and the staff is 10 going to tell you a little bit more about that in a few 11 minutes. And that's the second part of the meeting is 12 to be able to listen to your comments, youtr concerns, 13 your advice, your recommendations and that will be the 14 focus of the second part of the meeting but, before we 15 go to that, after we are done with the NRC 16 presentations, there Will be an opportunity to answer 17 some of your questions before we move on to the 18 comments.

19 In terms of ground rules, they are very 20 simple and they are just designed to allow all of us to 21 have a productive meeting, and the first is I would 22 just ask that only one person speak at a time, most 23 importantly so we can give our full attention to 24 whomever has the floor but also so that we can get a 25 clean, what I call a clean .transcript. We have Marty ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

5 1 Farley with us today who is our Court Reporter, so to 2 speak, and he is going to be doing a transcript of the 3 meeting, which will be available to all of you as a 4 public record of what was said here today, and one 5 person at a time obviously will help Marty to know who 6 is speaking and how to identify that person.

7 I would ask you to try to be as concise as 8 possible so that everybody who wants to speak today has 9 an opportunity to do that and when we go to the 10 question period, please try to confine it to questions.

11 I think it's normal for all of us to wrap questions up 12 in a comment but if you.could try to stick to a 13 question and then hold your comments until the time 14 when we get to the comment period of the meeting. We 15 do have yellow cards out there for people to sign up, 16 if they want to speak, and it's not a requirement but 17 it allows us to know how much time we should-allot for 18 each speaker.

19 And we have a little bit of a luxury this 20 afternoon that we often don't have, we have about ten 21 people who have signed up to speak, so we can give you 22 a little bit more time than we usually do for your 23 comments, and I'm going to set a ground rule of 24 approximately ten minutes for comments and I'll give 25 you the word when it's time for you to sum up. Some ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

6 1 people are not going to take 10 minutes, we may have 11 2 or 12 minutes for others, but that's just a rough 3 ground rule and that will allow us to give people 4 enough time and to be able to finish at 4:30.

5 And your comments today are going to serve 6 two important purposes, one, they are going to alert 7 the NRC staff to what concerns are out here that they 8 should be thinking about, and that means today start 9 thinking about and perhaps talking to you after the, 10 meeting to get a better idea of what your comments and 11 concerns are. But secondly, your comments today will 12 alert everybody else in the audience to what issues are 13 on people's mind in the community, and of course your 14 written comments will allow you to expand as much as 15 you want on whatever themes you want to.

16 Another ground rule obviously is courtesy 17 towards one another. You are going to hear a lot of 18 different opinions, you may not agree with them but 19 please extend courtesy to the person who is expressing 20 them. And the draft EIS is a broadly-based document, 21 it covers a lot of territory so there is a lot of 22 comments that are relevant to that draft environmental 23 impact statement and we welcome all of those comments, 24 and of course most helpful are going to be those 25 comments that touch on specific aspects of the draft ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

7 1 EIS but, as I said, we welcome all of your comments 2 today.

3 Let me introduce the people who are going 4 to be talking to you today. First, we have Alicia 5 Williamson, who is right here, and Alicia is the 6 project manager for the environmental review on this 7 license renewal application and she is going to give 8 you an overview of license renewal. She has been with 9 the NRC for about five years, and she has been involved 10 in environmental assessment projects since she has been 11 here and she was also the project manager, I believe, 12 on the Brunswick renewal application, so she has 13 substantial experience in this and she will be talking 14 to you in a few moments. In terms of her educational 15 background, she has a bachelors in biology and a 16 masters in environmental science, both from North 17 Carolina A&T State University in Greensboro, North 18 Carolina.

19 Our second speaker is going to be Bobbie 20 Hurley, who is right here, and Bobbie is the team 21 leader of the group of expert consultants that the NRC 22 has hired to help us with this evaluation, and Bobbie 23 is with a company called Earth Tech, and she has had 24 about 25 years experience in environmental assessment 25 work and she has a bachelors in chemistry and biology ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

8 1 from Mary Washington College, or is it University?

2 College and a masters in chemistry from William & Mary.

3 I would just ask you to bear with us, let 4 Alicia and Bobbie go through their presentations, 5 they've tried to make it as brief as possible but of 6 course we are from the government, so that's probably 7 about three or four hours, but I think it will only be 8 about 25 minutes to a half hour. But if you could just 9 hold your questions until they are done, and then we'll 10 go on to you for questions and then we'll go into the 11 comment period. And thank you all for being here today 12 to help the NRC with this decision and, Alicia, are you 13 ready?

14 Okay, this is Alicia Williamson.

15 MS. WILLIAMSON: Good afternoon, everyone.

16 Thank you, Chip.

17 I would also like to extend my thanks to 18 everyone for taking time out to attend this meeting.

19 To begin today's presentation, I'm going to briefly go 20 over the agenda and purpose of the meeting. Next, I'll 21 explain the NRC's license renewal process for nuclear' 22 power plants with emphasis on the environmental review, 23 then Bobbie Hurley from Earth Tech, the NRC contractor-24 who helped prepare the supplemental environmental 25 impact statement, will present the preliminary findings ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

9 1 of our environmental review which assesses the impacts 2 associated with operations of Pilgrim Nuclear Power 3 Station for an additional 20 years.

4 Then we will go into the most important 5 part of the meeting which is for us to receive comments 6 on the Pilgrim supplemental draft environmental impact 7 statement. We will also give you some information 8 about the schedule for the balance of our review and 9 let you know how you can submit comments in the future.

10 At the conclusion of the staff's presentation, I will 11 be happy to answer any questions. However, I must ask 12 you to limit your participation to questions related to 13 the environmental review and hold your comments until 14 the appropriate time.

15 Before I explain the license renewal 16 process, I would like to take a minute to talk about 17 what we do and what our mission is at the NRC. The 18 Atomic Energy Act is legislation that authorizes the 19 NRC to issue operating licenses for a 40-year license 20 term for nuclear power reactors, this 40-year term is 21 based primarily on economic considerations and 22 anti-trust factors, not on safety limitations or 23 technical limitations of the plant.

24 The Atomic Energy Act also authorizes the 25 NRC to regulate the civilian use of nuclear materials ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

10 1 in the United States. In exercising this authority, 2 the NRC missions is threefold, to ensure adequate 3 protection of public health and safety, to promote the 4 common defense and security and to protect the 5 environment.

6 The NRC regulations also include 7 provisions for extending plant operation for up to an 8 additional 20 years. Entergy Nuclear Operations, 9 Incorporated, also known as Entergy, owns and operates 10 the Pilgrim plant. On January 27, 2006 Entergy 11 submitted an application for the renewal of the Pilgrim 12 operating license for an additional 20 years, the 13 Pilgrim operating license is set to expire June 8, 14 2012. As part of NRC's review of the Pilgrim license 15 renewal application, the NRC staff has performed an 16 environmental review to look at the impacts of an 17 additional 20 years of operation on the environment.

18 We held a meeting right here in this same 19 room in May, 2006 to seek your input regarding the 20 issues we needed to evaluate in the environmental 21 review for Pilgrim license renewal. We indicated at 22 that earlier scoping meeting we would return to this 23 area to present the preliminary findings documented in 24 a draft environmental impact statement which is one 25 primary purpose of today's meeting.

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11 1 This slide presents the big picture 2 overview of the license renewal process which involves 3 two parallel paths, the safety review process shown 4 here along the top portion of the diagram using the red 5 arrows and the environmental review process shown along 6 the bottom portion of the diagram using the green 7 arrows.

8 An opportunity for the public to request a 9 hearing and petition for intervention on the Pilgrim 10 license renewal application was available in the 11 beginning of the license renewal process, two 12 contentions, one safety and one environmental, were 13 accepted by the NRC Atomic Safety Licensing Board. The 14 parties to the hearing include Pilgrim Watch, Entergy 15 and the NRC. The Towns of Duxbury and Plymouth are 16 participating in the hearing process as interested 17 government entities. If you would like more 18 information regarding the hearing for Pilgrim, please 19 see our Web site www.NRC.gov.

20 I'm going to briefly now describe the two 21 review processes, safety and environmental, starting, 22 with the safety review. For license renewal, the 23 safety review focuses on aging management of systems, 24 structures and components important to safety, the 25 person in charge of this portion of the review is the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

12 1 safety project manager, Mr. Perry Buckberg.

2 Perry, could you stand, please?

3 During the safety review, the staff 4 conducts audits to evaluate the adequacy of the 5 technical information in the license renewal 6 application, NRC inspectors perform on-site inspections 7 to verify that the applicant's aging management 8 programs and activities are implemented or have been 9 planned for implementation.

10 The results of the safety review are then 11 documented in a safety evaluation report and in an 12 inspection report, the results of the safety evaluation 13 report and inspection report are then independently 14 reviewed by the Advisory Committee on Reactor 15 Safeguards or also knows as ACRS. The ACRS reviews 16 this information, forms their own conclusions and 17 recommendations and reports these conclusions and 18 recommendations directly to the Commission.

19 Before I begin the discussion on the 20 environmental review, I would like to mention a few 21 important areas of NRC oversight that are separate from 22 the license renewal process, these areas include 23 emergency planning, security and current safety 24 performance.

25 The NRC monitors and provides regulatory ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

13 1 oversight of activities in these areas on an ongoing 2 basis under the current operating license. Therefore, 3 we do not reevaluate them in license renewal because 4 they are subject to ongoing NRC inspections and 5 oversight, this oversight would continue into the 6 extended period of operation if the license is granted.

7 Any issues identified in any of these areas are 8 immediately addressed under the current operating 9 license.

10 One important element of the ongoing 11 regulatory oversight process is the NRC resident 12 inspectors. Resident inspectors are based at all 13 operating nuclear power plants, their job is to carry 14 out safety, excuse me, their job is to carry out our 15 safety mission on a daily basis by ensuring that these 16 plants have acceptable safety performances and are in 17 compliance with the current regulatory requirements.

18 These inspectors are considered the eyes and the ears 19 of the NRC.

20 Today, we have here in the audience with 21 us the senior resident inspector stationed at Pilgrim, 22 Mr. William Raymond.

23 Could you please stand? Thank you.

24 For more information regarding the reactor 25 oversight process, you can access the Internet address ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

14 1 listed here at the bottom of the slide.

2 The second part of the license renewal 3 process involves the environmental review, this slide 4 outlines the steps of the environmental review process.

5 The environmental review, which is the subject of 6 today's meeting, evaluates the impacts of license 7 renewal in a number of areas including ecology, 8 cultural resources and socioeconomics, among many 9 others. The environmental review involves scoping 10 activities and development of a document called a draft 11 supplement to the generic environmental impact 12 statement for license renewal.

13 The draft supplement to the generic 14 environmental impact statement provides the staff's 15 preliminary assessment of environmental impact during 16 the renewal period, the draft environmental impact 17 statement for Pilgrim was published for comment on 18 December 8, 2006. If you would like a copy and have 19 not previously received one, we have plenty in the 20 back, in the rear of the room at the NRC display 21 tables, we are here to take your comments on this 22 document. In July, 2007 we will be issuing a final 23 version of the Pilgrim supplemental environmental 24 impact statement, this document will address all 25 comments that we receive here today at this meeting or ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

15 1 in writing.

2 Next, I would like to give you a little 3 information on the statute that governs the 4 environmental review. The statute that governs the 5 environmental review is the National Environmental 6 Policy Act of 1969, also commonly referred to as NEPA.

7 NEPA requires that all federal agencies follow a 8 systematic approach in evaluating potential 9 environmental impacts associated with certain actions.

10 We at the NRC are required to consider the impact of 11 the proposed action and any mitigation for those 12 impacts we consider to be significant, we are also 13 consider, required to consider alternatives to the 14 proposed action.

15 The NRC has determined that an 16 environmental impact statement or EIS will be prepared 17 for any proposed license renewal of nuclear plants.

18 NEPA and our environmental impact statement for license 19 renewal are disclosure tools, they are specifically 20 structured to involve public participation and obtain 21 public comment, this meeting facilitates the public 22 participation in our environmental review. In the 23 1990s, the NRC staff developed a generic environmental 24 impact statement or generic EIS that addresses a number 25 of issues that are common to all nuclear plants. As a ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

16 1 result of that analysis, the NRC was able to determine 2 that a number of environmental issues were common or 3 similar at all nuclear power plants.

4 The staff is supplementing that generic 5 EIS with this site-specific environmental impact 6 statement or supplemental EIS that addresses issues 7 specific to the Pilgrim facility. Together the generic 8 EIS and supplemental EIS form the staff's analysis of 9 the Pilgrim site. Also, during the review, the staff 10 searches and evaluates any new and significant 11 information that might call into question the 12 conclusions that were previously reached in the generic 13 EIS, the staff searches for new information not 14 addressed in the generic EIS as well.

15 This slide is our decision standard for 16 the environmental review, I'll give everyone a minute 17 to pause and read it.

"18 Now, stated a bit more simply than what 19 you read here in the slide is basically are the 20 environmental impacts of license renewal great enough 21 that maintaining the license renewal option for Pilgrim 22 is unreasonable? Listed here are important milestone 23 dates for the Pilgrim environmental review, the dates 24 highlighted in green indicate opportunities for public 25 comment on the environmental review.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

17 1 We received Entergy's application 2 requesting license renewal for Pilgrim on January 17, 3 2006, a public scoping meeting was held right here in 4 this same room back on May 17, 2006 as part of the 5 scoping process. Many of you here today may have 6 attended that meeting and provided comments to us, all 7 comments received during the scoping period, including 8 comments from the May 17 scoping meeting that were 9 within the scope of the environmental review are 10 contained in Appendix A of the draft environmental 11 impact statement, out of scope comments were answered 12 in the scoping summary report. Copies of both the 13 scoping summary report and the draft environmental 14 impact statement are available at the NRC display 15 tables in the back.

16 On December 8, 2006 the Pilgrim draft 17 supplement to the generic EIS was issued, this document 18 is the subject of today's meeting. We are accepting 19 public comments on the draft until February 28, 2007.

20 This concludes my remarks on the license renewal 21 process.

22 Now I am going to turn the meeting over to 23 Ms. Bobbie Hurley, the Earth Tech Contract Technical 24 Manager who will explain our findings.

25 MS. HURLEY: Hello. My name is Bobbie ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

18 1 Hurley and, as Alicia said, I am the NRC Contract 2 Manager at Earth Tech and I am currently leading the 3 Earth Tech project team on the Pilgrim environmental 4 impact statement.

5 The NRC contracted with Earth Tech to 6 evaluate the impacts of license renewal at Pilgrim 7 Nuclear Power Station, the environmental impact 8 statement project team consisted of scientists and 9 engineers from Earth Tech as well as NRC. The overall 10 team expertise for the environmental impact statement 11 evaluation is shown here on this slide and includes the 12 disciplines of atmospheric science, socioeconomics and 13 environmental justice, archeology and historic 14 resources, aquatic and terrestrial ecology, radiation 15 protection and land use.

16 Before I get into the environmental 17 findings, I would like to provide you with just a 18 little bit more detail on the environmental analysis 19 approach. In the mid 1990s, NRC evaluated the impacts 20 of all operating nuclear power plants across the 21 country, NRC looked at 92 separate impact areas and 22 found that, for 69 of these areas, the impacts were the 23 same for all plants with similar features. The NRC 24 called these category 1 issues and they were, these 25 were called category 1 issues and they were able to ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

19 1 make the same or generic conclusions that all the 2 impacts on the environment would be small.

3 The NRC published these conclusions in the 4 generic environmental impact statement that Alicia 5 mentioned called the GEIS in 1996, the NRC was unable 6 to make similar determinations for the remaining 23 7 issues. As a consequence, they decided that they would 8 prepare supplemental environmental impact statement for 9 each plant to address the remaining 23 issues, the 10 Pilgrim supplemental EIS is the document that we are 11 here today to discuss. This slide shows the process 12 used to evaluate the category 1 and category 2 issues 13 in the Pilgrim EIS, only certain issues addressed in 14 the generic EIS actually are applicable to Pilgrim.

15 The project team evaluated all category 1 16 issues that were relevant to Pilgrim to determine if 17 the conclusions reached in the generic EIS are still 18 valid, specifically we looked for any new and 19 significant information that might alter or change the 20 original conclusions. If we found no new and 21 significant information, then we adopted the 22 conclusions of the generic environmental impact 23 statement. If new and significant information was 24 identified, then we would conduct a site-specific 25 analysis on each of those *issues.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

20 1 For Pilgrim, we did not find any new and 2 significant information for any of the category 1 3 issues, and therefore, for all category 1 issues, we 4 adopted the conclusions of the generic EIS. For all 5 category 2 issues applicable to Pilgrim, we performed a 6 site-specific analysis, this is what constitutes the 7 bulk of the supplemental EIS that we are going to be 8 discussing today. Our analysis also includes a process 9 to identify and evaluate any new and potential issues 10 that may not have been included at the time that the 11 generic EIS was published.

12 Potential new issues could have been 13 identified through receipt of comments during the 14 scoping period, through the environmental on-site audit 15 or during the environmental impact analysis process.

16 If new issues were identified, then we would perform a 17 site-specific analysis on those issues. If we 18 determined that there were no issues, then we would go 19 no further.

20 In the case of Pilgrim, it was determined 21 that essential fish habitat was a new issue not 22 originally addressed in the GEIS, and as a result, we 23 did perform an essential fish habitat assessment 24 specific to Pilgrim and it is included in Appendix E of 25 the draft supplemental EIS.

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21 1 This slide outlines how impacts are 2 quantified. In the generic EIS, NRC defined the three 3 impact levels that are shown here, small, moderate and 4 large. As an example of how we use these different 5 levels, I will use the Pilgrim cooling system as an 6 example. The operation of the Pilgrim cooling system 7 has the potential to have aquatic resource impacts, 8 impacts can occur through entrainment and impingement 9 of organisms into the cooling system as well as through 10 thermal shock.

11 To show how these impacts are quantified, 12 I'll give this further example, if, for example, as we 13 did our analysis we determined that the loss of the 14 aquatic resources is so small that it cannot be 15 detected in relationship to the total population of the 16 Western Cape Cod Bay or the impacts have not 17 destabilized the aquatic resources, then we would 18 classify that as a small impact. If the losses to the 19 aquatic resources decline and the decline is measurable 20 but then stabilizes at some lower level, we would call 21 that a moderate impact. If the losses cause the 22 aquatic resources to decline to a point where they can 23 not be stabilized and they continue to decline, then 24 they would be classified as large.

25 When the project team evaluated the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

22 1 impacts from the continued operation at Pilgrim, we 2 considered information from a wide variety of sources, 3 as shown here on this slide. We used information in 4 the license renewal application, including information 5 provided by Entergy in the environmental report. We 6 conducted an audit in May of 2006 where we toured the 7 plant, talked to plant personnel and reviewed 8 documentation of plant operations, we also spoke to 9 federal, state and local officials, permitting 10 authorities and social services and we considered the 11 comments that we received during the public scoping 12 period. All of this information forms the basis of 13 analysis and preliminary conclusions that are presented 14 in the draft supplemental environmental impact 15 statement.

16 The environmental impact statement 17 considers the environmental impacts of continued 18 operation of the Pilgrim Nuclear Power Station during 19 the 20-year license renewal period and that is 2012 20 through 2032.

21 Next, I'll take a few moments to identify 22 the highlights of our review, specifically the cooling 23 system, radiological impacts, threatened and endangered 24 species, cumulative impacts and the impacts of 25 postulated accidents and severe accident mitigation ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

23 1 alternatives.

2 The first set of issues I'm going to talk 3 about relate to the cooling system for Pilgrim. There 4 are three category 2 issues relevant to the cooling 5 system at Pilgrim, this includes entrainment, 6 impingement and heat shock. Entrainment refers to the 7 process where very small aquatic organisms are pulled 8 into the cooling system, the majority of these 9 organisms generally experience mortality due to 10 physical, chemical or thermal impacts. Impingement 11 refers to larger organisms being pulled into the 12 Ocooling system and pinned onto the debris screens of 13 the system, they are not draw into the cooling system 14 and generally experience a lower mortality rate than 15 what is seen with entrainment. The system at Pilgrim 16 incorporates traveling screens that move any impinged 17 organisms off the debris screens into a fish return 18 system and back into the bay.

19 Heat shock, the third category 2 issue 20 related to the cooling system, refers to when 21 relatively warm water is released into a colder 22 environment, aquatic organisms adapted to the cooler 23 water can lose equilibrium or die when exposed to 24 significantly warmer water. Our review of the category 25 2 issues indicate that the Pilgrim cooling system may ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

24 1 have a moderate impact on the local Winter Flounder 2 population due to entrainment, a moderate impact on the 3 Jones River population of Rainbow Smelt due to 4 impingement and a small to moderate impact on all of 5 the marine resources. However, it was also determined 6 that the impacts of heat shock would be small.

7 Radiological impacts were determined in 8 the generic EIS to be a category 1 issue, that is the 9 impact of radiological releases during nuclear power 10 plant operations during the 20-year relicensing period 11 would be small. However, because these releases are a 12 concern to many people, I will be discussing them in a 13 little more detail here. All nuclear power plants 14 release some radiological effluents into the 15 environment, although it should be noted that it's 16 currently Pilgrim's current operating policy to not 17 routinely release liquid radioactive effluents.

18 During our site visit, we looked at the 19 documentation for effluent releases and the 20 radiological monitoring programs at the plant, as well 21 as the commonwealth's independent monitoring programs, 22 and we looked at how the gaseous and liquid effluents 23 were treated and released, as well as how the solid 24 wastes were treated, released and shipped. We looked 25 at how the applicant determines and demonstrates that ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

25 1 they are in compliance with the regulations for release 2 of radiological effluents, we also looked at data from 3 the on-site and near site locations that the applicant 4 monitors for airborne releases and direct radiation and 5 other monitoring stations beyond the site boundary, 6 including locations where water, fish and food products 7 are sampled.

8 In addition, we reviewed a number of 9 studies, including the Southeastern Massachusetts 10 Health Study and BEIR 7 to determine if there have been 11 any new and significant findings applicable to the 12 Pilgrim supplemental EIS. Our evaluations, which are 13 presented in Section 4.7 of the draft supplemental EIS, 14 determined that these studies did not constitute new 15 and significant information.

16 In summary, we found that the average and 17 maximum calculated doses for a member of the public are 18 well within the annual limits that are considered 19 protective for human health. Since releases from the 20 plant are not expected to increase during the 20-year 21 relicense term and since we also found no new and 22 significant information related to this issue, we 23 adopted the generic EIS conclusions that the 24 radiological impacts to human health and the 25 environment are small.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

26 1 There are-ll marine aquatic and five 2 terrestrial and fresh water aquatic threatened and 3 endangered species that have the potential to occur in 4 the vicinity of the Pilgrim site or its transmission 5 lines. We prepared a detailed biological assessment to 6 analyze the effects of continued operation and 7 relicensing of Pilgrim and that is included in Appendix 8 E of the draft supplemental EIS. Based on the 9 biological assessment, additional independent analysis 10 and discussions with the U.S. Fish and Wildlife Service 11 and the National Marine Fisheries Service, the staff's 12 preliminary determination is that the impact of 13 operation of the Pilgrim plant during the license 14 renewal period on threatened or endangered species 15 would be small.

16 Cumulative impacts are the impacts of the 17 proposed action, in this case license renewal, taken 18 together with other past, present or reasonably 19 foreseeable future actions, regardless of what agency 20 or person undertakes those actions. The cumulative 21 impacts were evaluated to the end of the 20-year 22 license renewal term. Our preliminary determination is 23 that any cumulative impacts resulting from the 24 operation of the Pilgrim plant during the license 25 renewal period would be small for all resources, with ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

27 1 the exception of marine aquatic species which would 2 experience small to moderate cumulative impacts.

3 The team also looked at the impacts 4 related to the uranium fuel cycle and solid waste 5 management, as well as the decommissioning of Pilgrim.

6 In the generic environmental impact statement, NRC 7 considered impacts associated with these topics as 8 category 1 issues and our team found no new and 9 significant information and therefore adopted the GEIS 10 conclusions. As part of the environmental review 11 process, we also evaluated a number of alternatives to 12 license renewal. Specifically, we looked at the 13 impacts of replacing Pilgrim power with power from 14 other sources.

15 Pilgrim has a power capacity of 715 16 megawatts. Alternatives that the team looked at 17 included a no action alternative, that is not renewing 18 the license. We looked at replacing Pilgrim generation 19 with generation from new power plants, either coal, 20 natural gas or new nuclear plants, we looked at the 21 impacts and capabilities of providing that replacement 22 power with purchase power. We also looked at other 23 technologies, such as wood, wind and solar power, to 24 replace Pilgrim's power and then we looked at a 25 combination of alternatives to replace that capacity.

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28 1 For each alternative, we looked at the 2 same types of issues that we did when we were 3 evaluating Pilgrim's license renewal. The team's 4 preliminary conclusion is that the environmental 5 impacts of the selected alternatives would reach 6 moderate to large significance in at least some of the 7 categories evaluated.

8 To summarize, for category 1 issues 9 presented in the generic EIS that relate to the Pilgrim

.10 plant, we found no information that was both new and 11 significant. Therefore, we have preliminarily adopted 12 the generic EIS conclusion that impacts associated with 13 those issues would continue to be small.

14 In the Pilgrim draft supplemental EIS, we 15 analyzed the remaining category 2 issues pertinent to 16 the Pilgrim plant and determined that the environmental 17 impact resulting from these issues was small in all 18 categories with the exception of a moderate impact on 19 local Winter Flounder populations due to entrainment, a 20 moderate impact to the Jones River population of 21 Rainbow Smelt due to impingement and a small to 22 moderate impact on all other marine aquatic resources.

23 Lastly, we found that the environmental impacts of 24 alternatives in at least some impact areas would reach 25 moderate or large levels of significance.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

29 1 Now I'm going to switch gears and present 2 the findings of the accident analysis for Pilgrim. We 3 have with us here in the audience Mr. Robert Palla from 4 the NRC and he was responsible for this portion of the 5 analysis. The EIS evaluated two classes of accidents, 6 design basis accidents and severe accidents. Design 7 basis accidents are those accidents that the plant is 8 designed to withstand without risk to the public, the 9 ability of the plant to withstand these accidents has 10 to be demonstrated before the plant is granted a 11 license. Since the licensee has demonstrated 12 acceptable plant performance for the design basis 13 accidents throughout the life of the plant, the 14 Commission found in the generic EIS that the 15 environmental impact of design basis accidents is small 16 for all plants.

17 The second category of accidents evaluated 18 in the generic EIS are severe accidents. Severe 19 accidents, by definition, are more severe than 20 design-based accidents because they could result in 21 substantial damage to the reactor core. The Commission 22 found, in the generic ETS, that the risk of a severe 23 accident is small for all plants.

24 Nevertheless, the Commission determined 25 that alternatives to mitigate'severe accidents must be ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

30 1 considered for all plants that have not done so, the 2 alternatives are called SAMAs or severe accident 3 mitigation alternatives. The SAMA evaluation is a 4 site-specific assessment and is a category 2 issue, as 5 we explained earlier.

6 The purpose of performing the SAMA 7 evaluation is to ensure that plant changes with the 8 potential for improving severe accident safety 9 performance are identified and evaluated. The scope of 10 potential plant improvements that were considered 11 include hardware modifications, procedure changes, 12 training program improvements and basically a full 13 spectrum of potential changes. The scope includes 14 SAMAs that would prevent core damage as well as SAMAs 15 that improve containment performance, given that core 16 damage event occurred.

17 The preliminary results of the Pilgrim 18 SAMA evaluation are summarized on this slide, there 19 were 281 candidate improvements identified for Pilgrim.

20 The number of candidate SAMAs were reduced to 59 based 21 on a multi step screening process, a more detailed 22 assessment of the risk reduction potential and 23 implementation cost was then performed for each of the 24 'remaining 59 SAMAs. A total of seven SAMAs were 25 identified as potentially cost-beneficial, five of ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

31 1 these potentially cost-beneficial SAMAs were identified 2 in the environmental report and the remaining two SAMAs 3 were identified as a result of NRC staff analysis.

4 None of the potentially cost-beneficial 5 SAMAs relate to managing the effects of plant aging 6 during the period of extended operations. Accordingly, 7 they were not required to be implemented as part of 8 license renewal. Regardless, the NRC staff considers 9 that further evaluation of the potentially 10 cost-beneficial SAMAs by Entergy is warranted.

11 This concludes my remarks and now I would 12 like to turn the program back over to Alicia.

13 MS. WILLIAMSON: Thank you, Bobbie.

14 This slide shows a recap of where exactly 15 we are in the environmental review. We issued the 16 draft on December 8, 2006, we are currently in the 17 middle of the public comment period that is scheduled 18 to end on February 28, 2007, we expect to address all 19 public comments received during the comment period, 20 make any necessary revisions to the draft and issue a 21 final environmental impact statement in July of 2007.

22 This slide identifies me as your primary point of 23 contact at the NRC for the Pilgrim license renewal 24 environmental review, it also identifies where 25 documents related to the Pilgrim review may. be found in ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

32 1 the local area which includes the Plymouth, Duxbury and 2 Kingston Libraries. At the bottom of the slide is the 3 Internet address where anyone can go and directly 4 access the Pilgrim supplemental environmental impact 5 statement.

6 There are several ways you can provide 7 your comments on the Pilgrim draft EIS, you can provide 8 comments today during the comment period of this 9 -meeting and, as you may have heard from Mr. Cameron 10 earlier, that those comments carry the same weight as 11 any other comments that you submit in writing. If 12 perhaps you are not ready to provide a comment to us 13 today, you can send your comments to us via regular 14 mail at the address shown here, you can also send us 15 you comments electronically to the e-mail address that 16 we have specifically set up for the Pilgrim 17 environmental review which is PilgrimEIS@NRC.gov. And 18 the last option is, if you would like to submit your 19 comments in person and happen to be in the Rockville 20 area, we will be more than happy to take your comments 21 there as well.

22 With that, I would like to extend my 23 thanks to each and every one of you for coming out 24 today and turn the meeting back over to Facilitator 25 Cameron.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

33 1 MR. CAMERON: Thank you. Thank you, 2 Alicia, and thank you, Bobbie.

3 We have time for questions before we move 4 on, does anybody have any questions? Did you have one?

5 Well, that's fine, we can try to answer it for you.

6 MS. CONNERTON: I just wanted to expand 7 upon if the SAMAs were warranted for the cost/benefit 8 analysis.

9 MR. CAMERON: Okay, so you had a question 10 about the SAMAs and the cost/benefit analysis and you 11 wanted us to expand on that by talking, giving you some 12 examples?

13 MS. CONNERTON: The seven that you--

14 MR. CAMERON: Oh, the seven, okay.

15 Bob, can you just talk briefly to the 16 seven that passed the cost/benefit test? And I guess 17 just to emphasize again, although we said that further 18 consideration by Entergy was warranted, the seven, even 19 though they passed the cost/benefit, screened were not 20 in the aging license renewal area, but can you just 21 talk to that?

22 MR. PALLA: Well, just to summarize, in 23 the environmental report, the applicant identified five 24 potentially cost-beneficial SAMAs and they indicated 25 that they had passed them on to their engineering group ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

34 1 for further analysis for possible implementation. Now, 2 as a result of our review and some of the questions 3 that we asked, we considered some additional SAMAs that 4 were perhaps lower cost alternatives than the ones they 5 had looked at. And in some cases we looked at SAMAs 6 that were identified from the reviews of previous 7 plants that had come in for license renewal. As a 8 result of this additional review, two additional 9 potentially cost-beneficial SAMAs were identified.

10 So, basically, as it stands right now, 11 five had been identified in the ER and had been passed 12 on for further analysis, and two additional came out of 13 the review and our recommendation was that these seven, 14 the five already identified plus the two additional, 15 should all be further evaluated for implementation.

16 They are not required to be implemented as part of 17 license renewal because they are not aging related but, 18 nevertheless, they would still, they could be worth 19 implementing for reasons of just continued plant 20 operation and just further reducing the level of risk.

21 MR. CAMERON: I want to ask you if 22 that -- Before I ask you if that is the information 23 you needed, could you please introduce yourself to us?

24 MS. CONNERTON: My name is Kelly 25 Connerton, I actually am an employee and I was just ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

35 1 wondering what those seven were, where could I find the 2 info.

3 MR. PALLA: Oh. They are identified 4 specifically in Appendix G.

5 MR. CAMERON: Okay, so they are described 6 specifically in there.

7 And that's Kelly Connerton. Okay.

8 Thanks, Kelly.

9 Thanks, Bob.

10 Further questions at this point about 11 process or the substance of the draft environmental 12 impact statement? Okay, let's move onto the second 13 part of the meeting and listen to what all of your 14 concerns are out there. I'm going to call out the 15 names of three speakers in sequence so that you know 16 when your time is coming up and we are going to start 17 with Lilias Cingolani, and I'm sorry if I mispronounced 18 that, Lilias, but Lilias is from Kingston, 19 Massachusetts.

20 Then we are going to go to Mary Lampert 21 from Pilgrim Watch and then we are going to go to Joyce 22 McMahon, who is from Mass AREA, who has a, they have a 23 presentation back there and materials.

24 So, Lilias, would you like to come up to 25 the, yeah, come up, if you don't mind.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

36 1 MS. CINGOLANI: Good afternoon. I'm just 2 a local yokel and I don't have much to say except that 3 I feel, in the long run, fission-based power is not the 4 answer and I personally do not want to see nuclear 5 power plants' lives extended any more than they have to 6 be. The fusion power plants, such as is being built in 7 Europe, probably is a better answer in the long run, 8 but it's going to cost billions of dollars. Meanwhile, 9 over in China, there is a country that's already on the 10 New York Stock Exchange and they are getting into 11 cheaply making silicon-type -- I don't have my notes 12 with me -- voltaic cells and so forth. And if China 13 really gets into this, they'll be making all the 14 materials they need, all the electricity they can get, 15 they've got over a billion people over there.

16 Meanwhile, in California, there is many, 17 many companies, one that comes to my mind is Pyron, 18 which is connected with Boeing Spectrolab, and they 19 have made and designed an array of glass, magnifying 20 glass, small cubic-type things, I can't explain it, and 21 a 25-foot diameter array which focuses the sun's energy 22 onto voltaic-type generators. And it seems to me that, 23 in the long run, the world has to turn to materials and 24 processes that do not involve radioactive materials 25 which are dangerous, no matter what you say about how ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

37 1 they decompose and blah, blah, blah. This stuff has to 2 be stored, it has to be transported.

3 Anyone here already knows enough, much 4 more than I do, and can argue every point I'm trying to 5 make. But I feel it's common sense to start the 6 process to truly clean and probably in the long run 7 will be cheaper-type energy. The solar array that I 8 just mentioned is 40 percent efficient and already 9 solar energy is down to about $2 a kilowatt, if my, I'm 10 not sure if I'm right on that, but it's been cut in 11 half, it was $4, now it's down to $2 and it's heading 12 for a cheaper and cheaper base level.

13 And I don't have anything more to say, 14 this is all my personal opinion, and I'm not an expert, 15 but I have lived across the bay from Pilgrim since it 16 was built, and I fished outside of it and I even drove 17 down there one time, drove right in, I probably can't 18 do it now, walked all around and nobody stopped me, but 19 this was roughly 20 years ago, and I took pictures and 20 I also have a whole album of pictures I took inside 21 Pilgrim of all their machinery and everything as a 22 project for a class I was taking at Bridgewater State 23 College. So I've always been interested in Pilgrim, 24 but common sense tells me it's time to start phasing 25 out of this type of electrical source.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

38 1 MR. CAMERON: Thank you very much, Lilias, 2 we appreciate those comments on alternative energy 3 sources.

4 And let's go to Mary Lampert now from 5 Pilgrim Watch.

6 MS. LAMPERT: Good afternoon.

7 My students in the dark ages always 8 referred to me as a very tough grader and I think the 9 NRC will feel the same. I clearly think you are going 10 to be very,, very busy until July because the conclusion 11 that the impacts are small, except for two species of 12 fish, I feel result from two parts, one, by ignoring 13 and misinterpreting new and significant information; 14 second, by assuming the rules that were largely put in 15 place in the 1970s currently and in the future are 16 protected of public health and safety, are being 17 followed to the T by the licensee and the NRC is 18 assuring that it is. Anybody who heard of the Davis 19 Besse plant with a whole in its head, I think I don't 20 have to say anymore.

21 Before I start my comments, I think there 22 are two points that have to be brought up, in the GEIS 23 Section 5 it deals with design-basis and severe 24 accidents with an emphasis on releases substantially in 25 excess of permissible limits for normal operations.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

39 1 Nowhere in this section is the spent fuel pool excluded 2 nor the reactor core cited as the only risk.

3 Therefore, I will argue that you are remiss not to 4 include in the supplement the spent fuel pool under 5 postulated accidents.

6 Second, another issue near and dear to 7 citizen's hearts is security and terrorism. The 9th 8 Circuit Court in California faced the question of 9 whether the NRC needs to consider terrorism in 10 licensing decisions under NEPA, they concluded that in 11 fact they did. This is an important licensing 12 decision. The industry in California went to appeal to 13 the Supreme Court and the Supreme Court decided not to 14 hear it which indicates they gave their blessing to the 15 decision. So these to factors, therefore, that being 16 terrorism, security and the spent fuel pool under 17 postulated accidents must be considered if you are 18 going to do an honest job.

19 And now I'll try to focus my comments on 20 the areas of major concern to citizens which are 21 health, postulated accidents, spent fuel, radioactive 22 waste. The NRC draft concluded that there was nothing 23 new or significant and the impacts from radiation on 24 health would be small, they did this by misinterpreting 25 and ignoring important significant information that ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

40 1 pertains specifically here. Very basically, they 2 ignored new and significant research that shows 3 radiation's effects are cumulative and they effect the 4 most vulnerable, the old, the young and the sick. By 5 ignoring this, then they went on to ignore and give 6 significance to important facts here.

7 Demographics. By 2032, during the 8 licensing period, the population is expected, one in 9 three, to be over 55, it's one in five now, therefore a 10 more vulnerable population will be in this area.

11 Second, they ignored the radiation-linked diseases that 12 are in this area. The former founder and director of 13 the Mass Cancer Registry has done an analysis, year to 14 year, of cancer statistics in the seven communities 15 that are likely to be impacted which was determined 16 from a state study on health impact. They have seen, 17 every single year, either statistically significant or 18 elevated rates of leukemia, rates of thyroid cancer 19 until this very day, this was ignored. Also ignored 20 was the fact of elevations in prostate and multiple 21 myeloma from 1999 to '02. Therefore, again, a 22 population that is sensitive.

23 They also ignored looking further at the 24 Southeastern Massachusetts Health Study. They didn't 25 ignore it, they simply misrepresented it, which is ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

41 1 quite shameful, I might add. The Southeastern 2 Massachusetts Health Study stated, was a study done by 3 the Mass Department of Public Health on adult leukemia 4 and found a, concluded a fourfold increase the closer 5 you lived or- if you worked at the reactor. Then there 6 was a re-review, a second peer review panel, 7 politically appointed so that Boston Edison, the then 8 owner, could appoint half the panel and approve the 9 half.

10 However, the draft says that the NRC 11 considered the relevant information in the re-review --

12 they didn't use that word -- and concludes that the 13 peer reviews and even the authors now agree that the 14 study does not demonstrate a causal relationship 15 between Pilgrim effluents and the potential effect of 16 cancers in the areas around the state. So, I called 17 the principle author of the study and I said did you 18 talk to them? He said no, I never talked to them, I 19 stand by this study, as did Boston Edison's own peer 20 review panel, hand-picked, that said the results can 21 not be discarded because of methodological weaknesses.

22 And I said, well, what about the Assistant 23 Commissioner, Suzanne Condon? What did she say? And I 24 have e-mails to this effect, oh, she said the 25 department stands by these studies, this particular ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

42 1 study, and they went on further, the association 2 between leukemia and the proximity to Pilgrim was 3 unexpectedly strong and this raised biological 4 plausibility of the study, the study results could not 5 be dismissed. Then the NRC goes on in the draft to 6 cite various studies that supposedly say there is no 7 association between exposure and living and being near 8 a reactor.

9 What they did was cherry-pick studies that 10 were the industry's and government's equivalent of the 11 tobacco scientists. What they failed to do is to look 12 at all the recent research that is out there, and I 13 would refer you, and I will in writing, to Clark 14 University's Marsh Institute that has collected all 15 research that is done on this area. Then they go to 16 the BEIR 7 report and say there is nothing really new 17 or significant there to change our determination. The 18 reality is that what they didn't say is what the BEIR 7 19 report had to say on the incidents of cancer being a 20 third higher than they previously thought.

21 What they didn't say was the BEIR 7, 22 speaking specifically to the greater effect of low dose 23 radiation exposure on women and children, over 30 24 percent higher in woman. What they didn't say is the 25 new information on effect on workers, if they receive ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

43 1 the maximum allowable dose, where NRC had said one out 2 of eight would get cancer, now BEIR 7, one out of four.

3 All these things are clearly significant. What they 4 didn't say in the draft was the BEIR 7 talked about 5 health effects other than cancer that can be expected 6 from low dose radiation exposure such as heart disease 7 and stroke.

8 And what they didn't say when they were 9 talking about health effects in the postulated 10 accidents section of the new and significant 11 information presented by the Massachusetts Attorney 12 General of the likely health consequences of a spent 13 fuel pool accident at Pilgrim, yes, 24,000 cancers 14 expected if there is a complete release of just Cesium 15 137, 8,000 if only ten percent of that bad guy is 16 released.

17 What they didn't say under postulated 18 accidents was a reference to the Sandia National 19 Report, the CRAC II which in 1982 NRC asked them to do 20 for the consequences specifically of a core melt at 21 each reactor and what that study said was that you 22 could expect 3,000 early injuries -- no, what was. it?

23 No, 3,000 fatalities and 30,000 'early injuries, that 24 was '82.

25 But what they didn't look at was Dr. Edwin ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

44 1 Lymon, a Union of Concerned Scientists report done on 2 why these figures have to be updated, why they are 3 conservative, new information of why this is pertinent 4 now. And so by ignoring or misinterpreting these 5 important factors, they fail then to look at 6 significant mitigation that could occur and they ignore 7 the fact that, guess what? I don't know how much 8 radiation is coming out of there, Entergy doesn't know 9 and the NRC doesn't know, and so an important 10 mitigation step going forward, if you are honest about 11 health effects, is to have a requirement or look at to 12 analyze.

13 I mean that's what you are supposed to be 14 doing, having combination real-time wind and radiation 15 detectors placed in logical areas in off-site 16- communities that provide real-time data on this to the 17 state, and to the local communities and to the NRC.

18 Hey, they should know too. This was recommended back 19 in 1990, we are talking about the future until 2032, so 20 you can play your games and not analyze the real, the 21 new and significant information that is out there, take 22 your cherry-picked, tobacco science equivalent studies 23 and continue pretending, and also looking at acceptable 24 dose to a mythical, mythical 30 year old healthy guy 25 and not the effect that it should be on those who are ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

45 1 most sensitive, which BEIR 7 points out are the young, 2 the old and the sick. I think that's what I have to 3 say about health.

4 Now, do I have time for my other subjects?

5 MR. CAMERON: Mary, let's go on to other 6 people, if that's--

7 MS. LAMPERT: Okay.

8 MR. CAMERON: -- fifteen and--

9 MS. LAMPERT: Because I would like to talk 10 about waste and postulated accidents but, thank you, I 11 appreciate the position you are in and you are always 12 very courteous and fair to people.

13 MR. CAMERON: Thank you, Mary, we'll see 14 if we can get back to you.

15 There is other issues and would you make 16 sure -- You mentioned the Massachusetts Cancer 17 Registry and just make sure that the staff has access 18 to a Web site or how to get that information. I don't 19 know, they may already know about it, but I just want 20 to make sure that they have that in your written 21 comments. And I don't want to get into a discussion of 22 BEIR 7 but I noted when Bobbie mentioned it and you 23 mentioned it now that it's not going to be evident to 24 people, all people, what exactly BEIR 7 is. And I just 25 want to ask Bobbie to just tell us not about the study ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

46 1 but what does BEIR stand for and who is that? Oh, 2 Alicia,? Okay, beautiful.

3 MS. WILLIAMSON: Basically, BEIR stands 4 for Biological Effects of Ionizing Radiation, it's a 5 study that's conducted by the National Academy of 6 Sciences. It's published, if I'm not mistaken, about 7 every three years. Is that correct, Rich? He is our 8 senior health physicist, he is the expert on that, but 9 that's correct, Rich? About every three years they 10 publish that?

11 I might turn it over.

12 MR. CAMERON: And, Rich, without, if you 13 could just tell us why this is BEIR 7? In other words, 14 just who is doing this and why are they doing it, I 15 guess, so people understand.

16 MR. EMCH: It's called BEIR 7 because 17 there have been seven reports, the first one was BEIR 1 18 back in, I don't even remember the exact date, probably 19 somewhere around 1972. The BEIR reports that talk 20 about ionizing radiation, which is what we are talking 21 about here, the entire title of this BEIR 7 report is 22 "Health Risks from Exposure to Low Levels of Ionizing 23 Radiation, BEIR 7, Phase II", and each of the, the 1, 24 the 3, the 5 and the 7 all talked about similar issues 25 and they've been published at various intervals, ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

47 1 probably not three years, since the first one was in 2 the mid '70s. They have been published at very 3 intervals over the years and the draft of this one came 4 out in 2005 and the final version came out in 2006.

5 MR. CAMERON: Okay, thank you very much.

6 And as we heard, the draft supplemental 7 environmental impact statement looks at BEIR 7, and you 8 have heard Mary Lampert talk about the' study and when 9 Mary and others submit their comments, written comments 10 that will be available to people, they'll be discussing 11 BEIR 7 too, so just so you know what that acronym is.

12 And let's go to Joyce, this is Joyce McMahon and she is 13 from Mass AREA, and then we are going to go to Bob 14 Ruddock, Rebecca Chin and John Stobierski.

15 MS. MCMAHON: Good afternoon. My name is 16 Joyce McMahon and I am the Communications Director for 17 the Massachusetts Affordable Reliable Electric 18 Alliance, Mass AREA for short.

19 First, let me thank you for taking this 20 opportunity to address the commission, we do appreciate 21 your time. Second, I would like to tell you a little 22 bit about Mass AREA and why we felt it was important to 23 be here. Mass AREA is a diverse, state-wide group 24 comprised of more than 65 labor, trade associations, 25 businesses and, with fill disclosure, including ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

48 1 Entergy, educators, scientists, advocates and community 2 leaders.

3 During today's sessions, you'll hear from 4 some other Mass AREA members, including the South Shore 5 Chamber of Commerce, the Massachusetts AFL-CIO and the 6 Associated Industries of Massachusetts. As a group, we 7 are committed to finding clean, low cost and reliable 8 electricity solutions that benefit all of 9 Massachusetts, it is an urgent public policy challenge.

10 We came together one year ago after several warnings 11 were issued by the Federal Energy Regulatory 12 Commission, ISO New England and others that energy 13 supplies will be insufficient to meet peak demand as 14 early as 2008 and that energy prices are causing 15 hardship for the region's businesses and residents, 16 especially the most vulnerable populations such as the 17 elderly and low income.

18 While Mass AREA's mission is brought in 19 focus to include new electric generation in the form of 20 renewable energy resources, improving the transmission 21 infrastructure, developing new natural gas supplies and 22 encouraging energy efficiency, Mass AREA and its 23 members fully support a license extension for the 24 Pilgrim Nuclear Power Plant. On a typical day, Pilgrim 25 provides seven to nine percent of the Commonwealth's ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

49 1 electricity. Without it, Massachusetts and the region 2 as a whole could face power supply shortages, including 3 rolling blackouts, a lot sooner than predicted of next 4 year.

5 Perhaps one of the most important issues 6 that led Mass AREA to support a license extension for 7 Pilgrim is the fact that the plant operates safely and 8 continuously earns the NRC's highest safety rating of 9 green. We also know that NRC staffers are on-site at 10 the plant each and every day overseeing operations and 11 helping to maintain a safe and secure environment.

12 The production and distribution of 13 electricity, whatever the source, is inherently a 14 challenging safety issues, yet nuclear power has proven 15 safe. In 50 years of commercial operations, there has 16 never been a radiological death at any U.S. nuclear 17 plant.

18 Mass AREA and its members are also 19 comforted in the knowledge that Pilgrim's owners work 20 diligently with state and local emergency officials, 21 some of their programs include giving the local 22 communities radio equipment so that they all operate on 23 the same frequency and conducting extensive training 24 sessions to make sure everyone is prepared in the event 25 of an emergency, be in plant-specific or a natural ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

50 1 occurrenc~e such as a hurricane or a blizzard. The real 2 danger is a scenario that Massachusetts will face if 3 the state does not have enough affordable and reliable 4 electricity.

5 Blackouts aren't simply an inconvenience 6 or a temporary loss of business, blackouts cause death 7 because people who are already frail and infirm can't 8 get heat or cooling they need to sustain life. High 9 prices are a danger too as they cause folks to curtail 10 electricity use and again result in real life safety 11 concerns and possible harm. Over the past several 12 months, there have been a few proposals for new power 13 plants but most are small, still the largest proposal, 14 Cape Wind, faces significant opposition and the smaller 15 units have not even begun the very long siting process.

16 As such, it becomes even more vital that we maintain 17 our current supply, including Pilgrim.

18 Opponents of the Pilgrim Power Plaht often 19 say we will be better off if the generator-was 20 decommissioned. However, the baseload power that would 21 replace Pilgrim would most likely come from sources 22 that are more expensive, far more polluting or both.

23 At this time, wind and other renewable energy 24 technologies simply can not generate the massive 25 baseload power that would be needed were Pilgrim to ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

51 1 cease operations. Moreover, the electricity that 2 Pilgrim supplies is created without generating any 3 greenhouse gas emissions and therefore it does not 4 contribute to global warming.

5 Pilgrim also mitigates the production of 6 hundreds of tons of sulfur dioxide and nitrogen oxides, 7 chemicals which are harmful to human health, especially 8 among children and the elderly, these health and 9 environmental benefits alone are enough argument for 10 renewing Pilgrim's license to produce power.

11 From an economic standpoint, since the 12 owners of the plant sell their power through long-term 13 contracts and not on the volatile short-term market, 14 the power produced at Pilgrim is much lower cost than 15 the regional average. Massachusetts ranks fourth in 16 the nation in terms of highest electricity costs, 17 couple that with our high housing and health care costs 18 and it becomes even more important to maintain 19 Pilgrim's very reliable, low cost electricity so that 20 we don't continue to have an exodus of residents and 21 businesses from our state who can no longer afford to 22 live or work here.

23 Speaking of work, Pilgrim is also an 24 important source of jobs, it has more than 700 25 permanent full-time employees, most of whom live in ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

52 1 Plymouth and the surrounding communities, indeed 2 Pilgrim supports the local economy to the tune of $135 3 million in local economic activity. Though the draft 4 environmental impact statement noted a moderate socio 5 economic impact should the plant cease operations, we 6 believe those who would lose their jobs would face a 7 large economic and financial loss.

8 In summary, Mass AREA has weighed all of 9 the environmental, economic and energy supply traits of 10 Pilgrim, particularly its long record of safety, and 11 concluded that the Pilgrim Nuclear Power Plant is vital 12 to the region, state and local economy for three 13 reasons, its environmentally sound operations, its 14 economic contribution to the local community through 15 the provision of jobs and purchase of goods and 16 services and its provision of reliable, low cost 17 electricity. Mass AREA encourages the NRC to grant 18 Entergy's Pilgrim station an extension of its license 19 so that it can continue to safely operate for an 20 additional 20 years.

21 Further, we urge the Atomic Safety and 22 Licensing Board to consider the Pilgrim related matters 23 before it as quickly and expediently as possible while 24 the license renewal process takes its natural pace.

25 Again, thank you for the opportunity to speak with you ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

53 1 today.

2 MR. CAMERON: Thank you, Joyce.

3 Next we have Bob Ruddock. And while he 4 is, just let me note that Alicia pointed out that there 5 is a commission paper, which is a staff report to the 6 Nuclear Regulatory Commission, back on the tables that 7 address this BEIR 7 issue in more detail, for anybody 8 who wants some more information on it.

9 MR. RUDDOCK: Good afternoon. My name is 10 Robert Ruddock and I am the General Counsel for 11 Associated Industries of Massachusetts. On behalf of 12 AIM, I want to thank the Nuclear Regulatory Commission 13 for the opportunity to present our views here this 14 afternoon, for conducting this meeting and for the 15 opportunity to provide these comments.

16 AIM is a statewide association of 17 employers, more than 7,000 of them are our members, 18 they employ roughly 680,000 employees across the 19 Commonwealth. The organization's goal is to effect 20 public policy to create a positive economic climate for 21 our businesses and for jobs in the State of 22 Massachusetts.

23 We think it's essential to put our 24 comments into the proper context. As an earlier 25 speaker indicated, Massachusetts has very high ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

54 1 electricity costs affecting every consumer, 2 residential, commercial and industrial. Electricity 3 has historically been driven, most recently, by the 4 shift to generation by natural gas fuels which are 5 costly and which have some concern about continued 6 supply. Pilgrim Nuclear Power Station is a very 7 important balance for these high costs and for the lack 8 of fuel diversity in our state.

9 In addition, the critical role Pilgrim 10 plays in supply and diversity, its role in producing 11 electricity without air pollutants and laudatory, no 12 pollution contributes to the state's goal of reducing 13 greenhouse gas emissions. Achieving these goals will 14 have some cost impacts on all consumers, but it's great 15 to know that Pilgrim station provides economical 16 electricity without a carbon footprint. Pilgrim also 17 contributes to meeting and sustaining the electricity 18 supply, as our demand grows on average of about two 19 percent a year compounded.

20 With that as context, AIM believes that 21 the draft environmental impact statement adequately 22 complies with the requirements of the act, AIM urges 23 the commission to adopt the recommendation of the 24 report to continue consideration of relicensing. Given 25 Pilgrim's positive contributions to the reliability, ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

55 1 supply and cost of electricity in this state and its 2 significant environmental benefit, we also would urge 3 the commission to in fact relicense this plant.

4 Thank You again for your attention.

5 MR. CAMERON: Thank you very much, Bob.

6 Next we are going to go to Rebecca.

7 Rebecca Chin is with the Duxbury Nuclear Advisory 8 Committee.

9 MS. CHIN: Thank you. I'm also a former 10 Chairman of the Duxbury Board of Health, so I would 11 like to keep that in context with my first set of 12 comments.,

13 The NRC draft SEIS concludes that the 14 health impact is and will continue to be small by 15 mischaracterizing the Southeastern Massachusetts Health 16 Study. The draft SEIS states that the authors of the 17 Southeastern Massachusetts Health Study have stated 18 that the study shows both a statistical association and 19 a cause and effect relationship between leukemia 20 incidents around the nuclear power plant and exposure 21 to effluents from the plant.

22 The final report released to the public in 23 October of 1990 found a two to fourfold increase of 24 leukemia among residents of certain towns within a 20 25 mile radius of the plant, the draft goes on to cite ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

56 1 peer reviews from a second rereview peer group that did 2 not support the causal relationship. However, the peer 3 review panel referred to in the draft was appointed by 4 Boston Edison's request, the owner of Pilgrim at the 5 time, and contrary to accepted scientific practice, 6 half of the rereview panel members were appointed by 7 MDPD and the other half by Boston Edison, the company 8 directly impacted and implicated by the study's 9 findings.

10 In the executive summary of its report 11 though, the second peer review panel concluded that the 12 findings can not be readily dismissed on a basis of 13 methodological errors or proven biases, the association 14 found between leukemia and the proximity to the Pilgrim 15 nuclear facility was unexpectedly strong and this 16 raised concern regarding the biological plausibility of 17 the study. However, because the study's results could 18 not be dismissed, further study may be warranted, 19 including expanding the case finding and including 20 children.

21 The study noted that Boston Edison 22 admitted higher than average releases in the early days 23 due to poor fuel or damage rods and lack of filtration 24 systems, the study researchers also knew that a number 25 of possible points were not monitored and the monitors ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

57 1 on even the main stack did not measure all types of 2 radiation, that significant radiation had been reported 3 in shellfish, milk and vegetation near the plant. The 4 re-review panel member schooled in monitoring was a 5 Boston Edison employee who discounted any unmonitored 6 releases and blamed the too high radiation levels in 7 milk and vegetation on bomb testing in China.

8 The panel also claimed that if Pilgrim had 9 released significant levels of radiation, it would have 10 been detectable on large numbers of monitors throughout 11 Eastern Massachusetts. However, the Boston Edison 12 appointee was questioned on this and he conceded that, 13 in 1970, there existed only three monitors, one at 14 Pilgrim, another at MIT Cambridge keeping track of 15 MIT's reactor and a third in South Boston keeping tabs 16 on Dupont. These had the same lack of sensitivity as 17 Pilgrim's and were too far away to realistically have 18 been expected to detect Pilgrim's emissions.

19 The inescapable conclusion is that, both 20 in the 1970s and now, no one really knows how much 21 radiation Pilgrim emitted. The re-review panel 22 effectively admitted as much, suggesting that there 23 should be an independent evaluation of the potential 24 radiation exposure from the Pilgrim plant and from 25 other sources. The study was even more explicit, it ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

58 1 recommended that a system of real-time monitoring and 2 radio nucleotide emissions be implemented so that 3 reliable and timely data are available by which 4 exposure can be assessed more precisely.

5 The re-review panel's statement in the 6 study's conclusion is contradicted by the fact that the 7 death rates for the study have remained close to the 8 state average exemplifies the how to lie with 9 statistics problem. The re-review panel looked at 10 death rates for Plymouth County as a whole, the 11 Southeastern Mass study found an increased risk in 12 those, to those in a much smaller, more concentrated 13 area likely, within the likely to be impacted 14 geographic area. The re-review panel's executive 15 summary admitted that there have been other reports of 16 observed cancer increases that are inconsistent with 17 predictions based on mathematical modeling and radio 18 biology theory.

19 In 1990, the Southeastern Mass findings 20 was not based on mathematical models or estimates of 21 radiation releases, rather it was focused on what 22 really happened to real people. The NRC's impact 23 statement ignores the principle Mass Department of 24 Public Health and peer review conclusions that the 25 findings can not be dismissed and that further ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

59 1 attention to the possible risks associated with the 2 power plant may be warranted, including expanding case 3 findings and including children.

4 My second comment is on the draft SEIS, 5 that the NRC staff mistakenly concluded that the 6 applicant's SAMA analysis was sound, that the faulty 7 SAMA analysis used by Entergy in the environmental 8 report caused it to wrongly dismiss mitigation 9 alternatives such as adding a filter to the direct 10 torus vent. The purpose of a SAMA review is to ensure 11 that any plant changes that have a potential for 12 significantly improving severe accident safety 13 performance are identified and addressed, one examples 14 of how a poorly performed SAMA analysis can lead to 15 erroneous conclusions is the Pilgrim environmental 16 reports look at the cost and benefits of installing a 17 direct torus vent filter at Pilgrim.

18 The direct torus vent system is a method 19 to relieve high pressure which is generated during an 20 accident review, severe accident, excuse me. in 1986 21 it was determined that the Mark I containment, 22 especially being smaller with lower design pressure, in 23 spite of a suppression pool, has a 90 percent 24 probability of that containment failing. The purpose 25 of the containment is to provide a barrier between the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

60 1 lethal radiation inside the reactor and the public. In 2 order to protect the Mark I containment from total 3 rupture, it was determined necessary to vent high 4 pressure build-up. As a result, the direct torus vent 5 system to all Mark I reactors, including Pilgrim, was 6 installed.

7 Operated from the control room, the vent 8 is a reinforced pipe installed in the torus and 9 designed to release radioactive high pressure steam 10 generated in a severe accident by allowing the 11 unfiltered releases directly to the atmosphere through 12 a 300-foot vent stack. Use of the vent discharges 13 steam and radioactive material directly into the 14 atmosphere, bypassing the standby gas treatment system 15 filters normally used to process releases via the 16 containment ventilation pathway. There is no radiation 17 monitor on the pipe and valves that compromise the 18 direct torus vent line and operators now have the 19 option to direct action to expose the public and the 20 environment to unknown amounts of harmful radiation.

21 As a result of Pilgrim's design 22 deficiency, the original idea for a passive containment 23 system has been dangerously compromised and given over 24 to human control with all its associated risks of error 25 and technical failure. There appears to be an internal ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

61 1 contradiction in what we are being told, the NRC 2 believes that the release from a severe core melt 3 accident would be reduced by a factor of 100, this is 4 considerably more optimistic than estimated in the 5 NRC's first study on the subject.

6 As the contention is that the reduction of 7 a filtration system would have zero benefit, here the 8 contenders seem to be assuming that a factor of 100 9 equals 100 percent and that's false, even a release of 10 1 percent of the core's radioactive iodine and cesium 11 would be a very severe event.

12 In its environmental report, Entergy 13 analyzes the benefits of installing a filter to the 14 torus vent in the course of reviewing possible severe 15 accident mitigation alternatives, their report states 16 this analysis case was used to evaluate the change in 17 plant risk from installing a filtered containment vent 18 to provide fission product scrubbing. A bounding 19 analysis was performed by reducing the successful torus 20 venting accident progression source terms by a factor 21 of two to reflect the additional filtered capacity and 22 capability.

23 Reducing the releases from the vent path 24 resulted in no benefit, according to the state report, 25 the basis for conclusion that successful torus venting

. ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

62 1 accident progression source terms are reduced by a 2 factor of two to reflect the additional filtered 3 capability, the cost of implementing SAMA at Peach 4 Bottom was estimated at $3 million. Therefore, this 5 SAMA is not cost effective for Pilgrim. Entergy has 6 determined that, in return for a cost of $3 million, 7 there will be no benefit to public health or safety.

8 How is it possible to find zero benefit 9 from installing a filter that would reduce by a factor 10 of two the radioactive venting to the public in a case 11 of a severe accident? Unfiltered venting has been 12 judged unsafe by all regulatory agencies outside the 13 United States. In its analysis of several risk 14 contributors to core damage frequency, the disposition 15 of those events frequently included venting via the 16 direct torus vent path to reduce containment pressure.

17 In other words, a filter in the torus vent would reduce

18. the impact in many possible severe accidents.

19 The only conclusion to draw from the 20 outcome of the direct torus vent filter SAMA analysis 21 is that Entergy has used the MACCS II code to downplay 22 the health and economic cost of severe accidents and 23 use the probablistic safety analysis model to make the 24 benefits of mitigation appear to be zero. NRC staff 25 reviewed Entergy's analysis and concluded that the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

63 1 methods used to implementation of those methods of 2 sound, the costs of SAMA's evaluation would be higher 3 than the associated benefits in 2.2, in 5.2.5. The NRC 4 staff is wrong to accept Entergy's SAMA analysis in 5 this application.

6 The SAMA analysis included in the Pilgrim 7 environmental report is incomplete, not only does the 8 probablistic modeling for severe accidents artificially 9- make consequences appear insignificant but the 10 application has used incomplete and incorrect input 11 parameters to the MACCS II code. The direct or torus 12 vent filter is an example of how this cost/benefit 13 equation might have been skewed in favor of no 14 mitigation. While the NEPA does not require agencies 15 to select particular options, it is intended to foster 16 both informed decision making and inform public 17 participation and thus to ensure the agency does not 18 act upon incomplete information only to regret its 19 decision later, after it's too late to correct. It 20 then said if further analysis is called for, that in 21 itself is valid and meaningful remedy under NEPA.

22 The applicant has drastically undercounted 23 the cost of severe accident and this could have led it 24 to erroneously reject mitigation alternatives, further 25 analysis is called for. The EPA has acceptable ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

64 1 standards for exposure, in the real world there is no 2 safe level of exposure to radiation.

3 In conclusion, the danger of NRC rubber 4 stamping the Entergy's SAMA in the draft SEIS, 5 accepting the licensee's minimization of consequences 6 that make the cost of adding a filter to the direct 7 torus vent seem unnecessarily high or not cost 8 effective when it is obvious that the mitigation of 9 installing the filter could indeed serve to protect the 10 public health and safety, I repeat unfiltered venting 11 has been judged unsafe by all regulatory agencies 12 outside of the United States.

13 MR. CAMERON: Thank you. Thank you very 14 much, Becky.

15 And we are going to go now to John 16 Stobierski.

17 MR. STOBIERSKI: Good afternoon. I would 18 like to thank you, Mr. Cameron, Ms. Williamson and 19 Ms. Hurley for your presentations and for running a 20 very good, and informative and fast paced meeting, I 21 appreciate it. And I appreciate the presence and the 22 diligence of your colleagues as well who are working on 23 the relicensing of the Pilgrim Nuclear Power Plant. I 24 will try to be brief and not try your patience.

25 My name is John Stobierski, I am here ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

65 1 representing the South Shore Chamber of Commerce, which 2 is an independent association of 2,000 businesses, 3 including health care and educational institutions and 4 nonprofit organizations in the communities from Boston 5 to Plymouth, we are the largest chamber of commerce in 6 Massachusetts. We are an association of business 7 people who are committed to the economic health and the 8 quality of life of the communities that we serve.

9 A few months ago, we invited members of 10 our leadership to examine the issues surrounding the 11 relicensing of Pilgrim Nuclear Power Plant and whether 12 it was an issue that the chamber should get involved.

13 with, whether we should weigh in. We reviewed the 14 record of the Pilgrim Nuclear Power Plant and its 34 15 years of operation safely as a neighbor of ours, we 16 examined its contribution to the economy of this 17 region, the 500 people that it employees directly, the 18 130 contract employees who serve at the plant and the 19 economic offshoots of that employment base and of the 20 businesses that do business in this region because of 21 the presence of the plant.

22 And they evaluated the plant in terms of 23 our need as a region, as a growing region, one of the 24 few growing areas in the Northeast, the need for 25 diverse and reliable and affordable sources of energy.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

66 1 The residents and the employers who are here, who may 2 be moving here as this area grows, are deciding whether 3 to make a long-term investment in our region and the 4 status of the Pilgrim station is very important to 5 those decisions. Recently, a dozen and a half of our 6 board members and other leaders of the chamber spent 7 some time at the plant, these are folks from 8 construction and engineering and manufacturing and 9 environmental sciences.

10 And I'm not going to represent to you that 11 they conducted a thorough, top to bottom survey of 12 every last square inch of the plant, but this was not 13 some awed troop of Brownie Scouts either, these were 14 skeptical business people who have an investment in 15 this region and want to make sure that nothing they do 16 or say jeopardizes the safety or the reputation of 17 their employees, their neighbors in the area where they 18 are invested. After evaluating the plant and its 19 contributions to our region, its economic impact, the 20 employment base, its environmental record, the 21 addition, the very critical addition that it makes to a 22 diverse and reliable energy supply and the plant's 23 presence and overall contributions to the quality of 24 life in our region, our leadership voted, after a 25 healthy discussion, voted and voted unanimously to ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

67 1 encourage the Nuclear Regulatory Commission to approve 2 in a timely fashion the full relicensing of the nuclear 3 power plant.

4 We are pleased to have this safe, secure, 5 reliable source of power and its significant beneficial 6 contributor to the employment base and to the overall 7 economic well being as part of our region and we thank 8 you very much.

9 MR. CAMERON: Thank you very much, John, 10 for those comments.

11 We are going to go to Malcolm, 12 Mr. McNaught. Is Malcolm McNaught still here?

13 Okay, Pine duBois? And Pine is from the 14 Jones River Watershed Association. And then we'll go 15 to Ben Morgan and then to Heidi Mayo from Pilgrim 16 Watch.

17 MR. DUBOIS: Thank you, hi. I am from the 18 Jones River Watershed Association, which the Jones 19 River is just a few miles north of here and drains as 20 the largest river into Cape Cod Bay, and I'm here to 21 just preview, I guess, my comment that I hope to make 22 in writing prior to the deadline with some others who 23 are concerned about the aquatic and marine habitat.

24 And although I share concerns of many of the other 25 residents regarding the safety and what we were just ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

68 1 previously talking about, I'm not going to address 2 those now.

3 As far as the impact analysis, we do 4 continue to be extremely concerned about the fisheries 5 that inhabit Cape Cod Bay and in particularly the 6 estuary of the Jones River which are in severe decline.

7 We have concerns about the methods and approach and the 8 limitations of the approach in the document, although I 9 do admit that I found the document extremely 10 interesting and informative reading. However, because 11 the populations of herring, Alewife, Rainbow Smelt, 12 Shad, American Eel are all in severe decline in the 13 Jones River and elsewhere on the Atlantic Coast region, 14 I believe that even the assessment of moderate impact 15 is inaccurate, and that continued impingement and 16 entrainment of these types of species on the Pilgrim 17 intake screens is severe. And that even though I 18 understand from the document that the NPDES permit will 19 consider modifications to that intake, it's my opinion, 20 and we will comment this way, that there should be no 21 relicensing certainly without considerable modification 22 to the intake and discharge structure that provides 23 cooling water to the plant.

24 I~think this is an extremely significant 25 and difficult proposition, I believe it deserves ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

69 1 attention that should have been given to it a long time 2 ago. I believe that the monitoring that has been done 3 since 1972 certainly has made that clear and I'm sorry 4 that the industry has waited until the NPDES renewal to 5 begin to address it.

6 In addition, I think that there needs to 7 be some consideration given to the facts of global 8 warming, I was interested to read in the report that 9 Pilgrim made an attempt to deepen the intake channel 10 because they wanted to get the water cooler and that 11 effort failed.

12 I think, in general, the ocean is getting 13 a little warmer, certainly the bay is getting warmer, 14 and I believe that it is in part getting warmer not 15 only because of global influences but because there is 16 a continual daily thermal discharge of superheated 17 water from the plant as a result of the cooling 18 function. And that the documents do not consider the 19 impact of that general warming upon the bay, upon the 20 essential fish habitat and upon the species that live 21 there, and I think this was a flaw in the supplement 22 and I believe that it should be corrected in the final, 23 that the warming of the bay waters has to be 24 considered.

25 What was considered was the shock to the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

70 1 species, in terms of the discharge and I believe that 2 the report basically says, well, a fish can swim away 3 from superheated water, and while I believe that's 4 true, I think if the general warming pattern is there, 5 then we are kind of --. Like us in this room, we are 6 sort of all stuck with the environment that we happen 7 to be in at the moment and if you can't get out of it, 8 you have to. suffer the result. That is what's 9 happening to our marine fisheries, and there is a 10 bigger impact than locally to Pilgrim or locally to the 11 Jones River, and we have to pay attention to that and 12 we cannot delay that attention any longer, anymore than 13 we can delay the attention given to some of the other 14 concerns.

15 Cape Cod Bay is an ocean sanctuary under 16 Massachusetts state law, that wasn't mentioned in the 17 report. It is a violation of state law that anything 18 effect a habitat and I think that that would mean that 19 the fish species considerations has to be broadened and 20 it certainly has to include such species as shad and as 21 the American Eel, and perhaps even the Sand Tiger Shark 22 which again wasn't mentioned in the report but is not 23 only becoming more of a species of special concern, it 24 also is becoming more frequent in our waters or it 25 appears to be so.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

71 1 Part of my problem is that I, like you, 2 didn't grow up an environmentalist, I became one 3 because of staring at the river. So, as you look at 4 these things, you see more and then once you see more, 5 you start to see less and that becomes a problem. We 6 are starting to see a lot less native species and a lot 7 more altered species and this is not good for us in the 8 long run, we are also seeing entrained in the system 9 the American Lobster, this is a commercial fishery also 10 and that deserves more attention, I believe, than in 11 the report.

12 I'm concerned about the method of approach 13 in monitoring, I would like to talk to Earth Tech a 14 little bit more about this, but I understand that a lot 15 of the monitoring happens post sweeping of the screens 16 and I think there is probably an impingement and an 17 entrainment factor that happens when we are not looking 18 and that there needs to be --. I at least need more 19 understanding of that and a complete listing of the 77 20 species that are impinged and the 66 species that are 21 entrained so that I can help evaluate what these 22 impacts are going to be.

23 On two other subjects, one was there was 24 an assessment of social justice, I believe, and by way 25 of that an assessment of our drinking water supplies, ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

72 I and there was a listing of some typical water 2 withdrawals, none of them exceeding two million gallons 3 a day, and I do want to point out that at the ten mile 4 limit is Silver Lake which supplies ten million gallons 5 a day to the Brockton water supply system in the City 6 of Brockton, which is a social justice community, and I 7 do not believe there has been monitoring of Silver 8 Lake, although I could be wrong, regarding emissions 9 and those kinds of long-term impacts.

10 And lastly, the alternatives section 11 discussed wind, it dismissed hydro power and although 12 I'm not an advocate for damming our rivers and 13 increasing hydropower, I would be curious to see an 14 alternatives analysis given to the tidal usage of the 15 Cape Cod Canal.

16 Thank you.

17 MR. CAMERON: Great, thank you. Thank you 18 for those comments, Pine.

19 And we are going to go to Ben Morgan next, 20 Ben?

21 MR. MORGAN: Good afternoon. I, like the 22 last speaker, am going to be talking about some marine 23 species, pretty much on the Winter Flounder is the only 24 one that I'm an expert on or I consider myself an 25 expert on. My name is Ben Morgan, I live in Chatham, I ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

73 1 used to be a fisherman, now I'm currently an owner of a 2 fish hatchery, the fish hatchery is for Winter 3 Flounder. Winter Flounder, as previous speakers have 4 talked about, have been deemed a moderate, I think I 5 have the right terminology, a moderate impact instead 6 of a small impact, meaning that there has been some 7 mortality associated with Pilgrim's activities.

8 So about eight years ago people from 9 Pilgrim and myself had worked on how to possibly make 10 that a small impact, meaning how do you deal with this 11 problem of killing Winter Flounder or impinging Winter 12 Flounder? Basically, since eight years ago, we've been 13 taking adult Winter Flounder that are natural wild 14 stocks and spawning them. And in that process, we've 15 basically reproduced 33 millimeter hatchery fish, which 16 would be the same as a wild fish, and placed it out 17 into our harbors very close to us right now, and done 18 studies to see how they survive and if it is possible 19 to replenish the stocks by use of hatcheries for 20 mitigation.

21 And over the past eight years, we have 22 compiled a whole bunch of data, nothing seems to be 23 negative, everything seems to be showing that, at a 24 larger scale, you could make this problem mitigated by 25 the use of hatcheries, making it a small impact that ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

174 1 Entergy has or even a no impact with Winter Flounder, I 2 know nothing about the other ones. Basically, I can 3 support that idea with the idea that aquaculture of 4 hatcheries have been used for decades with replacing 5 fish stocks, this has, we have seen this work with 6 shellfish in Massachusetts and all kinds of other 7 fisheries around the world.

8 The potential benefit to this being used 9 as a mitigation todl would be to the community, giving 10 jobs to the hatchery and also giving more fish for the 11 fishermen to catch. In conclusion, I basically believe 12 that Pilgrim could have no impact on the Winter 13 Flounder population, in my mind, by use of hatcheries 14 and that the benefits could really be to the 15 communities, to the fishermen and also for jobs. I 16 think that if we, if the number of hatchery released 17 fish was increased, that they wouldn't have a problem 18 to augment any potential problem associated with Winter 19 Flounder.

20 Thank you, have a good day.

21 MR. CAMERON: Thank you, Ben.

22 We are going to go to Heidi, Heidi Mayo, 23 and then to Arthur Gast. Heidi?

24 MS. MAYO: I would like to address the 25 issue of Pilgrim's impact on public health, I think the ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

75 1 commission has. a responsibility to look at 2 site-specific information on this issue. Thyroid 3 cancer and thyroid disease are clearly 4 radiation-linked, radioactive iodine released from 5 reactors is drawn into the thyroid, often resulting in 6 cancer and thyroid disease. Examples of widespread 7 increases in thyroid cancer has occurred in the 8 communities around Chernobyl, and Marshall Islands and 9 Hanford, another example of this type of increase 10 occurred right here near Pilgrim.

11 As a result of radiation releases in the 12 early and mid '70s and some really big ones in June of 13 1982, cases of thyroid cancer and leukemia in the 14 surrounding area were significantly elevated.

15 Recognizing the effect of Iodine 131 on the thyroid, 16 the NRC has implemented the Potassium Iodide Program.

17 I have a box in my cellar for my family but I don't 18 need it, since they weren't offering back in 1982 and 19 now I don't have a thyroid anymore. So the draft 20 statement that there have been no health effects here 21 is very incorrect.

22 In his report to the Southeastern 23 Massachusetts Health Study Review Committee in 1992, 24 Dr. Richard Clapp, former director of the Massachusetts 25 Cancer Registry, presented a graphical assessment ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

76 1 showing elevated cases of leukemia and thyroid cancer 2 in the towns closest to Pilgrim during the period of 3 '82 to '89, a second graph depicted the pattern of 4 thyroid cancer in the same set of towns, it shows a 5 peak in the years 1987 and 1988, the year I was 6 diagnosed. These patterns of cancer incidents are 7 consistent with the predicted health effects of the 8 radiation released in the early 1980s.

9 Additionally, the Massachusetts Cancer 10 Registry for the years 1998 through 2002 shows a 11 continuing increase of leukemia and thyroid cancer 12 around here. No one knows exactly how much radioactive 13 iodine has been and is being released from Pilgrim 14 because there is not adequate monitoring or reporting, 15 we don't know, I mean we do know that large releases 16 were measured in the '70s and '80s but today no one 17 knows what's coming out of the plant. If this plant is 18 relicensed as is, we will never know, the least we 19 should have is adequate real-time monitoring and 20 reporting displayed in all communities as part of the 21 public record.

22 Since the NRC recognizes the dangers of 23 Iodine 131 to our health and Pilgrim has indeed had a 24 negative impact on public health, this case should 25 require a site-specific review as part of the renewal ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

77 1 process.

2 Thanks.

3 MR. CAMERON: Thank you, Heidi.

4 Arthur?

5 MR. GAST: I had originally planned to 6 come here tonight, I have a position regarding the 7 station, I am a former member of the Nuclear Matters 8 Committee, I was among the group that volunteered two 9 years ago when the original committee all, for some 10 reason, all resigned and I didn't understand it. I 11 started reading the articles in the paper and letters 12 to the editor from some of the employees who are 13 presenting information here today and because I have a 14 nuclear, and engineering, and construction and 15 industrial background that goes back 50 years, I hate 16 to say because that doesn't make me young, I thought 17 that I ought to come down and offer my services to the 18 selectmen to give a little balance to this.

19 I figured that the replacement committee 20 would all be rabid anti-nuclear people and I was wrong, 21 the people who volunteered was probably the finest 22 group any small community in America could put 23 together. We had a consulting meteorologist, we had 24 two medical people, including the head of nuclear 25 medicine at the local hospital, we had two nuclear ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

78 1 engineers who had extensive background, including at 2 the plant, who are no longer at the plant, just a 3 tremendous number of people with very good experience.

4 Now I resigned a year ago, January 4, 5 2006, and I sent the board of selectmen my resignation 6 and I offered my own positions because they didn't get 7 into our reports, for reasons I don't want to get into 8 now. But here it is, I'll just read it exactly as I 9 sent it to the selectmen a year ago. I support 10 Entergy's intention to apply for an extension of-its 11 NRC operating license beyond the current 2012 12 expiration date. My reasons are, one, this is hardly a 13 new or dramatic change, it's the very same plant that's 14 been operating quietly, safely and efficiently, largely 15 out of view, having no massive cooling tower or 16 towering smokestack, which some people want to change, 17 for 33 years without major incident, the plant appears 18 to be well managed and maintained and protected.

19 The plant produces a significant portion 20 of our area power requirements that would otherwise 21 need to be imported at far greater cost and 22 environmental impact by fossil fuel-fired and 23 generating plants burning scarce and costly natural gas 24 or coal and oil with their negative environmental 25 impacts or importing scarce and expensive Canadian ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

79 1 hydro power.

2 Three, it produces no discharge of carbon 3 dioxide greenhouse gas, nitrous oxide orange plume like 4 the oil-fired plant down on the canal, sulfur oxide 5 precursors of acid rain or mercury emission to enter 6 the seafood chain as from coal-fired plants.

7 Radioactive discharge from vent stacks is 8 negligible to nonexistent, as measured by on-site 9 monitors meeting regulatory requirements. No shipment 10 and unloading of heavy fuel, oil or LNG impacts our 11 local area. While nothing involving terrorism is 100 12 percent predictable, the often cited vision of a 9/11 13 style aircraft attack is virtually precluded by the 14 design and layout of the critical plant elements and 15 surrounding structural supports. Similarly, the notion 16 of a frogman entering through the sea water inlet canal 17 and the massive centrifugal cooling water pumps without 18 being homogenized is ludicrous.

19 Five, no verifiable health impact has been 20 detected or certified to have resulted from the plant's 21 presence or operations.

22 I'll just add to this our committee had 23 Dr. Sid Nuremberg and the head of nuclear medicine at 24 the hospital, came in with boxes of supporting evidence 25 to say while there were spots of cancer in the town, ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

80 1 the type of cancer caused by nuclear radiation is 2 virtually nonpresent.

3 Number six, there is no free lunch to fill 4 our national and regional energy needs. I've been 5 involved with these alternative energy things that came 6 up and all through the last 30 years, massive federal 7 funding of alternative energy, coal gasification, shale 8 oil retorting, solar energy, wind power or fuel cells 9 have not brought significant power to our electrical 10 grid in over 30 years of technological effort.

11 Opposition to oil production off-shore and 12 on federal lands with no added refining capacity since 13 the mid '70s has left us dependent on insecure foreign 14 sources, and I feel that as much as anybody, I was 15 designing refineries back in the '70s and there were no 16 more to design. Failure to extend Entergy's operating 17 license leaves the town with problems, if not the 18 responsibility of removal of a derelict plant and 19 related transmission lines and equipment.

20 Questions regardingspent fuel, security 21 and the impact of revenue lost from jobs and support 22 revenue disappearing and disposition of the plant's 23 acreage to new uses, condos.

24 Much of the foregoing is based upon my 25 career-long experience with a multitude Of ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

81 1 technologically advanced industrial plants worldwide of 2 the size, complexity and age at least as great as the 3 Pilgrim station.

4 Respectfully submitted. That's all I have 5 to say.

6 MR. CAMERON: Thank you, Arthur.

7 Did I get everybody who wanted to speak?

8 I know I went through all the yellow cards, at this 9 point. We do have, it's unusual, but we do have the 10 luxury of having some more time, at this point, and I 11 don't think we are going to have that luxury tonight.

12 And because Pilgrim Watch is the major group concerned, 13 I'm going to ask Mary Lampert whether she could use ten 14 more minutes to go over your comments?

15 MS. LAMPERT: At least.

16 MR. CAMERON: Okay. Well, there will be 17 some, there will be some limit, but Mary Lampert and 18 then I want to ask the NRC staff to address a couple 19 points.

20 Mary Lampert?

21 MS. LAMPERT: Yes. I covered health, the 22 second area of interest.I would like to talk about is 23 the section postulated accidents and I stated two 24 factors that had to be factored in here, one was the 25 decision of the 9th Circuit Court in California and ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

82 1 also a proper reading of Section 5 of the GEIS. There 2 is new and significant information regarding postulated 3 accidents that was not considered. If considered, 4 nobody could conclude that the result would be small.

5 Important to consider, but it was neglected, was the 6 issue of security, there is site-specific information 7 that you have to consider.

8 First, vulnerability, what type of 9 protection do they have? There is no protection from 10 an air attack and despite the previous speaker, a 11 helicopter loaded with explosives could cause a severe 12 accident targeting spent fuel, targeting the switch 13 yard, targeting the control room, we don't have to go 14 on, it's an undisputed fact, they are not built to 15 resist an air attack. Security from the water is 16 virtually nonexistent, there are buoys which are 17 floating no trespassing signs, period, explosives can 18 be put up into the canal, that is why Homeland Security 19 recommended a grate for Millstone, which they turned 20 down.

21 Also, from a land attack, there is no 22 effective security, they are dependent upon outside 23 security arriving. However, the OSRI mock attacks have 24 demonstrated that a force can do the job, hit the 25 target sets in about three minutes, no way the state ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

83 1 police, etcetera, are going to get there in three 2 minutes. And neglected and what should be included is 3 the spent fuel pool as being a serious target and a 4 target of serious consequences, which Section 5 5 discusses that you focus on consequences. The new and 6 significant information is the National Academy of 7 Sciences spent fuel vulnerability study where they 8 identified reactors that have the spent fuel pool 9 located in the attic of the reactor, as Pilgrim, are 10 especially vulnerable to attack.

11 This has gone into the dangers of densely 12 packed pools, like Pilgrim, that are inside the main 13 reactor building, outside primary containment at the 14 top. In the Massachusetts Attorney General's motion to 15 intervene, there is an attachment by Dr. Gordon 16 Thompson, again new and significant information, that 17 discusses the danger of a highly, densely packed spent 18 fuel pool fire and what the consequences would be.

19 Again, to remove this from discussion of postulated 20 accidents is ludicrous.

21 Then, by not looking at these issues, you

.22 do not come up with then, an analysis of mitigation 23 which clearly, for spent fuel, as put forth in the 24 attorney general's motion, would be to analyze the 25 effect of having a lightly packed spent fuel pool and ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

84 1 putting the rest into secured dry-cask storage. Also, 2 an analysis should be required of the recommendations 3 in the National Academy's study such as what fact an 4 analysis would be the effect of, reconfiguration of the 5 pool? What realistically is the effect of the firehose 6 brigade, etcetera, so we can have a true analysis.

7 This moves into the severe accident 8 mitigation analysis which the draft decided was, the 9 analysis was sound which, again, if you really looked 10 at it, you could not come up with that conclusion and I 11 hope they will look at it more seriously again. The 12 licensee, the applicant, used the MACCS II code, they 13 are not restricted, by the way, of only using that 14 code, but what is important is what goes in, what are 15 the variables, the input data, because obviously that 16 would effect the analysis of what the consequences are 17 and the input data clearly is lacking.

18 For economic data, they put in the average 19 property value of farm and non-farm property, they did 20 not look at, for example, the added value of an ongoing 21 business enterprise, clearly a manufacturing plant is 22 valued at far more than the bricks and mortar that go 23 into it. In doing an analysis of alternative sources 24 of energy, there was an analysis of historic, you know, 25 value of the area and what the impact would be, but it ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

85 1 is not in the SAMA analysis for Pilgrim. Clearly 2 because this area has such great historic value, also

.3 clearly because of our beautiful seaside location, that 4 impacts and raises the values of our property. Tourism 5 is here because, not to come to these meetings, 6 obviously, but because of the history that's here, 7 because of the seaside location and that would be gone 8 and has to be factored in.

9 Not also considered properly were two 10 emergency planning variables, one, evacuation delay 11 time which is, in English, notification. They stated 12 that the public would be notified, at max, within six 13 hours, that makes assumptions which aren't true, that 14 sirens can be heard inside the houses, which they can 15 not be heard inside. What about an accident happening 16 at night? What about the fact that some sirens are not 17 going to operate? You cannot expect part of the fire 18 or police department and DPW to cover over 125 square 19 miles to notify people who are doing different things, 20 clearly this is just, that people will be ready to get 21 out of here in six hours is unrealistic.

22 Evacuation speed, again, a very 23 unrealistic time was put into the formula because it 24 had faulty emergency planning assumptions, they 25 overlooked, for example, the shadow evacuation. There ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

86 1 is an assumption that everybody outside whatever the 2 zone is is going to stay home and go about their 3 business, we know, from Three Mile Island, we know from 4 telephone surveys that were done after that people 5 outside the ten miles, people close to Boston will be 6 hitting the road, putting a cork, so to speak, in the 7 bottle, so that people here are not going to be able to 8 get out in the timely manner that was assumed.

9 We also know that there is nothing magic 10 about the ten miles, so the evacuation speed is how 11 long it's going to take to get from, let's say, my 12 house in Duxbury to just a little bit past the magic 13 ten miles in Marshfield. Again, we know from the 14 Sandia National Labs studies, we know from study, after 15 study, after study that there is nothing magic about 16 the ten miles so to assume the consequences end at that 17 point and we can call an evacuation successful once you 18 cross the ten miles is patently absurd.

19 And so because of the problems with the 20 severe accident mitigation analysis, what it does is 21 falsely minimize consequences so the cost of mitigation 22 seems not necessary, as described for the direct torus 23 vent system, and we could go through many other 24 mitigations that should be relooked at, but the key is 25 you have to do an honest analysis to begin with, which ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

87 1 was never done.

2 The next area was nonaccident view to 3 radioactive waste. Again, small impact, how can there 4 be a small impact? Because, number one, when you are 5 looking at spent fuel, it is assuming there is validity 6 to the fantasy of the Nuclear Waste Confidence Act, 7 that somehow Yucca is going to be there, or a 8 radioactive waste fairy is going to come or God knows 9 what they are assuming. But we know reality and one of 10 the NRC Commissioners was quoted in all the papers

.11 yesterday, Commissioner Merrifield, that he has no 12 confidence in Yucca and that we, essence, should start 13 again from zero. So, without looking at and providing 14 a plan of what people are going to do with this high 15 level waste, how can one say then that there is no 16 impact?

17 The same could go.for low level waste, low 18 level waste is a misnomer because it is everything but 19 the spent fuel and it can-have some highly toxic and 20 long-lived radio nucleates in it. Entergy is a major 21 producer of this stuff, the new and significant 22 information that was overlooked was that Barnwell, 23 South Carolina, which takes our waste, has said by 24 June, '08 the door is shut, also they say in the draft 25 that they have confidence that other sites will be ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

88 1 built. That's baloney, there has been millions of 2 industry money spent to try to find a site in Illinois, 3 etcetera, etcetera, etcetera, and no new sites have 4 been built because nobody wants it.

5 Massachusetts had the beginnings of a 6, search in the '90s and they stopped looking, so what is 7 going to happen to this? Again, if it is the plan, if 8 it is not realistically looked at and a plan is not put 9 forward, you cannot analyze it and say it's going to be 10 no problem. And so what we will have on our eroding 11 coastline on Cape Cod, subject to increasing storms 12 from global warming, etcetera, etcetera, etcetera, 13 turning into a high level and low level radioactive 14 waste dump until my kids are my age. This has to be 15 analyzed and faced honestly, okay?

16 The next issue that I would bring up--

17 MR. CAMERON: Mary, could you just make 18 this the last one?

19 MS. LAMPERT: Yeah. Is, if you are 20 talking about waste, is transportation. Again, the 21 transportation, God knows, let's pretend that there 22 will be a Yucca or there will be someplace to put the 23 stuff, then the issue is how is it going to get there?

24 The draft brightly says impact small, how do they know 25 it's going to be small? A, what's the plan? I've read ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

89 1 the plan in DOE and apparently 24 barges are going to 2 South Boston to be put on a railroad to go through like 3 Chicago, does anyone in their right mind think this is 4 going to happen when one of the casks per barge has 40 5 times the radiation in the Hiroshima bomb?

6 Do you think Cohasset, Hingham, Senator 7 Lynch, how about the people in South Boston? He will 8 be lynched, but the point being that these issues have 9 not been looked at seriously because of my general 10 comment in the beginning, that the draft is playing 11 games by pretending that rules, policy that the NRC has 12 are real and that because the plan is there and it's 13 going to happen that we don't have to worry about it so 14 it's significance is small. But we are not dealing 15 with, we shouldn't be dealing with fiction but, in 16 reality, when you read this, that's where this belongs.

17 Again, thank you, Chip.

18 MR. CAMERON: You're welcome, you're 19 welcome, Mary, we'll look forward to your written 20 comments also.

21 I just wanted to go to Bob Palla, who you 22 met earlier, just for one clarification on some perhaps 23 I think new information or whatever.

24 MR. PALLA: Well I just wanted to talk, 25 one of the speakers mentioned the direct torus vent and ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

90 1 the idea that this had zero benefit, and within the 2 environmental report that was initially submitted, 3 that's true. There was an error in the development of 4 the table and the development of that benefit estimate 5 which was subsequently corrected in response to RAIs 6 and the draft environmental impact statement does 7 discuss that in Appendix G to the precise, so you'll, 8 it does have fairly significant benefit now.

9 You also mentioned that the reduction in 10 source term was limited to a factor of two for a 11 filtered vent, you.have to realize that the sequences 12 that this particular design alternative was assumed to 13 address were ones that already passed through the 14 torus. Now if fissure parts are released from the 15 reactor and go through the torus into the torus vent, 16 they'll be scrubbed by the suppression pool and the 17 suppression pool has a very significant decontamination 18 factor. So the benefit of putting a filter in series 19 with the suppression pool wouldn't be as big as it 20 might seem, at least for that particular configuration, 21 so that's why the factor of two.

22 On its face, you might think it should be 23 bigger but if you consider that it already passes 24 through the suppression pool, in a way it's already 25 been filtered and a filtered vent would just further ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

91 1 filter it. It was two, yeah, but it's two after you've 2 already knocked. the fission product down by scrubbing 3 in the suppression pool.

4 MR. CAMERON: Yeah, it does and, Becky, 5 when you look at the revision in there, you can always, 6 you may still disagree and you can file additional 7 comments to the ones that we have already.

8 And I'm going to turn it over to Rani.

9 Oh, we have, Rich, do you want to -- ? Okay, one 10 further thing from Richard Emch, NRC staff.

11 MR. EMCH: Hi folks. My name is Rich 12 Emch, I work for the U.S. Nuclear Regulatory 13 Commission, my background is health physics.

14 I want to talk about three issues for just 15 a moment but before I get to the three issues, you 16 know, as we said at the beginning of this meeting, the 17 purpose of this meeting is for us to give you 18 information and for us to sit back and listen to you 19 tell us what your comments are, and so that's what this 20 meeting is really about. And in fact a number of you 21 have availed yourself of that opportunity and so that's 22 really what we are here for is to listen to what you 23 have to say. In other words, as opposed to, we are not 24 really here to debate you about what you said.

25 With that in mind, I just want to mention ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

92 1 three things, one of them has to do with the Southeast 2 Massachusetts Health Study, one has to do with the BEIR 3 7 report and then I want to talk a little bit about 4 what we know about releases from the Pilgrim Nuclear 5 Power Plant. Months ago I did meet with officials from 6 the Massachusetts Department of Public Health, 7 Dr. Knorr was not in the room, Suzanne Condon and other 8 members of her staff were and I didn't tape record the 9 meeting, but I did take notes and I guess, after 10 hearing the comments today and we did indeed meet with 11 Suzanne Condon and Dr. Knorr yesterday and, based on 12 all that, I guess I'm going to be forced to conclude 13 that I must have not quite gotten exactly what they 14 were telling me.

15 And guarding against that possibility 16 again yesterday, they have agreed to put their 17 thoughts, their beliefs, their conclusions on the 18 record., they are going to send us their comments and 19 we'll put those comments on the record so we can all 20 see what the Department of Public Health in 21 Massachusetts has to say on this.

22 That being said, I'm not going to attempt 23 to talk about what the Southeast Massachusetts Health 24 Study said right now because that's what they are going 25 to tell us, although I have seen the study, I have seen ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

93 1 a number of critiques of it and I personally do not 2 believe that any increases that the study may have 3 found are from radiation from the plant or radiation 4 exposure from the plant, but we'll be examining that.

5 The reason that I believe that is because 6 I have looked at their release records, I have looked 7 at the information about what comes out of the plant, 8 I've looked at their environmental monitoring reports, 9 I talked to the state about their environmental 10 monitoring data and the doses to people living near the 11 plant are really quite small. You heard earlier 12 discussions about NRC standards, okay, well, the EPA 13 standard, if you don't like our standards, the EPA 14 standard is 25 millirem per year total body to any 15 member of the public from the entire fuel cycle, 16 including Pilgrim plant.

17 If you read our document, you'll see that, 18 based on the effluent reports, based on the monitoring, 19 the doses from this plant to a member of the public are 20 very small compared to that, they are in the range of 21 one or two, maybe three millirem per year to the worst 22 case individual.

23 MS. MAYO: So you are saying there is a 24 healthy dose of radiation that you can get and it's 25 okay?

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

94 1 MR. CAMERON: Let him finish with his and 2 it will be on the record.

3 MR. EMCH: Let me switch to the BEIR 7 4 report for a moment and maybe this will help. The BEIR 5 reports, from the very beginning, BEIR 1 and up through 6 BEIR 7, it was reconfirmed in BEIR 7, have always said 7 that it is prudent to assume, it is prudent to operate 8 on the assumption that there is some health risk 9 associated with any amount of radiation exposure, 10 that's not new, that is the, that's been in the BEIRs 11 since the beginning, it is the basis of the NRC's 12 radiation standards and that's why we have the 13 standards, you have heard them referred to as the ALARA 14 standards.

15 So what I'm saying is that the levels at 16 Pilgrim are very small, they are well within those 17 standards, the NRC believes that those standards are 18 protective of public health. If you look in BEIR 7, I 19 don't want to get into a debate about what all the 20 numbers say but what BEIR 7 does, one of the things it 21 does talk about, it does talk about how the estimates 22 have changed, it makes comparisons to what other 23 studies have found. I believe the estimates were 24 slightly higher in BEIR 7, as opposed to BEIR 5, as was 25 pointed out earlier tonight, but there is comparison ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

95 1 with other documents as well.

2 Again, though, these are, if you read the 3 entire report, if you talk about the entire report, 4 BEIR defines low doses as 10,000 millirem, 10,000 5 millirem, not 5 or 10 but 10,000 and all of their 6 estimates of risk and of damage, health damage, are 7 based on doses that are really up in that range because 8 there is no evidence of damage at the doses at the 9 levels that we are talking about.

10 So I just wanted to mention those few 11 things, I want to thank you folks for giving us your 12 comments about this, we will look at them. I 13 appreciate you giving us this information and we'll all 14 look to see what the Department of Public Health says 15 in their comments.

16 Thank you.

17 MR. CAMERON: Okay, and two things, Heidi, 18 Rich is going to be here, or anybody, Rich is here, 19 when we close the meeting, he'll be glad to talk more 20 about these issues with you and I guess that when we do 21 hear from the Dr. Knorr and the health department, if 22 we could put those up on the Web site as part of the 23 comments so that people can see what Dr. Knorr and 24 Dr. Knorr's colleagues said about that, that would be 25 helpful.for everybody.

ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

96 1 And I want Rani to close the meeting up, 2 but I would just like to thank all of you for following 3 the guidelines and for all of your comments which were 4 very specific and I think very relevant, so thank you.

5 Rani? Rani Franovich, did you get 6 introduced or are you going to introduce yourself?

7 Rani Franovich is the chief of the environmental 8 section for license renewal and Rani and her staff are 9 the ones who do the environmental evaluations for all 10 license renewal applications and Rich, Rich Emch, and 11 Alicia both work for Rani Franovich and so, Rani?

12 MS. FRANOVICH: Thank you, Chip.

13 I just wanted to thank you all for coming, 14 I know everybody is very busy and this part of our 15 environmental review process where we seek comments 16 from members of the public and they participate, it's a 17 really important step of the process, and it's always a 18 pleasure to get out and meet with people in these 19 communities around the nuclear power plants, so thanks 20 again for coming. I did want to remind everyone that 21 if you wish to comment on the draft supplemental 22 environmental impact statement for Pilgrim, the public 23 comment period ends February 28th and Alicia's contact 24 information is in the handout.

25 And I also wanted to remind everyone that ADVANCE SERVICES Franklin, Massachusetts (508) 520-2076

97 1 we have public feedback forms for our public meetings.

2 If you have any ideas on how we can improve these 3 meetings, any suggestions on things we can do better, 4 things we maybe could do differently, please feel free 5 to share those suggestions with us, those feedback 6 forms can be left on the table outside where you 7 registered or, if you prefer, you can mail them into 8 us, postage is prepaid.

9 And with that, thanks again for coming.

10 (Whereupon, at 3:58 p.m., the hearing 11 was adjourned.)

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