ML102850369

G20100527/EDATS: OEDO-2010-0688 - Transcript Mary Lampert 2.206 Regarding Hydrogeologic Assessment at Pilgrim Nuclear Power Station, Pages 1-33

ML102850369
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Site:	Pilgrim
Issue date:	09/27/2010
From:	Richard Guzman Division of Operating Reactor Licensing
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Guzman R, NRR/DORL, 415-1030
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References
2.206, G20100527, OEDO-2010-0688, NRC-461, TAC ME4500
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Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

2.206 Petition RE Mary Lampert Docket Number: (n/a)

Location: (telephone conference)

Date: Monday, September 27, 2010 Work Order No.: NRC-461 Pages 1-33 Edited by Rich Guzman, NRC Petition Manager NEAL R. GROSS AND CO., INC.

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

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

1 1 UNITED STATES OF AMERICA 2 + + + + +

3 NUCLEAR REGULATORY COMMISSION 4 + + + + +

5 NUCLEAR REACTOR REGULATION 6 + + + + +

7 PETITION REVIEW BOARD 8 ---------------------------------

9 In the Matter of:  :

10 10 CFR 2.206 PETITION  :

11 OF MARY LAMPERT  :

12 WITH RESPECT TO  :

13 PILGRIM NUCLEAR POWER STATION  :

14 ---------------------------------

15 16 Monday, September 27, 2010 17 18 The above-entitled conference convened via 19 teleconference, pursuant to notice, at 2:00 p.m.

20 Eastern Standard Time.

21 BEFORE:

22 TED QUAY, Petition Review Board Chairman 23 RICH GUZMAN, Project Manager, NRR 24 CLIFF DOUTT, DLR 25 DAVE ALLEY, DCI 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 BEFORE (Continued):

2 BLAKE PURNELL, NRR 3 TANYA MENSAH, DPR 4 STEVE GARRY, NRR 5 SHELDON STUCHELL, DPR 6 LISA REGNER, DLR 7 MIKE CLARK, OGC 8 NRC HEADQUARTERS STAFF:

9 MATTHEW McCONNELL, Division of Engineering 10 NRC REGION 1 STAFF:

11 DON JACKSON, Division of Reactor Projects 12 JOHN WHITE, Division of Reactor Safety 13 ALSO PRESENT:

14 DAVID AHLFELD, Pilgrim Watch 15 PAUL BLANCH, Pilgrim Watch 16 REBECCA CHIN, Duxbury Nuclear Advisory Committee 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 P-R-O-C-E-E-D-I-N-G-S 2 (2:00 p.m.)

3 MR. GUZMAN: So let's go ahead and get 4 started. I will go ahead and kick off the conference 5 call. Good afternoon. My name is Rich Guzman. I am 6 the project manager for Pilgrim Nuclear Power Station 7 in the Office of Nuclear Reactor Regulation, or NRR.

8 I would like to thank everyone for 9 attending this meeting. The purpose of today's 10 conference call is to allow the petitioner, Mary 11 Lampert, to address the Petition Review Board, or we 12 may call it the PRB, regarding the supplemental 13 petition information dated August 13th, 2010 titled 14 "Pilgrim Watch 2.206 Petition Regarding Hydrogeologic 15 Assessment, Pilgrim NPS."

16 I am the petition manager for the 17 petition. The PRB Chairman is Ted Quay. The meeting 18 is being recorded by the NRC Operations Center and 19 will be transcribed by a court reporter. The 20 transcript will become a supplement to the petition 21 and will also be made publicly available.

22 I would like to open with introductions.

23 So please state your name, your position, and the 24 office you work for within the NRC. And I'll go ahead 25 and start.

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4 1 My name is Rick Guzman, project manager in 2 NRR.

3 CHAIRMAN QUAY: Ted Quay, NRR.

4 MR. DOUTT: Cliff Doutt, License Renewal, 5 NRC.

6 MR. ALLEY: Dave Alley, Division of 7 Component Integrity.

8 MR. PURNELL: Blake Purnell, NRR, project 9 --

10 THE REPORTER: This is the Court Reporter.

11 I'm having some technical issues. One moment, 12 please. Can anybody hear me?

13 MR. GUZMAN: We can hear you, yes.

14 MS. LAMPERT: Could the NRC 15 representatives speak up? After Ted, I didn't hear a 16 name.

17 MR. DOUTT: Cliff Doutt, NRC, Division of 18 License Renewal.

19 MR. ALLEY: Dave Alley, NRC, Division of 20 Component Integrity.

21 THE REPORTER: I am sorry. This is the 22 Court Reporter. I am not getting this. Hold on one 23 moment, please. Can anybody hear me?

24 MR. GUZMAN: Yes. We can hear you, yes.

25 THE REPORTER: I'm having some cable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 issues. Just one moment.

2 MR. BLANCH: Are they submerged?

3 (Laughter.)

4 CHAIRMAN QUAY: Now, Paul.

5 MS. LAMPERT: They're just not qualified, 6 Paul.

7 MR. BLANCH: Okay.

8 THE REPORTER: This is the Court Reporter.

9 So the last person I got was Ted Quay.

10 MR. DOUTT: Cliff Doutt, Division of 11 License Renewal.

12 MR. ALLEY: Dave Alley, Division of 13 Component Integrity.

14 MR. PURNELL: Blake Purnell, NRR project 15 manager.

16 MS. MENSAH: Tanya Mensah, Division of 17 Policy and Rulemaking.

18 MR. GARRY: Steve Garry, NRR, Division of 19 Inspections.

20 THE REPORTER: Sorry. It's me again, the 21 Court Reporter. One moment. Is anybody on?

22 MR. GUZMAN: Yes, we are on.

23 THE REPORTER: Thank you. Okay. Let's 24 try and go forward.

25 CHAIRMAN QUAY: What's the last one you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 got?

2 THE REPORTER: Say it again.

3 CHAIRMAN QUAY: What's the last name you 4 got?

5 THE REPORTER: Ted Quay.

6 CHAIRMAN QUAY: Okay. So let's start 7 again. Why don't you spell it for him?

8 MR. DOUTT: Cliff Doutt. The last name is 9 D-o-u-t-t. I'm with the Division of License Renewal.

10 MR. ALLEY: Dave Alley, Division of 11 Component Integrity.

12 MR. PURNELL: Blake Purnell, Division of 13 Policy and Rulemaking.

14 MS. MENSAH: Tanya Mensah, Division of 15 Policy and Rulemaking.

16 MR. GARRY: Steve Garry, NRR, Division of 17 Inspection and Regional Support.

18 MR. STUCHELL: Sheldon Stuchell, Division 19 of Policy and Rulemaking.

20 MS. REGNER: Lisa Regner, Division of 21 License Renewal, project manager for Pilgrim.

22 MR. CLARK: Mike Clark, Office of the 23 General Counsel.

24 MR. GUZMAN: And we have completed 25 introductions here at NRC. At this time are there any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 NRC participants from headquarters on the phone?

2 MR. McCONNELL: Yes. This is Matthew 3 McConnell. I am a senior electrical engineer in the 4 Division of Engineering.

5 THE REPORTER: This is the Court Reporter.

6 I'm going to need to dial back in. I think we may 7 need to restart the proceeding. I'm very sorry.

8 MR. GUZMAN: Okay.

9 (Pause.)

10 MR. GUZMAN: This is Rich Guzman. I guess 11 this is going to be our break here. We'll try to come 12 back in two minutes or so. And hopefully the Court 13 Reporter will be back.

14 I apologize for the delay this has caused 15 people, but we're going to mute talk from this end.

16 Feel free to do that on your side as well. And then 17 we'll just wait to hear from the Court Reporter.

18 (Whereupon, the foregoing matter went off 19 the record at 2:09 p.m. and went back on the record at 20 2:10 p.m.)

21 MR. GUZMAN: This is Rich Guzman again.

22 We're back. We would like to go ahead and proceed 23 with this conference call. So in the event that the 24 Court Reporter does come back on, we will just let him 25 begin his transcription. Yes.

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8 1 And, again, I earlier stated that the 2 meeting is being recorded by the NRC Operations 3 Center. And so we will still be able to get the 4 meeting minutes transcribed by a Court Reporter on the 5 back end. Okay? And, again, that transcript is going 6 to be part of the supplement and as part of the 7 overall petition package.

8 So I think where we left off is we can 9 still go around the room. So we left with Matt 10 McConnell. I wanted to check to see if there are any 11 NRC participants from the regional office on the 12 phone.

13 MR. JACKSON: Yes. Don Jackson, Division 14 of Reactor Projects; and John White, Division of 15 Reactor Safety.

16 MR. GUZMAN: Okay. Are there any 17 representatives from the licensee on the phone?

18 (No response.)

19 MR. GUZMAN: Okay. And, Ms. Lampert, 20 would you please undercook yourself for the record?

21 MS. LAMPERT: Yes. Mary Lampert, 22 Director, Pilgrim Watch.

23 MR. GUZMAN: Okay. Are there any others, 24 such as members of the public, on the phone?

25 MR. AHLFELD: This is David Ahlfeld. I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 an expert with Pilgrim Watch. And I am on the faculty 2 in the Department of Civil Engineering, University of 3 Massachusetts, Amherst.

4 MR. BLANCH: This is Paul Blanch. I'm an 5 expert also for Pilgrim Watch. My area of expertise 6 is electrical, buried piping, and overall nuclear 7 operations. I have more than 45 years nuclear 8 experience.

9 MR. GUZMAN: Okay.

10 MS. CHIN: This is Rebecca Chin. I 11 co-chair the Town of Duxbury Nuclear Advisory 12 Committee. And I joined Pilgrim Watch in signing the 13 petition.

14 MR. GUZMAN: Okay. Is that everyone? Is 15 everyone accounted for for this conference call?

16 (No response.)

17 MR. GUZMAN: Okay. At this time, before I 18 turn it over to Chairman Ted Quay, I would like to 19 emphasize that we each need to speak clearly and 20 loudly to make sure that the Court Reporter can 21 accurately transcribe this meeting. If you have 22 something that you would like to say, please first get 23 your name for the record.

24 And for those dialing into the meeting, 25 please remember to mute your phone to minimize any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 background noise or distractions. If you don't have a 2 "mute" button, this can be done by pressing the keys 3 *6. And then to unmute, press the *6 keys again.

4 Thank you. And at this time, I'll turn it 5 over to the PRB Chairman, Ted Quay.

6 CHAIRMAN QUAY: Good afternoon. Welcome 7 to this meeting regarding the 2.206 petition submitted 8 by Mary Lampert. I would like to first share some 9 background on our process.

10 Section 2.206 of title 10 of the Code of 11 Federal Regulations describes the petition process, 12 the primary mechanism for the public to request 13 enforcement action by the NRC in a public process.

14 This process permits anyone to petition 15 the NRC to take enforcement-type action related to NRC 16 licensees or licensed activates.

17 Depending on the results of its 18 evaluation, NRC could modify, suspend, or revoke an 19 NRC-issued license or take any other appropriate 20 enforcement action to resolve a problem.

21 The NRC staff guidance for the disposition 22 of 2.206 petition requests is in management directive 23 8.11, which is publicly available.

24 The purpose of today's meeting is to give 25 the petitioner an opportunity to provide any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 additional explanations or support for the information 2 submitted by letter dated August 13th, 2010 before the 3 PRB's initial consideration and recommendation.

4 This meeting is not a hearing. Nor is it 5 an opportunity for the petitioner to question or 6 examine the Petition Review Board on the merits of the 7 issues presented in the petition request.

8 No decision regarding the merits of this 9 petition will be made at his meeting. Following this 10 meeting, the Petition Review Board will conduct its 11 internal deliberations. The outcome of this internal 12 meeting will be discussed with the petitioner.

13 The Petition Review Board typically 14 consists of a chairman, usually a manager at the 15 Senior Executive Service level at the NRC and as a 16 petition manager and a Petition Review Board 17 coordinator. Other members of the Board are 18 determined by the NRC staff based on the content of 19 the information in the petition request.

20 At this time I would like to introduce the 21 Board. I am Ted Quay, the PRB Chairman. Rich Guzman 22 is the petition manager for the petition under 23 discussion today. Tanya Mensah is the office Petition 24 Review Board coordinator.

25 Other technical staff include Sheldon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 Stuchell from the Office of Nuclear Reactor 2 Regulations Licensing Process Branch; Matt McConnell 3 from the Office of Nuclear Reaction Regulation's 4 Electrical Engineering Branch; Steve Garry from the 5 Office of Nuclear Reaction Regulation's Health Physics 6 Branch; and Don Jackson and John White from NRC's 7 region 1. We also obtained advice from our General 8 Counsel, represented by Mike Clark.

9 As described in our process, the NRC staff 10 may ask clarifying questions in order to better 11 understand the petitioner's presentation and to reach 12 a reasoned decision whether to accept or reject the 13 petitioner's request for review under 2.206.

14 I would like to summarize the scope of the 15 petition under consideration and NRC activities to 16 date. On July 19th, 2010, as supplemented by letter 17 dated August 6, 2010, Ms. Lampert submitted to the NRC 18 a petition under 2.206 regarding Entergy's management 19 of non-environmentally qualified, inaccessible cables 20 and wiring at the Pilgrim station.

21 For this discussion, we may call the July 22 19th petition the cables petition. On August 9th, 23 2010, Ms. Lampert addressed the PRB by conference call 24 and provided additional explanation for the cables 25 petition as well as for the supplement dated August NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 6th, 2010 before the PRB's initial consideration and 2 recommendation. The PRB met on August 23rd to discuss 3 the cables petition and to make an additional 4 recommendation in accordance with management directive 5 8.11.

6 The PRB's initial recommendation was that 7 the petition met the criteria for review and will be 8 accepted for review under 10 CFR 2.206. Ms. Lampert 9 was informed of this determination on September 1st, 10 2010.

11 On September 3rd, Ms. Lampert requested 12 that additional information in her August 13, 2010 13 petition, which for this discussion we may call the 14 hydrogeo petition, be included as a formal supplement 15 to the cables petition.

16 In the hydrogeo petition, Ms. Lampert 17 requested that the NRC issue an order requiring 18 Entergy to immediately perform an updated 19 hydrogeologic analysis.

20 As the basis for this request, Ms. Lampert 21 states that the hydrogeo analysis is necessary for the 22 following reasons: one, to provide reasonable 23 assurance that leaks are not occurring so that the 24 piping and other buried components are able to perform 25 their intended safety function; for Entergy to be in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 compliance with the industry groundwater protection 2 initiative; and, three, to determine where underground 3 cable flooding may be occurring to assure that all 4 submerged cable splicers, connectors, and wiring are 5 able to perform their required functions.

6 As a reminder for the phone participants, 7 please identify yourself if you make any remarks as 8 this will help us in the preparation of the meeting 9 transcript that will be made publicly available.

10 Thank you. At this point I would like to 11 turn it over to Ms. Lampert. And you may go ahead.

12 MS. LAMPERT: Yes. Mary Lampert.

13 Essentially what this involves is provide reasonable 14 assurance to the public for the integrity of the 15 submerged components, which are important to safety.

16 In essence, we have two types that we're talking 17 about.

18 We're talking about pipes, tanks, what 19 have you carrying radioactive liquids. So we can be 20 assured that they are not surrounded in an environment 21 that is conducive to corrosion and also that when 22 they're leaking, we would know where to place 23 monitoring wells to assure it could be picked up 24 before it went off site in excess of regulations.

25 Also, the other part is obviously cable, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 submerged cable, slices connect to and the wiring to 2 assure that they, too, are not in an environment that 3 is conducive to corrosion surrounded in this case by 4 water.

5 There are two aspects to provide 6 assurance. One is to know where the buried components 7 are, number one, that are within focus; and, number 8 two, to understand the environment that they are 9 located in. And in this case, we're looking at 10 groundwater because we know that water is conducive to 11 corrosion and we also know that how the groundwater, 12 water is flowing will determine where any leaking 13 radioactive materials or other hazardous substances 14 may be going.

15 We, as you probably know, have a 16 contention that was heard at Pilgrim on buried 17 components carrying radioactive liquids. Due to this, 18 we gathered considerable information about Pilgrim's 19 environment, one being very conducive to corrosion, 20 and assessed what Pilgrim had as far as monitoring 21 wells.

22 Until the end of November of 07, they 23 didn't have any. And, more disturbing, when they 24 started to place monitoring wells on site, they were 25 relying upon a 1967 -- that's pre-operational --

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16 1 hydrogeo subsurface study.

2 Since this time, Mass. Department of 3 Public Health, Division of Environmental Assessment 4 has gotten very interested in the issue under 5 direction of Governor Deval Patrick's letter to 6 Commissioner Jaczko in February of this year. And 7 they have done on site visits, et cetera.

8 Disturbingly, they reported at the end of 9 June that there still had not been subsurface hydrogeo 10 studies. So that any monitoring wells that were put 11 in place subsequent to the original ones placed in 12 November '07 were not really based upon fact. And so, 13 despite that, despite the fact of an inadequate number 14 of wells and questionable placement of those wells, 15 not in conformance with standard design, there has 16 been a persistent finding of tritium in these wells, 17 usually not startling, only once beyond the 20,000 18 picocuries; however, persistently there, more than you 19 would expect.

20 And so the question is, is there more 21 migrating off site because there are not enough wells?

22 Because the wells that exist have not been placed 23 according to hydrogeo current analysis when since 24 1967, there has been significant construction on the 25 site, caving on the site, and just changes, or are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 these wells that are in place simply picking up the 2 tail of a tritium leak and the substantial portion is 3 going between them? The issue is unless we have the 4 proper studies, we will not know.

5 And, as important is that there be 6 transparency, that hydrogeo studies if they are done 7 properly, the industry should have no trouble in 8 making them public so experts, such as Dr. Ahlfeld, 9 can view them to have assurance they were done 10 properly.

11 It was most disturbing that when Mass.

12 Department of Public Health initially asked Entergy --

13 I believe it was in June. It could have been -- I 14 know it was in May -- to see the study, they refused 15 to show them. And then there was bickering back and 16 forth. And they were finally allowed to see those 17 studies.

18 But this secrecy, lack of transparency 19 certainly is not acceptable. It certainly is in 20 conflict to the wishes expressed by Chairman Jaczko, 21 by the NEI groundwater initiative, and we expect 22 better.

23 And I think at this point it would be 24 worthwhile to turn the conversation over to Dr.

25 Ahlfeld, who can explain what a proper hydrogeo study NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 should entail and why -- that is his area of expertise 2 -- and then turn it over to Paul Blanch on the 3 implications for safety of cables, splicers, 4 connectors, and the wiring.

5 MR. AHLFELD: Thank you, Mary. This is 6 David Ahlfeld, again University of Massachusetts. And 7 I neglected to mention that my expertise is in 8 groundwater studies and transport of contaminants in 9 the subsurface and groundwater.

10 I want to make it clear that PRB may not 11 be aware that the use of networks of monitoring wells 12 is quite standard in a wide variety of industries for 13 detection of problems, detections of possible leaks.

14 Everything from gas stations to large chemical 15 facilities use monitoring wells as a way to detect 16 leaks that might have occurred into the subsurface.

17 In order to design such a network; that 18 is, in order to decide where wells should go, both 19 vertically and horizontally in space, one needs to 20 understand where the water is going that might convey 21 contaminants from the site or from particular 22 facilities on the site. In order to understand the 23 flow behavior, one needs to understand the geology and 24 the hydrology, hence the hydrogeo aspect of this 25 request.

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19 1 As Ms. Lampert pointed out, the only data 2 that we are aware of on geology is from the 1967 3 study, which was a set of boring logs done as part of 4 the construction process. And it's obviously in 5 anticipation of putting a large building on this site.

6 What were the soil-bearing capacities under the site?

7 That was the question that was addressed by those 8 studies, some utility to the present questions but not 9 every question is going to be answered by that sort of 10 study.

11 A typical hydrogeologic assessment for 12 this sort of setting would include monitoring wells 13 and other excavations where we would determine the 14 nature of the subsurface stratigraphy, we would 15 determine the location of the water table; we would 16 conduct -- "we" being an industry specialist who might 17 do this -- hydraulic tests, where we measure by 18 various means the properties of the subsurface. And 19 from that, we can infer the rate of water movement; 20 the speed, the velocity at which water can move 21 through the subsurface; and then over a period of time 22 collection of data on water levels. That helps us to 23 infer flow direction.

24 I made some remarks along these lines in a 25 document dated 2008, which Ms. Lampert quotes from in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 the petition. And I just want to mention that since 2 that time, Entergy has put in a number of wells and 3 quite a few more this past summer as this tritium 4 problem has become more evident. And that's great.

5 It's good, useful information, although, to my 6 knowledge, we've seen nothing yet except the actual 7 data of the tritium measurements out of those wells.

8 We don't have anything on the geology that was 9 encountered, on the water levels that were 10 encountered, or other tests that may have been 11 performed.

12 Nevertheless, I just want to make the 13 point that those wells are what I would characterize 14 as a part of the plume-chasing effort. That is, they 15 appear to have a problem. Let's try to find out where 16 that tritium is and going and looking for it, which is 17 a good thing to do but is somewhat different than a 18 hydrogeologic assessment where we're really trying to 19 understand the behavior over the whole site.

20 Ms. Lampert mentioned the implications of 21 having a large industrial facility on this site, the 22 implications to the hydrology. It's particularly 23 important on a site of this size and it's because of 24 its location right on the coastline to have a very 25 detailed understanding of the hydrology because while NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 one might expect in a typical setting to have flow 2 directions generally from the uplands towards the sea, 3 here we have this large building, parking lot, et 4 cetera -- buildings, I should say, and parking lots 5 that are interfering with the normal infiltration of 6 water.

7 And we probably have complex storm 8 drainage patterns that are disposing of water in ways 9 that would disrupt the typical flow directions. So it 10 becomes a particularly complex hydrologic site and 11 particularly important to know in detail what is going 12 on with the flow, flow rates, and directions of 13 groundwater flow, again all of that information 14 feeding back to using the network as a means of 15 assuring that there are no leaks from the critical 16 facilities.

17 So thank you.

18 MS. LAMPERT: Paul?

19 MR. BLANCH: Hi. This is Paul Blanch. I 20 probably don't have a whole lot to add other than 21 obviously the importance of identifying we know that 22 there have been many tritium leaks from most of the 23 plants and in order to detect the tritium leak, you 24 want to go as close to the source as possible and try 25 to follow the path of the tritium and any other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 radioactive isotopes that have been released and there 2 is a flow to wherever they are going.

3 The need for hydrology study is necessary 4 to determine, well, help determine, the source of the 5 leak and the path of the leak as it is released to the 6 environment.

7 With respect to buried pipes, again, the 8 hydrology and obviously the chemical composition of 9 the salt water and what other contaminants, corrosive 10 material we may have in the groundwater is very 11 important to understanding the probability of buried 12 pipe corrosion.

13 This same licensee, who operates Indian 14 Point, had an event in February of 2009. And, 15 according to their own root cause analysis report at 16 Indian Point, it was a failure of the feedwater. it 17 was caused by groundwater. Had they had and if 18 Pilgrim had a proper study, they would be able to 19 identify those points and those buried pipes that have 20 a higher probability of being exposed to high moisture 21 or submergence in the ground.

22 And another issue that we're actively 23 involved with in working with the NRC is the cables.

24 We have discovered and the NRC has discovered that 25 many of the cables that pass underground contain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 within conduits -- obviously these conduits are not 2 watertight. Some of them are, in fact, totally dry 3 and have a very low probability of exposure to water, 4 but other conduits and manholes are exposed to water.

5 Without a full understanding of the water 6 levels and patterns -- and I'm not a hydrologist or a 7 geologist -- the probability of cable submergence has 8 also got to come into play. If we have manholes, 9 which are certainly not watertight, and the hydrology 10 study shows that these manholes are exposed and the 11 bottom of the manhole is below the normal water level 12 or high-tide level or whatever, obviously that 13 increases the probability.

14 So the hydrology study is needed for those 15 three identified points: the transport of radioactive 16 materials leaking from the plant; the potential for 17 corrosion of buried pipes; and, again, not only as the 18 water level, the flow direction, and so on, but the 19 chemical composition is very, very vital to 20 understanding the potential for corrosion, primarily 21 buried pipes, and what it does also, the 22 buried-cables.

23 And the third one is obviously the buried 24 cable issue, where it would be important from a safety 25 standpoint to know which cables and which pipes are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 subjected to this groundwater. And it's pretty much 2 all I have to say from an engineering standpoint, 3 again not being a hydrologist or anything, but I do 4 know that water flows downhill. And that is about the 5 extent of that.

6 MS. LAMPERT: Well, I wanted -- Mary 7 Lampert. Also, Paul and I had discussed the issue 8 that one cannot assume a conduit, let's say, for a 9 cable for electric wiring is perfectly horizontal.

10 And what would the implications of that be?

11 So you're looking at a manhole. And, and, 12 as they did at Pilgrim, you saw they were filled with 13 water. And then you have a corrective action to pump 14 them out, pump out the manhole with a certain 15 frequency. So, therefore, you would assume the 16 problem is taken care of.

17 However, if the conduit is at an angle, it 18 could well be, then, that there is puddling at the 19 more base end of the angle. And the issue then if you 20 know more about groundwater level, et cetera, you 21 would be able to predict that and see that simply 22 looking down a manhole here and there and pumping it 23 out, a situation of that type would not be effective.

24 We have focused on safety. Obviously with 25 non-qualified electric wiring, it is important that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 they not be in a submerged condition. And also it's 2 very important for safety that radioactive liquids are 3 not going off site.

4 But it is also important for long-term 5 safety and money. And I'm thinking about 6 decommissioning, that to have assurance that the site 7 isn't going to be far more contaminated and, 8 therefore, funds not available, monitoring wells would 9 certainly have their place here, wells that are 10 properly placed upon recent hydrogeo studies as the 11 NEI guidance, which Entergy signed onto, certainly 12 supports. And so I would throw in the decommissioning 13 aspect as another good reason for our petition.

14 MR. BLANCH: And let me -- again, this is 15 Paul Blanch -- throw in another example. Recently at 16 the Millstone Nuclear Power Plant in Connecticut, a 17 large cable vault, eight-foot by eight-foot by I'm not 18 sure, it was discovered to have very high levels of 19 water in it.

20 With a hydrological study, one would be 21 able to determine, which they have not determined yet, 22 whether that water was a result of leaking from the 23 plant or whether it was due to rainwater or some other 24 external ingress from the soil to the vault.

25 You know, I understand from my sources NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 that it is being looked at and being investigated, but 2 a study would also help identify the source of the 3 water. Is it water coming from a leaky tank or is it 4 coming from natural groundwater?

5 So there are many reasons why an updated 6 groundwater hydrology study needs to be conducted, 7 especially at Pilgrim and other plants, but we're only 8 talking about Pilgrim. I just provided that as 9 another example of the need for a complete up-to-date 10 study.

11 MR. AHLFELD: This is David Ahlfeld. I 12 can elaborate on that a little further that, for 13 example, at Pilgrim right now we have, let's see, over 14 the summer at one well, number 205, there were tritium 15 recordings of up to about 25,000 picocuries per liter 16 and at another well, 206, there were values of upwards 17 of 10,000. These 2 wells are about 200 feet apart.

18 They're both fairly close to various parts of the 19 building.

20 One might ask -- and, in fact, we are 21 asking, are these from the same source, the 200 feet 22 apart? Is that tritium from the same location or are 23 these two different leaks? If they're leaks from some 24 facility in the building or adjacent to the building, 25 what is the facility?

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27 1 These are obvious questions. And, yet, we 2 have inadequate information on the hydrogeology to do 3 anything but guess at this point. And a high-quality 4 hydrogeologic report made public would give us the 5 information, the data that we and Entergy could use to 6 answer those questions and similar questions that 7 might arise in the future.

8 MS. LAMPERT: And I also think -- Mary 9 Lampert. We expect because of global warming and we 10 are seeing increased storms at lots of shorelines, et 11 cetera. And so there are changes that occur, are 12 occurring on the coastline. Pilgrim is very close to 13 the shores. And the shores then are becoming closer 14 to Pilgrim.

15 So it is important to have your, in 16 essence, baseline information now so one can assess 17 changes that are happening, what changes are occurring 18 in the near future, track it so that you can be 19 prepared to take whatever steps, protective steps, are 20 necessary.

21 MR. BLANCH: This is Paul Blanch again.

22 Not only due to global warming, but we have natural 23 beach changes due to hurricanes that periodically hit 24 the Cape Cod area. And the shoreline is constantly 25 changing. And these studies need to be periodically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 updated, irrespective of global warming.

2 I'm sure the shoreline does change. We 3 have seen it in the past. And I'm sure it continues 4 to occur.

5 MS. LAMPERT: Right. Because we are 6 subject to nor'easters in the winter months. And 7 there are occasional hurricane effects in the late 8 summer and early fall.

9 Becky Chin, do you have any comments to 10 make?

11 MS. CHIN: What did you ask me? I was on 12 mute.

13 MS. LAMPERT: Yes. I didn't know whether 14 you had any comments to make.

15 MS. CHIN: Well, I served two terms as 16 chair of the Duxbury Board of Health. And we did deal 17 with monitoring laws on a regular basis and borings on 18 the coastline as Duxbury also sits in the Bay.

19 I am well aware of the differences in 20 sites, areas that are right next door to each other 21 that will have very different hydrological information 22 that will provide us.

23 But I also would like to make note that I 24 was a resident in this community in the 1960s, when 25 the original borings were made. And I'm well aware NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 that they did a lot of construction. And they removed 2 and filled when they built that station. And I'm very 3 suspect to what is there now as to what this 1967 4 report shows.

5 That's about the areas of my expertise.

6 Thank you.

7 MS. LAMPERT: Dave?

8 MR. AHLFELD: Yes. This is David Ahlfeld 9 again. That is a very good point, again, that the '67 10 report was pre-construction. So that was, let's say, 11 natural conditions. And a number of borings were 12 made. So that we have some idea of what is present 13 geologically at depth, but certainly the surface was 14 rearranged, the soil was rearranged, the soil was 15 removed, other soils brought in. So the geology has 16 changed as a result.

17 And, in addition, we have parking lots and 18 buildings and storm drainage rearranging the water 19 flow that goes into the subsurface. So, in effect, we 20 have no hydrogeologic study post-construction of the 21 facility.

22 MS. LAMPERT: Which says to me we are 23 flying blind and which is not acceptable in any shape 24 or form. And adding more and more wells, although 25 comforting, is to my mind more public relations than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 anything else if we have no assurance that there are 2 no rational, good, or scientific reasons for where 3 they are. And we deserve better than that. And I 4 think the NRC could certainly understand that.

5 Do any members of the Commission have 6 questions that you want to pursue at this time?

7 CHAIRMAN QUAY: Let me check here, Mary.

8 Anybody in headquarters have any questions for Ms.

9 Lampert? Matt McConnell, I know you are on the line.

10 Do you have any questions for Ms. Lampert?

11 MR. McCONNELL: I don't have any questions 12 at this time.

13 CHAIRMAN QUAY: Okay. John White and Don 14 Jackson are on the line from region 1. Do you have 15 any questions for Ms. Lampert?

16 MR. JACKSON: No questions from region 1.

17 CHAIRMAN QUAY: Okay. Before I conclude 18 the meeting --

19 MR. BLANCH: This is Paul Blanch. Can I 20 make one other statement? It was in a supplement.

21 There are NRC requirements, primarily general design 22 criteria 60 and 64. However, we are not sure of the 23 applicability of those to the Pilgrim station.

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31 1 accident or anticipated occurrences be monitored. And 2 if we do not have monitoring wells at the proper 3 location, I'm not sure how these particular 4 regulations can be met. And they're very clear in the 5 GDCs and whatever applicable GDCs are at Pilgrim.

6 MS. LAMPERT: And this is Mary Lampert.

7 In the petition, I also cited criterion 16. I won't 8 repeat it, but it seems very clear that the 9 requirement to assure that the cause of a condition is 10 determined and corrective action taken to preclude 11 repetition logically would lead to including a 12 hydrogeologic study if water leaked out from piping, 13 tanks, or water leaks in to submerged underground 14 cables.

15 MR. BLANCH: Yes. That is 10 CFR 50, 16 which is quality assurance. And that's criterion 16, 17 not appendix A but appendix B.

18 MS. LAMPERT: Great. Well, I hope we have 19 been helpful to the Commission so you can deal with 20 this in a way that will provide assurance to the 21 public. What we want to do is reduce risk and have a 22 feeling of confidence.

23 And obviously confidence has been eroded 24 as more and more leaks are occurring around the 25 country. Especially with reactors getting older, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 can expect more leaks. And, therefore, we need more 2 measures to reduce this risk in identifying problems 3 that at this point we can say are likely to occur as a 4 precautionary measure to protect public safety going 5 forward. And that is what we are looking for.

6 CHAIRMAN QUAY: Okay. Before I conclude 7 the meeting, members of the public may provide 8 comments regarding the petition and ask questions 9 about the 2.206 petition process. However, as stated 10 at the opening, the purpose of this meeting is not to 11 provide an opportunity for the petitioner or the 12 public to question to examine the Petition Review 13 Board regarding the merits of the petition request.

14 Are there any members of the public that 15 have any further comments?

16 (No response.)

17 CHAIRMAN QUAY: Okay. Not hearing any, 18 Ms. Lampert, thank you for taking the time to provide 19 the NRC staff with clarifying information on the 20 petition you have submitted.

21 Before we close, is the Court Reporter on 22 the line?

23 (No response.)

24 CHAIRMAN QUAY: Okay. With that, the 25 meeting is concluded. And we will be terminating the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 phone connection. Thank you very much.

2 (Whereupon, there was a chorus of "Thank 3 you.")

4 (Whereupon, the foregoing matter was 5 concluded at 2:49 p.m.)

6 7

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