ML102520207

Transcript for Evening Public Scoping Meeting ISO Seabrook LRA SEIS

ML102520207
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Site:	Seabrook
Issue date:	08/19/2010
From:	Office of Nuclear Reactor Regulation
To:
jeremy susco
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Download: ML102520207 (101)

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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Seabrook Station License Renewal Public Meeting: Evening Session Docket Number: (n/a)

Location: Hampton, New Hampshire Date: Thursday, August 19, 2010 Work Order No.: NRC-390 Pages 1-90 NEAL R. GROSS AND CO., INC.

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

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

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

4 PUBLIC MEETING 5 LICENSE RENEWAL AND ENVIRONMENTAL SCOPING PROCESS, 6 SEABROOK STATION LICENSE RENEWAL APPLICATION 7 + + + + +

8 Thursday, August 19, 2010 9 + + + + +

10 Galley Hatch Conference Center 11 Palladium Room 12 815 Lafayette Road 13 Hampton, New Hampshire 03842 14 7:00 p.m.

15 PARTICIPANTS:

16 Elva Bowden-Berry, Esq., NRC 17 Jeremy Susco, NRC Division of License Renewal 18 Richard Plasse, NRC Division of License Renewal 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 P-R-O-C-E-E-D-I-N-G-S 2 (7:00 p.m.)

3 ELVA BOWDEN BERRY: Good evening, 4 everyone. My name is Elva Bowden Berry. I'm an 5 attorney with the U.S. Nuclear Regulatory Commission, 6 or the NRC, as you'll hear it called today. And it's 7 my pleasure to co-facilitate this meeting with Lance 8 Rakovan. He's out -- well, he just appeared.

9 Standing there with his hand up. He's a 10 communications specialist with the NRC. We're going 11 do our best today to help make this meeting worthwhile 12 for everyone and we hope that you help us in that 13 process.

14 The purpose of this evening's meeting is 15 to discuss the License Renewal and Environmental 16 Scoping process for review of the license renewal 17 application for the renewal of the operating license 18 for Seabrook Station and to provide members of the 19 public with an opportunity to provide comments 20 regarding environmental issues that the NRC should 21 consider during its review.

22 The mission of the NRC is to regulate the 23 nation's use of byproduct, source and special nuclear 24 materials to ensure adequate protection of public 25 health and safety, to promote common defense and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 security and to protect the environment.

2 Now, a term you're going to hear quite a 3 bit this evening is scoping -- which means determining 4 the scope of the Environmental Review -- in this case 5 for the Seabrook Station site. Today's meeting is 6 just one way you can participate in this process and 7 you'll hear later on more ways that you can 8 participate.

9 The meeting this evening will essentially 10 have two parts. First, we'll hear from the presenters 11 from the NRC staff about the License Renewal and 12 Environmental Review process -- information we think 13 is important for you to understand when it comes to 14 Seabrook license renewal. There are couple of copies 15 of the presentation that were on the registration 16 table and if you need a copy I can ask Lance to -- if 17 you didn't pick it up, I can ask Lance to provide you 18 a copy of that.

19 We're going to try to keep the 20 presentations short this evening so we can get to the 21 real reason why we're here -- giving you all the 22 opportunity to comment. There were some yellow cards 23 that were on the registration tables -- some yellow 24 and blue cards -- and we ask that you fill them out.

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4 1 wanted to speak and I'll have the stack of cards and 2 be able to call upon them. The blue cards were if you 3 wanted to be on our mailing list. We've got a number 4 of yellow cards here and we'll just call people up.

5 If you haven't filled out a card and you 6 decide you want to comment, you can just get my 7 attention or get Lance's attention and we'll get a 8 yellow card to you and he'll provide it to me and 9 we'll add you to the list.

10 I also want to inform you that this 11 meeting is being transcribed, so I would ask you so 12 that we can fully capture everyone's comments to speak 13 clearly and when you come to the mic to give your name 14 and spell your name if necessary and tell us who 15 you're represented by. Also, in order for us to get a 16 clean copy, we ask that you keep sidebar conversations 17 to a minimum and low. The last thing I would like to 18 ask you to do in order to keep the transcript nice and 19 clean is to turn-off or silence your electronic 20 devices.

21 We're going to do our best to address any 22 questions that you have about license renewal or any 23 other NRC regulatory topics that you may want to 24 discuss. However, keep in mind that there's just a 25 few NRC staff here today and the right person may not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 be available to answer your question, but we'll 2 definitely try to provide you the best answer we can 3 and have someone get back to you, if necessary.

4 One other item I'm hoping you picked up 5 when you came in was our Public Meeting Feedback form.

6 You can fill this out here this evening and give it 7 to any NRC staff member or you can drop it in the mail 8 for sometime in the future and the postage is free.

9 Your opinion on how today's meeting went 10 will help us improve upon future meetings, so please 11 take a moment to let us know what you think and fill 12 out the card. The restrooms are located out these 13 doors to your right. The emergency exits are right 14 here to my left or back out the door that you entered 15 in.

16 Okay, let's go ahead and get started with 17 the meeting. I'd like to introduce some of the NRC 18 staff that is here. Bo Pham is the Branch Chief in 19 the Division of License Renewal. He's standing in the 20 back of the room. Jeremy Susco is the Environmental 21 Project Manager -- up here in front. Rick Plasse is 22 the Safety Project manager. Leslie Perkins is the 23 Project Manager and she's doing the slides for us this 24 evening. Jon Johnson is standing in the back of the 25 room. He's our Plant Resident Inspector. And Michael NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 -- Dreher is up in the front. I was afraid I was 2 going to mispronounce his name, so I had to pause.

3 He's in front. He's an attorney in our Office of the 4 General Counsel. And Scott Burnell is with our Office 5 of Public Affairs -- standing over by the door.

6 With that I'll turn things over to Rick 7 and Jeremy. I'll be back for the second portion.

8 Thanks.

9 RICHARD PLASSE: Thank you, Elva.

10 ELVA BOWDEN BERRY: Okay.

11 RICHARD PLASSE: Okay. Thank you for 12 everyone for coming to the meeting tonight. Can 13 everyone hear me? I have a habit of getting away from 14 this mic. We'll try to make sure I stay near it.

15 Okay, the first slide basically -- the Meeting 16 Purpose. We're going to provide an overview of our 17 process -- the Safety Review. That's my 18 responsibility as the Safety Project Manager from the 19 Division of License Renewal. And then the 20 Environmental Review -- Jeremy's the Environmental 21 Project Manager. Then, as Elva said -- we'll collect 22 your input on the scope of the Environmental Review.

23 Next slide.

24 NRC's Mission -- in exercising its 25 authority, the NRC's mission is threefold: one to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 ensure adequate protection of public health and 2 safety; two to promote the common defense and 3 security; and three to protect the environment. The 4 NRC accomplishes its mission through a combination of 5 regulatory programs and processes, such as:

6 conducting inspections, issuing enforcement actions, 7 assessing licensee's performance and evaluating 8 operating experience from nuclear plants across the 9 country.

10 One important element of our inspection 11 program is the Resident Inspector. Elva introduced 12 Jon Johnson in the back. The NRC has Resident 13 Inspectors at all operating nuclear plants. They live 14 in the local community. Their job's to carry out our 15 safety mission on a daily basis by ensuring that the 16 plants have acceptable safety performance and are in 17 compliance with their regulatory requirements. These 18 inspectors are considered the eyes and ears of the 19 NRC. Next slide.

20 The Seabrook current license expires in 21 2030 -- that's their 40-year of operation. The 22 license renewal application was received by our staff 23 on June 1st and if renewed -- it's a 20-year renewal -

24 - the license would expire in 2050. The period of 25 extended operation requested is from 2030 to 2050.

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8 1 Next slide, please.

2 This slide -- one of the areas that we've 3 got a lot of attention from the public since June is -

4 - well, why 20-years? Why not wait for 30-years or 5 later. So, we put in this slide to try to address 6 that. This is taken directly out of the Statements of 7 Consideration when the rule was issued coming up with 8 the 20-years. So the NRC determined that 20-years of 9 operational and regulatory experience provides an 10 applicant with substantial amounts of information and 11 would disclose any plant specific concerns with regard 12 to age related degradation. Also, another way to look 13 at it -- 20-years remaining on the operating license 14 would be reasonable considering the estimated time for 15 utilities to plan for replacement of retired plants.

16 If you read those Statements of Consideration, it goes 17 into a lot of detail that plants may want to come 18 earlier than 20-years and in fact several plants have 19 done that. To give you two examples -- Millstone Unit 20 3 applied at 18. Well, to apply less than 20 that 21 requires an exemption to the rule. So, they had to 22 put an exemption request in for that application to 23 come in at 18-years. Another plant up in the 24 Northeast, Nine Mile 2 applied at around 17-years.

25 Next slide, please.

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9 1 This is a simple flowchart of the license 2 renewal process. This diagram represents the License 3 Renewal Process. The top portion of the diagram shows 4 the Safety process. The bottom portion shows the 5 Environmental process. These two reviews are 6 conducted in parallel to evaluate two separate aspects 7 of the license renewal application.

8 During the Safety Review, the staff 9 conducts audits to evaluate the adequacy of the 10 technical information in the application. The NRC has 11 qualified inspectors perform on-site inspections to 12 verify the applicants Aging Management programs and 13 activities are implemented or have been planned for 14 implementation. Then the results of the Safety Review 15 are documented in a Safety Evaluation Report and also 16 in Inspection and Audit Reports. The Safety 17 Evaluation Report is forwarded to the Advisory 18 Committee on Reactor Safeguards, that's the ACRS --

19 that's the second block on the top row there -- who 20 will perform an independent review of the license 21 renewal application and the staff's resultant product 22 -- the Safety Evaluation Report. The ACRS is a group 23 of scientists and nuclear experts who serve as a 24 consulting body to the Commission. The ACRS reports 25 their findings and recommendations directly to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 Commission. They'll put a letter, which would be also 2 attached to the Final SER, with their recommendations 3 to the Commission.

4 The bottom -- the Environmental Review --

5 Jeremy will talk in some detail on that. There's 6 opportunity for hearing -- we'll get into the 7 deadlines for that. One of the questions came up in 8 the afternoon -- I'll give a little highlights of a 9 little bit of the hearing process -- if an intervener 10 decides to put in some contentions, they need to come 11 in by a certain date. We'll get into that later. The 12 Atomic Safety Licensing Board -- the ASLB -- will 13 review all the contentions whether to be admitted or 14 not. To give you an example -- I'm the Project 15 Manager for Prairie Island. There was 11-contentions 16 that were put in. The ASLB admitted seven of them.

17 Then they go through the process of -- if they 18 maintained being admitted to the end, there'll be a 19 hearing and all the parties will get their 20 opportunities at the hearing. The ALSB is three-21 judges who will review the contentions as they go 22 through that process. If and when those processes is 23 complete, the final NRC decision will be made based on 24 those three areas -- the Environment Review, the 25 Safety Review and whatever comes through the hearing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 process, if applicable. Next slide, please.

2 So, as far as the review schedule goes, 3 our schedule is on our NRC.gov web site -- the 4 Division of License Renewal. There is a specific page 5 for Seabrook and we'll get to that a little later on 6 in the slides. Without a hearing, it's a 22-month 7 schedule. If a hearing is granted, that would add 8 some time to go through the legal process. So, 9 without a hearing it's scheduled to be completed in 10 approximately April 2012 and that's if there is no 11 hearing. If there is a hearing, it will be some later 12 time. Typically, we say 30-months, but it could be 13 longer. Could be a little shorter. Next slide, 14 please.

15 This slide just shows the contents of a 16 license renewal application. The staff reviews this 17 information to verify that aging effects would be 18 effectively managed and environmental impacts are 19 characterized and disclosed. So, basically the 20 layout: Chapter 1 will be some general information 21 about the powerplant owner and operator; technical 22 information about the plant and how the applicant 23 proposes to manage aging -- Chapters 2, 3 and 4; 24 changes to the plant operating limits related to Aging 25 Management is applicable. Then there'll be an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 environmental report estimating the effects of 2 extending the license by 20-years. Next slide.

3 Going into a little more detail on the 10 4 CFR Part 54 Safety Review. The focus of our review is 5 on the aging effects to structures important to plant 6 safety. We talk about structures -- a lot of the 7 passive equipment: cabling, the buildings, the pipes.

8 The active components: the valves, the pumps --

9 they're tested in accordance with the plant's license 10 through tech spec requirements. So, they may test 11 things monthly/quarterly -- IST tests. So, those are 12 not part of the license renewal Safety Review. We 13 look at the passive equipment. The staff will review 14 to determine that the aging effects will be 15 effectively managed.

16 And how we do that -- we review the 17 application and the supporting documents on site. We 18 also do technical reviews in the office and then the 19 on-site audits we actually look at the site documents 20 for the Aging Management programs. We also look at 21 the operating experience from the plant for the 22 various systems. We go through the corrective action 23 system and look for where they've had issues in the 24 past and how they've dealt with them for the future to 25 mitigate them happening again. The on-site NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 inspections besides our audits -- the region will do 2 an on-site inspection and do plant walk-downs and 3 actually look at some of the Aging Management programs 4 -- some of them that exist, some of them that are new 5 -- and look at how they plan on implementing them.

6 Then all of that is fed into the Safety 7 Evaluation Report. The Safety Evaluation Report will 8 be issued at least a month or a month and a half 9 before the original ACRS meeting where we'll go over 10 any issues that are still on the table. It also gives 11 the ACRS to independently ask the staff and the 12 applicant any particular issues that they may have 13 identified in their review, in addition to 14 understanding what are the issues that we're still 15 dealing with the applicant for resolution.

16 After that meeting, there'll be a final 17 ACRS meeting, which all the issues that have been on 18 the table -- there'll be discussions on how they were 19 resolved. Then, as I said earlier, the independent 20 review by the Advisory Committee will result after 21 completion of their final meeting review. Next slide, 22 please.

23 License Renewal Safety Principles --

24 there's two guiding principles that form the basis of 25 NRC's approach in performing its Safety Review. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 first principle is that the current regulatory process 2 is adequate to ensure that the licensing basis of all 3 operating plants provides and maintains an acceptable 4 level of safety.

5 The second principle is that the current 6 plant specific licensing basis must be maintained 7 during the renewal term in the same manner and to the 8 same extent as during the original licensing term. To 9 ensure that the plants current licensing basis is 10 maintained during the extended period of operation, 11 the effects of aging must be understood and addressed.

12 The staff conducts a detailed review of new and 13 existing programs -- surveillance activities -- to 14 determine with reasonable assurance that the effects 15 of aging for certain structure systems and components 16 will be adequately managed and monitored. Next slide.

17 Here are some areas where we have ongoing 18 regulatory oversight. The principles that we just 19 talked about -- basically the NRC monitors and 20 provides regulatory oversight of activities in these 21 areas on an ongoing basis under the current operating 22 license. Therefore, we do not reevaluate them in 23 License Renewal because they're subject to ongoing NRC 24 inspections and oversight. This afternoon, a question 25 came up about Emergency Planning. If there's a real NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 issue in the Emergency Planning area that would be 2 dealt with in real time today. There're specialists 3 in the region, the Residents are the eyes and ears 4 here. If an issue comes up, it will be dealt with 5 appropriately as security or any current issue that 6 would come up that the plant would have to deal with.

7 Next slide.

8 Okay, I kind of mentioned the hearing 9 process earlier. The deadline is September 20th --

10 that's a 60-day period for the public to bring up any 11 issues based on review of the application. Again, the 12 ACRS meetings -- the tentative dates -- are September 13 2011 and February of 2012 for the final meeting. To 14 support that, we'll have the SER out before those 15 meetings. Our actual audits start in September and 16 October. With that, I'll turn it over to Jeremy.

17 JEREMY SUSCO: Thanks, Rick. My name is 18 Jeremy Susco. I'm the Environmental Project Manager 19 working on the Seabrook License Renewal application.

20 And I want to talk about the Environmental Review that 21 goes along with Seabrook's license submittal.

22 The first bullet point up there -- it's in 23 bold for a reason -- public input really drives what 24 we look at in this Environmental Review. That's why 25 we're here tonight -- to hear your input.

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16 1 We're going to take that input and our own 2 investigation and we're going to create an 3 Environmental Impact Statement. I'll go on in a 4 couple slides of what that means. It's really an 5 investigation and disclosure of the impacts of 20 more 6 years of operation -- the potential of 20 more years 7 of operation at Seabrook Station. The reason we do 8 that is for the staff to determine a recommendation to 9 energy planning decision-makers to determine if the 10 adverse environmental impacts of license renewal are 11 so great that 20 more years would be an unreasonable 12 thing to do. Next slide, please.

13 So, the Environmental Impact Statement is 14 the ultimate product of our Environmental Review.

15 We're going to rigorously investigate the 16 environmental impacts of license renewal, as well as 17 reasonable alternatives for the area here. The 18 Environmental Impact Statement -- it's really a tool 19 for other energy planning decision-makers to decide on 20 whether or not to continue the operation here at 21 Seabrook. Next slide, please.

22 So, as I said, this slide looks far better 23 on my desktop back at NRC headquarters, but some of 24 the things that go into our analysis -- we're going to 25 look at fish and wildlife, for example. We're going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 to look at historical and cultural resources, human 2 health -- and we're not just going to do it by 3 ourselves. We've actually already starting to engage 4 with several other state, federal and local agencies.

5 We've already been talking to the Massachusetts 6 Division of Fish and Wildlife, for example, the New 7 Hampshire Department of Environmental Protection and 8 the New Hampshire Natural Heritage Bureau. Next 9 slide, please.

10 Again, another slide that looked far 11 better on my computer. So, this is the process that 12 we use that goes into creating this Environmental 13 Impact Statement. I'm going to step away from the mic 14 and speak much louder here, so I can actually read 15 what's on here -- read to you, excuse me. So, the 16 first thing is the Notice of Intent and we published 17 that back in -- that was in July. That's our Notice 18 of Intent notifying the public that we are going to be 19 creating an Environmental Impact Statement.

20 The next thing that's hard to read there 21 it says -- Public scoping/meeting -- and that's what 22 we're here tonight. We're going to take those 23 comments, as well as the other investigation and 24 research that we do and we're going to create a Draft 25 Environmental Impact Statement. We're going to put NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 that out again to the public. We're going to publicly 2 issue the Draft Environmental Impact Statement --

3 we'll let you know when that's ready. And we're going 4 to come back. And we're probably going to meet in 5 this exact same room. It will be next June is our 6 anticipated date for that. We will again looking for 7 your comments on our Draft Environmental Impact 8 Statement. We're going to take those comments, 9 address them, roll them into the Final Environmental 10 Impact Statement, as appropriate. Then we'll issue 11 the Final Environmental Impact Statement.

12 Ultimately, that Environmental Impact 13 Statement will be one of the components that goes into 14 the final NRC decision. The bullet down here -- the 15 yellow blocks -- they're yellow on my desktop, 16 there're these blue boxes up here. Next slide, 17 please.

18 So, why are we here tonight -- Scoping 19 Meeting. As I said before, the purpose is for us --

20 for the NRC -- to hear your comments on what we should 21 look at in our Environmental Review and perhaps even 22 what we shouldn't. What that does is allows us to 23 better focus on the really important impacts and 24 alternatives for the Seabrook License Renewal 25 application. So this is not really a Q & A session, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 if you will. It's really a chance for us to hear your 2 comments. Next slide, please.

3 So, some of the examples of the feedback 4 and the input that we're looking for is -- so what's 5 unique about this community? What's unique about 6 Seabrook? What are some of the local environmental 7 issues that we really should be looking at and 8 examining? What socio-economic issues -- when it 9 comes to taxes and infrastructure and jobs -- are 10 important? As well, what other reasonable 11 alternatives are appropriate for this area? And we're 12 going to use this information to help us draft the 13 Environmental Impact Statement. Next slide, please.

14 So, you don't have to write any of this 15 down. It's all in your hand-out. But there's 16 essentially four ways to give us your comments. One's 17 the mail -- you see the address up there. You can 18 also fax. Regulations.gov is actually a federal 19 government-wide web site for any agency that does, for 20 example, a rulemaking proceeding or something like 21 this creation of a Environmental Impact Statement 22 where a lot of public comment is desired, then we use 23 regulations.gov. When you go to that web site -- if 24 you search under that docket ID, that would 25 essentially bring you to the web site where you can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 submit your comments related to this Environmental 2 Impact Statement. And, on the record today -- that's 3 why we have the transcriber here.

4 All these comments are due by September 5 21st to give us enough time to roll them all into the 6 Environmental Impact Statement. We will respond to 7 your comments. It's small down there, but if you want 8 to see our response, we put all the responses together 9 in a Scoping Summary Report. They also will be in an 10 Appendix to the Environmental Impact Statement. But 11 we do need either your mailing address or your e-mail 12 address to get those -- if you want to see our 13 response. An e-mail address is preferred and that's 14 one of the reasons why we have on your sign-in sheet 15 when you came in, there was a spot for an e-mail 16 address. Next slide, please.

17 We've talked about all this before, but I 18 just want to highlight it again -- the opportunities 19 for public involvement. We have -- the first bullet 20 here tonight -- the scoping meeting, as well as the 21 other ways that you can submit comments. The 22 opportunity for a hearing that, as I said, expires on 23 the 20th. The Draft Environmental Impact statement --

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21 1 Impact Statement. That exact same last slide on how 2 to submit comments, you'll see that exact same slide 3 again -- it'll be the same process. You are invited 4 down to Washington, DC -- those are open public 5 meetings that we have with the Advisory Committee on 6 Reactor Safeguards. And any other meetings that we 7 have as required as we go along in this process, you 8 will be invited to as well and we'll put out notice 9 for that. Next slide, please.

10 So, the Final Agency Decision. So, as 11 Rick talked about, the Safety-half of that review that 12 gets rolled into the Safety Evaluation Report. The 13 Environmental Impact Statement that I'm working on --

14 that will be another component that goes to the 15 Commission; the inspection findings and conclusions 16 from the inspections that we do in support of license 17 renewal; as well the recommendations from the Advisory 18 Committee on Reactor Safeguards -- an independent 19 body. That'll all go to the Commission for their 20 ultimate decision on whether or not to extend the 21 license for 20 more years. Next slide, please.

22 There are two physical locations -- well, 23 actually three. The third is in Washington, DC, so 24 not really that convenient if you live here. That's 25 in our headquarters. But, locally the Seabrook Public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 Library has -- there's a copy in the back. There's 2 two giant binders there. The Seabrook and the 3 Amesbury Library -- they both have copies of the 4 application. They will also receive a copy of the 5 Draft Environmental Impact Statement and the Final 6 Environmental Impact Statement. You can always go to 7 the Seabrook License Renewal web site where you can 8 download an electronic version of any of those 9 documents anytime you like. Next slide, please.

10 For keeping up-to-date, the NRC -- we 11 switched over from mail to a listserver. If you go 12 onto this web site, there's a map of the United States 13 and you can select Seabrook and put your e-mail 14 address down and you press `Subscribe` and you've just 15 subscribed to the Seabrook listserver. That will 16 subscribe you to all of the public documents that we 17 put out related to Seabrook -- which includes the 18 License Renewal documents. We can all sign you up if 19 you want. It's the only reason we have the e-mail 20 address on the sign-in sheet. Or you can sign-up 21 yourself. But, if you decide at any point that you 22 don't want to be part of the listserver, just like 23 most of the junk mail you get -- or junk e-mail you 24 get -- there's always a `click here to unsubscribe`.

25 Next slide, please. But ours isn't junk mail.

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23 1 Points of Contact -- there's Rick and mine 2 -- our e-mail address and our phone number and you can 3 contact us for any questions that you have on License 4 Renewal. So, that actually concludes the presentation 5 portion. I'll turn it back over to Elva. Thank you.

6 ELVA BOWDEN BERRY: Okay. I'm going to 7 open it up for questions on the presentation or any 8 clarifying questions about the process, if anyone has 9 one. I'll hand you the mic and you can ask your 10 question -- All right, if we don't -- oh, okay. I 11 didn't see you.

12 Please state your name and who you 13 represent, thank you.

14 MARY LAMBERT: Yes, Mary Lambert, Pilgrim 15 Watch, here for C-10. Are you going to put on the 16 Relicensing web site the rules process?

17 ATTORNEY MIKE DREHER: By rules process --

18 ELVA BOWDEN BERRY: Can you go to the mic, 19 please, Mike?

20 ATTORNEY MIKE DREHER: Absolutely.

21 ELVA BOWDEN BERRY: Thank you.

22 ATTORNEY MIKE DREHER: Sorry, Elva.

23 ELVA BOWDEN BERRY: All right.

24 ATTORNEY MIKE DREHER: Mike Dreher with 25 OGC. Just to clarify your question -- is that a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 question about the Rules of Procedure for the 2 Commission?

3 Those are available on the Commission's 4 web site, as well as some other government web sites.

5 They're all found under 10 CFR -- Title 10 of the 6 Code of Federal Regulations.

7 MARY LAMBERT: I meant with Relicensing --

8 ELVA BOWDEN BERRY: Mary, can you wait 9 until I bring the mic to you? Thanks.

10 ATTORNEY MIKE DREHER: Oh.

11 MARY LAMBERT: I'm aware of that, but for 12 the ease of people who are just beginning this 13 process, if you put it where you have Relicensing --

14 and you have various things -- a menu -- to go to.

15 You should have it there. So people will know where 16 to go immediately and won't have to figure this out a 17 year later.

18 ATTORNEY MIKE DREHER: Okay.

19 MARY LAMBERT: If they're doing it pro se.

20 JEREMY SUSCO: That's a good comment.

21 We'll take that feedback back. But, there is a 22 specific License Renewal web site not just related to 23 Seabrook, for anybody that's going through license 24 renewal. It does describe a lot of that exact same 25 process more generically. But, it's a good comment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 and we'll take that for feedback.

2 ELVA BOWDEN BERRY: Okay. State your 3 name, please.

4 PAUL GUNTER: Thank you. My name's Paul 5 Gunter. I'm with Beyond Nuclear and I was a resident 6 of New Hampshire for about 23-years. You know, one 7 thing your presentation -- in establishing the scope 8 for the License Renewal process -- one thing that you 9 left off that I'd like you to explain in a little bit 10 more detail is why 20-years more generating nuclear 11 waste in the absence of a management plan for nuclear 12 waste -- why that isn't in the scope of this 13 proceeding? So, if you could explain to this crowd --

14 I mean, this crowd I think would be particularly 15 interested because the Department of Energy was here 16 in 1985 and 1986 looking to take seven New Hampshire 17 towns by eminent domain so that they could put this 18 nuclear waste in the granite -- in the granite state.

19 It became a very politically hot topic here.

20 But, in this whole scheme of things that 21 you're now bringing up before us, one of the more 22 conspicuous items that's absent from this 23 Environmental Review particularly -- is what are you 24 going to do with the nuclear waste and how are you 25 handling that? And in addressing it, I'd like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 something in a little bit more detail because the 2 Yucca Mountain solution has failed.

3 JEREMY SUSCO: Well, I can answer that in 4 two parts. One we'll start with Seabrook. So, Yucca 5 Mountain is a very important issue to the Nuclear 6 Regulatory Commission. I know that in particular, 7 Seabrook's important to everybody that's here. So, 8 the Commission has done the analysis to determine that 9 at least until 2080 waste can safely be stored at 10 Seabrook. So that's at least until 2080. We've done 11 that analysis that the environmental impacts will be 12 small for storing waste here at Seabrook until 2080.

13 Like I said, the waste here at Seabrook's 14 important to the Commission, but the way that the 15 Commission's really looking at it is as a whole --

16 what does the industry do whether or not Yucca 17 Mountain gets licensed or not. So, that's really the 18 question that's before the Commission. It's important 19 what happens at Seabrook, but it's also important what 20 happens to all 104 reactors that we regulate. License 21 Renewal is not the right vehicle for that --

22 essentially, that to happen. The Commission is 23 looking at that -- whether what happens at Yucca 24 Mountain or not. It's not going to get looked at as 25 part of License Renewal. It will get looked at for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 all 104 reactors whether or not they only operate for 2 40-years, they operate for 60-years or even less than 3 that.

4 LEE ROBERTS: My name is Lee Roberts. I'm 5 a resident of Portsmouth with my husband. I'm also 6 with Seacoast Peace Response. I have great concerns 7 about nuclear of any sort and I would like to ask a 8 question and that is what is the ACRS group exactly 9 that goes -- that reviews these scoping answers that 10 you come up with? Is this a bipartisan group? Is 11 this one that is connected to you guys or is it 12 completely separate and impartial? That's one 13 question. I had another one too, I hope I can 14 remember it. Thank you.

15 RICHARD PLASSE: Yes. The Advisory 16 Committee of Reactors Safeguards -- they're 17 independent to the NRC. They are impartial. They're 18 appointed. They typically consist of some senior 19 people who may have worked in the industry. They're 20 also scientists. Maybe they've worked at some of the 21 labs. But they independently look at our product --

22 the Safety Evaluation that we put together -- and 23 they also will look at the application and they'll 24 probe issues/questions, whatever, from their review 25 that they have questions on they will probe and --

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28 1 LEE ROBERTS: I have a follow-up.

2 ELVA BOWDEN BERRY: Hold on. Let me --

3 RICHARD PLASSE: Okay.

4 ELVA BOWDEN BERRY: -- hand you the mic so 5 you can speak.

6 LEE ROBERTS: My follow-up is -- who 7 chooses these people? Thank you.

8 RICHARD PLASSE: I believe -- I really 9 don't know, to be honest with you. It may be the 10 Commission, but they work for the Commission.

11 SCOTT BURNELL: I'm Scott Burnell with the 12 Public Affairs office at the NRC. The ACRS takes 13 nominations for its membership and they do have to 14 have a very high level of technical qualifications.

15 It is the Commission -- the five politically appointed 16 members that run the agency -- who are responsible for 17 determining which of these people are qualified to 18 serve on the ACRS.

19 LEE ROBERTS: Which agency, sir, I'm 20 sorry?

21 SCOTT BURNELL: The five --

22 LEE ROBERTS: You said the people in the 23 agency. Which agency?

24 ELVA BOWDEN BERRY: Hold on. I'm going to 25 give you the microphone.

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29 1 LEE ROBERTS: Sorry -- I think you said 2 something about that there are five people of the 3 agency that choose these other people. Is that 4 correct?

5 SCOTT BURNELL: Yes. The five --

6 LEE ROBERTS: What agency chooses them?

7 SCOTT BURNELL: The five commissioners who 8 are appointed to be in charge of the Nuclear 9 Regulatory Commission.

10 LEE ROBERTS: So those are commissioners 11 in --

12 SCOTT BURNELL: The NRC.

13 LEE ROBERTS: -- New Hampshire?

14 SCOTT BURNELL: No, in the NRC.

15 LEE ROBERTS: Oh. So -- well, it's all an 16 inside deal then isn't it?

17 SCOTT BURNELL: No. These are outside 18 experts.

19 LEE ROBERTS: That sure sounds it. I 20 mean, you have to admit that does sound a bit 21 incestuous?

22 PAUL BLANCH: This is Paul Blanch. I 23 obviously worked with the NRC and with the Commission 24 and with the ACRS and I can say what Scott said that 25 these are technically very, very well-qualified people NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 and I know many of them. Independence is not there.

2 If you saw one of the flowcharts here -- Final 3 Decision on License Renewal lies with the Commission.

4 Who appoints the ACRS? It's the Commission -- the 5 same people. And they want to renew their tenure on 6 the ACRS. Many of them stay there as long as 10 or 7 more years. So, as far as an independent body to 8 review license renewal applications or any other 9 technical issue -- while they're very well-qualified, 10 they are still not independent. They are all, 11 essentially -- every one of them is appointed by the 12 Commission. The same Commission that runs and 13 everyone from the NRC works for. So, as far as 14 independence -- it is not there.

15 ELVA BOWDEN BERRY: Go ahead, Scott.

16 SCOTT BURNELL: The members of the ACRS 17 are chosen for their technical qualifications not for 18 their ability to provide a particular point of view.

19 One way to view the ACRS is sort of as a doctoral 20 dissertation committee. They're going to take a very 21 hard look at the staff's information. They're going 22 to ask probing questions and those questions are based 23 on the technical knowledge that members of the ACRS 24 have. It is not an effort to rubberstamp the staff's 25 work. If you ever have a chance to sit in on an ACRS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 1 meeting, you will see just how quickly the ACRS 2 members dig into the staff's work to make sure that it 3 is technically valid.

4 ELVA BOWDEN BERRY: Okay. We're going to 5 move --

6 KURT EHRENBERG: I have a question.

7 ELVA BOWDEN BERRY: -- does anyone have 8 any questions?

9 KURT EHRENBERG: I should be loud enough 10 that I don't need the microphone.

11 ELVA BOWDEN BERRY: No, you have to have 12 the mic because we're transcribing the meeting. Is 13 your question about the presentation or -- I don't 14 want to move to the --

15 KURT EHRENBERG: It's a follow-up to his 16 presentation.

17 ELVA BOWDEN BERRY: I want to move on and 18 I want to make sure we're getting everything in the 19 right order, so there's a second part of the meeting -

20 -

21 KURT EHRENBERG: I have a question I'd 22 like to ask.

23 ELVA BOWDEN BERRY: Okay. Please state 24 your name clearly and speak directly into the mic.

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32 1 New Hampshire. How many licenses or license renewals 2 have been denied by the NRC up to this point? What's 3 the number?

4 ELVA BOWDEN BERRY: Okay. What was --

5 SCOTT BURNELL: To this point, every 6 applicant has provided enough information for the NRC 7 to make a technically sound judgment that license 8 renewal is called for.

9 KURT EHRENBERG: Not just license renewal, 10 but original licenses that have been denied?

11 SCOTT BURNELL: I beg your pardon. We do 12 need to have the microphone, so you can be in the 13 transcript.

14 KURT EHRENBERG: My question also included 15 the original licensing, not just renewals. How many 16 have been denied?

17 SCOTT BURNELL: There have been several 18 cases where applicants chose not to complete the 19 licensing process.

20 KURT EHRENBERG: That was not the 21 question.

22 SCOTT BURNELL: It answers your question, 23 sir. There have been several opportunities for --

24 KURT EHRENBERG: How many? How many?

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33 1 --

2 KURT EHRENBERG: How many? Two, three?

3 ELVA BOWDEN BERRY: One minute.

4 SCOTT BURNELL: Dozens.

5 ELVA BOWDEN BERRY: Excuse me.

6 SCOTT BURNELL: Dozens of plants did not 7 complete the licensing process.

8 KURT EHRENBERG: But how many have been 9 denied was the question.

10 ELVA BOWDEN BERRY: Excuse me. We're 11 going to move on.

12 LEE ROBERTS: No, no. [indiscernible]

13 ELVA BOWDEN BERRY: Like I said --

14 DR. PETER SOMSSICH: We want an answer to 15 that question.

16 ELVA BOWDEN BERRY: Like I said --

17 DR. PETER SOMSSICH: You know the answer.

18 LEE ROBERTS: No, we need answers. We're 19 not going to move on.

20 ELVA BOWDEN BERRY: Excuse me.

21 KURT EHRENBERG: We want an answer to the 22 question.

23 DR. PETER SOMSSICH: You want public input 24 [indiscernible] --

25 ELVA BOWDEN BERRY: Excuse me, everyone.

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34 1 Let's stay under control.

2 DR. PETER SOMSSICH: We're under control.

3 ELVA BOWDEN BERRY: The transcriber --

4 hold on a minute. The transcriber cannot hear all of 5 your responses and your comments and your questions 6 unless we speak one at a time and clearly. He may not 7 be the right person to answer your question, as I 8 indicated at the beginning. So, if that question is 9 still out there, we'll get an answer to that question.

10 It may not be right now. So, we're going to move on 11 to the next phase of the meeting.

12 LEE ROBERTS: So, does this mean there's 13 no comments anymore?

14 KURT EHRENBERG: So you're not going to 15 answer that question?

16 ELVA BOWDEN BERRY: No, I didn't say `no 17 comments`.

18 KURT EHRENBERG: Yes, you did.

19 ELVA BOWDEN BERRY: No --

20 KURT EHRENBERG: You're not answering.

21 ELVA BOWDEN BERRY: Sir, excuse me. Like 22 I said, you have to speak into the mic in order for 23 the transcriber to get it.

24 KURT EHRENBERG: Then bring the microphone 25 here. I'll speak into it.

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35 1 ELVA BOWDEN BERRY: I didn't say we're not 2 going answer the question. As I said in the 3 beginning, we're going to --

4 DR. PETER SOMSSICH: Give him the 5 microphone.

6 ELVA BOWDEN BERRY: I will give him the 7 microphone, but as I said, he may not be the right 8 person to answer the question. So the question could 9 get answered later.

10 LEE ROBERTS: That isn't a very hard 11 question.

12 KURT EHRENBERG: You can [indiscernible] -

13 -

14 LEE ROBERTS: It's a simple number.

15 SCOTT BURNELL: In every instance where an 16 applicant has completed the licensing process for an 17 original license, they have provided us enough 18 information for us to come to the technical decision 19 that they are due a license. Sir, your answer is --

20 none have been denied because all of the applicants 21 have met the regulations.

22 DR. PETER SOMSSICH: Thank you.

23 ELVA BOWDEN BERRY: Okay, this will be the 24 last question on the presentations and then we'll move 25 on and get your comments. Do you want -- okay. Is it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 on the presentation? Well, okay. We're going to open 2 it up for the second phase of the meeting where we're 3 going to get your comments. I have a stack of yellow 4 cards and I'm going to go through the cards and we're 5 going to make sure we get the people's comments who 6 weren't here earlier today and had the opportunity to 7 speak, so we can give everyone an opportunity to get 8 on the record. So, the first card I have is Maggie 9 Hassan of New Hampshire.

10 STATE SENATOR MAGGIE HASSAN: Thank you.

11 Do you want me to just --

12 ELVA BOWDEN BERRY: Speak directly in --

13 STATE SENATOR MAGGIE HASSAN: Yeah, just 14 directly into it? Okay. Good evening. My name is 15 Maggie Hassan. I am a New Hampshire State Senator and 16 I'm honored and privileged to represent District 23, 17 which includes Seabrook in the State Senate. I wanted 18 to speak for a couple purposes. My constituents have 19 varying opinions on nuclear power. They have varying 20 opinions on whether they believe the plant should have 21 been licensed in the first place. To the degree 22 people are talking to me about it, they have varying 23 opinions about relicensure.

24 I wanted to speak about a couple of 25 things. First and foremost that when constituents NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 have called me with questions about the operation and 2 safety of the plant or when I've had those questions 3 or when my colleagues in the Legislature have had them 4 -- we have been impressed or I have been impressed 5 with the openness of the Seabrook plant in inviting us 6 to the plant, giving us information, answering our 7 questions, touring us through the plant. They have 8 been cordial, responsive, specific. So, I give them 9 kudos for that. I think they have been a good 10 participant, at least since the time I have been in 11 the State Senate, which is the last six years.

12 The plant is obviously an enormously 13 important employer and taxpayer and community 14 participant to many of the communities in our area.

15 So, from that perspective, I'm looking at the scope of 16 the NRC's Environmental Review -- they are an 17 incredibly important presence here and there are many, 18 many of my constituents who are very happy that they 19 are here. On the flip side of that -- this is an 20 enormously fragile ecosystem. There's just 18-miles 21 of the New Hampshire shoreline that we hold very, very 22 dear. There is the Great Bay Estuary that is really 23 at a tipping point in terms of its environmental 24 quality. So, we would ask that the NRC and its 25 environmental and safety experts listen with great NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 care to the concerns that will be raised throughout 2 this process about the impact on this extraordinary 3 part of our state and our country.

4 I think more than anything else, people in 5 my district want to know that the plant is well-run 6 and that the people there hold as dear as my 7 constituents do, this part of our state and our 8 country. They also want to know that the NRC is doing 9 its job. I can't stress enough as an elected official 10 how concerned people are right now that government is 11 capable of doing what the citizens trust it to do. I 12 can't think of a more important example of a nuclear 13 power plant sitting so close-by to so many levels of 14 our ecosystem and human life.

15 So, with that I just thank you all for 16 being here. I look forward in any way I can assist 17 from the state government point of view in making sure 18 that this process is as complete and informative for 19 all of you as I can. I would be happy to do that and 20 I know my other legislatures and the Governor's office 21 feel the same way. To my constituents who are in the 22 room -- I hope that you will bring forward not only to 23 the NRC, but again if the Senate or the House or the 24 Governor's office can be helpful in facilitating 25 conversation, as that may need to happen, I look NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 forward to doing that as well. More than anything, we 2 just want to know that we are keeping New Hampshire 3 beautiful and safe. Thank you.

4 ELVA BOWDEN BERRY: Thank you. I have a 5 stack of cards here. So, the first three names I have 6 are Chris Nord, Paul Bamberger and -- excuse me if I 7 pronounce your name wrong -- Dr. Peter Somssich. I'm 8 going to ask you to go to the podium and state your 9 name clearly and if you need to spell it, spell it for 10 the record and tell us what organizations you're with.

11 So, with that -- Chris Nord.

12 CHRIS NORD: Thank you. Is it possible to 13 go back to the early slide in this slideshow that 14 talked about why 20-years? Why we're looking at this 15 20-years ahead? Can I see that?

16 Yeah -- well, as I was looking -- I've 17 been trying to think of an analogy -- sorry. I'll 18 start by giving you my name. My name is Chris Nord, 19 N-O-R-D. I live in Newton, New Hampshire. So, I'm 20 inside the 10-mile radius for Seabrook and I've 21 basically lived in this region since 1981. So, I've 22 lived entirely within the 10-mile radius since 1981.

23 I asked for this back because I've been trying to 24 think of an analogy -- hopefully a humorous one. I 25 don't know how humorous it is, but I've had a lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 old cars in my life. I can tell you that the 2 difference between a 10-year-old car and a 15-year-old 3 car -- there is not a linear relationship. If you 4 look at new, 10-years, 15 -- problems arise in that 5 next five-years. Problems would arise in the next 10-6 years that are not in a linear relationship to the 7 previous 20-years. So, for us to pretend that this is 8 some how an accurate look at what the plant's 9 performance will be in 40-years is disingenuous. That 10 must be stated. Onto my comments.

11 Three areas -- high-level waste, 12 evacuation planning, and tritium and embrittlement --

13 those two together.

14 So, for high-level waste -- as was asked 15 earlier -- where is the high-level waste to go? We 16 have 20-times the radioactive activity of the 17 Chernobyl accident's release contained here at 18 Seabrook in far less than adequate a storage system --

19 far less than adequate. It's going to be here for the 20 foreseeable future, which might mean many decades 21 because Yucca Mountain is not going to open. That was 22 the plan -- the plan was no good.

23 Why isn't going off to some permanent 24 disposal site on Indian land somewhere a good idea?

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41 1 everyone feels like we would feel -- the state of New 2 Hampshire it turned out didn't want the DOE to take 3 over seven towns by eminent domain. Nobody's going to 4 want that. So, all over the United States, plants 5 just like ours -- the people in those regions live in 6 sacrifice zones where the radioactive inventory, 20-7 times the size of Chernobyl's release, is left right 8 on site. That's what we're left with. Why is our 9 homegrown dumpsite not adequate? First of all, it's 10 here in Seabrook, which is one of the fastest-growing 11 summer populations in the -- well, fastest-growing 12 populations in the United States. One of the most 13 populous beach populations in the United States during 14 the summertime. So, we have a lot of people moving 15 in.

16 Secondly, an above ground closely housed 17 unhardened dry-cask bunker constitutes one of the most 18 vulnerable terrorist targets on U.S. soil. Which is a 19 huge worry. Should be a huge worry for our elected 20 officials, but we don't seem to be getting traction in 21 the state of New Hampshire with that issue. Yet, 22 Florida Power and Light's bunker was rushed to 23 construction years after whole agencies of the federal 24 government were established to protect the American 25 public from fiascos such as this. We have a roadmap NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 for better technologies than the new home system that 2 was implemented quickly by Florida Power and Light 3 just as Florida Power and Light is quickly trying to 4 implement this relicensing process. The process 5 should be slowed down so that the proper technologies 6 could be used to adequately protect the public.

7 The disposition of Seabrook's reactors 8 high-level waste should be included within the scope 9 of any license extension process. Sufficient time 10 should be devoted to finding the state-of-the-art 11 storage technologies for all U.S. commercial and 12 military high-level waste now because so-called 13 temporary storage must suffice to keep us safe for 14 perhaps many decades. I want to point out for the 15 technicians in this room that believe that this is not 16 within the scope of these upcoming hearings -- the 17 Generic Environmental Impact Statement, Section 5, 18 allows for review of high-level waste storage in terms 19 of consequence. In this case, it could be the 20 consequence of a severe accident, for instance, due to 21 terrorist attack. Which is just how the issue was 22 raised in California and the Ninth Circuit Court of 23 Appeals upheld the contentions of those that brought 24 that litigation to court. So, this is a totally 25 permissible arena for high-level waste to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 1 considered within the scope. That's one.

2 Evacuation Planning -- it's the second 3 one. I'm going to just take a drink.

4 ELVA BOWDEN BERRY: I'm going to ask you 5 to wrap it up. I have a handful of cards. We want to 6 get everyone's comments in.

7 CHRIS NORD: Yup 8 ELVA BOWDEN BERRY: I don't want to cut 9 you short, but --

10 CHRIS NORD: Well, you know, I bet 11 everybody that's here would like you to stay so that 12 their comments can be made. I'll do this really 13 quickly.

14 Evacuation Planning was a snow job here 15 20-years ago. The reason -- the reason that so many 16 rules got changed -- the field got changed 20-years 17 ago -- was because the evacuation plans 20-years ago 18 were not sufficient. So, someone came up here earlier 19 and said we're dealing with it in the moment -- in the 20 here and now. Well, in the here and now, these 21 evacuation plans are unworkable. They've been 22 unworkable for 20-years. Take a look. The Federal 23 Emergency Management Agency 20-years ago -- the Region 24 One director, Ed Thomas, said it's no good. And 25 because of that, we have to stop the license. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 Reagan administration pulled him, installed a new 2 Region One director and they rubber-stamped the 3 evacuation plans. That's not an adequate evacuation 4 plan. We have twice as many people living in the 5 seacoast region than we did 20-years ago. So, how is 6 that going to work? That has to be included within 7 the scope of relicensing.

8 Tritium -- tritium and pipe degradation.

9 Almost 20-years ago, again, in a different part of New 10 England -- the Deerfield River Valley of western 11 Massachusetts -- exposure to tritium was linked to 12 Down syndrome -- statistical significance -- for Down 13 syndrome and assorted other health maladies. The 14 study was signed-off on by the State of Massachusetts.

15 The study is available. If you needed the study and 16 don't have it, I can give you the study because I've 17 got it at home. So, tritium is a known evil quantity 18 and the linkage was made 20-years ago to the Yankee 19 Atomic reactor in Rowe, Massachusetts. Yankee Atomic 20 was closed in the early 90s due to concerns around 21 pipe embrittlement. Is it possible that pipe 22 embrittlement caused the release of all of that 23 tritium?

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45 1 get a chance to speak tonight, but if we've got pipes 2 that are inaccessible and can't be monitored, then 3 that certainly falls within the scope of the upcoming 4 license extension hearings. That stuff has to be 5 looked at because we cannot have tritium flowing into 6 the groundwater and coming right across the marsh into 7 Hampton. I mean, Winnacunnet Road is right on the 8 marsh. I have friends that live on Winnacunnet Road.

9 So, is it true that Florida Power and Light is 10 digging test wells because they're trying to track 11 tritium? I mean, these are hugely important concerns 12 and should be included within the scope of these 13 hearings. Thank you for your audience.

14 ELVA BOWDEN BERRY: Thank you for your 15 comment. We're going to ask everyone to keep your 16 comments to no more than 10-minutes because I have 17 really a stack of cards and I want to let everybody 18 have the opportunity to speak and I just want to 19 remind you that we're talking about environmental 20 scoping. Paul Bamberger is the next speaker. If you 21 could just go to the podium and state your name 22 clearly and where you're from. Thank you.

23 PAUL BAMBERGER: Is this all right? I'm 24 not familiar with this -- I just have one comment 25 stated three ways. Tonight I saw something happen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 twice already that's bothered me for years in this.

2 Recently I read a quote from an official 3 from Seabrook who said -- We can handle the nuclear 4 waste for the next 20-years and beyond. Well, 5 beyond's faith -- there's no information. When people 6 answer serious questions with words like `beyond` it 7 really scares me. And he also did it tonight to me.

8 He said -- Well, it's safe until the year 2080. But 9 it's been decades now that you had a chance to prepare 10 for 2081 and I heard you say nothing about 2081. It's 11 another non-answer to a very serious question. And 12 you get this all the time. You have to be very 13 careful with the way they use the language.

14 And that other person -- all he had to say 15 to you was the number. And it's easier to engage you 16 in some foolishness rather than say -- None have been 17 refused. It would've taken two seconds and it 18 would've been over. But this circular non-answer has 19 been going on ever since Seabrook has been going on.

20 And not just in the Seabrook issue, but generally.

21 But there's three tonight -- two tonight and one in 22 the newspaper. Beyond `beyond` -- what does that tell 23 me? Nothing. 1980 -- what does that tell me about my 24 children in 1981? Nothing. It really scares me.

25 Thank you.

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47 1 ELVA BOWDEN BERRY: Mr. Bamberger, could 2 you tell us where you're from?

3 PAUL BAMBERGER: New Hampshire.

4 ELVA BOWDEN BERRY: Now, Dr. Peter --

5 Somssich?

6 DR. PETER SOMSSICH: Yup, thank you.

7 ELVA BOWDEN BERRY: Please spell your name 8 for the record and tell us what organization you're 9 with.

10 DR. PETER SOMSSICH: Yes. It's Peter 11 Somssich, S-O-M-S-S-I-C-H. I'm a resident of 12 Portsmouth and since my memory's not so good, I've 13 written up my comments that I've given to your clerk 14 over there.

15 I'm attending the session to express my 16 opposition to the 20-year extension of Seabrook 17 Nuclear Power Plant's current operating license. Not 18 only do I reside within the official evacuation zone 19 of this power plant should an emergency be declared, 20 but I'm also a trained atomic scientist with both 21 training and professional work relevant to nuclear 22 power safety. I have a Ph.D. from the University of 23 Heidelberg, Germany in physics and have worked 24 professionally as a research scientist on nuclear 25 energy related issues. Currently, I am employed as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 analytical scientist in a non-nuclear related field 2 and do not have a personal vested or financial 3 interest to protect with regard to Seabrook Nuclear 4 Power Plant.

5 In addition to my initial training in 6 various professional positions, I have continued to be 7 a permanent student of energy related issues, nuclear 8 power issues, alternative energy issues surrounding 9 nuclear proliferation for the past 40-years. My 10 objections to the 20-year extension of the operating 11 license can be grouped into four categories. Number 1 12 -- What's the hurry? 2 -- Financial liability. 3 --

13 Safety and security concerns. 4 -- Materials for 14 nuclear weapons proliferation. Also I'd like to 15 propose an alternative suggestion to any operating 16 license extension should one be considered.

17 What is the hurry? I am sure that I'm not 18 the only member of the public who was surprised to see 19 a request for an extension of a license that is still 20 valid for another 20-years. To apply for an extension 21 5-years before the expiration date would not surprise 22 me, but 20-years -- that is strange. The only logical 23 explanation I can think of is that this is an 24 insurance policy against possible problems with the 25 plant in the next 40-years and/or that the owners of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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49 1 the plant see what all outside experts already know, 2 that in fact nuclear power is too expensive and will 3 not be able to compete with other sources of power in 4 the future, even as recently as the next 10-years.

5 Financial viability. What independent 6 energy experts except those who are employed by 7 nuclear power industry already agree is that nuclear 8 power is currently not able to compete with other 9 energy options on a free-market basis, were it not for 10 the federal government, which is providing it with 11 large low-risk loans and insurance protection against 12 liability. This type of power is already the most 13 expensive kind available and will not improve 14 significantly in the near term future, if at all.

15 That is why private investors have rejected even very 16 generous options to build a new power plant over the 17 last 30-years. This energy is not renewable and 18 therefore not sustainable and all indications are that 19 at least in the United States and most of the rest of 20 the world, it will stay that way.

21 Safety and Security Concerns. The safety 22 record of many U.S. nuclear power plants over the past 23 30-years has been better than was expected by the 24 critics. However, the strong scrutiny brought to bear 25 by both environmental groups and government agencies NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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50 1 must be credited with most of this outcome, since 2 otherwise profits would have been the main focus. It 3 is, however, also important to point out that 4 Seabrook's initial license was conditioned by the 5 requirement that a final destination point for its 6 nuclear waste be determined prior to initial 7 operation. This never happened because the federal 8 government never provided such a location. If 9 Seabrook had told the public at the time that the 10 final destination of the waste was in fact on the 11 property of Seabrook Station, perhaps that license 12 would never have been issued. Regardless of the 13 disposal issue, this power plant must be considered a 14 possible terrorist target and the level of security 15 needed for adequate protection must be very high.

16 However, undisclosed visits by government teams 17 testing such security at nuclear power plants have 18 concluded that the current security measures are not 19 enough. This means that there will be added 20 additional expense for all nuclear power plants in the 21 near future.

22 Materials for Nuclear Weapons 23 Proliferation. Not only is a nuclear power plant a 24 potential terrorist threat, but it must also be viewed 25 as a target for groups attempting to procure nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 1 fuel materials to enable the production of nuclear 2 weapons. With increasing storage of nuclear waste on-3 site, as is the current case currently at most nuclear 4 sites, without the full protection against theft that 5 a centralized facility could provide, the attraction 6 for both terrorists and nuclear weapons brokers will 7 only increase.

8 Finally, an alternative suggestion. As 9 many of you present today already know, most European 10 countries have already turned their backs on nuclear 11 power for many of the reasons already mentioned above.

12 However, in Germany, which is phasing out its nuclear 13 energy industry, a number of environmental groups have 14 supported the extension of nuclear power licenses, if 15 they are safe enough to operate, in exchange for the 16 payment into a renewable energy fund of some portion 17 of the windfall profits that operators and owners will 18 reap as the result of a license extension. Since most 19 nuclear power plants are built for a specific number 20 of years in operation and have been budgeted and paid 21 for during these years, a license extension provides 22 extra operating years and extra revenue. It would 23 seem only a fair deal to ask for some of that windfall 24 profit, say 50%, to be invested in a fund for truly 25 renewable energy projects should an extension be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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52 1 granted.

2 I appreciate this opportunity to submit 3 this statement. Thank you.

4 ELVA BOWDEN BERRY: Thank you. The next 5 three speakers will be Debbie Grinnell, Cathy Wolff 6 and William Harris.

7 Please state your name and your 8 affiliation when you get to the mic. Thank you.

9 DEBBIE GRINNELL: I'm Debbie Grinnell and 10 I'm with the C-10 Research and Education Foundation 11 and serve both as a staff person doing research and 12 also as a founding Board member. When Seabrook 13 submitted their application 20-years in advance of 14 their license expiration -- which would bring the 15 plant to 2050 -- we were very aware that the parts and 16 the underlining underpinning construction foundation 17 of this plant has parts from the 1970s. We looked 18 over some recent inspection reports to look at how 19 NextEra was managing their component systems and 20 parts. What was immediately brought to our attention 21 after the last refueling and inspection report was 22 that NextEra was cited for submerged electrical cables 23 in two-vaults that were underwater -- underwater, 24 which is saline, which is highly corrosive.

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53 1 inaccessible electric cables that are in water that is 2 known to cause early failure. So, we thought what's 3 the most responsible thing to do here? We looked into 4 some recent research. We looked into what the NRC was 5 doing and the NRC had actually contracted/sponsored a 6 study with the Brookhaven National Labs and asked them 7 to assess the early cable failures before the 40-year 8 license expiration and to analyze which cables, how 9 many -- but they didn't actually do that because they 10 were a research institute and what the generic letter 11 requested was not to find/locate on the schematics 12 every buried/submerged underground pipe and electrical 13 cable -- it was to identify the ones that are already 14 failed.

15 So, what we needed to know up-front was 16 how many have failed, where are they, what 17 manufacturers are most responsible. What were the 18 years of the greatest failure? 1970s. We still don't 19 know what manufacturer manufactured and what usage 20 NextEra has. What we do know is that none of the 21 cables that are submerged at Seabrook were qualified 22 for submersion. They are not marine cables. They are 23 not qualified, which means that the plant is now 24 operating outside of its design basis and in violation 25 of Federal Regs. The NRC has done a very minor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 citation. There is no fine. They were asked to pump 2 out the water and come up with a long-term solution.

3 What hasn't happened in this industry -- we haven't 4 identified where all the cables are. How many there 5 are? How many are submerged? And what condition 6 they're in.

7 The reason we can't do that is because the 8 only way this can be done is visually. The Brookhaven 9 National report reported that the surveillance 10 testing, the in-service program, the maintenance rule, 11 the aging program -- does not identify the cables 12 before failure. It is impossible to do. So, short of 13 instituting -- which has not been done by the NRC -- a 14 responsible program that is based on a regulation that 15 would enforce the industry to actually: know where all 16 the cables are, the condition of them. We cannot go 17 forward with this.

18 We have, as a result of this knowledge, 19 asked Paul Blanch, who is a energy consultant. He's 20 an electrical engineer. He worked for Northeast 21 Utilities and many other utilities. His expertise is 22 in instrument and control engineering. I would like 23 to defer to him at this point because we are not 24 technically based and that's why we asked an energy 25 consultant to give us advice on this situation. Paul NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 -- can I ask you to speak for me?

2 ELVA BOWDEN BERRY: Debbie, we're not 3 going to take people out of order. Paul spoke earlier 4 today, so we want to get to the speakers who haven't 5 been here.

6 AUDIENCE MEMBER: I'd like to hear him.

7 CATHY WOLFF: I'm next in line. Can I 8 yield to him if I'm next in line? Is that 9 appropriate?

10 ELVA BOWDEN BERRY: Well, we won't --

11 PAUL BLANCH: I'm a neutral party here.

12 Anyway --

13 ELVA BOWDEN BERRY: We want to give 14 everybody a chance --

15 PAUL BLANCH: My name is Paul Blanch, B-L-16 A-N-C-H. Thank you, Debbie. And I just want to give 17 another example of NRC enforcement, or as some people 18 talk about, NRC enfarcement. I was tempted to get up 19 here and light up a cigarette and that would endanger 20 the health and safety of the people in this meeting 21 room and I'm sure the police officer in the back would 22 come up here, drag me out, maybe impose a fine and 23 maybe even put me in jail or something like that. I'm 24 sure the local police would enforce the regulations.

25 Now, let's contrast that to Seabrook. Seabrook is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1 violating the regulations. They're emitting hazardous 2 substances -- tritium and possibly other -- which are 3 unmonitored that are a health hazard.

4 So, what does the NRC Office of 5 Enforcement do? They clearly identify it's a 6 violation of regulations. Same as with cable. And 7 they issue them a severe non-cited Green violation, 8 but they don't make them put out the cigarette. That 9 thing is still leaking tritium. In the same respect, 10 we have the cable issues, which Mrs. Grinnell just 11 talked about, and we have cables that are clearly 12 outside their capability to operate per 10 CFR 50 13 Appendix B, Criterion I think is 15 and 16, 14 Design/Control/Inspection. The NRC knowingly allows 15 these plants to operate outside of its design basis.

16 We know that the cables must be qualified in order to 17 determine whether that plant could safely operate and 18 its emergency equipment will properly operate.

19 I've just got so many examples -- the 20 buried pipe inspection program -- we just found out 21 and again working with the General Accountability 22 Office that the buried pipe inspection program only 23 covers steel pipes. Well, they've got every other 24 kind of material pipes and then the real shocking 25 thing that came up in the GAO investigation is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 buried pipe inspection program only looks for external 2 corrosion. So Seabrook says -- We'll look at external 3 corrosion when the thing fails -- is basically what 4 they say. It just goes on and on and on. We need a 5 regulatory agency that will actually look at their 6 regulations, enforce their regulations and if the 7 plant is not compliant with those regulations change 8 the regulations or shut down the plant until the plant 9 can operate.

10 Again, with this license renewal 11 application -- it's just a license to continue to 12 operate outside of the regulations. The NRC accepts, 13 as Mrs. Grinnell said, Seabrook's program and other 14 programs like Vermont Yankee who have observed water 15 in manholes. They acccept -- We'll look at the 16 manholes once every two-years to see whether there's 17 any water in. If there's any water in there, we'll 18 pump them out. Use a little engineering common sense.

19 When you have manholes connected by conduits that 20 contain cables and if I have water in each end of the 21 conduit or the manholes and I pump it out and it's 22 good for another two-years -- how do we ever, ever 23 know that those cables are dry? We don't.

24 Take a look at the Brookhaven report, 25 which is sponsored by NRC research. They say -- You NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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58 1 must take a look and determine if these cables are 2 submerged. Nothing is being done presently or for the 3 next 40-years other than Seabrook says -- We'll look 4 at them every once in awhile and see if they're dry.

5 If not, we'll pump them dry and we'll continue to 6 generate those mega-dollars everyday.

7 I can go on and on on the shortcomings of 8 this application. The fact that insufficient 9 information is provided in there for anyone to 10 determine whether this plant is safe -- whether it is 11 in compliance with the regulations. I think that the 12 NRC needs to give a hard look at how they take 13 enforcement action and they cannot just turn a blind 14 eye to clear regulations, whether it be environmental 15 qualifications or whether it be 10 CFR 50, 55(a) for 16 piping inspections and leaky terminations, structural 17 integrity of pipes. There is no assurance. I was in 18 the Navy, as Mr. Bo Pham was in the Navy. Those 19 nuclear power plants -- we slept less than 100 feet 20 away from them. Those were safe. They were regulated 21 properly. They were operated properly. When I got 22 out of the Navy and I saw how these power plants were 23 built and not regulated -- I was totally shocked.

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59 1 really do its job -- enforce its regulation -- that 2 these plants should not continue to operate as they 3 are right now with unqualified cables and pipes in 4 unknown conditions leaking God knows what. Thank you.

5 ELVA BOWDEN BERRY: Thank you for your 6 comment. Okay -- Cathy Wolff. And please I'd ask you 7 not to defer your time because there are people who 8 haven't had the opportunity to speak, so they need to 9 have that opportunity and some people have already 10 spoken once today. Thank you. State your name and 11 your affiliation.

12 CATHY WOLFF: My name is Cathy Wolff. I 13 live in Kittery, Maine. I belong to different groups, 14 but I'm a concerned citizen. This is not going to 15 address the technical or the environmental. You're 16 getting a lot of information on that. This will be 17 fairly short.

18 It was almost 40-years ago that other NRC 19 representatives sat in similar rooms in New Hampshire 20 listening to citizens suggest that the salt marshes in 21 Seabrook might not be environmentally and otherwise 22 the best place to put a nuclear power plant. I'm sure 23 you are all knowledgeable of this history. But --

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60 1 reps talked, even laughed with each other or sat there 2 looking bored. They clearly were not listening. And 3 why should they?

4 The hearings -- and there were many 5 hearings in those years -- were pro forma. Soon, a 6 construction permit was issued with some changes in 7 design brought about by the Herculean efforts of 8 people who believed that if they could not stop the 9 nuke, at least they could try to make it safer.

10 Despite the permit, protests continued -- drawing 11 international attention to an industry that had 12 essentially gone unquestioned even by the NRC. Public 13 opinion began to shift as people realized there were a 14 lot safer, a lot cheaper and a lot more effective ways 15 to generate electricity. The nuclear industry 16 suffered. Wall Street withdrew support. Nuke plants 17 were shelved. But we did not freeze in the dark -- a 18 promise that had been made to us by the builders of 19 Seabrook.

20 Then, in the last few years the industry, 21 as you well know I'm sure, launched a new political 22 offensive to help assure its comeback would not be 23 derailed again by public opinion. It sought even 24 larger tax subsidies with a lot of help from the last 25 administration. A streamlined licensing process that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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61 1 gives an even shorter shrift to public input than 2 existed previously. And they moved quickly to extend 3 the lifetime of existing plants. I believe there have 4 been 50, so far, that have applied for and received 5 operating license extensions. Ironically, those 6 extensions will only increase the chances of a serious 7 accident. An accident that could be a PR nightmare 8 for the nuclear industry -- not to mention what it 9 might do to the people who live nearby.

10 There were reasons that your predecessors 11 set a lifetime of 40-years before a plant should be 12 decommissioned. It wasn't whim. Do any other power 13 generating plants -- oil, coal -- have decommissioning 14 dates set by law? I haven't been able to find out, 15 but I don't think they do. It's nice to see that 16 manners -- and I'm mentioning this mainly because 17 that's the way it felt this afternoon, not necessarily 18 at the beginning of this evening's session -- or 19 perhaps maybe just improved PR device -- although 20 after the beginning of this evening's session, I doubt 21 that -- has creeped into the NRC's public hearing 22 process since the 1970s, but I would hope that's not 23 all that's changed. I would hope that you -- you NCR 24 [sic] representatives -- will go back to Washington 25 and please don't just review the issues raised here --

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62 1 which you have to admit, at least this afternoon and 2 beginning already this evening, are substantial and 3 thought-provoking. You may not be able to stop 4 nuclear companies from applying for absurdly premature 5 license renewals -- although let's hope that a rule 6 change will -- but you certainly don't have to smooth 7 the way for their approval. You can, with diligent 8 study, recommend -- Hey, wait 10-years, try it then.

9 Please consider as you deliberate that you 10 have not heard -- at least not this afternoon and not 11 so far this evening -- a single argument today 12 directly related to why an operating license should be 13 extended 20-years before it expires. Not a single 14 argument. Even the handout from the company that I 15 picked up out there that's seeking the extension does 16 not make a lot of sense. So they can plan ahead, they 17 argue. Well, does that mean that without an extension 18 they plan to let things fall into dangerous disrepair?

19 In fact, your very own PowerPoint fails to provide 20 even a substantial -- a word that got bantered around 21 earlier today -- reason much less a complete one.

22 The fact that the folks at Seabrook 23 provide jobs, give money to the United Way and are 24 generally good guys and good community members does 25 not address the issue. I am sure that 10-years from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 now they will still be good guys and loyal Chamber of 2 Commerce members both in Exeter and Hampton.

3 The only final thing I have to say is in 4 your PowerPoint, you have on page 21 or slide 21 --

5 the Final Agency Decision -- the Commission considers 6 Safety Evaluation, Environmental Impact, NRC 7 inspections, recommendations from the ACRS -- how 8 about also considering public input? Thank you.

9 ELVA BOWDEN BERRY: Thank you. Next we're 10 going to have William Harris, then Skip Medford and 11 Gil Brown . Please state your name and your 12 affiliation when you get to the mic. Thanks.

13 WILLIAM HARRIS: Good evening. My name's 14 William Harris. I live in Newburyport, Massachusetts 15 where we have many people concerned about emergency 16 evacuation. But my primary interest comes from 17 managing research projects at the RAND Corporation in 18 Santa Monica, California on nuclear energy, economics, 19 reprocessing, nuclear proliferation for Robert Seamans 20 and Bob Fri of ERDA, then the Department of Energy. I 21 served on advisory panels to assess nuclear 22 alternative fuel systems as to their proliferation 23 resistance. I did research projects on alternative 24 energy systems -- solar, et cetera. I've been an 25 environmental attorney, so I've also litigated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 environmental issues.

2 I'd like to address mainly issues relating 3 to the scope of the Environmental Review. First, what 4 has changed significantly since the licensing hearing 5 that ended with the license in 1990 for the Seabrook 6 plant? Several significant changes have occurred. We 7 have a significant population increase -- both in 8 southern New Hampshire and in northern Massachusetts.

9 You'll get the 2010 census data during your review 10 for this license. We have increased mobility of 11 people. So, during the summer, we have 12 much more peaking of beach traffic. We have a great 13 infusion of population at the beaches, which raises a 14 challenge for evacuation planning. We have some 15 setbacks in long-term high-level waste management, but 16 I think the Yucca Mountain thing is not entirely over.

17 It may depend on elections this year and later.

18 There's also an issue of alternative dry-cask storage 19 as a technology that might be considered for 20 mitigation in lieu of on-site swimming pool storage of 21 waste from this plant. And another major change since 22 1990 -- and this is the primary field I work with. I 23 used to plan and draft arms-control treaties on leave 24 working for the State Department -- The Arms Control 25 and Disarmament Agency -- the United States through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 this Nunn-Lugar Program has bought and repossessed by 2 various means both high-level waste and low-level 3 waste and nuclear fuel rods from other countries, 4 which are important for our non-proliferation efforts.

5 So, I believe it is a positive factor that 6 needs to be considered that since the United States 7 has now accumulated much more nuclear material -- from 8 other nations and has decommissioned a substantial 9 number of nuclear weapons -- that the recycling of 10 this material in low-level enriched fuel assemblies is 11 a much safer alternative for those fuels than to leave 12 them abroad in a Kazakhstan or any other number of 13 other places. So, these are major changes that need 14 to be considered in the relicensing. Though I also 15 find it troubling that the relicensing is done so far 16 ahead. I believe there's some opportunities that 17 ought to be included in the design of the 18 Environmental Review.

19 My first concern has to do with emergency 20 evacuation planning and recovery operations. Not only 21 did FEMA have trouble with the original evacuation 22 planning, but the governor of Massachusetts, then 23 Governor Dukakis, could not approve in 1990 the 24 evacuation plan. We already had traffic saturation 25 troubles then.

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66 1 I've been working on mitigation for the 2 Whittier Bridge Project, which is I-95 crossing the 3 Merrimack River. We're going from 6 to 10-lanes --

4 8-lanes and two emergency lanes. There've been 5 significant studies mainly from Florida since 6 hurricane Andrew -- many important reports from the 7 National Research Council on contraflow evacuation 8 opportunities and so ultimately we will have more 9 flow-capacity -- we'll have a significant, about a two 10 thirds increase, in flow south in the event of an 11 emergency at Seabrook. But we're getting saturation 12 on I-95. We have not yet had the adequate modeling of 13 connectors between say Route 110 going east/west 14 between I-95 and 495. So, we really don't have the 15 flow-capability to handle evacuations in a major 16 emergency, especially in the summer when we have beach 17 traffic.

18 Now, a most significant change since 1990 19 that I think needs to be considered in the 20 Environmental Review and I think also in the Safety 21 Review -- has to do unfortunately with the development 22 of volitional actors -- terrorists -- who would like 23 to take out high-value targets that can cause great 24 harm.

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67 1 findings that are pertinent to the Seabrook 2 relicensing. First we have the 9/11 Commission, which 3 in its official release indicated that those who 4 planned the World Trade Center bombings had actually 5 had Seabrook as a priority target just before that.

6 That's all online in the 9/11 Commission report.

7 Then more recently Curt Weldon, the 8 Congressman from Pennsylvania who served on the Armed 9 Services Committee of the House, released information 10 that a group of mainly Pakistani citizens in Canada 11 with 19 arrests were considering an attack on Seabrook 12 after 9/11. So, I think as we're planning for the 13 operation of this plant past 2030 -- even in the next 14 decade -- we need now to take a re-look as part of the 15 environmental mitigation and risk assessment for this 16 relicensing, the consequences of having actors who are 17 malevolent rather than just the risk that come from 18 nature and from failures of technology that are 19 inadvertent.

20 I believe the C-10 Coalition -- I am not a 21 member. I am not opposed to nuclear power -- but I 22 believe they've done some important work to model 23 weather patterns from Seabrook. It may have made 24 sense for the 1990 assessment to look at prevailing 25 winds. Prevailing winds mainly go west to east.

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68 1 Unfortunately, when you are dealing with malevolent 2 actors, you will not get an attack when the prevailing 3 winds go from west to east. You may get it when they 4 go north/south because that would pick up a much 5 larger population north of Boston that would be 6 exposed in the event of a terrorist attack.

7 So, I suggest that there are opportunities 8 if you take the weather modeling that was done by the 9 C-10 organization and other studies and get the 10 assistance from the Defense Threat Reduction Agency --

11 they have the nation's best models. They have a 12 declassifiable version that can do the plume analysis 13 when the winds are blowing in any number of 14 directions, but you should include as the greatest 15 threat a north/south wind pattern and then you should 16 probably include the prevailing wind patterns and you 17 should include summer beach times -- our summer 18 traffic on I-95 peaks between May and October. The 19 main peaks are July/August to Labor Day. You have 20 major peaks in congestion on weekends. If you do that 21 -- I believe if you did that analysis and the U.S.

22 Department of Transportation now has excellent models 23 -- their Office of Emergency Evacuation -- they have 24 excellent software models. NRC has a group of 25 excellent software models on emergency evacuation.

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69 1 If you get the help of the Defense Threat 2 Reduction Agency, which has a colonel in this region 3 who would do the modeling for you, I believe you would 4 be able to develop much better mitigation planning.

5 So, you do not evacuate everybody in a major 6 emergency. You only evacuate the people who are at 7 high risks of radiation or other threats. That would 8 be essential to do.

9 You should also include consideration of 10 what's been developed by the U.S. Department of 11 Transportation for contraflow traffic where they 12 provide in their contracting that all contractors 13 working on interstates are responsible to remove their 14 construction equipment in an emergency because during 15 hurricane evacuations in Florida and elsewhere, we've 16 had problems with contraflow traffic when equipment is 17 left on these interstates. So, I believe that this is 18 at least one advantage of this early relicensing 19 application, which is we have an inadequate set of 20 emergency plans to evacuate people. We have good 21 software in the federal government in different parts.

22 And an excellent plume analysis done by the Defense 23 Threat Reduction Agency that's available to NRC. I 24 hope that as part of this relicensing, you consider 25 mitigation measures that would be important for both NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 evacuation and recovery operations in the event of a 2 terrorist attack or just an accident at the plant.

3 I also hope you'll consider dry-cask 4 storage options, so that you can get the spent-fuel 5 assemblies that are now on site at Seabrook off that 6 site. That could also reduce a target of attack and 7 radiological harm.

8 So, one other aspect I think that you 9 should consider in a relicensing application is 10 alternative nuclear energy systems where there are 11 scale economies to be on the same site because you 12 already have a site with all the infrastructure and 13 the security systems that are now likely to be much 14 less vulnerable. Some of the Babcock and Wilcox -- I 15 may not have the name right -- plants that are 16 underwater at all times, so that even if an aircraft 17 were to come at just the right angle -- and I've 18 supervised modeling of aircraft attacking nuclear 19 power plants and LNG plants and these plants were not 20 designed for direct attack by aircraft that are 21 purposely trying to take out the plant.

22 But these plants do have some redundant 23 features -- under many conditions they would survive 24 an aircraft attacking a nuclear plant -- but a safer 25 option is to have plants that are always protected, so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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71 1 even if an aircraft came at just the right angle with 2 just the right amount of energy that you would have a 3 safer outcome. So, I believe that when you're 4 considering relicensing for this long period of time, 5 one ought to consider alternative nuclear plants at 6 the same site as an option to consider in lieu of just 7 automatically extending a license for a plant that 8 simply was not designed for an era of terrorism.

9 So, I will at some point provide written 10 comments. I've taken much time and I thank you.

11 ELVA BOWDEN BERRY: Mr. Harris, thank you.

12 Could you stay there for a minute. You mentioned 13 ERDA and could you specify what that is for the 14 record?

15 WILLIAM HARRIS: ERDA -- The Energy 16 Research and Development Administration had a research 17 council and I supervised many of their research 18 projects at the RAND Corporation. That was then run 19 by a Robert Seamans and the Deputy Director Robert 20 Fri, F-R-I. So, they were between the Atomic Energy 21 Commission and the Department of Energy. I also 22 worked for the Department of Energy doing studies, as 23 well. I think that period is 1976, when the AEC goes 24 out of business, to about 1980 with the Department of 25 Energy. So, E-R-D-A is in the middle.

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72 1 ELVA BOWDEN BERRY: Okay. Thank you very 2 much. We'll have Skip Medford.

3 SCOTT MEDFORD: Thanks very much for the 4 opportunity. You stated my name. I'm a biologist. I 5 also live in New Hampshire, perhaps closer than other 6 commenters this evening. I'll keep my comments very 7 brief. In case nobody said it yet -- as long as the 8 owner/operators can satisfy valid concerns about the 9 plants continued viability, I support license renewal.

10 Second -- and primarily addressed to the 11 NRC members here. Will you conduct or will you ensure 12 the applicant conducts an equitable review of taxes 13 paid and contributions made to various states, towns, 14 residences impacted by the siting and continued 15 operation of the plant? Perhaps on a per megawatt 16 basis, per area impacted basis or other comparable 17 metric within the industry or within the region?

18 Thank you very much.

19 ELVA BOWDEN BERRY: Thank you. Gil Brown.

20 Can you state your organization when you get to the 21 mic.

22 PROFESSOR GILBERT BROWN: Sure.

23 ELVA BOWDEN BERRY: Thank you.

24 PROFESSOR GILBERT BROWN: Hi, good 25 evening. I'm Gilbert Brown, a professor of nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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73 1 engineering at the University of Massachusetts in 2 Lowell. So, I'm not exactly a resident, although I do 3 swim at the beach and I certainly enjoy the seacoast 4 as much as anybody that does live around here. So, 5 you might ask why am I here? What are my comments?

6 Well, it's a very good question, actually. I'm 7 listening to a lot of the technical comments or 8 comments that deal with technical issues -- this 9 probably isn't the forum to debate each one of the 10 issues, but all these issues need some airing. I'm 11 confident that you will air those. As a previous 12 speaker said, if there are issues with the safe 13 operation of the plant, then the NRC has the right and 14 the responsibility to say -- Stop. I know you've done 15 that to plants in New England and elsewhere and if the 16 plants aren't safe to run, they shouldn't run.

17 So, one of my main points is to separate 18 the issues about license renewal from the running of 19 the plant. I'm almost certain in the presentation 20 that you make that point. So a lot of the comments 21 here I think deal with that piece of the NRC business 22 of being a independent regulator overseen by Congress, 23 commissioners appointed by the president and reviewed 24 by the Senate, ACRS appointed by this process of 25 independence challenging those assumptions --

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74 1 challenge the very basis upon which this nation is a 2 stable democracy. I'm not here to challenge that. Do 3 your job. And I'm comfortable with the answers. If 4 the answer is -- no go. Then it's no go.

5 License renewal -- I think the issue of 6 why now? Why not N minus five and whatever that is --

7 15-years down -- at the last minute? Oh, I think 8 you'd be really, really uncomfortable. I would be if 9 it was a last-minute rush to get the license renewal.

10 License renewal is not a permission to operate the 11 plant. That happens every day with -- two on-site 12 inspectors? A myriad of inspection reports. People 13 were asking what's different from 40-years ago? Oddly 14 enough, I can remember 40-years ago. Better than 15 maybe yesterday, sometimes. But, really and I'll be 16 the first in this audience to mention TMI, which I 17 know you know what it means and my students think it 18 means To Much Information. But we established the 19 Institute -- we, the country, the nation, the owners 20 of the plant -- established the Institute for Nuclear 21 Power Operations. This is a level independent from 22 the requirements of the NRC. This is an excellence 23 model. The plants that you knew 25-years ago, 30-24 years ago -- in Seabrook's case 20-years ago -- are 25 not the plants that are operating today. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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75 1 performance speaks to that. The attention to detail.

2 The maturation of -- if you'll pardon the expression 3 -- safety culture. Three-way communication.

4 Attention to detail. And in my business that I do for 5 a living -- educate the workforce for the future.

6 The attention to detail, the knowledge 7 base -- it's a very different environment than it was.

8 If you haven't been around up close and personal -- I 9 know you have issues. There are issues every day. We 10 fly on airplanes. There are issues every day. We 11 cross the street. There are issues every day. I mean 12 life is an issue with one certainty. So, it's 13 different though today. It's better. The bar has 14 been raised and the performance speaks to that. The 15 quality, the detail, the attention to safety -- the 16 oversight by the commissioners and the staff. It's a 17 different world. I can attest to that.

18 One of the things I do is independently 19 review the training and issue decisions as to -- Is 20 this an accreditable training program? Are the people 21 at the site -- and every site has to do this --

22 training the workers to the standards not of the NRC, 23 but of the INPO standards. They are so high that they 24 carry the weight of regulation.

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76 1 take this seriously. And the plants are running safer 2 and therefore better -- a figure of merit, which 3 speaks to the economics. It's a red herring to say 4 the nuclear plants aren't economic. Every analysis 5 says baseload electricity provided by nuclear power 6 plants are the most economic electricity in the 7 country. For sure it's the greenest. No CO2. You 8 can shake your head. There isn't a -- well --

9 AUDIENCE MEMBER: Yes, there is.

10 PROFESSOR GILBERT BROWN: I'm glad you 11 finished my thought, thank you. We study this -- I'm 12 studying this right now with a graduate student 13 putting out a sort of a white paper. There is no --

14 too coin a phrase -- free lunch. We all leave 15 footprints. Every energy source leaves a footprint, 16 be at a windmill, be it a solar panel or be it a 17 nuclear plant. You know what - we're going to need 18 all of them to meet the requirements -- I know the 19 congresswoman, the State Senator -- I don't know if 20 she's still here. Is that you? I can't -- I guess 21 she left -- talked about in her opening comments about 22 keeping New Hampshire safe. But it's also keeping New 23 Hampshire with electricity because without 24 electricity, nobody is safe.

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77 1 24/7 electricity and it does it over 90% of the time.

2 In the 80s, if you were 80% of the time you were a 3 good performer. The average was in the 60s. Even in 4 school, that's not a good average. So, the industry 5 average now is over 90%. I don't know what Seabrook's 6 number is today. It could be 95% -- something like 7 that. It's really run well. That's a figure of 8 merit. It means attention to detail is being paid.

9 So, I want to --

10 MARY LAMBERT: Is this the S-E-I-S?

11 PROFESSOR GILBERT BROWN: I beg your 12 pardon?

13 MARY LAMBERT: Is this speaking to the 14 exam question -- the S-E-I-S?

15 ELVA BOWDEN BERRY: Hold on, Mary. Let me 16 bring you the mic.

17 PROFESSOR GILBERT BROWN: It's as much to 18 that question, ma'am, as I believe I've heard from all 19 the other speakers and no one else made comments to 20 the ideas of terrorism, the ideas of plant 21 performance, which is the everyday job. I have spoken 22 to the issue that 20-years, I believe -- and here's my 23 last point, frankly. The 20-year license renewal is, 24 albeit, arbitrary -- for sure. It's a regulation.

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78 1 20-years. That's not the point.

2 The point, I believe, is that this is a 3 mature technology. In the business I'm in, we're 4 talking about careers. We're not talking about 5 consulting, coming to show up to work one day and 6 doing another job. These are lifelong careers. We're 7 training our students to work in a field -- to work at 8 the power plant -- as a career. I believe that that's 9 maybe one of the unstated positive aspects of going 10 forward with a plan that has the plant licensable, 11 operationable, for that period of time. We can create 12 academic programs. We can work with the community 13 college to train people to work in the plants and keep 14 providing reliable energy for the good citizens of, 15 not just New Hampshire, but New England. Thank you.

16 ELVA BOWDEN BERRY: Thank you for your 17 comments. I'm going to remind everyone as Jeremy 18 said, there's four-ways to submit comments as 19 indicated on the slide that's up right now. At this 20 point, I don't have any cards for any new speakers 21 anymore, so the cards I have left are for people who 22 have spoken already today. So, I want to invite 23 anyone new if they want to give a comment before I 24 open the floor to people who have commented before.

25 Okay, the first person is Tom Noonis. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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79 1 just want to ask that you keep your comments brief 2 since we have your comments already in the record 3 today.

4 TIM NOONIS: Thank you. For the record, 5 it's Tim.

6 ELVA BOWDEN BERRY: Tim -- sorry.

7 TIM NOONIS: That's all right. The last 8 is N-O-O-N-I-S.

9 My name is Tim Noonis and this evening I'm 10 wearing two different hats. My first hat is that I am 11 the chairman of the Board of Directors of the Hampton 12 Area Chamber of Commerce. Seabrook Station is a very 13 strong supporter of the Hampton Area Chamber of 14 Commerce and through it, all the members that we 15 serve.

16 Seabrook Station is always willing to 17 sponsor and participate in the many events and 18 festivities that the Chamber promotes to encourage 19 business and tourism in the areas that we serve. I 20 have the privilege to serve on various boards and 21 civic committees with the employees of Seabrook 22 Station. I have found them to be a very bright and 23 positive group and an asset to the communities that we 24 live in.

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80 1 small mom-and-pop businesses to very large 2 corporations. These businesses depend on reliable and 3 reasonably priced electricity to operate their 4 businesses successfully. The long-term viability of 5 Seabrook Station is integral to the success of our 6 members. Seabrook Station is a crucial part of this 7 area's economy and you could not ask for a better 8 corporate citizen.

9 On behalf of the members of the Hampton 10 Area Chamber of Commerce, we would encourage you to 11 extend Seabrook Station's operating license.

12 My second hat this evening is a 17-year 13 resident and homeowner here in Hampton. A few years 14 ago, I went to a conference where the keynote speaker 15 was the cofounder of Greenpeace. In his address, he 16 said the biggest mistake that Greenpeace made was 17 equating nuclear power with nuclear weapons.

18 He continued on to say that nuclear power 19 has proven to be a safe and reliable source for 20 generating electricity and that the operation of these 21 nuclear power plants does not contribute to climate 22 change.

23 I hear the clamoring for good jobs, cheap 24 power and a clean environment. But when it comes time 25 to site one of these power plants or even a wind NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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81 1 turbine, everyone screams -- Not in my backyard.

2 Seabrook Station is in my backyard and I have found 3 them to be a very good neighbor. I would encourage 4 you to extend Seabrook Station's license.

5 ELVA BOWDEN BERRY: Thank you. Can I have 6 Janet Guen and then Doug Bogen. Is Janet still here?

7 Okay -- Doug Bogen.

8 DOUG BOGEN: I would like to pass. I'd 9 make all the points that I think others have made as 10 well tonight.

11 ELVA BOWDEN BERRY: Okay, thank you. Paul 12 Gunter.

13 PAUL GUNTER: Thank you. My name is Paul 14 Gunter, G-U-N-T-E-R. You got the spelling this 15 afternoon as well. I'm not going to -- I want to 16 reiterate a couple of points. First of all, I'm the 17 Director of the Reactor Oversight Project for Beyond 18 Nuclear, which is in Washington, DC area. I had been 19 a resident of New Hampshire for about 23-years. But, 20 I wanted to note a couple of things that we've heard 21 tonight and ask you if you see a pattern?

22 First of all, it is beyond the scope of 23 this proceeding in its Environmental Review to address 24 the issue of there's no management for the nuclear 25 waste that would be generated in that 20-year cycle --

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82 1 beginning in 2030/2050. So, we have an unmanaged 2 issue and it is beyond the scope.

3 We are also not allowed to address the 4 issue within the licensing process about security, 5 even though we know and I think it's been referenced 6 by an expert here today -- but clearly it was already 7 a public document by one of the federal labs -- I 8 believe it was Oak Ridge. No, I'm sorry, it was Argon 9 National Lab -- that the reactor design for Seabrook 10 was never designed nor constructed nor evaluated for 11 fire and explosion from a direct impact from an 12 aircraft. Matter of public record. That public 13 record disappeared for a while after 9/11, but it is 14 now back a part of the NRC public document room.

15 Now, again, we have what appears to be an 16 unmanaged problem that's beyond the scope of being 17 addressed within the context of extending this 18 reactor's operation another 20-years. Also, you've 19 heard comment and concern with regard to an evacuation 20 plan that's proved to be a very prickly problem -- a 21 lot of uncertainties. That too is now beyond the 22 scope of this proceeding. And we can go on. There 23 are several that present this unmanaged problem for 24 the NRC and I think that it begins to suggest that we 25 have an obsolete and antiquated review process that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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83 1 has to be challenged. I think that you're getting 2 some of that challenge tonight.

3 As one of the petitioners to change the 4 rule that facilitates Florida Power and Light 5 submitting an application 20-years in advance of the 6 expiration date -- I suggest to you that this is yet 7 another one of these streamlining of a very 8 problematic issue that does not serve to benefit 9 public health and safety and security nor does it 10 offer adequate protection to the environment 11 necessarily. But it provides and facilitates a 12 conveyor belt for this licensing process. As a 13 consequence, that has to be challenged today. We 14 have, as of yesterday, formally challenged the 10 CFR 15 54 Part 17(c), which says you can do that. But, I 16 just want the Agency, the public, the various experts 17 on both sides to see that there appears to be a 18 pattern here that facilitates this process, but not 19 necessarily to the benefit that is mandated by 20 Congress or presented to us publicly.

21 I'll just close my remarks by pointing out 22 one other piece here. I'm just going to read into the 23 record one of the aspects of this 10 CFR 54 Part 17(c) 24 that presents a problem for those of us who would like 25 a fair airing of a relicensing process -- filing for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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84 1 license renewal midterm of the current license finds 2 the licensee at a place in this system/structure/and 3 component service-life where the industry experiences 4 few failures that are observed and generally those 5 that are observed are episodic or anomalous in nature 6 and thus cannot be readily plotted as a trend for 7 prediction purposes. The time of an elevated rate of 8 failures due to design/manufacturing/construction 9 defects has passed. That's what we call early 10 component failure in what is traditionally called a 11 bathtub curve. I'm sure Dr. Brown is quite familiar 12 with the bathtub curve.

13 In that early failure rate, it's largely 14 irrelevant to aging management in the proposed 15 extended period of operation. The anticipated end-of-16 design-life and aging issues have barely, if at all, 17 begun to emerge. We're basically at the bottom of 18 this bathtub curve where you have a high incidence 19 early on as you work the bugs out -- whether it's a 20 nuclear power plant or an electric toaster or an early 21 model of a car -- there are these early failures. But 22 now we're at the bottom of that bathtub curve that has 23 been described to us as a highly efficient period of 24 operation of any facility.

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85 1 how a given plant will age is available to be trended, 2 provide lessons or otherwise illuminate the path 3 forward. It is generally observed that for many 4 system structures and components, such information 5 flow rates increase rapidly in the fourth quarter and 6 toward the end of the license. This 7 system/structure/component reliability progression is 8 well known and often illustrated in the so-called 9 bathtub curve.

10 Additionally, corrosion risk is a function 11 of time. For example, the Beaver Valley Nuclear Power 12 containment was discovered to have been rusting from 13 the outside of an inner liner that was inaccessible 14 for inspection. So, the evidence of this through-wall 15 corrosion on the containment component surfaced when a 16 bubble appeared in the paint on the inside of the 17 containment. So, it was a outside/in corrosion 18 process that escaped inspection and maintenance until 19 it was discovered by a bubble in the paint on the 20 inside.

21 Now, similarly -- I was very involved in 22 the Seabrook controversy. It was well known to us 23 that the pores in that concrete were facilitated by 24 such things as cutting of rebar that -- there were a 25 whole host of issues that raised concerns about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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86 1 integrity of both the construction and the 2 documentation of quality control in that facility -- a 3 whole host of systems and structures and components.

4 And I submit to you that our concern that this review 5 process now is coming at the bottom of this bathtub 6 where things are relatively stable, but the Agency is 7 proposing to give its approval for the latter life --

8 escaping the operational experience of the latter life 9 of this plant for the next 20-years, we believe is to 10 be responsible, both in terms of how this application 11 is being presented and how it's being reviewed.

12 We strongly urge you to again -- we are 13 asking the Agency both formally and in its review 14 process to reject this application. It's premature.

15 It doesn't provide the staff with enough information 16 to give a fair assessment of how this plant can be or 17 if it can be well-managed in this period of 18 2030/22050. Thank you.

19 ELVA BOWDEN BERRY: Thank you. Mary 20 Lambert.

21 MARY LAMBERT: I'll be quick and -- well, 22 here it is. He's a lot taller. I'll be quick. I 23 spent most of my time on the Severe Accident 24 Mitigation Analysis, which is within scope. And 25 focused mainly on the fact that the computational tool NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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87 1 -- the computer code -- that they are using, the 2 MACCS2, is an antiquated code. It is not properly 3 Q/A'd for licensing. It was done for research and it 4 very much underestimates impact by having embedded in 5 it the straight-line Gaussian plume model, which is 6 inappropriate for this coastal site for largely 7 underestimating clean-up because it was based upon 8 WASH 1400, which in turn was based upon cleanup after 9 a weapons event. But there is not a comparability --

10 as WASH pointed out and also some of the NRC staff 11 reviewer's of 1150 pointed out -- between a weapons 12 event with large particles and large mass loadings to 13 a reactor accident. So, I won't go into it.

14 There was also underestimating by a very 15 large measure health costs and also underestimating 16 Evacuation Time Estimates because it's apparent from 17 at least reading the application they did not quote 18 any ETEs for us to even question what the assumptions 19 -- if they used KLD -- whether they considered peak 20 traffic times, holidays, beach traffic, etc., etc. and 21 also ignoring spent-fuel pool accidents, which seem to 22 be in scope because of Section 5 of the GEIS.

23 But I would say, for something different, 24 that my comments on the MACCS2 particularly in regard 25 to clean-up and the gross underestimation of cost that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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88 1 result from it -- even the author of the code, David 2 Shannon, has written to the fact that if you are 3 interested in economic costs, don't use this code.

4 And who should know better than the person who wrote 5 it. That seems obvious. But, you should bring it in 6 to your discussion of alternatives because in 7 comparing alternative energies, you should be having a 8 chart on economics. The only fair way to do it is not 9 as suggested by a previous speaker that all you look 10 at is the running costs because if that were the case, 11 then a lot of people's houses would be real cheap if 12 somebody else paid their mortgages, if someone else 13 paid their insurance, et cetera, et cetera. That 14 seems to be the case with the nuclear industry.

15 So, when you compare costs -- when you 16 have to do your alternatives comparison -- I ask you 17 to take the economics -- what the difference in 18 subsidies for each are and then to tie in the MACCS2 19 code when you're talking about liability and insurance 20 because the MACCS2 -- it was MACCS, actually -- which 21 is the same in every respect to the MACCS2 -- is the 22 underpinning, also the Price Anderson Act. So, the 23 amount of insurance that is provided through the Price 24 Anderson Act that the industry is responsible for 25 rests upon this inadequate code estimation of costs.

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89 1 So, that too should be factored in.

2 Now, I'm not trying to screw the industry.

3 What I'm trying to do is get an honest assessment of 4 what the costs are, so in fact then we can have an 5 honest appraisal and also then come up with a fair 6 accounting of mitigations as they are offset by the 7 cost. So, thank you for that thought -- or listening 8 to that thought.

9 ELVA BOWDEN BERRY: Thank you, Mary.

10 We're at the end of our time and I have no more 11 commenters' cards. Mr. Bo Pham is going to make some 12 concluding remarks.

13 BO PHAM: Thank you, Elva. My name is Bo 14 Pham and I'm a Branch Chief at the NRC for License 15 Renewal projects. So, we have not only the Seabrook 16 project, but several other projects in our branch as 17 well.

18 I thank you for your time today. I just 19 want to kind of sum up by saying where do we go from 20 here? So, we received your comments for tonight. The 21 comment period actually goes all the way until 22 September 21st. Once we receive all the comments, 23 Jeremy and our team of Environmental Reviewers and 24 technicians will get together and for the next six-25 months or so will vet through each comment. Consider NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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90 1 the comments. And put together the Draft 2 Environmental Impact Statement. We'll issue that and 3 then come back to you and receive your comments on 4 that as well. So, I certainly appreciate your time to 5 come out and provide us a diverse set of comments and 6 opinions. We will certainly consider all your 7 comments. We may not always agree on them, but I can 8 assure you we will consider every single comment. So, 9 once again, thank you for your time.

10 PAUL BLANCH: Bo, just one thing. I want 11 to put on the record some comments and questions.

12 Some of them I did not get to, but I'd like to 13 formally have those on the record if you would please.

14 ELVA BOWDEN BERRY: Thank you. With that, 15 I want to thank you all for coming this evening.

16 (Whereupon, at 9:09 p.m., the public 17 meeting was closed.)

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