ML071780024

Transcript of Public Meeting Big Rock Point, on Thursday, November 13, 1997, Pages 1-84

ML071780024
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Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	11/13/1997
From:	Office of Nuclear Reactor Regulation
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ASB-300-41
Download: ML071780024 (86)

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OFFICIAL TRANSCRIPT OF PROCEEDINGS UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

Title:

PUBLIC MEETING BIG ROCK POINT Docket No.:

Work Order No.: ASB-300-41 LOCATION: Charlevoix, MI DATE: Thursday, November 13, 1997 PAGES: 1 -84 V'

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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3

4 5 PUBLIC MEETING 6 BIG ROCK POINT 7

8 9 Stroud Hall 10 12491 Wailer Road 11 Charlevoix, Michigan 12 13 Thursday, November 13, 1997 14 15 16 The meeting met pursuant to notice at 6:30 p.m.

17 18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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2 1 PROC E EDI N GS 2 [6:30 p.m.]

3 MR. JOHNSON: If I can have your attention now.

4 My name is Phil Johnson. I am chairman of the Charlevoix 5, County Board of Commissioners, and I will be serving as your 6 moderator tonight. Tonight's public meeting is held by the 7 U.S. Nuclear Regulatory Commission. It is designed to focus 8 and share information concerning Consumers Power's decision 9 to immediately dismantle the Big Rock nuclear plant.

10 Making the presentation tonight will be Mr. Jim 11 Rang of Consumers Energy. Mr. Rang is manager of business 12 and regulatory administration for Big Rock. He will discuss 13 the Proposed Shutdown and Decommissioning Activities Report 14' for Big Rock Point.

15 Mr. Paul Harris of the NRC is in the Office of the 16 Nuclear Regulatory Reactor. Regulation of Non-Power Reactors 17 and Decommissioning Projects, and he will discuss the 18 regulatory process involved in decommissioning a nuclear 19 power plant.

20 We have Mr. Bruce Jorgensen of the NRC's Division 21 of Material and Safety. He will describe the NRC's 22 decommissioning and inspection process.

23 This is the third meeting to be held to discuss 24 the proposed decommissioning activities at Big Rock Point.

25 Your comments are valued. If you have a comment or ANN RILEY & ASSOCIATES, LTD.

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3 question, we ask you to stand, state your name and also 2 spell it. If you can talk a little loud, we have a court 3 reporter here, she will be taking all the notes tonight, and 4 this is going to be a recorded meeting and it is going to be 5 a public record.

6 We thank you for your attention, and if you have 7 any questions? If not, Mr. Jim Rang.

8 MR. RANG: Thank you, Phil.

9 MR. JOHNSON: One other thing. If you want a copy 10 of the proceedings tonight, there is a sign-up sheet in the 11 back.

12 MR. RANG: I have copies of my presentation that I 13 am going to be going through with you. Perhaps we can hand 14 those out.

15 We are pleased to be here tonight to discuss our 16 decommissioning plan. I think we probably set a record.

17 This-is our third opportunity to discuss the decommissioning 18 planning process, but now that we are into it, it is another 19 opportunity for us again to walk you through what the 20 planning process is all about within Consumers at our Big 21 Rock site.

22 Before I get started, let me introduce some of our 23 people from Consumers that are here tonight.

24 Bob Fenech is our senior vice-president of fossil, 25 hydro and nuclear operations.

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4 1 Ken Powers. Ken is our site manager, site and 2 decommissioning manager.

3 We have Ken Pallagi, who is our radiation and 4 environmental manager.

5 Dr. Bob English is our corporate health physicist, 6 our radiation health physicist specialist.

7 We have Don Hice. Don is our plant manager.

8 Craig Szczopka next to him from our corporate 9 office, nuclear plant administration services or our quality 10 assurance manager.

11 Harry Linsinbigler. Harry is the purchasing and 12 materials manager here at the site.

13 Curt Jurgens. Curt is our construction manager.

14 It's nice of you guys to all sit in a row there.

15 [Laughter.]

16 MR. RANG: Greg Debner. Greg is manager of our 17 reactor fuels project.

18 Tim, I know Tim Petrosky is here. Tim is our 19 public affairs director.

20 Karen Wooster. Karen is here. She is our 21 emergency planning director.

,22 Ellen Zienert, our human resources director, way 23 in the back.

24 Did I miss anybody?

25 Greg Withrow is our engineering manager..

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5 1 I-guess Bill Trubilowicz is not here, is' that 2 correct?

3 We have got most of our, essentially all of our 4 managers here from the site that are leading us into and 5 through the decommissioning process. Once I finish mine and 6 I turn it over to Paul, then Paul will introduce the NRC 7 people, his people that support him.

8 We have some people from the state.

9 Dave Minard and Dennis Hahn.

10 Anybody else that we have? Ron Kallin.

11 I am going to take you through some of the 12 planning processes that we went through, and if I happen to 13 slip into nuclearese, please raise your hand and I will go 14 back and-state what those are. Sometimes it is too easy for 15 us to do that. I will try to be vigilant of that.

16 This is my agenda. We are going to go through our 17 team priorities that we identified and laid out for our 18 decommissioning process as well as I am going to spend most 19 of my time discussing the Post Shutdown Decommissioning 20 Activities Report. This is-the decommissioning document 21 that is formally submitted to the Nuclear Regulatory 22 Commission, and it is made up of four parts, and I am going 23 to come back and visit those four parts. Scope, cost, 24 schedule, and environmental assessment, it is basically what 25 the decommissioning process is all about, and then I will ANN RILEY & ASSOCIATES, LTD.

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6 1 summarize.

2 In developing our team priorities, the entire 3 staff worked at putting these together, and we came up with 4 three areas we felt we would need to address to lead us 5 through the decommissioning process. Not unlike what we had 6 during power operation. Safety, efficient restoration, and 7 future of our people, of our plant and people.

8 First of all, dealing with the first part, the 9 first priority, the safety component, there is really three 10 parts to that: Nuclear,, radiological and industrial.

11 Safety is a priority that we are quite proud of throughout 12 our 35 year plant operati~on history at Big Rock, and it is 13 our intent to carry that same safety record all the way 14 through the decommissioning in all three of those areas. We 15 want to maintain that throughout the decommissioning 16 process.

17 Now-on the nuclear safety side, while the plant is 18 not operational, it is shut down, we still have rules and 19 regulations by which we operate the spent fuel pool, where 20 the spent fuel is stored, and all of the support systems,

.21 and also throughout the storage of fuel, both in the fuel 22 pool as well as in the dry cask portable canister system.

.23 It is our intent to and under requirements to meet those 24 regulations and continue our safe operation through those 25 systems. Even though the risk of power operation is not ANN~ RILEY & ASSOCIATES, LTD.

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7 1 there, we still have the nuclear safety issues that we need 2 to address surrounding fuel, and we have set up a program' to 3 do just that.

4 In the area of radiological, we have committed to 5 dose reductions, ALAPA, which is as low as reasonably 6 achievable for both the site people working at the site as 7 well as the general public. As you will see, as I go 8 through, we have set up our priorities to do just that, and 9 I will cover a few of those activities in a few moments.

10 Then also industrial safety. We are quite proud 11 of our 20 years without a lost time accident. We have led 12 the nation for some time in industrial safety, and it is our 13 intent to continue that same safety record throughout the 14 decommissioning process.

15 -Going through the decommissioning, in some ways, 16 because of the construction site that we have, the removal.

17 of equipment, the scaffolding and so forth, there is a 18 greater risk of safety issues that may come up. So we have 19 to be very vigilant to maintain our industrial safety.

20 I think we at the site would like nothing better 21 than -- I mentioned we just recently celebrated our 20 years 22 without a lost time accident. It is our objective in five 23 years for Mr. Fenech and Mr. Powers to receive a citation 24 for going 25 years in the nuclear industry without a lost 25 time accident. It is going to be 'quite a goal, but we think ANN RILEY & ASSOCIATES, LTD.

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8 1 we are up to achieving that.

2 The next priority, efficient restoration. It is 3 our intent to use all of our resources productively, to 4 decommission the plant and restore the site to green field 5 condition in five years, and not only to do it in five 6 years, but to do it under budget. That also will be a goal 7 that we expect to achieve, and we have set our standards 8 high to accomplish that.

9 Our third priority -- we think if we take care of 10 the first two, that if we do 1 and 2 well, that the third 11 priority will take care of itself, and that is establishing 12 future opportunities for our people once the plant is 13 decommissioned.

14 It is our intent to be able to market our services 15 after the plant is decommissioned, but we can only do that*

16 if we are successful. Now if we are good and we are 17 successful, our rewards will be what? We work ourselves out 18 of a job in. the next two years, three years, four years or 19 five years. But if We are successful, we will also create 20 new opportunities for our people, and that is what our 21 objective is, to attempt to do that, and be able to provide 22 a future for our people not only here following Big Rock, 23 but,then also perhaps at Palisades and at other facilities 24 throughout the United States.

25 These are the team priorities that we have ANN RILEY & ASSOCIATES, LTD.

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9 1 established to guide us through our decommissioning.

2 Mike, if you would go back to the first slide just 3 for a moment.

4 The PSDAR, there are four parts to it, as I 5 mentioned. There is the scope, cost, schedule and 6 environmental assessment. I will discuss the first part 'of 7 *that, which is the .scope of our decommissioning process, and 8 it is a flow chart that takes us through from beginning to 9 end what our decommissioning process will look like.

10 We shut the unit down in August 1997. We are into 11 the dismantlement stage. Some areas we had already -- those 12 areas that we had already prepared and had the documents 13 for, allowing us to begin dismantlement. By about early 14 2000 we expect to have the dry transportable canister 15 systems on site to allow us to load fuel from the spent fuel 16 pool into the canisters and expect to have them all loaded

17. later in the year 2000.

18 Along about early 2002, we plan on terminating our 19 Part 50 operating lice nse and then transfer the fuel that is 20 currently, the fuel storage that is currently under the Part 21 50 license to the Part 72 license for continuous storage in 22 the dry transportable canister system on an interim basis 23 until the Department of Energy picks up the fuel.

24 Our site restoration, the balance of the plant, we 25 begin that early in 2002 and finish up in 2002 getting us to ANIN RILEY & ASSOCIATES, LTD.

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10 1 the green field condition.

9~2 The fuel will be-stored on site on pads, security 3 fenced, until the Department of Energy takes the fuel, and 4 that, you know, with the passage of the bills in Congress, 5 perhaps that process may be speeded up a bit, and if it 6 does, our fuel could be. gone by the time we have finish 7 dismantling the plant.

8 In the PSDAR, we covered the scope. Now we go to 9 the cost. I am going to cover two -- I can't just talk 10 about the cost without talking about the funding. We expect 11 to be fully funded with interest earned and market value of 12 the fund within a couple of years. We are currently -- we 13 currently have, as of September, 195 million dollars in the 14 trust fund as of September 30, 1997. We are continuing to 15 collect 2.1 million dollars per month through December 2000.

16 So if you run out the numbers and then factor in some 17 interest and perhaps market value, we would easily have our 18 290 million dollars that we are authorized to collect in the 19 fund.

20 On the cost side, we filed in 1994 our cost 21 estimate of 290.1 million dollars. That was under the 22 SAFSTOR operation. We will be updating that cost estimate 23 and filing by March 31st of 1998 our new cost estimate 24 update addressing the immediate dismantlement, five years 25 and green field option, and we anticipate that no additional ANN RILEY & ASSOCIATES, LTD.

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11 1 funding will be required from the customers.

2 I have covered scope and cost. These next two 3 slides will go to the schedule and give you a summary, a 4 schedule of the activities as we work our way down, and as 5 you see in your handouts, we plan on maintaining fuel pool 6 operations into the year 2000. We expect to be dismantling 7 our equipment and have the equipment basically dismantled by 8 2001. We expect to have our dry cask fuel loaded by late in 9 the year 2000, and then we go into major building demolition 10 in 2001 and 2002 and then complete the site restoration.

11 The next slide gives us some specific projects 12 that we are working on through the decommissioning process 13 these next six to nine months. You will see here the three 14 safety issues as part of our priorities.

15 We plan on performing a primary system 16 decontamination. We will be starting -- the contract has 17 been awarded, and we will be starting in December and 18 finishing in January. The net effect of that system 19 decontamination will be to reduce the dose to our workers, 20 the radiation dose to our site workers by a factor of 10 to 21 100. We also will be installing high efficiency particulate 22 activity filters, the HEPA filters, prior to the chemical 23 decon process, which also provides the radiological safety 24 values, and then we will be installing a-radwaste 25 evaporation system to process our liquid waste, and that is ANN RILEY & ASSOCIATES, LTD.

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12 I currently in the design phase.

2 From an industrial personnel safety standpoint, we 3 are installing aL new substation arid electrically repowering 4 the site. It is kind of interesting. When you think about 5 decommissioning, you think, gee, we are going to remove 6 everything from the site. Before we can do that, and one of 7 the lessons learned from other sites that we have visited, 8 is that you need to install some things from a worker safety 9 standpoint in order to help You dismantle and decommission 10 the plant.

11 This electrical repowering of the site will remove 12 the shock hazard that is there. Let me give you an example.

13 If you go in and start working on a motor control center 14 bus, there are several breakers in that bus. In a number of 15 cases most of those breakers will be dead and will no longer 16 be used to power the facility, to power the fuel pool 17, operations. However, typically there could be one or two 18 that is going to be live in that bus work, and one of the 19 hazards you have is if you still have that bus bar in the 20 back and it's live, and if you have a worker that is in 21 removing the breakers, it is very easy to inadvertently 22' touch a live bus work. In other plants they have had 23 significant safety issues that have arisen, and one of the 24 lessons learned is to do this repowering around the site to 25 eliminate that safety concern..

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13 1 Also, one of the first things that we are 2 addressing over the next few months is removing the 3 insulation, the asbestos from piping. That will be going on 4 well into next year, and once we chemically decon the 5 primary system, that insulation will be removed as well.

6 A third industrial safety project is removing the 7 oils and lubrication. Another safety hazard that we can 8 remove and eliminate early on.

9 From the nuclear safety standpoint, some 10 additional projects is control room relocation. This will 11 allow us to more accurately operate the spent fuel pool and 12 its equipment. We are also going to reconfigure security.

13 We will be installing skid-mounted equipment in 14 the spent fuel pool to accommodate a more efficient 15 operation.

16 We will also be revising several of the documents 17 on the soft side, like the Final Hazards Summary Report will 18 be revised along with the design basis documents. We have 19 our technical specifications, our site emergency plan, 20 security plan,- quality assurance plan and fire plan that 21 have either been submitted for approval or are in the 22 process of being submitted, with all of those documents 23 being approved later on next year, probably between the 24 first and second quarter of next year.

25 The fourth component in the PSDAR, the Post ANN RILEY & ASSOCIATES, LTD.

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14 1 Shutdown Decommissioning Activities Report, is the 2 environmental assessment. We have concluded that the 3 impacts due to decommissioning Big Rock are in compliance 4 with the rules and regulations. The regulations, as you see 5 there, require it.

6 There are two decommissioning methods, two 7 decommissioning options that can be utilized: Decon, 8 immediate decon, which in our case is our five year green 9 field, and/or SAFSTOR method. Both of those were evaluated 10 f~or Big Rock, and both are fully addressed within the bounds 11 of the Final Generic Environmental Impact Statement, the 12 PGEIS.

13 We have concluded that there are no unique aspects 14 of the decommissioning plan process that would invalidate 15 the conclusions reached within the bounds of the impact 16 statement, the generic impact statement.

17 An example of one of the things that we have done 18 to ensure that we stay within the bounds is the installation 19 of the HEPA filter within containment that I des ,cribed 20 earlier as one of our projects.

21 Also, the last item is the worker doses that are 22 projected as our goal for decommissioning Big Rock are 23 considerably less than those that are referenced in the 24 *standard boiling water reactor that is described in the 25 Generic Impact Statement.

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15 1 In summary, our target is to decommission Big Rock 2 by 2002. That is green field in five years. We plan to do

.3 it safely. We plan to do it within budget. We plan to be 4 good environmental stewards of the environment, to be 5 environmentally conscious.

6 This is the plan that we submitted, Revision 1, 7 back on September 19th, to the NRC, and this is what we are 8 using in going forward. I would also state that the earlier 9 versions of the decommissioning plan and the PSDAR have 10 allowed us to go forward. This is just the next step of the 11 process.

12 I think I will turn it back to Phil. I guess we 13 will have Q and A after you and Bruce are finished.

14 MR. JOHNSON: Thank you very much.

15 Our next speaker is Paul Harris from the NRC.

16 MR. HARRIS: Good evening. My name is Paul 17 Harris. I am the NRC project manager for the 18 decommissioning of Big Rock Point. I am glad to see a 19 number of members of the public here tonight.

20 After I do my presentation and Bruce does a 21 presentation on inspection, we look forward to your comments 22 and your questions.

23 First, as project manager, I am the principal 24 point of contact for the NRC and the focal point for the NRC 25 for all activities associated with Big Rock Point. In ANN RILEY & ASSOCIATES, LTD.

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16 1 particular, I process license amendments, and I also process 2 requests for exemption from regulatory requirements. I also 3 coordinate NRC staff review of licensee activities and 4 submittals. I also work in the NRC headquarters in 5 Rockville, Maryland. However, I am not the only person at 6 the NRC who does any regulatory reviews for Big Rock Point.

7 I would like to introduce some of our staff that are 8 attending this meeting tonight.

9 My immediate supervisor is Dr. Mike Masnik. He 10 has extensive experience in regulatory processes and the 11 decommissioning of the Trojan nuclear power plant.

12 His immediate boss is Sy Weiss. Sy is the 13 Director of Decommissioning of Nonpower Reactors.

14 From Region III we have Mr. Roy Carniano. He is 15 Deputy Division Director of Nuclear Materials Handling.

16 Also we haveMr. Bruce Jorgensen, who is the 17 Branch Chief of Region III.

18 Mr. Roy Leemon, the senior resident at Big Rock 19 Point. Roy is our on-site inspector. The current plans are 20 to keep Roy on site for approximately one year in direct 21 oversight of licensee activities.

22 Also with us we have Ms. Ann Hodgdon. She is our 23 lawyer from headquarters, from Rockville.

24 We also have Mr. Jim Shepherd. He is a project 25 manager out of the Office of Nuclear Materials, Safety and ANN RILEY & ASSOCIATES, LTD.

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17 1 Safeguards. His division has the primary review on the 2 license termination plan that Big Rock Point will be 3 submitting.

4 We also have Etoy Hylton, who is at the desk back 5 there. She is our licensing assistant. She basically keeps 6 us out of trouble, and she helps us process amendments and 7 exemptions.

8 I would like to cover -- pardon me. Etoy just 9 flagged that I missed Ms. Angela Greenman. She is our 10 public affairs officer out of Region III.

11 And Lee Thonus. I am glad Lee is here tonight.

12 Lee is the Project Manager at TMI Unit 2. Lee has extensive 13 experience in the decommissioning activities at TMI Unit 2 14 following the accident that occurred at that facility. I am 15 happy to have him here.

16 I would like to cover some history first with Big 17 Rock Point.

18 As indicated by Mr. Rang, in 1995, Big Rock Point 19 submitted their decommissioning plan. The plan they 20 provided provided specific information on how they intend to 21 store, dismantle, maintain and decontaminate the facility.

22 This facility includes structures, systems and components 23 that are radioactive. Their proposed schedule utilized the 24 27 year SAFSTOR period, and this was to allow the decay of 25 radioactive materials, radioactive isotopes, prior to any

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18 1 major dismantlement activities.

2 Also in this plan there were descriptions on how 3 they planned to accomplish specific decommissioning and 4 decontamination activities, the expected occupational doses, 5 and a site-specific decommissioning cost estimate. They 6 also provided a supplement to their environmental report to 7 discuss the decommissioning of their facility.

8 In the decommissioning plan they described their 9, intent, as Mr. Rang indicated, to restore the site to a 10 green field condition. In this submittal, however, 11 Consumers did recognize and did state that they maintain the 12 option of pursuing immediate dismantlement of the facility 13 after shutdown should a low level waste site become 14 available.

15 Following the submittal of the decommissioning 16 plan, we held a public meeting in May of 1995 to discuss the 17 decommissioning plan with the public, and Consumers Energy 18 again provided some specifics regarding their plans. And 19 again this was 1995 so everything they were doing was their 20 best guess estimate of what would occur.

21 However, in July of 1996 the NRC amended their 22 decommissioning rules, and these rules were published August 23 26th. So as not to get caught between the old rules and the 24 new rules, Consumers Energy asked us to delay our review and 25 approval of their decommissioning plan to allow them time to ANN RILEY & ASSOCIATES, LTD.

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19 1 assess the new rule.

2 In August of 1996, the amended rules became final, 3 and then we held another meeting in March of 1997, and this

,4 meeting was held here and was held to discuss how the rules 5 changed for decommissioning, and it provided Consumers 6 Energy another opportunity to explain their plans for 7 decommissioning. Again, they discussed their intent to go 8 into 27 year SAFSTOR. However, they again maintained the 9 option to pursue immediate dismantlement and decontamination 10 should a low level waste site become available.

11 To summarize what we discussed in March, we 12 discussed the rule-making change, and we discussed the fact 13 that the decommissioning plan was now called the Post 14 Shutdown Decommissioning Activities Report. We discussed 15 why it's the licensee's decision on how to decommission the 16 plant, whether to pursue immediate dismantlement, or to 17 place the plant into long-term safe storage. We also 18 discussed why NRC's review and approval of the 19 decommissioning plan was no longer necessary, bearing in 20 mind that NRC's review and approval of the license 21 termination plan is now specifically required in the 22 regulations. Also, because there is a specific review and 23 approval associated with the licensee's termination plan, 24 there is an opportunity for hearing when that major activity 25 will occur.

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20 1 Further, as Mr. Jim Rang also mentioned, as long 2 as their decommissioning activities are within the bounds of 3 our generic environmental impact statement, there is 4 reasonable assurance and confidence that decommissioning 5 will be safe, can be conducted safely, and would not result 6 in any undue harm to the public.

7 Following that March meeting, the licensee 8 submitted a letter telling us that they intend to shut down.

9 That was in June of 1997. In August,.Big Rock Point shuts 10 down.

11 On September 19th, Consumers Energy makes a 12 decision and informs the NRC staff of their decision to 13 pursue immediate dismantlement and decontamination.

14 On September 20th, the licensee safely removes all 15 their radiated fu el from the reactor vessel and places it in 16 the spent fuel pool.

17 On September 23rd, the licensee certifies the 18 permanent removal of all its fuel, and with this 19' certification, they are prohibited by regulation from 20 returning that fuel back to the reactor vessel.

21 Today is November 13th and we are holding a public 22 meeting to discuss these plans the licensee has decided.

23 Now what is decommissioning? I know that the NRC 24 staff has received a number of questions from the public on 25 this topic. For clarification purposes, decommissioning is ANN RILEY & ASSOCIATES, LTD.

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21 1 to remove a facility safely from service and reduce res idual 2 radioactivity to a level that permits release of the 3 property and termination of the license. Note that this 4 definition does not include nonradiological dismantlement, 5 nor does it differentiate between reactoiý plant structures,

.6 systems, components, and spent fuel storage systems.

7 Consumers has indicated that they plan on 8 completing decommissioning in the year 2002. This refers to 9 their power plant, structures, systems and components, and 10 would also include those systems needed for the wet storage 11 of spent fuel. However, they also stated that they intend 12 to pursue a dry cask fuel storage system. Our regulations 13 also require decommissioning of those systems. Therefore, 14 the plant system will, be gone in the year 2002. However, 15 the spent fuel will still be maintained in dry cask storage 16 on the site until transferred to another facility.

17 Remember that the NRC's focus is on the safe 18 removal of all radiological hazards. However, the licensee 19 first must remove that facility safely from service. They 20 have done that. Now the licensee must reduce levels of 21 radioactivity on the site. During these activities that 22 they perform, we will conduct inspections, independently 23 assess their activities, and independently reach conclusions 24 regarding their conformance or compliance with the NRC 25 regulations to assure that decommissioning is conducted ANN RILEY & ASSOCIATES, LTD.

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.22 1 saf ely.

2 If the licensee decontaminates their facility to 3 levels that meet the minimum site release criteria, the NRC 4 could release the site and terminate the license. The 5 definition of site release is a site may be released for 6 unrestricted use if the dose resulting from contamination 7 remaining on the property will be as far below 25 millirem' 8 per year as is reasonably achievable.

9 To clarify Big Rock Point's planned activities, we 10 see two flow paths. Right now Big Rock Point maintains a 11 Part 50 license. That is their operating license. That is 12 for the power plant structures, systems and components, 13 including wet spent fuel storage. On the left-hand branch, 14 we go down the facility trail, and we see that we have 15 license termination in the proposed year of 2002. If they 16 eliminate dry cask storage, we go down the other way, down 17 dry spent fuel storage, and they obtain a general license.

18 When they terminate their facility license in 19 2002, they have to convert this general license to a 20 site-specific license for that spent fuel dry system. When 21 they convert it to the site-specific license, we will have a 22 public meeting and an opportunity for a hearing. When they 23 transfer all the fuel off the site, that structure will then 24 be terminated, and they would have to go through a 25 prerelease, and the NRC would have to approve license ANN RILEY & ASSOCIATES, LTD.

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23 1 termination.

2 That concludes my presentation for tonight. I 3 look forward to your questions and your comments, and I 4 thank you for your attention.

5 MR; JOHNSON: Thank you very much.

6 Our last presenter this evening will be Mr. Bruce 7 Jorgensen from the NRC.

8 MR. JORGENSEN: Thank you, Phil. Thank you for 9 being the moderator tonight, and thanks to the township for 10 this excellent facility.

11 My name is Bruce Jorgensen. I am Chief of the 12 Decommissioning Branch in the Inspection Office in Chicago.

13 It is always good to get'back to Michigan, though. This is 14 sort of my second homestate. I grew up in Nebraska, but my

15. kids grew up in Michigan because during the 1980s I was the 16 senior inspector at both Palisades and Big Rock or Palisades 17 and DC Cook, and we lived outside the little town of South 18 Haven, which is sort of a Charlevoix wannabe down along the 19 southwest shore of Lake Michigan.

20 I am going to be talking about the decommissioning 21 inspection program. There are really just three things to 22 talk about: What kind of inspections are we going to do, 23 who is going to do them, and how our plans might change 24 according to the circumstances over the period that these 25 decommissioning activities take place.

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24 1 Starting with what kind of inspections are we 2 going to do, Big Rock has been regulated basically all of 3 its life, and it is going to continue to be regulated until 4 it has no more life. NRC is a by-the-book sort of a 5 'fýegulator. We call our book the Manual, and the Manual has 6 many chapters, and most of what I will be talking about is 7 Manual Chapter 2561. As an agency, we sat down and prepared 8 a program and procedures for just the eventuality that 9 reactors would be decommissioned, because it is obvious that 10 eventually that's going to happen to all of them.

11 Manual Chapter 2561 is a public document. Its 12 title is Decommissioning Power Reactor Inspection Program.

13 Not a big surprise.ý It contains a number of objectives, 14 including verifying safety and compliance independently, as 15 Paul has said. Ensuring the adequacy of what the licensee's 16 programs and procedures are accomplishing. Identifying 17 changes in performance, that is, declines in performance, 18 before performance becomes unacceptable, and effectively 19 using our limited inspection resources.

20 There are some definitions' in there that may be 21 apropos to the discussions we have tonight. Two of them you 22 have probably heard already. Decon is one of them, and that 23 is a decommissioning option. SAFSTOR is another. The 24 program is really set up based on how many activities and 25 how frequently and how intensely the licensee is working.

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25 1 So a high level activity program is defined and a low level 2 activity program is defined.

3 Consumers has chosen to go immediately to 4 dismantlement. That means that they have chosen what we 5 would call the high level activity option, and that affects 6 how we do our inspection planning. A final definition is 7 ISFSI. That is one of those nuke-speaks. It stands for 8 Independent Spent Fuel Storage Installation. That is also 9 part of Consumers Power's current plans.

10 Responsibilities and authorities for who is going 11 to do what are laid out in our Manual Chapter. I think the 12 only thing that I would call out is that it is the 13 responsibility of the regional administrator to make 14 decisions about how much inspection is going to be done, by 15 whom, and that includes making a decision as to whether we 16 leave a permanent inspection presence at the project while 17 it is undergoing decommissioning.

18 There is some flexibility required in planning to 19 do decommissioning inspections. Activities may take place 20 at a plant over a period of anywhere from five years to 21 maybe 50 years, and obviously you don't do the same 22 activities at programs that have that much difference in 23 time span. Our Manual.Chapter defines, however, a minimum 24' inspection program that will take place at eve~ry facility, 25 and that is called our Core' Inspection Program. That's laid ANN RILEY & ASSOCIATES, LTD.

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26 1 out in some detail in Appendix A to theManual Chapter.

2 In addition to that, there is an optional1 3 inspection program that is called Regional Initiative, which 4 is above and beyond the core program, and that is where we 5 choose extra types of inspection activities to do, depending 6 on what has gone on at the fac ility and what activities the 7 licensee is pursuing. There are some estimates in the 8 program for how much direct inspection efforts, and how many 9 hours an inspector might reasonably be expected to spend 10 doing this inspection procedure or that-one.

11 ,There is a requirement for a Master Inspection 12 Plan, and we are putting together a Master Inspection Plan, 13 we call that the MIP, and it will say which procedures will 14 be done; what the estimated schedule will be, what 15 organization is responsible to carry that out.

16 There will be periodic management visits to the 17 site to assess how things are going. There will be periodic 18 visits that the inspection staff will make to the Regional 19 Office to make adjustments to that-Master Inspection Plan as 20 we go along.

21 The program provides for flexibility, in staff 22 utilization, using a resident inspect~or, assigning a 23 decommissioning, inspector, and use of regional or 24 headquarters inspectors.

25 There are basically four areas that are covered by ANN RILEY & ASSOCIATES, LTD.

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27 1 the Core Inspection Program. Being a by-the-book regulator, 2 we have-prepared procedures that fit into each of those four 3 areas. One of the areas is called facility management and 4 control. The basic focus is, is the licensee on top of 5 things? How is their planning going, internal 6 communications, that sort of thing? There are four 7 procedures that are in the Core Program in facility 8 management and control.

9 There is an area called decommissioning support 10 activities. There are four procedures that apply to that.

11 Spent fuel safety. And, of course, the spent fuel 12 is where most of the radioactive material is, 99.9 plus 13 percentage. It's the thing that most concerns an agency 14 that wants to ensure that radioactive materials don't cause 15 any harm. We have nine procedures that are available to use 16 in the core program for spent fuel safety.

17 And, finally, radiological safety. In a way all 18 of this feeds into radiological safety, keeping the 19 radiation where it is and away from people. We have four 20 procedures there.

21 I think that is a total of 21 procedures in the 22 Core Program. There are another 35 procedures in the

-23 Regional Initiative Program.

24 That lays out what kinds of inspections we will 25 do. Who is going to do them? The regional administrator ANN RILEY & ASSOCIATES, LTD.

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28 1 has the authority to determine whether an inspector should 2 be assigned to the site 'full-time. That's the option we 3 have chosen, because there is going to be a lot of 4 activities going on at Big Rock at least for the next year.

5 Roy Leemon has agreed to stay at Big Rock Point 6 and take the assignment as the decommissioning inspector for 7 a one year period. Roy is a very experienced guy, and he is 8 exceptionally knowledgeable about Big Rock. He has been the 9 senior resident inspector here for four years. He knows how 10 the place is put together. He might know something about 11 how it ought to come apart. He has had a wide range of 12 experience in his career, and has the ability to do 13 inspection activities and exercise inspection procedures in 14 different areas. He will be joining the decommissioning 15 branch, which is my branch, as part of the assumption of the 16 duty as the decommissioning inspector for Big Rock.

17 I have seven additional people 'in the office in 18 Chicago that work for me, a very educated group. I have got 19 three master's degrees and three Ph.Ds in those seven 20- people. More than 20 years experience on the average. A 21 diversified group. A biochemist, an industrial hygienist, a 22 nuclear engineer, that is one of the Ph.Ds, so is the 23 biochemist, three health physicists and a civil engineer 24 with a Ph.D. So I have got staff that's directly available 25 to me to support Roy in~the areas where we think we want to ANN RILEY & ASSOCIATES, LTD.

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29 1 apply some specialized expertise.

2 The civil engineer Ph.D is also the independent 3 spent fuel storage coordinator for all of Region III, so he 4 has responsibilities relating to all of the so-called dry 5 cask projects.

6 My people are, some of them, certified already as 7 reactor inspectors and as decommissioning inspectors. Above 8 and beyond that, I can borrow expertise virtually anywhere I 9 want and whatever I need. So that is what kind of 10 inspection we are going to do and who is going to do it.

11 The last topic is how we evolve the inspection 12 plan according to circumstances. I'mentioned the Master 13 Inspection Plan. We have put together a Master Inspection 14 Plan already. We are finalizing that. To~start with, we 15 loaded all the core procedures in there, of course, and 16 virtually all of the regional initiative procedures.

17 Experience will tell us whether we have got two few or too 18 many inspection activities planned. Roy Leemon will conduct 19 the majority of those inspection activities.

20 We will be producing inspection reports, which are 21 public documents, every six to eight weeks to discuss what 22 it was that we looked at, what we found. And then, as I 23 mentioned, there will be performance reviews periodically.

24 1 think probably, to start with, quarterly, to make 25 judgments about do we need to shift emphasis, do we need to ANN RILEY & ASSOCIATES, LTD.

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30 1 add some activities, are we spending too much time in one 2 area or another.

3 Among the things that would result in changes to 4 our Master Inspection Plan would be following up on events 5 that are not planned, they just happen, and we make 6 decisions on an individual basis. Is this something we have 7 to look into? we might want to focus on something that 8 looks like it might be a weak area or might be a trend that 9 is going in the wrong direction. There are generic issues 10 that come up that might apply to all kinds of plants that 11, are in decommissioning or plants that have safety-related 12 equipment that is still functional.

13 We have maintenance rules and inspections planned 14 at all the facilities. The decision has been made to do an 15 inspection of compliance to the maintenance rule at Big Rock 16 Point. It may be relatively reduced in scope because the 17 amount of equipment that's required to be maintained under 18 the NRC maintenance rule is going to be relatively small.

19 In addition, bulletins or generic letters that NRC produces 20 in response to events at other plants or to things that we 21 find out during inspection of other plants can generate

22. inspection activities that apply across-the-board, generic 23' inspections.

24 Much of our scheduling is dependent on watching a 25 specific activity. What that means is we do the inspection ANN RILEY & ASSOCIATES, LTD.

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31 1 when Big Rock Point people do the activity. So one of the 2 things we need to do is monitor the schedule that they have 3 very closely, and changes in their schedule may result in 4 changes in our plans As well.

5 After the first year of activity, we will revisit 6 and either assume the inspection lead out *of the regional 7 office and-send inspectors as needed with continued periodic 8 licensee performance assessments, or extend the tour of the 9 full-time inspector at the site. That is a decision we will 10 make down the road. I guess the one thing I am sure of is 11 that we will be here as an inspection presence to the 'very 12 end.

13 That is the very end of my remarks. I look 14 forward to your comments and questions.

15 Thank you for your attention.

16 MR. JOHNSON: Thank you very much. We will go 17 into the comments and then questions. I have a list of five 18 people that have comments. As I call your name, would you 19 please spell it and -- we are going to take a five minute 20 break first and then we will start.

21 Thank you.

22 [Recess.]

23 MR. JOHNSON: We will begin again. At this point 24 I believe we are going to take questions. Again, I would 25 like to emphasize that when you get up to state your ANN RILEY & ASSOCIATES, LTD.

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32 1 question, if you can be brief. State your name, spell it, 2 and please try to talk loud enough for the court reporter.

3 At this time we will start taking the questions.

4 Does anyone have any questions?

5 Yes, sir.

6 MR. KEEGAN: Michael Keegan, K-e-e-g-a-n.

7 In October of '96 the NRC issued an industry-wide 8 letter demanding that utilities respond under oath as to how 9 the plant was built, was it in compliance with the Final 10 Safety Analysis Report, was, it built as designed, were the 11 technical specifications up to code, and I am wondering if 12 Big Rock plant has in fact done that response to the NRC as 13 they requested in October of '96.

14 MR. RANG: Jim Rang responding. I believe that 15 was the 54(f) letter in response to that. We provided our 16 response addressing those issues. It was submitted, and we 17 had a dialogue with the Nuclear Regulatory'Commission on how 18 we were going to address the issues, and we were proceeding 19 along with that, and then we shut the plant down. So that 20 we had accomplished the things that we had set out to do in 21 that time frame. I don't know if we have anything 22 additional that anybody would want to add to that. But we 23 did respond, and we had a time line addressing the issues.

24 MR. KEEGAN: Well, I need to know from the NRC if 25 in fact the plant is built as it is specified in the FSAR.

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33 1 MR. HARRIS: For clarification purposes, this 2 letter he is talking about is commonly referred to as the 3 50.54(f) letter that is sent to operating power reactors, 4 requesting them to describe their understanding of what 5 their licensing and design basis is of their facility. From 6 a decommissioning perspective, it is equally important that 7 the licensee understand the design of their facility while 8 they take it apart.

9 The current NRC position on the 5'0.54(f) letter is 10 our review is not completed yet, and the reason is there are 11 approximately 105-106 operating reactors that submitted that 12 letter. The NRC staff is currently reviewing those 13 responses in a generic fashion to understand the problems 14 across the industry. When that analysis is done, we will 15 understand what the generic problems are, and we will apply 16 those as needed to facilities such as Big Rock Point.

17 MR. KEEGAN: With no assurances that the plant is 18 built as the Final Safety Analysis Report indicates, how can 19 dismantlement of this plant commence when they don't know 20 exactly how they built it and you have not verified it?

21 MR. HARRIS: We continually verify the design of 22 that facility and the licensing basis for that facility.

23 There are reports that the licensee is required to provide 24 us regarding any changes, tests or experiments that they 25- conduct at their facility, and they are required in writing ANN RILEY & ASSOCIATES, LTD.

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34 1 to provide us those-submittals. When they send us those 2 submittals, we conduct a review of them, and in most cases 3 we perform an inspection to assess their engine.ering 4 controls and how they address that.

5 Through the years of the operation of Big Rock 6 Point facility, we have conducted a number of inspections on 7 an engineering and design basis, on modifications of systems 8 and structures, and we have confidence, based upon the 9 docketed inspections that we have performed, that. this 10 licensee understands the configuration of their facility and 11 can enter into decommissioning.

12 MR. KEEGAN: I would like a track record of the 13 50.54 Part (f) communications.

14 MR. HARRIS: Okay.

15 MR. JOHNSON: Do we have any more questions?

16 MR. KAMPS: Is this the same as our name signed up 17 on the sheet or is this separate?

18 MR. JOHNSON: We are doing questions. We will do 19 comments-at the end.

20 MS. BEEMON: JoAnne Beemon, B-e-e-m-o-n.

21 I am concerned about some of the radioactivity on 22 site and the levels on site for the in quotes green field 23 unquote, and specifically two things. One, I remember 24 reading back in the Sixties, there were alarms that were 25 turned off and discharges from liquid waste batches into the ANN RILEY & ASSOCIATES, LTD.

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35 1 channel. So I am concerned about one thing. I am concerned 2 about the levels of radiation in the channel, and two, the 3 cesium spill and what the plans are for that kind'of 4 decontamination. At the time it wasn't possible because you 5 would have to get big equipment and go under the ball and 6 stuff like that. So what's up?

7' MR. RANG: I think I will defer the response to 8 Dr. English. Do you feel comfortable in responding t'o that 9 question?

10 DR. ENGLISH: I am Bob English, Certified Health 11 Physicist. I have been working for Consumers about 23 1-2 years.

13 The cesium I think you are referring to is the 14 condensate tank. There were a few millicuries of 15 radioactivity that leaked in about 20,000 gallons of water 16 under the tank and under the turbine building. That which 17 was available for -- that which was not under the turbine 18 building was removed, and we have since done sampling 19 elsewhere in other areas around that and have found no 20 contamination of the areas that are up gradient. That would 21 be to the -- basically to the south.

22 The materials, such as the cesium you mentioned, a 23 very small quantity of it, 37 millicuries potentially there 24 that we will -- we know where it is, and we will be 25 evaluating it and taking it out in terms of a limit that we ANN RILEY & ASSOCIATES, LTD.

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36 1 have identified by running computer programs that are 2 utilized by licensees to show compliance with subpart (e),

3 that is the 25 millirem plus ALARA for the site to be 4 terminated, and our termination plan for how we are going to 5 accomplish that and what those levels are, how we are going 6 to'measure them and confirm that we are below those levels 7 will be submitted two years prior to the termination of the 8 license for NRC to evaluate and approve.

91 The discharge canal is not currently a problem.

10 The analysis we have done do not show it is above the 25 11 millirem per year levels. It is well below that.

12 MR. JORGENSEN: As for NRC, our inspection program 13 for final release includes our own surveys, our own samples 14 analyzed in our laboratory, and our standard, as Ken 15 mentioned, has got to be as far as reasonably achievable 16 below 25 millirem.

17 We have a fairly long history in the nonreactor 18 industry of performing these kinds of surveys. In the State 19 of Michigan we have done those jointly with the Michigan 20 Department of Health, and we would expect to cooperate with 21 them in the final surveys at Big Rock Point.

22. MS. GREENMAN: Bruce, can you put 25 millirem in 23 perspective, like what you get for an X-ray, that type of 24 thing?

25 MR. JORGENSEN: I guess one of the comparisons ANN RILEY & ASSOCIATES, LTD.

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37 1 that is made is average exposure to a U.S. citizen is in the 2 neighborhood of 300 millirem per year. So 25 millirem would 3 be a month's worth of living, driving, flying, going to the 4 doctor, all of that stuff.

5 MR. HARRIS: Angela, that's a good question, 6 because 25 also is equivalent to your annual exposure just 7' from cosmic radiation, and it is equivalent also to the 8 amount of radiation dose you get from food and water, from 9 just intake from food and water.

10 MR. JOHNSON: Yes, sir?

11 MR. KAMPS: Yeah, I have a question about the 25 12 millirem dose because some of the -

13 MR. JOHNSON: Excuse me. Could you state your 14 name,?

'15 MR. KAMPS: My name is Kevin Kamps, K-a-in-p-s.

16 It seems like an arbitrary level to me because of 17 the research that I have read, that there is no safe 18 threshold for exposure to radioactivity. So the cosmic 19 radiation that you have referred to, yeah, that is natural, 20 but it does harm to health. So any increase in' thatE 21 exposure will' increase harm to the public's health or the 22 individual's health. So that is my concern about returning 23 the site to unrestricted use is that the radioactivity that 24 is present there, if homes are built there, the people that 25 live in those homes are going to receive additional ANN RILEY & ASSOCIATES, LTD.

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38 1 radioactivity, increasing their risk for contracting 2 diseases. Whatever that site would be used for, it is a 3 public space as well, people coming onto that site. So I 4 don't understand how that level of exposure was deemed 5 acceptable because there is no safe threshold of exposure to 6 radioactivity.

7 MR. JORGENSEN: I think you have just made the 8 argument why our real standard is as low as reasonably 9 achievable, below 25 millirem. Reasonable efforts should be 10 made to make it zero if that's possible. But failing that, 11 if it is unreasonable, prohibitively expensive, just 12 impossible from an engineering standpoint to get it to zero, 13 then it should be reduced as far as practicable. NRC 14 operates on the exact principle that you are talking about, 15 that exposure should be avoided when it's possible, but that 16 doesn't mean that it always has to be zero.

17 MR. HARRIS: The NRC just published a final 18 rule-making on this license determination on the 25 millirem 19 limit. That went through an extensive regulatory process 20 that involved the public, involved the scientific community.

21 Not to give you a bureaucratic answer, but I am sure those 22 people in the research you mentioned had the opportunity to 23 provide comment to the NRC and the commission regarding 24 that. While it is true that the current NRC position is 25 that it is based upon a linear threshold where dose would be ANN RILEY & ASSOCIATES, LTD.ý Court Reporters 1250.1I Street, N.W., Suite 300 Washington, D.C. 20005 (202) 842-0034

39 proportional to harm, you might say, it is currently being 2 reviewed by the NRC 'in light of current scientific studies 3 on exposure to radiation..

4 Do you have any additional questions along those 5 lines?

6 MR. KAMPS: Well, I have additional questions but 7 not on that subject.

8 MR. JOHNSON: Yes, sir.

9 MR. WINNELL: My name is Mike Winnell, 10 W-i-n-n-e-l-l.

11 In your big black book here entitled NRC 12 Correspondence Related to Plant Shutdown and 13 Decommissioning, my question is -- this says the

. 14 radionuclear inventory for the reactor vessel as a unitized 15 package is expected to be a Type B quantity meeting the low 16 specific activity material criteria. What is Type B?

17 MR. RANG: Dr. English, do you want to address the 18 Type B quantity?

19 MR. THONtJS: My name is Lee Thonus. I am a 20 project manager with the NRC Headquarters.

21 In the shipping of radioactive material, there are 22 several quantities that are defined. One is the smaller 23 exempt quantity, the Type A quantity, and then a larger 24 quantity is a Type B quantity. It varies from isotope to 25 isotope as to what a Type A or Type B quantity is. But in ANN RILEY & ASSOCIATES, LTD.

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40 1 general a Type B quantity is a larger quantity for which we 2 require a package with a higher level of integrity.

3 MR. WINNELL: Is-this related to low level 4 radioactive waste in Class A, B, C?

5 MR. THONUS: No. Unfortunately they use the same 6 letters. It follows the same sort of pattern, where the A 7 is the lowest level and B is more and C is more than that.

8 In the Code of Federal Regulations, there is a 9 table, and it will give you isotope by isotope, that so many 10 Curies of this isotope is a Type A and perhaps ten times 11 that much would be a Type B.

12 As kind of a quick overview, a Type A package 13 would be the kind of package that you could drop say four 14 feet and it would have to withstand that kind of a drop 15 without breaking open._ The Type B, since there would be 16 more radioactive material, it typically has to withstand, 17 that type of packaging has to withstand a 30 foot drop. So 18 it is just a much stronger package, or it has to have other 19 safeguards in place so that it would have the equivalent 20 level of protection. The more radioactive it is, the more 21 hazard, a stronger package.

22 But other than telling you there is a table that 23 gives you isotope by isotope. I used to be able to rattle 24 them of f for you but I can't anymore.

25 MR. WINNELL: So if the potential of the proposed ANN RILEY & ASSOCIATES, LTD.

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41 1 plan is to stuff a bunch of components inside the reactor as 2 sort of a place to put something that are greater than Class 3 C components, does this affect the integrity of a Type B 4 rating for this reactor?

5 MR. THONUS: You are talking about the plan to 6 ship a reactor vessel with components inside. There are two 7 -- you are discussing two sets of rules. One is the waste 8 classification. The package for the purposes of shipment 9 has to be -- has to undergo an engineering review to make 10 sure that that package is suitable for that shipment. The 11 burying of that material has to undergo a separate review to 12 make sure th~at it meets all the criteria for burial. It 13 would have to meet both.

14 If you could make the package strong enough and 15 meet all of our engineering acceptance criteria for shipment 16 as a package, and when it got to the burial site, it 17 wouldn't meet the burial criteria, you couldn't send it to 18 the burial site. When those things come into the NRC for 19 review, we look at both is the integrity of the package 20 adequate for the kind of transportation it is going to 21 undergo and the kind of material that is going to be inside, 22 and we would also do a review, is this material suitable.

23 If it is greater than Class C, it wouldn't be suitable for 24 routine burial.

25 MR. WINNELL: Would the reactor be a Class C or ANN RILEY & ASSOCIATES, LTD.

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42 1 greater than Class C?

2 MR. HARRIS: We don't know, Mike. -The licensee 3 has not come to us for this yet.

4 MR. WINNELL: So then the question is, it says 5 here the method of disposal which would result in lowest 6 cost and lowest dose to workers is shipment within the 7 intact reactor vessel, provided that authorization to 8 average the radionuclear inventory throughout the metal mass 9 of the vessel and containers, such that the total package is 10 not GTTC. In other words, the parts that are in it are 11 GTTC, but the reactor, I guess, shield is less than -- is 12 presumed to be less than it.

13 MR. HARRIS: Right.

14 MR. WINNELL: So, in other words, I gather the 15 reactor, with all the really bad stuff that is inside, it 16 could be buried in a less secure spot than if you took the 17 components out and you would have two separate items to deal 18 with. This is the only reason I can see for this type of 19 language.

20 DR. ENGLISH: Bob English again.

21 We weren't intending to put stuff in like a 22 garbage can. These are things that are built into the 23 reactor, a portion of the reactor now.. The internal 24 portions of the reactor itself are more highly radiated than 25 the vessel around the outside because they are closer to the ANN RILEY & ASSOCIATES, LTD.

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43 1 neutron field. In fact, they are surrounded by the fuel.

2 Therefore, what we are asking is the same as the Trojan 3 plant has asked for their burial, that that be allowed to be 4 a portion of the total reactor calculated into the total so 5 that you can calculate the classification based on what is 6 present in the total reactor.

7 Now this happens, when you do take things apart,.

8 and you end up with greater than Class C in a small portion 9 of it, you can no longer average it once it is out. So we 10 want to be careful that we don't get ahead of ourselves, 11 take it out and then it is separated. If we cut it out, put 12 it aside, it would be greater than a Class C thing, and we 13 could never average it back in.

14 But for the purposes of the cost of being able to 15 do the cheapest thing for the monies of our ratepayers, and 16 to do the best thing in terms of dose for our workers, it is 17 much better not to handle it, pull it out,,have to cut it 18 up, put it in another container, ship it separately, more 19 shipments on the highways and so forth, and more dose to 20 everybody, than to leave it intact, close it up in the 21 reactor and ship it. But we do need the NRC and the burial 22 people to agree. We can do it the other way. It is just

23. that our dose -- my dose analysis of the 425 personrem 24 accounts for being able to do that low dose technique.

25 The reason we brought that up especially is to ANN RILEY & ASSOCIATES, LTD.

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44 1 show that the 425 personrem probably would not apply if we 2 have to take the stuff out, cut it up, repackage it 3 separately, and make special shipments or store it for long 4 periods of time with the fuel, which we would have to do if 5 it is greater than Class C, because right now nobody is 6 taking greater than Class C. It gets stuck here on the site 7 forever. So obviously we would like to get rid of it for 8 everybody present.

9 MR. JOHNSON: Mr. Winnell, maybe you can discuss 10 this after. We have got other people.

11 DR. MASNIK: Mike Masnik, M-a-s-n-i-k.

12 He mentioned the Trojan plant. All plants that 13 have been decommissioned to date and where the vessel has 14 been removed have had the internals removed. The Trojan 15 plant is the first one that has requested that the vessel be 16 removed with the internals still in-the vessel, and that 17 review is ongoing. It's been a year. It is going to be a 18 considerable time from now before the agency makes a 19 decision as to whether or not to allow this. The question 20 was raised as to whether or not burial sites can accept it, 21 and whether or not they can design the shipping package such 22 that it is strong enough to withstand any sort of calamity.

23 So it is a proposal.

24 MR. JOHNSON: Yes, ma'am.

25 MS. HACHHARCAR: My name is Cara, C-a-r-a, ANN RILEY & ASSOCIATES, LTD.

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45 I Hachharcar, H-a-c-h-h-a-r-c-a-r, I live in Charlevoix, and I 2 am concerned about my friends here, Greg and Bill, who work 3 at the plant. If the SAFSTOR method of decommissioning is 4 deemed safer for the decommissioners, why do they all of a 5 sudden change to do it in this quick span of time? I also 6 have a question about the reliability of the casks that will 7 be used.

8 MR. JOHNSON: Who did you want to answer this?

9 Mr. Rang?

10 MS. HACHHARCAR: Whoever would like to.

11 MR. RANG: There are two options or three options 12 to decommission the plant. One is SAFSTOR, one is 13 entombment, and the third is the immediate decommissioning 14 and dismantlement. We chose to look at two of the three, 15 the SAFSTOR and the immediate decon. Both of those are 16 acceptable methods. While it is true that over the 17 long-run, if you have-any long-term SAFSTOR period, that 18 there is less dose to the workers over that extended period.

19 However, there are trade-off s that need to be balanced.

20 First of all, while you may think initially that 21 there is a reduction in the volume of materials being 22 shipped, if you have -- there are short-lived and 23 longer-lived isotopes, radioisotopes. As long as you have 24 an isotope that exceeds the limits, even though the rest 25 have decayed off, it still needs to be shipped to a burial ANN RILEY & ASSOCIATES, LTD.

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46 1 site. So it turns out there is ve~ry little volume 2 reduction. So the cost is still there to ship the material 3 even after the, as we looked at the 27 years, there is very 4 little cost reduction in shipping the materials to the site 5 over that delayed period.

6 We also looked at the possibility: will a site be 7 open in 25-30 years down the road to ship the materials to?

8 That question -- that answer is unknown. The repositories 9 to ship the materials to are available and open at this 10 time. So it seems to us to take advantage of that 11 opportunity to* ship the materials over the next five year 12 period.

13 Plus there is another trade-off and that is the 14 cost. If you put the plant into SAFSTOR, you have the 15 maintenance, the annual maintenance of the plant, and the 16 cost. It is more expensive going into the SAFSTOR mode of 17 operation. You still have to dismantle the plant after a 18 period of time. So you still have not only the 19 dismantlement cost but the maintenance cost.

20 There is also the opportunity to take advantage of 21 the qualified people at the site who are trained to not only 22 operate the plant, but know the plant and can take the plant 23 apart. If you go into a SAFSTOR mode of operation, you lose 24 that talent because all you need is a custodial site, if you 25 will, a custodial staff, if you will, for an extended period ANN RILEY & ASSOCIATES, LTD.

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47 1 of time, and then you have to rachet back up again with 2 resources that are available to dismantle the plant. That 3 is more expensive.

4 We have to weigh the balance against additional 5 costs to our customers to dismantle'the plant, and there is 6 probably,-you know, another item would be, we feel we can 7 meet our obligation to reduce the nuclear liability, we have 8 an opportunity to do that, over a fairly short period of 9 time, and, so we are taking advantage of that.

10 As we look at all of those, you know, it is a 11 balancing act. You need to look at the dose and also look 12 at the costs and look at the other activities that make up 13 part of that formula.

14 One thing I would also add. We have put on record 15 in our original decommissioning plan filing that our 16 estimate for the 27 year SAFSTOR and then dismantlement by 17 year 30, the dose estimate was about 180 personrem. The 18 dose to do the dismantlement in five years is about 425 19 personrem over the five years versus over the 30 years. In 20 considering, on a comparison basis, Big Rock, during its 21 last five cycles of operation, its last five years of 22 operation, the average personnel dose to the worker was 23 about 200 personrem per year.

24 You say, well, how does that compare with others 25 in the industry? We report those numbers, and they are ANN RILEY & ASSOCIATES, LTD.

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48 1 trended, to the Nuclear Regulatory Commission as well as to 2 NPO, Nuclear Power Operations, who monitors the trending, 3 and Big Rock's compare very favorably. In fact, Big Rock is 4 one of the lowest in the country in terms of exposure during 5 power operation.

6 If we look at the last five years with the 7 refueling outage in there, we are talking probably two years 8 of power operation versus five years of dismantl ing the 9 plant. That number was around 200 personrem average per 10 year during that power operation.

11 So we think we have looked at all of those and we 12 have balanced those. That is kind of a long-winded answer, 13 but that's how we have arrived at going forward with the 14 immediate dismantlement. Again, both options are options to 15 US. You know, they are within the bounds of the impact 16 statement and so those opportunities are available to us to 17 select either.

18 MR. JOHNSON: Yes, ma'am.

19 MS. CAREY: Corinne Carey, C-a-r-e-y.

20 Am I catching on to the idea that only questions 21 will be answered now but comments will not-include answers 22 of questions?

23 MR. JOHNSON: That is correct.

24 MS. CAREY: Oh. Well, then I better talk now. I 25 have several questions.

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49 1 Well, first of all, my apologizes for not being on 2 time. I notice this paper says 6:30, and it was my 3 understanding that the meeting started at 7:00. so it 4 started at 6:30?

5 MR. JOHNSON: No, it started at 7:00.

6 MS. CAREY: Well, even at that I couldn't find it.

7 So thank you.

8 Pertinent to what we are talking about, in 9 Sunday's newspaper, the Grand Rapids Press, where I am from, 10 it's a New York Times news service out of Washington, 11 "Measurement of radiation in bomb work is questioned", and 12 one of my questions would be is there really much difference 13 in measuring radiation exposure of workers between bomb work 14 and nuclear power plants.

15 Secondly, what this article and the study involved 16 points out is that the badges that were used did not measure 17 the inhalation and the ingestion of radioactivity, and that 18 any urine samples that were taken were not combined with the 19 badges. So that perhaps the whole basis of measuring 20 radioactive exposure for personnel is false, faulty. So 21 that's my question.

22 MR. HARRIS: Corinne, who would you like to answer 23 your question?

24 MS. CAREY: Whoever knows the answer.

25 MR. JORGENSEN: I would say a couple of things.

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50 1 We know a lot more about how to measure radiation 2 than we did in the Fifties and Sixties when we were talking 3 about bomb fallout. Our regulations speak to, from an 4 occupational point of view, protecting people as 5 individuals, and this is part of an answer, I think, to this 6 question of manrem against manrem and so forth. Our 7 regulations are aimed at the workers being exposed to so

8. little radioactivity that their health will not be in 9 danger. So we will regulate on the basis that every worker 10 will get less than five rem exposure per year, and if 11 something, happens that they get more than that, we would be 12 very interested in figuring out how it happened and making 13 sure it never happens again.

14 I use the term rem. It gets a little technical, 15 but the term rem was developed over the years to account for 16 internal and exter nal and different types of radiation from 17 different kinds of isotopes to take into account the various 18 biological effects that could involve different organs or 19 different sources of radioactivity. So for 37 years, up 20 until certainly during 1997, we did inspections at Big Rock 21 to look at their compliance to our limits for exposure to 22, their workers. That includes for any workers that have the 23 potential to be exposed to inhaling or ingesting or getting 24 materials inside their body, assays for urine, and that sort 25 of thing. So we have good confidence that we know how much ANN RILEY & ASSOCIATES, LTD.

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1 exposure people are getting, that it is accurate, that it is 2 added up correctly from the different sources, and it is in 3 compliance with our limits.

4 MS. CAREY: Then another question I have. This 5 information -- well, I better go back. At the press 6 conference when the plant was closed, I was told that the 7 document justifying worker exposure on a fast track plan 8 would be sent to me. Afterwards I was told use the process, 9 the public has available the public document room, and I 10 asked, well, could I at least have the number of the 11 document, and at this point I am wondering if there is such 12 a document that justifies this exposure and puts it in some 13 kind of a numerical framework.

14 I tried the public document room and of course 15 couldn't find anything that was directly pertinent. I have 16 found several things since that are pertinent.

17 This is from the Public Citizen, which is the 18 group that Ralph Nader originated. And, in fact, they are 19 from Washington too. Aren't you Mr. Harris?

20 MR. HARRIS: Yes, I am.

21 MS. CAREY: Yes, we talked on the phone. Thank 22 you.

23 The characteristics of highly irradiated nuclear 24 waste must be fully understood. The first concept to grasp 25 is the dangerous nature of nuclear waste. Public Citizen ANN RILEY &ASSOCIATES, LTD.

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52 1 uses the term highly irradiated to describe this type of 2 waste because it is deadly, whereas the term usually used in 3 the industry is spent, which to me and to most people means 4 less, but if anything it is up to 100 million times more 5 irradiated according to the PR man, Mark Savik, at the 6 Palisades plant.

7 A'person standing one yard away from an unshielded 8 ten year old fuel assembly would receive a lethal dose of 9 radiation, 500 rem, in less than three minutes. ,.A three 10, second exposure, 100 rem, at the same distance would 11 significantly increase the risk of cancer or genetic damage.

12 And then there is a chart that at the age of one year the 13 radiation characteristics of an irradiated assembly is 14 2,500,000 Curies per assembly. That's called the activity.

15 The surface dose rate, reins per hour, is 234,000 Curies, and 16 this particular one happens to go five year span, ten year, 17 50 year, and the 50 year --

18 MR.-JOHNSON: Excuse me. Do you have a question 19 or are you doing your comments now?

20 MS. CAREY: Yes. I would like first of all to 21 know what kind of document you have, used to justify early 22 worker exposure by immediate dismantling, and secondly, yes, 23 I would like a copy of it, please, and thirdly, how was this 24 presented to the advisory board, which I assume discussed 25 all this? I mean I am hearing a lot of rationale as to why ANN RILEY & ASSOCIATES, LTD.

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53 1 it was put on a fast track, both in dismantling and in the 2 two and a half years before the plan time and according to 3 the original decommission plan that I assume was discussed 4 thoroughly by the advisory board. Now did they also get a 5 chance to discuss and make recommendations and be aware of 6 these other factors that you have just mentioned?

7 MR. RANG: Jim Rang responding.

8 What I would refer you to is the Final Generic 9 Environmental Impact Statement, FGEIS, which is New Reg 10 0586.

11. MS. CAREY: Is that this one?

12 MR. RANG: New Reg 0586.

13 MS. CAREY: This is an earlier version?

14 MR. HARRIS: Can you read the title?

15 MS. CAREY: Generic Environmental Impact Statement 16 in Support of Rule-Making on Radiological Criteria for 17 License Termination of NRC Licensed Nuclear Facility, New 18 Reg 1496, Volume 1. I got this in July. I don't know if 19 that is when it was printed.

20 DR. MASNIK: The correct new reg is the FGEIS on 21 Decommissioning of Nuclear Power Plants, and we will be 22 happy -- in fact, here it is. We will be happy to provide 23 you with a copy.

24 MS. CAREY: It is thicker than this one.

25 [Laughter.].

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54 1 MS. CAREY: Does that have the documentation as to 2 justifying worker exposure?

3 DR. MASNIK: Yes. This discusses, both decon and 4 SAFSTOR, and it is based on a number of other documents as 5 well, and we will provide you with a copy of this.

6 MS. CAREY: Good. Thank you.

7 DR. MASNIK: If y ,ou could just 4ive your name to 8 Etoy in the back, and we will send you one next week.

9 MS. CAREY: Can I expect it within two weeks?

10 DR. MASNIK: We will put it in the mail next-week.

11 MR. JOHNSON: Do we have any other questions?

12 Yes, sir.

13 MR. KAMPS: Yes. My question -

14 MR. JOHNSON: Could you state your name and spell 15 it, please?

16 MR. KAMPS: My name' is Kevin Kamps, K-a-in-p--s.

17 My question is in regards to the casks that were 18 talked about. Would that be the VSC-24 casks?

19 MR.- RANG: No, it would not be. We have secured a 20 contract with Westinghouse to provide what is called the dry 21 transportable canister system. That is licensed for both 22 the storage and shipping, and those casks are going through 23 the licensing process as we speak.

-24 MR. KAMPS: I guess my question to the NRC is -- I 25 am from Kalamazoo*, and my representative, Fred Upton, is the.

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55, 1 sponsor of the Nuclear Waste Policy Act of 1997, and when I 2 have spoken to him a number of times about the safety of the 3 transportation casks that would be used to transport high 4 level waste on the highways and on the railways, he often 5 says that the NRC is the one who would ensure the safety of 6 the casks.

7 My concern is, with the explosion in Wisconsin and 8 with the unforeseen cracking of the casks at Palisades, my 9 concern is for entering into a process like this when the 10 integrity of the casks is in question. With the'demand for, 11 information that came out in October, it seems like the 12 decision by Consumers Energy to pursue this path should have 13 been tempered by bad experiences of Palisades. So what 14 response would the NRC or Consumers have to this?

15 MR. HARRIS: The licensing process for the casks 16 that Consumers Energy is proposing started recently, and the 17 NRC staff, which, by the way, is a large staff that reviews, 18 all these license applications for dry cask systems, 19 rejected the initial proposal by the vendor based upon a 20 number of determinations by the staff that their proposal 21 was inadequate. The proposal was sent back to the vendor 22 and the vendor is again going to resubmit.

23 Based upon that initial rejection, the NRC staff 24 will receive a second submittal and conduct. a rigorous 25 technical review of it'. This review will take anywhere from ANN RILEY & ASSOCIATES, LTD.

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56 1 one year to two years long. A number of design 2 considerations are going to be taken into effect. The 3 regulations, Part 72 of our 10 CFR, stipulates design.

4 controls, engineer controls, quality assurance, sabotage in 5 transportation, just to name a few. All those 6 considerations are going to be looked, at.

7 You also mentioned this explosion at Point Beach.

8 That is true, that licensee did have an event involving 9 hydrogen gas ignition during the welding process on the 10 cask. The NRC did an extensive team assessment of that 11 event and looked at it and saw a number of generic issues 12 that came out of it. Out of those generic issues the NRC 13 took some actions to improve their inspection procedures and 14 sent out some requests for information. We got some lessons 15 learned from the industry, and tailored their inspection, 16 review and approval processes to ensure that type of 17 situation doesn't occur again.

18 Bruce, do you have anything else you want to add?

19 MR. JORGENSEN: I don't think so.

20 MR. KAMPS: I guess the lesson that I see in it is 21 the danger of rushing forward into something without fully 22 considering all aspects to it, like the use of the VSC-24s 23 at Palisades and at Point Beach, and I see a parallel in the 24 rushing forward to decommission Big Rock.

25 MR. HARRIS: Well, I can assure you here that the ANN RILEY & ASSOCIATES, LTD.,

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57 1 NRC staff is not going to be rushing forward. There is a 2 specific review process associated with this. The licensee 3 still hasn't provided their submittal to us.

4 Mike, do you want to help me out here?

5 DR. MASNIK: Mike Masnik.

6 I think your points are well-taken, and I think 7 the industry was basically knocked to their knees on these 8 two events, and there is a lot of activity at NRC 9 headquarters, and right now the licensing process in a 10 number of these applications quite frankly is going poorly 11 for the vendor. They are not making a convincing argument.

12 So it will be reviewed, and I can assure you, we are not 13 going to license a cask that would be capable of being 14 shipped on the highways unless we are absolutely certain 15 that it will comply with the regulations, both the 16 Department of Transportation and the NRC regulations. I 17 can't say much more than that.

18 MR.. KAMPS: I just see a lot of rushing forward.

19 My Congressman, in his bill, it is another rushing forward 20 with casks that haven't been designed or tested. That's my 21 concern.

22 DR. MASNIK: The casks cannot transport fuel 23 unless they are licensed, and until the vendor demonstrates 24 to our satisfaction that they can survive the kind of 25 accidents that are predicted for these kind'of casks, they ANN~ RILEY &.ASSOCIATES, LTD.

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58 1will not travel the roadways or the railroads of this 2 country.

3 MR. JOHNSON: Do we have any other questions?

4 MR. WINNELL: Yes. Mike Winnell.

5 I am surmising now that the intact reactor method 6 of removing the reactor is the preferred option, and that 7 that will begin in the first quarter of 1999, but the spent 8 fuel pool will not be emptied until some time in 2000, early 9 2001. My question is how are you going to get this reactor 10 out of containment without cutting a hole in the vessel?

11 And if you do, how will you patch the hole up? What happens 12 during the time it is open? And what kind of assurances are 13' there going to be that you don't drop it in the spent fuel 14 pool?

15 MR. RANG: The process that we use -- as we begin 16 to dismantle Big Rock, we develop decommissioning work 17 packages, DWTs as we refer to them. Those have a very 18 rigorous analysis that's done, Part 50.59 analysis, and in 19 working through that analysis, we have to be assured that 20 there are no unreviewed safety questions, no issues that go 21 unaddressed, and that's the process that we will be working 22 through in the next year or two as to how we are going to be 23 removing, you know, the components, and those have not yet 24 been developed.

25 Our schedule as we have laid out, we think.it is a ANN RILEY & ASSOCIATES, LTD.

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59 1 schedule that-.can be accomplished, but if the analysis is 2 not ready, then the components won't be removed until the 3 analysis supports that, yes, it can be removed, and it will 4 work through that process.

5 MR. WINNELL: So you really don't know how you are 6 going to get it out before you get the spent fuel out of the 7 pool?

8 MR. RANG: We have several ideas that we are 9 looking at, but until we work through the process, I can't 10 tell you which one we are going to utilize.

11 MR. WINNELL: So will those plans all be reviewed 12 by NRC and will there be an inspector on site when all this 13 tran~spires? Because I hear the inspector is going to be 14 gone after one year, and all this stuff is going out after 15 he is gone.

16 DR. MASNIK: I was just going to say the two 17 things that we are really concerned about, safe storage of 18 the irradiated fuel and off-site releases in excess of-the 19 limits, and whenever there is an activity on the part of the 20 licensee that can influence either of those, the NRC will 21 conduct a review, and we will be involved particularly in 22 any major activity like removing a large component. We will 23 have people to look at the cranes. We will have people that 24 look at the health physics aspects. We' will certainly be 25 concerned about anything that has the potential for ANN RILEY & ASSOCIATES, LTD.

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60 1 impacting the spent fuel in the spent fuel pooi.

2 MR. JORGENSEN: I think from a practical point of 3 view, as far as the inspection activity, as Mike hit the 4 nail on the head, the activity has got to stay in the pool 5 so you have got to protect the fuel at all times, and as 6 part of that activity, you are looking not just to protect 7 the fuel, but if something does go wrong, ensure that there 8 is no off-site release. We are not going to do the design 9 for anybody, we are not going to tell them the details of 10 how it has to be done, but we already have in place rules 11 that address heavy loads and moving heavy components near 12 spent fuel pools. If it's going to be done, it has got to 13 be a single failure-proof crane, and we have got a 14 substantial document that lays out the requirements that 15 have to be met to move loads near the fuel pool. The 16 containment for keeping activity inside should there be a 17 release. So all those criteria would have to be met by 18 whatever option is chosen and laid out in detail. And so 19 those are the kind of criteria we would be making our 20 judgments against. Exactly the kind of questions you have 21 talked about, we' have thought of all those questions: What 22 is the path, what is the load, what are the possible things 23 that can go wrong?

24 MR. WEISS: Sy Weiss, NRC. Maybe you would be 25 in~terested in seeing some pictures we have of the ANN RILEY & ASSOCIATES, LTD.

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1 decommissioning activities that took place at Trojan.

2 At Trojan the equipment access hatch was very 3 close to the spent fuel pool, within'five-ten feet, so it 4 was not prudent to take heavy equipment out to that hatch.

5 So what the people did at Trojan was to make a hole in 6 containment, and this is the activity th at is going on here.

7 And then once they have completed this, then they were going 8 to take components out through that.

9 Let me skim through what I have here. That is an 10 upside down picture of again the Trojan facility, and this 11 shows them removing a steam generator out of the containment 12 through the hole they made in the concrete with a ne w crane 13 system that they had installed outside, then lifted it up 14 inside, laid it flat, and moved it out and then they took it 15 further out, and then they laid it down on a transporter.

16 MR. JORGENSEN: This is something actually 17 Consumers Power has some experience with, having replaced 18 the steam generators at Palisades. They made a large hole 19 in the containment there, moved out two components at 20 something over 100 tons a piece, brought in new ones and 21 repositioned them. In the case of Palisades, though, the 22 fuel pool is not inside the containment.

23 MR. WEISS: In this, picture, this is inside 24 containment, again at Trojan, and this shows them lifting up 25 one of the steam generators to get it ready to put it on its ANN RILEY & ASSOCIATES, LTD.

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62 1 side and then move it outside through the hole in the 2 containment.

3 One last picture that may be of interest. Again 4 this is a Trojan picture, and this shows the steam generator

5. on a transporter, the transporter has been put on a barge, 6 and they are getting ready to ship it to the disposal site 7 along the Columbia River.

8 I have other pictures of Yankee-Rowe showing them 9 shipping the steam generators on rail cars but it is pretty 10 much the same.

11 MR. POWERS: My name is Ken.Powers. I am the site 12 director and resident manager of Charlevoix at Big Rock.

13 To give you another idea, the reason Jim mentioned 14 we haven't decided yet, we have got seven of the world's,

'15 largest construction companies now giving us bids, and we 16 won't select one of them until next February as to who is 17 going to do that work for us. So we are very concerned 18 ourselves. My office is 100 yards from there, I live there 19 every single day, so I care very, very much about what goes 20 on in addition to what the NRC will do. So we are going to 21 go through a very extensive, careful process..

22 This whole plant was designed and built in two 23 years. We are going through a very methodical five year 24 proces~s, and I take exception if anybody thinks -- we are 25 not rushing anything. I myself and the staff that's here ANN RILEY & ASSOCIATES, LTD.

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63 1 .with me, we live on this site, many of us live in this area, 2 so we are personally invested in addition to what the 3 Nuclear Regulatory Commission is going to do.

4 We are going through a very methodical process 5 with the best engineering pr~ocess we can, and we are not 6 going to go forward with anything unless we feel very 7 comfortable with. it.

8 As far as the vessel question that you asked 9 specifically, it looks to us like there are several very 10 safe technical approaches similar to what Mr. Weiss has 11 showed you that have been at other plants. I have 12 personally been involved in the construction of five nuclear 13 plants and moving all this type of equipment into them. So 14 I haven't yet, except some Navy experience I had 30 years 15 ago, been involved in taking them out,. but it looks to me 16 that it is about the same kind of process in reverse.

17 1 can tell you I am going to make sure myself that 18 this is done the right way just for my own personal 19 confidence, and I invite the public and anyone else to stay 20 with us because I think it is going to be interesting.

21 Those pictures Mr. Weiss showed you are very interesting, 22 large construction-type projects. So please stay tuned with 23 us, and we would be very happy to show you that process as 24 we go forward. We are not ready tonight to show that to you 25 because we are just not at that stage yet, and we haven't ANN RILEY & ASSOCIATES, LTD.

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64 1 selected who is going to do this work for us.

2 MR. JOHNSON: One more.

3 MR. WINNELL: So then I will just state from my 4 own perspective then, the Big Rock Point Plant request for 5 emergency planning exemptions is to go into effect, I 6 gather, this month or soon thereafter. It seems like, with 7 that level of activity going on, that there should not be an 8 exemption for an emergency plan, that the public should be 9 informed, the proper public officials and whatnot should be 10 in charge, and that nothing should change. Really nothing 11 should change until the fuel goes out of here. But I surely 12 object to this taking effect, you know, relatively soon, 68 13 days after shutdown.

14 MR. HARRIS: What Mike is referring to is the 15 September l9th~licensee's submittal to modify or exempt 16 themselves from certain regulatory requirements. That 17 exemption is still under NRC review. Our staff is still 18 carefully looking and evaluating their requested exemption.

.19 We have not yet reached any conclusion on any of their 20 requested exemptions. Let me finish, please.

21 The way it stands right now is that the licensee 22 is required to meet their current regulations in their 23 current emergency plan until we tell them otherwise. we 24 have extensive discussions with FEMA, and we are also having 25 discussions with the State Emergency Planning. It would be ANN RILEY '& ASSOCIATES, LTD.

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65 1 premature right now to give any conclusion on that.

2. However, I accept your comment that we need to be careful in 3 our review of these exemptions.

4 MS. BEEMON: As a matter of fact, there was a memo 5 from the NRC asking Consumers Power Company --

6 MR. JOHNSON: Could you give your name for the 7 record again?

8 MS. BEEMON: JoAnne Beemon again. But there is a 9 memo from the NRC asking for further clarification. I 10 believe fuel handling is one of the things that is 11 questioned, releases of radioactivity in the event of fuel 12 handling, and that has to be answered within a few days, I 13 believe, but it just reminded me, when we did our spent fuel 14 pool intervention, one of the things that -- two of the 15 things. One, the load limits over the pool were 24 tons, 16 and also we had the unique privilege of being awarded a high 17 impact absorption device in the event that certain loads 18 were carried over the pool, which basically we referred to 19 as a crash pad, but because of the configuration of the pool 20 being up inside the containment, the concern, of course, is 21 that you can't sheer the concrete of the pool that is 22 suspended, and if you do sheer the concrete of the pool, 23 then you can run into difficulties with, you know, 24 compromising your cladding and you can have a criticality 25 accident from what -- not what Greg said -- but from what ANN RILEY & ASSOCIATES', LTD.

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66 1 other experts have told me. Greg has told me that is not 2 possible. It 'just is interesting.

3 MR. JOHNSON: I don't think there was a question, 4 it was just a comment.

5 Are there any more questions?

6 MS. CAREY: Corinne Carey. I am wondering, does 7 an exemption mean that there will not be full-time continual 8 monitoring on site and that information available to the 9 people on site?

10 MR. HARRIS: I am not sure I understand your 11 question.

12 MS. CAREY: During the decommissioning, just as 13 with transporting various radioactive materials, I 14 understand it is important that there be continual 15 monitoring and it available on site to the people who are 16 actually doing it, not to get a report back a month later or 17 six weeks later or whatever. So will there be monitoring on 18 site continuously and it available to the 'personnel there on 19 site?

20 MR. HARRIS: Monitoring of the spent fuel pool?

21 MS. CAREY: Of radioa'ctivity.

22 MR. RANG: There will be continuous monitoring, 23 radiation monitoring. Mr. Pallagi has a pretty sizeable 24 staff to do just that as we progress through our 25 decommissioning activities.

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67 1 MS. CAREY: So exemption will not include that?

2 MR. RANG: The exemption that we submitted dealt 3 with the site emergency plan for off-site dose calculations.

4 It has nothing to do with the radiation monitoring at the 5 site. We will continue to maintain monitoring until the 6 license is terminated.

7 MR. JOHNSON: Are there any more questions?

8 Yes, ma'am.

9 MS. SCHALLER: I am going to direct this question.

10 My name is Doris Schaller from Don't Waste Michigan, 11 Northern Chapter. Don't Waste Michigan has other chapters 12 besides ours. My box number is 445, Petoskey, Michigan, 13 49770. And, yes, if I don't get the answers now, maybe you 14 could send them to me.

15 Mr. Powers, the NRC on October 21st sent you a

16. letter spelling out requirements and asking for additional 17 information and amendments of the facility operating 18 license, and a lot of technical questions. This was at 19 least two pages. And my question is have the requirements

20. of that letter been satisfactorily met, and does the plant

.21 now have the license to start decommissioning? It said they 22 had to give the answer within 30 days.

23 MR. POWERS: Ken Powers.

24 First of all, we submitted to the NRC some, if you 25 looked at all the documents, I mean well over 500 pages of ANN RILEY & ASSOCIATES, LTD.

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68

. 1 things for them to look at. The normal process is they will 2 send letters back to us, and Mike will have to refresh me 3 what the October 21st letter was. They will send letters 4 back to me requesting additional information for their, 5 review. As I said, it is a very extensive process, that 6 they ask us questions and we will respond. I am not privy 7 to know, I know we responded'back within all the 8 requirements, so I am assuming, is that the one we just 9 recently sent?

10 MR. BOUFASSA: Yes. As a matter of fact, it was 11 due in 30 days, it was due November 21st, and actually we 12 signed it yesterday, Doris, so we actually beat the 30 day 13 deadline.

14 MR. POWERS: It is probably in the mail. The NRC 15 doesn't probably have it yet. But none of that-has any -

16 those questions have nothing to do with the license to 17 proceed. The word "license" doesn't make sense in this 18 context. We have a process that is in place now where we 19 are doing some minor preparation items. As Jim mentioned, 20 we are moving asbestos insulation from piping, et cetera.

21 The document you are referring to has to do with some 22 ongoing things we won't be doing even for a couple of years.

23 I think, as Jim mentioned, I am expecting NRC 24 approval of those submittals probably within the first or 25 second quarter of next year. We are going to'be going ANN RILEY.& ASSOCIATES, LTD.

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69 1 through weeks and months of back and forth reviews. So 2 those of you that are interested will want to keep tuned to 3 the Federal Register because I am sure that won't be the 4 last letter I receive from Mr. Harris for additional 5 information. That is the proce ss, and we have complied with 6 any requests we have had thus far and will continue to do 7 that.

8 MS. SCHALLER: In other words, they will be issued 9 a license before all these specifications and quý!stions have 10 been answered, is that right?

11 MR. HARRIS: Well -

12 MS. SCHALLER: Will they have the license without 13 all that?

14 MR. HARRIS: Actually their current license 15 remains in effect for this period we are in right now. The 16 request for information that you are referring to was 17' requesting the licensee to provide us additional information 18 regarding their September 19th submittal that Mike Winnell 19 has. The licensee needs to follow their technical 20 specifications and license as it is written right now for 21 any activity they perform on site. They need to, if they 22 conduct any initial decommissioning activities, such as 23 asbestos removal, like Ken Powers mentioned, they can do 24 that using their current programs and procedures that they 25 have in place that are required to be implemented under ANN RILEY & ASSOCIATES, LTD.

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70

.1 their current operating license.

2 MR. JOHNSON: Are there any other questions?

3 Okay. I think we are going into public comment, 4 and Mrs. Schaller, I think you'are right on top of the list.

5 You have five minutes a piece and we will monitor them. if 6 they go over, you can bring your written comments up and we 7 will go through them.

8 MS. SCHiALLER: In this magazine or this paper, 9 from the Charlevoix Courier, I read the headlines, and it 10 said "Radiation Isn't the Danger at Big Rock". It depends 11 on the method, I would say, for decommissioning whether this 12 is true.

13 Originally the SAFSTOR method was planned for 14 decommissioning.Big Rock nuclear plant. Then, in publicity 15 11-5-97 iii the Petoskey News Review, we learned that 16 Consumers were planning the decon method. That's immediate 17 dismantlement.' This is allowed by the NRC providing, you 18 know, certain requirements are met. So this letter to 19 Kenneth Powers from the NRC was trying to get at that, which 20 I assume it hasn't been done yet or hasn't been accepted.

21 our organization, Don't Waste Michigan, favors the 22 SAFSTOR method of decommissioning for good reason. This 23 method delays dismantling for 30 years during which the 24 reduction of radiation takes place. NRC's own studies found 25 that employing SAFSTOR reduces exposure to workers from 544 ANN RILEY & ASSOCIATES, LTD.

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71 1 manrems to 14. Repeat, 544 manrems to 14. Also, it redu~ces 2 the volume of contaminated waste from 18,548 cubic yards to 3 1,830 cubic yards.

4 Now we are hopeful that this meeting will result 5 in retaining the original,.plan using the SAFSTOR method.

6 Contrary to the headlines in the Charlevoix Courier, 7 radiation is the danger at Big Rock.

8 The direction as to which method should be used 9 needs to come from the NRC. The reported incident from 10 Monroe, Michigan, which Mike told us about, who is from 11 Monroe, Michigan, this was the Fermi plant, and it was 12 reported that 35 of the workers developed cancer or were 13 dying from cancer. Out of those 39 workers, 35 were either 14 dying of cancer or had cancer, and I think this needs 15 investigation by the' NRC before this project of 16 decommissioning is set in stone.

17 I thank you.

18 Radiation is a danger at Big Rock.

19 MR. JOHNSON: Michael Keegan, K-e-e-g-a-n.

20 MR. KEEGAN: Michael Keegan from Monroe, Michigan.

21 I am with Don't Waste Michigan and Coalition for a 22 Nuclear-Free Great Lakes'.

23 I have been reviewing documents for 17 years.I 24 would like to state that this is not a public hearing, this 25 is a public meeting, and in my opinion the NRC has ANN RILEY & ASSOCIATES, LTD.

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72

.1 deregulated decommissioning by default. You are-not 2 allowing a public hearing process by where there can be 3 cross examination to make sure that everything that' 4 everybody is saying is factual. We can't get at the facts, 5 and I am here today asking for a public hearing.

6 At Palisades we attempted to get a public hearing.

7 We went to the Supreme Court of the United States. The NRC 8 blocked us. We attempted to get an environmental assessment 9 and public hearings. We attempted to get an injunction to 10 prevent the loading of the casks at Palisades, and we were 11 denied an injunction in federal court by Judge Bell. We 12 were denied the injunction because the utility and the NRC 13 in my opinion perjured themselves to federal courts, and 14 told them if there is a problem, we can always unload these 15 things. Well, lo and behold, there is a problem, and you 16 don't have any unloading procedures, and you have not been 17 able to do that at Palisades. Now here it comes again.

18 I1am told trust us one more time, we have a 19 different system of storage, we are going with Westinghouse.

20 Is this again to be a generic ruling-process by which the 21 public doesn't have any public hearing process or 22 environmental assessments, environmental impact statements?

-23 It is a charade, and I for one don't wish to participate.

24 As I stated earlier, I am from Monroe, Michigan.

25 We had a Fermi I plant there which had a core meltdown in ANIN RILEY & ASSOCIATES, LTD.

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73 1 1966. It began disassembly in '73 through '75, very much on 2 the fast track. It was shut in '72, very much on the same 3 fast track. Of a particular work force that took that plant 4 apart, of 39 men, 35 of them are now dead of cancer. Now 5 you better think about that when you are considering worker 6 exposure. Go look into it. Word out to all workers who 7 have potentially decommissioned that plant at Big Rock, a 8 plant that ran for 35 years, similar in size to the Fermi I.

9 Fermi I ran for a total of 342 hours0.00396 days <br />0.095 hours <br />5.654762e-4 weeks <br />1.30131e-4 months <br />. Those risks are real.

10 I am asking for independent monitoring of that 11 plant that is verifiable to the public and to the citizens 12 of Charlevoix. Basically it boils down to trust. We do not 13 trust Consumers Power, we do not trust the NRC, and we want 14 independent verifiable monitoring of that plant.

15 We need the resident inspector to remain on site 16 and not to be removed after one year. We need a watchdog 17 there. I would like to know what is the full inventory of 18 radioactivity at the Big Rock plant. How irradiated is that 19 vessel? That concludes my comments.

20 MR. JOHNSON: Thank you.

-21 JoAnne Beemon.

22 MS. BEEMON: So that you don't have to crane your 23 neck.

24 I am JoAnne Beemon, and the real difficult thing 25 a-bout this whole problem, and we do have kind of a problem ANN RILEY & ASSOCIATES, LTD.

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74 1 here, it is a challenge or whatever, is that there are no 2 easy answers. Someone, a reporter said to me, "Well, what 3 do you want?" Here is JoAnne Beemon, who has been critical 4 of this industry for over 20 years.

5 We intervened in the spent fuel pool storage 6 expansion. We spent $10,900, you guys spent three mill ion 7 dollars, and we made a lot of nuclear lawyers rich. But 8 somebody said, "What do you want? If you are so concerned 9 about nuclear waste, what do you want? Why are you being 10 critical now?"

11 There are no easy answers. Nuclear waste is toxic 12 for hundreds and thousands of years. we are talking about 13 ice ages. We are talking about 10,000 generations of 14 children whose legacy from us will be nuclear waste. How 15 can we be responsible?

16 It is interesting to me that a utility who 17 produced this waste, telling us all the time that this is 18 not a problem and we can take care of it, now can't afford 19 20 years out of 250,000 years to SAFSTOR it until we can 20 perfect a technology of casks.

21 I say this very, very carefully and with a great 22 deal of respect. I hate sensationalism, although I am kind 23 of sensational sometimes. But we had a terrible accident in 24 Charlevoix, and it was about fireworks, and there were 25 people killed and people injured, and everyone said, "Who is ANN RILEY & ASSOCIATES, LTD.

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75 1 minding the store?" And we have a potential for several 2 Hiroshimas, for several Chernobyls, and it is-on the Big 3 Rock site and it is on that site now, arnd the Big Rock 4 Consumers Energy does not have enough faith in its own 5 technologies to know that that stuff can sit on that site 6 for 20 years and be safe.

7 What I beg of you guys, and I know I am not a 8 local, I have only been here 20 years. You have to be born, 9 here. It doesn't count coming in from Beaver Island and 10 being born in the harbor either. You have to be born here.

11 But I care about this town, and the question is what is the 12 right thing to do, and it is a real problem.

13 I guess to proceed with caution, to proceed 14 carefully. Basically we have been wined and dined very 15 nicely by Consumers Power Company. I have my own mug, I 16 have a T-shirt and a hat, and I like them. I won't wear 17 them in public. But we are being wined and dined because 18 the company does not want to hang onto its liability, which 19 is the nuclear waste.

20 We are being asked to peep to the federal 21 government, to be given ourselves, so that we are given 22 posses sion of that waste. We will have to be responsible 23 for that.

24 In favor of Consumers Power Company and in their 25 defense, the Department of Energy said they would take this ANN RILEY & ASSOCIATES, LTD.

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76 1 waste by January 1, 1998, courtesy of NRC and Congress. So 2 that waste belongs to us, the people, but us, the people, 3 got nowhere to take it, and nobody wants it, and Consumers' 4 Power Company, as long as that waste is on site, they are 5 liable for that. If they can get someone else to take 6 possession, it is all ours, and we are the people.

7 When you go out and when you say I believe in 8 Consumers Power Company, I believe in those casks, even 9 though they have failed time and time again, and look at 10 what is happening at Palisades. They can't unload those 11 things. They are too hot. If they are put in a fuel pool, 12 it flashes the steam and you have got radioactivity. It is 13 a problem. They do not know what they are doing, and they 14 are asking you to trust them now because they don't want the 15 waste on their property because they can't tolerate the 16 liability. Utah does not want it and Nevada does not want 17 it and the Indians don't want . Nobody wants it.

18 So you in Charlevoix, when you let them put that 19 nuclear waste in experimental casks, you just might be 20 living next door to that stuff for 20 or 40 or 100 years.

21 But that isn't even the question. The question is what is 22 right and what is moral, and kindergarten ethics say if you 23 make a mess, it is your responsibility to clean it up, and 24 the utilities and the NRC have never understood that. You 25 don't create something that-is deadly for 150,000 years or ANN RILEY & ASSOCIATES, LTD.

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77 1, 200,000 years or whatever and not be able to be responsible 2 for it. And don't give me the crap about technology will be 3 developed and it will be okay. Our kids will come up with 4 an answer. That is irresponsible.

5 But we are here now so what do we do with it? We 6 proceed with caution. To put the waste in casks is the 7 wrong thing to do. It is the wrong time to do it. we 8 should be proceeding with caution, and you know what, nobody 9 in Charlevoix is going to like that option. Nobody is going 10 to like me for-saying, hey,. the right thing for us to do is 11 keep it in our own kids' backyard for 20 years. I am going 12 to get a really worse reputation here than ever. But nobody 13 wants it. They don't want it in Utah or Nevada or anywhere.

14 Yucca Mountain is still as far away from being complete as 15 it was 20 years ago. More questions are coming up.

16 Also, the other thing that is very, very troubling 17 to me is that they are organizing in other'states, and that 18 is one of the reasons why they want to move now, because 19 other states are organizing. They do not want it, they are 20 not going to get it across borders, and democracy will be 21 really tested because we can't even get Consumers Power 22 Company, who produced this stuff, to take responsibility.

23 How are we going to make Utah and Nevada take it?

24 It is a really, really, really complex, difficult 25 problem, and it is something I wish -- there ain't no good ANN RILEY & ASSOCIATES, LTD.

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78 1 guys and there ain't no bad guys. It is just you and I, you 2 know, and we have to figure out what the solution is or the 3 best solution. To jump into a technology that has not been 4 shown to be safe because we want to get it of f site so we 5 can make condos, extend the Gold Coast or whatever we want 6 to do is immoral and it is irresponsible.

7 MR. JOHNSON: Thank you.

8 Kevin Kamps, K-a-in-p-s, do you have comments?

9 MR. KAMPS: Yes.

10 My name is Kevin Kamps. A lot of my concerns have 11 already been brought up by some of the earlier speakers just 12 now.

13 I'have been to the Chernobyl region two times so 14 far. I work with a group called the-Chernobyl Children's 15 Project, and I have met liquidators who were the people who 16 were sent in in large numbers, in the tens of thousands, 17 hundreds of thousands actually, in the Chernobyl region at 18 the plant, but in the whole surrounding Area who were 19 responsible to try to deal with the catastrophe, to try to 20 supposedly liquidate the situation. Just the devastation, 21 to witness that firsthand just has given me a lot of passion 22 for the issues involved.

23 I am just -- I am concerned about so many things.

24 Some of the issues have already been brought up. But I am 25 concerned-about the transport of the wastes on the roads.I ANN RILEY & ASSOCIATES, LTD.

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79 1 really am not confident in the cask technologies at this 2 point. The more I learn, the less confident I am at this 3 point.

4 I am concerned about the release of this land as a 5 green field. That really concerns me. Because I feel like 6 people -- I wonder if there will be markers on the site to 7 let people know that this is, you know, what this site is 8 about and what health hazards there might be ass~ociated with

.9 it.

10 And I am concerned about that if this is the 11 supposed answer to the se problems, I wonder about, like if 12 Congressman Upton from Kalamazoo gets his way and the waste 13 is transported to Yucca Mountain, Nevada, my concern is with 14 those people as well and the people in Barnwell, South 15 Carolina where all of this material is being rushed to in 16 the next few years.

17 There is such a number of low level, so called low' 18 level waste sites around the country that are l~eaking, the 19 radioactivity is leaking. And Yucca Mountain would also be 20 a very poor choice for the high level repository with the 21 earthquake fault lines that run through that area and the 22 movement of water. It appears to be a desert, but there is 23 an underground aquifer that could- come in contact with the 24 wastes. Rainwater passes through the fractured earth out 25 there.

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80 So I don't feel that these are really solutions.

2 I feel like it is just shifting the problems. It is 3 shifting it onto the roadways and onto the railways. It is

4. dumping it on other Places, and I do feel it is a rush, 5 because the Perspective of time we are talking about is 6 pretty great. It is incomprehensive actually.

7 I am interested to stay involved in this issue so 8 that wise decisions can be made, and that is why I am here 9 tonight.

10 MR. JOHNSON: Thank you.

11 Corinne Carey.

12 MS. CAREY: I would like to use a table. I don't

. 13 talk off-the-cuff very well.

14 I did manage to make some extra copies of some of 15 the information that I am using tonight. So this is 16 available, a few copies, for anybody who is interested in

.17 seeing it.

18 I had not planned on saying this part. However, 19 this is from a comment in a video by Mary Sinclair, and I 20 have copies of that too if you would like copies of that.

21 On June 13th of 1996 the chairman of the Nuclear Regulatory 22 Commission, Dr. Shirley Jackson, requested the Office of the 23 Inspector General, that is OIG, to evaluate NRC staff 24 actions in relation to the explosion at Point Beach that was 25 mentioned earlier this evening. The chairman'also asked the ANN RILEY & ASSOCIATES, LTD.

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81 1 Inspector General to review the entire dry cask storage 2 program ,with emphasis on loading and unloading techniques, 3 the NRC's. staff, scope and criteria for completing safety 4 evaluations, as well as other matters, and then it gives the 5 official number here.

6 Among the conclusions issued by the Inspector 7 General in a report on December 10th of that year, 1996, was 8 the following statement: "INRC staff told us they do not 9 formally approve or validate licensee loading and unloading 10 procedures because the agency does not have sufficient staff 11 or expertise to review each procedure," and again it cites 12 the source of this.

13 I am curious to know how that fits with the 14 discussion we have been having tonight.

15 Oh, Mr. Harris, one for you, and' this is for the 16 panel. I don't know how you handle this.

17 My statement,,to whom it may concern, public and 18 industry, government and citizen, regarding the Big Rock 19 nuclear-plant decommissioning. That any business in a 20 democracy should require decommissioning of major 21 contaminants of ever-lasting, life-threatening components is 22 shocking.

23 That fast-track shortcuts be adopted outside the 24 NRC and Community Advisory Board approvals of original 25 company proposed plan trivializes the stated policy and ANN RILEY & ASSOCIATES, LTD.

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82 1 worker and public health and safety. Because in this blue 2 book that we already mentioned is the page that mentions 3 specifically, "The public should not only be fully informed 4 of the decommissioning actions at a particular site, but 5 also be able to effectively participate in site 6 decommissioning decisions," and it goes on. But when the 7 plan has been changed, is that effective public input?.

8' Increasing evidence, and I have a packet of things 9 here, of nuclear hazard requires a moral nation to do the 10 right thing and apply the precautionary principle with proof 11 of no harm on the generator. The public trust requires that 12 sudden closing of Big Rock two and a half years early not 13 only demonstrates full and thorough preparations and 14 specific process -- it must demonstrate full and thorough 15 preparation and specific process, but fully inform the 16 public of various impacts.

17 No. 1. Restructuring or deregulation of the 18 electric industry, which was given at the press conference 19 as one of the major reasons for two and a half years early, 20 shifting of stranded costs to the ratepayers and/or 21 taxpayers.

22 No. 2. Real estate developments and connections, 23 including PR aspects on 'downstream/downwind areas, and 24 specific details on green fields.

25 No. 3. At least a fivefold increase in worker ANN RILEY & ASSOCIATES, LTD.

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83 1 exposure because of immediate dismantling of high level 2 components, and that is this kind of information that we 3 already referred to. Again, the stuff I have that I can 4 call documentation comes from various sources that I feel 5 are very credible, but I haven't been able to get a specific 6 documentation which -- could you do me a favor and even put 7 the page number where I will find this? I mean that book is 8 twice as thick as 'this book. All right?

9 No. 4. official written consideration and 10 response to independent citizen-requested analysis by Dr.

11 Marvin Resnikoff, who was here a year-year and a half ago, 12 specifically on a necessary 50 year cool-off period for 13 worker and public and transport safety. And one of the 14 points he made was what is the rush to decommission it now 15 when it can't be transported anyway because the casks, if 16 they have been designed, have certainly not been built, and 17 certainly not *been tested, and certainly do not have a 18 record of safety on which to rely? So where is the stuff 19 going to go, even though the place closes down early? Also, 20 clarification of full financing sources and process, and it 21 is my understanding that the two and a half years short also 22, cuts off the ratepayer input on the decommissioning finance 23 costs.

24 No. 5. Documentation for all of the above and on 25 continual on-site monitoring of radioactivity and releases.

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84 1 To decommission this pioneer nuclear plant is 2 essential. To set a responsible and thoroughly accountable 3 precedence is both urgent and the right thing, and I.have 4 signed it my name, and for my grandchildren, Mike, Paula, 5 Megan, Brandon, Linda, and my great-grandkids, Jory and 6 Gypsy.

7 MR. JOHNSON: Thank you.

8 Does anyone else at this time have any public 9 comment that they would like to make for the record? If you 10 have any written comments that you would like to have for 11 the record, you can place them up here on the desk and they, 12 will be put into the record.

13 If there are no other comments, I think we will 14 adjourn this meeting and thank you all for coming. Drive 15 safely.

.16 [Whereupon, at 9:35 p.m., the public meeting was 17 concluded.]

18 19 20 21 22 23 24 25 ANN RILEY & ASSOCIATES, LTD.

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REPORTER' S CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:

NAME OF PROCEEDING: PUBLIC MEETING BIG ROCK POINT DOCKET NUMBER:

PLACE OF PROCEEDING: Charlevoix, MI were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.

Elizabeth A. Higdon Official Reporter Ann Riley & Associates, Ltd.