ML090680874

Transcript of Susquehanna Steam Electric Station Public Meeting Transcript: Evening Session, Meeting May 28, 2008, Pages 1-87

ML090680874
Person / Time
Site:	Susquehanna
Issue date:	05/28/2008
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References
NRC-2218, TAC MD3021, TAC MD3022
Download: ML090680874 (94)

Text

Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title: Susquehanna Steam Electric Station Public Meeting: Evening Session

Docket Number: (n/a)

Location: Berwick, Pennsylvania

Date: Wednesday, May 28, 2008

Work Order No.: NRC-2218 Pages 1-87

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 NUCLEAR REGULATORY COMMISSION 2 + + + + +

3 PUBLIC SCOPING MEETING 4 SUSQUEHANNA STEAM ELECTRIC STATION 5 UNITS 1 AND 2 6 LICENSE RENEWAL APPLICATION 7 + + + + +

8 WEDNESDAY 9 MAY 28, 2008 10 + + + + +

11 7:00 p.m.

12 + + + + +

13 BERWICK, PENNSYLVANIA 14 + + + + +

15 The Public Meeting was convened at the Eagles 16 Building, 107 South Market Street, Berwick, PA, J.P.

17 Leous presiding.

18 NRC STAFF PARTICIPATING:

19 J.P. LEOUS 20 DREW STUYVENBERG 21 LANCE RAKOVAN 22 ERIC BENNER 23 IRENE YU 24 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 DIANE SCRENCI 1 P-R-O-C-E-E-D-I-N-G-S 2 (7:05 p.m.)

3 MR. LEOUS: Good evening. My name is 4 J.P. Leous. It's my pleasure to welcome you here 5 this evening and to serve as tonight's facilitator 6 for our meeting on the draft Supplemental 7 Environmental Impact Statement for the license 8 renewal of Susquehanna Steam Electric Generating 9 Station, units 1 and 2.

10 The purpose of tonight's meeting is two-11 fold. First, to share NRC staff's findings contained 12 in the draft report. And second, to receive any 13 comments on this document, which is the 34 th 14 supplement to the generic Environmental Impact 15 Statement for license renewal of nuclear power 16 plants, otherwise known as new regulation 1437.

17 Before we kick things off, I would like 18 to take a moment to let you know what to expect from 19 tonight's meeting and set some ground rules. In a 20 moment, NRC's Environmental Project Manager for the 21 Susquehanna environmental review, Drew Stuyvenberg, 22 will share his team's preliminary findings with us.

23 Drew has been with the agency for about a year and a 24 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 half and hold's a master's degree from Duke 1 University in Energy and Environmental Policy.

2 Once Drew has concluded his presentation, 3 specifically on the results of the environmental 4 review and how you can submit comments, we'll open 5 things up to any questions you may have, and of 6 course, to receive comments from the public.

7 If you've already registered with us, I 8 have your name and we'll call you up. If you haven't 9 registered, but would like to speak, don't worry, 10 I'll be keeping an eye out for things and as we get 11 moving we'll call you up.

12 We are taking a transcript for tonight's 13 meeting, which is one of the reasons I'm using this 14 microphone. So during the public comment period, 15 when I do call you up, please step up to either 16 microphone and please state your name clearly into 17 the microphone and any affiliation you may have.

18 This will help us keep an accurate record of the 19 meeting.

20 Also, I'll ask that only one person speak 21 at a time. This will help our court reporter, Doug, 22 keep accurate records of tonight's meeting.

23 Before we start, I'd like to introduce 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 4some other NRC staff that are with us tonight.

1 First, Mr. Eric Benner, Eric is the Branch Chief for 2 the NRC's license renewal environmental technical 3 staff. And we also have Diane Screnci from NRC's 4 Office of Public Affairs.

5 We also have Kirk LaGory who is from 6 Argonne National Laboratory, and who is one of the 7 ecologists working on this project. Hopefully, when 8 you came in you were able to grab a copy of the 9 slides, as well as a public meeting feedback form.

10 If you do have a chance before you leave 11 tonight to fill out that form and return it to us 12 before you leave, that would be great.

13 Alternatively, at your leisure, you can complete that 14 form and mail it to us. It actually doubles as its 15 own envelope. So, no postage required. When you're 16 done filling it out, just pop it in the mail and it 17 will get to us, and this helps NRC staff improve the 18 public meeting process.

19 Please take a moment now to silence cell 20 phones or any other electronic gadgets you might 21 have, just to minimize disturbances as we get through 22 the meeting.

23 I'd also like to thank the Lucerne County 24 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 Community College and the Berwick Industrial 1 Development Agency for allowing us to host the 2 meeting here tonight. And with that, I'll turn 3 things over to Drew.

4 MR. STUYVENBERG: Thank you, J.P. First 5 of all, I just wanted to take a moment to thank all 6 of you for coming out to this meeting this evening.

7 I hope the information that we provide you all will 8 help you understand the process that we're going 9 through, what we've done so far, and the role that 10 you can play helping us make sure that the final 11 Environmental Impact Statement is as accurate and 12 complete as possible.

13 I'd like to start off by briefly going 14 over the agenda and the purposes for today's meeting.

15 Next slide, please. I'll start off with a brief 16 overview of the license renewal process and then move 17 on to presenting the preliminary findings of the 18 staff's environmental review in which we've assessed 19 the impacts associated with renewing the operating 20 licenses for Susquehanna Steam Electric Station.

21 Then I'll provide some information about 22 the schedule for the remainder of our review and 23 about how you can submit comments in the future. And 24 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 finally, we'll leave time for the most important part 1 of this meeting, and that's the chance to receive any 2 comments that you all may have. Next slide, please.

3 The Atomic Energy Act gives the U.S.

4 Nuclear Regulatory Commission the authority to issue 5 operating licenses for commercial nuclear power 6 plants for a period of up to 40 years.

7 For Susquehanna, the licenses for units 1 8 and 2 will expire in 2022 and 2024 respectively. Our 9 regulations make provisions for extending plant 10 operation for an additional 20 years.

11 The NRC received PPL Susquehanna's 12 application for license renewal of units 1 and 2 on 13 September 13, 2006. As part of the NRC's overall 14 review of that application, we've performed an 15 environmental review in which we've looked at the 16 impacts that an additional 20 years of operation will 17 likely have on the environment.

18 We held meetings here on November 15, 19 2006 to discuss the overall license renewal process, 20 including both safety and environmental reviews, and 21 to seek your comments regarding issues that we needed 22 to evaluate.

23 Today, we're here to present the 24 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 preliminary results of our review that we've 1 documented in our draft Environmental Impact 2 Statement. After I present these preliminary 3 results, we'll open up the floor to your comments.

4 Next slide, please.

5 Next, I'd like to give you some 6 information on the statute that governs our 7 environmental review, and that's the National 8 Environmental Policy Act of 1969, commonly referred 9 to as NEPA.

10 NEPA requires that all federal agencies 11 follow a systematic approach in evaluating potential 12 environmental impacts associated with certain 13 actions. We at the NRC are required to 14 consider the impacts of the proposed action, which in 15 this case is license renewal. We are also required 16 to consider alternatives to the proposed action. The 17 NRC has determined that an EIS will be prepared for 18 any proposed license renewal of a nuclear plant.

19 NEPA and our Environmental Impact 20 Statement are disclosure tools. They're specifically 21 structured to involve individuals and groups from 22 outside the NRC. For example, this meeting is 23 intended to facilitate public participation in our 24 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 environmental review. Next slide, please.

1 The supplemental Environmental Impact 2 Statement -- I'm sorry, I'm getting ahead of myself.

3 This slide illustrates the NRC's environmental 4 review process that we use to evaluate the impacts of 5 license renewal. This process involves scoping 6 activities to seek out information; a site audit to 7 examine the local environment and how the plant 8 affects it; and the development of a document called 9 a supplemental Environmental Impact Statement, or 10 SEIS, to contain the staff's analysis and 11 conclusions.

12 The draft supplemental Environmental 13 Impact Statement, which we published in April 2008, 14 provides the staff's preliminary assessments of the 15 environmental impacts expected during the license 16 renewal term. Next slide, please.

17 The supplemental Environmental Impact 18 Statement is a site-specific complement to the 19 agency's generic EIS for license renewal of all 20 nuclear power plants. In the mid-1990s, the NRC 21 developed a generic EIS by evaluating the impacts of 22 all operating nuclear power plants across the U.S.

23 The NRC looked at 92 separate issues, and 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 9 found that for 69 of those issues the impacts were 1 the same for all plants with similar features. The 2 NRC called these Category 1 issues, and we were able 3 to make generic conclusions that all of the impacts 4 on the environment will be small. The NRC was unable 5 to make similar determinations for the remaining 23 6 issues.

7 Together, the generic EIS and the 8 supplemental EIS form the staff's analysis of the 9 environmental impacts of license renewal for the 10 Susquehanna site.

11 Also during the review, the NRC staff 12 looks for and evaluates any new and significant 13 information that might call into question the 14 conclusions contained in the generic EIS, while also 15 searching for new issues not addressed at all in the 16 generic EIS. Next slide, please.

17 The conclusions in our generic EIS and 18 our supplemental EIS help the NRC to determine 19 whether license renewal is acceptable from an 20 environmental standpoint.

21 After we compare the impacts of license 22 renewal to the alternatives, we use the standards 23 shown on this slide to make our decision. Simply 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 put, we're trying to determine whether license 1 renewal is acceptable from an environmental 2 standpoint. Next slide, please.

3 NRC staff uses information from various 4 sources as we conduct our environmental review. We 5 use the information received in the environmental 6 report that was submitted as part of PPL 7 Susquehanna's license renewal application.

8 We also conducted an audit in May of last 9 year, and we toured the facility, observed the plant 10 systems, and evaluated interaction of the plant 11 operations with the surrounding environment.

12 During this audit, we talked to plant 13 personnel and reviewed specific documentation. We 14 also spoke to federal, state, and local officials.

15 Additionally, we considered the comments received 16 during the public scoping period.

17 All of this information form the basis of 18 our preliminary conclusions contained in the draft 19 supplemental Environmental Impact Statement. Next 20 slide, please.

21 This slide shows some of the expertise 22 that we assembled for the Susquehanna environmental 23 review. As you can see, our diverse staff is made up 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 of biologists, economists, health physicists, and 1 other specialists. Next slide, please.

2 Here we see some of the major impact 3 areas that we address during the Susquehanna 4 environmental review. I'll discuss each of these 5 impact areas in a little more depth in a few moments.

6 Next slide, please.

7 So, a major question as we look at our 8 Environmental Impact Statement is how are impacts 9 quantified? Now, the generic EIS defines three 10 impact levels: small, moderate, and large. I'm going 11 to use an example. This is a hypothetical example.

12 This example is, say, fish in the 13 Susquehanna River. So, let's say that despite 14 prevention measures, the operation of the Susquehanna 15 Steam Electric Station may affect fish populations, 16 because the plant takes in water from the river to 17 use for cooling.

18 Now, if the decrease in fish population, 19 because of the operation of the plant, is so small 20 that it can't be detected in relation to the overall 21 fish populations, then that impact would be small.

22 If the losses cause the fish population 23 to noticeably decline, but then stabilize at a lower 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 level, that would be a moderate impact.

1 If the losses cause the fish population 2 to decline to the point where it cannot be 3 stabilized, or continually declines, then the impact 4 would be large. We applied this type of 5 methodology to each resource area studied in the 6 environmental review, such as socio-economics, 7 consumptive water use, air quality, etcetera. Next 8 slide. I'll elaborate a little more on these types 9 of issues. Next slide, please.

10 So, the first set of issues that I'm 11 going to talk about relate to operation of the 12 cooling system at the plant. We looked at issues 13 like discharges from the plant into the river, 14 aquatic species being affected due to water intake 15 systems, and impacts of the cooling towers may have 16 on plants and birds.

17 All the cooling system impacts, in this 18 case applicable to Susquehanna, are Category 1 19 issues. This means that the NRC had made a generic 20 determination that the impacts from normal nuclear 21 plant operations, during the period of extended 22 operations, are small, because of how this plant's 23 design helps reduce impacts to the environment.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 Since impacts from the plant aren't 1 expected to increase on a year-to-year basis during 2 the license renewal period, and since we found no new 3 and significant information while we reviewed all of 4 those aspects of the plant, we have preliminarily 5 adopted the generic conclusions that the impacts are 6 small for these issues. Next slide, please.

7 The NRC staff also looked for potential 8 impacts to threatened and endangered species. The 9 NRC staff identified three terrestrial species as 10 having the potential to occur on or near the 11 Susquehanna site, or near its associated transmission 12 line right-of-ways.

13 During consultation with the U.S. Fish 14 and Wildlife Service, they indicated only one of 15 these species, the Indiana bat, may occur at the site 16 or along the transmission line right-of-way.

17 During our consultation process, the Fish 18 and Wildlife Service determined that the license 19 renewal action will not have a significant adverse 20 effect on overall habitat quality for the Indiana 21 bat. The project is not likely to adversely affect 22 the species.

23 As part of the license renewal review 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 process, the NRC staff reviewed information provided 1 by PPL Susquehanna during the site audit; information 2 included in Susquehanna's environmental report; and 3 information from Pennsylvania state agencies, 4 including the Fish and Boat Commission, the 5 Department of Natural Resources and Conservation; and 6 the Department of Environmental Protection; as well 7 as the information provided by the U.S. Fish and 8 Wildlife Service.

9 The staff's preliminary determination is 10 that the impacts during the period of extended 11 operation of Susquehanna units 1 and 2 and its 12 associated transmission lines, on threatened or 13 endangered terrestrial species would be small. Next 14 slide, please.

15 Radiological issues are also a Category 1 16 issue, and therefore the impacts during the license 17 renewal period are small. By design, the operation 18 of nuclear power plants is expected to result in 19 small releases of radiological effluents, or 20 emissions, and Susquehanna is no exception.

21 During our site audit, though, we looked 22 at selected parts of the Radioactive Effluent, or 23 emission, Monitoring and Radiological Environmental 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 Monitoring Programs and supporting documentation.

1 We also looked at how gaseous and liquid 2 effluents are controlled, treated, monitored and 3 released, as well as how solid radioactive wastes are 4 handled, packaged and shipped.

5 We also met with staff from the 6 Pennsylvania Bureau of Radiation Protection. We 7 looked at how the applicant's radiation protection 8 program maintains radiological releases in compliance 9 with the NRC's regulations.

10 We also looked at the applicant's 11 radiological environmental monitoring data from on-12 site and off-site monitoring stations. The data 13 included the results of evaluations of water, milk, 14 fish, food products, and direct radiation.

15 Based on our review of the data, we found 16 that the calculated dose to the maximally exposed 17 member of the public to be well within the NRC's 18 radiation protection limits.

19 The dose of the maximally exposed person 20 is a conservative calculation which assumes maximum 21 values, such as breathing rate, food consumption, 22 drinking water, and proximity to the plant associated 23 with an individual who is exposed from all radiation 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 sources from the plant.

1 Based on a historical review of the 2 radiological data, and the current status of the 3 plant's radiological systems, the staff concluded 4 that the radiological releases from the plant are 5 expected to be similar on a year-to-year basis during 6 the period of extended operation.

7 During the staff's review, no new and 8 significant information related to this issue was 9 found, and thus we've adopted the findings in the 10 GEIS, and preliminarily concluded that the 11 radiological impact on human health and the 12 environment is small. Next slide, please.

13 Now, socio-economic impacts comprise a 14 wide array of issues, including impacts to public 15 services, education, aesthetics, recreation, housing, 16 utilities, transportation, historic and archeological 17 resources, and environmental justice.

18 The staff's independent review of data 19 provided by PPL Susquehanna, local and state 20 governments, the U.S. Census Bureau, and other 21 organizations, indicate that there would be no impact 22 in most socio-economic areas.

23 In the area of historic and archeological 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 resources, however, NRC staff preliminarily 1 determined that impacts may be moderate.

2 After reviewing documentation provided by 3 the applicant and by the Pennsylvania Historic and 4 Museums Commission, the NRC staff reached its 5 moderate conclusion, because significant 6 archeological resources are known to occur on the 7 site, but the entire site has not yet been surveyed.

8 In addition, PPL Susquehanna's procedures 9 for addressing new discoveries on-site may not 10 necessarily effectively protect these resources 11 should they be found in the future.

12 NRC staff recommended a number of 13 possible mitigation measures that could decrease the 14 level of impact in this area if implemented by PPL 15 Susquehanna. Next slide, please.

16 Another area of our review is what's 17 called postulated accidents. There are two classes 18 of accidents that we initially evaluated in our 19 generic EIS. The first of these is design-basis 20 accidents, and second is severe accidents.

21 Design-basis accidents, are those 22 accidents that the plant is designed to withstand 23 while creating only a low radiological risk to the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18public. The ability of the plant to withstand these 1 accidents has to be demonstrated before the plant is 2 granted its initial operating license.

3 Because the licensee has demonstrated 4 acceptable plant performance for the design-basis 5 accidents throughout the life of the plant, the 6 commission found in the generic EIS that the 7 environmental impacts of design-basis accidents is 8 small for all plants.

9 The second category of accidents is 10 severe accidents. Severe accidents are, by 11 definition, more severe than design-basis accidents, 12 because they may result in substantial damage to the 13 reactor core. The commission found in the generic 14 EIS that the risk of these accidents is small for all 15 plants.

16 Nevertheless, the commission determined 17 that alternatives to mitigate severe accidents must 18 be considered for all plants that have not already 19 done so. These are called severe accident mitigation 20 alternatives, or SAMAs, and require site-specific 21 analysis.

22 The purpose of the SAMA evaluation is to 23 ensure that plant changes, with the potential for 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 changing severe accident safety performance, are 1 identified and evaluated. Next slide, please.

2 So, the scope of potential plant 3 improvements considered, included hardware 4 modifications, procedural changes, training program 5 improvements, and a spectrum of various combinations 6 of alternatives. The scope includes SAMAs that would 7 prevent core damage, as well as SAMAs that would 8 improve containment performance if a core damage 9 event occurs.

10 The preliminary results of the 11 Susquehanna SAMA evaluation are summarized on this 12 slide. Fifteen potential SAMA candidate improvements 13 were identified for the Susquehanna units 1 and 2, 14 based on the review. Five of these SAMAs were 15 identified as being potentially cost-effective, or 16 cost beneficial, I should say.

17 None of those potentially cost beneficial 18 SAMAs, however, are related to managing the effects 19 of plant aging during the license renewal period.

20 Accordingly, they're not required to be implemented 21 as part of license renewal. Next slide, please.

22 Cumulative impacts are the impacts of 23 license renewal when taken together with other past, 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 present, or reasonably foreseeable future actions 1 regardless of what agency or person undertakes those 2 actions. It's kind of a broader look at how this 3 action fits in the context of things that have gone 4 on in this area before.

5 The NRC staff has identified many past, 6 present, and reasonably foreseeable future actions 7 that we've considered in this review for cumulative 8 impact on the environment.

9 The NRC staff identified past actions 10 like anthracite coal mining, or industrial 11 development and farming. Ongoing current effects, 12 including remaining industries, population centers, 13 and other economic activities, and potential future 14 actions like constructing and operating one or two 15 new units at or near the Susquehanna site.

16 The NRC staff evaluated the potential 17 effects of new units at the Susquehanna site, since 18 PPL Corporation submitted letters in May 2007 19 indicating its intent to file it for a combined 20 license application in late 2008 for one new unit.

21 In discussions with NRC staff, PPL 22 indicated that it may ultimately pursue two units at 23 the site. PPL Corporation has not yet submitted a 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 combined license application for a new unit or units.

1 And if and when it does so, the NRC staff would 2 review that application and decide whether to approve 3 or deny a license for the new facility at that time.

4 5 The environmental impacts of the combined 6 license action would be analyzed and addressed in a 7 separate Environmental Impact Statement that will be 8 prepared by NRC staff.

9 Based on our overall evaluation of past, 10 present, and future effects on the environment in the 11 region, overall cumulative impacts could range from 12 small to large.

13 Where we found large impacts, they were 14 typically the result of historic actions like the 15 coal mining I mentioned earlier, or like dam 16 construction on the Susquehanna River. Next slide, 17 please. 18 As part of the environmental review 19 process, we also evaluated a number of alternatives 20 to license renewal. Alternatives, in this case, are 21 options that could serve the same purpose as 22 Susquehanna units 1 and 2 would serve during the 23 period of extended operation.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 Specifically, we looked at the impacts of 1 replacing the power from Susquehanna units 1 and 2, 2 which after completely implementing their extended 3 power up rate, would be approximately 2600 megawatts.

4 We considered alternative power sources, or using 5 conservation to reduce demand.

6 Specifically, energy alternatives we 7 evaluated included replacing Susquehanna's generation 8 with power from new coal, natural gas, or nuclear 9 units, as well as the impacts and capabilities of 10 providing replacement power from other providers.

11 Additionally, we looked at other 12 technologies, such as biomass, wind, and solar power 13 to see whether their available potential could 14 replace Susquehanna's units 1 and 2. We also 15 analyzed the combination of alternatives that 16 included conservation and continued operation of one 17 Susquehanna unit.

18 Finally, we addressed the impacts that 19 would likely result if NRC simply did not take action 20 to renew the licenses, and Susquehanna units 1 and 2 21 simply shut down at or before the end of their 22 current licenses. Next slide, please.

23 After each alternative, we looked at the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 same types of issues that we did when we evaluated 1 the environmental impacts of license renewal to allow 2 us to directly compare the impacts of renewing the 3 unit 1 and 2 licenses with those potential 4 alternatives.

5 The NRC's preliminary conclusion is that 6 the environmental impacts of alternatives, including 7 not renewing the licenses, could reach moderate 8 levels in some of the categories evaluated, and large 9 levels in some resource areas for some alternatives.

10 11 For the combination alternative, the 12 environmental impacts would likely be small for most 13 areas considered, with several potential moderate 14 impacts. Next slide, please. During the 15 environmental review, we found no information that 16 was both new and significant.

17 Therefore we have, preliminarily, adopted 18 the generic EIS conclusions that the impact 19 associated with the 69 issues will continue to be 20 small, or we determined that some of those issues did 21 not apply to the Susquehanna plant.

22 In the Susquehanna draft Supplemental 23 Environmental Impact Statement, we analyzed the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 remaining 23 site-specific issues and determined that 1 11 were applicable to Susquehanna units 1 and 2, 2 because of plant design or because of environmental 3 characteristics.

4 For 10 of these issues in environmental 5 justice, we preliminarily determined that the 6 environmental impacts resulting from these issues 7 would be small. Impacts to historic and 8 archeological resources, however, would likely be 9 moderate.

10 Based on these conclusions, the NRC's 11 preliminary recommendation is that the environmental 12 impacts of license renewal are not so great that 13 license renewal would be unreasonable. That is, we 14 have preliminarily concluded that license renewal is 15 acceptable from an environmental standpoint. Next 16 slide, please.

17 Now, listed here are some important dates 18 for the Susquehanna license renewal and environmental 19 review. In April of 2008, we issued the Supplemental 20 EIS and we're currently accepting public comments on 21 the draft until July 21 st of 2008. The final 22 supplemental EIS is scheduled to be published by 23 March of 2009. Next slide, please.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 This slide identifies me as your primary 1 contact with the NRC for the environmental review of 2 Susquehanna Steam Electric Station. Ms. Evelyn 3 Gettys is the contact for any questions related to 4 safety review, and that safety review is currently 5 still ongoing.

6 Documents related to the Susquehanna 7 review may be found at the McBride Memorial Library 8 here in Berwick, and at the Mill Memorial Library in 9 Nanticoke.

10 At the bottom of the slide is the 11 internet address where you can directly access the 12 Susquehanna units 1 and 2 draft Supplemental 13 Environmental Impact Statement, and all of these 14 items are also in your packet. So, if there's 15 anything you want to write down, it's all in front of 16 you. Next slide, please.

17 There are several ways you can provide 18 your comments on the Susquehanna draft Environmental 19 Impact Statement.

20 First, you can provide your comments 21 today during the comment period of this meeting. If 22 perhaps, you're not ready to provide your comments 23 directly today, you can send your comment via email 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26to the following address: susquehannaeis@nrc.gov.

1 It's posted up here and in your packets, and we'll be 2 sure to get those as well.

3 You can also send your comments by U.S.

4 mail, or you can hand deliver them, if you happen to 5 be in the area at our headquarters in Maryland.

6 And with that, this portion of the 7 presentation is concluded and you will soon be able 8 to offer your comments directly on the staff's review 9 and on our preliminary findings. Thank you.

10 MR. LEOUS: Great! Thank you, Drew.

11 Just before we get to the question and comment 12 period, just some housekeeping matters. Some of the 13 documents we've heard, you've heard us speak of 14 tonight, the draft supplemental Environmental Impact 15 Statement is here, and there's copies should you like 16 them. 17 Additionally, the generic Environmental 18 Impact Statement copy is here for you to peruse.

19 There's additional information on various issues that 20 the NRC deals with at the other end of the table.

21 All of these documents and plenty more 22 are available on the NRC's website, should you be so 23 interested. As Drew mentioned, I just want to 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 reiterate that we are accepting both oral comments 1 and written.

2 Should you have written comments that 3 you'd like to share with us tonight, feel free to 4 hand them to myself or any of the other NRC personnel 5 here. In addition, as Drew mentioned, we are 6 receiving comments well after tonight's meeting until 7 July 21 st , as Drew mentioned, numerous ways to get 8 those to us. Also, after the comment 9 period if there are any issues that you'd like to 10 discuss with staff, NRC's technical staff will be 11 here after the meeting for as long as you'd like to 12 chat with us.

13 So, there will be plenty of opportunity 14 to speak with you on a one-on-one basis, if that's 15 what you prefer. That being said, before we get to 16 comments, if anybody has any questions, in terms of 17 clarifying issues that Drew had mentioned, you can 18 just raise your hand and we can flesh those out.

19 Great. Yes. We actually need for Doug 20 to get it on the record, yes.

21 MS. FRACKE: One of my questions is how 22 many here are from the government? I know you said 23 the NRC and some others.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 MR. LEOUS: Well, in addition to Drew, 1 Eric, Lance, myself and Diane, and there is one 2 member of EPD here, as well. So, that's one, two, 3 three, four, five, six. Kirk is an employee of 4 Argonne National Laboratory as well. He's a 5 contractor for the NRC, yes.

6 MS. FRACKE: How many are newspaper or 7 what kind of reporters are here today?

8 MR. LEOUS: Is there anyone from the 9 media? This afternoon we did have several reporters 10 from local media that did speak with Drew, but it 11 doesn't appear to be anybody here this evening.

12 MS. FRACKE: What news media did you 13 contact? 14 MS. SCRENCI: I'm Diane Screnci. I'm the 15 Public Affairs Officer. We did send out press 16 releases announcing the new availability of the draft 17 Environmental Impact Statement, as well as the 18 schedule for the meeting several weeks ago to all the 19 reporters in the area, and there were a couple of 20 reporters here this afternoon. There were three.

21 MS. FRACKE: Do you remember any of the 22 reporters or the papers, radio, or T.V. that you 23 used? 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 MS. SCRENCI: That were here today or 1 that we sent them to?

2 MS. FRACKE: Yes, that it was sent to.

3 MR. LEOUS: It's difficult without having 4 various microphones here. So, if you could take that 5 microphone, and I'll talk to her. The question was 6 essentially if you recall which newspapers or media 7 personnel were contacted. Is that correct? Okay.

8 MS. SCRENCI: We have a complete list of 9 newspapers, radio stations, T.V. stations that we 10 send to when we are issuing press releases for 11 Susquehanna. It's the Hazelton newspaper, the 12 Wilkes-Barre news media, the Scranton media. So, 13 it's all the reporters that are around the area.

14 MR. LEOUS: Actually, Ms. Fracke, if we 15 could just --

16 MS. SCRENCI: I absolutely don't recall 17 the names of any of the radio stations, but it's the, 18 what is it, the Press Enterprise, the -- I'm sorry, 19 off hand I don't recall any others, but I do have an 20 email list.

21 MR. LEOUS: If we could just stick a pin 22 in this. This portion of meeting is really to 23 clarify any issues that Drew presented, just to make 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 sure that we communicated things, and we can 1 certainly get to other questions later. Just, in 2 this portion before we get to comments I just want to 3 make sure -- okay. Okay.

4 MS. FRACKE: My neighbor was curious, 5 too. Why are they going so early for another license 6 when they just got one up to 2024? Why now to 2044?

7 MR. LEOUS: Drew?

8 MR. STUYVENBERG: Just to briefly answer 9 that, NRC regulations allow an operating plant to 10 pursue license renewal after having 20 years of 11 operation. So, Susquehanna units 1 and 2 achieved 12 that several years ago. So, that's why they were 13 able to apply for a license renewal. Sometimes that 14 review can take several years.

15 MS. FRACKE: But they just got one for 20 16 years. Why another 20 years? Why up to 2044? I 17 mean, that's crazy.

18 MR. LEOUS: Well, Drew?

19 MR. STUYVENBERG: I was going to say, 20 just to briefly explain, there initial license was 40 21 years. So, it's from when they first start operating 22 to 40 years afterwards. And so after they've 23 operated for 20 years into that 40 year period, they 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31can then apply for a license renewal. But this is 1 their first renewal.

2 MR. LEOUS: Okay. Actually, as Drew is 3 getting there, that question may best be answered by 4 plant personnel rather than NRC staff in terms of 5 their motivations for applying for license renewal.

6 This staff may not be in the best place to comment on 7 that. 8 Barring any other questions regarding the 9 review, we can get into the comment section here, and 10 I do have a Fred -- he's not there? Okay, Sue, if 11 you wouldn't mind.

12 MS. FRACKE: What does the NRC allow to 13 be admitted into the water and into the air from the 14 nuclear power plant?

15 MR. LEOUS: Eric?

16 MR. BENNER: Yes. I can't recite them 17 off the top of my head. Eric Benner, Branch Chief of 18 the Environmental Review Branch. There are limits on 19 what can be released. Primarily our review ensures 20 that the plant operated within regulations.

21 The part of the regulations that lists 22 all the different isotopes and the limits on those 23 different isotopes is 10CFR, part 21, or part 20, I'm 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 sorry. So, we have a copy of 10CFR here.

1 After we're done with the comment 2 portion, I'd be happy to show you some of that.

3 Really for our review, we're just looking to ensure 4 that the plant has complied with the regulations.

5 Well, and I articulated that I would be happy to show 6 you the regulations that I referred to.

7 MR. LEOUS: Great. Thank you, Eric.

8 Sue, I know you expressed interest in sharing some 9 comments with us tonight. So, if you would care to 10 step up to the podium.

11 MS. FRACKE: My name is Sue Fracke. I 12 live in the ten-mile dead zone around the plant in 13 Sugarloaf. Good evening, ladies and gentlemen who 14 sincerely care about the health, safety, and welfare 15 of people everywhere.

16 For those of you in the nuclear industry, 17 whether government or business, may you conceive the 18 ugly diseases that you have helped innocent people 19 die from, or be crippled with for the rest of their 20 lives. I cannot wish you a good anything. The last 21 time I spoke out at one of these type meetings, a man 22 came up to me and said, "Sue, you always say the same 23 thing." And I told him, "That is 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 because nothing has changed with the nuclear 1 industry, still giving us the same old load of feces, 2 such as, `I'm not afraid to move my family close by.

3 I wouldn't submit my children to anything that could 4 harm them.'," and that is what scares me about you 5 people. You're as stupid as our appointed president, 6 and who thinks he's anointed.

7 Every year, 20,000 people die of cancer 8 from naturally occurring background radiation. You 9 would think that this fact alone would be enough to 10 say let us not produce any more radiation, as it will 11 kill more people.

12 With all our other means of making 13 energy, especially all the various kinds of solar 14 energy that we now have the technology to do, it 15 makes no sense to use a source of energy that is 16 dangerous and will cause more people to die of cancer 17 and other degenerative diseases. Even if some people 18 are cured from cancer, they will worry forever that 19 it will come back to them and all the suffering that 20 comes with it, and many times it does come back.

21 In the Federal Register, December 15, 22 1989, part 2, by the Environmental Protection Agency, 23 40CFR, part 61, national emissions standards for 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 hazardous air pollutants, radionuclides, final rule 1 notice, etc. reiterated from the Federal Register of 2 December 27, 1979, the EPA listed radionuclides as a 3 hazardous air pollutant.

4 EPA determined that radionuclides are a 5 known cause of cancer and genetic damage, and that 6 radionuclides cause or contribute to air pollution 7 that may reasonably be anticipated to result in an 8 increase in mortality, or an increase in serious 9 irreversible or incapacitating reversible illness, 10 and therefore constitutes a hazardous air pollutant 11 within the meaning of Section 112A-1.

12 There are three major types of long-term 13 health impacts from exposure to radiation: cancer, 14 hereditary effects and developmental effects on 15 fetuses, such as mental retardation.

16 In addition, risk distribution from 17 radiation for most of the sources considered for 18 regulation show that fatal cancers occur much more 19 frequently than non-fatal cancers. And cancers 20 generally occur more often than genetic or 21 developmental effects.

22 It also states that numerous studies have 23 demonstrated that radiation is a carcinogen. I don't 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 35get that you guys don't seem to recognize this. It 1 is assumed that there is no completely risk-free 2 level of exposure to radiation to cause cancer.

3 That's right in the Federal Register. I 4 guess you guys don't read it. Radiation corrodes 5 metal, such as in the pipes of nuclear power plants, 6 causing holes that constantly emit radiation in our 7 air under the routine operation of the plants.

8 Radiation is cumulative in our bodies, 9 and the effects of exposure can sometimes take many 10 years before showing up. And we were worried that 11 Saddam Hussein had weapons of mass destruction.

12 We've got them, 110 or more or less in our country 13 right now.

14 Along with radioactive air pollutants, 15 the Environmental Protection Agency reports that in 16 2002, 24,379 U.S. non-nuclear facilities released 17 4.79 billion pounds of toxins into the atmosphere.

18 Of these pollutants, 72 million pounds 19 were known carcinogens. We have no concept of the 20 synergistic effects of these toxins when they are 21 mixed with radioactive pollutants. These toxins 22 impinge on health during your entire life, even 23 before birth.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 36 A study in New York city shows that the 1 genetic material in fetuses still in their mother's 2 womb is damaged by air pollution. From the Radiation 3 and Public Health Project in Norristown, 4 Pennsylvania, they have found that, "Current 5 emissions, current rates of infant deaths, childhood 6 cancer, and thyroid cancer are known to be affected 7 by emissions from nuclear reactors are elevated in 8 Lucerne county," the site of the Susquehanna nuclear 9 plant. 10 The National Academy of Sciences BEIR 11 Committee, in their 1990 study, also published there 12 is no safe dose of radiation. And again in their 13 1995 and 1996 reports, they again reported the same, 14 but this time said there may be biological damage in 15 addition.

16 The United States Department of Energy, 17 DOE, is conducting a ten-year program of basic 18 research in microbiology and these researchers, some 19 in university and some in government agencies, are 20 finding new, unanticipated forms of genetic damage.

21 A damaged cell may be able to repair 22 itself, but the repaired cell will not be more like 23 the original undamaged cell. There could be 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 irreversible damage to our species.

1 These are not decisions to be made by 2 engineers. This should be in realm of biologists and 3 geneticists, independent of the government and all 4 the industries.

5 "These high rates should shock all 6 Lucerne county residents and they should demand a 7 thorough study of the health risks posed by the 8 Susquehanna plant," said Joseph Mangano of the 9 Radiation and Public Health Project, who presented 10 the data.

11 "If radioactive," and this is a quote, 12 more quotes, most a lot of them from him, "If 13 radioactive emissions from the plant have been 14 harmful, people should know this before the 15 government decides whether or not to extend the 16 plant's license. The 2000-2004 county rate of white 17 infants who died in their first month was 23 percent 18 above the U.S. rate, based on 55 deaths. In that 19 same period, 43 Lucerne children under age 15 were 20 diagnosed with cancer, a rate 38 percent above the 21 nation. Data are taken from the National Center for 22 Health Statistics and the Pennsylvania Cancer 23 Registry." I guess you guys didn't contact them.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 38 Thyroid cancer statistics may be most 1 alarming. In the late 1980s, the two reactors at 2 Susquehanna were starting, the Lucerne rate was 20 3 percent below the U.S. However, in 2000-2003, the 4 Lucerne rate was 100 percent above, double the 5 nation. 6 Radioactive iodine, found only in nuclear 7 weapons and reactors, seeks out the thyroid gland 8 where it kills and impairs cells leading to cancer.

9 Two large nuclear reactors have operated at 10 Susquehanna beginning in 1982 and 1984 respectively.

11 Virtually all of the 312,000 residents of 12 Lucerne county live within 15 miles of the plant and 13 would be most likely to receive the greatest 14 radiation exposures. Like all reactors, Susquehanna 15 routinely emits gasses and particles into the air and 16 water, which enters human bodies by breathing and the 17 food chain. There are over 100 radioactive chemicals 18 in this mix. Each causes cancer and is especially 19 harmful to fetuses, infants and children.

20 California closed down the Diablo Canyon 21 nuclear plant many years ago. Through conservation, 22 solar and other forms of energy, they created over 23 800 new jobs and lowered their rates.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 39 Nuclear power is only about 19 percent or 1 so of our energy in the U.S. Through conservation 2 and solar we could close down all the nuclear plants 3 in our country and save thousands of lives, if not 4 millions.

5 These findings, and other data on local 6 disease rates, should be part of the federal decision 7 on whether the U.S. Nuclear Regulatory Commission 8 should approve the application of PP&L Susquehanna to 9 operate the plant until 2044. The current license 10 allows operation until 2024. These plants were 11 originally designed to only operate for 12 to 15 12 years. 13 PP&L and the NRC are pushing our luck.

14 Anyone who wants more nuclear power plants -- and our 15 president wants 54 more in this country -- should be 16 considered an insane terrorist. Our president 17 constantly tries to scare us about terrorists.

18 Nuclear plants, and the high level radioactive waste 19 sites, both now at the Susquehanna site, could be a 20 terrorist's dream.

21 We are also using depleted uranium bombs 22 in Iraq. Both our soldiers and the Iraqis are being 23 exposed. Many of the Iraqi children are getting 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 40 leukemia.

1 Remember the Gulf War Syndrome? Our 2 soldiers were exposed then, too, and many of their 3 children had birth defects, and many of the soldiers 4 got very sick. And our government didn't want to 5 tell them why. Who is the terrorist?

6 And you know, if a person has a gun and 7 goes around and starts shooting people and gets 8 caught, they put him in jail for life, if not capital 9 punishment.

10 But you people have so far allowed all 11 these nuclear power plants who have caused more 12 cancer and other degenerative diseases, but it goes 13 slower. It's not an instant kill.

14 So, all of you can just go around and 15 say, "Oh well, nobody's dying right away." So you 16 don't know and you'll never know, and they're not 17 faces to any of you people.

18 So, you can go about your business and 19 collecting your money, but I consider you all 20 murderers, because that's what you're doing any way 21 you look at it. You're not looking at it the way we 22 get the information. You get different information 23 that says very small impact.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 41 So, what's a small impact? How many 1 people die and it's a small impact? How many 2 animals, we've seen a lot of our animals getting 3 cancer, and it's just, it's disgusting to see all 4 this. And our families and diabetes. All these 5 diseases that are just going around like crazy like 6 we didn't see when I was a child. We didn't see so 7 much of it, and now all of it's got to be something.

8 And nuclear is one of the answers. And I 9 say shut them down, don't, just deny them another 10 license, or I wish there was a hell for you to go to.

11 MR. LEOUS: Great. Thank you, Sue. Mr.

12 Epstein? If you care to share your comments.

13 MR. EPSTEIN: Well, I'm going to take a 14 little different tact here. My name's Eric Epstein.

15 I'm the Chairman of Three Mile Island Alert. We're 16 a SAFE organization based in Harrisburg. We monitor 17 three nuclear power plants: Susquehanna, Peach 18 Bottom, and Three Mile Island.

19 I don't know how we want to proceed. I 20 have comments, but I also have a document I'd like to 21 enter into the record. And then we can discuss how 22 we proceed from there with official comments, because 23 what I did is I read the entire document, have some 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 42concerns. And I've been tracking this issue since 1 the November 2006, I think, was our first meeting up 2 here. I would just say, right off 3 the bat, there's got to be a different way to respond 4 to questions. In Appendix A, you have responses to 5 questions, and they basically, you homogenize them.

6 You don't really answer questions. I don't know if 7 you know what I'm referring to, but this is something 8 that the NRC does time and time again.

9 There are people that take the time to 10 research issues, ask a pointed question, and what you 11 do is get a cumulative response. I mean, just as a 12 generic tone, as a former college professor, I 13 wouldn't give you a high grade there. I think if 14 somebody's taken the time and effort to raise an 15 issue, they deserve a specific response.

16 I was disappointed. I spent a lot of 17 time preparing a presentation. You may not agree 18 with some of the policies that I advocate, but I 19 don't really think the public is well served.

20 And I would say this, you know, we've 21 gone through Three Mile Island. We've gone through 22 Peach Bottom. That plant was shut down, because the 23 operator ended up having his TMI unit 1 was shut 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 43 down, like six and a half years, I think, under NRC 1 order. 2 We have a lot of experience testifying 3 before you guys and reading these documents. Believe 4 me, if my house catches on fire, don't even send the 5 fire police. I still have all the hard documents.

6 I'd also like to extend a compliment, 7 because this was a lot easier to get through. I did 8 look at it on PDF, but it's nice to have this. I'm 9 not really sure why we still don't do page numbers, 10 but that's kind of a housekeeping issue.

11 I point out that I'm also in federal 12 court suing the Susquehanna River Basin Commission 13 and PPL Susquehanna. And one of the reasons I'm 14 doing that is because I don't think the NRC has done 15 a good job when it comes to looking at environmental 16 impact and water use. Especially in a state like 17 Pennsylvania where I think we've collectively taken 18 water for granted, but it's a limited commodity.

19 We're getting ready to finish Act 220 and 20 we're going to have a water budget for the year 2008, 21 and PPL is ahead of the game. And there is the 22 potential for Susquehanna to be declared a water-23 budgeted area way after you have declared there's no 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 44 impact to the water.

1 So, I guess my biggest sense of concern 2 and disappointment is the lack of coordination 3 between state and federal agencies. This is now my 4 third re-licensing proceeding. Unfortunately, I 5 think I lead the league in that. However, TMI, we 6 just came to a settlement, so I won't have to pursue 7 that particular issue.

8 I'll just try to read, not a lot, but 9 refer to my notes. One of the things that dismayed 10 me the most is that the first time I was here, I had 11 to introduce the NRC to the SRBC.

12 I know that since that time you guys have 13 developed a relationship, but I've got to tell you, 14 that's not a confidence builder when the agency 15 overseeing the re-licensing of a nuclear power plant 16 is unaware that there's a federal compact that 17 oversees surface water consumption. It was a 18 disappointment.

19 I know things have improved. I know the 20 SRBC has now hired someone to do that issue.

21 Hopefully, re-licensing at TMI will warrant more 22 scrutiny. Certainly at Limerick, I'm sure you're 23 aware there's a Delaware River Basin Commission.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 45 So right off the get-go, one of the 1 concerns I had, which was raised by somebody else, is 2 that Susquehanna's a pretty new plant. I think it's 3 one of the youngest to come up for re-licensing.

4 It's hard for me to understand how you 5 can capture an aging plant and a young plant. You 6 know, I think one of the things you may want to look 7 at down the road is when these plants come up for re-8 licensing, there may be an adjustable criteria for a 9 plant that's operated, let's say for 30 years, 10 compared to 20. Just the lessons learned type of 11 thing that I would put out there.

12 Beginning on June 5, 2007, PPL and the 13 NRC have filed responses in opposition to my concerns 14 relating to water use, water chemistry, and aquatic 15 challenges. In fact, I lost a case at the NRC, 16 because all the issues I raised were considered 17 outside the scope and not material to this 18 proceeding.

19 One of the flaws with re-licensing is, 20 since the ROP's inception, this process is so 21 construed. There's something terribly wrong when 22 there's been 48 license applications, and only one 23 contention has been admitted. I want to say that 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 46again. How many? Because that's what Exelon told me 1 last week. One contention in Oyster --

2 [Unintelligible]

3 MR. LEOUS: Hang on, Diane. Hang on, 4 Diane. 5 MS. SCRENCI: Sorry, there was one 6 contention in Oyster Creek, I believe there are three 7 contentions at Vermont Yankee. There's one 8 contention at Pilgrim, and there are 150-something 9 under consideration by an Atomic Safety and Licensing 10 Board at Indian Point.

11 MR. EPSTEIN: No, let's have this 12 discussion. Let's speak, because this is something 13 you're taking pride in.

14 MR. LEOUS: Now is not the time to get 15 into a back and forth. So, --

16 MR. EPSTEIN: Yes, but what I'm saying 17 is, let's say that my number is off and there's been 18 three at Vermont Yankee, one at Pilgrim. Out of how 19 many? The percentage is infinitesimal. I mean, when 20 we did this the first time around, when we actually 21 licensed the plant, what I'd like to see, Diane, if 22 you're going to brag about these numbers.

23 Well, I just want to say a simple 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 47comparison will eliminate my point. If you look at 1 the number of contentions that were accepted when 2 these plants first came on line, compared to now, 3 it's unbelievable how many are not getting passed, 4 either the technical or environmental scope.

5 I mean, I've done this the first time 6 around. Contentions were routinely accepted, 7 litigated. We had discovery. We don't have 8 discovery. They're rarely accepted. What I'm saying 9 to you is you guys have narrowed the process.

10 If somebody wants to take issue with me, 11 I mean, that is an extraordinary mental gymnastic I'd 12 like to witness. So, let's say I'm wrong, it's not 13 one contention, it's five, six, seven. Out of the 14 hundreds that have been entered.

15 Now the first time we did this, in the 16 70s, you actually got contentions admitted and you 17 litigated. So, what I'm saying to you is, look, the 18 process has changed. The ability to get a contention 19 litigated to basically vet it, it's not there. I 20 mean, I think we can all agree with that.

21 What I would love to see the NRC do, and 22 I know you won't, number of contentions admitted the 23 first time around versus contentions admitted this 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 48time around. And you're going to see this, Diane.

1 I'm telling you, that's reality.

2 The problem I have is this is like a 3 shell game. Do you go before the PUC? Do you go 4 before the SRBC? But when you go to the SRBC, 5 anything that says nuclear radiation go back to the 6 NRC. 7 You can't go to the PUC anymore, because 8 now it's deregulated. They haven't filed anything at 9 the PUC for water consumption.

10 DEP has actually filed suggestions. They 11 won't let me see it. It came out in another 12 proceeding when I was doing discovery. So, I'm a 13 citizen. This is not what I do for a living. You've 14 made it very difficult for someone to intervene, get 15 a contention admitted, and to vet an issue. I don't 16 think it's a user-friendly process.

17 And again, I'm probably one of the few 18 people who have done it both times. Now, maybe there 19 were problems the first time around, but to basically 20 shut folks out is not going to be healthy.

21 I think we can all agree that 22 unintentionally destabilizing a sensitive and 23 important aquatic asset, like the Susquehanna River, 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 49is not in the public interest. All I'm saying is 1 that all sensible and proactive measures should be 2 deployed to mitigate against this scenario.

3 The merits, and this is basically what 4 I've been saying at each re-licensing proceeding, the 5 merits of an exhaustive investigation are numerable 6 and present, really, no hardship to PPL Susquehanna.

7 The problem I'm having here is that this 8 case is going to reform what happens next at TMI, and 9 at Limerick, and then the uprates that are going to 10 occur after that. I think we all know what Exelon's 11 strategic architecture is. PPL is unique. They only 12 have one plant.

13 Susquehanna, on a conference call I had, 14 or Exelon, on a conference call I had the NRC, said 15 their strategic architecture, over the next three 16 years, is to re-license and uprate every plant. So, 17 we're going to see different variations of the re-18 licensing occur.

19 So, this document is extremely important.

20 I mean, extremely. This is going to be the 21 blueprint for moving forward. Well also, and I don't 22 want to belabor the point, but obviously the concern 23 that I think we have in Pennsylvania, which may be 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 50 unique -- obviously, there are New Jersey and others 1 -- besides the sheer volume of nuclear waste that's 2 going to be generated.

3 And let's be adults Yucca Mountain's not 4 getting built. It's not happening. I'm not saying 5 it's good or bad. That's reality.

6 At some point we need to start having a 7 discussion as adults. If we're going to generate 20, 8 30 metric tons of waste per reactor year, and it has 9 nowhere to go, that's an environmental impact.

10 Now while I disagree with Sue, I think 11 these plants were probably designed for 40 years, and 12 from what I understand that was basically actuarial, 13 but to get another 10, 20 years to generate, you 14 know, 30, 60 metric tons of high level waste with 15 nowhere to go, I can't see how that's not an 16 environmental impact.

17 And I've said this before and I'll say it 18 again, what we're going to do with the legislature, 19 start taxing you for storing radioactive waste on 20 site. 21 If we want to play this game, we'll play 22 the game. It's a risk reward. Nobody here asked for 23 the waste. It's going to be here. It has nowhere to 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 51 go. 1 In addition to that, beginning in July 2 2008, I didn't see any discussion about this, 3 Barnwell's going to close to us. We have nowhere to 4 take our low-level radioactive waste. Nowhere do I 5 see in the scoping process what do we do with these 6 two reactors, let alone another two reactors.

7 So, now we've got high-level waste, low-8 level waste, mixed waste, waste on the road going to 9 SEG in Tennessee to be compressed. All kinds of 10 different ripple impacts that are potentially 11 negative for this community. Waste goes in, waste 12 goes off, waste stays on. It would have been nice if 13 that would have been factored.

14 I would just say that the same company 15 that I'm having problems with on the surface 16 withdrawal of water from Susquehanna, essentially the 17 river intake and grand fathering two wells, T1 and 18 T2, is the same company that's basically going to be 19 allowed to re-license a plant for 20 years and not 20 really have these on-site inspections.

21 What I saw at the SRBC and what I saw at 22 the NRC is basically documentation that's provided by 23 PL, by government agencies, and to review that 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 52documentation. Now, I'm sure there's on-site 1 inspections, but I didn't see the rigorous on-site 2 examination that I would want, or the due diligence 3 that I think you need to do for a plant that's going 4 to be asked to operate for another 20 years. That's 5 the concern that we have.

6 You know, things when this plant were re-7 licensed, there was no such thing as compensatory 8 fire measures, i.e. roving fire watches. You know, 9 thermal lag. Whether it's radwaste, there's flanges 10 that don't, o-rings.

11 I mean, one of the things that you guys 12 do well is there's RIS that come out every week.

13 There's a whole host of technical issues. I thought 14 it was a no-brainer. You take a checklist to the 15 RIS, all the generic challenges faced in the 16 industry, and see if any of those show up.

17 I mean, how hard was that? Because 18 Susquehanna's actually mentioned in the RIS on 19 several occasions. Take the RIS. See the re-20 license. Well, see if we have a generic issue. See 21 if we have a site-specific issue, rather than do this 22 kind of generic pancake application.

23 Whoever does the RIS, by the way, 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 53deserves a lot of credit. That's a really good 1 document. The issues that I was disappointed in, and 2 I think you guys have heard me pound on time and time 3 again, really have to do with aquatic challenges.

4 I'll be specific. Neither PPL or the 5 EPA, and this is great how 316a and 316b doesn't 6 really matter, because it's in court, even though 7 it's going to be ripe for argument this fall, we just 8 won't deal 316a and 316b as if it's gone away.

9 Dude, that's great magic. Great magic.

10 Four of the issues I raised, still outstanding, never 11 been addressed, never got a response at any venue. I 12 mean, I can take losing. Not well, but I'd like to 13 know what I'm losing.

14 Neither the PPL, EPA, the DEP, or the NRC 15 addressed safety and structural challenges caused by 16 microfouling versus macrofouling; microbiologically 17 influenced corrosion; biofilm disease-causing 18 bacteria, like legionella and wisteria; the 19 difficulty in eliminating established biofilms; 20 oxidizing versus non-oxidizing biocides; the eastward 21 migration of asiatic clams, zebra mussels.

22 Nothing here is proactive. You know, now 23 I saw, you had two pages on these, and we're going to 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 54 get to that, which were really interesting, but 1 nothing here is proactive. This is really an 2 interesting scoping tool. Everything is reactive.

3 Nothing is anticipated. Nothing is proactive.

4 It's, I mean, in my field of work it's 5 exactly the opposite. You try to anticipate what's 6 going to happen and prevent it. Here it's basically, 7 until it happens, then we'll react. I just think 8 that's dangerous.

9 I can't ask you, and I know you don't 10 have the power to go back and talk to the NRC 11 commissioners and have it changed, but I think the 12 reactor oversight process is flawed in that 13 particular area, and as it translates to re-14 licensing.

15 I read the GEIS. What I found, what was 16 interesting is the NRC has acknowledged the absence 17 of water monitoring tools for algae and benthic 18 macroinvertebrates.

19 So, I don't know why, but the monitoring 20 stopped in 1994. That's 14 years ago. How you can 21 give somebody a clean bill of health on a monitoring 22 protocol that no longer exists is beyond me.

23 Again, this is in your document. The NRC 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 55 acknowledged, and this is again in the GEIS, "PPL 1 does not sample private wells on nearby properties," 2 which amazes me, because I'm sure you guys know the 3 word Bravewood. And the closest well is a domestic 4 well near the southeast corner of the facility.

5 So, I don't even know if that's the 6 appropriate pollutant pathway or what, but I think we 7 all know now, and it's not just tritium, that we've 8 got migratory pollutant paths raised at all nuclear 9 power plants. It would have been nice if we had 10 testing in place to capture this.

11 Now, we have six, and I think if I'm 12 reading this correctly, at one point we had four 13 tritium monitoring wells, we're up to six. However, 14 I'm not really sure where they're at. I may have 15 missed it, and I'm not sure the rhyme or reason of 16 how we do it. TMI is a little more aggressive, but I 17 think it's good that PPL has more, rather than less.

18 To me the issue is this, it's real basic, 19 if there is a tangible impact to the community when a 20 major industrial facility, and again I want you to be 21 aware that this is a precedent for water use. We're 22 going to have coal gassification facilities. We're 23 going to have an ethanol plant. We have a new 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 56gambling casino close by. We're going to have an 1 airport in Hazelton.

2 This reminds me of the land use work I do 3 where the developer comes in and says, "Look, I'm 4 only going to have a 2 percent net impact on the 5 traffic." Well, Dude, what about the other 10 6 developers? You know? There's an aggregate impact 7 and you guys aren't charged to look at it. It all 8 goes to the same place. Right now, and the 9 SRBC is not here, we are very vulnerable to drought 10 conditions. Nuclear power industry does not have to 11 comply with drought restrictions. It's a voluntary 12 compliance. Who's going to resolve this? Who's 13 going to reconcile this?

14 I just spent the last two years, 15 thousands of hours, thousands of dollars trying to 16 get answers to these questions and no one is 17 answering. Who is going to rectify it when one day 18 we wake up and say, "Hey, the water for the golf 19 course, the water for the nuclear power plant, or the 20 water for sewage?" 21 Dude, I don't know which agencies you 22 talked to, but I deal with land use. That's what I 23 do on a day-to-day basis. You guys have a potential 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 57nightmare on your hands. Not even talking about 1 radiation.

2 I'm going to talk about nuclear power 3 production, is there's a limited amount of water 4 that's got to go somewhere and how we're going to do 5 this resource allocation is not dealt with in this 6 document. In fact, nobody deals with it. DEP 7 doesn't deal with it in relation to this. They deal 8 with it in a segmented way. EPA doesn't deal with 9 it. That's right, 316a and 316b, it's not right yet, 10 so we can't deal with that.

11 So, we have all of these fragmented 12 regulatory bodies out there. This concerns me. This 13 is aside from the, this is just completely aside from 14 the debate on whether nuclear power is good or bad.

15 I'm not even having that debate.

16 The debate that I'm having with you is 17 that water is a valuable commodity. It's limited.

18 Who the hell is going to decide where it goes, when 19 it goes, and if it goes? And we have a crisis, I 20 believe, on our hands.

21 And I think people -- in fact, today at 22 the legislature we just passed, out of committee, the 23 potential to box $750 million to break a badly broken 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 58Pennsylvania water infrastructure. Our water and 1 sewage systems are failing, yet we're going to give 2 these guys, who made roughly $860 million last year, 3 a free pass on 20 years. Something's got to be 4 looked at.

5 My concern is this, and I'm not asking 6 you guys to do this, I know you have an 7 administrative charter and a statute, and I'm not 8 asking you to go beyond that charter, which is 9 inherent.

10 What I'm asking you to do is not to decay 11 into this regulatory fragmentation protocol where you 12 just hold your arms back and say, "I'm not looking at 13 that," because that is, and the new word I got over 14 the last two years, regulatory creep.

15 Pick up the phone. Call your colleague, 16 "Dude, are you looking at this? Are you not looking 17 at it? What's happening?" Nobody picked up the 18 phone last year. TMI, Mike can talk about it. All 19 of a sudden the water was reduced, turnpike collapses 20 a bridge. We had this going on and that going on.

21 My god, people aren't talking.

22 It's not just this -- I mean, what 23 strikes me is how similar this is to when a developer 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 59 comes in and wants to build a community, and then 1 makes believe there's no other communities being 2 built, or any other resources. This is insane, guys.

3 This is insane.

4 Again, put aside whether you're pro or 5 anti-nuclear. This is not good. PPL will face water 6 chemistry issues, biofouling, aquatic challenges.

7 That's going to happen. They've acknowledged it. We 8 all acknowledge it. And that may impact your 9 operation abilities.

10 It seems to me that the SRBC and the NRC 11 is saying don't worry about it, because it's in our 12 best interest to solve it. Nobody's asking, maybe we 13 should worry about it, because maybe they're taking 14 shortcuts to satisfy their bottom line. That's what 15 concerns me. You know, logic would tell you, yeah, 16 it's in your best interest. You want to have the 17 best equipment and the most robust equipment, the 18 inspections. It takes people. Look at the number of 19 people working at the plant.

20 We'll get at that later, which is really 21 interesting, because that number that you accepted is 22 kind of startling. That's the water issue. I've 23 resigned myself to the fact that those issues aren't 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 60 going to get solved here or at the SRBC, so I sued 1 you and we're in federal court.

2 But I'll tell you this, and anybody who 3 knows me, there will be answered. And I'll take you 4 guys wherever I have to take you. You're going to 5 answer the questions.

6 And the irony is I've never opposed re-7 licensing of this plant. I've never opposed the 8 upright. I've just asked to have you guys answer the 9 questions. How hard is that? I'm going now onto 10 year two asking the same questions, no response.

11 It's insane.

12 The most troubling thing to me are the 13 socio-economics. I live in the world of public 14 policy. And you have a 29 county rate base here, 15 about 2.3 million customers. It's a very unique, 16 very loyal rate base, and if you look at the PUC 17 standards to PPL's credit, they haven't lost many 18 customers. That's going to change. The rates are 19 going to go up 34.5 percent.

20 I saw nothing in this document about rate 21 check. How can that not be a socio-economic impact?

22 Now, I'm one of the prime negotiators with this. I, 23 look, PPL will tell you, I assume every time they 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 61breathe. I don't like doing it, but 34 2 percent 1 rate increase.

2 These are for people, mostly seniors, who 3 are having a hard time now, on a fixed income, 4 filling up their gas tank and taking care of health 5 insurance. Not a word. Thirty-four and a half 6 percent.

7 Think about that. If that's not a socio-8 economic impact, I don't know what is. Rate shock 9 doesn't fall in here. In fact, here's a quote 4-50 10 foot, "There will also be no disproportionately 11 higher adverse health or environmental impact or 12 result on minority or low-income populations in this 13 region.

14 Now let me read to you, just to show you 15 where I'm coming from. In an aging population base 16 affects staffing, I mean, just in general, affects 17 staffing, off-site support staffing, response times, 18 emergency planning and social services. These human 19 components are critical ingredients than the 20 infrastructure of any large industrial complex.

21 You want basically, when you do your 22 planning, you want people at all different sectors of 23 the age base. Not necessarily top-heavy on the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 62bottom, and not necessarily top-heavy on the top. On 1 the bottom you have Africa, on the top you have Boca 2 Raton. That's a weird conflict.

3 The ripple impact was not discussed in 4 the GEIS. Transportation and support services were 5 limited to two paragraphs. Now, I'm sure you did 6 more of that, but there were only two paragraphs.

7 With a steadily aging population, I want 8 you to think about this, where are the EMS and EMT 9 technicians, paramedic fire service providers going 10 to come from in a state, and in sector, and this is 11 Pennsylvania, built on volunteerism?

12 I do municipal planning every day. It is 13 hard and I love those guys. The fire police guys, 14 the EMS guys, the EMT guys. Where are you going to 15 get these people in an aging sector?

16 Now, in 2003, just to give you some 17 numbers, 16.2 million patients across the country 18 arrived by ambulance in emergency department visits.

19 No different than here at Geisinger or wherever.

20 That's 31 ambulances arriving at an emergency room in 21 America every minute.

22 Of those, 40 percent were senior 23 citizens. And you'll see where I'm going with that.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 63 So, 40 percent of the people making emergency room 1 visits are senior citizens.

2 So, let's look at our demographic. Who's 3 going to take this population to the emergency room?

4 The Bureau of Labor Statistics has calculated the 5 average age and the median years of tenure for 6 persons in any specific occupation, easy to get, real 7 easy to get and it's updated annually.

8 This data is obviously useful for career 9 planning, understanding turnover for my daughter, for 10 moving out of the house, whatever. Okay? The 11 average age of workers in this occupation, which is 12 EMS technician, fire police, is 34.3.

13 So, this population is getting older.

14 The ability to get people to take them to the 15 hospital is going down. Now, the average age for 16 most occupations is 38. PPL and the NRC never asked 17 this question. What happens to an aging population 18 when we need to staff a nuclear power plant and when 19 we need to take a visit to the emergency room? Who's 20 going to take them there? It's an inverse 21 relationship.

22 If that's for me, tell them I'll be back 23 later. Didn't we say turn off the cell phones?

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 64Somebody didn't get the memo. All right. PPL and 1 the NRC have failed to ask, let alone answer, who's 2 going to transport and provide the emergency services 3 for an economically distressed population in need of 4 medical services.

5 So, let's take it one step further. You 6 guys spend a lot of money doing this and I appreciate 7 it. You did the scoping. You did the evaluation.

8 You did this, that and the other thing.

9 You never examined the impact of re-10 licensing on aging human beings who live within the 11 shadow of the plant, and this is a disproportionately 12 older population.

13 So, let's look at the numbers. In 14 Lucerne county, the population declined almost 2 15 percent between 2000 and 2003. In Columbia, it was 16 almost a 1 percent decrease.

17 The U.S. Census Bureau reported that the 18 average population of 65 years or older, per county 19 it's 12.4 across the country; and in Lucerne county 20 it's 19.7, 20 percent 65 or older; and at Columbia 15 21 percent; and Salem Township, which hosts the plant, 22 20 percent of the population is 65 or older.

23 Didn't see any of this data in there, 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 65although I did see some DLE statistics. Columbia and 1 Lucerne county are two of the six counties in the 29 2 county rate base. That's PPL, "Above the system 3 average percentage on the poverty level," PPL's 4 figure.

5 So, PPL is telling you they've got older 6 people -- well, we're telling you the number of older 7 people, active seniors if you will, are way above the 8 norm, PPL's telling you in their report to the PUC 9 that the older people that we do have are above the 10 norm in terms of being, you know, challenged in 11 paying their bills.

12 The bureau indicated that 22.8 percent of 13 Lucerne county, and 23 percent of Columbia county 14 populations qualify as low-income households eligible 15 for energy assistance, living or below the federal 16 poverty line.

17 The other thing to look at is when you 18 take that number and break it out, people that are at 19 that level, at or below poverty lines, are less 20 likely to volunteer to provide the emergency and 21 medical technician service. So, there's a 22 correlation.

23 What I'm saying to you is people are not 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 66 abstract hypotheticals that you can rework into some 1 formula in a back room in D.C. Taken together, both 2 counties are holding older Pennsylvanians less likely 3 to be absorbed into a nuclear workforce.

4 The reality is Pennsylvania is the third 5 oldest state. Our fastest growing population are 6 octogenarians. That's reality. Fastest growing 7 population are octogenarians, people being over 80.

8 So, we are going to continue to age.

9 Where are we going to get the workers from? That's 10 something we just don't do at this plant, but we have 11 a brain drain occurring throughout the state.

12 These senior citizens are concurrently 13 paying higher electric rates and more in property 14 taxes as a result of the plant. The company has not 15 anticipated or planned to address the hardships that 16 it created for the 65-plus community.

17 I asked this in 2006. This is my 18 question from a hearing. Have you planned for this 19 community? Here's the quote, "PPL Electric has 20 conducted no polling to gauge residential customers' 21 awareness of rate caps, and the impact that removing 22 these rate caps will have on electric rates."

23 So, my opinion, failure to survey the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 67 impacts of the licensing on an aging community is an 1 indictment on your inability to grasp the good 2 workforce and solid community are intangible points, 3 interchangeable parts.

4 Now, I know this is different than other 5 places you go. The point I'm trying to make is I 6 think we have to move away from the generic 7 boilerplate model. I mean, it's clear that this is 8 an aging population, a good population, good schools, 9 good folks, religious folks. It's a place where you 10 want to be, have a plan. Folks are getting older.

11 How do we retain them? I mean, and that's what we're 12 working on.

13 On the tax issue, it was interesting, 14 because I do appreciate the amount of work that went 15 into it, but it was interesting, because you didn't -

16 - by the way, did you guys read, do you read their 17 annual reports when you do this? Do you read the 18 annual reports? Do you read the SEC reports? Do you 19 read the 10k reports? All right, but did you read 20 the annual report this year?

21 Let me, an interesting spin on the taxes, 22 and this is something you may not capture in other 23 states, look, deregulation shifted power plants back 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 68 to the local tax rolls under the assumption utilities 1 would pay at least the same as they had paid, you 2 know, subject to real estate costs.

3 This company basically picked up 2.86 4 billion in stranded costs, which is interesting, 5 because we keep talking about economics, but when 6 this plant was built, it was basically twice as much 7 as predicted. It was predicted to be 2, came in at 8 around 4. I'm rounding the numbers.

9 So, it will be interesting to see where 10 they come in with the next plant, which I don't think 11 is going to be built. But these economics come back 12 and hit the same people that I've been talking about, 13 seniors. If you're on a fixed income and you're 14 paying higher electric rates, watch what happens to 15 your taxes.

16 I think both of the analysis that you use 17 and the company use are flawed. PPL's analysis is 18 interesting, because I think it's limited to a, I 19 think a five year snapshot, 2001-2005. I think your 20 snapshot was about the same. It didn't look at pre-21 PURTA, or PURTA numbers.

22 So, you basically compressed it and 23 flattened it out and you don't have a really 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 69congruent perspective. But what's interesting is the 1 amount of money, if you put it out on a graph and 2 plot it, it's very interesting. The amount of money 3 the company's making versus the amount of money the 4 taxes they're paying.

5 So, while the one is flat the other one's 6 high. Now, if that's the case, and in America we 7 like to see that, that's a business being profitable.

8 Good for them.

9 If that's the case, there's no reason to 10 recover stranded costs, 2.86 billion. The rate payer 11 gave them 2.86 billion, because they couldn't recover 12 the costs in the marketplace. They're exploding with 13 profit.

14 So, basically they're double dipping, and 15 I'll show you what we're talking about. This is 16 according to the president of the company in an April 17 4 letter to the shareholder. I am a shareholder.

18 "PPL's total return has been 254 percent," more than 19 three times return on the S&P index over the last 20 five years.

21 So, the same time that you compressed 22 your snapshot on taxes, you didn't look at the 23 earning ability, or the ability of this company to 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 70 pay taxes, nor did you take a historical snapshot to 1 see what their contributions were when they first 2 began in operation and what they are now.

3 Longitudinal perspective, basic economics, would love 4 to see you do it.

5 Let's look at what they paid in 1984.

6 Let's look at what they paid now. Let's look at how 7 much they're making. You know, you just take these 8 charts and compare it. Same thing with the RIS.

9 Let's just, I mean, I can help you with these metrics 10 and I'll charge you less than the Argonne guy, 11 guaranteed.

12 What's interesting to me, and I don't 13 know how you did this, the staffing level I think 14 came from the Chamber of Commerce, it didn't come 15 from the company. So, PPL will have to acknowledge 16 whether or not, I noticed all the numbers were round.

17 One thousand people working at the plant 18 is proportionately, per reactor, much lower than any 19 other reactor in this state. That's an interesting 20 correlation, and this all ties together.

21 What I'm wondering is if it's an older 22 workforce and you're not able to pull people. Is 23 that the reason why they have less people per reactor 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 71 working, or maybe they're saying they're a better 1 company. I don't know.

2 The number I got was 1000. Did anybody 3 probe that, or you just republished it? I mean, if 4 you look in your, you basically just take your 5 Chamber of Commerce numbers that says PPL, 1000 6 employees.

7 What's interesting, we don't say union, 8 non-union. We don't look at the employees they had 9 five years ago, ten years ago compared to what we 10 have. If you read the annual report, you'll see that 11 we're down about 20 percent.

12 So, if you took that trend and projected 13 it into the GEIS, it would be safe to assume that the 14 number of people working at this plant is going to 15 continue to trend downwards. The number of people 16 paying taxes, trend downwards. PPL has a lot of 17 people doing great volunteer stuff, trending 18 downwards, never captured in here.

19 It's interesting, because I'm usually not 20 a fan of Peach Bottom or TMI, but proportionately 21 their numbers are much higher. I would assume the 22 numbers they gave you does not include security 23 personnel. Nor is there any trending done for what 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 72 most businesses do now, retirements, attrition, 1 early-out, full-time versus part-time, outsourcing.

2 I'm a member of the American Nuclear 3 Society. Everybody in this room who works for the 4 industry is aware that the nuclear industry is, we're 5 going through an institutional shock. You know, most 6 people are leaving. We don't have the same core 7 people you used to have.

8 Here I am, a guy who's been known to be 9 anti-nuclear, saying, "Yes. You actually need to 10 beef pro-nuclear engineering, because we need people 11 to staff the plants." I mean, you look at the last 12 ANS publication, it was almost totally devoted to the 13 fact that you don't have enough people working in the 14 field. 15 If you don't have enough people working 16 in the field, and you don't have enough people 17 regulating in the field, why wouldn't it be captured 18 in your GEIS? Who's going to work at the plant down 19 the road? Are they going to be coming from a 20 dedicated science, or do we have to basically finesse 21 the science they're at in order to make them stretch 22 into a job? Issues I'd be looking at.

23 I know at TMI, 50 out, everybody's 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 73leaving. I don't know what's happening here. I 1 don't know what the average age is. It's not in 2 here. I mean, things I think would have been 3 interesting to know when trend up.

4 I believe, and let me conclude by saying, 5 the NRC attempted to address these issues. I think 6 you did try and do it. I don't think you succeeded.

7 I'm just saying that re-licensing a 8 nuclear power plant should not impose an economic 9 hardship on the host community. That's not the way 10 it was advertised when it came in at either TMI, 11 Peach Bottom, or Susquehanna. And I have all the 12 documents when all of these plants came to the 13 community, and this is after the "too cheap to 14 meter." I know that line's been beat up, but what it 15 was going to do.

16 Just for fun, go back and look at how 17 many people worked at this plant when it came on-18 line, look at how many people work now. Look at how 19 much they're paying in taxes, and look how much an 20 economic investment. Really interesting if you can 21 get the money, or if you can get the figures.

22 You know the NRC, in my mind, must 23 reexamine the economic impact of Susquehanna on the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 74 community or address how re-licensing a nuclear power 1 plant, while shifting the tax burden and increasing 2 the rates on an aging community, is compatible with 3 your mission. I don't think it is.

4 Now, I read all the NEI stuff, and the 5 other stuff you read and everything. This is like an 6 economic microwave. It's not reality. What I'm 7 saying to you is that, before you re-license and 8 uprate the plant, it would be nice to have the 9 questions I raised issued.

10 And it would be nice to at least know 11 that you're taking some of the thoughts that I'm 12 sharing with you into consideration, so that it 13 strengthens your licensing process.

14 I'm going to conclude with a couple of 15 points. The NRC and PPL must confront unresolved 16 water use, water safety, and inter-agency issues, 17 even if they fall outside the conventional nuclear 18 toolbox. I mean, let's be proactive here.

19 Power generation, plant cooling, public 20 safety are inherently connected. There is no 21 separate imaginary fence between generation and 22 safety. Although that's what you guys "found" in the 23 hearing when you denied my contentions.

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 75 I think we've demonstrated that aging 1 equipment, coupled with water shortages, water 2 chemistry, or invasive aquatic species, could create 3 safety challenges at the plant over the life of the 4 extension. How are we going to respond? There's no 5 plan A. There's no plan B, no plan C.

6 The impact of re-licensing on the local 7 community is material and germane, and the NRC should 8 not sanction the re-licensing of a nuclear plant that 9 will result in increased property tax burden for 10 older residents.

11 What I'm saying here is that I don't 12 think there's any artificial regulatory moat between 13 the SRBC and NRC, the EPA, or the DEP, and what I 14 would have liked to have seen and you still have time 15 to do it, is if you go down and interact more 16 aggressively with your sister, brother agencies. I'm 17 not sure what pronoun to use anymore.

18 There's got to be a better way. And this 19 is, again, where I'm coming from as a consumer 20 advocate with health insurance outpacing inflation, 21 property taxes steadily increasing, and electric 22 rates poised to spike. Can consumers afford to live 23 near a nuclear power plant that produces rate hikes?

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 76 I mean, I can't solve that riddle. Maybe you can.

1 Just a point of clarification, I just 2 want to make sure that we're all clear here. You 3 guys are aware that I have two rule-making petitions 4 filed before the NRC. You either are or you aren't, 5 because one of the rule-making petitions asks that 6 the re-licensing of a nuclear power plant be 7 contingent on the issuance of the newly approved 8 emergency plant. You're aware, I'm just asking you 9 now. That's been filed. That's been with the NRC 10 now for over a year.

11 So, that is likely to have an issuance 12 before the final process here is granted. Are you 13 aware of the other petition that we have, which is 14 asking that the relocation centers for special needs 15 populations be moved at least ten miles from a 16 nuclear power plant?

17 What I'm saying to you, again, is that it 18 wasn't happenstance that I filed them when I filed 19 them. So, I'm being really up front with you that 20 we'll contend the re-licensing of this plant if that 21 issue is not dealt with.

22 I mean, it's been there for a while. You 23 guys have held it in abeyance for a year. I think 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 77 it's wrong, but then again the petition we filed on 1 security is now seven years old. I'm not too 2 optimistic there.

3 The other thing, and I want to just, this 4 is the last question I want to end with, is if you 5 look at the annual report, by the way it's a nice 6 report, the Einstein guy there you've got to like, 7 apparently had hair lice.

8 If you go to page 105, and it doesn't, in 9 every annual report it talks about nuclear insurance 10 and just let me read you this: "PPL Susquehanna is a 11 member of certain insurance programs that provide 12 coverage for property damage to a member's nuclear 13 generation station. Facilities at the Susquehanna 14 Station are insured against property damage as 15 losses, up to 2.7 billion, under these programs."

16 Final thought is this, the people I just 17 talked about and advocated for, they're senior 18 citizens on a fixed income. Those people are having 19 a hard time dealing with healthcare, filling up their 20 gas tank. They're going to get rate shock. Can they 21 take that insurance out on their home if there's an 22 accident, and I think you know the answer.

23 If this technology is so safe, and if 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 78 we're going to re-license the plant, don't you think 1 it's time we're at least allowed to take out 2 insurance for our plant, our home, our business?

3 But look, I'm hoping that we can bond 4 afterwards, maybe we can engage. I have extra copies 5 of my comments here. I'll be filing these formally.

6 I will read the next iteration, but hopefully you 7 understand that the criticisms are intended to 8 strengthen your process and alert you to things you 9 may have missed. Do you guys, the PPL guys there, 10 you got an extra of these? Extra for the NRC?

11 MR. LEOUS: Great. Thank you, Eric.

12 Actually, just one moment. There is another 13 gentleman that had signed up to speak, so we can get 14 to that. I have a John Zaginaylo.

15 MR. ZAGINAYLO: My name is John 16 Zaginaylo. I'm not really, really prepared for this.

17 I picked up the article in the local newspaper, 18 thought I'd better come down. My family and I 19 operate a small dairy farm and crop farm in Briar 20 Creek Township in the 10-mile, I won't use dead zone, 21 but high-risk zone. And they don't know I'm here 22 tonight.

23 My wife's home milking and my kids are 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 79 getting ready to plant corn and I should be doing all 1 that, but I want to personally say that I'm here 2 because I have significant concerns and I really am 3 concerned about what goes on with my neighboring PPL 4 plant. 5 And we have a future in agriculture here 6 and my daughter's coming home. She wants to operate 7 the farm, and just to kind of give you a personal 8 reason that it took a little effort to get here to 9 make these comments, I will provide formal comments 10 when I organize my thoughts a little better, but I've 11 got them on a little paper here right now.

12 But I also have an engineering 13 background. I'm also a registered professional 14 engineer. What is generally lacking in this 15 environment, when I looked and I quickly hurried and 16 looked on the website, there's nothing there on 17 production agriculture. I even looked under 18 endangered species and I thought it would be there, 19 but it wasn't.

20 So, production agriculture in our 21 community is real. There are dairy farms. There are 22 vegetable farms. They're very big. Certainly cereal 23 grain farms. It's not real blatant in the community, 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 80 but it's real for those of us working in it, and we 1 live in the environment.

2 The environment is part of us. So, the 3 Environmental Impact Statement is very dear to me, 4 and I'm concerned about it. And I'd like to see your 5 report, or your study, acknowledge that, and go into 6 some depth, because we're producing milk, fresh 7 vegetables consumed by our local residents and 8 outside the area. We also produce cereal grains that 9 are fed to other people. If they are, I'd like to 10 know the quality and the safety of those foods there.

11 12 Personally, they say they test dairy 13 products. I have not seen anybody test any of our 14 milk or products that we sell or raise. And there 15 are not many dairy farms in the community. I would 16 expect that we would have been approached in some 17 manner for this environmental impact.

18 So, production agriculture is completely 19 absent, and I think this thing shouldn't go any 20 further until that stone's unturned somewhat. The 21 fact that it is absent kind of alarms me, saying that 22 if they overlooked such an important part of our 23 community, even though it's not blatant to most, but 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 81what other things have they overlooked? What has 1 been glossed over and not fully developed and 2 studied?

3 I'm not aware of all of the components, 4 socio-economic one might be one, but I think we need 5 to be concerned about the volume of the document, the 6 generic of it. I'd like to see an Environmental 7 Impact Statement that's very site-specific.

8 I want to see data that I recognize, my 9 neighbor's farm, products that we market and raise.

10 The things that, specific examples of how the 11 environment can affect us, for instance, everybody 12 sees the plume and I'm not reacting to the plume, but 13 a plume means moisture in the air.

14 Heat going into the river means increased 15 temperature. Light visibility is important to the 16 crops in order to get growing through the days, and 17 getting the production, and the yields that we want.

18 And if we don't have the right amount of sunlight, 19 we're being deprived and I think it needs to be 20 looked at. Things like growing degree days and how 21 they affect crop production.

22 What's the trend over the years? Has 23 this area sustained lower production? Is the quality 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 82of our product different? I don't know for sure.

1 The other thing on the animal side, there's a lot of 2 variables that cost us money in production with the 3 dairy cows. And we're always looking for the answers 4 to resolve them.

5 For example, reproductive efficiency. We 6 kind of keep our cows a long time, so we're really 7 concerned about our animal welfare and health. And 8 part of that is breeding them back, so they stay on 9 the farm, productive and reproductive efficiency is 10 affected by many things.

11 Is it affected by the plant? Does the 12 plant affect the food that they eat, and basically 13 like selenium, or some kind of micronutrient that may 14 affect their reproductive efficiency. That's costing 15 us money. If our cows don't get bred back for every 16 month they go, it costs us a lot of money. And to 17 sustain our livelihood in our business, those 18 subtleties are very critical, something we can't 19 control.

20 So, I just challenge you, and I'll knock 21 it off closely here, that put production agriculture 22 in all aspects, dairy, fresh vegetables, and cereal 23 grains, or crop production, and look at that in the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 83 trends and how a plume, and how radiation, how 1 micronutrients an things might be affected.

2 And then, I think your report will look 3 more complete, and not so suspect that maybe other 4 areas aren't fully developed. And I'll try to put 5 those comments in writing to you. So, it's time to 6 plant corn and beans. I don't know how much I'll get 7 to you before the end of June. So, thank you.

8 MR. LEOUS: Great. Thank you, sir. And 9 for the presentation, knowing that you are busy, you 10 do have until July 21 st to submit comments. Now, Sue, 11 I know you had a comment for Eric and we can take 12 that offline at the meeting's conclusion. Does 13 anyone else have any comments on the draft 14 Environmental Impact Statement? Okay.

15 MS. FRACKE: Eric, when you were talking 16 before, and I understood you better than everybody 17 else except the last fellow, but you mentioned 18 something about that they're going to have to upgrade 19 or do something to the nuclear power plants within 20 the next three years or something. Something's going 21 to come out to do that.

22 So, would that be the reason that, if 23 they get another license renewal, that will even 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 84 further grandfather them, so they won't have to be 1 into that upgrading thing?

2 MR. LEOUS: Actually, Eric, I can take 3 this here.

4 MR. EPSTEIN: Okay.

5 MR. LEOUS: If we could just --

6 MR. EPSTEIN: Yes. I was talking about 7 Exelon and I think their strategic architecture was 8 in the next three years to re-license all their 9 plants, to have uprates at all their plants. I think 10 PPL, and they're here, they can correct me if I'm 11 wrong. I think this is their third uprate. They've 12 had two other uprates.

13 But I think most power plants across the 14 country, I'm not sure I know of any that hasn't had 15 an uprate, which is increasing their capacity.

16 So, I would imagine PPL is better suited 17 to answer this, that, and maybe the NRC can answer 18 this. I think most plants now are going for re-19 licensing, and concurrent with that, an uprate. Does 20 that seem to make sense?

21 MR. LEOUS: Eric, you have experience 22 with this.

23 MR. BENNER: Yes. Essentially, the --

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 85 MR. EPSTEIN: I'm responding to Sue's 1 question. What I'm saying generic that I think most 2 plants, I know all plants have uprated. I think PPL, 3 this will be their third uprate. It's probably the 4 largest. I think many plants now that are re-5 licensing are also coming in with an uprate request.

6 MR. BENNER: Yes. I wouldn't think it 7 was many. You know, we have regulations for what an 8 applicant needs to do to renew their license, and we 9 have regulations for what an applicant needs to do to 10 do a power uprate.

11 And just for explanation purposes, there 12 are different types of power uprates. What they do, 13 for the different types, is allow the plant to 14 operate at a higher power level.

15 So, when we say uprate, you know, if a 16 plant puts out 1000 megawatts, it would allow a plant 17 to put out 1100 megawatts. So, with that, depending 18 on the size of the uprate means different equipment 19 changes that need to be made to the plant.

20 MR. EPSTEIN: I don't want to run this 21 out. There's two different processes. Re-licensing 22 a plant is a much more in-depth process. Uprating is 23 something that occurs frequently. I guess my 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 86 question to you is, you can uprate a plant without a 1 re-license and I think that every plant in the 2 country, unless I'm missing something, has had at 3 least one uprate.

4 MR. BENNER: Yes. I don't know the 5 statistics. I don't think that's the case. I mean, 6 I think there are a number of plants that haven't 7 gone through power uprates. Whether they do or not, 8 whether they apply to or not, is their decision, 9 which I would guess would be based on economics.

10 Whether or not we approve the uprate is based upon 11 assurance that operation at the uprated power levels 12 would be safe.

13 MR. EPSTEIN: Let's just cut to the 14 chase. I mean, I'm actually using the NEI numbers.

15 Let's say it's 90 percent of the plants that have had 16 an uprate. Almost all the plants have had an uprate.

17 It's rare that it's rejected. It's rare that a 18 license is rejected.

19 So, there's two currents going in here.

20 A plant comes in and asks to be re-licensed. None 21 have been rejected so far. I think there have been a 22 couple of uprates that have been rejected.

23 But what I'm saying to you is the trend 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 87 is this, plants are getting re-licensed for 20 years, 1 they're getting uprates. There's very few 2 exceptions. Is that a correct -- I'm asking you, 3 unless I'm missing something. Is that not a correct 4 trend? 5 MR. BENNER: I think the trend, and this 6 goes back to the comment you made about contentions 7 being admitted, is after the original round of 8 licensing of these plants, I think the NRC factor 9 those lessons into its licensing processes to look at 10 those issues that were admitted the first time 11 around. And I think the industry, 12 realizing that these licensing processes are 13 challenging, and anyone who has delved into the re-14 licensing requirements, if you look at our 15 regulations, and you look at our, we have for the 16 staff's review we have a standard review plan, which 17 is new regulation 1800, which outlines the things the 18 staff has to look at.

19 We also have an environmental standard 20 review plan, which is new regulation 1555, which 21 outlines the environmental issues the staff has to 22 look at. We have regulatory guides, which tell the 23 industry what information they need to provide.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 88 I think we've all grown to a point where, 1 before an applicant applies, for either a renewal or 2 power uprate, they put the energy into developing the 3 information we need to assure that the plant can 4 operate safely under either of those conditions.

5 MR. EPSTEIN: Let me just --

6 MR. LEOUS: One second here.

7 MR. BENNER: There's no trend, per se.

8 It's an application, it's generally only going to be 9 submitted once the applicant has developed adequate 10 information to meet the commission's regulations.

11 MR. LEOUS: Right. And, Eric, not to 12 interrupt. What I would like to do is, and in no way 13 to stymie this dialogue, however, I would like to 14 bring this meeting back to the purpose in terms of 15 discussing the draft Environmental Impact Statement.

16 And I would encourage this dialog to continue, but 17 what I'd like to do is stick a pin in it for now, and 18 -- 19 MR. EPSTEIN: Well, let me just make a 20 point here, because I think at issue is, because I 21 don't know where else to ask this question, is the 22 generic application of how you re-license plants.

23 And basically you're saying you've learned your 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 89 lessons, and you're taking those lessons learned from 1 the first time around.

2 The lesson you haven't learned, and this 3 is what concerns me, is the hubris that exists.

4 Prior to 1979, there was this arrogance that 5 permeated the industry and the NRC. I'm seeing it 6 come back. I'm willing to concede things have gotten 7 better, and you've learned some lessons.

8 But for you to come here and say there's 9 no trend, or we basically learned all the lessons we 10 need to learn. Let me just point something out to 11 you. When we intervened on the re-licensing of unit 12 2, had we not raised a contention of a reinforced 13 containment structure, that was us. That was us, not 14 you guys. We raised it.

15 The TMI 2 accident would have been much 16 more severe. We raised it, because nobody wanted to 17 examine the proximity of a nuclear power plant near 18 an airport. I mean, that's insane.

19 So, what I'm saying to you, none of us in 20 this room can say that we've learned all the lessons, 21 or we need to know what we have to do. As you're 22 constricting the process, all I'm pleading you to do 23 is to think about widening the process.

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 90 Arrogance is a very dangerous emotion.

1 That's what I'm seeing here. And I don't, look, this 2 is the third re-licensing I've been to. I'm not 3 doing any more, because essentially I think it's a 4 farce. I think it's clear you know how I feel.

5 But, man, you've got to have an open 6 mind. You've got to be willing to concede that other 7 people have comments, concerns, issues raised that 8 can make this process stronger.

9 But every plant has been re-licensed.

10 Very few uprates have been turned down. You know, 11 that's like an election in Syria, and I wouldn't call 12 Syria a democracy, and I wouldn't call this an open 13 and transparent process.

14 So, I've got to tell you, you know, have 15 you gotten better? Yes. I lived through TMI. I've 16 done Peach Bottom. Yes, things have improved, but to 17 sit on your laurels and be content, Eric, it's 18 dangerous. That's my warning to you.

19 MR. LEOUS: Great, and --

20 MR. BENNER: I appreciate that.

21 MR. LEOUS: And again, I think this is a 22 great dialog that we should continue, you know, after 23 this meeting. But to bring things back to the 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 91 purpose of the Susquehanna draft supplemental 1 Environmental Impact Statement, barring no further 2 comments on the document, I'd invite Eric to wrap up.

3 MR. BENNER: And I think that's a perfect 4 segue to my wrap-up, because I don't think we're 5 sitting on our laurels. I think by virtue of the 6 fact that we actively solicit public comments, both 7 in the scoping process and in this meeting. All we 8 can do is solicit. We can't require people to come 9 to this meeting.

10 MS. FRACKE: If they all knew the truth, 11 they'd be here. You guys lie so damn much. You 12 don't give a damn about anything but your money. I'm 13 disgusted.

14 MR. LEOUS: Sue, I just ask you to --

15 MR. BENNER: Yes.

16 MR. LEOUS: -- while Eric finishes up his 17 final comments. Thank you.

18 MR. BENNER: Yes. I think I allowed you 19 to speak and I would appreciate the same 20 consideration. May I? As I said, we have an active 21 program to solicit comments on the environmental 22 review. That's our purpose here tonight.

23 I appreciate all of the comments you 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 92provided. Several of these comments have been 1 provided previously and have been addressed in the 2 EIS. Several comments we've heard tonight are new, 3 and those comments will be addressed in the final 4 Environmental Impact Statement.

5 The purpose of this review is the 6 environmental impacts. There are other avenues to 7 engage the NRC, and Eric, you've articulated that 8 you've engaged several of them, the hearing process 9 by submitting contentions. We endorse that. We 10 encourage that.

11 I don't think we're sitting on our 12 laurels. I think no one in the NRC believes that the 13 process hasn't been strengthened by the active 14 involvement by the public, and we would continue to 15 encourage you to do that.

16 With that, like Drew said, we will be 17 accepting public comments for another period of time.

18 The slides we handed out provides the mechanisms by 19 which you can provide public comments. With that, we 20 do appreciate your time and your attendance. And I 21 wish you a good evening. Thank you.

22 (Whereupon, the above-entitled meeting 23 was concluded at 8:46 p.m.)

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