1. Pilgrim Will Close By June 1, 2019 Decommissioning 101 Mary Lampert Pilgrim Watch Town of Duxbury Nuclear Advisory Committee July 2016

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3. OVERVIEW 3

4. What is Decommissioning? Most people assume decommissioning Pilgrim will include: Removing all radioactivity Dismantling and removing the reactor Safely storing spent fuel and other wastes until they are eventually moved off-site Removing any contaminated soil Restoring the site to its original condition 4

5. NRC’s Decommissioning Definition much narrower- removal residual radioactivity The NRC’s definition - Title 10 of the Code of Federal Regulations, Section 50.2 (10 CFR 50.2): “The safe removal of a facility from service and reduction of residual radioactivity to a level that permits termination of the NRC license.” Rule restricts use DTF to “reduction residual radioactivity”- not spent fuel management, site restoration, or demolishing non- radiological structures 5

6. What is Residual Radioactivity- according to NRC & the State? Radioactivity in structures, materials, soils, groundwater, and other media at a site -excluding background radiation, fallout from weapons tests or other reactor accidents When is the Radioactivity “Significant”? NRC: 25 mrem (0.25 mSv) per year - total includes doses from groundwater sources of drinking water, if site to be used unrestricted use; 100 mrem/yr -500 mrem if site restricted use. Less if State has more conservative standard Is Massachusetts’ standard more conservative? 6

7. NRC Has Three Decommissioning Options 1.Decontamination (DECON) Structures and components contaminated with radioactivity are either cleaned, or removed and shipped to a licensed radioactive dump site 2.Safe Storage (SAFSTOR) The facility is placed in nuclear limbo for up to 60 years for later decontamination 3.Entombment (ENTOMB) The facility is basically covered over in cement and left forever. 7

8. ECONOMICS Is there enough money? If not… what will happen and who will pay? 8

9. Pilgrim will choose SAFSTOR – Insufficient Funds for DECON Pilgrim’s Decommissioning Trust Fund (DTF) has $870 million (09/15) Entergy estimated that it would cost $1.243 billion (2014 dollars) to decommission Vermont Yankee (VY) - VY is smaller than Pilgrim. Entergy’s Pilgrim DTF now contains at least $346.58 million (if work started today), and perhaps billions, less than will be needed NRC hopes DTF investments will grow more than increased decommissioning costs, but… NRC estimates DTF will grow 3.5% to 5% above inflation NRC estimated decommissioning costs will increase 5% to 9% annually 9

10. How big will the shortfall be? 10

11. Decommissioning Trust Fund Investments Fall Behind Escalating Decommissioning Costs Assumptions: (a) NRC’s 2% investment growth; (b) 1.5% (rather than 3%-6%) growth in decommissioning costs; and (c) this does not factor in Entergy dipping into the DTF for purposes other than radiological decommissioning. 11

12. Why isn’t there enough money in the DTF? 1.DTF only covers removing radioactivity-a fraction of the job 2.DTF only represents cost of decommissioning today 3.NRC’s assumption DTF will grow through investments to make up shortfall-unrealistic 4.Entergy will raid fund leaving less to grow – example, Vermont: Spent Fuel Management- $225 million Property Taxes -$1.2 million Emergency Planning & Insurance-$5.4 million Legal & Lobby Fees 12

13. Will Entergy Fund the Shortfall? Pilgrim is a Limited Liability Company (LLC) 13

14. Entergy told Vermont Legislators it has no responsibilities past the 60 year Safstor period 14

15. PROTECT OUR WALLETS Support Amendment 37 to Energy Bill Establishing funding for postclosure activities Requires any commercial nuclear reactor in the Commonwealth, to pay annual $25,000,000 post-closure funding fee – if decommissioning does not occur within 5 years post closure - to help insure taxpayers won’t have to pay. Fee placed in trust fund in office of the State Treasurer. After reactor completely decommissioned, any excess in fund returned to the plant owner, with interest. Status: Energy Bill’s Conference Committee 15

16. Will Entergy Fund the Shortfall? Pilgrim is a Limited Liability Company (LLC) 16

17. SAFSTOR Impacts of Delayed Decommissioning Delays economically productive use of site Property values nearby remain depressed Contamination onsite - not identified and cleaned up - providing opportunity for contamination to spread – both on and offsite Workers with specific knowledge of spills and other specific problems will have retired - reducing likely effective cleanup Offsite emergency planning will be eliminated after operations cease - placing unfunded burden on state and local communities Contributions to the state for environmental monitoring also likely will be eliminated - placing unfunded burden on Mass. taxpayers 17

18. SITE RESTORATION Will the site be cleaned up? If so, when and who decides how clean is clean? 18

19. Site Restoration NEPA analysis not required Instead Post Shutdown Decommissioning Analysis Report (PSDAR) must discuss why environmental impacts associated with site’s decommissioning activities have already been addressed in previous environmental analyses. Otherwise, licensee must request approval of the activities and submit to the NRC details on the additional impacts of decommissioning on the environment. Site characterization submitted at least 2 years before license termination 19

20. How Clean is Clean?  Release site unrestricted use: 25 millirem per year total effective dose equivalent to an average member of the critical group -limit includes the dose from drinking groundwater  Release site restricted use: –100 or 500 millirem for restricted use.  Does MA require site returned to unrestricted use? 20

21. Site Restoration (Continued) Are all structures onsite removed? No What is removed? Major radioactive components, such as the reactor vessel, steam generators, or other components that are comparably radioactive are removed Structures removed to 3 feet below grade 21

22. Site Restoration (Continued) Rubbilization: Removal all equipment from buildings; Surfaces decontaminated; Above-grade structures demolished into rubble - buried in the structure's foundation below ground; Site surface then covered, regraded and, landscaped for unrestricted use. Not prohibited in MA- Should it be; and how to prohibit it? 22

23. SPENT FUEL MANAGEMENT Spent Fuel Safety Our No. 1 Concern Fuel will be here for decades- perhaps indefinitely 23

24. SPENT FUEL- No Forwarding Address 24

25. Concerns during Decommissioning Didn’t sign up to be a long term nuclear waste dump- but that is the reality NRC’s Nuclear Waste Rule Allows  Spent fuel can stay in either the pool or in dry casks for 60 years  During the subsequent 300 years, spent fuel assemblies may be kept in dry casks onsite – changing pad and casks every 100 years 25

26. PILGRIM’S SPENT FUEL POOL 26

27. Pilgrim’s Spent Fuel Pool The Problem Location: Pilgrim’s pool is located in the upper floor of the reactor, outside primary containment with a thin and vulnerable roof overhead. Crowded: Pilgrim’s pool was designed to held 880 used fuel assemblies; it now holds 3,279 Fire: If pool loses water simply to the top of the assemblies, a pool fire can occur releasing radiation 27

28. CONSEQUENCES FIRE IN SPENT FUEL POOL Health and economic consequences comparable to those caused by an accident at an operating reactor, including displacement > ten million people; hundreds of billions of dollars in damages; hundreds miles downwind contaminated. These risks could be reduced by transferring spent fuel to dry casks- which are more resilient against accidents or attacks- and by returning U.S. spent-fuel pools to open-frame, low­ density configurations, which have a lower risk of fire. Both options would also avoid concerns raised at the Pilgrim where reports show deterioration of neutron-absorbing materials that has increased the risk of an uncontrolled nuclear reaction in the densely packed spent-fuel pool. References: National Academy of Sciences, Lessons Learned from the Fukushima Nuclear Accident for Improving Safety and Security of U.S. Nuclear Plants, Phase 2 (Washington, D.C.: The National Academies Press, 20 16); Technical Study of Spent Fuel Pool Accident Risk at Decomm issioning Nuclear Power Plants," Nuclear Regulatory Commission, NUREG- I 738, January 200 I, http://pbadupws.nrc.gov /docs/MLO I 04/MLO I 0430066.pdf.http://pbadupws.nrc.gov /docs/MLO 28

29. DRY CASK STORAGE- SAFER SOLUTION 29

30. DRY CASK STORAGE Fuel cooled in the spent fuel pool for > 5 years after being taken out of the reactor can go into dry casks Each cask can hold 68 spent fuel assemblies Each cask weighs 392,281 lbs. when placed on pad Casks cost about $2 million each Existing storage pad can hold 40 casks. Entergy will need an additional pad to empty the pool 2015 -(3) casks on pad – 2016 (5) more will be added 30

31. DRY CASK STORAGE SAFETY ISSUES Dry cask storage is far safer than pool storage, but there are problems… According to the Nuclear Regulatory Commission (NRC) The thin (0.5”) stainless steel canisters may crack within 30 years. No current technology exists to inspect, repair or replace cracked canisters. With limited monitoring, we will only know after they leak radiation. Each dry cask will contains ½ as much Cesium-137 as the total released at Chernobyl 31

32. Security - Pilgrim’s Plan “Candlepin Bowling for Terrorists” 32

33. WEAPONS AVAILABLE TODAY Cask Shell Canister = 0.5” (1.3 cm) Cask Concrete Wall = 26.75” (68 cm) 33

34. Cask Shell Canister = 0.5” (1.3 cm) Cask Concrete Wall = 26.75” (68 cm) 34

35. Solution: Safer Dispersed/Hardened Dry Cask Storage- Literally, Dirt Cheap 35

36. Alternate Security Solutions Casks in Reinforced Concrete Building; Submerged Casks, Holtec-Hi- Storm U ( plus-security, con- unable inspect); Blast Shield 36

37. Dry Cask Storage Pad & LLRW Located Close To Bay Vulnerable to Coastal Storm Damage Flooding, Surge, Sea-Level Rise, Salt Water Degradation 37

38. Pad Located Close To Reactor Building Will it i nterfere with dismantling reactor building ? 38

39. BASIC PRINCIPLES TO PROTECT OUR COMMUNITY Entergy pay for decommissioning in full, not the Commonwealth’s taxpayers –Pass Amendment 37 to Energy Bill Decommissioning occur ASAP following closure - not defer dismantlement/cleanup for decades Spent nuclear fuel assemblies moved out of the pool and into hardened dry casks as soon as possible Offsite emergency planning retained until spent fuel pool is emptied and, on a reduced level, until fuel leaves the site - Entergy shall continue to provide funding MDPH continue and expand its offsite radiological monitoring and onsite tritium monitoring - Entergy continue provide funding 39

40. BASIC PRINCIPLES (Continued) Site returned to “greenfield” for unrestricted use - radioactivity and chemical contamination cleaned up Council on Decommissioning established upon closure that includes representatives from: pertinent state agencies, elected officials from Plymouth and Barnstable Counties; and citizen from impacted communities - open process with open public meetings- Pass Amendment 103 - Energy Bill Workers: skilled workforce retained; job training provided 40

41. Conclude… Support Amendment 103 Energy Bill Feasibility Study -Messrs. Tarr, deMacedo, Wolf and OConnor moved that the bill be amended by inserting at the end thereof the following:- "SECTION_. (a) There shall be a Pilgrim Nuclear Power Station decommissioning advisory panel. The advisory panel shall ensure best practices, engage citizens and advise state and local officials and residents on matters related to the decommissioning and postclosure activities of the Pilgrim Nuclear Power Station. The advisory panel shall be convened not later than the date a written certificate of permanent cessation of operations at Pilgrim Nuclear Power Station is submitted to the Nuclear Regulatory Commission. The advisory panel shall consist of the following members: the attorney general or a designee, who shall serve as chair; 1 member of the senate; 1 member of the house of representatives; the commissioner of public health or a designee; the commissioner of environmental protection or a designee; the chair of the department of public utilities or a designee; the director of the Massachusetts emergency management agency or a designee; the executive director of the Old Colony Planning Council or a designee; the executive director of the Cape Cod commission or a designee; 1 person appointed by the board of selectmen in the town of Plymouth; 1 person appointed by Entergy Nuclear Generation Company; the president of the Utility Workers Union-America local 369 or a designee; 2 persons who shall be members of the public, 1 to be appointed by the president of the senate and 1 to be appointed by the minority leader of the senate, 1 of whom shall reside within the emergency planning zone surrounding Pilgrim Nuclear Power Station, but not in the town of Plymouth; 2 persons who shall be members of the public, 1 to be appointed by the speaker of the house of representatives and 1 to be appointed by the minority leader of the house of representatives, 1 of whom shall reside within the emergency planning zone surrounding Pilgrim Nuclear Power Station, but not in the town of Plymouth; 2 members of the public to be appointed by the governor, at least 1 of whom shall reside in Barnstable county; and 1 person with expertise in decommissioning and post-closure activities appointed by the attorney general. The advisory panel shall invite the Nuclear Regulatory Commission to appoint a designee, who may serve ex officio. Vacancies on the advisory panel shall be filled by the appointing authority. (b) The advisory panel shall: (i) hold annual public meetings to discuss issues relating to post closure activities; (ii) advise the governor, the general court, executive agencies and the public on issues related to postclosure activities; (iii) serve as a conduit for public information and education and encouraging community involvement in matters related to postclosure activities; (iv) receive reports on the Decommissioning Trust Fund as defined by the Nuclear Regulatory Commission and other funds associated with post closure activities, including fund balances, expenditures made and reimbursements received; (v) receive reports regarding postclosure activities, including site assessments and postclosure decommissioning reports, providing a forum for receiving public comment on assessments and reports and providing comment on these assessments and reports as the advisory panel deems appropriate to state agencies, interested stakeholders and the owner of the Pilgrim Nuclear Power Station; (vi) post all documents related to decommissioning and postclosure activities promptly on a publicly accessible website; and (v) file a report annually with the clerks of the senate and house of representatives who shall forward the report to the governor and to the chairs of the joint committee on telecommunication, utilities and energy. The advisory panel shall cease operations when the site is released to the public for unrestricted use or upon a majority vote of the members of the advisory panel that the advisory panel has served its purpose and its continued existence is no longer necessary. 41

42. Conclude… Support Amendment 37- Energy Bill Prompt Decommissioning -Messrs. deMacedo and Wolf, Ms. Gobi and Mr. OConnor moved that the bill be amended by inserting before section 1 the following section:- “SECTION A1. Chapter 10 of the General Laws is hereby amended by adding the following section:- Section 76. (a) For the purposes of this section the following words shall have the following meanings unless the context clearly requires otherwise: “Affiliate”, a business that directly or indirectly controls or is controlled by or is under direct or indirect common control with another business including, but not limited to, a business with whom a business is merged or consolidated, or which purchases all or substantially all of the assets of a business. “Decommissioning”, closing and decontaminating a nuclear power station and nuclear power site including dismantling the facility, removing the nuclear fuel, coolant and nuclear waste from the site, releasing the site for unrestricted use and terminating the license; provided however, that, for the purposes of this section, SAFSTOR is not decommissioning. “Nuclear power station”, a commercial facility that uses or used nuclear fuel to generate electric power. “Post-closure”, the period beginning when a nuclear power station has ceased generating electric power and ending when the nuclear power station and station site have been completely decommissioned. “Post-closure activities”, the activities at or in connection with a nuclear power station and station site during post-closure including, but not limited to, moving spent nuclear fuel into dry casks, job training, site and environmental cleanup, off-site emergency planning, SAFSTOR and decommissioning. (b) Each nuclear power station shall pay an annual post-closure funding fee of $25,000,000 if the station is not fully decommissioned within 5 years of the time the power station ceases generating electric power. The fee shall be assessed by the executive office of energy and environmental affairs annually on the owner or affiliate of each nuclear power station on March 1 and shall be paid to the state treasurer for deposit into the Nuclear Power Station Decommissioning Trust Fund established in subsection (c). The fee shall be paid until: (i) the nuclear power station is fully decommissioned as required under regulations promulgated by the United States Nuclear Regulatory Commission; and (ii) the executive office of energy and environmental affairs issues, after notice and an opportunity to be heard, an order finding that post-closure activities have been completed. (c) There shall be a Nuclear Power Station Post-closure Trust Fund. The state treasurer shall serve as trustee of the fund and shall make expenditures from the fund to support decommissioning measures including: (i) payments for not less than 1 post-closure activity completed at a nuclear power station site, but only after the money in a federal decommissioning trust fund is exhausted; and (ii) payments to a person or entity named in an issuance of authorization from the executive office of energy and environmental affairs stating the amount to be disbursed and the completed post-closure activities to which the amount applies. The fund shall consist of: (i) the fee collected under subsection (b); and (ii) the interest earned on the money in the fund. Amounts credited to the fund shall not be subject to further appropriation and money remaining in the fund at the close of a fiscal year shall not revert to the General Fund. (d) The executive office of energy and environmental affairs shall not issue authorization for payment except upon the receipt of: (i) an affidavit or declaration, executed by an entity or person responsible for completing the relevant post-closure activity at a nuclear power station under the pains and penalties of perjury, identifying completed post-closure activity with respect to which a disbursement is requested and setting forth facts establishing that each such activity has been completed and the costs incurred by the nuclear power station owner with respect to each such activity; and (ii) verification of the facts in the affidavit or declaration by the executive office of energy and environmental affairs or another appropriate state agency. The secretary of energy and environmental affairs shall determine the appropriate form, content and supporting information necessary for the affidavit or declaration. Money disbursed under this section in reliance on a false certification to the secretary of energy and environmental affairs may be recovered from the entity or person receiving the disbursement, with interest, through an action by the attorney general. A false certification shall be subject to section 5B of chapter 12. (e) The balance of the Nuclear Power Station Post-closure Trust Fund shall be returned to the owner or affiliate of the nuclear power station upon the issuance of an order, after notice and opportunity for hearing, finding that the post-closure activities at the station have been completed by the executive office of energy and environmental affairs.”; and by inserting after section 18 the following section:- “SECTION 18A. Section A1 shall take effect on January 1, 2017.”. 42