ML102850369

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

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

Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title: 2.206 Petition RE Mary Lampert

Docket Number: (n/a)

Location: (telephone conference)

Date: Monday, September 27, 2010

Work Order No.: NRC-461 Pages 1-33

Edited by Rich Guzman, NRC Petition Manager

NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

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

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 UNITED STATES OF AMERICA 1 + + + + +

2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 NUCLEAR REACTOR REGULATION 5 + + + + +

6 PETITION REVIEW BOARD 7 --------------------------------- 8 In the Matter of:  :

9 10 CFR 2.206 PETITION  :

10 OF MARY LAMPERT  :

11 WITH RESPECT TO  :

12 PILGRIM NUCLEAR POWER STATION  :

13 --------------------------------- 14 15 Monday, September 27, 2010 16 17 The above-entitled conference convened via 18 teleconference, pursuant to notice, at 2:00 p.m.

19 Eastern Standard Time.

20 BEFORE: 21 TED QUAY, Petition Review Board Chairman 22 RICH GUZMAN, Project Manager, NRR 23 CLIFF DOUTT, DLR 24 DAVE ALLEY, DCI 25 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 BEFORE (Continued):

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3 P-R-O-C-E-E-D-I-N-G-S 1 (2:00 p.m.)

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

7 I would like to thank everyone for 8 attending this meeting. The purpose of today's 9 conference call is to allow the petitioner, Mary 10 Lampert, to address the Petition Review Board, or we 11 may call it the PRB, regarding the supplemental 12 petition information dated August 13th, 2010 titled 13 "Pilgrim Watch 2.206 Petition Regarding Hydrogeologic 14 Assessment, Pilgrim NPS." 15 I am the petition manager for the 16 petition. The PRB Chairman is Ted Quay. The meeting 17 is being recorded by the NRC Operations Center and 18 will be transcribed by a court reporter. The 19 transcript will become a supplement to the petition 20 and will also be made publicly available.

21 I would like to open with introductions.

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 4 My name is Rick Guzman, project manager in 1 NRR. 2 CHAIRMAN QUAY: Ted Quay, NRR.

3 MR. DOUTT: Cliff Doutt, License Renewal, 4 NRC. 5 MR. ALLEY: Dave Alley, Division of 6 Component Integrity.

7 MR. PURNELL: Blake Purnell, NRR, project 8 -- 9 THE REPORTER: This is the Court Reporter.

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

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

13 MS. LAMPERT: Could the NRC 14 representatives speak up? After Ted, I didn't hear a 15 name. 16 MR. DOUTT: Cliff Doutt, NRC, Division of 17 License Renewal.

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 issues. Just one moment.

1 MR. BLANCH: Are they submerged?

2 (Laughter.)

3 CHAIRMAN QUAY: Now, Paul.

4 MS. LAMPERT: They're just not qualified, 5 Paul. 6 MR. BLANCH: Okay.

7 THE REPORTER: This is the Court Reporter.

8 So the last person I got was Ted Quay.

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

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

13 MR. PURNELL: Blake Purnell, NRR project 14 manager. 15 MS. MENSAH: Tanya Mensah, Division of 16 Policy and Rulemaking.

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

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

21 MR. GUZMAN: Yes, we are on.

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 6 got? 1 THE REPORTER: Say it again.

2 CHAIRMAN QUAY: What's the last name you 3 got? 4 THE REPORTER: Ted Quay.

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

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

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

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

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

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

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 7 NRC participants from headquarters on the phone?

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

4 THE REPORTER: This is the Court Reporter.

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

7 MR. GUZMAN: Okay.

8 (Pause.)

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

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

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

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

20 MR. GUZMAN: This is Rich Guzman again.

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 8 And, again, I earlier stated that the 1 meeting is being recorded by the NRC Operations 2 Center. And so we will still be able to get the 3 meeting minutes transcribed by a Court Reporter on the 4 back end. Okay? And, again, that transcript is going 5 to be part of the supplement and as part of the 6 overall petition package.

7 So I think where we left off is we can 8 still go around the room. So we left with Matt 9 McConnell. I wanted to check to see if there are any 10 NRC participants from the regional office on the 11 phone. 12 MR. JACKSON: Yes. Don Jackson, Division 13 of Reactor Projects; and John White, Division of 14 Reactor Safety.

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

17 (No response.)

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 9an expert with Pilgrim Watch. And I am on the faculty 1 in the Department of Civil Engineering, University of 2 Massachusetts, Amherst.

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

8 MR. GUZMAN: Okay.

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

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

15 (No response.)

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 0background noise or distractions. If you don't have a 1 "mute" button, this can be done by pressing the keys 2 *6. And then to unmute, press the *6 keys again.

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

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

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

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 1 additional explanations or support for the information 1 submitted by letter dated August 13th, 2010 before the 2 PRB's initial consideration and recommendation.

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

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 2Stuchell from the Office of Nuclear Reactor 1 Regulations Licensing Process Branch; Matt McConnell 2 from the Office of Nuclear Reaction Regulation's 3 Electrical Engineering Branch; Steve Garry from the 4 Office of Nuclear Reaction Regulation's Health Physics 5 Branch; and Don Jackson and John White from NRC's 6 region 1. We also obtained advice from our General 7 Counsel, represented by Mike Clark.

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 36th, 2010 before the PRB's initial consideration and 1 recommendation. The PRB met on August 23rd to discuss 2 the cables petition and to make an additional 3 recommendation in accordance with management directive 4 8.11. 5 The PRB's initial recommendation was that 6 the petition met the criteria for review and will be 7 accepted for review under 10 CFR 2.206. Ms. Lampert 8 was informed of this determination on September 1st, 9 2010. 10 On September 3rd, Ms. Lampert requested 11 that additional information in her August 13, 2010 12 petition, which for this discussion we may call the 13 hydrogeo petition, be included as a formal supplement 14 to the cables petition.

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 4compliance with the industry groundwater protection 1 initiative; and, three, to determine where underground 2 cable flooding may be occurring to assure that all 3 submerged cable splicers, connectors, and wiring are 4 able to perform their required functions.

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

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

11 MS. LAMPERT: Yes. Mary Lampert.

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

15 In essence, we have two types that we're talking 16 about. 17 We're talking about pipes, tanks, what 18 have you carrying radioactive liquids. So we can be 19 assured that they are not surrounded in an environment 20 that is conducive to corrosion and also that when 21 they're leaking, we would know where to place 22 monitoring wells to assure it could be picked up 23 before it went off site in excess of regulations.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 5submerged cable, slices connect to and the wiring to 1 assure that they, too, are not in an environment that 2 is conducive to corrosion surrounded in this case by 3 water. 4 There are two aspects to provide 5 assurance. One is to know where the buried components 6 are, number one, that are within focus; and, number 7 two, to understand the environment that they are 8 located in. And in this case, we're looking at 9 groundwater because we know that water is conducive to 10 corrosion and we also know that how the groundwater, 11 water is flowing will determine where any leaking 12 radioactive materials or other hazardous substances 13 may be going.

14 We, as you probably know, have a 15 contention that was heard at Pilgrim on buried 16 components carrying radioactive liquids. Due to this, 17 we gathered considerable information about Pilgrim's 18 environment, one being very conducive to corrosion, 19 and assessed what Pilgrim had as far as monitoring 20 wells. 21 Until the end of November of 07, they 22 didn't have any. And, more disturbing, when they 23 started to place monitoring wells on site, they were 24 relying upon a 1967 -- that's pre-operational --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 6 hydrogeo subsurface study.

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 7 these wells that are in place simply picking up the 1 tail of a tritium leak and the substantial portion is 2 going between them? The issue is unless we have the 3 proper studies, we will not know.

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

10 It was most disturbing that when Mass.

11 Department of Public Health initially asked Entergy --

12 I believe it was in June. It could have been -- I 13 know it was in May -- to see the study, they refused 14 to show them. And then there was bickering back and 15 forth. And they were finally allowed to see those 16 studies. 17 But this secrecy, lack of transparency 18 certainly is not acceptable. It certainly is in 19 conflict to the wishes expressed by Chairman Jaczko, 20 by the NEI groundwater initiative, and we expect 21 better. 22 And I think at this point it would be 23 worthwhile to turn the conversation over to Dr.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 8should entail and why -- that is his area of expertise 1 -- and then turn it over to Paul Blanch on the 2 implications for safety of cables, splicers, 3 connectors, and the wiring.

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

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

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

16 In order to design such a network; that 17 is, in order to decide where wells should go, both 18 vertically and horizontally in space, one needs to 19 understand where the water is going that might convey 20 contaminants from the site or from particular 21 facilities on the site. In order to understand the 22 flow behavior, one needs to understand the geology and 23 the hydrology, hence the hydrogeo aspect of this 24 request. 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1 9 As Ms. Lampert pointed out, the only data 1 that we are aware of on geology is from the 1967 2 study, which was a set of boring logs done as part of 3 the construction process. And it's obviously in 4 anticipation of putting a large building on this site.

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

6 That was the question that was addressed by those 7 studies, some utility to the present questions but not 8 every question is going to be answered by that sort of 9 study. 10 A typical hydrogeologic assessment for 11 this sort of setting would include monitoring wells 12 and other excavations where we would determine the 13 nature of the subsurface stratigraphy, we would 14 determine the location of the water table; we would 15 conduct -- "we" being an industry specialist who might 16 do this -- hydraulic tests, where we measure by 17 various means the properties of the subsurface. And 18 from that, we can infer the rate of water movement; 19 the speed, the velocity at which water can move 20 through the subsurface; and then over a period of time 21 collection of data on water levels. That helps us to 22 infer flow direction.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 0the petition. And I just want to mention that since 1 that time, Entergy has put in a number of wells and 2 quite a few more this past summer as this tritium 3 problem has become more evident. And that's great.

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 1one might expect in a typical setting to have flow 1 directions generally from the uplands towards the sea, 2 here we have this large building, parking lot, et 3 cetera -- buildings, I should say, and parking lots 4 that are interfering with the normal infiltration of 5 water. 6 And we probably have complex storm 7 drainage patterns that are disposing of water in ways 8 that would disrupt the typical flow directions. So it 9 becomes a particularly complex hydrologic site and 10 particularly important to know in detail what is going 11 on with the flow, flow rates, and directions of 12 groundwater flow, again all of that information 13 feeding back to using the network as a means of 14 assuring that there are no leaks from the critical 15 facilities.

16 So thank you.

17 MS. LAMPERT: Paul?

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 2radioactive isotopes that have been released and there 1 is a flow to wherever they are going.

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

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 3 within conduits -- obviously these conduits are not 1 watertight. Some of them are, in fact, totally dry 2 and have a very low probability of exposure to water, 3 but other conduits and manholes are exposed to water.

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 4subjected to this groundwater. And it's pretty much 1 all I have to say from an engineering standpoint, 2 again not being a hydrologist or anything, but I do 3 know that water flows downhill. And that is about the 4 extent of that.

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

9 And what would the implications of that be?

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 5they not be in a submerged condition. And also it's 1 very important for safety that radioactive liquids are 2 not going off site.

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

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 6that it is being looked at and being investigated, but 1 a study would also help identify the source of the 2 water. Is it water coming from a leaky tank or is it 3 coming from natural groundwater?

4 So there are many reasons why an updated 5 groundwater hydrology study needs to be conducted, 6 especially at Pilgrim and other plants, but we're only 7 talking about Pilgrim. I just provided that as 8 another example of the need for a complete up-to-date 9 study. 10 MR. AHLFELD: This is David Ahlfeld. I 11 can elaborate on that a little further that, for 12 example, at Pilgrim right now we have, let's see, over 13 the summer at one well, number 205, there were tritium 14 recordings of up to about 25,000 picocuries per liter 15 and at another well, 206, there were values of upwards 16 of 10,000. These 2 wells are about 200 feet apart.

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

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 7 These are obvious questions. And, yet, we 1 have inadequate information on the hydrogeology to do 2 anything but guess at this point. And a high-quality 3 hydrogeologic report made public would give us the 4 information, the data that we and Entergy could use to 5 answer those questions and similar questions that 6 might arise in the future.

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

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

20 MR. BLANCH: This is Paul Blanch again.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 8 updated, irrespective of global warming.

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

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

8 Becky Chin, do you have any comments to 9 make? 10 MS. CHIN: What did you ask me? I was on 11 mute. 12 MS. LAMPERT: Yes. I didn't know whether 13 you had any comments to make.

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 9that they did a lot of construction. And they removed 1 and filled when they built that station. And I'm very 2 suspect to what is there now as to what this 1967 3 report shows.

4 That's about the areas of my expertise.

5 Thank you.

6 MS. LAMPERT: Dave?

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

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3 0anything else if we have no assurance that there are 1 no rational, good, or scientific reasons for where 2 they are. And we deserve better than that. And I 3 think the NRC could certainly understand that.

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

6 CHAIRMAN QUAY: Let me check here, Mary.

7 Anybody in headquarters have any questions for Ms.

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

9 Do you have any questions for Ms. Lampert?

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

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

15 MR. JACKSON: No questions from region 1.

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

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

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

23 But there are clear requirements that 24 require that any effluents during normal operation or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3 1accident or anticipated occurrences be monitored. And 1 if we do not have monitoring wells at the proper 2 location, I'm not sure how these particular 3 regulations can be met. And they're very clear in the 4 GDCs and whatever applicable GDCs are at Pilgrim.

5 MS. LAMPERT: And this is Mary Lampert.

6 In the petition, I also cited criterion 16. I won't 7 repeat it, but it seems very clear that the 8 requirement to assure that the cause of a condition is 9 determined and corrective action taken to preclude 10 repetition logically would lead to including a 11 hydrogeologic study if water leaked out from piping, 12 tanks, or water leaks in to submerged underground 13 cables. 14 MR. BLANCH: Yes. That is 10 CFR 50, 15 which is quality assurance. And that's criterion 16, 16 not appendix A but appendix B.

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

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3 2can expect more leaks. And, therefore, we need more 1 measures to reduce this risk in identifying problems 2 that at this point we can say are likely to occur as a 3 precautionary measure to protect public safety going 4 forward. And that is what we are looking for.

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

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

15 (No response.)

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

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

22 (No response.)

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3 3 phone connection. Thank you very much.

1 (Whereupon, there was a chorus of "Thank 2 you.") 3 (Whereupon, the foregoing matter was 4 concluded at 2:49 p.m.)

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