ML20207A639

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Transcript of 990406 Public Meeting in Solomons,Maryland Re Draft Environ Impact Statement for Calvert Cliffs NPP to Support Review of License Renewal Application.Pp 1-164. Supporting Documentation Encl
ML20207A639
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Site: Calvert Cliffs  Constellation icon.png
Issue date: 04/06/1999
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1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION ,

I 3 ***

4 PUBLIC MEETING - ENVIRONMENTAL 5 REVIEW FOR THE CALVERT CLIFFS l

6 LICENSE RENEWAL APPLICATION 7 ***

8 9 Holiday Inn Select i

10 155 Holiday Drive 11 Solomons, MD 20688 12 Tuesday, April 6, 1999 13 14 The public meeting, commenced, pursuant to notice, i 15 at 1:33 p.m. .

1 16 17 PARTICIPANTS:

18 FRANCIS CAMERON, Facilitator 19 CYNTHIA CARPENTER, NRC 20 CHRISTOPHER GRIMES, NRC 21 THOMAS KENYON, NRC 22 MARY ANN PARKHURST, Pacific Northwest National 23 Laboratory 24 ROBERT PALLA, NRC l

25 j 9905270120 990512

ADDCK 05000317 PDR  ;

L- >

2 1 PROCEEDINGS 2 [1:33 p.m.]

3 MR. CAMERON: Good afternoon, everybody. Could 4 you all come up and take a seat. We're going to get started 5 right now.

6 Good afternoon. I would like to welcome you to 7 the Nuclear Regulatory Commission's public meeting on the 8 draft environmental impact statement for the license renewal 9 application for the Calvert Cliffs Nuclear Power Plant.

10 My name is Chip Cameron, and I'm the special 11 counsel for public liaison at the Commission, and I'm going 12 to serve as your facilitator for today's meeting.

13 This afternoon, you're going to have an 14 opportunity to hear from the NRC on the contents of the 15- draft environmental impact statement on the license renewal 16 application, and you're also going to get an opportunity to 17 ask questions of the NRC and to make comments to the NRC on 18 the draft environmental impact statement and on license 19 renewal generally.

20 My role as a facilitator will be generally to try 21 to help all of us have a good meeting this afternoon.

22 Specifically, what I would like to assist you with is to 23 make sure that everybody who wants to talk gets an 24 opportunity to talk this afternoon. Secondly, I would like 25 to make sure that if there's anything that you don't u .. .. . .

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3 1 understand, that we clarify that for you and also if there's 2 anything the NRC staff doesn't understand'in terms of a

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i 3 comment or a question, that we clarify that also.

4 Finally, I want to assist you in keeping the 5 - meeting civil, focused and relevant. In regard to the focus j l l 6 of the meeting, we are here to talk about the draft 7 environmental impact statement, but we realize that are 1 8 broader issues of concern here and there will be t l

9 opportunities for you to express those concerns also. I 10 The NRC is taking written comments on this draft 11 environmental impact statement and our speakers will tell 12 you where those are to be submitted and when, but we're here 13 this afternoon to meet with you in person and to listen to 14 your comments. Any comments you make this afternoon will be 15 treated just as we treat the written comments, which is to 16 evaluate these comments and to respond in a summary that's 17 in the final environmental impact statement.

18 In terms of ground rules, they're fairly simple.

19 If you have something to say, if you could raise your hand 20 and I'll recognize you and either come up to this microphone 21 or, if you want to speak from the podium, you can do that, 22 or I can pass you this talking stick. Please state your 23 name and affiliation if appropriate. .

24 We're keeping a transcript of the meeting. That 25 transcript will be available. So we want to make sure that e J

1

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4 1 te have your name and affiliation on record. Along those 2 same lines, I would ask yt' to only speak one at a time so 3 that we can listen to what t'.ae person who's speaking has to 4 say, and also so that we can get a clean transcript of wh tt 5 the person is saying.

6 I would also ask you to be to the point in your 7 comments. I'm not going to establish any rigid time limit 8 on comments. Try to keep it in'the five- or six-minute-9 period. I'm sure some people will go beyond that, but. may 10 have to ask you to summarize if you're going on too long so 11 that we can get to other people who need to talk, who want 12 to talk this afternoon.

13 There are sign-up cards for people who want to 14 speak. That's basically for our purposes in trying to plan 15 for how much time to give, and I will go through those cards 16 to make sure that everybody who signed up has an opportunity 17 to speak. But very simply, just raise your hand when you 18 have something to say.

19 Our agenda this afternoon is going to begin with a 20 meeting overview, and Cindy Carpenter from the NRC is going 21 to give you sort of a guide to the -- to what you can expect 22 to hear throughout the meeting, and then we're going to go l 23 right from Cindy's presentation to Chris Grimes from the 24 NRC, and he's going to talk about license renewal generally, 25 the status of license renewal, the status of the other i

5 1 issues that are being looked at in additional to the draft 2 environmental impact statement issues, and then we'll go to 3 Chris for comments and questions.

4 We're going to have comments and qu'stions after 5 every -- pretty much every agenda item so that you don't 6 have to sit here and just listen to the NRC talking for the ,

7 whole afternoon.

) 8 Next, Tom Kenyon from the NRC will talk about the 9 National Environmental rolicy Act process. This is the NEPA 10 process under which the draf t environmental impact statement 11 was developed. Then we're going to get really specific.

12 We're going to go to Mary Ann Parkhurst, and I'll have 13 everybody introduce themselves ir. a minute for you, who is 14 going to talk about the specifics of the draft environmental 15 impact statement, and also Bob Palla from the NRC is going 16 to talk about some more specifics.

17 The last session is preliminary conclusions.

18 we're going to go back to Tom Kenyon for that.

19 We want to try to be as interactive posrible and 20 we want to give you some specific information this 21 afternoon. Now, for those of you who have breader comments, 22 there are two appropriate times to m.tke those comments, 23 either after Chris Grimes' nession, which will be the second 24 session coming up, or after the last presentation that talks 25 _about overall conclusion:. Let's keep the other areas for

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l 1 specific questions on those particular areas. i 2 So if you have questions, comments, please don't 3 be bashful, please make them, make the comments, ask the 4 questions, and we'll look forward to hearing them.

5 We do have copies of the viewgraphs that you're .

I 6 going to see this afternoon and we will pass those out if {

7 you hadn't picked them up already. Does anybody need a copy 8 of the slides? Just raise your hand and Barry will -- okay.

9 There's a couple of people. Barry will pass them out to you 10 and then we'll get rolling here.

11 All right. Well, let's get started with the first

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. presentation from the NRC, and this is Cindy Carpenter, who 13 is going to give you an overview of the meeting.

14 MS. CARPENTER: Okay. Hi. My name is Cindy 15 Carpenter, and I'm the branch chief for the Generic Issues, 16 Environmental, Financial, and Rulemaking Branch in the 17 Office of Nuclear Reactor Regulation in the NRC.

18 We are here today to discuss the results of the 19 NRC's environmental review of the Calvert Cliffs Nuclear 20 Power Plant in support of Baltimore Gas & Electric's license 21 renewal application for the plant.

22 We're going to talk a little bit about the 23 statutory requirements for this action, the results of the 24 staff's review, the preliminary conclusions of the staff 25 resulting from this review, the schedule that we're working l

7 1 to, and we will provide members of the public the 2 opportunity to comment or ask questions about what is in our 3 staff's environmental impact statement or on anything that 4 . you heard today.

5 Next slide.

6 To provide you with some background, the operating 7 licenses for the Calvert Cliffs Nuclear Power Plant Units 1 8 and 2 will currently expire in the years 2014 and 2016 9 respectively. As will be discussed later, the Atomic Energy 10 Act allows a utility such as Baltimore Gas & Electric to 11 renew its license for up to 20 years. As part of the 12 license renewal process, it requires the NRC to l

13 systematically consider the environmental impacts during our i 14 decisionmaking process on this matter.

15 Slide 4.

16 Calvert Cliffs submitted their license renewal 17 application in April of 1998. We held a scoping meeting 18 here in July of 1998 to identify issues that may be needed i

19 -- that have needed to be addressed during the staff's i 20 - review. ,

21 In March of this your, the NRC issued a draft 22 environmental impact statement describing the results of our 23 review. We are currently in the middle of the comment 24 period for that document, during which we will receive 25 comments from members of the public on its contents. These 4

8 1 comments may help the staff evaluate the acceptability of 2 the environmental aspects of the Calvert Cliffs license 3 renewal, which brings us to why we're here today.

4 Next slide.

5 The purpose of today's meeting is to present the 6 results of the NRC's environmental review, to discuss what 7 our staff considered, to clarify any issues to members of 8 the public, to assist you in preparing comments, to identify 9 ';hether or not an environmental license renewal issue was 10 inappropriately excluded, accept any comments from you or 11 other members of the public, and to discuss the schedule for 12 submitting comments and how to submit them.

13 Now, before we get into the details of the NRC's 14 environmental review, I would like to turn the podium over 15 to Mr. Christopher Grimes. He is the Branch Chief for the 16 License Renewal and Standardization Branch, and he'll 17 provide you an overview of the entire license renewal 18 prccess.

19 MR. GRIMES: Thank you, Cindy.

20 As Cindy mentioned, my name is Chris Grimes, I'm 21 the chief of the license renewal and standardization branch 22 in the NRC's Office of Nuclear Reactor Regulation.

23 As a way of generally describing the license 24 renewal process, I would like to start off with a 25 description of the NRC and its responsibilities.

9 1 Could I have slide 6, please?

2 NRC's mission is to regulate the civilian use of 3 nuclear materials --

4 MR. CAMERON: Please speak up a little bit.

5 MR. GRIMES: Thank you, Chip.

6 The NRC's mission is to regulate the civilian use 7 of nuclear materials, to ensure adequate protection of 8 public health and safety, to promote the common defense and 9 security, and to protect the environment.

10 The NRC's authority is derived from the Atomic 11 Energy Act of 1954, the Energy Reorganization Act of 1974, 12 as well as amendments to those acts and other legislation 13 involving security waste and energy policies.

14 The NRC's regulations are issued under Title 10 of 15 the United States Code of Federal Regulations, which we'll 16 refer to repeatedly today as 10 CFR. 17 For commercial power reactors, the NRC's 18 regulatory functions include licensing. A nuclear plant 19 license is based on a set of established regulatory 20 requirements to ensure that the design and proposed 21 operation of the plant are safe based on radiological safety 22 standards.

23 NRC conducts routine inspections to ensure that 24 the plant design and operation conform to the license 25 requirements and enforcement actions are taken in the event l

10 1 the license requirements are nct satisfied.

2 Could I have slide 7, please.

3 The Atomic Energy Act and the NRC regulations 4 limit commercial reactor licenses to 40 years, but they also 5 envisioned the renewal of such licenses and the regulations 6 were revised to provide for license renewal for up to an 7 additional 20 years.

8 The 40-year term was originally selected on the 9 basis of economic and antitrust considerations, not 10 technical limitations. But once selected, the design of 11 several systems and structural components were engineered on 12 the basis of an expected 40-year service life. The 13 requirements for the initial 40-year license are contained 14 in 10 CFR Part 50. i l

15 When the first reactors were const'ucted, r major 16 components were expected to last at least 40 years.

17 Operating experience has demonstrated that that expectation i

18 was unrealistic for some major plant components, such as the 19 steam generator in a pressurized water reactor; however, 20 research over the last decade has concluded that there are 21 no technical limitations on plant life since major 22 components and structures can be replaced or refurbished.

23 Thus, plant life is determined primarily on economic 24 factors.

25 As a result, the NRC established safety

11 1 requirements in 10 CFR to provide for license renewal. The 2 rule which was originally issued in 1991 and amended in 1995 l

3 provides that the basis upon which a plant was originally '

4 licensed remains valid after 40 years, and can be carried 5 over into a 20-year period of extended operation. That rule

-6 requires that an applicant demonstrate that the applicable 7 aging effects will be adequately managed for a defined scope 8 of passive long-lived system structures and components based 9 on a determination that aging for active components will be 10 adequately managed by existing maintenance and surveillance 11 programs and other aspects of the existing license can carry 12 through under the period of extended operation.

13 The rule also requires that certain time-dependent 14 design analysis be identified and evaluated. A new license 15 can then be granted upon a finding by the Commission that 16 actions have been or will be taken so that there is 17 reasonable assurance that applicable aging effects will be 18 adecuately managed for that period of extended operation, j 19 and whether or not adverse environmental impacts of license 20 renewal are so great that preserving the option of license 21 renewal for energy planning decisionmakers would be 22 unreasonable.

23 The United States currently receives about 20 l 24 percent of its electricity from the 103 operating nuclear 25 power plants. The electricity sector is moving rapidly into

12 1 a deregulated environment in which energy supply choices 2 will be dictated by cost to the consumers. At the same time 3 there are growing pressures to limit. fossil fuel emissions 4 for both clean air and potential global climate change 5 considerations.

6 Deregulation and competition have increased 7 utility interest in license renewal to strategic importance 8 because the large generating plants have become vital 9 economic assets. Operating nuclear power plants are 10 expected to remain competitive after retail electric 11 restructuring provided that the costs associated with safely 12 maintaining operating plants can be reasonably projected 13 into the future.

14 Some U.S. plants may not apply for license renewal 15 for economic reasons. The NRC established the license 16 renews.1 requirements so that any plant that is financially 17 and materially capable of operating safety beyond the 18 current term should have that opportunity as is described in 19 the generic environmental impact statement for license 20 renewal. Calvert Cliffs is the first plant to apply for 21 license renewal. A second renewal application for the 22 Oconee plant in South Carolina was received in July of 1998.

23 Although these licenses do not expire until 2013 24 or later, many utilities are interested in pursuing license I

25 renewal today to ensure that they clearly understand what I

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1 requirements will be necessary for an extended license for 2 future planning. May I have slide 9, please.

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3 The licensing process consists of parallel I4 4 technical and environmental reviews. The technical review i

l 5 is documented in a safety evaluation report for the aging )

6 management aspects of the renewal application, while the I 7 environmental review is documented in a supplement to the 8 generic environmental impact statement.

9 The aging management findings will ba verified by 10 NRC inspections and reviewed by the NRC's Advisory Committee 11 on Reactor Safeguards in accordance with our usual practices 12 for licensing.

13 On March 21st, 1999 the NRC issued the safety 14 evaluation report, that is the technical or safety review, 15 which addresses the scope of passive long-lived systems, 16 structures and components, the applicabic aging effects and 17 4 the aging management programs. That report identifies open [

18 items in confirmatory matters related to the safety review  !

19 under Part 54 that must be resolved before the Commission 20 can complete its decision on a license renewal for Calvert 21 Cliffs. That report is available to the public.

22 Meetings will be held between NRC and BG&E in the 23 future to discuss the resolution of the open and 24 confirmatory items. The resolution of those issues will be 25 reflected in a revised report that is scheduled to be

14 1 completed by November, 1999.

2 Following receipt of the renewal application for 3 Calvert Cliffs in April 1999, the NRC received a request for 4 a hearing on the license renewal application. Because the 5 petitioner requesting the hearing failed to point to any 6 specific information in the application which raised a 7 safety concern, the request was denied.

8 As I said before, there will be meetings between 9 BG&E and the NRC to discuss the safety evaluation report.

10 Members of the public are invited to attend these meetings.

11 Time is designated at the conclusion of each of those 12 meetings for public comments and questions.

13 For example, monthly management meetings are held 14 in Rockville to discuss the status of the renewal review, 15 and a meeting will be held at the Calvert Cliffs Education 16 Center on April 15th to discuss the results of the 17 inspection activities that have been conducted thus far.

18 The Advisory Committee on Reactor Safeguards has 19 also scheduled public meetings on the safety evaluation 20 contents. They report their findings directly to the 21 Commission. They provide an independent advisory role and 22 provide a separate perspective that is submitted directly to l

23 the Commission for their decision.

24 They also hold public meetings that are 25 transcribed. A meeting of the ACRS Subcommittee on plant

. . . . . . . . . . . . . . . . . . _ . . . . . . _ _ _ . . .. _ _ _ .o

T 15 1 license renewal will be held in Rockville, Maryland on April 2 28th and 29th, 1999. Oral and written statements can be 3 provided during that meeting in accordance with the 4 instructions that are described in the notice of the meeting t

5 in the Federal Register. If there are any questions about 6 the overall licensing process or license renewal I would be 7 pleased to take them at this time.

8 MR. CAMERON: Could I just ask you to clarify one 1

9 thing first, Chris, before we get into questions? The 10 meetings that you spoke of, the BG&E-NRC meetings, the 11 Advisory Committee on Reactor Safeguards meeting -- how do 12 people find out if there is going to be a meeting and is 13 there a sheet that lists all future meetings for, say, the 14 rest of the year?

15 MR. GRIMES: All of the meetings at the NRC are 16 made available on the web and there is also a telephone 17 designated for announcements on meetings that are being 18 held. The Advisory Committee on Reactor Safeguards and the 19 Commission meetings are published in the Federal Register as 20 well as being announced on our normal meeting announcement 21 system.

22 MR. CAMERON: Sometime perhaps we can provide 23 people with both the phone number and the website, the 24 address for the website, in case anybody is interested in 25 keeping up with this.

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16 1 MR. GRIMES: Okay.

2 MR. GUNTER: My name is Paul Gunter and I am with 3 Nuclear Information Resource Service. Chris, I have got a 4 question with regard to the process as to how we are moving 5 forward here with a particular in the GEIS.

6 When I originally read the GEIS, the 7 transportation issue for nuclear waste -- that was a 8 Category 2 issue. Has that been changed or has that --

9 MR. GRIMES: It is being changed.

10 MR. GUNTER: Being changed.

11 MR. GRIMES: There was a proposed -- there is a 12 proposed rulemaking pending right now.

13 MR. GUNTER: Right. Well, see, I think this 14 speaks to my concern because what we are looking at upon the 15 board here and what we are experiencing is a little like a 16 moving target in terms of just keeping up on the changes 17 that are being made'as this road is being paved, you know, 18 again does not bring _any increasing degree of public 19 confidence in this process, as we see it.

20 I would like you to give me some sense, if you can 21 right now, just how nuclear waste transport moved from a 22 Category 2 issue, which was an item that we could have 23 spoken to, now to a Category 1 issue? Because my suspicion 24 is that again the NRC has acquiesced to an industry lobby 25 effort to take yet another issue off the table.

17 1 I am wondering if you can clarify that for me.

2 MR. GRIMES: Yes, I would be happy to, because we 3 prefer not to think of it as taking issues off the table but 4 putting them in their proper place.

5 There is rulemaking that is going on to address 6 certain issues on a generic basis rather than have them 7 resolved on plant after plant. If the same answer is going 8 to apply to all plants, then we treat those issues 9 generically, just as we did when we originally issued the 10 proposed changes to Part 51 that depended on that generic 11 environmental impact statement and the newspaper accounts 12 that describe us as acquiescing to industry pressure or to 13 public pressure or to Congressional pressure are actually 14 measures of how we are reacting to questions about 15 efficiency and effectiveness and to the extent that you have 16 concerns about the generic issues associated with waste 17 handling or waste transportation or waste disposal, those 18 issues are being addressed on a generic basis and that is 19 the appropriate forum for any interested public to engage 20 us.

21 We are obliged to address those things to all 22 interested parties, not just on a one plant specific basis.

23 MR. GUNTER: Could I just follow up? I don't need 24 the microphone.

25 MR. CAMERON: You do.

18 1 MR. GUNTER: Okay. So this is,-what we are 2 looking at is a draft report.

3 MR. GRIMES: That's correct.

4 MR. GUNTER: Okay. Did the industry, were the 5 industry comments filed on this? I am trying to get some 6 sense -- obviously this is a moving target and I am trying 7 to get some sense of where the public retort is to industry 8 comments on this in terms of, okay, so the industry 9 obviously wants to take transportation off the table and in 10 your eyes that is putting it in the more appropriate place,

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11 but have they done-that by ru.lemaking?

12 MR. GRIMES: It is a rulemaking that is out for 1 13 public comment right now.

14 MR. GUNTER: Okay. Can you give me a Federal 15 Register cite on that?

16 MR. GRIMES: I would be happy to.

17 MR. CAMERON: Yes, I think that it may be helpful 18 to clarify for everybody here that doing something through 19 rulemaking is a public process and there is a proposal 20 issued that people can comment on and Chris will provide 21 that Federal Register notice.

22 One other question that comes up that Paul raised 23 I think -- are the comments.that anybody files on the draft 24 environmental impact statement, are they being posted on the 25 web as they come in like comments on a proposed rule are, or

19 1 they will only be available -- are those comments available 2 somehow?

3 MR. KENYON: I am Tom Kenyen. I am the 4 Environmental Project Manager. It wasn't our intent to post 5 them on the web. However, when we issue the -- they are 6 available through the public document room. They can be 7 obtained through the PDR and we will be putting all the 8 comments and their disposition in the final environmental 9 impact statement in the Appendix A to the document.

10 MR. CAMERON: Okay .nk you, Tom, but if someone 11 wants to look at another y s comments before they file, 12 assuming that those -- th aan look at those comments that 13 have already been filed L_ going to the NRC's public 14 document room?

15 MR. KENYON: That's correct.

16 MR. CAMERON: Okay. Thank you very much.

17 MR. GRIMES: I would also like to mention that the 18 environmental impact statement, the draft environmental 19 impact statement, and the NRC safety evaluation report are l 20 now or will be in the future available on the web.

21 MR. CAMERON: Okay, we have a question or a 22 comment over here. Robin?

23 MR. MILLS: My name is Robin Mills. I am Director 24 of the Maryland Safe Energy Coalition. You stated 25 previously in your comments that all the parts could be l

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20 1 replaced or refurbished. In reference to that statement, 2 how do you plan to replace or refurbish the reactor pressure 3 vessel as the nil ductility transition temperature is i l

4 increasing due to neutron embrittlement and defects caused l

5 in the metal?

6 MR. GRIMES: The repair or replacement of the 7 reactor vessel has a variety of different concepts that have 8 yet to be demonstrated, but are being tested in foreign 9 countries. Right now there are experiments ongoing that are 10 demonstrating how annealing could be used to change the 11 material properties of a reactor vessel and in Tokyo later 12 this month there is going to be a paper presented by the 13 Japanese on how they would propose to replace a reactor 14 vessel should it come to that, but my general comment about 15 the conclusion about the viability of license renewal was 16 intended to -- the concept that if there is any part of the 17 plant that does not satisfy its design requirements, it's 18 technically feasible to repair or replace that up to and 19 including replacing the reactor vessel, but it becomes very 20 expensive and it becomes an economic consideration that the 21 utility would have to face when they reach that point.

22 Present analysis for all of the reactor vessels in 23 the United States indicate that they have life expectancies 24 that approach 60 years depending on what the continued 25 fluents on the reactor vessels -- what those measurements

21 1 indicate. Some of them will fall short and they will 2 probably end up having to shut down before the end of a 3 renewed license life.

4 MR. MILLS: Just as a follow-up, there are samples 5 of metal that are placed inside the reactor vessel. Can you 6 tell me or do you know how many samples remain at Calvert 7 Cliffs to test the nil ductility transition temperature over 8 the 60 year lifespan? Are there enough samples left to 9 prove that the reactor vessel is safe?

l 10 MR. GRIMES: The' answer I believe is two specimens 11 left in the vessel, although I am not sure, but I also know I

12 that there are plants that are using data from other vessels j 1

13 and they have programs for sharing information on the 14 material conditions so even if there weren't any specimens 15 there would still be an adequate database for the ve.sel to 16 project its material conditions.

17 Some of those details are described in the safety 18 evaluation report that we issued on Calvert Cliffs and on 19 the other plants. We have routine reports on the material 20 specimens when they are submitted and when those are 21- available publicly.

22 'MR. CAMERON: If someone wants to get a copy of 23 the SER that discusses those issues, we'll be able to tell 24 them how they can get a copy?

25 MR. GRIMES: Yes.

i i

22 1 MR. CAMERON: Are there any specific meetings 2 coming up between the NRC and the licensee on the nil 3 ductility or any of the issues that Robin was talking about?

4 MR. GRIMES: Not on those specific topics.

5 However, I imagine that those will most likely be covered 6 during the ACRS meetings, and so if you have an interest in 7 those topics, I would encourage you to attend the ACRS 8 meetings.

9 MR. MILLS: Is that still an open item? I

{

10 MR. CAMERON: The question is, is it an open item?

11 The answer is?

12 MR. GRIMES: I don't believe so. I think that 13 that section might have had a confirmatory item.

14 MR. CAMERON: Okay. Thank you very much. l 15 Other questions? Comments? David.

16 MR. LOCHBAUM: My name is David Lochbaum, with the 1

17 Union of Concerned Scientists. l l

18. I looked at the safety evaluation report that the 19 NRC issued in March of '99 and the question it has on this  !

20 process. The comment period for both the environmental and 21 the license application of Part 51 and Part 54 started on  ;

22 July 8th of last year and ended on August 7th.

23 Since that time Baltimore Gas & Electric, 24 according to Appendix A to safety evaluation report has 25 supplied 47 supplements to the original application. In

23 1 counting up the pages, it is more than the original 2 application, so basically an incomplete and inaccurate 3 document was submitted to the public to provide comments on.

4 After that time the public doesn't have a chance 5 for the hearing that's shown up on your drawing here. Any 6 issue that comes up as a result of the review of this'47 7 additional information, you don't have a shot at a hearing.

8 That doesn't seem to us to be a fair process -- where the

9. public gets *,o watch but doesn't get to participate.

10 Do you see that as a fair process?

~1 1 MR. GRIMES: We believe it is a fair process and 12 it is a longstanding process in terms of filing an ]

13 application, having the regulatory authority ask questions 14 and exchange information. The fact that this was the first 15 of a kind-in terms of the format and content of an 16 application, I am surprised at the amount of information 17 that flowed back and forth, not necessarily supplementing 18 the application as much as simply clarifying it and allowing 19 us to test it. l 20 With regard to the hearing process, the standards 21 for establishing a formal adjudication of issues, it 22 normally sets out to be conducted in parallel with rather l 23 than' sequentially, and that is not unique to this licensing 24 process. It is typical of all licensing processes.

d 25 MR. LOCHBAUM: In the original licensing there i

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24 1 were two stages. You had a hearing process at the beginning 2 and a hearing process between the safety evaluation report 3 and the original license being granted.

4 The second one has been taken out and it was taken 5 out, we feel, so that the public doesn't have a shot in 6 determining the outcome.

7 MR. GRIMES: The public can petition at any 8 time -- and I would encourage you to -- we are continuing to 9 work with the UCS and others in terms of trying to improve 10 those processes, but from the standpoint of this process, 11 identifying issues to be litigated at the beginning is the 12 same process and the same concept that was applied when a 13 petition ~or when an application was received for an 14 operating _ license and that was --

15 MR. LOCHBAUM: No. It's different. It is 16 significantly different. I 17 In the beginning you had two opportunities for 18 public hearings, now you have one. This one you have to 19 look at a document in 30 days that the NRC Staff has 20 estimated it will take 22 manyears to review and come up 21 with contentions, and now you are locked out, and you 22 consider that to be that same as the original licensing?

23 MR. GRIMES: Yes, I do.

24 MR. LOCHBAUM: It's both the NRC but other than 25 that it is not --

25 1 MR. GRIMES: From the standpoint, as I said 2 before, of the policy statement that the Commission has 3 issued in terms of whether or not there are issues that 4 should be formally litigated, the petitioner first has to 5 identify that there is something worth litigating, and that 6 is, in our view, comparable, but to the extent that -- you 7 know, your concerns about where the public involvement 8 should be and what information should be available, you 9 know, the Commission will consider those in terms of whether 10 or not there is a better process -- and to identify a better 11 process that you think would still achieve the desires of 12 efficiency and effectiveness.

13 MR. CAMERON: Okay. We have I think a 14 clarification here from the Office of General Counsel and 15 then we have another comment up here.

16 MS. ZOBLER: Marian Zobler, Office of the General 17 Counsel. Just to clarify, I think Mr. Lochbaum is thinking 18 of a construction permit and an operating license, two  ;

I 19 different licenses, two different processes. And Mr. Grimes  ;

20 is correct that what -- I'm sorry, can you hear me? I am j i

21 not used to microphones. I also have a bit of a cold. I l l

22 apologize. j 23 And what Mr. Grimes said is correct, is that the l 24 normal process, 30 days to request a hearing after the 25 notice availability, then at such time later a licensing

26 1 board will establish a time for the filing of what the NRC 2 calls contentions. If you are familiar with NRC practice, 3 you know what those are. Very specific safety concerns that 4 a petitioner may seek to raise. And I just want to clarify 5 in case there is any confusion.

6 MR. GRIMES: I would also to emphasize, --

7 MR. CAMERON: Thanks, Marian.

8 MR. GRIMES: -- you know, we are trying to point ,

9 out that besides -- and forgive me, Marian, but besides 10 keeping lawyers employed and taking issues to court, we 11 conduct all of our activities in a public forum, and we 12 invite the public to watch and question. We offer the 13 public an opportunity to attend meetings and to ask 14 questions, and to make comments. And as I said before, the 15 ACRS meetings are transcribed meetings and those comments go 16 into the record as part of the decision. Yes, ma'am.

17 MS. DELLINGER: Can the public petition to close 18 Calvert Cliffs?

19 MR. GRIMES: Yes, ma'am.

20 MS. DELLINGER: We can?

21 MR. GRIMES: Certainly.

22 MS. DELLINGER: When can we do it?

23 MR. GRIMES: Any time. But you have to have good 24 cause.

25 MS. DELLINGER: And that means that we have to

27 1 file a lawsuit to close it?

2 MR. GRIMES: You can make petition to the 3 Commission at any time to take what you believe is an 4 appropriate action. Under 10 CFR --

5 MS. DELLINGER: Well, I think there are a huge 6 number of people who would like to file a petition to close 7 Calvert Cliffs.

8 MR. CAMERON: You may, in summary, in terms of the 9 public having an opportunity to comment on the technical 10 issues, the aging management issues, they can come to the 11 meetings that are going to be held. They can file what is I

12 called a 2.206 petition that is named after the section in 13 .the NRC's rules that allows any member of the public to file 14 a petition requesting action against any licensee. That is 15 the scope of the public comnients at this point. Is that 16 correct, Chris?

17 MR. GRIMES: That is correct.

18 MR. CAMERON: And if anybody needs more 19 information on any of that, please talk to the NRC staff 20 about that. We do have someone here from our Office of 21 General Counsel. As you -- and Barry has just given me 22- this, we do have a handout on the public petition process 23 that explains a little bit, Kay. I don't know if that will 24 help.

25 But I would just say that there are a number of

28 1 groups here, such as the Maryland Safe Energy Coalition.

2 They have a banner out there. We have Union of Concerned 1

I 3 Scientists, Nuclear Information and Resource Service, and 4 Critical Mass Energy Project, Public Citizen, as well as a 5 number'of others. So, please give us your affiliation when 6 you talk.

7 Anybody else have a question to Chris? Because we 8 are going to move on'to the real focus of the meeting today, 9 which is the Draft' Environmental Impact Statement. Final 10 questions right now? Remember, we will have sort of a broad 11 concluding section, if you want to come back and say 12 something then.

13 -All right. Let's go to Tom Kenyon, who is going 14 to talk about that. Thank you, Chris.

15 Before you start, we are going to have Mike help 16 us-adjust the mixer up here so that it will be a little bit 17 easier for you people to hear in the back, we hope.

18 Okay. Wow, maybe that is too much. How about 19 now? Is that a little bit better for you, people? Okay.

20 Good. Thanks a lot, Mike. Go ahead, Tom.

21 MR. KENYON: Good afternoon, my name is Tom 22 Kenyon, and I am the Environmental Project Manager for the 23- .Calvert Cliffs License Renewal Project. I work in the 24 Generic Issues, Environmental, Financial and Rulemaking 25 Branch in the Office'of Nuclear Reactor Regulation at the

29 1 NRC.

2 I intend to briefly talk about the processes 3 required by the national policy -- I'm sorry, the National 4 Environmental Policy Act, the so-called NEPA process, and l 5 then describe how that process translates into the ,

6 regulations at the NRC, and how the process and the 7 regulations are being implemented, to take a look at the 8 environmental impacts of license renewal for Calvert Cliffs.

)

9 NEPA was enacted in 1969 and requires all federal 10 agencies to use a systematic approach to consider 11 environmental impacts for certain decision making processes.

12 The NEPA process is a significant tool, although it is not 13 the only tool that we use in decision making. It is a 14 disclosure tool that involves the public. It invokes a 15 process whereby information is gathered by the federal 16 agencies to make better decisions, and then it documents 17 that information and provides the opportunity for the public 18 to take a look at it and evaluate the results.

19 .The NEPA process results in a number of different 20 documents, and one of the chief documents is an 21 Environmental Impact Statement that is required for all 22 major federal actions that significantly affect the quality 23 of the human environment.

24 There.are a couple of variations in the types of 25 Environmental Impact Statements that can be prepared,

30 1 depending on the nature of the proposed action. One of 2 these documents is what we have referred to already as a 3 Generic Environmental Impact Statement, or what we commonly 4 call the GEIS, which addresses the generic impacts common to 5 a number of similar proposed actions.

6 We also -- another related document is the 7 Supplemental Environmental Impact Statement which we are 8 going to be talking about today called a SEIS, where the 9 Environmental Impact Statement has already been issued, and 10 then additional information or issues may arise that need to 11 be considered and disclosed in the supplement.

12 As I will discuss shortly, the NRC uses both of 13 these kinds of documents in our environmental reviews for 14 the license renewal applications.

15 As I mentioned earlier, NEPA requires than an 16 Environmental Impact Statement be prepared for all the major 17 federal actions that significantly affect the quality of the 18 human environment. And the NRC has already determined that 19 license renewal is such a major federal action. Therefore, 20 we are going through the NEPA process now for Calvert 21 Cliffs, and we have prepared the draft supplement to the 22 license renewal Generic Environmental Impact Statement.

23 That supplement, Supplement 1, discusses the plant-specific 24 results of the Calvert Cliffs review. Slide 11, please.

25 As far as the NEPA process goes, there are certain

31 1 steps that we at the NRC are required to follow, and these 2 steps are consistent for all Environmental Impact Statements 3 prepared by all federal agencies for any proposed major 4 federal action. The first step is the Notice of Intent, in 5 which we notify the public of our intent to prepare an 6 Environmental Impact Statement. For Calvert Cliffs, the 7 Notice of Intent was issued in June 1998 in the Federal 8 Register.

9 To prepare for the review, the staff assembled a 10 team of NRC staff with backgrounds in the specific technical 11 and scientific disciplines required to perform these 12 environmental reviews. In addition, to supplement the 13 technical expertise of the staff, we engaged the assistance 14 of Pacific Northwest National Laboratories to make sure that 15 we had a well rounded knowledge base to perform this review.

16 We have put together a team of about 20 people, many of j 17 which are here today to answer questions that may arise.

18 The next step is the scoping process where we 19 identify issues that need to be addressed in the 20 Environmental Impact Statement. The scoping period for 21 Calvert Cliffs started in June 1998 and ended in August.

22 During that time, the staff solicited input from the 23 federal, state and local authorities, and from members of 24 the public. In fact, the NRC had two scoping meetings here 25 in July 1998 for that purpose. In addition, during this 4

)

i

32 1 time, the staff visited the site to obtain a better 2 understanding of the site layout, to get a feel for regional 3 setting, and to take a look at the environmental measures 4 that have been put into place by BGE. Slide 12, please.

5 After obtaining input from the public and other 6 sources, the NRC conducts its environmental review. The 4 7 staff looks at a number of things. Particularly, it looks 8 at the environmental impacts of the proposed license 9 renewal. It looks at alternatives to the proposed action 10 and the environmental impacts of.those alternatives, and it 11 looks at mitigation measures, which are things that can be 12 done that would decrease the environmental impact of the 13 license renewal.

14 It is important to know for Calvert Cliffs that a 15 number of issues were raised to the NRC during the scoping 16 process by the public or were identified by the staff during 17 the course of its review that did not have a bearing on the 18 ~ decision to renew the license. However, we knew that a 19 number of these issues were appropriate for consideration 20 now because the plant -- because it was relevant because the 21 plant is currently operating. These have been referred to 22 the appropriate NRC programs such as the allegations 23 program, the operating plant project manager and other 24 agencies that may be interested in these issues for 25 disposition.

33 1 After an agency has conducted its environmental 2 review, it issues what is called th' Draft Environmental 3 Impact Statement, or the Draft EIS, for public comment.

4 These are drafts not because they are incomplete, but rather 5 because we are in the middle of -- we are at an intermediate 6 stage in the decision making process.

7 In the case of Calvert Cliffs, we have called this 8 the Draft Supplement 1 to the Generic Environmental Impact 9 Statement for License Renewal, and I will explain the 10 interrelationship of this document with the GEIS in a 11 minute.

12 The minimum public comment period requires for 13 this document is 45 days, and that is where we are in the 14 process now. In the case of the staff's Calvert Cliffs 15 review, the NRC elected to allot a total of 75 days for the i 16 comwent period, thus, giving an extra 30 days for comments.

17 Today we are holding two public meetings to describe the 18 results of the NRC's review and to answer questions that you 19 may have, and to try to help members of the public formulate 20 your comments. The comment period for Calvert Cliffs ends 21 on May 20th, 1999.

22 After the agency has gathered the comments and 23 evaluates them, it may decide to change portions of the 24 Environmental Impact Statement based on those comments. It 25 then issues the final Environmental Impact Statement, and

y 34 1 for Calvert Cliffs, the schedule we are working at today is 2' to issue the final Environmental Impact Statement in 3 November. Next slide, please.

4 This slide is a flow diagram showing the 5 environmental license renewal process. The second line 6 where it is showing the scoping process, environmental 1

7 review, site visit, is where we were last year in July. Now 8 we are at the second blue marker called the Draft Supplement 9 to the GEIS. We have issued it for comment and we are in 10 the process of getting your comments. Next slide, please.

11 Now, I would like to spend a few moments 12 describing how the staff incorporated NEPA into the 13 regulatory framework of the NRC and how the staff performs 14 its environmental assessments. The NRC's implementing l

15 regulations for carrying out the NEPA process are located in '

16 Part 51 of Title 10 of the Code of Federal Regulations.

17 This is what we refer to as 10 CFR Part 51. This regulation 18 contains the requirements that determine how the NEPA i 19 process is implemented at the NRC. It outlines the contents 20 of those Environmental Impact Statements and the process 21 that the NRC must undertake in order to meet the l 22 requirements of NEPA.

23 Early on in establishing the license renewal 24 process, it was recognized that the original Environmental 25 Impact Statements that were written for the plants when they I i

i m

l 35 1 received their operating licenses would need to be updated 2 to address any refurbishment activities and to address the 3 additional 20 years of operation. So the NRC undertook a 4 rulemaking effort to modify Part 51 and to amend it to 5 address license renewal environmental impacts. It is 6 important to note that this was done separately from the 7 rulemaking efforts on Part 54 that address the safety issues l

8 that are involved with license renewal.

9 As part of the rulemaking effort on Part 51, the 10 staff developed a Generic Environmental Impact Statement, l 11 which we call the GEIS, which took a systematic look at 12 thousands of hours of operating experience at all of the 13 nuclear power plants to help us identify potential 14 environmental impacts. In addition, the staff is finalizing 15 its Environmental Standard Review Plan for License Renewal.

16 This provides guidance on how to perform our review.

17 The staff used the information that we have 18 developed and the guidance -- a draft of the Environmental 19 Standard Review Plan and the other guidance in doing its 20 plant-specific review on Calvert Cliffs.

21 There are copies of 10 CFR, Part 51, of the GEIS 22 and of the Environmental Standard Review Plan in the back of 23 the room if you are interested in taking a look at it.

24 These documents are also available from the NRC's public 25 document' rooms and can be obtained from the Government

36 1 Printing Office. Slide 15.

2 The GEIS was published as NUREG-1437 and was 3 issued as a final document in 1996. It formed the basi.'. for 4 the rule revisions in Part 51. The NRC worked with the 5 states, the Council on Environmental Quality, the 6 Environmental Protection Agency and a number of other 7 groups, and held a series of public workshops to develop the 8 final GEIS. Based on the extensive interactions that took 9 place, the NRC decided that it was appropriate to limit the 10 scope of what we were going to consider in the license 11 renewal arena.

12 The staff identified and categorized the impacts 13 that were specific to license renewal both during the 14 refurbishment period and also during the additional 20 years 15 of operation. We identified a total of 92 issues that could 16 potentially have an impact as a result of extending the 17 license. For each of these issues in the GEIS, the staff 18 described the activities, identified the population of the 19 resource that was affected, assessed the nature and 20 magnitude of the impact. It characterized the significance 21 of the impact and it considered whether or not additional 22 mitigation is warranted. Next slide, please.

23 To characterize the significance of the effect, 24 the staff adopted the definitions issued by the President's 25 Council on Fnvironmental Quality in terms of small, moderate 4

37 1 and large. A small effect is one that is not detectable or 2 that was too small to noticeably alter any important 3 attribute of the resource. A moderate effect was one that 4 was sufficient to alter noticeably the attribute, but it was 5 not sufficient to destabilize the attributes of the 6 resources. And a large effect is one that was clearly 7 noticeable and it was sufficient to destabilize the 8 attribute of the resource. Next slide. You have got two of 9 them there.

10 When the staff looked at the 92 issues that were 11 identified in the GEIS, they found out some of them were 12 generic, and that is that they were common to all plants 13 regardless of the design or where they were sited. The NRC 14 wanted to categorize them differently from those that needed 15 to be evaluated on a plant-specific basis, and so we chose 16 to designate these generic impacts as being in Category 1.

17 There were three criteria that were developed to 18 determine whether or not an impact was a Category 1 issue. i 1

19 If an impact met all three of these criteria, then it became l 20 or was considered a Category 1 issue, and it was addressed 21 on a generic basis in the GEIS. I 1

22 The first criterion was that the impacts had to 23 apply to all plants or to plants with something -- specific 24 plant or site characteristics, such as all plants with 25 cooling towers, for instance.  !

38 1 The second criterion had to have what we call a 2 single significance level in terms of what that means is it 3 couldn't be just a small impact at one site and a large 4 impact at another, but it had to have a small impact at all 5 the sites or it had to be a moderate impact or it had to be 6 a large impact at all the sites.

7 And the third criterion was whether or not there 8 were additional plant-specific mitigation measures that were 9 not likely to be sufficiently beneficial to be warranted.

10 An example of a Category 1 issue is the 11 transmission line right-of-way impacts. The NRC considers 12 that those impacts apply to all the plants. All the plants 13 have transmission line right-of-ways. The significance 14 level of the impact was the same for all plants, and there 15 were no further mitigation measures that could be taken on a 16 plant-specific basis.

17 There were 68 Category 1 issues identified and 18 assessed in the fin.nl GEIS. These 68 are identified in 10 19 CFR Part 51 ar not requiring additional plant-specific 20 analysiF. However, the applicants are required to inform 21 the NRC in its license renewal application of whether or not 22 there's any new or significant information on these category 23 1 issues. And in addition, during the scoping phase of the i

I 24 review, the staff looks at comments from members of the j 25 public and through our consultations with the Federal, l

39 1 State, and local agencies to determine whether or not there 2 is any significant new information regarding these issues.

3 If some new and significant information is 4 revealed during our review, that information was included in 5 our review, and we took a look at it on a plant-specific 6 basis. If not, if there was no new and significant 7 information, then the staff adopts the generic conclusions 8 from the GEIS, l

i 9 Slide 18.

10 Of the remaining issues, remaining 92 issues, 22 11 are considered that they did not meet one or more of the 12 Category 1 criteria, and so plant-specific review was 4

13 required.

14 Slide 19, please.

15 There are two other issues that were not 16 categorized at the time of the proceedings. Because the 17 Presidential Executive Order on environmental justice had 18 just been issued at the time the GEIS was issued, the staff 19 concluded that it did not have enough information to 20 characterize it one way or the other. So in the rulemaking 21 it's been determined that it must be reviewed on a 22 plant-specific basis, just to make sure it's covered.

23 The other uncategorized issue concerns the 24 possible chronic effects of electromagnetic fields. Because 25 conflicting research results existed and there were no clear

40 L l conclusions regarding the impact, the Commission decided to

'c wait until there was clear scientific consensus on the issue 3 before deciding whether or not it's a Category 1 or Category 4 2 issue.

5 Again, the final rule determined that the effects 6 of the electromagnetic fields must be looked at on all 7 plants. All 92 of these issues are codified in 10 CFR Part 8 51. There's the table, Table B-1, that contains all 92 of 9 them in the regulation and it also designates their 10 category.

11 And finally, the review process is designed to 12 identify whether or not there is any significant new 13 information available. As I said earlier, the applicants 14 must inform the NRC whether or not they are aware of any 15 significant new information. In addition, the staff does 16 its own independent review to determine whether or not there 17 is new information. Such information for Category 1 issues 18 is included in the status review to determine the 19 environmental impact. If not, the staff adopts the generic 20 conclusions in the GEIS. If a significant new information 21 is identified on an issue that was not included in the 22 original 92 issues of the GEIS, then it is given the same 23 plant-specific treatment as though it were a Category 2 24 issue.

25 Next slide, please.

41 1 The purpose of this slide is to show how the GEIS 2 and Supplement 1 on Calvert Cliffs are interrelated. On the i 3 left side you can see the 68 issues listed in Category 1 and ,

I 4 the 22'as Category 2. On the right side gives you an idea l 5 of our evaluation of all 92 of these issues by the staff as 6 we've discussed them in the Supplement 1.

I 7 We took a look at all the 68 Category 1 issues and j 8 determined which ones were applicable and not applicable to 9 the site, and we determined there was 20 of them that were 10 not applicable because of refurbishment considerations or 11 because of specific design aspects of the plant. We also 4 12 determined that nine of the Category 2 issues were not 13 applicable for the same reasons. All the ones that were 14 determined to be applicable the staff assessed, and you'll 15 see the results of all of our discussions-in the Draft 16 Supplement 1. In addition, there's one, during the course 17 of our review and during the scoping process last' year one 18 new issue was identified which was also assessed on a 19 plant-specific basis, and we'll talk about that in the next 20 presentation.

21 That concludes my discussion on the NEPA process l 22 and the role of the GEIS in the staff's review. The next l 23 item on the agenda is going to be a detailed discussion of 24 the results of the staff's plant-specific review for Calvert 25 Cliffs, in other words, what's in the Supplement 1. But

L  !

42 1 before I go on to our next presentation, I just want to know 2 if there are any questions.

3 MR. CAMERON: Any questions for Tom? He did a 4 pretty comprehensive job of explaining the NEPA process for i I

5 license renewal, and you heard earlier on a question where 6 an issue was moved from a Category 2 to a Category 1 issue l

7 through a rulemaking. Is this process clear to everybody 8 with the process Tom described? Do you have any questions 9 or comments on this at this time before we get into the real 10 meat of the environmental impact statement?

1 11 Okay. Well, good, let's go to the specifics. I j 12 thank you very much, Tom.

13 MR. KENYON: As I mentioned earlier, to supplement I 14 the knowledge base of the staff we engaged the assistance of 15 Pacific Northwest National Laboratory, and the team that we I 16 used from PNL was headed up by Miss Mary Ann Parkhurst, who 17 is the staff scientist at PNL. And she will present the

)

18 results of our review.

19 Mary Ann.

20 MR. CAMERON: And Mary Ann has said that if you 21 have a -- if anybody has a clarifying question about the 22 information she's presenting, that she's willing to take 1

23 those questions during her discussion. But I would ask you 24 to limit it to clarifying questions, if you don't understand .

25 something that she's saying, and then the comments on her

V I

43 1 conclusions, we'll do that after Mary Ann is done and after 2 Bob Palla from the NRC staff is done.

3 Mary Ann, how do you want to talk? Do you want to l -

1 .4 use that and.just --

5 MS. PARKHURST: Sounds like it's live.

6 MR. CAMERON: Good.

7 MS. PARKHURST: I think I'll work from here and l 8 try not to trip'over the cord.

9 MR. CAMERON: All right.

10 MS. PARKHURST: And because we have some technical 11 difficulty with the graphics in the draft document, here's a 12 photograph that helps provide a little bit of the structure, 13 what the plant looks like from the Chesapeake Bay. We'll 14 start out with this and then get on with the talk.

I 15 Okay. Next slide, please.

1 16 The Calvert Cliffs Nuclear Power Plant Draft j 17 Environmental Impact Statement is a supplement to the 18 Generic Environmental Impact Statement, the GEIS. As such, 19 we call it the SEIS. And so that I don't have to 20 continually say the supplement to the draft environmental 21 impact statement, I'm going to use SEIS here, and please 22 just recognize that I'm talking about this particular -- I'm 23 a little concerned about the acoustics here. Are they --

24 okay, I'm hearing some off -- some odd effects, feedback.

25 Okay,-I'll try it here.

l I

1 I

l

44 1 I also want to mention we use in the document the 2 acronym CCNPP for Calvert Cliffs Nuclear Power Plant each 3 time. I'm going to just use Calvert Cliffs and recognize 4 I'm referring to the plant and not to the geologic cliffs 5 structure. That will keep me from having to use a few more 6 words in there too.

7 okay. As Tom described it, and we're going to 8 have a little bit of overlap in what we're talking about 9 here, the GEIS looked at many, many issues. The SEIS 10 addresses all of these issues, but it focuses on the 11 plant-specific environmental impacts. The SEIS covers the 12 Category 3 issues, the Category 2 issues, those two issues i

13 that were not categorized, and new issues that came up 14 through the process.

15 Next slide, please.

16 Though important to the issue of license renewal, 17 we specifically did not consider several items in this 18 document because of its environmental nature. First is the 19 need for power. This is really in the realm of the utility 20 and State officials' concerns, not NRC's. The second one, l

21 we looked at -- also did not evaluate the cost of power.

22 Again, this is outside the scope of NRC's evaluation on the 23 license renewal option. Safety is handled through the 24 safety evaluation report, the one that Chris Grimes talked 25 about earlier, and so we don't include safety issues in this

i-45 1 report. And in regard to spent-fuel disposal, this is an l 2 industry-wide issue, it's of interest to all of us, it's 3 under the authority of Congress and the Department of 4 Energy, but it's outside the realm of the license renewal 5 environmental impact statement except again for the 6 transportation issue, which we'll mention briefly a little 7 later.

8 Next slide, please.

9 The process for evaluating environmental issues 10 was conducted in accordance with the guidance provided in l

l 11 the Environmental Standard Review Plan for license renewal l 12 again that Tom mentioned to you. We started out first by 13 gathering information, and the first place to do so was the 14 application that BGE had -- BGE's application for license 15 renewal. Part of the application included an environmental 16 report, a fairly extensive document. This was where we 17 began our process.

i 18 Our next source of information was the public 19 scoping meeting here last July. Verbal conments and written 20 ones made during that time frame were reviewed for is there 21 new information here, are there things that we don't --

22 hadn't already heard about? What else is here that we 23 didn't know otherwise by looking through the plant's 24 application?

25 Afterlthe meeting then we referred to -- and visit l

1 l

46 1 to the site, where we had an opportunity to observe for 2 ourselves or refamiliarize ourselves in many cases what the 3 plant looked like, what the issues were, what its 4 surroundings looked like, then we went on to look through 5 BG&E's process for identifying how they came up with new and 6 significant information. Now BG&E pulled together a 7 committee to look at the environmental issues they were 8 specifically aware of that impact.ed their facility, and they 9 pulled into this review process the Department of Natural 10 Resources, Maryland's Department of Natural Resources, and 11 their environmental science vendor.

12 This team conducted site inspections, document 13 reviews, and interviews trying to find out what might be new 14 that would have some bearing on extending the review 15 license -- or extending the operating license for the 16 renewal term. They searched for information that might 17 indicate that any of the findings in Category 1 might not be 18 valid at their plant or anything else that might not fit the 19 GEIS sorts of issues, you know, was there something unusual 20 at Calvert Cliffs that would cause us to have to look in 21 more detail in one of the 92 issues under review.

22 I think I should have stayed at the podium where I 23 could at least put my notes down.

24 Next slide, please.

25 We also visited many of your county, regional, I

l 1

r 47 1 State agencies looking for information on the environmental 2 effects of Calvert Cliffs and of the proposed license 3 renewal. We visited information services like the Academy 4 of Natural Sciences, the University of Maryland's Chesapeake 5 Biological Laboratory, Maryland's Archeological and 6 Conservation Laboratory, area Chambers of Commerce, and even 7 realties, looking for demographics of the area.

8 We verified with the regulating agencies that the 9 environmental permits were in order for continued plant 10 operations, and we discussed with these regulating agencies 11 the environmental consequences of continuing for the renewal 12 term.

13 Next slide, please.

14 Our next step was to take a look, for the staff, 15 my staff, to take a look at the Category 1 issues. What 1-6 we're looking at again is pertinent new and significant 17 information outside the bounds of the EIS, of the GEIS. For 18 information where there was no significant information 19 revealed -- for those issues where there was no new 20 significant information revealed, the staff embraced -- this 21 is an NRC term; I'm going to say adopts -- the conclusions 22 of the GEIS. So where we found nothing that said okay, this 23 situation falls outside of the bounds supplied by the GEIS 24 and requires additional information, when we did not find 25 that, we simply adopt the conclusion of the GEIS that we do

48 1 not need to continue additional analysis along these lines.

2 Next slide, please.

3 As Tom mentioned, of the many Category -- of the 4 68 Category 1 issues to begin with, 11 of them are not 5 applicable for Calvert Cliffs. Most of these have to do 6 with cooling towers or cooling ponds, things that Calvert 7 Cliffs doesn't have. And so what we did with these issues 8 is we simply identified them and put them in the Appendix F 9 where they're not part of the document, but we indeed did 10 take a look at them in any case as we are required to, of 11 all 92 issues.

12 There were nine issues that were identified as 13 refurbishment issues. Now BG&E specifically indicated they 14 had no plans to do refurbishment, no major refurbishment at 15 the plant in order to extend the term through the license 16 renewal process. I think I need to go back and find my 17 exact words on that. But in any case, refurbishment is not 18 an issue at Calvert Cliffs and in its EIS. So we have nine 19 issues there which we have identified and are doing nothing 20 more with, they're not applicable. The remaining 48 issues 21 were reviewed for new and signific_nt information, and this 22 is found in the next four to seven -- chapters 4 to 7.

23 Yes. Clarification here.

24- MR. DOROSHUK: I'm Barth Doroshuk, the Director of 25 the License Renewal Project. I believe the finding that or

49 1 the conclusion we drew is that there would be no 2 refurbishment outside the powerplant that would affect --

3 there was no refurbishment to be conducted that affected 4 anything outside the perimeter of the powerplant.

5 MR. CAMERON: Okay. Thank you for that 6 clarification.

7 Can you people hear this mike?

8 All right.

9 MS. PARKHURST: Yes. And, you know, we're 10 saying -- I think I have a direct quote here somewhere on 11 refurbishment I may get to later -- in any case, BG&E stated 12 it has no plans for major refurbishment activities that 13 would result in our reviewing them in this particular 14 classification.

15 So what we did then again review are the 48 16 issues, and we went through the BG&E's environmental report, 17 the public scoping meeting information, and our 18 consultations with regulators and technical experts to 19 determine what information we needed to know in order to 20 complete this analysis.

21 Next slide, please.

22 Of the Category 2 issues -- these Category 2 23 issues we have to go through an analysis on if they're 24 applicable to the site. Five of them were not and are again 25 found in Appendix F. Four related to refurbishment. Again,

50 1 we did not evaluate them. We simply listed them in chapter 2 3. The remaining 13 issues underwent independent review and 3 are specifically addressed. If necessary we were to 4 consider mitigation measures if there were some serious 5 impacts likely to be created that could be mitigated in some 6 reasonable fashion. And we identified the significance of 7 each issue as small, moderate, or large.

8 Next slide, please.

9 Our two not categorized issues, environmental i 10 justice and chronic exposure to electromagnetic fields.

11 Environmental justice was not -- was a new issue at the time 12 or is not included in the original lists of -- or GEIS 1

13 analyses. Chronic exposure is one that they were waiting to 14 see is there a scientific consensus on whether there are 15 health effects from electromagnetic fields.

16 We had a new issue emerge in our public scoping 17 meeting, and that was of microorganisms in high-radiation, 18 high-temperature conditions. This is a fairly interesting 19 idea, and the organisms of this type are called 20 extremophiles, living at the extreme edges of some 21 particular environment. So this was as topic for us to look  !

i 22 at that was not previously expected or involved with the l 23 license renewal.

24 Next slide, please. l 25 MS. PARKHURST: The document itself, and for those i

51 1 1

1 of you who haven't seen what it looks like, it's this 2 document here, has NUREG Number 1437, Supplement 1. The 3 GEIS is NUREG 1437, so this is again just a supplement 1 to 4 that document. It's got an introduction -- surprise, 5 surprise. This introduction includes some of the NEPA i 6 process information. It also summarizes the results of the 7 GEIS and discusses the license renewal process itself, the 8 purpose and need for this action, which is the license 9 renewal of the Calvert Cliffs plant, and it provides an 10 abbreviated list of compliance and consultation of the 11 regulating authorities consulted during this process.

12 Chapter 2 describes the current nuclear plant site ,

l 13 and the plant interactions with the environment. This is a i l

14 fairly standard overview of issues, including such things as 15 land use, water use and quality, air quality, aquatic j 16 resources, terrestrial resources, the radiological impacts 17 to surrounding areas, socioeconomic factors, and I will pull 18 out here specifically housing and public services, 19 transportation and demographics, and then historic and 20 archeological resources within this 2,300 acre plant site.

21 Next slide, please.

22 The next chapter is, again, chapter 3 is l 23 refurbishment. It's real short.

24 Chapter 4, operation during the renewal term. We ,

i 25 hit the Category 1 issues for operational renewal or

1 l

52 1 operations,. license renewal during operations versus 2 refurbishments. The Category 1 issues, Category 2, and the 3 new issues raised by BGE, the public, and/or those found by I 4 the staff in the course of our analysis.

5 Next one, please.

l l 6 In our review of the Category 1 issues, all 48, we 1

7 found no significant new environmental information regarding 8 these issues; therefore, again, we are embracing the 9 conclusions of the GEIS as our preliminary result of this 10 investigation.

11 Okay. Next one, please.

12 Of the Category 2 issues, I'm going to go through 13 each topic and talk about the issues that we reviewed, and 14 there were, like I say, 13 Category 2 issues, plus the two l 15 not-categories ones.

l l

16 The first ite:m or first topic was aquatic ecology.

17 We were looking at three main topics here, three things that 18 required our review, and I've got them in somewhat -- some 19 shorthand here. If you want to know more specifics, we can 20 have our ecologist further define them for you later. But i 21 we're looking at the entrainment of fish and shellfish 22 within the cooling system. We're looking at impingement of 23 fish and shellfish probably on the -- did you have something 24 to say there? Okay. And we're looking at heat shock 25 associated with the cooling water discharge back out into

53 1 the Chesapeake Bay.

2 Now, the Chesapeake ecosystem has been extensively 3 characterized in an around this area, and especially over 4 the past 30 years. The documents published by the Maryland 5 Power Plant Research Program, part of the Maryland 6 Department of National Resources, were extremely useful.

7 I've got one of these documents here. There's a 8 whole series of documents that, like I say, the Maryland l

9 Power Plant Research Program has put together, and they're i 10 very good background information if you're looking for some 11 Chesapeake specific information on power plants, discharges 12 and so on.

)

13 Additionally, the plant is in compliance with 14 conditions of the national pollutant discharge elimination l

15 system, and has an active NPDES permit. This means that I 16 they have to meet certain requirements, conditions, 17 characterizations of their effluent streams to continue 18 their permit.

19 The next major item was threatened or endangered 20 species. We reviewed these by consulting with the 21 appropriate agencies to determine whether threatened or 22 endangered species are present and whether they would be j

23 adversely affected by license renewal operations.

l 24 We consulted with the U.S. Fish & Wildlife Service 25 and with the National' Marine Fishery Service in particular.

54 1 The National Marine Fishery Service concluded that the 2 short-nosed sturgeon and the loggerhead turtle, potentially 3 occurring in this vicinity, would not be adversely affected 4 by Calvert Cliffs' license renewal.

5 Now, the Fish & Wildlife Service recommended or 6 they identified Federal protected species under their 7 jurisdiction that might occur on the site. These include 8 the Tiger Beetle, the Northeastern Beach Tiger Beetle and

{

9 the Bald Eagle.

1 10 They concluded that there were no adverse impacts 11 likely to result to these species because of license 12 renewal. They did recommend you BGE amend its agreement  !

'13 with the Nature Conservancy to allow foot access to the 14 beach below Calvert Cliffs so that the census of Tiger j 15 Beetles could continue even after the operations of the 16 facility were concluded. They asked that the site be 17 maintained as Tiger Beetle habitat after decommissioning.

18 The Fish & Wildlife Service recommended 19 constraints on activities within a quarter of a mile of the 20 active eagle nest during nesting season. So these were 21 things I think that were generally being done anyway, but 22 they're -- again, this is a recommendation by the Fish &

23 Wildlife Service.

24 Next slide, please.

25 There was only one Category 2 issue related to

55 1 water, surface or groundwater, and in this particular case, 2 the only one applicable here was the groundwater use and 3 quality concerning groundwater conflicts where you had a 4 plant using more than 100 gallons per minute.

5 The Calvert Cliffs plant withdraws about 280 6 gallons per minute and is within compliance with the 7 groundwater appropriations permit issued by the Maryland 8 Department of the Environment.

9 Also listed here having to do with human health is 10 the acute effects of electric shock from electromagnetic 11 fields.

12 BG&E's south power transmission line circuit was '

13 designed to be in compliance with the National Electric 14 Safety Code for electric shock potential. The north circuit 15 was installed before this code was adopted, so BG&E had to 16 verify that their north circuit also meets code 17 recommendations for preventing shock from induced currents.

18 Next slide, please.

19 Category 2 issues related to socioeconomics.

20 There are several. On housing impacts, BG&E projects that 21 an additional 60 employees may be required during their 22 renewal period. This does not count the rsgular outage 23 sessions that would occur anyway; these would be permanent 24 staff.

25 Based on this projection, the housing demand could l i

i i

i

s 56 1 increase by as many as 190 housing units if the 60 employees 2 generated a population increase of about 580 people within 3 the Calvert and St. Mary's Counties.

4 Public utilities. Additional public water 5 supplies might be needed to serve this additional 6 population. That's a given.

7 Off-site land use. Because Calvert County is 8 experiencing high population growth, conversion of 9 agricultural land to residential and commercial use is 10 likely to continue; however, less than 1 percent would be 11 attributable to plant-related population growth.

12 Another element of off-site land use is the 13 property tax issue. The BG&E estimates that property tax 14 would rise probably to about 33 million dollars per year by 15 2036. Is that possibly right? That's huge. Currently, 16 about 20 million is paid a year, and that's 21 percent of 17 the county budget. By having this money available, the 18 infrastructure improvements are paid largely with money from 19 this particular source.

20 Transportation issue. The additional 60 employees 21 that the plant may require are unlikely to noticeably add to 22 the highway burden. I know this is something that came up 23 in public scoping meetings. The analysis shows this 24- particular preliminary conclusion.

25 Historic and archaeological resources. With no i

1 1

i l

l

57 1 plans for future land disturbances within the continued 2 license renewal term, vegetation -- the production -- excuse 3 me -- the protection of the natural landscape and vegetation 4 - would most likely be beneficial rather than adverse by 5 protecting any buried sites during that time frame.

6 Next slide, please.

7 MR. LOCHBAUM: I have a question.

8 MS. PARKHURST: Yes.

9 MR. CAMERON: Let me get you a microphone, David.

10 MR. LOCHBAUM: David Lochbaum with Union of 11 Concerned Scientists.

12 When you talked about the housing effects, you 13 said 60 employees that might lead to 190 housing units 14 because of 580 additional people. Public transportation, 15 you talk about no impact from 60 employees. Those 530 other 16 people are not included in the public transportation study?

17 MS. PARKHURST: They're included, and primarily, 18 though, what you're getting is -- you know, the plant 19 traffic, I would presume, is very heavily what -- that 60 20 doesn't add much to. But yes, they're included in the 21 overall analysis on the transportation. Thank you.

22 Environmental justice is a relatively new subject i 23 of analysis. It refers to a policy that Federal action 24 should not result in disproportionately high and adverse  !

25 environmental impacts on low income or minority populations. ,

l

58 1 Air, land and water resources within 50 miles of 2 Calvert Cliffs were examined for such disproportionate 3 adverse impacts. No unique or unusual pathways were 4 identified that would result in such impacts. A demographic 5 analysis of, the area and field interviews found that small 6 pocicets of minority populations and low income populations 7 are either well mixed into the majority population or 8 concentrations of minority individuals are too small to be 9 identified in census detail. They are not located in places 10 where disproportionate impacts would be expected.

11 Regarding the chronic effects of electromagnetic 12 fields, like I say, this one is a not-categorized issue 13 while the scientific community is -- their opinion is out on 14 the health effects of the chronic EM fields.

15 To date, experimental and epidemiological evidence 16' of adverse health effects are still inconclusive. So we 17 have -- we're not taking action on this one for lack of any 18 more direct information.

19 Next slide, please.

20 As I mentioned earlier, we did have one new issue 21 come up through the public scoping process. The topic was 22 organisms existing at high radiation, high temperature 23 conditions. The concern noted was the possible 24 environmental impacts created by the mutation and/or escape 25 of this type organism from extreme temperature and radiation

59 1 conditions as might exist within a spent fuel pool into the 2 Chesapeake Bay. This concept was discussed with l

3 microbiologists that specialize in extremophile research. I 4 They_ concluded that there is little potential for 5 detrimental population increases of these extremophiles in j 6 the environment, partly because organisms associated with 7 thermal waters at9 likely to die if they're transported to ,

8 the cooler waters of the Cliesapeake Bay. Additionally, they 9 would be unlikely to be able to compete with the indigenous 10 microbiota of the Bay. These extremophiles are unlikely to 11 pose a hazard to public health.

12 Based on the specialists' analysis, these 13 conclusions, the staff concludes that this issue, while new 14 to NRC's analysis of license renewal issues, does not meet 15 the significant information standard.

16 Okay. Moving to the next slide, please.

17 Chapter 5 of the SEIS covers the postulated plant 18 accidents. There are two parts of this analysis. The first 19 one is a design- basis accident, and this is a Category 1 20 issue. Design- basis accidents are those for which a plant 21 is designed to be able to withstand without any off-site 22 releases, and NRC's determination of the impact of design-23 basis accidents, given the steps already taken in designing 24 the plant, was determined to be of small significance for 25 all plants. Thera was no significant new information

60 1 identified as part of our analysis on the design basis

2 accidents.

3 We've got a question over here.

4 MR. MILLS: Yes. About that, on page 5.3 here, 5 you have a design -- let's see. BG&E estimated the core 6 damage frequency at 3.3 times ten to the minus four per 7' reactor year; is that correct?

8 MS. PARKHURST: Can somebody help me?

9 MR. MILLS: Page 5-3, next to the last paragraph, 10 core damage frequency -- l 11 MS. PARKHURST: I think we're on severe accident 12 mitigation there. I think you're jumping into the next 13 -section. This is the design- basis accident. This is 5.1.

14 MR. MILLS: Oh, I'm sorry.

15 MS. PARKHURST: Yes. You're jumping ahead, and 16 I'm going to give you just enough information to say we're 17 going to delay this one --

18 MR. MILLS: All right.

19 MS. PARKHURST: -- later on.

20 MR. CAMERON: We'll come back to you.

21 MS. PARKHURST: Let me find where I am here in my 22 notes again.

23 Again, under the -- the design- basis accidents 24 where -- we had found nothing that would indicate they would 25 not be a Category 1 issue. The environmental impact of

61 1 severe accidents was determined to be a Category 2 issue.

2 Although the Commission found that the projected impacts of 3 accidents defined by NRC as severe are small for all plants, 4 alternatives to mitigate severe accidents must be considered i 5 for plants that have not formerly considered such 6 alternatives previously.

7 A discussion of the severe accident mitigation i I

8 alternatives, dubbed SAMAs, will be discussed later by NRC's 9 Bob Palla. How's that for getting out of having to answer 10 that one? i 11 Okay. Next slide. )

1 12 The impacts from the uranium fuel cycle and solid 13 waste management were covered in chapter 6. Most of this 14 follows very specifically the requirements and the words 15 provided in the 10 CFR 51 rule on these topics. The 16 Category 1 issues applicable to the operations of Calvert 17 Cliffs include the following: offsite radiological impacts 18 to the individual, collective offsite radiological impacts, 19 non-radiological impacts of the uranium fuel cycle, 20 low-level waste storage and disposal, mixed waste storage 21 and disposal, on-site spent fuel, and non-radiological i

22 waste. -

l 23 Now, these issues are important and have been i

24 evaluated in the GEIS, but because there was no new 25 information that NRC became aware of during the review

62 1 process, the NRC adopts the GEIS conclusion for Calvert 2 Cliffs that this is a Category 1 issue.

3 The Category 2 issue that is potentially ,

4 applicable to Calvert Cliffs is the transportation of 5 radiological waste. This issue has two elements. The first 6 element is that a review of the effects of transportation of 7 fuel and waste shall be-performed consistent with the I 8 approach outlined in 10 CFR 51. There's a subsection called 9 environmental effects of transportation of fuel and waste, 10 and there's a table, S-4, designated with that. ,

l 11 The impacts identified in the table are valid if a '

12 licensee meets all of the criteria outlined. Some of these 13 criteria relate to fuel enrichment and fuel burnup.

14 NRC determined that the environmental impacts from 15 Calvert Cliffs's fuel enrichment and fuel burnup meet the i

16 criteria and that the environmental effects are unchanged or 1 17 reduced from those identified in Table S-4; therefore, no 18 additional analysis is required for this element of the 19 issue.

20 The second element of this issue is that a 21 discussion be included in the SEIS of the generic and 22 cumulative impacts associated with transportation operation 23 in the vicinity of a high-level waste repository site.

24 However, analysis of this topic as a Category 2 issue comes 25 with a big caveat because of NRC's current rulemaking

i f 63 i

l 1 process on this issue to change the transportation of l

2 high-level waste from a Category 2 to a Category 1 issue or 3 to define it as a Category 1 issue.

4. The proposed rule was published in Federal 5 Register February 19, '99, as was stated earlier. The 6 applicant has the option of providing a plant-specific 7 discussion of transportation operations in the vicinity of a l 8 high-level. waste repository site to avoid licensing renewal 9 delays while awaiting final publication of the rule. BG&E 10 identified no significant new issues related to 11 transportation of waste and defers to the proposed rule.

12 The proposed rule confirmed the values in table 13 S-4 are bounding for transportation of high-level waste in 14 the vicinity of a high-level repository. The final rule is 15 expected to be published no later than August 1999 and 16 should proceed publication of Calvert Cliffs's final SEIS. )

l 17 Next slide, please. I 18 Oh, excuse me. I've got another topic on that 19 same page.

20 Regarding decommissioning, that forms our chapter 21 7, again, a very small chapter. Category 1 issues 22 applicable to the decommissioning of Calvert Cliffs 23 following the license renewal term include radiation doses, 24 waste management, air quality, water quality, ecological

-25 resources, and socioeconomic impacts. No significant new

64 1- information were identified with regard to these Category 1 2 issues. There are no Category 2 issues identified with 3 decommissioning.

4 Okay. Next slide now, please.

5 Let me summarize the impacts of license renewal on 6 plant operation during the renewal term as identified in 7 this preliminary analysis. There were no significant --

l 8 there was no significant new information identified. Again, I 9 we had a new issue, we looked at it, we determined it was 1

10 not significant. We determined that the impacts for 11 Category 1 issues were bounded by the analysis in the GEIS j 12 and required no further analysis.

13 We looked at the impacts of the Category issues, l

14 Category 2 issues, and determined that they were of small 15 significance and would require no additional mitigation. I )

16 will mention here that Federal Wildlife Service did 1

17 recommend implementation of certain mitigations for species l 18 that I covered previously.  :

19 Now, I just said some things before I gave you a 20 chance to realize where I came up with them, and that was on l 21 the small significance for everything. This gives me a 22 chance to show where we have summarized it. This comes from 23 Table 9.1 in the document for anyone who is wondering where 24 this information was summarized.

25 The topics, we have got our impact categories on l

1

_ ...)

65 1 both sides here from land use, ecology, water -- water 2 quality, and this should be water use, too. Water use is a 3 heavy part of it, probably more so than water quality. Air 4 quality, waste, human health, socioeconomics, aesthetics, 5 archaeological and historical resources and environmental 6 justice. When we looked at each of these issues and rated 7 them by significance, using the Council of Environmental 8 Quality standards, we came up with all of these meeting the 9 small level of significance.

10 Okay. Next slide, please. Now, we did find that 11 there were Category 2 issues that were of unavoidable 12 adverse impact -- or that provided unavoidable adverse 13 impacts. Again, we did not find anything beyond those of 14 small significance, but as part of the NEPA process, we are 15 required to look at the unavoidable adverse impacts.

16 The three most obvious ones that we came up with 17 in our analysis were the continued drawdown of water at 18 off-site wells. Other aspects -- other organizations are 19 using that drawdown capability, but, certainly, Calvert 20 Cliffs is one of them, and though this is not determined to 21 be of more than small significance, it certainly is 22 something that does continue.

l 23 Another thing is the continued loss of fish and 1 1

24 shellfish. Most of this is considered cropping losses, 25 where you get some normal losses, but you have high I

1 1

66 1 survivability, you are not losing a lot as a result of this, 2 based on the studies that have been done along this line, 3 and there have been quite a few. And the housing and 4 traffic impacts from the addition of about 60 employees.

5 These, again, were the most obvious unavoidable adverse 6 impacts we found from this analysis.

7 Next slide, please. Most any power operations are 8 going to cause the use of irreversible or irretrievable 9 resource commitments. In this case, one of the most common 10 being materials and equipment ~ required to maintain 11 operations. And then specific for the nuclear plant =, the 12 nuclear fuel itself and the permanent storage space tar 13 spent fuel assemblies.

14 The next one, please. An analysis of the tradeoff 15 between the short-term use versus the long-term productivity 16 led us to these two main points. First, that the current 17 environmental balance is well established and the plant is 18 in compliance with environmental regulations. Extending 19 operations through the license renewal term would extend the 20 time that this general balance would be expected to 21 continue.

22 Looking at this balance from another angle, 23 continued operations trough the renewal term would delay the 24 alternative uses of the site, beneficial or otherwise. i 25 Next one, please. Another part of the NEPA

67 1 requirement is that we look at -- evaluate alternatives to 2 the proposed action. Because there is nearly limitless l 3 possible energy sources and mixes of energy sources, the i

4 analysis is limited, as defined in the GEIS, to those 5 eminently -- or reasonable, of demonstrated capability with l

l 6 sufficient generating capacity to replace power plant 7 generation. For generating capacity comparison, Calvert 8 Cliffs has a design rating for net electric power outputs of 9 about -- of 845 megawatts for each of its two units.

10 Now, there is a lot of other alternatives -- or 11 there are a lot of alternatives considered both by the GEIS 12 and by ourselves in reviewing the possibilities out there.

13 These were considered and rejected because they couldn't 14 provide sufficient power to replace Calvert Cliffs under 15 what we do know of the technology now and projecting it in 16 the future. Lots of possibilities for new technology, 17 certainly, but from what we have to go on at this point, in 18 this evaluation, we had to rule out solar, wind, -- or we 19 did not continue -- we had to reject on this basis, solar, 20 wind energy, biomass, conservation and energy efficiency, 21 geothermal and things like fuel cells. Imported power was I i

22 considered, but shows no particular advantage, it just 23 shifts where the impacts occur.

24 So we are back to, in the final analysis, what did i 1

25 we look at? Okay. We looked at the no action alternative, '

68 1 which case perhaps the license would be denied or withdrawn.

2 The two -- the no -- excuse me. The two alternatives that 3 look like -- that BGE had identified as being possible ones, 4 being coal-fired power generation and gas-fired power 5 generation, these are serious alternatives with a lot of 6 potential and could be done at the sites, and it is these 7 that the nuclear license renewal option were compared with.

8 The next one, please. Okay. Sorry for those of 9 you in back. Perhaps your handout with give you enough 10 detail you can see this. Again, this is coming off of 11 Chapter 9, Table 9.1 in Chapter 9 of the SEIS. Looking at 12 the no action alternative, where we do not have license 13 renewal, from the environmental significance, we are showing 14 he impacts to be relatively small. Again, we have got 15 small in aspects of what we call the ecology aspects, the 16 land, ecology, water use, air quality, waste, human health.

1 17 When we get to the socioeconomics, there could be 18 anywhere from a small to a large impact, depending on what 19 would be replacing it, if anything., here. So we have got a 4 20 fair range of possible impacts on the no action, but most --

21 many of them are small, again, the socioeconomics could be 22 large.

23 The next one, please. Now, here we are 24 contrasting the proposed action and the no action 25 alternative with the coal-fired generation possibility and

69 1 we have got this split into two slides so that you wouldn't 2 have to try to read it on even smaller fonts. The 3 coal-fired, we have got -- we looked at it from two 4 perspectives. One is whether, if they site the coal plant 5 at the current nuclear plant site, and, secondly, if they 6 looked at what we call a green field site, someplace else 7 where it would have to be developed for use.

8 Now, the land use on the current site would be 9 probably small, it could be moderate. The ecologies, the 10 aquatic and terrestrial ecology probably wouldn't be a lot 11 different. Water quality, surface water quality use 12 probably not a lot different. A lot more groundwater would 13 be needed to handle -- to deal with the scrubbers. Air 14 quality and waste, moderate significance mostly likely in 15 this case.

16 If we went to a green field site, gen' ally, the 17 significance is at least as much or greater than that of j l

18 using the Calvert Cliffs site.

19 Next slide, please. Again, continuing with the 20 coal-fired generation possibility alternative, human health, 21 socioeconomics, aesthetics, archaeological, historical and 22 environmental justice, again, our proposed action, 23 generally,'these are of small significance.

24 Denial of the renewal. We have got small to l 25 large, depending on the issue. Again, socioeconomics would l

70 1 probably be hardest hit, or fairly hard hit anyway.

2 With the coal-fired generation, we have got small 3 to large, small to moderate significance for the Calvert 4 Cliffs site. The large one there is for aesthetics and this 5 is something that probably would not be real identifiable 6 from the highway because of how it is -- now, you have got a 7 question specific to what I am asking right there, or what I 8 am saying right there?

9 MR. MILLS: Pretty close.

10 MR. CAMERON: Is this a clarifying question for 11 this part?

12 MR. MILLS: Yeah. I don't see -- Robin Mills, 13 again.

14 MS. PARKHURST: Yes, we can hear you.

15 MR. MILLS: I don't see the effects of an accident 16 listed there. Now, I know it is a small point, but as I 17 look at page 5-3, it states that the risk of an accident 18 over license extension is 1 in 150, core damage frequency.

19 There is going to be a meltdown, one chance in 150. That is 20 the way I figure out these statistics, point -- 3.3 times 10 21 to the 4th times 20 years works out to one chance in 150 22 that there is going to be a meltdown. Okay. Is that right?

23 Do I have that right? .00033 --

24 MS. PARKHURST: Bob, I think we will let Bob --

25 MR. MILLS: Times 20, one in 150.

71 1 MS. PARKHURST: This is again --

2 MR. MILLS: Now, you are saying that that -- if we 3 have a core meltdown, that is a small effect? The effect 4 here is small.

5 MS. PARKHURST: I am saying this is not -- the 6 accidents are not included in this. The severe accidents is 7 a separate issue.

8 MR. MILLS: Okay.

9 MS, PARKHURST: Bob will talk about it next.

10 MR. MILLS: Accidents is not an environmental 11 effect?

12 MS. PARKHURST: Now, that is -- I think that I am 13 still going to have to pass this on to NRC. This part of 14 the analysis, this part of the environmental effects are 15 separate from what you are talking about, and, yes, 16 actually, they come out with a small significance even on 17 their severe accident, as part of the GEIS analysis, so that 18 is indeed correct.

19 MR. MILLS: Okay. I think you should include 20 that, though, in environmental significance of license 21 renewal.

22 MS. PARKHURST: Thank you for your comment.

23 MR. CAMERON: Okay. I think we are going to have 24 some more comment on that when we get to Bob, as you noted, 25 Mary Ann. And perhaps because of the all the material you

i 72 1 are covering --

2 MS. PARKHURST: We are almost through, by the way.

3 MR. CAMERON: I know, and I am not asking you to 4 stop. I am just saying rather than going right into Bob's 5 presentation, let's stop and take some questions for you on 6 all of the stuff you discussed.

7 MS. PARKHURST: Sure. Okay.

8' MR. CAMERON: Go ahead, Mary Ann.

9 MS, PARKHURST: It sounds like a good idea. Okay. l 10 Again, placing a coal-fired plant on the Calvert Cliffs site 11 appears by this -- these standards, to be preferable than 12 going to a green field site, though, for these topics it is 13 not a whole lot different. ,

1 I

14 The next one, please. Here we are looking at the j 15 gas-fired generation, again, at the Calvert Cliffs site, and 16 at a new green field location. I have left up proposed 17 action and no action not just for your personal comparisons, i 18 for looking through, but it made it a whole lot easier 19 cutting and pasting these graphs together, and, 20 conveniently, it does show, again, the license renewal 21 issues being small. The denial of license being small for 22 these issues. Gas-fired generation, you will notice is 23 small all the way down to air quality, and we have that as a 24 moderate effect. A green field site, we have more impacts, 25 because, again, you are disturbing more land most likely.  ;

73 1 The next one, please. The second half of the same 2 table with the coal -- or with the gas-fired generation.

3 Whether this were done at -- whether Calvert Cliffs were 4 converted to a gas-fired generation, whether the site was 5 converted for that use, or a green field site, wouldn't have 6 a whole lot of difference in the significant factors on the 7 human health, socioeconomics, aesthetics, archaeological and 8 environmental justice factors.

9 Now, I want to mention that we looked at one other 10 element in the alternatives and that is what we have got at 11 the site currently is once-through cooling. What we might 12 also consider as a possibility is closed cycle cooling tower 13 system cooling. If that were the case, whether you are 14 looking at coal-fire or gas-fire plant, the changes would be 15 minor to moderate in land use, minor changes to terrestrial 16 and aquatic ecology systems, and at least a minor if not 17 moderate change in -- excuse me, it would be minor change in 18 surface water quality, but you would have probably more 19 groundwater usage is my understanding on that one, and I am 20 going to ask my expert because I just pulled that out of the 21 air, and I don't think that is correct.

22 The impacts are identified in Chapter 8 in the  ;

23 -document and we did indeed compare then and the changes l 24 really would be essentially moderate, except for the 25 aesthetics, if you consider the big cooling towers. Cooling l l

I

74 1 towers often are considered not so aesthetically pleasing.

2 Okay. Would you please go to the next slide? We 3 are going to get back to this in a minute, but I want to 4 mention we have summarized the environmental impacts of the 5 proposed action, the no action alternative, coal-fired power 6 generation at a current and a green field site, gas-fired 7 power generation alternative at a current and green field 8 site and the impacts of changing from a once-through cooling 9 to cooling tower closed cooling system. And now I think it 10 is time for those questions that Chip is ready to have you 11 direct in my direction here.

12 MR. CAMERON: Great. And keep in mind that we are 13 going to have the severe accident mitigation presentation 14 next. So how about questions, comments for Mary Ann on that l 15 whole comprehensive analysis that PNNL did for the NRC.

)

16 David.

17 MR. LOCHBAUM: David Lochbaum with Union of 18 Concerned Scientists. You mentioned that there has been a 19 lot of studies that show that shellfish and the fish that 20 are captured on the intake screen and system survive that, 21 many of them survive. Are you aware of any studies that 22 show that humans living around the plants are not dying 23 earlier because of radiation releases?

24 MS. PARKHURST: We are going from impingement to 25 human radiation on this one, is that what you are offering 4

75 1 on that?

2 MR. LOCHBAUM: I was just looking at -- you looked 3 at shellfish. I assumed you looked at humans to the same 4 degree.

5 MS. PARKHURST: Okay. There is some question 6 here. This is an issue that, again, is outside the -- well, 7 there are category 1 issue portions of this, but it is 8 outside the realm of the Environmental Impact Statement.

9 The levels of releases at the site are under continual 10 monitoring surveillance by the plant and that is something 11 that NRC has active programs, continuing to make sure that j 12 they stay well within limits. That really is not a part of 13 this impact statement.

14 MR. LOCHBAUM: On page 2-23 of your report, you do j 15 talk about some of those, looking at the radiation limits.

-16 MS. PARKHURST: Yes.

17 MR. LOCHBAUM: There is a book that came out 18 recently that shows that for the two counties, Calvert and 19 Prince George's, there is a 15 percent higher mortality rate 20 for white females from breast cancer since the plant has 21 operated than before the plant was operated, and I just 22 wondered why that is excluded from an environmental impact l l

23 study.

24 MS. PARKHURST: Again, I should go back, 25 mentioning a little bit in Chapter 2, where he is talking

76 1 about the radiation monitoring, other effects. This is 2 descriptive material provided for background information 3 only. This particular kind of issue was not intended as a 4 part of the Environmental Impact Statement and is not 5 included in this. And I suspect that since that time there 6 have been many other changes in society that we probably 7 could be talking about, but I think we will leave that issue 8 and see if there is any other comments NRC wants to add on 9 that.

\ 10 MR. GRIMES: Yeah, I will just -- I will add that 11 the --

12 MR. CAMERON: Chris Grimes.

13 MR. GRIMES: The limits that are used for 14 effluents from nuclear power plants are constantly being 15 reviewed and challenged by studies such as the one that Mr.

16 Lochbaum described. There are also datasets that show other 17 trends, different trends, but we constantly look at those 18 kinds of studies, and that information in order to determine 19 whether or not there are any insights related to the 20 radiological protection standards, because those apply today 21 as well as in the future.

22 MR. GUNTER: Paul Gunter, Nuclear Information 23 Resource Service.

24 My question goes to the movement of the 25 transportation of high level nuclear waste from a Category 2

77 1 issue, as it was addressed originally in the original 2 supplement, being moved to a Category 1 issue.

3 First of all, I would like to know, can you just 4 give me a little bit of background in the audience, a little 5 bit of background on how this movement originated?

6 MS. PARKHURST: In the Calvert Cliffs site or in 7 NKC's proposed rulemaking and so on?

8 MR. GUNTER: Obviously in NUREG-1437, Supplement 9 1, obviously Staff considered transportation a Category 2 10 issue for NRC. Subsequent to the issuance of the draft, 11 comments bc y been received to again take this issue off the 12 table and I want a little bit of history on how this issue 13 arrived before Staff and appears different than what is in 14 this document before us today.

15 You know, I understand that it is by rulemaking 16 but can you give us -- I want some information on how this 17 issue evolved into a rulemaking? Who applied for the 18 rulemaking and how we are proceeding here? '

19 MS. PARKHURST: Don, is that one that you would be i

20 willing to discuss here?

21 MR. CLEARY: I am Don Cleary, NRC.

22 I am in the rulemaking section of the branch that j 23 has been mentioned. This rulemaking came about at the time 24 the final rule, Part 51, license renewal rule, was published 25 in December of 1996. At that time we recognized that there .

l

, 78 1 were two areas that were not adequately treated in our 2 analysis of transportation.

3 One was we had a new -- Table S-4 has fuel, spent 4 fuel being transported to multiple locations. We are faced 5 now with the candidate site, one site, Yucca Mountain. That 6 analysis had not been done for Table S-4.

7 The second area is utilities were using, going to 8 higher enriched and burnup fuel -- higher enriched fuel and 9 burning it longer than was covered in Table S-4, so at the il time in the Federal Register notice when we published the 11 final rule, the Commission stated that it would review these 12 issues in the future and that is what we are doing.

13 MR. GUNTER: Okay. Who was the petitioner for the 14 rulemaking?

15 MR. CLEARY: There is no petitioner. The 16 Commission recognized a piece of analysis that was undone 17 and said that it would do that analysis in the future, which 18 is what we are doing now.

19 MR. GUNTER: Okay. How come that is not noted in 20 the draft -- this draft document?

21 MR. CLEARY: I wil] have to defer to the people 22 that were responsible for that document.

23 MS. PARKHURST: Yes. This is partly a timing 24 thing. Tom Essig actually was responsible for the -- who is 25 in the same organization -- if he were here today probably

79 1 could provide you with more of that information than those 2 of us here.

3 MR. GUNTER: Well, I can only say that, you know, 4 it remains a concern. If you are trying -- if this agency 5 is trying to build public confidence in this -- in having 6 adequate oversight, safety oversight, of public health, 7 public safety, that you are not gaining it by continually to 8 provide us with dwindling documents where issues --

9 obviously, you know, you are saying that transportation is a 10 generic issue, but there are unique situations in this 11 county in terms of roads, in terms of population densities, 12 that should be granted si ecial consideration, particularly 13 because this is the first license renewal to be submitted.

14 It gives you an opportunity to look deeper into 15 some potentially dicey issues, but instead of actually 16 taking it on, embracing it, as you have termed it, we see l

17 these issues being sequestered from the public venue, from 18 the public's ability to address it, and that is -- I think 19 that is irresponsible, and it only portrays the NRC in this 20 role of no regulatory criteria, rather than a regulator.

21 MS. PARKHURST: Don, isn't this in the vicinity of 22 the repository that we are talking about here?

23 MR. CLEARY: Yes. I would like to clarify that 24 there are really two transportation issues.

25 .There is the local transportation issue which is

80 1 associated with increased workforce, increased population.

2 That is still being addressed and that is separate from the 3 transportation issue that I was referring to, which is 4 strictly the transportation of spent fuel.

5 Transportation of spent fuel is covered in Table 6 S-4. What is uncovered is all of that fuel converging on 7 one location as opposed to multiple locations and that is 8 all the rulemaking is handling. ,

9 MR. CAMERON: Okay. I think we are going to come 4 10 back up here to Jim. We have a question back here, but the 11 point being that local transportation issue are still within 12 the purview of this environmental impact statement?

13 MR. GUNTER: Category 2 --

14 MR. CAMERON: You just make sure everybody 15 understands local transportation and how that fits into 16 this.

17 MR. CLEARY: One part of the rulemaking which I 18 didn't mention is really an administrative correction for 19 local transportation in the GEIS. Local transportation at 20 the time of -- during the operating period was not picked 21 up -- the conclusions were not picked up in the table.

22 Transportation during refurbishment is Category 2. It was 23 not specific for the operating period.

24 The rule that we have out for public comment notes 25 that this was an oversight and notes that transportation

81 1 should be covered for both the refurbishment and the 2 operating period, local transportation impacts.

3 MR. CAMERON: I am not sure where that leaves us 4 with that but we will try to get some more on that later.

5 Sir, you had a question or a comment.

6 MR. REYNOLDS: I had a comment. I have been 7 sitting here for about two and a half hours now.

8 My name is Chris Reynolds. I am a resident here 9 in Calvert County. I work here. I play here. I spend I I

10 money here. I get the impression I am watching a Kabuki 11 play Or something. You all give your presentation and it is 12 interesting and it is important for us to hear it, and I 13 don't mean to knock any of the points that you gentlemen and 14 ladies in the upper right-hand corner here are making 15 either, but you are debating stuff you all have talked about 16 before.

17 The purpose of holding the hearing here in Calvert 18 County is to hear Calvert County residents. I appreciate 19 what you have said. Make your comments up in Washington and 20 Rockville, where the Nuclear Regulatory Commission 21 Headquarters are located and would you get moving please.

22 MR. CAMERON: And you, from a Calvert County 23 perspective, do you have anything.to ask on this particular  ;

l 24 portion at this point?

25 MR. REYNOLDS: No, sir -- on procedures --

82 1 MR. CAMERON: Okay. Then we will give you a 2 chance to that. Yes, sir? Is it on this particular 3 section? Okay.

4 MR. MIHURSKY: Thank you. I would ask for five 5 minutes to add a statement for the public record. I am Dr.

6 Joseph Mihursky, a university professor, and I have been an 7 employed ecologist for a little over 40 years.

8 For many years I ran a field and laboratory 9 research operation concerned with environmental effects of 10 energy conversion systems such as nuclear power plants.

11 Here in Maryland our study sites included a region 12 around Calvert Cliffs as well as four other power plant 13 sites. We were recognized as a center of excellence by 14 Federal agencies in the state of Maryland.

15 I have been an advisor to other U.S. states, the 16 Federal Government, and other nations of the world on these 17 same environmental matters.

18 Regarding power plants, we made a number of 19 recommendations about site selection, engineering designs 20 and operational features that in the main were implemented 21 by BG&E in order.to minimize biological damage to the local 22 bay system. I heartily comment BG&E for doing so. The 23 Calvert Cliffs plant, which requires about 15 square mile 24 feet of water per day, to release its waste heat, does 25 affect pumped, entrained and impinged organisms because of

83 1 required bay water pass-through of its heat exchange system.

2 Organisms such as phytoplankton, zooplankton, 3 shellfish and fin fish eggs and larvae, small fish as well 4 as combed jellies and jellyfish may be damaged or killed 5 because of the large hydraulic mixing and diluting 6 circumstances' effects upon bay organism population dynamics 7 is debatable or difficult to assess, especially if you are 8 doing this on a wide regional, baywide scale.

9 Hydraulic and physical discontinuities of current 10 velocities and temperature do influence normal seasonal 11 behavior of mobile species such as fin fish. Also water 12 velocity has scoured about a 90 to 100 acre area in the high 13 velocity discharge zone and has resulted in changed benthic 14 community structures.

15 Although the above incremental effects on the 16 local bay system are known, the state and Federal regulatory 17 agencies have deemed them acceptable in return for 18 electricity production. Now although BG&E has worked hard 19 at being a good neighbor, personally I would prefer having a 20 more benign and lower risk electricity-producing system in 21 operation, as I do live within the 10-mile radius of risk 22 concern.

23 I do understand in detail the process and  !

24 procedures that led to the installation at this location by 25 BG&E. The past is done. My existing concerns as a local

84 1 informed citizen of Calvert County for 38 years are 2 five-fold.

3 One is continued storage of spent radioactive

4. material onsite, but I recognize the complexities of this 5 national problem.

6 Two is the eventual issue of decommissioning, 7 burial costs, and future care and protection of the i

8 facility.

9 Three is the question of biological effects of 10 batch release of radioactive tritium to the bay. Although 11 tritium is a weak beta emitter, it can be incorporated with

)

12 water into the cell nucleus of rapidly developing, early 1 l

13 life history stages of bay organisms such as oysters, clams, '

.4 fish and so forth. What does tritium uptake mean to the  ;

I 15 genetic well-being of key bay organisms? I am not aware 16 that this question has been addressed at the Calvert Cliffs 17 site.

18 Some years ago I was part of a Federally-appointed 19 team to oversee the decontamination of the Three Mile Island 20 facility after partial fuel rod meltdown and radioactive 21 release. One of the recommendations eventually developed 22 concerned precautionary measures about public safety whereby 23 potassium iodide pills should be made available to every 24 household and facility having children that were located 25 within the critical area around a nuclear power plant.

l

1 85 1

1 1 This recommendation recognized that children are l 2 highly prone to uptake or radioactive iodine that may be 3 released from a plant incident.

4 Such uptake can cause thyroid cancer problems, so 5 my fourth concern is that since such precautionary measures  ;

6 are being followed by other U.S. states and nations of the 7 world, why is such a policy not pursued here by Government 8 and management in the Calvert Cliffs region?

9 My fifth and final concern is a metallurgical one.

10 I realize that a nuclear power plant is an awesome 11 engineering accomplishment but I also recognize that in the

]

12 earlier days we did not have a sufficient database on the 13 effects of long-term radiological emissions upon 1 14 metallurgical properties.

15 We now know that brittleness is one of the 16 consequences of this exposure and results in blows of welds 17 and piping. How is this substantial problem going to be 1

18 avoided as this facility continues to age?

]

19 I would like to submit these for the public record 20 and thank you for the opportunity to comment on this very 21 important societal matter. Thank you.

22 MS. PARKHURST: And thank you for such thoughtful 23 comments. A couple of them we might want to --

24 MR. CAMERON: And I just want to emphasize that 25 any of these comments will be considered as part of the I

86 1 public record.

2 Do we have any final questions, comments before we 3 go on to severe accident?

4 MR. RICCIO: Hi. My name is Jim Riccio. I am the 5 staff attorney with Public Citizens Critical Mass Energy i

l 6 Project. i

~

l 7 As much as I liked the gentleman's comments in the 8 back, the reason we are here is because this plant has the 9 potential of affecting our back yard as well. We are only 10 40 miles away and an accident in this facility could easily 11 wipe out my neighborhood as well.

12 One thing I would like to address is I am glad to l

13 see you are addressing the health impacts of electromagnetic 14 fields. That'is going to be interesting. I wish you would '

15 look at the health impacts of chronic exposure to low dose 16 radiation. The last couple of BEIR reports that have come 17 out have found that the numbers we were using from 18 Hiroshima-Nagasaki data were well underestimating, six to i 19 eight times underestimating what we were getting in terms of 20 chronic low dose exposures.

21 There was a recent study done by UCLA which I wish 22 you would incorporate into your work as well that was done 23 on Rocketdyne workers. They basically found that -- and 24 actually one of their conclusions was that before we move l

25 ahead with exposing the public to more and more chronic low

87 1 dose radiation that we should take a look at our standards 2 and re-evaluate them in light of new data.

3 I realize that parts of this may not necessarily 4 affect your generic environmen'tal impact statement, but I i 5 wanted to follow up on Dave's comments -- and I will be J

6 happy to save my SAMA comments for later.

7 MS. PARKHURST: Thank you. Yes, we are aware of 8 that particular study and the objections to it as well, and ,

9 it goes to part of the continuing NRC look at what the 10 effects appear to be. NRC continually reviews that.

1 11 Chris, did you want to add or not?

12 MR. GRIMES: I'll cover them when we talk about 13 SAMA issues.

14 MS. PARKHURST: Okay, we'll catch that when we hit 15 SAMA issues. Any other environmental related issues? Any 16 other comments?

17 MR. CAMERON: I think we have some right here.

18 MS. PARKHURST: Okay.

19 MR. ABBE: Some of you heard these comments in 20 July. Some of you have not. I have been requested to 21 repeat them.

22 My name is George Abbe. I am a Senior Scientist 23 with the Academy of Natural Sciences Estuarine Research 24 Center, located.in St. Leonard, Maryland. ,

25 I have been a research scientist with the Academy i

88 1 for almost 32 years now, working primarily with blue crabs 2 and oysters in Southern Maryland. I am also currently 3 serving as President of the National Shell Fisheries 4 Association, which is an international society of over 800 5 scientists who work with shellfish such as clams, oysters, 6 scallops, shrimps, crabs, lobsters and similar organisms.

7 That honor will be passed on to a new President 8 when we meet in Halifax later this month. Today, however, I 9 would like to speak to you as a Senior Scientist with the 10 Academy.

11 Academy scientists began working in the Chesapeake 12 Bay near Calvert Cliffs in 1968 under contract with 13 Baltimore Gas & Electric. Our goals were to determine 14 whether the generation of electrical power and subsequent 15 discharge of heated water frota the Calvert Cliffs nuclear 16 power plant had significant effects on water chemistry, 17 phytoplankton, zooplankton, epifauna and benthic organisms, 18 shellfish and fish.

19 Our preoperational studies at Calvert Cliffs were 20 conducted for seven years until Unit 1 began to generate 21 power in 1975. We continued these studies for another seven 22 years until 1981. Results of these studies appear in I 23 numerous scientific reports, peer reviewed journal articles 24 and a book published in 1987 by Springer-Verlag entitled, 25 " Ecological Studies in the Middle Reach of Chesapeake Bay:

I

89 1 Calvert Cliffs," edited by Kenneth L. Heck, Jr.

2 I am unable to detail results of all these studies 3 because of time, since that would take days, but we detected 4 relatively little effect of power generation at the Calvert 5 Cliffs nuclear power plant on the aquatic organisms that 6 live in the Bay immediately adjacent to the plant.

7 Although there was damage to some small organisms 8 drawn through the plant in the cooling water and to some of 9 the fish impinged on the travelling screens, the damage was I 10 generally minimal and as long as numbers are not large, fish 11 injured or killed by the plant are not lost to the 3 12 ecosystem, but simply provide food for other fish and crabs I j

13 in the area.

14 There have been a few instances since 1975 when 15 ( fish losses were significant, but BG&E usually sought our 16 advice and was responsive in its efforts to minimize these 17 losses.

18 Oysters that we placed in the discharge area grew 19 slightly faster than similar organisms or similar oysters 20 that we held some distance from the plant. Oyster 21 mortalities were unaffected, averaging about 7 percent 22 before and 6 percent after the start of power generation.

23 Analysis of 16 years of crab population data beginning in 24 1968 showed that the percentage of the catch made at 25 stations in the vicinity of the Calvert Cliffs plant were 1

)

l

90 1 nearly identical during both preoperational and operational 2 periods and catches at control sites were nearly the same as 3 near the plant.

4 After these initial studies, during the 1980s and 5 1990s, BG&E continued to fund additional research projects j l

6 focusing on oysters and crabs in the vicinity of Calvert J

i 7 Cliffs. We now have a 31-year dataset on blue crabs near )

8 Calvert Cliffs that recently provided much of the input to 9 the stock assessment of Chesapeake Bay blue crab, 10 Callinectes sapidus, conducted by NOAA's Chesapeake Bay 11 stock assessment committee and is currently part of the 12 database used by the technical work group of the bi-state 13 blue crab advisory committee in its efforts to manage this 14 last great fishery of the Chesapeake.

15 In biology or fisheries a 5 or 10 year dataset is 16 often considered to be quite long. A 31 year dataset is not 17 only rare, it is almost unheard of. This extremely valuable 18 dataset is the result of long-term funding by BG&E and it is 19 difficult for me to overemphasize this point.

20 In talking with colleagues around the country 21 about this data they are amazed that a power company would 22 do something like this for such a long period of time.

23 In addition, we have cooperated with state of 24 Maryland researchers for more than 20 years in a program 25 that transplants oysters quarterly into the discharge area

91 1 at Calvert Cliffs to examine accumulation of radionuclides.

2 While we are not directly measuring contamination, although 3 the state is, these sentinel oysters will serve as a means 4 for detecting unscheduled or excessive releases from the 5 plant.

6 I believed early-on that Baltimore Gas & Electric 7 had a commitment to the environment both in learning what 8 was there and then protecting it. Their continued funding 9 of environmental research after we had shown that the 10 thermal discharge had little effect on local organisms is in 11 my opinion a direct result of their commitment.

12 Although the blue crab research is no longer 13 funded by BG&E, I still believe in their commitment. We 1

14 remain available and interested in advising them on l

15 ecological problems they might encounter and I am committee 16 to the environment as well. That is why our blue crab 17 studies will continue, although now through other funding 18 sources.

19 For over 30 years the Academy has served as an 20 advisor to Baltimore Gas & Electric at both the corporate 21 level and the plant level. At the same time we have 22 provided oversight and scientific expertise to the state of 23 Maryland. The fact that we are able to interact smoothly 24 with all of these groups about topics of mutual interest in 25 my mind underscores BG&E's interest in and commitment to the

i 92 1

1 environment.

2 Thank you very much.

3 MR. CAMERON: Thank you.

4 [ Applause.] l 5 We have two short segments left, severe accident 6 and then the conclusions and any statements associated with 7 that, and I'd just like to thank Mary Ann and her team for 8 all the work in that presentation.

9 Now we're going to have a short presentation, 10 severe accidents. We'll have some questions, and then we'll 11 go to conclusions and any statements all of you in the 12 audience might have or questions.

13 Go ahead, Bob.

14 MR. PALLA: Okay. My name is Bob Palla, and I'm 15 with the Probabilistic Safety Assessment Branch in the 16 Office of Nuclear Reactor Regulation. And I want to just 17 outline very briefly what we had done in the area of severe 18 accident mitigation alternatives for the Calvert Cliffs 19 site.

20 Severe accidents is a class of accidents in which 21 the reactor core sustains some degree of damage, which could 22 range from relatively benign rupture of the fuel cladding to 23 in the limit rupture and meltthrough of the reactor vessel.

24 And the containment could and in most cases is predicted to 25 maintain its integrity in the majority of these accidents,

93 1 but some of these accidents do result in releases. In these 2 kinds of -- the probabilities of such events and the 3 consequences are dealt with through the probabilistic safety 4 assessment study, and that formed a lot of the basis for 5 what we had done in the severe accident mitigation 6 alternativen.

7 Let me just state very briefly that the issue of 8 severe accidents itself, and we had some questions about the 9 core damage frequency and probably that the numbers aren't 10 as low as one might like them to be, we did not as part of 11 the severe accident mitigation study look at the numbers 12 themselves and make any judgments about whether the numbers 13 were low enough. What we did in this study here was to look 14 at ways that the residual risk could be made lower, and this 15 is basically a very systematic process for screening where 16 the risk is coming from and trying to identify ways that it 17 could be reduced without adversely impacting on the plant. I 18 And that's what I'm going to talk about, the issue of severe 19 accidents and the numbers, the core damage frequency, et I

20 cetera. Severe accidents itself was covered as one of the j 21 issues in the GEIS, and it was a Category 1 issue.

22 What is a Category 2 issue is the severe accident l

l 23 mitigation alternatives that I'm going to be speaking about 24 here.

25 Now the purpose of the evaluation is to ensure

94 1 that plant design changes -- the design in the sense of 2 hardware, it could be something as simple as a procedure --

3 but we're searching to identify ways that we could further 4 reduce the risk in a smart way that doesn't cost, you know, 5 exorbitant amounts of money and is effective at either 6 preventing core damage or at mitigating the consequences.

7 And by the latter I mean if you could find a way to improve 8 the containment performance, that would be part of this as 9 well. So we're looking at both preventive and mitigative 10 ways that the risk could be reduced.

11 Next slide.

12 I'm going to outline here very briefly what the 13 process is that we used. The structure is basically driven 14 by understanding where the risk is coming from, and the most 15 effective way to do this is by looking at the plant-specific 1

16 probabilistic safety assessment study. What we have in the l 17 case of Calvert Cliffs, like at all other plants in the 18 U.S., is an individual plant examination which is a 19 probabilistic study that identifies the different sequences, 20 and the sequences is basically a combination of hardware, 21 equipment failures, human errors, those things that need to 22 occur collectively to result in damage to the core.

23 We looked to the plant-specific study, we used it 24 here for the Calvert Cliffs SAMA analysis to identify what 25 are the dominant accident sequences, where is the risk

95 1 coming from for this plant.

2 We used the latest version of the study. It 3 covered both internally initiated events, such as 4 loss-of-coolant accidents, and it also included external 5 events, such as seismic events. Through that process, we 6 identified a large number of potential improvements.

7 Now in addition to looking at the individual plant 8 examination, there were numerous generic studies that also 9 provided insights into ways that. risk could be reduced. And 10 these were considered as well as the plant-specific studies 11 to arrive at a very comprehensive set of candidate 12 citernatives. Now these were then looked at in terms of 13 their estimated costs and ballpark estimates of the risk 14 reduction that was achievable.

15 There's a number of -- it's in excess of 100 16 potential designs that were initially identified. Then by 17 looking at those that cost we31 in excess of what the 18 expected benefit is. You can take a risk-reduction number 19 and you can turn that into estimates of costs, and then you 20 could compare the hardware costs against the basically the 21 benefit of the fix, and the initial screening was done that 22 basically eliminated those alternatives that had excessively 23 high costs, and those alternatives that on the other end of 24 the spectrum didn't offer very much risk reduction.

25 So through -- by basically skimming off at both

96 1 ends of the spectrum, one could pare back the number of i 2 alternatives. Initially the risk reduction and cost l

l 3 estimates were done in a scoping manner, very approximate, 4 very conservative, and then as the number of alternatives 5 were narrowed down, more realistic estimates of the risk l 6 reduction and the costs were considered. So this process 7 was followed basically going in with 100-plus alternatives 8 and then paring this number down to approximately 20, which l

i 9 received a more in-depth look in terms of both cost and in 10 terms of risk reduction.

11 Then the fourth bullet there is determine whether 12 or not implementation of the improvement is justified. We 13 looked at the resulting alternatives to see whether they 14 would provide -- meet three criteria. We wanted -- these 15 alternatives are worth doing only if you can get a 16 significant reduction in the total risk. If you're only 17 going to reduce it by a percent or so, you're still left 18 with 90 percent and 99 percent. This was not judged to be l

19 significant enough to pursue, but we were looking at things 20 that could provide the biggest risk reduction, and we were  ;

21 looking -- in the second item we were trying to have a 22 favorable value impact ratio, and these value impact ratios 23 are derived in accordance with regulatory guidance that we 24 have for doing cost-benefit analysis. So it's -- this is 25 very much process-driven, where the rules of how one 1

I l 97 1 estimates the costs of the various design alternatives are 2 very well established.

3 Finally, the risk reduction, we considered long 4 and hard how one would deal with the issue of license 5 renewal if one found cost-beneficial SAMAs, and I'll talk l 6 more about that in a moment, but the third criterion is that l

7 in order to require a design alternative to be implemented 8 as part of renewal, license renewal, we felt that it would 9 need to be associated with the impact of the additional 20 10 years, specifically that it would need to be something that 11- was aging-related that was not considered in the initial 12 licensing of the plant. So these were the basic three 13 criteria that we used to make the final screening.

14 Next slide, please. Number 53.

15 As a result of this process, one design 16 alternative was identified by BG&E that involved the 17 installation of a watertight door, and that improvement 18 would reduce the risk from internal flooding scenarios. It 19 reduces the core damage frequency by about 5 percent. Its 20 costs were relatively minimal, and BGE has committed to 21 pursue this under their corrective actions program.

22 Now in looking at the additional SAMAs, we 23 identified a number of enhancements that in accordance with  !

24 the way that the NRC does regulatory analysis, which is not 25 completely consistent with the way that the industry views i

L 1 1 1 98 1 these analyses, we include some additional costs -- I'll 2 just characterize them as societal costs -- that get 3 factored into our analysis. What they tend to do is they l

l 4 tend to make alternatives look more attractive, because 5 we're considering primarily two important factors are 6 averted onsite conts, and this is specifically replacement  ;

7 power costs and insurance costs is one of the, you know, 8 that defray the cost of onsite cleanup. This is kind of a j l

i 9 contested issue, and there's not really -- NRC and industry 10 don't really see eye to eye on how that should be handled, 11 but we did our analysis in accordance with these -- our 12 guidelines.

13 We identified some additional SAMAs that we think 14 deserve to be looked at further. Now they do not relate to 15 aging, and we for purposes of renewal are not requiring 16 these alternatives to be looked at here. But I will talk 17 about it right now rather than put it off. The philosophy 18 that we have -- I don't want anyone to leave the room with 19 the impression that we've identified some things that are j 20 worth doing and we've swept them under the carpet. As part 21 of license renewal, we didn't see implemented these 22 alternatives because they were not related to aging.

23 Our philosophy is that the environmental l

24 supplement is narrowly focused on the environmental impact 25 of extending the operating license another 20 years.

l l

l

99 1 Operation for the remainder of the current license is 2 addressed by the previous environmental statement, prior 3 staff reviews, and the ongoing regulatory oversight of 4 utility operations. There's a presumption that we're making 5 that the current level of risk is acceptable or would be 6 made acceptable if risk outliers were identified. Now 7 that's where this comes in. The judgment was made here that 8 it was more appropriate to pursue the implementation of 9 SAMAs as an issue under the current operating license rather 10 than as a license renewal issue.

11 Now the decision logic for a SAMA is basically in 12 two categories. The first category is if the SAMA is 13 cost-beneficial, and it relates to aging, then the SAMA 14 would be implemented as part of license renewal. However, 15 the implementation could be completed as late as just prior 16 to license re ; sal, you know, to the renewal period, to the 17 beginning of the renewal period. So conceivably if we 18 pursued this as a renewal issue, it could be 15 years before 19 these fixes would need to be made, because they're 20 aging-related and this, you know, conceptually doesn't kick 21 in until the end of the current operating license.

22 The second category is that if the SAMA is 23 cost-beneficial but does not relate to aging, then the SAMA 24 would not be required as part of license renewal, but it 25 would be considered for implementation under the current

)

i l

100 1 license. Now the vehicle for doing that is a program that 2 we've initiated at NRC. It's referred to as the Individual 3 Plant Examination Followup Program. It's a program that -- .

1 4 it's still -- it's been initiated, but it's still in its I 5 early stages. l

)

6 What we intend to do is look at the insights from 7 -the individual plant examinations for all the plants and to 8 identify based on such things as core damage frequency, d 9 contributors to core damage frequency, large early release 10 frequency, we'll be looking at the insights from those 11 studies and perhaps looking at things that the results 12 suggest should be pursued further in the way of, you know, 13 hardware implementation. We intend to look at these 14 alternatives that we identified as part of this SAMA 15 analysis. We will look at them further as part of that 16 program. That's the plan.

17 If something does prove to be justified, it would 18 not wait until the end of the current operating license, it 19 would be pursued as early as these improvements could be 20 scheduled for implementation. And basically the few things 21 that we did identify would fall into that second category 22 and would be looked at further as part of IPE followup.

23 And just the last slide then. The last slide just 24 kind of concludes that additional plant improvements to 25 mitigate severe accidents are not required as part of

101 1 license renewal.

2 MR. CAMERON: Okay. Thanks, Bob.

3 .I know we have a couple questions on severe 4 accident, and it's just coincidental that I'm up here at 5 this part of the room, but does anybody have a question?

6 Jim, and then we're going to move to conclusions 7 and statement.

8 MR. RICCIO: My name again is James Riccio. I'm 9 the staff attorney with Public Citizen's Critical Mass 10 Energy Project.

11 There are just a couple of things. First I want i

12 to address off the bat I've heard a couple of things so far '

13 about this being the first plant to go through license 14 renewal. That's not the case. There was a plant up in 15 Massachusetts that tried to go through this process several i 16 years ago. When they tried to go through the process, they 17 realized that the plant shouldn't even be operating during 18 the current license, and the plant has since been shut down.

19 They have now rewritten the rule to make sure that never 20 happens again. Now I'm not saying that the process these 21 gentlemen are going through is not substantive, and I'm not 22 questioning their integrity. They're just doing their jobs 23 and they're having to follow a bad rule. j 24 Now to get into the SAMAs, I'm glad you followed 25 up with your IPE followup, because there's nothing in the l

102 1 documents that even talks about the IPE followup. Basically 2 there are several things that are addressed in here where 3 they basically find that we can make this plant safer, but 4 we're not going to do it because it doesn't have to do with 5 the aging of the reactor.

6 That's really unacceptable. If you know that you 7 can improve the safety of this plant for a relatively 8 minimal cost impact, I think it should be done. It says 9 right here under -- I won't even bother you with the entire 10 title, but basically they're talking about changing how the 11 actuation system for the safety systems work, how the logic 12 works.

13 Now safety system actuations are a problem 14 throughout this industry, and they try to be whittled away 15 first off by changing the NRC regulations on how you record 16 them. That didn't work too well, so now we're addressing 17 them under the SAMAs, and it says here that this i

18 modification would prevent the spurious safety system j l

I 19 actuations, which is one of the most risk-significant 20 contributors to the Calvert Cliffs PRA model. Yet because 21 it's not having to do with the aging of this reactor, it's 22 not going to be addressed, at least under this license 23 renewal.

24 You know, it seems ts be relatively inappropriate.

25 If you can enhance the safety of this reactor, you should do

1 103 1 it. The one thing that they're actually going to do for us 2 is to basically -- they're going to put it in a watertight 3 door. Well, that's great. .They whittle it down from 158 4 design changes down to 108 which are specifically for the 5 Calvert Cliffs reactor, again down to 23, they find some 6 that might actually increase safety, but they're not going 7 to do it except for putting in the watertight door.

8 This utility is about to dip into your pockets for 9 what they're calling stranded-cost recovery. This is 10 another term for basically the bad investment in nuclear 11 powerplants. They're going to be asking you for millions 12 and millions and millions of dollars. The least that they 13 can do is dip into their own pockets and fix some of the 14 safety problems that exist here so that if they run this 15 thing longer, that it won't pose even more of a risk to the 16 surrounding populations.

17 The other SAMAs -- the reason I like going into 18 this section is because this isn't being done out of the 19 kindness of NRC's heart or out of the largesse of BG&E.

20 Some of my friends several years ago had to sue the NRC to 21 ensure that these mitigation alternatives were taken into 22 consideration. Now what we're finding is that when we're 23 finding improvements, we're going to sluff them off till 24 somewhere further down the road, but we're not going to 25 address them in the license renewal process. It does you a i

104 1 disservice, it does the public a disservice, and 2 unfortunately it also does the utility and the agency a 3 disservice, because it lowers the credibility of both the 4 industry and the agency in the eyes of the public.

5 I hope that the issues that we're addressing here 6 today will eventually get addressed. They should be 7 addressed before they renew the license, but that doesn't 8 seem to be the case. So hopefully with our friends helping 9 and getting involved in the IPE followup we can assure that 10 these are addressed further down the line. However, if this 11 utility knows that there are things that could be done to 12 make this plant safer today, I see no reason why they 13 shouldn't be forced to do it.

14 MR. CAMERON: Okay. Thank you, Jim.

15 Bob, did you want to just reemphasize what the NRC 16 is doing about these?

17 MR. PALLA: Well, what we would do would be done 18 early rather than late. If it was tied to renewal, it could 19 conceivably be done much later. I'm agreeing, the 20 alternatives are out there, they're on the table, they seem 21 to make sense, so we're going to be looking at it further --

22 MR. CAMERON: All right.

23 MR. PALLA: Under this program.

24 MR. CAMERON: Okay. Thank you, Bob.

25 Let's go to just some quick conclusions, and then

r 105

1. I want to have Commissioner David Hale make some remarks and 2 others who want to make some remarks.

3 Tom, do you want to give us a conclusion and 4 schedule?

5 MR. KENYON: To summarize, as we have been saying 6 throughout the talks today, that Supplement 1 contains the 7 NRC's preliminary conclusions regarding the results of our 8 environmental review for Calvert Cliffs. It is important to 9 know that the overall license renewal decision is based on 10 the safety -- not only on the environmental review, but also 11 on the safety review that Mr. Grimes is in charge of.

12 If you did not yet get -- request a copy of the 13 Supplement 1 from the NRC, there are extra copies available 14 in the back. All you have to do is go back there and ask 15 them for a. copy. It also can be viewed at the NRC's public 16 document room in Washington, D.C. It can be seen at the 17 local public document room over in Prince Frederick, 18 Maryland, and additional copies can be obtained from the 19 Government Printing Office.

20 In addition to that, the document can be 21 downloaded off of the web site that we have. There is 22 information on the sheet that gives you the locations and 23 addresses of the PDRs and the web site Internet address.

24 Next slide, please. As we have talked about 25 today, the staff has looked at a number of items to do the i

i

106 1 environmental review for Calvert Cliffs. We have looked at 2 the conclusions and findings in the GEIS. We looked at the 3 environmental report that was submitted by BG&E in their 4 application. We have consulted with the local, state and 5 federal agencies, and we have done our own independent 6 review, including the results of the scoping process, and 7 considering the public comments that we received last year.

8 Next slide, please. Our overall conclusion is 9 that the adverse environmental impacts of license renewal 10 for Calvert Cliffs Nuclear Power Plant are not so great that 11 preserving the option of license renewal for energy planning 12 decision makers would be unreasonable. Now, that gives you I

13 our preliminary conclusions, but we are looking for input 14 from you folks on our review.

15 Next slide, please. The NEPA process has provided 16 two opportunities for members of the public to provide your 17 input on the environmental review. There was the one -- the 18 comment period that took place back in June through August )

l 19 of last year, and now there is the comment period that we i 20 are in the middle of today. As mentioned earlier, we have l 21 extended our comment period by 30 days from what is required 22 by NEPA, which will end on May 20th, 1999.

23 As we did with the comments that we received 24 during the scoping process, comments we receive that are not 25 bearing on the decision to renew the license will be

107 1 referred to appropriate NRC programs if they are appropriate 2 for the current operating plant.

3 Next slide, please. On the review schedule, as I i

4 said earlier, the comment period ends on May 20th, and after 5 we receive your comments, we.will sort the comments and 6 evaluate them. If appropriate, the comments may cause us_to 7 change our conclusions in the Draft Environmental Impact 8 Statement and we may decide it is necessary to change the l 9 final Environmental Impact Statement. That Environmental 10 Impact Statement for Calvert Cliffs is scheduled to be 11 issued in November.

12 In the final version of Supplement 1 of the GEIS, 13 the staff will identify all the public comments that we .

I 14 received during this comment period in Appendix A to the 15 document. We will document how we dispositioned those 16 comments and so members of the public will have -- will know 17 how they were dispositioned and they will see how they were  !

J i

18 addressed. 1 1

1 19 Next slide, please. The last slide gives you my 20 name and phone number. I am the point of contact for the 21 environmental review of the license renewal project. All 22 the documents, as we have said before, can be found in the 23 public document room in Washington and in Prince Frederick, 24 Maryland. You can submit your comments by mail or in 25 person, or by the e-mail at that e-mail address. Again, I m

i 108 1 want to remind you that there are information sheets in the 2 back to tell you how to get information or how to submit 3 your comments.

4 In summary, I want to thank you for attending 5 today's meeting. It has been long one, but it is an 6 important part of the overall license renewal process. It 7 is important that you participate because it makes for a 8 better process if you do participate. That concludes our 9 formal comments.

10 MR. CAMERON: So that you don't think that we 11 ending the meeting now, we are not. And we have a number of 12 people who want to make comments. There may be other 13 questions out here. But right now I would like David Hale, 14 who is a Calvert County Commissioner, to come up, to make I i

15 some statements. And, Tom, we may be back to you for 16 schedule questions or other questions.

17 MR. HALE: Good afternoon. I am mainly here to 18 address the NRC today. My name is David Hale, and I am the 19 Vice President of the Board of County Commissioners. The 20 President, Linda Kelley, will be here to testify, too, at 21 7:00 with I believe roughly, it not exactly, the same 22 message.

23 If you take one point away from this testimony l 24 today, it is the fact that the five County Commissioners 25 stand in unanimous support for the relicensing of this l

l I

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i 1

109 1 plant. I have a bunch of other points to make, but that is 2' the one point I want you to take away today, is that the i 1

3 local government that surrounds this plant stands in 4 unanimous consent in support of this licensing issue. As  !

5 you know, it is pretty rare we get a 5:0 vote on these --

6 especially on large issues like this, but we did it today.

1 7 We took the vote today so that we could come in front of you

8. today and stand here and say, today we stand in unanimous l

l 9 consent, 5:0.

10 I wasn't going to make specific comments, but I l 11- saw a couple of things on the slides I would like for you to 12 address. On slide 47 and again on slide 49, you seem to 13 evaluate socioeconomics, which is I believe mainly where my )

J l 14 testimony falls into, on the decision of no action or 15 denial, as small to large. I would ask you -- you need to 16 put extreme there. That is not small, that is not medium, 17 that is not large. You if choose no action, it is an 18' extreme impact to everyone who sits before you or lives 19 within a 30 or 40 mile radius of this plant, and I just 20 wanted -- I did bring some hard facts. I can leave the 21 sheet with you if you would like.

-22 Calvert Cliffs is the largest employer the largest l

23 private employer in this county. They provide 1500 jobs to 24 .the people and over a thousand of those are to residents of 25 this county. Calvert Cliffs provides 20 percent of the )

i 1

110 l

1 operating income to this county. They provide $79 million l

l 2 in salary and $59 million of that annually goes to this 3 country or people who live in this county.

4 This is where I say it is extreme. If you close 5- this plant, or if we cannot operate under a new license, we 6 are looking at on average $600 in taxes increase per house 7 per year. And that.is why I don't want to see large or 8 small in that category.

9 I guess the other thing is the employees of BG&E 10 -- it goes far beyond economics, and it is probably in the 11 details which you didn't have time to present today, but you 12 need to look at the impact to our volunteer fire and rescue 13 squads, to our volunteer teacher programs, to our high 14 schools, to our middle schools, to our elementary schools.

15 If we remove this work force and disperse it into the winds, 16 you remove a huge component of a service this county 17 desperately needs. So, again, I am going to leave it at l 18 that.

19 I appreciate you listening to me today. Please 20 take into account that it is not a small, medium or large l 21 impact should you choose no action. No action is action and 1

22 in this case it will be extreme. So, again, we stand in 23 unanimous consent to ask you and support this relicensing.

24- Thanks.

25 MR. CAMERON: Okay. Thank you very much, l

l

r=

111 l' Commissioner Hale.

2 (Applause.]

3 MR. CAMERON: Without getting into a long answer, 4 the types of impacts that Commissioner Hale identified, are 5 they addressed in the --

6 MS. PARKHURST: In Chapter 8, they are addressed 7 in more detail. I have got the socioeconomist here who can 8 actually discuss this, if you want a few words.

9 MR. CAMERON: I don't think a socioeconomist can 10 ever say a few words.

11 [ Laughter.)

12 MR. SCOTT: Two words. They are addressed. No, 13 there are a considerable number of details concerning the 14 existing effects of the plant on the environment and the 15 potential effects-both of closure of the plant and/or 16 replacement plants for that. So some of what you are seeing 17 there in characterization is, if you are looking at a '

18 closure scenario, you are also thinking about what would you 19 have to replace it with, and so'some of that information 20 results in that range of effects.

21 MR. CAMERON: Okay. Thank you. I think the point 22 'was not just that they are addressed, but how they are 23 characterized as small, medium, large. How about David --

24 Dr. Rogers, Dr. David Rogers?

25 DR. ROGERS: My name is David Rogers, I am a i

I

112 1 public health physician and I have served as Health Officer 2 for Calvert County for the past 26 years. Of course, my 3 beginning pre-dated the operation of the power plant. As 4 Health Officer, I am accountable to the Board of County 5 Commissioners, who, by statute, serve as the County Board of 6 Health and, as such, they have a duty to look after the 7 health and welfare of the county residents. I am also 8 accountable to the state Secretary of Health and Mental 9 Hygiene, of course, who has a broad responsibility.

10 As Health Officer, I am, of course, concerned 11 primarily with the health of the people who live in Calvert 12 County. I have heard a number of concerns raised about the 13 impact of the health -- the impact of the plant on the 14 health of the people who live in Calvert County, 15 particularly those who live near the plant. That is, of 16 course, a legitimate concern. I might say that my personal 17 residence is located approximately within a six mile radius 18 of the plant, so it is not only a matter that concerns me 19 professionally, but also in my personal life as well.

20 The thing that is unique, of course, about a 21 nuclear power plant is its potential for producing 22 radiation. And the one that we are concerned about with 23 ' radiation exposure, as far as human health is concerned, is 24 primarily the incidence of cancer, and that is the one thing 25 that I felt compelled to take a look at in trying to

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113 1 understand whether or not there has been an adverse effect 2 on human health from the operation of this power plant in 3- Calvert County.

4 Let me make reference, first, to a study published 5 by the National Cancer Institute in 1990 entitled, " Cancer 6 in Populations Living Near Nuclear Facilities." That was a 7 study that looked at cancer mortality between 1950 and 1984 8 and studied the effect of some 62 nuclear facilities that 9 were in service prior to 1982.

10 Let me just read from the conclusions of that l

11 report, and I see people nodding and smiling, so this may be 12 repetitious for some. It said that the comparison of cancer 13 rates both before and after nuclear facilities began 14 operation were especially informative. Overall, the 15 relative risks of leukemia and other cancers appear to be 16 slightly higher before reactor startup than after, providing l

L 17 no evidence that environmental pollution attributable to the l

l 18 facilities might be causing a substantial increase in cancer 1

19 risk in the study counties.

20 The committee concludes that the survey has 21 produced no evidence than an excess occurrence of cancer has 22 resulted from living near nuclear facilities, and so forth.

23 Now, the State of Maryland has had in operation 24 now for a number of years a so-called Cancer Registry. That 25 is a much better indicator of cancer than looking at

r i

114 1 mortality data. ' The Cancer Registry reco'."'s cases of cancer 2 as they become diagnosed and the State Health Department has 3 analyzed cancer incidence data for a five year period. Now 4 this is unpublished data, but it is available.

1

! 5 For a period of 1992 through 1996 -- now, let me l 6 say the Cancer Registry has only been in operation since 1

7 that time -- they looked very specifically at certain l

l 8 geographic areas. They looked in a small area at two 9 specific zip codes, 20657 and 20685, which are the Lusby 10 Post Office areas and the St. Leonard Post Office areas.

11 They looked at Calvert County as a whole. They looked at 12 the three southern Maryland counties which make up Southern j i

13 Maryland. They looked at the State of Maryland. And, of l 14 course, they compared that data with the country as a whole.

15 They also looked at the incidence of cancer in 16 children as compared with adults. Now, I heard concern 17 raised particularly about children, and that makes sense 1

18 because children, of course, are a better indicator for this 19 particular situation, because if you look at adults, you are 20 looking at a much more varied exposure possibility, with 1

21 work place exposures, living in different parts of the l

l 22 country, but with children who have lived here, one can 23 reasonably assume that their exposure has probably occurred 24 in their place or residence, at least during the few years 25 that they have been here as children.

l L ..

1 115 1 With children, they found that the incidence of 2 all cancers in children during this study period was 3 actually less in the zip codes that immediately surround the 4 plant than in the state as a whole. They also teased out 5 particularly the incidence of brain cancers and leukemia, 6 since these have been' associated particularly with exposure 7 to radiation. These, again, showed no significant increase 8 in incidence.

9 They also looked at the incidence of cancer in 10 adults, looking particularly at lung cancer, breast cancer, l

11 prostate cancer and colon-rectal cancer. Again, with the 12 adult population, in all of these study areas, looking at I 13 the zip codes and looking at Calvert County, and Southern 14 Maryland, there was no evidence of any increase in rates 15 that is localized to those areas.

16 So that I think one can reasonably conclude, in a 17 very objective fashion, that in terms of the effect on human J

18 health, as far as something that is specifically related to 19 radiation, there is no discernible effect with respect to 20 cancer which, of course, can be traced back to exposure to 21 radiation. I also, of course, would have no reason to 22 dispute the findings of the impact study that there is a 23 small or no effect on human health across the board.

l 24 Thank you for your attention.

25' MR. CAMERON: Thank you very much, Dr. Rogers.

116 1 (Applause.]

2 MR. CAMERON: I am going to ask Captain Mogel to l 3 come up.

1 4 MR. MOGEL: My name is Russ Mogel, I am Area l 5 Director of the Maryland Charter Boat Association, a Calvert 6 County resident, Chesapeake Beach. I have been running a 7 boat cn1 the bay for over 22 years. I talk to a lot of 8 people, lot of my fellow captains and so forth. All they 9 can say is they have seen improvements in our area since the 10 plant has been here.

11 At night when the plant is lit up, it is like a 12 light, bright beacon on the bay. It is really pretty.

13 Sometimes you think it is a cruise ship coming up and down 14 the bay if you look at it. So, just -- my basic comment is  !

15 don't extinguish the beacon on the bay for us. Thank you, i 16 [ Applause.] l 17 MR. CAMERON: Okay. Thanks, Captain Mogel. How 18 about Gerald Clark?

19 MR. CLARK: Good afternoon, my name is Gerald 20 Clark, and I am the President of the Solomons Island 21 Business Association, and I am sitting here today, and I 22 guess maybe I am one of the most unbiased people sitting in 23 the room because I don't work for the government, I don't 24 work for BG&E, I don't work for any association that has any 25 agenda towards nuclear power or nuclear waste or any other u

117 l 1 thing.

2 All I can tell you is BG&E and the business 3 community of Solomons have a marriage. We trust BG&E. But 4 one thing we always want to do is verify, and these folks 1

5 over here, their job is to verify what BG&E tells us. This l 6 report tells us what we already knew, these folks did it, 7 Okay. We don't -- our agenda is to live here, have a good l

8 quality of life. We like BG&E, that is our lifeline.

9 Anything short of relicensing this plant, from l 1

l 10 what you have here, unless you can show me something else -- l 11 I am not an educated person, I am just a high school l 12 graduate, I don't have a big degree, I don't know all the 13 technicalities, but I can tell you one thing, from what you 14 got in here, there is nothing to say no to. I mean if there i

15 is something else you need to tell us, tell us, then we can l l

16 deal with it. But we like BG&E. We want BG&E. Leave our 17 power plant alone. Thank you.

l 18 { Applause.)

19 MR. CAMERON
Okay. Thanks, Mr. Clark. Angie 1

20 Howard.

21 MS. HOWARD: I will be very brief and give a l

l 22 written statement. I am Angie Howard. I am with the l 23 Nuclear Energy Institute, and I also live just north of here 1

24 in Anne Arundel County.

l 25 Nuclear power represents 20 percent of the l

l.

118 1 electricity in this county. It is the largest emission-free 2 source of power that we have available to today, and that we 3 have to look forward to the future as we strive in this 4 country, and in this state to meet our clean air goals, the 5 future clean air goals, both from the standpoint of 6 greenhouse gas emissions and carbon.  ;

7 My written statement talks about the public 8 process that the NRC has put into place from the beginning l 9 and the development of a relicensing rule and the important 10 role that the public throughout this county, as well as

11 generically in the DC area, has provided to make this l

l 12 process better. Relicensing of nuclear plants is important 13 to our country. While BG&E may be the first to go through 14 the process, it is certainly not the last. There are quite 15 a number of other plants that are moving forward in their 16 planning processes. So it is important to, certainly, the 17 State of Maryland, and in Calvert County, as we have heard 1

18 today. It is important to our country. Thank you.

19- MR. CAMERON: Thank you, Angie.

20 Thomas Allhoff.

21 MR. ALLHOFF: Good afternoon. My name is Thomas l

22 Allhoff. I'm here today representing two organizations, the 23 first being the Responsible Growth Alliance, which is a j l 24 group of 30 builders, developers, engineers, and suppliers l

l 25 who have served in Calvert County in excess of 30 years.

l l

119 1 The second group that I'll be speaking towards or for is 2 SMBIA, Southern Maryland Building Industry. We will be 3 speaking again this evening, if we can last through the 4 presentation again.

5 [ Laughter.]

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6 As a point of reference, our members have had the 7 opportunity to review the GEIS report. We have made 8 numerous visits, site visits, to Calvert Cliffs. We visited 9 both the reactor complex itself, the spent-fuel storage 10 facility, and a number of members have also made a trip out 11 to Nevada to look at the proposed site at Yucca Mountain.

12 On a personal note, my background prior to working 33 with the building industry was 24 years with the United

)

14 States Navy as a naval officer trained, certified, and 15 ultimately qualified in using and working with nuclear 1

I 16 materials.

17 I'm also a resident of Calvert County, having 18 built three homes here. The first was in Chesapeake Beach. 1 l

19 The second was in Huntingtown. The third, two years ago, 20 being built in Saint Leonard, two miles from the Unit 1 21 reactor. So I'm getting closer to the powerplant than 22 further away.

23 The building industry in Calvert County is a very 24 unique industry when compared on a national level. The 25 builders in Calvert County live here. We work here. We're 1 l

1 l

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120 1 part of the community, part of the organizations. We do not 2 have a large influx of national builders, as many of our 3~ sister counties have.

4' Our businesses thrive in Calvert County because 5 we're involved in Calvert County. BG&E has been a superb 6 corporate neighbor. The GEIS draft report only confirms our 7 feelings that BG&E has professionally addressed the way they 8 work, the way they address environmental issues, as well as 9 the technical issues associated with the proper maintenance 10 and running of a nuclear powerplant.

11 We're builders. We're not nuclear scientists, 12 we're not environmentalists, and we're probably not 13 qualified to comment on the GEIS report other than to say 14 that all the questions that have been addressed in the GEIS 15 report appear to us to have been addressed properly and 16 satisfactorily across the board.

17 As business people we serve on boards, 18 commissions, committees, and panels throughout the year, and 19 BG&E employees are invariably part of that working group.

20 BG&E through its employees has demonstrated a very high 21 degree of professionalism in every task undertaken. It is 22 reasonable to us to assume that the professional thinking, 23 logical actions, and thoughtful implementation outside of 24 the plant are commonplace within the gated security of the 25 plant.

121 1 The GEIS report addresses very specific 2 environmental concerns. These concerns are there because of 3 past experiences throughout our country. As we read and 4 interpret the GEIS Calvert County -- Calvert Cliffs report, 5 we believe that Calvert Cliffs has done an exceptional job 6 in addressing all the issues associated with such a detailed 7 review process. We also appreciate very much the open forum 8 that the NRC has provided us. It is important that public 9 comment be heard, but we would ask that you please give 10 greater weight to the comments you hear from local groups 11 and individual residents.

12 We are deeply concerned with those interlopers who 13 have followed the ambulance call of nuclear relicensing into 14 our county. They continue to refer to Calvert County as a 15 possible nuclear waste dump. They continue to denigrate 16 Calvert Cliffs and its people, not to mention the 17 contributions to this county. We take great exception to 18 that.

19 We have seen the information on our Government's 20 commitment to the nuclear industry, and we fully expect the 21 Department of Energy and our Congress to fill their 22 commitment to authorize a permanent repository for spent 23 fuel. The housing industry as we fall under the 24 socioeconomic category is very market-sensitive in Calvert 25 County. In our case the buyers pretty much control

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l 122 1 everything. The biggest thing they control is site 2 selection. They choose to come here. They know the 3 powerplant's here. They choose to buy here.

4 We have seen as an industry no decline in housing 5 starts attributable to the presence of Calvert Cliffs, its 6 maintenance, location, or its continued operation. To date 7 we have had no lender, bank, or mortgage company express any 8 reservations with Calvert Cliffs prior to their lending 9 money for the purchase of buying new land or new housing.

10 Rule of thumb, if the banks don't have a problem with it, 11 you're doing something right.

12 [ Laughter.]

13 ' l The purchase of a sister reactor to perform 14 I real-time testing while the rest of the industry performs 15 P.heoretical testing is just one reason we are so comfortable 16 wit.h BG&E. They have demonstrated a very proactive approach 17 to nuclear power generation.

18 Calvert Cliffs has addressed environmental, 19 technical, maintenance, facility, emergency response, and 20 security concerns of the citizens of this county with prompt 21 and professional responses. The nuclear issue is a complex 22 one. The only way a community can feel at ease is if the 23 operating company is professional, honest, and direct with 24 the issues that arise through operation. BG&E has been all 25 of these things and more. The industry as a whole is a good

123 1 one. We just happen to feel that BG&E through its employees 2 is better than the average power provider.

3 There is no insurance against human error, but if 4 you look at the 13 areas addressed by the GEIS report, they 5 show a clear pattern of thoughtful and professional 6 responses to environmental issues. There are no guarantees 7 that things in the future will be as they have in the past, 8 but the alternative power sources and the impact they would 9 have on our county are far less desirable and more damaging l

10 to our environmental status.

11 BG&E, its employees, and local NRC personnel 12 continually go the extra mile to make Calvert Cliffs a safe, 13 environmentally friendly, and sustainable asset to our 14 community. We ask that you look favorably on the issuance 15 of a license to continue plant operation within our county.

16 As I stated before, we are local business people, 17 and if we thought for a minute that the relicensing of i

18 Calvert Cliffs would do anything to diminish our business l

19 climate or our community in general, we would not be here 20 today speaking in their behalf. Calvert Cliffs has 21 demonstrated its ability to be an asset to this community, 22 an asset we look forward to having around for a long time to I 23 come.

24 The only last comment I would make, not trying to  :

25 be overly critical, is dealing with slide 41. You listed

124 I

1 the addition of 60 new families as a negative impact on this 2 county.

l 3- [ Laughter.]

l 4 I would suggest to you, aside from us building our 5 houses --

6 [ Laughter.]

7 I would suggest to you that if these folks are of 8 the same caliber and quality of the present Calvert Cliffs 9 employees, they will be a definite asset and a positive 10 addition to this community.

11 Thank you for the opportunity to comment.

12 (Applause.]

13 MR. CAMERON: Thank you, Mr. Allhoff.

14 Dr. Rockwell. I know you've been patient out 15 there.

l 16 DR. ROCKWELL: Like the previous speaker, but I 17 unlike a lot of people here, I guess, I'm one who pays his 18 own way here. I'm not working for anybody else.

j 19 I'm representing the American Nuclear Society, and I 20 I have a written statement which was prepared by the i

21. American Nuclear Society which I want to put into the 22 record, and I won't try to read it to you. But it concerns 23 the environmental --

24 MR. CAMERON: We'll make sure all these statements  !

4 25 get into the record, so please provide us with them.

125 1 DR. ROCKWELL: There are some more copies of that 2 in the back, if you like.

l 3- MR. CAMERON: Okay. Thank you.

4 DR. ROCKWELL: But I just want to urge a couple of 5 things. One, when we talk about the danger to life and 6 health, first of all, you have to look at the facts, as Dr.

7 Rogers, was it, just gave us. The idea that somebody down 8 the road isn't feeling well and the doctor doesn't know 9 s, at's the matter with her, and so therefore it must be the 10 nuclear plant, is not a very good way to judge hazards. And 11 when you go in and you have these health departments who 12 have no interest in the nuclear industry but are only 13 interested in protecting the health of the citizens, and 14 they do an analysis of what the situation is, that's 15 something you can depend on.

16 If you don't want to depend on that, then just 17 look at the record. You worry about how often a meltdown is 18 going to occur. We've had over 100 nuclear powerplants 19 operating in this country, some of them more than 40 years.

20 In addition to that there are 220 nuclear powerplants that

-- 21 have been built by the Navy and operated by sailors, and in 22 all of these cases, nobody has ever been hurt. A whole 23 generation, 40 years, and nobody has ever been hurt.

24 We've got people, just this last couple of weeks 25 we've seen a solar plant explode, they had the hot fluid, 1

126 l 1 organic fluid with the heat transfer, blew up, we've seen 2 gas plants explode, we've seen fire from oil -- these are 3 real people getting killed by real accidents, and yet you 4 look at the story, nuclear waste, this dreadful problem of l 5 nuclear waste. Nobody has ever been hurt by nuclear waste, 6 and nobody ever will.

l 7 The only difference between a radioactive toxin 8 and a nonradioactive toxin is that a radioactive toxin 9 slowly dies out and becomes less toxic. But if you take the 10 toxins like bromine and -- look in your vitamin pills, for 11 instance, and you'll see in your vitamin pills there is i

12 boron, there is manganese, there is even selenium. These 13 things are in there because small quantities of these are 14 essential to human life. And'the same thing is true of l

15 radiation. Experiments have been done in which the natural 16 radioactivity of the body, which is mostly from natural 17 potassium, has been removed from mice, and they've been fed l

18 isotopically controlled potassium. They get sick and die.

19 It would be anomalous and it would be astonishing 20 if nuclear radiation did not act the same way as all other 21 toxins, because what they do in small quantities is that l 22 they stimulate the body's defenses, and it's like any other 23 thing, whether you're talking about a influence shot or 24 anything else, small quantities stimulate the body's 25 defenses. There's a study on that, a national study that's

127 1 going to be out this fall. It's already been done with 2 every-kind of toxin you can think of, and it's now 3 specifically looking at radiation and finding that it's 4 following'the same line, which you'd expect.

5 But the point I want to make is that we know what l 6 happens when a nuclear reactor melts down. It happened at 7 Three Mile Island. And we did get the initiation of'the )

)

8 China Syndrome, tons of molten fuel slumped to the bottom of l 9 the reactor, sat there, and that's supposed to be the start 10 of the China Syndrome. My company went in, sampled the 11 pressure vessel to see how deep it had penetrated, how far 12 toward China it had progressed -- a small fraction of an 13 inch.

14 So we know -- so that when someone makes a 15 statement about a location 40 miles away being endangered by 16 a nuclear accident, that's an irresponsible statement.

17- -There is no way you could make that happen. If you paid 18 people to do it, you couldn't produce that kind of an 19 effect.

20 So I just urge that when you look at these things, 21 you fall back. When people talk about nuclear waste being 22 the big hazard, who's been hurt? Nobody. How could they be 23 hurt? I urge you not to go out and eat nuclear waste, but 24 .other than that --

25 [ Laughter.)

1 4

J

l 1

128

'l You're not. going to get hurt. It's as simple as 2 that.

3 [ Applause.]

4' MR. CAMERON: I guess that's the tip of the day, 5 right, don't go out and eat nuclear waste.

l 6 [ Laughter.]

7 Donald Graf.

8 MR. GRAF: I'm Donald Graf, and I'm a resident of l 9 Calvert County. And after some of the other speakers we've 10 had up here today-and how they spoke, it would be

! 11 anything -- to attempt that would be really silly on my l

l 12 part, but I do want to speak as a resident.

13 I've been a resident here for many years, and I 14 intend to live out the rest of my years in retirement here.

15 I boat on the bay, I go down to the water, my grandchildren 16 'are here, and I feel very, very comfortable about what 17' they're doing. I'm also very concerned about the 18 environment, just as an individual. Nobody else. And I 19 ' live here.

20 I want to thank you for the opportunity to be able 21 to talk about matters of this nature. I've read the report.

22 I've read it pretty thoroughly. And I'm pretty impressed as 23 an individual about the depth and the thoroughness of which l 24 these people'have gone to determine safety for us that live i 25 here. Therefore, I feel very confident in accepting their l

l l

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129 1 conclusions and thoroughly feel safe in the extension of the 2 license of this plant.

l 3 I think we must have adequate power to maintain 1

4 our lifestyle, because this addresses the alternative.

-5 Nuclear is clearly the most clean way of doing it, and l 6 frankly I don't know how we as a country can possibly meet 7 the environmental release promises that were made by this 8 country if we don't continue nuclear power. I also look at 9 the global warming effects, and don't have any idea how we 10 can keep the power in our way of life unless we keep nuclear 11 power around.

12 I also do take some umbrage with outsiders who 13 come into our community and to propose furthering their own 14 misguided agenda, because I really believe it is misguided.

! 15 I respect the right of everyone to speak. Free speech in l

16 this country is pretty important. But I don't believe that 17 right to abuse that right by taking on other agendas should 18 take our time here this afternoon.

19 Now we have 20 years of experience in the 20 operation of this plant. This is not just a "what if" or j l

21 theoretical discussion, but we've heard an awful lot today -

j l 22 of the data that has been generated through this 20 years of 23 life of a plant, and I see no reason to expect our very 1 l

l 24 satisfactory experience has any reason to change. So I as a  !

25 citizen truly ask you and request that you give approval to

130 1 this application for extension for 20 years. And thank you 2 again for your time,' sir.

3 MR. CAMERON: Thank you.

4 [ Applause.]

5 How about Carolyn. Carolyn McHugh.

6 MS. McHUGH: I'd like to thank the NRC for having 7 the public meeting. I am Carolyn McHugh. I'm the executive 8 director of the Calvert County Chamber of Commerce. I am 9 here today to speak to a very specific area of our 10 environment, and that's the economic environment of Calvert 11 County.

12 I'm here today to speak on behalf of nearly 3,000 l 13 businesses in Calvert. The nuclear powerplant is just one 14 of those businesses, but it's an important business. There 15 are very few large employers in the tri-county area, and 16 specifically in Calvert. And of the 3,000 businesses in 17 Calvert, only 1,500 of them employ less than five employees.

18 They're not small businesses, folks, these are 19 microbusinesses. And they all depend in some degree on the 20 nuclear powerplant.

21 BG&E contracts locally for many of the services 22 that it uses to operate its daily operations. On any given ,

23 day, local businesses are contracted for rental of 24 equipment, for temporary staffing services, carpentry, 25 electricians,. plumbers, architectural engineering services,

1 h

131 1 fire suppression systems, landscaping, snow removal,

2. underground piping systems, for well water and for sewer 3 systems, for roofing repair, for roofing replacement, and 4 for HVAC systems. l 1

5 BG&E doesn't just stop at considering local l 6 businesses for contracts. Its procurement officers go out i

7 actively into our business community and give seminars to l 8 local businesses on how to get on the vendors list. Last l

l 9 year BG&E contracted for an estimated 1 to 2 million dollars t

10 of local businesses and contracts in the tri-county area.

11 Now that's the contracting dollar side of the l

12 equation. There's another. You've heard that BG&E is the 13 largest private employer in southern Maryland, that it 14 employs 1,500 employees, and that over 1,100 of those live 15 in Calvert County and that they bring $59 million of wages 16 to our county.

17 Now it's easy to paint with a broad brush and say l 18 that those payroll dollars stay locally, and in some way 19 affect virtually every business in Calvert, and it does.

20 But the significance of how those wages impact local 21 businesses and other organizations becomes much more 22 apparent and much more personal if you consider what I refer l- 23 to as the flight of the BG&E dollar.

24 Consider if you will this small scenario. BG&E I

25 pays an employee. The employee deposits that check in a i

l

132 1 local bank. Later the employee withdraws the money to buy 2 produce at a local farm stand. The farmer pays his local 3 co-op bill. The electric co-op pays an Internet provider.

4 The Internet provider buys a dinner someplace. The 5 restaurant owner pays an accountant, and the accountant buys 6 flowers for his wife for an anniversary. The florist pays 7 an attorney. And on Sunday, the attorney drops money into a 8 local collection plate at a church. On Monday, the church j 9 puts the money back in a bank. Our attorneys and our i 10 Chamber of Commerce do.

11 [ Laughter.]

12 And the cycle begins again.

13 Now that scenario may have made you laugh and it 14 may have brought to mind the nursery rhyme that makes us all 15 smile as children -- the butcher, the baker, and the 16 chndlestick maker. But I can assure you, ladies and 1 17 gentlemen, that if Calvert County, the smallest county in 18 Maryland, loses 1 to 2 million dollars in contracting 19 dollars, if it loses $59 million in employment wages, then 20 the citizens and the businesses in this county will not be j 21 smiling. Calvert Cliffs is a good neighbor for everyone in 22 Calvert. To the businesses it's more than that, it's a 23 lifeline. On behalf of all those businesses, I urge you to 24 grant the relicensing request of Calvert Cliffs.

25 Thank you for your time.

133 1 MR. CAMERON: I am trying to get to the people --

2 we have a few more to go. I am sorry we are running late 3 but we are going to stay so that we can hear all of you, 4 trying to go to the people who have not spoken as of yet, 5 but we have other people signed up.

6 Let's break the chain a little bit here and go to 7 Jim Riccio. Jim?

8 MR. RICCIO: Thanks, Chip. Again, I am Jim I 9 Riccio. I am the staff attorney with Public Citizen, and I I

10 guess I am the interloper you all are referring to. I 11 If you take a look at page 2-42 it has a nice I

12 little map of the area and an outlay cf basically what is '

13 known as the -- I used to know it as the plume exposure 14 pathway. Basically it is the pathway that you could possibly 15 ingest radionuclides in the event of an accident.

16 If you notice, that includes Washington, so if I 17 am an interloper, I am a little far from home, I still have 18 concerns about this reactor. What I have more concerns 19 about is the fact that the process the NRC has set up is 20 illegitimate. They had a substantive review process, but 21 that resulted in the shutting down of a nuclear power plant l 22 and the industry found that to be unacceptable. They had 23 too much invested in this reactor and too much invested in 24 your communities to see someone like the NRC take that away.

25 Now when I was here about six months ago I said

l 134 1 that the only green issues that were being dealt with here 2 were dollar bills, and again that seems to be the case.

3 What I came here today to address were the severe accident 4 mitigation alternatives, the ways you can make this reactor 5 safer.

6 Unfortunately I have been informed that we are not i 7 going to address all of those under this renewal process.

8 We are going to wait until period down the road to address 9 these alternatives, basically things like making sure that 10 your batteries are up to snuff.

11 Now you all had Daylight Savings Time here a few 12 days ago, and the fire departments always take that 13 opportunity to remind you to change the batteries in your 14 smoke detectors. Well, one of the things that this report, l 15 which is pretty substantive, talks about, is enhancing the 16 batteries at the nuclear power plant -- something a little 17 bit more important than your smoke detector.

18 They are not going to do that now. They are going 19 to say because it doesn't have to do with aging -- now they l 20 also said there may not be better batteries out there. I 21 can't believe that is the case.

22 There was a process. The process has been 23 neutered _by the nuclear industry and so basically a lot of 24 the safety issues that were addressed up at Yankee Rowe in 25 Massachusetts aren't being addressed down here. I don't

135 1 think that is appropriate. I don't think it is right.

2 I don't think the fact that there are other safety 3 alternatives that aren't being addressed in this report 4 until further down the road -- I don't think that is right 5 either. While it is important for you all to know that 6 obviously BG&E pays a lot of your salaries and provides a 7 very high standard of living for the people of this country, 8 but an accident is possible and to ignore those risks is 9 irresponsible. I would hope that in the future and further 10 down the road I can work with the people at NRC to ensure 11 that those risks that aren't being addressed in this 12 document are addressed before this reactor operates much 13 further.

14 One thing you should acknowledge too is that at 15 some point this reactor will shut down and you are going to 16 have to find other jobs and other ways of making a living 17 and turning a profit here.

18 This county existed long before Calvert Cliffs was 19 splitting atoms and it is going to exist long after it does, 20 hopefully, and so as responsible individuals in your 21 community, look down the road and realize that at some point 22 this reactor will shut down and that you are going to have 23 to make some tough business decisions, and so start moving 24 towards that now because even though they are extending the 25 license 20 years, no reactor has operated for 40 years in i

136 1 the United States. None.

2 More reactors are shutting down than are being 3 relicensed, and so to look into your future and say that you 4 can expect the largesse of BG&E to support this county is 5 short-sighted.

6 Now you can call us environmentalists and you can 1

7 say that we are interlopers but we do that because we have a {

1 8 belief that you are not being told the truth here, and that 9 is not just based on hearsay. I wrote a report on that rule 10 back in '94. I was going to intervene in the process. As a 11 matterlof fact I have been catching grief from the press 12 that I am not intervening in the process. The reason I am 1

13 not intervening in the process is because the process is a 14 farce. It is a rubber stamp and unfortunately it does a l

15 disservice to the people at BG&E, who put a lot of. effort 16 in, because their plant may have been able to get through 17 the original process.

18 It may have been able to prove that it should 19 operate beyond its license life, but unfortunately NRC is 20 not making that determination. They are saying it has 21 operated so far -- it will operate into the future -- don't 22 worry about it.

23 The people of Chernobyl probably thought the same 24 thing. Up until the day they melted the reactor down or I 25 guess they exploded it as well, they felt their level of I

i u

137 1 safety was adequate. It turned out not to be. After 28 2 shuttle flights NASA thought that their level of safety was 3 adequate. It turned out not to be.

4 After twenty-something years of operation here at 5 Calvert' Cliffs, BG&E and the NRC think that the level of 6 safety here is adequate. It may not be and there are at 7 least a few things in this report that you can do to improve 8 the safety of this reactor and since they are going to be 9 dipping into your pockets for millions of dollars for 10 stranded cost recovery, the least they can do is make a few 11 safety improvements at this plant.

12 Thank you for your time and your consideration of 13 my comments.

14 [ Applause.)

15 MR. CAMERON: Thank you. How about David Jenkins?

16 MR. JENKINS: Good afternoon and thank you. For 17 the record my name is David Jenkins. I am the Executive )

18 Director of the Tri-County Council for Southern Maryland.

19 We are the regional planning agency for St. Mary's, Calvert, 20 and Charles County. Our membership consists of all the 21 elected officials of Southern Maryland. That is, all the 22 County Commissioners, our House of Delegate members, and our 23- State Senators. That is 29 members.

24 I am here to support on behalf of the Council the j 25 licensing effort for BG&E at Calvert Cliffs. Our agency was l

138 1 created by state law in 1963 and we are responsible for a 2 variety of aspects in Southern Maryland regarding 3 environmental planning, transportation planning and we are 4 also involved with the regional economic development 5 - activity here in Southern Maryland.

6 I won't go through what some previous speakers 7 have indicated regarding BG&E's employees, their payroll and 8 their contribution to the area, but I would be remiss if not 9 -

saying that they have contributed very greatly to the 10 Southern Maryland region as well as to the Tri-County 11 Council by the contribution of John Smith and Jim Lamons 12 - have been very instrumental in working with the Council over 13 a number of years.

14 The importance of this facility with respect to 15 l both the environmental aspects as well as the economic 16 aspects has been recognized in the Council's draft plan for I-17 the future growth and development of Southern Maryland that 18 was issued in draft form in this very room in December of I

19 1998. It has been recognized that the plant along with its 20  ; employees of engineers and other technicians have 21 contributed greatly to the economic engine here in Southern 22 Maryland and probably we will continue to do so in the 23 i future and will allow additional technology transfer to 24 other opportunities here in Southern Maryland.

25 Again I want to re-emphasize the corporate

l l 139 l 1 contributions that BG&E has made to Southern Maryland. I l

2 live in Charles County and I have a lot of neighbors who 1

3 work here at the plant itself and on a personal note in my 4 previous experience in a previous life I had the experience 5 to work on various environmental projects and am somewhat l 6 familiar with the NEPA process.

7 Having reviewed the draft document and knowing the 8 complexity of this facility and how it has operated over the 9 years, it is in my opinion a very thorough job of analyzing 10 and identifying the issues that need to be addressed, so I 11 would applaud the NRC and BG&E for doing that.

12 So in conclusion, again we want to offer our 13 support for the effort to renew this license. Thank you for 14 the opportunity to be here tonight. Thank you.

15 MR. CAMERON: Thanks, David.

16 (Applause.)

17 MR. CAMERON: Paul Gunter.

18 MR. GUNTER: Thank you. My name is Paul Gunter.

19 I am Director of the Reactor Watchdog Project with Nuclear 20 Information and Resource Service in Washington, D.C. I have 21 been involved with this issue for about 25 years, originally 22 started over at Seabrook, New Hampshire, where we saw an NRC 23 licensing process basically roll over a community vote to 24 stop a construction project of the Seabrook Nuclear Power 25 Station, so I believe the. door obviously does swing both l

l I

I

[--

f 140 1 ways, and certainly I am here to also say that I am proud to 2 be an agent for communities that refuse to receive nuclear 3 waste from facilities like yours.

4 We were active in stopping the opening of the i 5 Sierra Blanca, Texas nuclear low level radioactive waste 1

l 6 site, predominantly a Hispanic community, $7000 annual 7 income per capita. It also happened to be located over an 8 earthquake fault which both industry and NRC and a large 9 degree of Texas government continued to overlook, but 10 eventually these issues prevailed and the Sierra Blanca site 11 was not opened, and I am happy to say that the same trend is 12 working along the lines in Ward Valley, California, another 13 site that -- a would-be recipient of radioactive waste 14 generated at nuclear power stations.

15 I am also proud to say that we do work with 16 communities that are concerned about the tracking of dry 17 casks that store high level radioactive waste, and it is a 18 concern of ours that there is a degradation on site storage 19 of high level radioactive waste.

20- We also work with the citizens of Nevada to stop 21 the transport and burial of 70,000 metric tons of irradiated 22 fuel generated at facilities like Calvert Cliffs at a site i

23 that has 28 earthquake faults and some of the youngest j 24 volcanos in North America and these are all part of our I 25 agenda to stop the mismanagement of high level radioactive  !

141 1 waste and low level radioactive waste, and certainly it is l

2 part of our agenda also that the first responsible in

.3 dealing with the radioactive waste problem is to put a cap 4 on the amount that is being generated and mismanaged and to 5 put a cap not only on the volume but the curie count that 6 will remain a persistent toxin in this environment long 7 after jobs are lost, long after one watt of electricity is 8 no longer received from these facilities, but the entire l 9 liability of radioactive waste generation will be passed I

10 along to a society that will receive absolutely no benefit.

11 But what I am really here to talk about is the l

12 concerns with this whole process and that the NRC has 13 determined this whole issue of no new information as a way 14 of cancelling out issues to be dealt with in license renewal 15 and I think is it absolutely absurd and irresponsible that I 16 have to stand here and say that this agency has taken off 17 the table the issue of continued generation of high level 18 radioactive waste with a policy that has been bankrupt for 19 50 years in terms of shuttling the waste around within the 20 fuel pools, exceeding design capacities now four or five 21 times in some sites, shuttling it off into dry casks that 22 have 20 year license periods for waste that will persist for 23 millions of years in geological spans of time simply to 24 continue operation, and this licensing process that we are 25 facing right now we believe to be an environmental justice

142 1 issue.

2 That is why we come to your community. It is not 3 to basically just to address the issues of your plant but 4 that the operation and continued operation of this facility 5 will not only impact communities outside of your own special 6 interest but will persist into an environment that spans 7 geological time, and I think for us not to deal with those 8 issues here and now is absolutely irresponsible.

9 The other thing is that the routine operation of 10 the Calvert Cliffs by NRC documentation has put about 11 150,000 curies of radiation into the environment. Now that 12 may seem like an insignificant and small number, but I think l l

13 that what I want to close on is that routine omissions with 14 bioaccumulation, biomagnification, persistent toxin and no j 15 safe threshold for radiation -- now this is an obvious topic 16 of controversy but I think the challenge that NRC has is to 17 produce the studies that show safe thresholds and to produce 18 those in and include them in the GEIS.

19 You know, it's like that would be a measure of 20 showing your confidence in the continued operation and the 21 continued release of these persistent toxins is something  ;

I 22 that can be permitted and allowed, but in fact to counter 23 some of the earlier issues, there are studies that show that 24 routine emissions, chronic low dose exposure has a 25 deleterious effect and you can go to the Massachusetts

r 143 1 Department of Public Health, which has no agenda, no 2 anti-nuclear agenda, but by their own published study in 3 October of 1990 it showed a 400 percent increase in adult 4 leukemia and they, the MDPH, directly attributed that

.5 increase to both the duration that the resident was to the 6 Pilgrim Nuclear Power Station and five contiguous 7 communities in a 25-community study area, but both their 8 duration and their proximity, so there are studies both 9 sides, but I think that that produces enough evidence to

.10 show that it should be a Category 2 issue and not shuttled 11 off into this category where it will not be addressed in the 12 proceeding. Thanks.

13 (Applause.]

14 MR. CAMERON: Thank you, Paul. Christopher 15 Reynolds -- we finally got you up there.

16 MR. REYNOLDS: The grouch.

17 MR. CAMERON: The grouch is here -- and we just 18 have a couple more including Barth Doroshuk from BG&E. I'm 19 sorry, go ahead, Chris.

20 MR. REYNOLDS: That's all right. I will try to 21 keep it very short. I don't want to repeat the comments 22 that were made before.

23 My name is Chris Reynolds. I am a resident of 24 Calvert County, as I told you before. I am an attorney here 25 and I am also Chairman of the Economic Development l

t i

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144 1 Commission here in Calvert County and Vice President and a 2 member of the Board of Directors of the Chamber of 3 Commerce -- so I am coming at this thing in a number of 4 different ways. Let me just -- from a standpoint of being 5 an individual resident of this county, with all respect to 6 you, Mr. Riccio, you do have a vested interest. This is 40 7 mile away neighbor of mine. My back yard is two miles and 8 that doesn't mean I have a greater right to speak about this 9 thing, but I do have a concern, a direct interest.

10 I can tell you I have read this report and I read 11 it as carefully as I could. I am not a scientist and I 12 can't tell you, I can't draw the conclusions as an expert 13 that have been drawn in this report, but I will tell you 14 that I think it is quite inclusive, it is exhaustive and I 15 can tell you I sit out in my back yard and I watch the 16 osprey and I see.with some frequency bald eagles. I fish 17 those waters by the plant. I eat the blue crab. God 18 willing, I am still alive here.

19 What I see and what I taste and what I feel tells  !

20 me that BG&E is a good neighbor and I think they deserve 21 relicensing. ,

i 22 As a representative of the business community, I 23 can tell you that BG&E, as you have heard before, provides 24 sustenance to this county. We rely on it. We need it and i 25 in addition to being a good economic partner with the county 1

1 I

165 1 their employees and representative do participate in a wide 2 variety of local institutions, fraternal and other, civic, 3 and like organizations. They are really a partner and a i 4 good partner and a good neighbor and we want them here for 5 another 20 years after 2013 and 2016.  !

6 Let me just address a couple of points, and first 7 of all, I want to say this is a welcoming community.

t 1

8 Calvert County is a wonderful, wonderful place. We are j 9 delighted to have you all here and we are delighted to have 10 you all here too, and I do appreciate the depth of your l l

11 feeling and the intelligence and emphasis that you bring to I

)

12 the process. I think it is good. We don't have to agree 13 with it, but we think it is good.

1

-14 I don't want you to think you are interlopers, 15 okay? We welcome your comments. We are welcoming. We are 16 an open community, so don't feel that you are not welcome 17 here, but there are a couple of things I did want to addr_ess 18 what you, Mr. Riccio, said, and then I'll leave, okay?

19 First, you said that we have to prepare for the 20 plant's shutdown, and you are right. There is no question 21 about it. Because of the economic constraints that this 22 county is facing now, it is the fastest growing county in 23 the state of Maryland with the lowest economic and 24 commercial tax base, and we literally -- I can't say we will l

25 go belly-up -- but things are going to be mighty tough  !

1 i

166 1 without Calvert Cliffs.

2 By the same token I don't want you to think that 3 we are just interested in getting the green, the dollars, 4 okay? Yes, I am worried about my health and I am worried 5 about the health of my wife and my child and even my dog --

6 these things concern me. I have a feeling of trust. I 7 think this report is quite inclusive and~there may be some 8 other issues that are addressed in another context but I 9 have good faith that my good neighbor, BG&E, is looking 10 after us, and I think the NRC'is doing a very, very good job 11 and affiliated organizations with studying all of the issues 12 that affect our lives, economic and existence.

13 The final point I would like to make is this. You 14 pointed to two tragic circumstances, Chernobyl was one and 15 the space shuttle disaster was another and there is not 16 question about those being terrible incidents and should all 17 give us pause, but life is a risk and as soon as our feet 18 hit the ground when we get out of bed it's a risk.

19 Lindbergh -- what would happen if he said I don't 20 know that I can make it, so he didn't go? What if John 21 Glenn says I am afraid I won't get back, I better not go?

22 And just to bring it maybe even to a more ridiculous level, 23 what if Mark McGwire said, well, the hell with it, I am 24 never going to break Babe Ruth's record -- but he did it.

25 We have to take some risks. They have to be measured. We

l l 147 l

l 1 have to assess our chances, but risk is a part of life.

i 2 Thank you all very much.

l l 3 MR. CAMERON: Thank you, Mr. Reynolds. Thank you.

4 David. Dave, did you want to say anything more? Robin, do j 5 you want to say something up here?

6 MR. MILLS: Hi, my name is Robin Mills. How are 7 you today? I am Director, recently -- just became recently 8 Director of the Maryland Safe Energy Coalition, and we are 9 very concerned and involved in this process.

10 I would like to ask everybody here if you would 11 work with me to_ conduct a small experiment. Can I ask 12 everybody in the room to please stand up, please? Just -- I I

13 it will be easy to do. Just please stand up, just for a I 14 minute.

15 Now, I wanted to ask those people who work for the 16 government, including NRC, to please have a seat. And those 17 people who work for BG&E or subcontractors of BG&E to please 18 have a seat. And those people who work for state and local 19 government agencies to please have a seat. I wanted to see 20 who was remaining standing, obviously. So I see that we 21 have quite a few people from professional agencies, 22 professional nuclear organizations. Can I ask the members 23 of the professional nuclear organizations to please have a 24 seat, including NEARS and the American Nuclear Society and i

25 NEI?

t i

148 1 Who do we have left? Is this the public? I guess 2 so. Thank you very much. That was very brief. We had six 3 people standing at the end.

4 Risk is the point here. Certainly, this county 5 would benefit a lot from having this contract extended for 6 20-years. The question is, how do we assess what the risk 7 of those additional 20 years is, and is that additional risk 8 worth the benefits? It is a value judgment.

9 There is a percentage chance that there will be a 10 severe accident, a very small percentage. And the benefits, 11 we know a little bit more about the benefits. The benefits 12 are going to be pretty big, the jobs, the income, the tax 13 base. And so it is a value judgment as to what the risks 14 and the benefits are.

15 On page 5-3 of this document, I tried to point out 16 earlier that BG&E tried to assess what the risk of a severe 17 accident would be. And I would like to go through those 18 figures just to make sure you all understand what the risk 19 is of a severe accident. And these are BG&E's figures on 20 5-3. They say 3.3 times 10 to the minus 4th, core damage 21 per reactor year, now that equals .00033, which is 33 per 22 100,000, which is 1 in 3,000, for 20 years, we multiply it 23 by 20 years. For two reactors, that means 1 chance in 75.

24 That is 1.3 percent chance that there will be a severe 25 accident that will damage the core. I want you to

169 1 understand that that is the risk, that 1 chance in 75 over 2 those 20 years that there will be a severe accident.

3- That is not a huge risk. But we have to 4 understand that despite Dr. Theodore Rockwell's statement

-5 that ne one has ever been hurt, that, in fact, Chernobyl did 6 hurt a lot of people, and it is still hurting people 7 throughout Ukraine, Bellarus, even Lapland. That hurt a lot 8 of people. And the risk of a major accident does exist, it 9 is not insignificant. So I think we have to face that 10 possibility and make value judgments.

11 In reducing that risk, BG&E has proposed on page 12 5-24 to replace a water-tight door. I think that is 13 inadequate. I think there are other things that could be 14 done and should be done to reduce that risk. This is an j 15 experiment, just like the experiment I had where I asked you 16 all to rise. This plant will operate longer than any 17 nuclear plant has ever operated anywhere on this planet, 18 period. Sixty years is more than any plant has ever 19 operated. So it is an experiment, this would be a first of 20 its kind. We don't exactly know all the mechanisms of what 21 will happen.

22 I would like to talk to you just a bit about some 23 study I have done on what the potential is for an accident.

24 This is an authoritative text, " Nuclear Reactor Engineering, 25 Reactor Design Basics," by Samuel Glastone and Alexander

150 1 Sozanski, 1994, a very authoritative text, and they talk 2 about the structural changes caused by neutron interactions, 3 in other words, neutron embrittlement.

4 Now, I keep looking through here, looking for them l 5 studying neutron embrittlement. I don't see a whole lot, 6 and I tried to bring it up as questions. But the bottom 7 line is that collisions by neutrons cause displacement 8 inside the metal lattice. The metal is like a crystal and 9 the neutrons zipping in there from the reactor cause atoms 10 to be knocked out of place, making the metal brittle, 11 because it has structural flaws inside the metal.

12 And these authors understand that. They say there 13 is the possibility that accident sequences leading to the 14 injection of emergency coolant water would result in 15 combinations of vessel temperatures with thermal and 16 pressure stresses that could lead to catastrophic vessel j 17 fracture. In other words, the reactor pressure vessel could i 18 crack and fall apart and there would be no way to cool the 19 core. And these authoritative authors recognize this as a 20 realistic possibility.

i 21 It is small, it is a very small chance that it i

22 might happen, but the chance that this might happen l 23 increases every year the' reactor operates, because there are l

l 24 more defects in the metal from neutron embrittlement. The l

l 25 temperature at which this happens increases year by year due

1 151 1 to defects in the metal.

)

2 He goes on to say, the feasibility of the lifetime

.3 extensive may indeed depend upon the non-ductile transition 4 temperature margin available. So, these authoritative 5 authors recognize this as being a critical point in license 6 extension. Yet, as I look through here, I don't see this as 7 being a major point. Authors in textbooks see it as a major 8 point. Why does not this become a major point in this 9 Environmental Impact Statement?

10 I think the risk of a severe accident is one of 11 the most severe consequences, environmental consequences, 12 that could occur, and I would like to see something done 13 about it. I receive stuff from the Nuclear Regulatory  !

i 14 Commission and I received this recently. It says down here, 15 more than one-third of the broken wires were shown to have 16 brittle fractures. This is the vertical tendons inside the 17 reactor building, containment building. One-third of the 18 broken wires were shown to have brittle fractures. This is 19 not expected, this is something unexpected that is occurring 20 inside Calvert Cliffs Nuclear Power Plant right now and it 1

21 is metal that has become brittle.  !

l 22 I could go on and on and on about this stuff. But 23 we just did an experiment -- or, actually, PECO just did an 24 experiment, I am a stockholder at PECO, and they did an i

25 experiment at Peach Bottom with Y2K. They turned the clocks l

l

)

i 152

{

1 forward to find out what would happen, and all the computers 2 crashed for seven hours. There were articles in the New 3 York Times and the Baltimore Sun and other places.

1 4 If power should fail and backup power fails, it is 5 a serious problem because the core can't be cooled, pumps l 6 don't operate. Cooling water is not sent to the spent fuel, 7 so the water boils off and the fuel melts, and disasters i

)

8 happen. Nuclear reactors need a consistent source of power, 1 9 and in a Y2K disaster situation or other possibilities, 10 there is the possibility of an accident. )

11 Jim talked about TMI, Chernobyl, Challenger, all 12 these accidents were said to be impossible. They said one 13 in a million before TMI. Now, they are talking about what, 1

1 14 one in a hundred? Before Challenger, one in a 100,000, now 1

15 it is one in 40, one in a hundred.

16 MR. CAMERON: Robin, n to have to ask you I am goi'g I 1

1 17 to -- J l

18 MR. MILLS: Okay. Well, I will write this down '

19 and I hope you read my comments. I can't afford full page 20 comments like BG&E can, but I went to a lot of expense and l

l 21 time and trouble to be here today, and I would like to 22 invite any local residents here to eat dinner with me this 23 evening and talk about it over dinner.

l l 24 MR. CAMERON: But no nuclear wastes, right?

l 25 [ Applause.] I l

l

153 1 MR. CAMERON: I am going to do an experiment. How 1

2 many people would like to stay here to 7:00 and join the 3 7:00 meeting? That's a joke. Sorry.

4 We have two more people, Kay Dellinger and then we 5 are going to go to Barth Doroshuk, and then we are done.

6 MS. DELLINGER: My name is Kay Dellinger, I am the 7 Legislative Coordinator of the Maryland Safe Energy 8 Coalition. Nuclear power, like nuclear weapons, is l 9 inherently evil. It is' evil from the beginning to the end.

10 It begins in uranium mines, and uranium mining leaves mine 11 tailings on the land and they get in the groundwater, and 12 they give horrible cancers to the miners and their families, 13 including children. And the end is nuclear waste in huge 14 amounts that remains radioactive and, therefore, dangerous 15 to every form of life for hundreds of thousands of years.

16 There is no safe way of disposing of this waste and no safe 17 place to put it, and no safe way of transporting it.

18 The terrible dangers of nuclear power from the 19 beginning to the end make it completely unsuitable for a 20 society to use to produce energy. The uranium miners who 21 die from cancer are people of color, primarily Native 22 Americans and these Native Americans are poor and powerless, 23 and they are nameless and faceless, and they die without 24 anyone in this country knowing or caring. Native Americans 25- revere nature and understand that the earth is our mother l

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154 1 and it is the earth that gives life to all of us.

2 . Human beings can never conquer nature. Human 3 beings are simply part of nature. We have become the most 4 destructive species that has ever been on this planet. We i

l 5 have caused tens of thousands of other life forms to become l 6 extinct and extinct is forever. The majority of our species l

l 7 has the absurd belief that human beings are superior to the 1

8 other species on this earth. In fact, we are not superior 1

L 9 to any species and our destructiveness makes us inferior to 10 other species.

11 Using nuclear power for energy is destructive and 12 it is unnecessary. This country can do the research and 13 development needed to produce efficient solar energy, wind 14 power and geothermal power. It can invest in conservation l 15 techniques and deploy them. Nuclear power plants are unsafo 16 and can have a major accident such as Three Mile Island had, 17 and this year is the 20th anniversary of Three Mile Island, 18 and such as Chernobyl had at any time.

19 The operating license for Calvert Cliffs should 20 not be extended and the Nuclear Regulatory Commission should 21 immediately develop a process to deny license extensions to 22 nuclear power plants. How can any license extension be 23 denied if there is no process in place to deny an extension? l 24 The Nuclear Regulatory Commission has given us 25 here the form of a public process without the substance of a I I l

L

155 1 public process. The NRC needs to immediately put into 2 effect a process to deny extensions of nuclear power plants.

3 Our country already has tons of nuclear waste from the 4 military and from commercial use, and it has no safe place 5 to put this radioactive waste.

6 The federal government just started putting 7 military nuclear waste in the waste isolation pilot plant in 8 New Mexico, even though New Mexico has not given the United 9 States a permit to do it. So much for states' rights. It 10 is a salt mine in New Mexico where they are putting this 11 waste, and if the federal government fills up the whole salt 12 mine in New Mexico with its nuclear waste, that salt mine 13 will only hold 2 percent of the military waste. There will ,

i 14 still be 98 percent left with no place to put it. )

15 The military and commercial use and production of 16 nuclear weapons and nuclear power must be permanently 17 stopped. It should be stopped beginning here and now by 18 denying Calvert Cliffs an extension on its license. Calvert 19 Cliffs must stop producing nuclear power. The NRC must make 20 it stop now.

21 MR. CAMERON: Okay. Thank you. We are going to 22 our last speaker, Barth Doroshuk from BG&E. Barth 23 MR. DOROSHUK: Well, good afternoon -- or good 24 evening. My name is Barth Doroshuk, and I am the Director 25 of the Life Cycle Management Project at Calvert Cliffs and I i

156 1 will bet you are wondering what I am going to say. I am 2 here to represent the Baltimore Gas & Electric Company at 3 the United States Nuclear Regulatory Commission meetings and 1 l

4 the purpose of these meetings is for the NRC to offer the 5 public another opportunity to participate in the relicensing 1

6 process at Calvert Cliffs. I 7 As we have heard, this particular opportunity it 8 to provide the NRC with any comments on the Supplement 9 Environmental Impact Statement for Calvert Cliffs. On 10 behalf of BGE and the Calvert Cliffs family of approximately 11 2,000 men and women who work at the plant, let me express my 12 thanks for the opportunity to make a statement regarding the 13 environmental impact of license renewal for Calvert Cliffs 14 Nuclear Power Plant.

15 Today I would like to discuss two subjects with 16 you, and then I will yield my remaining time to the other I l 17 speaker for BGE. First, I would like to discuss the 18 openness of the overall relicensing process, and, in 19 particular, that of Calvert Cliffs. And, recondly, I would )

20 like -- the second subject I would like to discuss are the 21 findings of the U.S. Nuclear Regulatory Commission regarding l

22 the environmental effects of relicensing. And, finally, I l 23 have arranged for Calvert Cliffs to make a few statements on 24 its own on behalf of itself relative to the surrounding  ;

25 environment -- we have gimmicks, too -- and its role in 1

F 157 1 Maryland and as a part of the BGE family.

2 There has been some interest today expressed in 3 i the public process of the relicensing of nuclear power 4 plants. Let me briefly describe how open the environmental 5 review has been, how many opportunities there have been for 6  ; public input. I want to do this by looking at the openness 7 of the overall regulatory process and how open our minds l 8 have been, about relicensing, to everyone. Then I want to 9 look at how open our door has been to everyone and tell you 10 about some of the people who have taken advantage of that 11 open door policy. And, finally, I will let you know, or I 12 will at least make you aware of our ongoing open invitation 13 .

to address your ideas, your questions, your concerns, or k 14 your suggestions.

I 15 Before our application was submitted, the NRC 16 :

conducted a five year public proceeding to prepare the 17 Generic Environmental Impact Statement on License Renewal.

18 The proceeding included public workshops, several 19 opportunities throughout those years to submit written 20 comments on the draft analysis that made up the GEIS, and, 1

21 finally, a formal rulemaking.

I 22 Then, in our proceeding, the NRC has conducted l 23 : scoping meetings, prepared a draft supplement looking at the 1

24 site-specific impacts of renewing the Calvert Cliffs 25 licenses. The NRC staff has looked at all the issues that l

l 1

l l

l l

158 1 were generically resolved in the GEIS. They have determined 2 that they remain valid for the Calvert Cliffs plant, and, in 3 addition, the staff has looked at the issues that were not 4 resolved in the GEIS and also found that any impacts 5 associated with these issues are small.

6 The public now only has the opportunity to express 7 its views today, as we have heard, but also the opportunity 8 to submit another round of written comments to the NRC on 9 the Supplemental Environmental Impact Statement for Calvert 10 Cliffs.

11 In July of last year, and as we heard today, many 12 of us met in the same location to express our opinions and 13 to submit our comments about what the scope of the 14 environmental review should be that would occur as part of 15 the review of our license renewal application. This process 16 has been much more than writing letters. The NRC listened 17 to our comments, to our ideas and our suggestions. They 18 even enlisted the assistance of a national laboratory to 19 help them review all of the information. As a result of 20 comments made, the scope of the review was expanded. We 21 have an open mind in this process.

22 Looking closer to home, here in Calvert County, 23 since 1993, BGE has held in excess of 60 public meetings 24 either here in Solomons, at the plant in Lusby or in 25 Rockville, Maryland at NRC headquarters. And in the last 12

159 1 months we have held no less than 14 of those public meetings 2 on the topic of license renewal.

3 We, additionally, have submitted literally 4 hundreds of documents that detailed our process. In fact, 5 98 percent of our application was on the public record for 6 over a full year prior to the formal submittal, and we had 7 requested the NRC to begin their review in a public nature, 8 holding public comments. It wasn't a 30 day shot in the 9 dark for the public.

10 Apart from the license renewal process, Calvert 11 Cliffs has a visitors center that is open seven days a week.

)

12 The Calvert Cliffs family hosts, on average, 3,000 people 13 per month who come to visit us. These visits allow for 14 learning by our visitors and for listening by us. In 15 addition, there is an open invitation to request a tour of 16 the actual plant seven days a week, inside the fence, inside 17 the buildings. Every year we conduct 100 to 150 tours a i

18 ranging from private citizens from Idaho who are touring l 19 Southern Maryland, to Boy Scout troops, to formal agencies, l 20 companies, and, yes, even the public action groups, without i 21 hesitation.

1 22 MR. DOROSHUK: The message here is if anyone, 23 anyone, whether you work for BGE, whether you work for a 24 government agency, whether you work for the nuclear 25 industry, whether you work for a public action group, if any i

i

160 l

11 of you have a nuclear safety concern or any information at i

-t 2 any time that indicates the environment is being disturbed, 3 there .:Us virtually an unlimited number of avenues to get 4 that information to BGE, to the NRC, to the State of 5 Maryland, to the State Police, to whoever the right people j 6 are. You can dial a toll-free number, you can e-mail us, or 7 you can simply stop by. I 8 I think the process that we're under -- going

)

9 through has offered an enormous amount of opportunity, not J

10 just because of license renewal, but on a daily basis, seven 11 days a week. It's been open, our minds have been open, our 12 doors are open, and there continues to be an open invitation 13 for all of you, no matter who you work for, no matter where 14 - you live.

15 Those of you who were here last July heard me 16 discuss the conclusions of BGE's own environment review and 17 some of the facts surrounding or decision to submit our 18 applications, some of the facts that supported our 19 conclusion that it makes good sense to continue to operate 20 the plant. After all the scientific studies that we have 1

21 conducted, that you've seen have been conducted, and I'm 22 impressed with the breadth of it all, and after taking into 23 account all of the considerations and all of the alternative 24 actions, we continue to believe that it makes good sense to 25 maintain the balance and the equilibrium established between l

l l

l

,1..

1 161 1 the plant, the air, the Bay and the land.

1 2 I would draw everybody's attention to the table 3 that everybody wants to go to. I believe it says it all. I 4 think Mary Ann did a wonderful job going through that today. ]

5 It compares the environment impacts of Calvert Cliffs's

)

6 license renewal and the alternatives, it reports the <

7 environmental impact of license renewal as small. Small is 8 defined as the environmental effects are either not 9 detectable or are so minor, they will neither destabilize 10 nor noticeably alter any important attribute of the 11 resource. In simple terms, there are no environmental 12 impacts. Indeed, the land, the water, and the air are clean 13 around here.

14 Each of the alternatives evaluated in this SEIS 15 have been determined to have one or more significant impacts 16 than license renewal in one or more category -- the document 17 evaluated, the no-action alternative, coal-fired plants, 18 gas-fired plants. Let me talk about some of the things it 19 didn't evaluate and put it into context. i 20 Many of us in the room here live in Calvert l 1

21 County. You can live in P.G. County, you can live in Anne l i

22 Arundel County, Calvert County is about 200 square miles of l 23 space and land. Calvert Cliffs, a 1,700-megawatt plant 24 which generates on the average 13 billion kilowatt hours a 25 year, occupies only 280 acres, one-thousandths the size of j l

l

l 162 I

1 , the county. A 2,000-acre green space -- the rest of the 2 ;

I site actually buffers the plant, and as pointed out, you 3 l can't see the plant as you drive by.

I 4 To replace Calvert Cliffs's electrical generation i

5 i with wind-driven turbines or, as some of us call them, I

6 I windmills, we would need to cover not 280 acres, 255,000 l

7 i acres of windmills or 400 square miles, or two Calvert I

8 =C ounties.

9 1

i If we were to look at solar and consider the 10 average solar incidence in Maryland, solar would require two 11 to three times that land area over the wind power option, 12 1000 square miles, five Calvert Counties.

13 If you were to look toward hydropower, we would 14 have to create a 2,600 square mile reservoir to replace 15 Calvert Cliffs.

16 BGE is committed to have a well-balanced, i

17 reliable, safe mix of energy sources for its customers in 18 Maryland and elsewhere. We think that Calvert Cliffs is an q 19 important and reasonable part of that mix.

20 The environment around us is a complex one. We 21 believe change should be considered carefully. After all 22 the scientific studies and considerations that go into these 23 actions, BGE feels it makes good sense to maintain the l

24 equilibrium established between the plant, the Bay, the air )

l 25 and the land. i i

T-163

1. I believe the consistent conclusion from all of 2 the environmental revic s- assessments and evaluations is 3 compelling.

4 The continued operation of Calvert Cliffs beyond 5 the original license period will provide the people of 6 Maryland with a safe and reliable source of energy.

7 The continued operation of Calvert Cliffs will 8 continue to be a contributor to the environment by striking 9 that careful balance between clean air and a stable energy 10 supply.

11 The continued operation of Calvert Cliffs will 1

12 provide economic stability to Maryland and to BGE. j 13 We've spent the last three-and-a-half hours -- I'm 1

14 going to take seven.more minutes of your time. But I want l

15 -- we've been talking about something else that's not in 16 this room, so in this part of my remarks, I would like to 17 show you a short video of Calvert Cliffs and allow the plant ,

18 to tell of its own role in our way of life here in Maryland.

19 We realize and we want to say up front that no )

20 film ever escapes a critic, so I'll say up front that we're 21 not Spielberg, nor do we intend to be or pretend to be. I 22 believe the short clip, however, shows the essence of a 23 great relationship between Calvert Cliffs and the rest of 24 our community, and I'm going to let Calvert Cliffs tell the 25 rest of the story.  !

l 1

1

\

l 164 1 (Video presentation.)

2 MR. DOROSHUK: I encourage you to stay around for 3 the 7:00 session. We'll probably have the bugs worked out.

4 But let me just say a couple of concluding remarks.

5 We at BGE and at Calvert Cliffs take pride in our 6 position as a good neighbor in the community. We believe 7 this is widely recognized. The value of Calvert Cliffs is 3 8 plain and simple. The value of the environment is also

]

l 9 obvious to all. The video would have encouraged you to l 1

10 speak out. To all that have offered rationale input to the 11 process, I want to thank you for taking part, all of you.

12 Speaking for the employees, all the employees and the 13 management at Calvert Cliffs, I would like to graciously 14 thank everyone who demonstrated their support for this )

15 initiative. We believe it just makes sense to continue to 16 preserve the safe, reliable and environmentally sound 17 technology that Calvert Cliffs offers us.

18 Thank you.

19 MR. CAMERON: Thank you, Bart.

20 We will be back here at 7:00. We may have a 21 working video, and we'll see. But thank you for your 22 patience and your tolerance. l 23 [Whereupon, at 5:55 p.m., the public meeting was 24 concluded.]

25

O F' ]

l 1

1 Introduction PUBLIC MEETING

  • Purpose O SEIS FOR COMMENT  ;
  • statu1o,ybaa ,,ound Nuclear Regulatory Commission

[wrek g- . -

i

  • Role of the GEIS April 6,1999 { )

l E l

  • Review results 9,s.,*,f
  • Schedule J [g
  • Public comment 7_ .n .

, l

> l CCNPP License Renewal

!, Calvert Cliffs License Renewal  !

. l l

i Environmental Review Milestones  !,

' I

  • dnits 1 and 2 ,
j.
  • Application received -4/98 .

l

  • Operating licenses to expire in 2014 and 2016, I j respectively I f,
  • Not.ice ofIntent - 6/98 i

f-

  • Scoping meeting - 7/98 j j

( Environmental Report

\_); {

  • Draft supplement to GEIS - 3/99  ;
  • Review process, contents, preliminary I conclusions and recommendations
  • Comment penod - 3/99- 5/99 i i  !

\

l I

Purpose of Today's Meeting NRC Mission l

  • Present results of environmental review
  • NRC govemed by:
  • Discuss what the staffconsidered l Atomic Energy Act
  • Clarify issues ofinterest to assist members of the public in > Energy Reorganization Act preparing comments

> National Environmental Policy Act (NEPA)

o h M es issue was inappropriately excluded

  • Mission statement:
  • Accept any comments from the public -

! > health and safety protection

  • Inform the public of schedule and process to submit i

> environmentalprotection m 5 > common defense and security 6 V

,1 What is Lic:nse Renewal? , Purpose and Need Atomic Energy Act

. . Renewal of an operating license

> Limits term oflicense

> Allows for renewal "

... to provide an option that allows for Power generation capability beyond the

  • License Renewal (10 CFR Part 54) j term of a current nuclear power plant j > Operate an additional 20 years beyond current operating license to meet future system

! license term generating needs..."

> NRC review

> Public, participation  ; gy,,hy,w,,,,gg,g, ,7,=,,,=

> Commission dec,ision wamm 7 3 L,

! I NEPA Process l

, License Renewal Process ,

_  !

  • NEPA requires Federal agencies to use a l r-* - - '

systematic approach to consider environmental j

! .. %j t

.U"- j lj; impacts l n

I l

  • l3 I'
  • EnvironmentalImpact Statement (EIS)is ,

l "- "~' * #+ required for major federal actions significantly

, = 1 M W, --* % : affecting the quality of the human environment

" ~ ~ *

action i 9  !!

10 t

i NEPA Process j NEPA Process (continued)  ; (continued)

! l i

  • Notice ofIntent - notifies public of j > Review - evaluates enviromnental impacts, I preparation ofEIS  ! alterna:ives, & mitigation measures i

I

  • Scoping Process - identifies scope of EIS  !
  • Issue draft EIS for public comment and solicits public input

! {

i > Public Meeting

! > Public Meettng i > Public Comment Period l I > Public Comment Period  ;

  • Issue final EIS 11 j

j 12

.g

Envir:nmentcl Lic:nse R:nswal Regulatory Background Process

,.s  ! Environmental License Renewal Review Process w

DE Ik ]l S

  • Regulations

! wg I > 10 CFR Part 51 i

gQ,, - (t %=v."=

s.

gg .,_,,

,m I

4

> Generic Environmental Impact Statement (GEIS) i

  • Regulatory Guidance i #~ -  ;
<T,,M f sg,,,/. { > Environmental Standard Review Plan for License  ;

i

~e Renewal j }

l 0 03 >

! 13 l,4 14 j Generic Environmental Impact Standard of Significance  ;

! Statement for License Renewal of '

! Nuclear Plants (GEIS, NUREG-1437) Council on Envitonmental Quality definition ,

I i l

  • SMALL: Effect not detectable or too small to
  • To improve efficiency oflicense renewal process destabilize or noticeably alter any important attribute of {

l the resource l l

  • Identified 92 issues of potential consequence '
  • MODERATE: Effect sufficient to alter noticeably but (3l
  • For each issue, approach consisted of: not to destabilize important attributes of the resource l VI i

> Describing activity

> Identifying population or resource affected  !

  • LARGE: Effect is clearly noticeable and sufficient to j

> Assessing nature and magnitude ofimpact destabilize important attributes of the resource

> Characterizing significance of the effect I

> Considering whether additional mitigation is warranted ,

15 l 16 i

Category 1 Issues il Category 2 Issues i

l 68 issues meet these criteria i

  • Impacts apply to all plants or to plants with  ;
  • 22 of the categorized issues did not  !

specific plant or site characteristics  ! meet one or more of Category 1 i

  • Single-significance level applies (SMALL, MODERATE, LARGE) .
  • Plant-specific review required
  • Additional plant-specific mitigation measures >

not likely to be sufficiently beneficial to be warranted ,

l l8

/]

V I7 I I

I i

1 1

J

1 i

)

i 4 l

. Issues Considered in SEIS I AdditionalIssues 1

' "' ^"~~

  • Two issues were not categorized "

T"~

h

> Environmentaljustice f)b 4

" ~~

l l

> Chronic effects of electromagnetic fields  !

  • Review process to identify whether there is **'

any significant new information

/ '

19 cas ses 20 i Calvert Cliffs' SEIS Limited Scope of the SEIS  !

,

  • Supplement to GEIS Issues not considered in the SEIS:
  • Need for power '
  • Plant-specific environmental effects i during the renewal term
  • Cost of power
> Category 1 issues
  • Safety o Category 2 issues  !

l > Not categorized

  • Spent fuel disposal (except for  !

! > Newissues transportation) 21 22 SEIS Information SEIS Information -

Gathering Process > Gathering Process (continued) i Reviewed BGE's application l

  • Visited county, regional, and State govemment, j environmental and resource regulators
  • Received input through public scoping process  ;
  • Visited information service agencies i

> All comments considered  ;'

> Comments not bearing on license renewal  !

  • Verified environmental permits and decision referred to appropriate NRC programs requirements for continuing operations Visited site and reviewed BGE's process for
  • Discussed consequences during renewal term
  • identifying newinformation i with regulating agencies

! 23

1 l

l Tre tment of Cat: gory 1 Issucs l Category 1 Issues (68) l p)

(v t Staffevaluated CCNPP site to determine whether

  • or not there was any new and significant

, Not applicable to site (11): issues identified in Appendix F of the SEIS information regarding Category 1 issues available j for that site I  !

  • Related to refurbishment (9): issues identified in Chapter 3 l > All Category 1 issues evaluated i l ,
  • Remaining (48) reviewed for new and significant l l > Where there was no significant new information

. . I  ; information: issues identified in Chapters 4 - 7

'lli

revealed, the stafrembraced the conclusions of

! the GEIS > BGE's Environmental Report

> Public Scoping Meeting

'l > Consultations with regulators and technical experts i

25 t

26 l I l

' Category 2 Issues (22)  ;

i AdditionalIssues I i

'

  • Not applicable to site (5): issues identified in Appendix F of the SEIS j '
  • Not categorized
  • Related to refurbishment (4): issues identified in Chapter 3 '

l

> Environmentaljust. ice

  • Remaining (13) issues underwent independent review and i

are specifically addressed: issues identified in Chapters 4 -7  !

> Chronic exposure to electromagnetic fields

> Considered mitigation measures for each Category 2

  • Newissue I assue, sf necessary r

> Identified significance of each issue as SMALL, > Microorganisms in high-radiation, high-  ;

MODERATE, or LARGE .

temperature environments i

27 4

l 28 i l

i Contents of CCNPP SEIS j EnvironmentalImpacts of i

Document organization and preh. .minary analysts lt .

License Renewal

  • Chapter 1: Introduction  !

, i

  • Chapter 3: Refurbishment
  • Chapter 2

> Land Use

  • Chapter 4: Operation during the renewal term

> Water use and quality ,j l

> Category 1 issues

> Air quality -

> Aquatic resources l

> Category 2 issues and specific issues that could not  !

i > Terrestrial resources be reviewed generically l > Radiological impacts to surrounding area l j

> Socioeconomic factors

> New issues raised by BGE, public, or staff

> Historic and archaeological resources 29 l 30 V

l

a Preliminary Results of Analysis Preliminary Results of Analysis Category I Issues

  • Aquatic ecology Category 2 Issues g
  • No significant new environmental information was identified for these issues > Entrainment of fish and shellfish in early life stages .

> Impingement of fish and shellfish  ;

  • Heat shock .
  • Staff embraces the conclusions of the  ;

GEIS

  • Threatened or endangered species
  • FWS has RECOMMENDED mitigation measures for
certain species 31 32 l

i  :

Prelimine.ry Results of Analysis Preliminary Results of Analysis i (continued) l (continued) ,

Category 2 Issues ,

Category 2 Issues l

  • Socioeconomics l
  • Groundwater use conflicts  !

! > Housing impacts l

  • Human health: Electric shock i

> Public utilities

> Public transportation

' > Offsite land use i

l > Historic and archaeological resources 33 34 l Preliminary Results of Analysis l, Preliminary Results of Analysis j (continued) '

(continued) i Not Categorized New and Significant Information

'

  • rganisms existing under high-radiation, high-
  • Environmentaljustice temperature conditions j

i i > Human health: Chronic effects of > Linie potential for detrimental population increase in  !

environment I electromagnetic fields ,

j

> Would not have deleterious effect on public health  !

,

  • Determined that this did not meet significant new ,

inf rmati n standard 36

35

>i Preliminary Rcsults of Analysis Preliminary Results of Analysis (continued) (continued)

()  !

  • Chapter 6: Uranium Fuel Cycle and Solid
  • Chapter 5: Postulated Plant Accidents Waste Management

> Design basis accidents l; > Transportation of radiological waste i> Severe accidents f 10 CFR 51.52(c), Table S-4 ,

i.

il

  • Chapter 7: Decommissioning <

> No Category 2 issues j 37 38 l

Summary ofImpacts of Operation Environmental Significance of

, During Renewal Term l License Renewal l

  • No significant new information identified j IU 1mpact Capry Linean impact Capey Laense

""" "a"d

  • Impacts for Category 1 issues bounded by analysis in ,

GEIS i= " = $W hanHWe $m

,  ! Ecoke SMAll Socmemnoma Sm G

  • Impacts for Category 2 issues of SMALL significance '

w=. Quany - s.r-e suni 4.*=ia su4u.

and would REQUIRE no additional mitigation i an$.ou,u sn.na sm

, Waner Qualsv - SMALL Resource

  • FWS RECOMMENDED impicmentation of EnmeneW hiu SMAR mitigation for certain species w.= suru 39 40 Unavoidable Adverse Impacts of License  ?

Irreversible or Irretrievable Renewal Resource Commitments j t

I

  • Materials and equipment required to i
  • Continued drawdown of water at offsite maintain operations wells ' l
  • Continued loss of fish and shellfish l
  • Permanent storage space for spent fuel
  • Housing and traffic impact from addition i~ assemblies of about 60 employees j i 41 l 42

\ ,/

! Sh2rt-Term Use vs. Preliminary Results of Analysis Long-Term Productivity (continued) i Chapter 8: Alternatives to License Renewal i i

> Current environmental balance well  ;

  • Limited to those " eminently reasonable of demonstrated '

established j capability and with sufficient generating capacity to replace ,

j plant power generation"

  • Renewal would delay alternative site use i

l

  • Includes"No-Action" alternative i - Coal-fired power generation i i l l l
  • Gas-fired power generation l 44 43
  • l

. , i

! Environmental Significance of Il Environmental Significance of j License Renewal (continued) i License Renewal (continued) j e

Papened No Actes Pas-Acces PueAction Acese Alarreseve CoakFued Generseen i inpact Caeywy Imnse Demei er CCNPP Gmeermed Impact Canywy Demalef inyece Caeywy Dend er Rseewal Rear =ai siw sin t Land Use SMALL EMALL $ MALL MODERATE  !

laid Use SMALL hman Heshh SMALL m LARE Escipp SMALL s~-mus SMALL e Ecotoy SMALL $ MALL SMALL MODERATE

'^Ra #=

l Wase, om , - ,fa.e .MG ,

e Waser Assihenca SMALL Weer Qualey - Swfme SMALL SMAll SMALL SMALL m l Waar MODERATE weer ow y - sMAu A,oisoie,cw mid we.n.s sMaa .  !

i Gsoundwaser Renowses 1.ARGE Waer Qualsy - $M E SMALL LARG SMALL m  ;

. c -

tARa i M E ,

d'r Quainy SMALL SMALL MODERATE MODERATE j we sM E sMAtt MODERAn uODERATE 45 '

46 l

Environmental Significance of ll Environmental Significance of l License Renewal (continued)  :; License Renewal (continued)  ;

Poposed No.Astee  ! Propend No Aenen l

f Aenen Ahmuasise CeabReed Geesesmen Aeties Ahemeeve Ca> Mead #

Impas Carpry License Demaior CTNPP Creenrised  ! Impaa Careywy tJcense Deenal er CCNPP GesenEeed l Renewal Raswed $6er Sem Resswai kenenal Saw $sm i l

Haven Hometh SM E SME SMALL SME i j Land Use SMALL SM E SME SMALL e cs SMALL SMAll e MODERATE MODERATE l

LARGE geo4og gMALL 3 MALL GMALL $ MALL e I

! Assdutics SMALL $ MALL MODERATE MODERATE *

  1. LARE mLARG l Waser Qua'ry - Surface $ MALL SMALL SMALL SMALL e Archeolopsal and SMALL $ Mall e SMALL SMALL i Waar MODERATE Hisencal Rasawees LARG Waser Quainy - SMALL SMAll SMAll SMALL Env' ' Jusen SMALL SMALL e MODERATE SMALL e 0"""d"#

i MODERAM LARGE  ! As Quainy BMALL SMALL MODERATE MODERATE j f Wane SMALL SMALL EMALL SMALL  !

47 48 l

l 1

  • 1 1

l E vir=m::til sigrificgice cf l Preliminary Results of Analysis License Renewal (continued) .

i (continued) -

/ h Psepeerd he-Aenes ra e- ^>---

).  ;

b'; impan canyny c-r-* c--o-Chapter 5: Postulated Plant Accidents i ticean n=w .r ctwrr c=nrwu mi me saw s.= ,  !

! *-- n w. sm sm se sm l

  • Design Basis Accidents l

I

! secesso nci sMAt1 sMAtt a sw sm i i

l_

l uoocaxre w=twa l

  • Severe Accidents l

l m a %w .m sm. se sm > Severe Accident Mitigation Alternatives

'"  ! (SAMAs) {

'-"--"'""" M i, M ?s Je*17.

1, 4 49

\l 50 l

- i j Evaluation of Severe Accident

l Evaluation Approach
j l Mitigation Alternatives (SAMAS) l

,

  • Characterize overall plant risk and lead contributors to risk

)

jj

  • Identify design improvements that can further reduce risk
  • Purpose of Evaluation:

l'

  • Quantify risk reduction potential and costs for each improvemert f

6

!l

  • Determinewhetherornotimplementation ofimprovementis To ensure that plant changes (design or justified

(

\

1l procedural) with the potential for  !, > significant reduction in total risk I improving severe accident safety l performance are identified and evaluated > Favwabinalueimpactratio r

l e Risk reduction is assocized with aging effects during period of extended operation 51 52 i

[ Results of SAMA Evaluation .! Results of SAMA Evaluation I l

  • One improvement to plant hardware selected for implementation a

' (continued)

CCNPP

> Reduces the risk from internal flooding events l l > Will be pursued undcr BGE's current corrective action program l'

  • Overall

Conclusion:

I'

  • Three addtional enhancements judged to be cost beneScial under  ! . .

current NRC rer.ulatory analysis guidelines, but do not relate to i. Additional plant improvements to further managing the efrects of aging mitigate severe accidents are not required at

> NRC intends to further evalume the need for these enhancemerts CCNPP as part oflicense renewal pursuant i in the context of corsinued opersion under the current operating license to 10 CFR Part 54 '

  • All remaining enhancements have either a very small or negaive  !'

net value, or offer only minimal risk reduction j] 53 '

54 V

f I

Envircnmental Findings from ii Staff Preliminary Conclusions <

License Renewal Review  ;, and Recommendations  ;

l 1

  • Based on

> The analysis and findings of the GEIS 4

contams NRC staff's prehminary conclusions regarding the environmental > The ER submitted by BGE

! acceptability of the license renewal action ,

. > Consultations with local, State and Federal l

  • Overall license renewal decision based on agenaes safety and environmental review > Independent review, including results ofscoping )

process j 55 56  ;

Staff's Overall Preliminary l Conclusions and i Public Comments l Recommendations  !
, i j
  • Comment period ends on May 20,1999 l

The adverse environmental impacts of

! license renewal for CCNPP Units 1 and 2 > 75 day comment period are not so great that preserving the option oflicense renewal for energy planning ,

  • Comments not bearing on decision to decision makers would be unreasonable.  ; renew license will be referred to ,

! 'j appropriate NRC programs.

1 1 i 57 58 1

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i Calvert Cliffs License Renewal

! Environmental Review Milestones i Pomt of Contact i  !

j

  • Application received - 4/98 > Agency point ofcontact:

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  • Notice ofIntent - 6/98 ,

Thomas J. Kenyon  !

j i I(800)368-4542  ;

I i Scoping Meeting - 7/98  !

l

  • Documents located at Public Document Room l
  • Draft supplement to GEIS - 3/99 " and Local Public Document Room

!

  • Comment period - 3/99- 5/99
  • Provide comments: by mail, in person, or e-mail at cceis@nrc. gov
  • Final Supplement to GEIS - 11/99 g

.a Public Meeting on i Cnivert Cliffs License Renewal Application April 6,1999 I am Dr. Joseph Mihursky, a University Professor and have been an applied aquatic ecologist for over 40 years. For many years I ran a field and laboratory research operation concerned with environmental effects of energy conversion systems such as nuclear power plants. Here in Maryland our study sites included a region around Calvert Cliffs as l

well as four other power plant sites. We were recognized as a " center of excellence" by '

Federal agencies and the State of Maryland. I have been advisor to other US States, the federal government and other nations of the world on these same environmental matters.

Regarding power plants we made a number of recommendations about site O selection, engineering designs and operational features that in the main were implemented by BG&E in order to minimize biological damage to the local bay system. I heartily commend BG & E for doing so.

The Calvert Cliffs plant which requires 15 square mile feet of Bay water per day to relertse its waste heat, does effect pumped entrained and impinged organism because of rec uired Bay water pass through ofits heat exchange system. Organisms such as phytoplankton, zooplankton, shellfish and finfish eggs and larvae, small fish as well as combjellies and jellyfish may be damaged or killed. Because of the large hydraulic, mixing and diluting circumstances, effects upon Bay organism population dynamics is debatable or difficult to assess especially on a larger regional Bay wide scale.

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q(/ Hydraulic and physical discontinuities of current velocities and temperature do

. influence normal seasonal behavior of mobile species such as finfish. Also water velocity has scoured about a 90-100 acre area in the high velocity discharge area and has resulted in a changed benthic community structure.

Although the above incremental effects on the local Bay system are known, the State and Federal regulatory agencies have deemed them acceptable in return for electricity production.

Although BG & E has worked hard at being a " good neighbor", personally I would prefer having a more benign and lower risk electricity producing system in operation, as I do live within the 10 mile radius of risk concern. I do understand, in detail, the process and procedures that led to the installation at this location by BG&E. The past is done.

My existing concerns as a local informed citizen of Calvert County for 38 years are five fold. Ong is continued storage of spent radioactive material on site, but I recognize the complexities of this national problem. Inn is the eventual issue ofdecommissioning, burial cost and future care of the facility. Three is the question of the biological effects of batch release ofradioactive tritium to the Bay. Although tritium is a weak beta emitter, it can be incorporated with water into the cell nucleus ofrapidly developing early life history stages of Bay organisms such as oyster, clams, fish, etc. What does tritium uptake mean to the genetic well being of key Bay organisms? I am not aware that this question has been addressed at the Calvert Cliffs site.

Some years ago I was part of a federally appointed team to oversee the decontamination of the Three Mile Island facility after partial fuel rod meltdown and radioactive release. One of the recommendations eventually developed concerned

precautionary measures about public safety whereby potassium iodide pills should be made available to every household and facility having children that were located within the critical area around a nuclear power plant. This recommendation recognized that children are highly prone to uptake ofradioactive iodine that may be released from a plant incident. Such uptake can cause thyroid cancer problems. So, my fourth concern is that since such precautionary measures are being followed by other U. S. States and nations of the world, why is such a policy not pursued here by government and management in the Calvert Clifts region?

My fifth and final concern is a metallurgical one. I realize that a nuclear power plant is an awesome engineering accomplishment. But, I also recognize that in the early days we did not have a sufficient data base on the effects oflong term radiological emissions upon metallurgical properties. We now know that brittleness is one consequence of this exposure and results in " blowouts" of welds and piping. How is this substantial problem going to be avoided as this facility continues to age?

Thank you for the opportunity to comment on this very important societal matter.

J. A.Mihursky O

o -

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THE AMERICAN NUCLEAR SOCIETY POSITION STATEMENT i

NUCLEAR POWER-THE LEADING STRATEGY FOR REDUCING CARBON EMISSIONS I October 1998

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  • o eis The American Nuclear Society 555 North Kensington Avenue La Grange Park,IL USA 60526 708.352.6611 (phone); 708.352.0411 (fax) www.ans.org O

NUCLEAR POWER:

THE LEADING STRATEGY FOR REDUCING CARBON EMISSIONS The American Nuclear Society believes that nuclear power should be utilized increasingly to meet the targets set by national governments for reducing global carbon dioxide emissions. Nuclear power is the only proven, large-scale source of electricity with near-zero carbon emissions.

The American Nuclear Society strongly recommends that nations continue to support research to determine the impact of man-made carbon dioxide on the Earth's climatel . They should al.;o examine and compare the complete costs of energy options, from mining to waste management, including environmental and socialimpacts.

Globally, nuclear power produces about 7% of the world's energy [1],[2] (BP 1998, EIA 1996). The U.S. Department of Energy states that the increase in non carbon-emittmg energy over the past two decades was mostly due to the growth in nuclear power production [3) (EIA 1994). It concludes that, since electricity use significant y outpaced overall energy use, a potential course of action is to maximize the best-available electricity generation technologies. Countries that rely significantly on nuclear power have higher Gross Domestic Products (GDP) for the amount of carbon dioxide

=izei France, with 42% ofits energy produced by nuclear plants, has the highest GDP per tonne of

. emitted carbon dioxide (EIA 1996). This is a clear example of the path that the world's nations should follow in order to reduce carbon emissions without impeding economic productivity.

Nuclear power is a safe, proven, sustainable, near zero-carbon energy source with tremendous current and future ability to reduce carbon dioxide emissions.

To minimize future emissions, nations should:

O eAssure the continued operation of safe, existing nuclear power plants and facilitate the extension of their operating life, eStrongly promote the development and deployment of optimized, advanced-design nuclear power technology that is more cost-competitive, eBolster the continued improvement of nuclear materials safeguards by the International Atomic Energy Agency (IAEA),

eProvide incentives for the use of energy sources that do not emit carbon dioxide, Encourage the use of renewable energies, where they can be shown to be economically beneficial and i environmentally acceptable.

. BACKGROUND AND BASIS ,

Nuclear power is the only sustainable energy option available for large-scale development to help  !

meet future ener

~e lectric utilities,gy needs. After several decades of development by governments it currently provides about 7% of the world's energy supply and 17% of the world's and inve electricity needs.

By 2050 the v orld's population is expected to reach 10 billion. The scale of economic activity then will likely be Aree to five times larger in order to meet the living standards of that population. The consumption of resources will increase markedly as the low-income countries embark on their own

" Industrial F. evolution" to achieve higher standards ofliving. Given these conditions, the use ofnon-carbon emitdng energy sources must be maximized, if national and international carbon emission  :

commitmer.ts are to be met.

i Increasing the supply of nuclear electricity can help meet the goal of satisfy'ng increasing public i demands for clean, reliable energy, while at the same time limiting carbon dioxide emissions.

Initicily, the increase in nuclear power should take place in those countries that already have the '

necessary, established industrial infrastructure. In the less developed countries, as industrial infrastructures improve, nuclear power will be needed to develop their economies and reduce their dependence on fossil fuels.

The table shows the Gross Domestic Product (GDP) compared to the carbon emissions of the four largest world economies in terms of GDP per tonne ofcarbon dioxide emitted to the atmosphere.

Also shown in the table are the data for the two largest populations of the world, China and India.

Most of the more efficient countries obtain a significant part of their energy from nuclear power.

France, for example, now relies on nuclear power for 42% ofits energy and has the highest GDP/ tonne of carbon emissions rating in the world.

GOODS AND SERVICES PRODUCED per TONNE OF CARBON DIOXIDE EMITTED

$GDP/ tonne CO2 (These six countries account for over 60% of the global economy and almost half the population) 1996 data from (BP,1998; EIA,1996)

Gross Domestic OfTotal Energy ion Country );[Iat.

i ns Product (GDP)(a) $GDP/ tonne CO2 Consumed Billions USS  % Nuclear France 58 1456 3378 42 hpan 125 4319 2947 14 Germany 84 2096 1926 12 U.S.A. 266 7713 1148 8 India 952 567 534 1.4 China 1210 813 192 0.5 (a) Gross Domestic Product at Market Exchange Rates The French program is a clear example of the potential of nuclear power to reduce carbon dioxide i emissions. From 1998 data (BP 1998), French carbon dioxide emissions peaked at 600 million tonnes in 1973 when the total energy consumed was 180 million tonnes of oil equivalent (MTOE).

By 1997, energy consumption had increased by 35% to 244 MTOE. However, as shown in the figures below, at the same time nuclear power had grown from 4 MTOE (2% of total) to 102 MTOE (42%), and carbon dioxide emissions had decreased by 28% to 430 million tonnes, ENERGY USE IN FRANCE FRENCH CARBON EMISSIONS i l

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Nuclear power is an energy source that is safe, commercially proven, contains its waste products, and minimizes the environmental impacts of energy generation. The amount of waste produced is very small relative to the energy generated and methods are available for managing this waste. By using '

demonstrated technologies, nuclear fuel reserves in nature can be extended for centuries of operation.  !

An important feature of nuclear power is that the cost of fuel is small compared with capital cost. i Thus, once built, nuclear power plants produce electricity at a cost that is relatively insensitive to '

inflation or the fluctuations of prices on the world energy market.

The United Nations International Atomic Energy Agency (IAEA) has been effective at monitoring nuclear material safeguards and instrumental in obtaining international safety agreements. It should continue receiving strong, international support in its role of controlling nuclear proliferation while sharing the peaceful uses of nuclear technology. In addition, the World Association of Nuclear i

O Operators has established high safety performance standards, and monitors and improves operations at facilities throughout the world.

l Other than the traditional use of biomass, renewable energy sources currently provide about 2% of the world's energy, virtually all as hydroelectric power. Hydroelectric power could, if environmental concerns were managed, maintain its current contribution to the global energy supply, by utilizing all potential rivers. Even if the other renewable technologies such as wind, solar and biomass grow to contribute 40% of the global energy supply in 2050 (WEC/IIASA 1996), the World Energy Council  ;

predicts that carbon emissions would still increase to 50% above the 1990 levels. l Of the alternatives that the countries of the world must consider in strategies to reduce carbon dioxide emissions, maintaining and expanding the use of nuclear power is the leading solution and should be the preferred path.

REFERENCES

1. HP Statistical Review of World Energy, British Petroleum Company plc, London (1998).
2. International Energy Annual 1996, Energy Information Administration, U.S. Department of Energy, Washington,(1996).
3. " Energy Use and Carbon Emissions: Some International Comparisons", Energy Information Administration, U.S. Department of Energy, Washington DC, (1994).

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4. " Energy for Tomorr:w's World", World Energy Council, St. Martin's Press, Inc., New York,ISBN 0-312-10659-9,(1993).
5. " Global Energy Perspectives to 2050 and Beyond", World Energy Council and the Intemational Institute for Applied Systems Analysis, published by the World Energy Council, London, (1995).

3 The American Nuclear Society is not qualified to take a position on the scientific validity of the global warming or its relationslup to industrialization. Nevertheless, many governments, including the U.S. government, have reached consensus that action should be taken to reduce carbon dioxide emissions, and have made international commitments towards this goal. The Society is uniquely qualified to comment on nuclear power's ability to support these international commitments.

American Nuclear Society,555 North Kensington Avenue, La Grange Park, IL 6052'6-5592, USA Tel:(708) 352-6611 Fax:(708) 352-0499 http://www.ans.orn 9

O

Remarks on License Renewal Angelina S. Howard Senior Vice President Nuclear Energy Institute Solomons, Maryland April 6,1999 Good afternoon. I'm Angie Howard, senior vice president with the Nuclear Energy Institute. ,I am very pleased to have this opportunity to meet with you today.

O The Nuclear Energy Institute is a Washington, D.C.-based policy organization that represents more than 275 U.S. and international companies in the nuclear energy industry.

2 Our membership includes every U.S.

utility that owns and operates a nuclear power plant, their suppliers, fuel cycle companies, universities, radiopharmaceutical firms and 1 research laboratories, labor unions i and law firms.

l Many of the Institute's activities l involve nuclear energy-which  :

provides about 20 percent of Q America's electricity.

We're here today to discuss the draft supplemental environmental impact '

statement for Calvert Cliffs for the license renewal period.

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3 After an extensive review, the NRC has found no significant environmental impact from license '

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renewal for the Calvert Cliffs plant.

l This review included potential i environmentalimpacts from plant operation ... the plant's interaction with the land, water and air ...

socioeconomic factors ... aquatic species ... threatened or endangered  ;

O species .. and many other issues.

The NRC also thoroughly evaluated a new issue identified during the scoping review-microorganisms that l j

live in high-radiation, high-l temperature areas.

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4 The agency concluded there is no significant impact associated with the l issue.

The NRC also examined the environmentalimpacts of alternative energy sources, compared with the Calvert Cliffs plant.

Ultimately-when this extensive review was complete-the NRC O concluded there are no environmental impacts that would preclude renewing the plant's operating license.

(Pause) l

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i I'm here today primarily in a l

professional capacity, as a I

representative of the nuclear energy industry. But I'm also here as a resident of Anne Arundel County, just north of here.

My children love to play outside. In fact, both of them are very competitive tennis players. I want my  ;

children-and your children-to have Q clear air to breathe. As a wife and mother, I believe the clean generating capacity from this plant is needed.

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L l 6 So I support nuclear plant license l renewal, both personally and professionally, as one who has devoted nearly 30 years to learning i how these plants work from the inside out.

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License renewal for nuclear power plants is important to our nation's energy and environmental future.

This nation already can't meet clear 1

O air requirements in many areas-and that is with nuclear power plants on line.

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7 I commend the NRC for working-O through a very open and public l process-to develop a generic environmental impact statement for 1

license renewal.

It helps ensure that no important issues are overlooked or left unexplored-while at the same time, it makes the review process effective and efficient.

lO That is what the federal government demands ofits agencies today. And that is what American taxpayers l

demand, too.

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The agency started preparing for license renewal several years ago, by identifying the types and severity of i environmentalimpacts that could occur as a result oflicense renewal.

l The NRC concluded that many of these issues could be addressed i

generically-for all nuclear power plants-in a generic environmental j impact statement. i O The remaining potential I environmental impacts must be addressed in the context ofindividual license renewal applications. That is what today's meeting is all about.

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9 This approach allows the proceedings to focus on issues germane to the individualplant seeking license

, renewal-in this case, Calvert Cliffs.

The NRC plays a vital role in license renewal. But it isn't the NRC that will decide whether nuclear energy-or a particular nuclear power plant-is the right generating source for a given area. Its role is to determine-solely Q from the safety standpoint, whether a nuclear plant may continue to operate under a renewed license.

Over a period of years, the agency has made tremendous efforts to involve the public in license renewal in meaningful ways.

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10 0 The NRC issued its first proposal for amending the environmental rule for >

license renewal in 1994-five years ago. At the same time, the agency issued a draft generic environmental impact statement, inviting public comments. That was followed by numerous rounds'of public comments-including public workshops in several regions of the O cou-try.

The NRC made a number of changes in the rule in response to comments.

Then it issued the final revised environmental rule in June 1996 and it became effective in August 1996.

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The same open process applies to the technical part of a license renewal application. It is a process that works.

What does license renewal mean?

Without a renewed license, a nuclear power plant must shut down when its current license expires. If the region O later decides that it needs the emission-free generating capacity that i

plant provided-it will be too late. )

The time for making that decision will have passed.  !

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operation remains an option. I

"*i""* d happen to think it's an excellent one.

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As some of you know, the NRC has taken steps to add discipline to the hearing process-both in determining  ;

whether a hearing is warranted, and in conducting a hearing if one is granted. The guidelines are i straightforward. For a hearing to be l 1

O gr nted, there must be sisnificant new safety information to be considered.

i That is a reasonable threshold.

Why put so much effort into nuclear plant license renewal? It offers three major benefits:

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I 13 One, it will allow the United States to O l maintain economic electric generating capacity that does not produce greenhouse gases or other pollutants, such as sulfur dioxide, nitrogen oxide and particulates.

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l Two, license renewal will preserve I good jobs for Americans-and l

l substantial tax revenue for the .

I communities where these plants are Q located. And ...

Three, renewal of a nuclear power plant's license is much cheaper than building new generating capacity.

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Many people don't realize that nuclear energy is the largest source of emission-free electricity generation in the United States. It represents 64.5 percent of our nation's emission-free electricity generating capacity. Hydro I is second, with 34.9 percent.

Photovoltaic cells and wind power each represents less than .01 percent of our nation's emission-free capacity.

Q Geothermal contributes a bit more-0.6 percent.

Under the Clean Air Act, states are under increasingly stringent controls I on emissions of sulfur oxides, particulate matter, nitrogen oxides and ground-level ozone.

15 O As an emission-free energy source, nuclear power plants already help limit the amount of greenhouse gases emitted through electricity generation.

Most nuclear power plants are in heavily populated areas of the country that are in "non-attainment" with the Clean Air Act for ozone or other O regulated pollutants-even though those areas get a large amount of electricity from emission-free nuclear plants. Non-attainment status requires these areas or states to reduce pollution in the air.

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16 The Environmental Protection Agency O has even proposed capping nitrogen oxide emissions in 22 states that contribute to non-attainment for ozone in other states. Maryland is one of these 22 states. And that's with the emission-free Calvert Cliffs plant on line.

That's also why it is so important that Calvert Cliffs continues to operate.

O Baltim re as and Electric Company and Duke Power Company and are only the first applicants for nuclear plant license renewal.

1 17 There will be many others. Several O other utilities 1 have indicated to the l

i NRC that they are considering license renewal. Entergy Corp. plans to complete its application by the end of this year to renew the license for its 4

Arkansas Nuclear One plant.

1 Nuclear energy provides important 3 benefits to the United States, and the communities in which these plants are O ' "**d '* Pr vid ** '""* "" ""*" af electricity-on demand-to support continued economic growth and our high standard ofliving. And it does all this without polluting the air.

1 Entergy Operations, Florida Power & Light, Northern States Power Co., PECO '

Energy, Southern Nuclear Operating Co. and Virginia Power. In addition, Carolina Power & Light CEO William Cavanaugh told Nucleonics Week in late June that he is " pretty certain" his company will try to extend the licenses ofits four nuclear units.

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The fact is, the United States can't meet existing clean-air regulations ,

without continued-and expanded-l use of nuclear energy.

l l Thank you.

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0 Caldmore Gas & Electric Statemtnt at the United St:tes Nuclear Regul: tory Commi sirn Public Comment Mudngs en the Draft Suppl mental Environmental Impact Statement for the Calvert Cliffs Nuclear Power Plant Good afternoon / evening. My name is Banh W. Doroshuk and I am the Director of the Life Cycle Management Project at the Calven Cliffs Nuclear Power Plant (Calven Cliffs). I am representing the Baltimore Gas & Electric Company (BGE) at these United States Nuclear Regulatory Commission (USNRC) meetings. The purpose of this meeting is for the NRC to offer the public another opponunity to participate in the re-licensing process of Calven Cliffs. As we have heard, this particular opponunity in the process is to provide NRC with any comments on this document, the plant specific supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants. On behalf of BGE and the Calvert Cliffs family of approximately two thousand men and women who work at the plant,let me express my thanks for the opportunity to make a statement regarding the environmentalimpact oflicense renewal for Calvert Cliffs.

Today I would like to discuss two subjects with you, and then I will yield my remaimng time to the other speaker for BGE.

First, I would like to discuss the openness of the overall re-licensing process and in particular that of Calvert Cliffs. The second subject I will discuss is the findings of the USNRC regarding the i environmental effects of re-licensing. Finally, I have arranged for Calven Cliffs to make a few statements on behalf ofitself relative to the surrounding environment and its role in Maryland, and as a pan of the BGE family.

There has been some interest in the public process of the re-licensing of nuclear power plants. Let i me briefly describe how open the environmental review has been, how many opportunities there 3 have been for public input.

I want to do this by looking at the openness of the overall regulatory process and how open our minds have been about listening to everyone. Then I want to look at how open our " door" has been to everyone and tell about some of those who have taken advantage ofit. And finally I willlet you know about our ongoing open invitation to address your ideas, questions and suggestions.

Before our application, the NRC conducted a five-year public proceeding to prepare the Generic EnvironmentalImpact Statement on license renewal. This proceeding included public workshops, several opportunities to submit written comments on the draft generic environmental impact statement, and a formal rulemaWg.

Then, in our proceeding, the NRC staff has conducted scoping meetings and prepared a draft supplement looking at the site-specific impacts of renewing Calvert Cliffs licenses. The NRC staff has looked at all the issues that were generically resolved in the GEIS and determined that they remain valid for Calvert Cliffs. In addition, the staff has looked at the issues that were not resolved in the GEIS and found that any impacts associated with these issues are small. The public now hu j not only the opportunity to express its views today, but also the opportunity to submit written l comments on the draft SEIS.

In July oflast year, many of us met in this same location to express our opinions and submit our i comments about the scope of the environmental assessment that would occur as part of the review of BGE's license renewal application. l Barth W. Doroshuk Page 1 04/06/99 Baltimore Gas & Electric

Caltimore Gas & Electric St:tzment ct th '

United St t:s Nuclear Regulatory Commissi:n Pubile Comment Mntings on ths Draft Supplemental Environmental Impact Statement for the I Calvert Cliffs Nuclear Power Plant G

This process has been much more than writing letters. The NRC listened to our ideas and suggestions. They have even enlisted the assistance of a nationallaboratory to help them review all of the information. As a result of comments made lastJuly, the scope of the review was expanded.

Looking closer to home at this issue, since 1993, BGE has held in excess of 60 public meetings with the NRC (no fewer than 14 public meeting in the last 12 months) on the topic oflicense renewal, and has submitted on the public record literally hundreds of documents detailing our effons.

Apart from the license renewal process, Calvert Cliffs has a visitor's center open seven days a week.

The Calvert Cliffs family hosts, on average,3000 people per month who come to visit us. These visits allow for learning by our visitors and listening by BGE.

In addition, there is an open invitation for visitors to request a tour of the actual plant -inside the fence, inside the buildings. Every year BGE conducts somewhere between 100 to 150 tours of Calvert Cliffs by our visitors without hesitation.

If anyone has a safety concem or any information anytime that indicates the environment is being disturbed there is virtually an unhmited number of avenues to get that information to BGE, the NRC, the State of Maryland or whoever the right people are. You can even dial a toll-free number if need be, or you can e-mail us, or you can simply stop by. I think the process has offered all an enormous amount of opportunity to participate.

Those of you who were here last July heard me discuss the conclusions of BGE's own environmental review and some of the facts surrounding our decision to submit our applications, some of the facts supporting our conclusion that it makes good sense to continue to operate the plant.

After all the scientific studies we have conducted and after taking into account all of the considerations and altemative actions, BGE continues to believe that it makes good sense to maintain the equilibrium established between the plant, the air, the Bay and the land.

I would draw everyone's attention to Table 9-1, on page 9-6. I believe that table says it all. It summarizes and compares the environmental impacts of Calvert Cliffs' license renewal and the altematives. It reports that the environmentalimpact oflicense renewalis recognized as smallin all impact categories. SmaSis defined as " environmental effects are not detectable or are so minor that they will neither destabilize nor noticeably alter any important attribute of the resource." In simple terms, this means there are no environmentalimpacts from license renewal on Calvert Cliffs.

Indeed, the land, the water, and the air are clean around here.

Each of the altematives evaluated within the SEIS has been determined to have more significant impact than license renewal in one or more impact category. The document evaluated the no-action altemative, and coal-fired and gas-fired power replacements. Let me briefly discuss some of the alternatives that did not make the final assessment and the reasons why.

Many of us in this room live here in Calvert County. This county has 213 square miles of land space. Calvert Cliffs, a 1700-megawatt power plant which generates on average approximately 13 Barth W. Doroshuk Page 2 04/06/99 Baltimore Gas & Electric

C l Cal 2more Gas & Electric Statement et the l United St:tes Nuclear Reguictory Commissirn i

4 Public Comment Mutings cn the Draft Supplenuntal Environmental Impact Statement for the Calvert Cliffs Nuclear Power Plant t

O billion kilowatt-hours of electricity, occupies only 280 acres at the Calven Cliffs site. A 2000-acre green-space buffer, the remainder of the Calven Cliffs site, surrounds the plant. To replace Calven Cliffs' electrical generation with wind-driven turbines or windnulls, we would need to cover 255 l thousand acres, or 400 square miles, almost twice the land ues of Calvert County. If we look at i

solar and consider the average solar incidence in Maryland, solar power would require two to three times the land area of the wind power option - over 1000 square miles. Hydropower replacement would require a 2600 square mile area of reservoir-covered land to generate the power of Calvert Cliffs. In the eastern United States, we simply don't have the land area to consider the wind, solar, or hydro altematives. l l

The environment around us is a complex one, and we believe change should be carefully {'

considered. After all the scientific studies and considerations that go into alternative actions, BGE feels that it makes good sense to maintain the equilibrium established between the plant, the air, the Bay and the land.

I believe the consistent conclusion from all of the environmental reviews, assessments, and evaluations is compelling. The continued operation of Calvert Cliffs beyond the orginallicensed periods will provide the people of Maryland with a safe and reliable source of energy. The continued operation of Calvert Cliffs will continue to be a contributor to the environment by stnking that careful balance between clean air and a stable energy supply. The continued operation of Calvert Cliffs will continue to provide economic stability to Maryland and BGE.

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We have spent the last two and one-half hours talking about something that is not in the room. So in this part of my remarks I would like to show you a shon video of Calvert Cliffs and allow the plant to tell ofits role in our way oflife here in Maryland. We realize, and want to say up front, that no film ever escapes a critic! So let me say up front that Speilbergs we are not, nor do we pretend to be! I believe this short clip shows the essence of the great relationship Calvert Cliffs has with our community. I believe I willlet Calvert Cliffs speak for itself.

We at BGE and Calvert Cliffs take pride in our position as a good neighbor in this community. We believe that this is widely recognized. The value of Calvert Cliffs is plain and simple. The value of the environment is also obvious to us all.

The video encourages people to speak out. To all that have offered rational input to this process, I thank you for taking part. Speaking for all the employees and management at Cahert Cliffs, I would like to graciously thank everyone who demonstrated their support of our initiative.

BGE believes it just makes sense to continue to preserve the safe, reliable and environmentally sound technology that Calvert Cliffs offers us.

Thank you.

l ("N.

Barth W. D-4huk Page 3 04/06/99 Baltimore Gas & Electric

s Third Draft: 5/28/98 A revised final V

CALVERT CLIFFS:

A BEACON OFENERGY A CREATIVE VIDEO SCRIPT FOR BALTIMORE GAS AND ELECTRIC COMPANY September 25,1998 Reminders: Visuals precede spoken words.

All visuals and music elements are suggestions only.

All narration is voice-over.

/~N t NOTE: In whatfollows, all shots marked with (A) below should be readily available from BGE video library archives orfrom other existing sources.

Video Audio FADE UP (MUSIC /SFX: Gentle acoustic guitar music, bluegrass or folk style, mixed with the natural sounds of the sea.)

Waves lap the rocky Atlantic coastline as we glide forward. Somehow the lighting suggests early evening, and .

we can almost smell the freshness of the salty breeze.

A lone figure in the distance is moving toward something just up from the shoreline. Closer shots reveal a man, dressed simply in modem-day denim and flannel and good workman's shoes. Clean-shaven and 40 or above, he strolls calmly toward a lighthouse.

We cannot identify him.

(Option to shoot actuallighthouse-O,', Cove Point Lighthouse on Chesapeake Bay.)

Scripts Unlimited, Inc. + 1 of 12 + Calvert Chffs: A Beacon ofEnergy M:-ME0E40. Doc Video Script

s Third Draf1: 5/28/98 revised final (NARRATOR, V/O:) Consider the lighthouse.

It's a simple idea. )

If possible, we show the man entering the building; [ edit to] arriving at the top, and settling in. His facial features remain dim or out of frame.

Based on a sturdy tower, a large window, and a steady source oflight.

His hands begin to flip switches. We see a big Navy ring. (Or: stock footage of otherlighthouses.)

It reminds us how, for centuries, the protection of others has often rested upon something as safe and reliable ...

Transition to stock footage of a lighthouse trsam sweeping through the night. Slowit down for enhanced effect.

... as a beacon oflight.

(SFX: There's a kind of voice to the beacon, a throaty and reassuring hum that crescendos during the sweep.)

The beam languidly sweeps over us.

Transition to an aerial night skyscape of Baltimore, an arcing and elegant shot. Among the skyscrapers,layerin night scenes of marquee lights and traffic (SFX: Mixed under, the dynamic sounds of. urban nightlife.)

(NARRATOR:) Today, the kind of energy we harness can be much more complex.

O Scripts Unlimited, Inc. + 2 of 12 + Calvert Citfs: A Beacon ofEnergy M:~ME0E40. Doc Video Script

Third Draf1: 5/28/98 revised final v) Transition to an early moming shot, bayside, serial. We swoop in over water.

/

(NARRATOR:) Yet here, the bay is tranquil ...just as the idea behind harnessing energy is simple.

We come upon the rounded towers behind the bay.

This is the Calvert Cliffs Nuclear Power Plant.

Think ofit as ...  !

A circle wipe creates a swift" moving beam" effect via highlight and subdue.

A Beacon of Energy.

Titles appear over it.

(MUSIC: By now, other musical instruments have joined the guitar and the rich sound comes up full.)

Baltimore Gas and  !

Electric Company presents .

O caen ones:

A Beacon of Energy l

(MUSIC: Somewhat faster now.)

Intenor, a home in the area. Lit for  ;

eady morning. A digital alarm clock d: splay changes to 6:00 a.m. and starts to buzz. '

Time has proven nuclear energy to be safe and reliable.

Key words on screen in large translucent text: .

safe reliable (SFX: Alarm clock buzz, muffled under the soothing music.)

Transition to interior shot, Calvert Cliffs, showing mammoth control panel l (A).

Since 1975, the people of Central and Southern Maryland have experienced the value of Calvert Cliffs.

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Third Draf1: 5/28/98

,- revised final

, Transition to interior shot, Calvert Cliffs, featuring massive turbines (A).

Option to surround the central part of -

the image with edge pix layered on /

showing energy use. These might include a designer lamp from an office setting, a hand-held hair dryer in a teen girl's hand, a toddler at a plug-in toy keyboard, and a high-speed Pepsi bottling machine or web press from the Baltimore Sun. (A)

Light, heat, music, industrial muscle ...

Let the high-speed machine shot engulf the screen. (A) Subdue 40% of it, with CG over:

40%

.. 40% ofit has come from here.

Fly over it in diagonal fashion the key word, again large and translucent:

energy Animate or step-animate a red arrow fm ratcheting down over a scenic

( ) Maryland background. A headline

'v' appears with words to this effect:

BGE announces lith consecutive fuel rote decrease Also, in the upper-right corner, as spoken, we see the words:

lower rates Calvert Cliffs has brought us lower rates.

Need a generic figure to show over a shot of many crowded people in a downtown Baltimore scene. CG over; billions '

With a combined cost savings . . over the lifetime of the plant ... in the billions.

Archive shot from BGE emphasizing a technical or engineering staffer at work. (A)

There is value, not only in the energy itself, but also in m the technology behindit.

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Third Draf1: 5/28/98 Plant exterior. Transition to lush farming shot, angled to emphasize some verdant y (A) -

Consider the rnany kinds of value from Calvert Cliffs.

Owls, deer, osprey, or bald eagle

.l 7 shot #1. (A) Key work onscreen:

friendly First, like the lighthouse, it is friendly to the neighboring environment. Of the 23-hundred acre property, less than 20% belongs to the plant site.

A tractor makes its circuit. (A)

Nearly 130 acres are farmlands.

Marsh shot. Woodlands shot.

A birdling or beastie peers furtively ,

from the brush. (A)

The rest is marsh ... and woodlands. In fact, the site has been called "the last relatively pristine cliff ecosystem O Tiger beetle beauty shot. (A) left ... on Chesapeake Bay."

It supports about 90% of the world population of the rare " puritan tiger beetle."

BGE people satting up nest boxes and perches or otherwise tending the wilderness. (A)

BGE people have helped. And in so doing, have won praise from the Wildlife Habitat Council ...

Bald eagle winging overhead. (A) -

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... and The Nature Conservancy.. j l

4 5

4

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I Third Draf1: 5/28/98 q revised finni Q

Hikers or walkers on a nature trailat Calvert Cliffs (Preferably, someone has a staff. Option for opening shot to favor feet climbing or walking, for a light play on the word " afoot"in narration. Then open up the shot to emphasize the people and close on their friendly expressions.)(A)

The air is fresh here. And, there's a new trend afoot.

Today, more people who fear global warming ... favor nuclear energy.

(MUSIC: Major transition here.)

Major visual transition. Retum to lighthouse exterior.

l The lighthouse brought a steady living ...

Inside, the hands are now using a -

humble polishing cloth to shine up some metal, glass, or wood.

O ... to those who faithfully tended it.

Montage, Calvert Cliffs people at work, with figures over the blend. (A)

So too, Calvert Cliffs has created thousands ofjobs . .

l and meant hundreds of millions to the local economy.

As the largest private employer in southern Maryland, Calvert Cliffs represents more than $79 million in annual salaries and pays over $20 million each year in

. local taxes.

l - Archive shot in motion of ethnic l- husband / wife, mature (senior) citizens enjoying an active lifestyle (perhaps l golf or tennis course). (A)

I sense of the size and scope of the

complex. (A) i Scripts Unlimited, Inc. + 6 of 12 + Calvert Chffs
A Beacon ofEnergy M:-ME0E40. doc ' Video Script u,
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revised final I: More of the same. Option to add on -

dollar sign icons, sized to represent the 8-fold-plus difference.

Clearly, the plant transcends its role as a generator of electricity; Calvert Cliffs adds value to the quality of life in Maryland.

Archive pix from history files; blended still or motion footage of Calvert Cliffs under construction.

Show dry storage facilities. Add other pix to match. 1 Safety continues to be a priority. BGE has long held to a maintenance standard that far exceeds industry norms.

1 For both equipment and systems, we have aggressively New angle, stearn generator.

For example, BGE has already announced plans to replace both steam generators, to ensure reliability. This -

effort alone means a commitment of $300 million over the next five years. ,

A different scene to suggest size / scope of facility.

Today, the future of this plant is under review.

Key word on screen (CG): j value Aerial of Washington DC's " monument alley," leading to the Capitol. (A) CG j over; l Nuclear Regulatory Commission  ;

(show NRC symbol as well) '

The Nuclear Regulatory Commission requires l

relicensing of any nuclear power plant after the first 40 years of service.

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Third Draf1: S/28/98 revised final lp

' d BGE staffers collating reams of paper into reports. Add generic pix to match.

l And although our deadline is technicallyyears in the I future, we have already started meeting it now. It's a pioneering move. BGE is the first in the nation to request a licence extension.

Mid-level staff meeting on the project, with many notebooks and resources on the conference table.

The commitment required is immense. With an application cost alone approaching $15 million dollars.

Generic pix to match. (Possibly a shot of staffers unloading the application. If so, make sure we see doc cover or .

add CG to explain what's going on.) .

Even so, we can assume nothing. Because relicensing is more than a goal. It's aprocess. With significant opportunities for the public to voice an opinion. And Baltimore citizens at work and play, j

In short, while Calvert Cliffs serves the community, the i community also needs to give at least moral support to this effort ... since the outcome is by no means guaranteed.

Key word on screen: -

future Scripts Unlimited, Inc. 9 8 of 12 + Calvert Clifs: A Beacon ofEttergy i M:-MEDE40 doc Video Script l

Third Draft: 5/28/98 -

Retum to exterior oflighthouse at work.

After all ... what if the light ... went out?

Retum to earlier" throaty hum" scene

. and recraft it to suggest the lighthouse beam going out and its warm voice dying away.

~ Dip to black.

L Nuclear engineer (man). Public relations staff member (woman).

For now, Calvert Cliffs means stability. Security.

Montage with exteriors oflocal hospital, school, retail center. (A) Or. -

Blended diversity shots with many faces. (A) Either way, wrap around it

. with the border of Maryland.

It's a resource worthy of preserving not only for the stakeholders involved, but also for the entire state of O Chris Poindexter and other top Maryland.

executives around a conference table, planning. (A)

- BGE is taking strategic actions to be a good corporate citizen. And to act on this urgent need.

Shot from a meeting involving public response. (Or, pix to match.)

We ask nothing ofyou but your voice.

A person favoring Calvert Cliffs steps

' to the microphone and begins to '

speak. (Or, pix to match.)

If you care about a positive outcome, let it be heard.

(S.O.T. - We hear a few words from the citizen-enough to sense support of Calvert Cliffs-prior to the Daytime serial over Calvert Cliffs.

Our messageis simple.

O Scripts Unlimited, Inc. - + 9 of 12 + Calvert Chffs: A Beacon ofEnergy M:~ME0E40. Doc Video Script e

c Third Draft: 5/28/98 revised final f s

() Blend visuals seen earlier with key words floating over as spoken, especially: alarm clock, high-speed machine, eagle, worPJng people, /

senior couple, child at toy keyboard.

CG:

safe reliable energy friendly value fufure Based on a safe and reliable source of energy . . one that's proven itself friendly to the environment as well as to customers ... Calvert Cliffs nuclear power plant has brought us all considerable volve. And will continue to do so in the future.

Retum to the lighthouse scenes from the opening.

,, (MUSIC: Slow again. We gradually lose instruments, (v ) until only the guitarline remains.)

(NARRATOR:) The lighthouse brought a message of f

security, and yet ... I Match dissolve from a wide-angle, upward shot of the lighthouse to a wide-angle, upward shot of one of the j

nuclear towers at BGE. i

... we cannot take this resource for granted. Together we must make a commitment to preserve the in' vestment.

Preserve the technology. Preserve the value. Preserve thejobs. And preserve the tradition ...

Now, it is not the twilight after sunset, but the twilight before sunrise. We see the same male worker as in the open.

This time, he steps from the bay shoreline up a grassy knoll to approach-not the lighthouse-but instead, Calvert Cliffs.

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'w Scripts Unlimited, Inc. + 10 of 12 + Calvert Clifs: A Beacon ofEnergy M:-MEDE40. DOC Video 8Cript t

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Third Draft: 5/28/98 The camera tracks up from behind him, and then somehow gets ahead of him, and looks back.

... that we know today as Calvert Cliffs.

We see the face now. The nun is Chris Poindexter.

He smiles in a craggy sort of way, and we get the feeling of a steady hand at the helm.

Think ofit as ...

Then, from a daylight serialniw filtered day-for-night to resemble a

- night scene, the image freezes and a

" beacon" effect sweeps in a clockwise motion from the two towers, lighthouse-fashion.

A Beacon of Energy.

Transition to the Atlantic ocean, reliably and safely sending waves upon the shore.

(SFX: Sea gulls.)

Fly on BGE bug logo.

Add copyright information. J (MUSIC: Crescendo.)

Fade to black.

- ((ESTIMATED TRT: 7:10 at 45 seconds per page for 9.5 pages. We factored out page breaks.))

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, e Third Draft: 5/28/98 revised final PRODUCTION NOTES

1. Although all the key words show here in theidentical font as other CG, such as " lower rates," I suggest you give the key words their own unique look and feel in your choice of CG font, to enhance visual continuity.
2. I left the term " puritan tiger beetle" offscreen deliberately, since we already have viewers reading a lot of text. If this causes curiosity among them, so much the better.
3. I think the "x" in NOx is subscript; please confirm.
4. On page 7, I chose to omit the number of years in the future the deadline is [16 to 17],

since I was concerned that it might undermine the viewers' sense of urgency about making their positive comments known. It also allows the speaker to fill in that gap, and protects the shelflife of your program.

5. Anywhere you wish to cut back, feel free. My vision is for this show to be tightly paced and not overly encumbered with details that might detract from the key message.
6. On page 8, I chose not to put the number of $300 million in CG. It's big enough to be memorable, and has already been published in various places.
7. Same page, I hope the "we can assume nothing"line is acceptable. Let viewers feel that they're needed.
8. Feel free to call, any time. I'll be happy to tweak where needed to help you make it great!

I'm out tomorrow afternoon, but should be easy to find Friday and Monday. Good luck!

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