Vermont Legislature SmartTranscripts:

[Rep. Kathleen James (Chair)]: We're live. All right, welcome everybody to the House Committee on Energy and Digital Infrastructure. It is Tuesday, May 12, and we are gonna spend a little bit of time this week, this weekend, next week, about the future of nuclear power from all kinds of different perspectives. So, my name is Kathleen James, and I am from Manchester.

[Rep. R. Scott Campbell (Vice Chair)]: I'm Scott Campbell from St. Johnsbury.

[Rep. Richard Bailey (Member)]: Richard Bailey from Lamoille too. Michael Southworth from Caledonia too. Christopher Howland, Rutland or Bram Kleppner, Chittenden, Burlington.

[Rep. R. Scott Campbell (Vice Chair)]: And Mike Mike? You know the second. Yeah. Oh, yes. Chris? Oh, okay. I was gonna go to. Okay.

[Rep. Kathleen James (Chair)]: All right. And we have representative Chris Morrow joining us online. Alrighty. Paul, for the record, if you could introduce yourself and the organization you represent, and we are ready to discuss your testimony with you.

[Paul Gunther]: Okay. Thank you. My name is Paul Gunther, and I'm here in Tacoma Park, Maryland. Thank you for allowing me to come in and participate virtually. I'm the director of the reactor oversight project at Beyond Nuclear, and I've been engaged in the nuclear issue coming up on fifty years now. My background is that I was actively engaged in the opposition to the Seabrook Nuclear Power Stations construction, which began in nineteen well, it was announced in 1969, but I became involved in 1975. I was actively engaged from there until the ultimate licensing. I also participated in organizing towns in New Hampshire when the US Department of Energy came into the Granite State to characterize the granite crystalline rock for a high level radioactive waste repository for 70,000 metric tons of the nation's nuclear waste. So New Hampshire and Maine were up in the top of the list for that characterization. Although that granite body extends throughout New England. There were 100 towns of 130 that town meeting spring in 1986 that voted to oppose the burial storage, transportation, and production of high level radioactive waste in the state of New Hampshire. And so it was a very good straw poll of the town meetings on how people think about nuclear power and nuclear waste, particularly when confronted with the issue of if you're going to make it, do you want to take it? And so that, you know, we were quite encouraged because the governor at that time was saying that, you know, don't cloud the issue of opposing a high level radioactive waste dump with the idea of, you know, you're gonna we're we're gonna make it at Seabrook and and create a de facto nuclear waste dump on the New Hampshire Sea Coast. So we brought that issue right to the village square. And I was one of the key organizers in that. I've never had an easier time in organizing public opinion as those two years between 1985 and 1986. Ultimately, in 1987, Congress voted the Nuclear Waste Policy Act of 1983, amended in 1987 to cancel the high level radioactive wage search in all but the state of Nevada. And so, you know, there was broad opposition to the idea of where is the legacy of nuclear power going to wind up. And it was a quite stark moment. And Nevada suddenly became the bill, the 1987 amendment bill was forever after recognized as the Screw Nevada bill, because it canceled the search in 11 other states and put the burden on Yucca Mountain, which is cracked with about a dozen earthquake faults. And some of these earthquake faults have volcanic ash running through them. And the entire Yucca Mountain Plateau is surrounded by young volcanoes. So this was never a good scientific choice. But again, the issue of nuclear power has forever been clouded in politics. And in many cases, the whole idea of science, ethics, public concern, they've been subordinated to the development of atomic energy and, at all costs. And, frankly, you know, I'd like to open this conversation and please interrupt me at any point. But, you know, I really, you know, since I've been involved with this now for fifty years, and, you know, I've been everything from, currently I'm, you know, in the education and we're now before the US Nuclear Regulatory Commission. We've got the commission in federal court right now before the US Court of Appeals for the District of Columbia because of the whole issue of license renewal. The 94 nuclear power stations in the country are clearly the most apparent bridge to the future for nuclear power by license extension. These plants are built.

[Rep. Kathleen James (Chair)]: I you talk about license renewals toward the end of your testimony. It'd probably be super helpful for us to be able to walk through your testimony kind of in a systematic so we can see in writing. Remember, you're fifty years ahead of us in terms of background in this issue, and it's a newer topic for most of So I think it would be helpful for probably all of us around the table to maybe walk through your testimony in a more chronological way so we can see your notes and ask questions and follow along.

[Paul Gunther]: Well, let's go to page two. And, you know, you've got a handout from Beyond Nuclear, 10 reasons to reject nuclear power. And I think this is the most concise outline of the reasons that we sort of find ourselves in a situation a lot like the Peanuts cartoon, where Lucy is offering the football to Charlie Brown for another kick. We all know what's going to happen, particularly those of us with some perspective on the nuclear issue. But these 10 items here, basically, we've seen them. We've walked through this scenario many times over through several generations of nuclear power stations. And now we find ourselves again faced with the whole idea of small modular reactors and advanced reactors. And I just wanted to take this time to acquaint the committee with this recurring conundrum that nuclear power for one, nuclear power is just too expensive. We saw it at Seabrook. When I came in to the picture, Seabrook was projected at 900,000,000 for two units. When I left to come work in Washington DC, it was close to $7,000,000,000 for Unit 1 and 900,000,000 were basically squandered on Unit 2, which was canceled. And now New Hampshire has inherited some of the most expensive energy in The United States, certainly within the top 10, maybe top five. But what I'm saying is that regardless of the size, whether we're talking the gigawatt reactor such as Seabrook or the micro reactor or the small modular reactor, all the expert opinion is that it's going to wind up more expensive. And while the modular design, you know, where you have anywhere from one megawatt electric all the way to 350 megawatts. These are all considered either micro or small modular. The problem is is that they are abandoning the whole issue of for Seabrook, the large reactors were built on an economies of scale where, you know, the bigger the reactor, the cheaper the power. Well, that didn't exactly pan out as planned through successive generations. The generation two, which was Seabrook, as well as generation three, which was later on from 2,005 to date. That now we are we're abandoning the concept of economy of scale through the more concrete, the more wired, the more backup, the less expensive it was projected. These SMRs, however, are now looking at where it's going to be you may be able to build them quicker. That's a question in and of itself, which we will discuss. But broad expert opinion that is divided, granted, is that it's going to be more expensive with these smaller reactors per kilowatt hour. So because they're now, you know, basically in a reverse on this economy of scale. So that's that's going to be a problem. We've already seen it play out on paper where the new scale is a new start company out of Washington State with an SMR reactor that was supported by the US Department of Energy. And they were going to they got a free site at the Idaho National Lab to run the pilot. And they were starting with a 50 megawatt reactor and running it through the design process. And Even on paper, got a power purchase agreement with the Utah Association of Municipal Power Suppliers. 50 municipalities in five states, Western states. And so there were about 35 of those municipalities that initially signed PPA and to contract and they started going through the process. By the time they reached 2023, they found that even on paper, a new scale could not control the projected cost. So where their contract recognized that they at least had to have 20% of the six forty megawatts covered by the membership. They didn't even have that. There were exit ramps along the way and the municipalities just kept backing out. The pilot project of the US Department of Energy with the small modular reactor essentially collapsed on paper because of financing and the inability to control cost. The creation of this idea that small modular reactors are going to be, because they're smaller, they're going to be cheaper. We've already seen an example of where Charlie Brown once again has wound up flat on his back going after this football. Nuclear power is going to be too slow. Well, again, over my experience, I've seen generally the projected time of completion has been just as inaccurate as the estimated cost of completion. We've seen some keyhole reactors that were able to get in at or around the projected six years. But generally speaking, have been, particularly on the second generation reactors like Seabrook, they failed by large margins. Seabrook was projected to come on in 1979. It came on in 1990. The record goes to Watts Bar Unit 2, which was construction was the application went in and was granted in 1973, but the plant wasn't actually commissioned until forty five years later for a forty year license. That's your span. And there was a whole host of reactors that were canceled in between almost as many as were applied for half that number canceled, almost half. Again, the failure to both meet time to completion and cost to completion. We're seeing the delays already. Again, these are all pretty much paper reactors right now. None of the designs are absolutely complete, Even though the Nuclear Regulatory Commission is moving forward with construction permits, the designs are still in flux. For example, the reactor by the firm out in Idaho National Labs, another site, actually it's in Wyoming, the Bill Gates reactor for a terra power reactor. They've started construction, but they're using a 10 CFR part 50 under code of federal regulation, which they've got to go through the construction permit that's been granted. They've started. But when they finish construction, then they will make application for an operating license. The NRC has already warned TerraPower the company that it's conditional and they will have to go through some additional completion process before they can be granted the operating license. Through each generation of nuclear power, delayed has played a critical role. We don't expect that to change for SMRs. There was a generation three, for example, that came with the Energy Policy Act of 2005. This was the Bush era. They were going to build these advanced reactors that were commissioned with tax credits, production credits, expedited licensing, everything to streamline the licensing construction, and issuance of an operating permit. Were given a one step licensing process. So one hearing to get both the construction permit and the operating license. That was again part of the streamlining for this generation three. The idea was to provide confidence to the industry to encourage applications and encourage investment. Well, ultimately according to the Congressional Research Service, the Congress used to track this process. There were 35 plus units that were basically the utilities offered up that they would take a chance for 35 units. 12 of them were the Westinghouse AP1000. Of the 35 plus, one reactor was going through the licensing process, but there were five or six reactors that were riding on that one application with the same design. The AP1000 was one of those. Of the 35, only four actually broke ground. In 2007, they were granted their applications. It wasn't the NRC's fault because the NRC granted more than a dozen of these one stop shop licensing processes, again, to encourage the industry. But only four of that 35 plus, they actually went through the groundbreaking and the construction. And only those four managed to do the financing for the construction by construction work in progress. The utilities put their rate payers upfront to finance through monthly utility bills to basically get the construction going. That went on and it went on seven years beyond the completion cost and time to completion for the Vogel three and four units in Georgia. Units 2 And 3 for the VC summer plant in South Carolina canceled with nearly $10,000,000,000 of this advanced payment through construction work in progress that was basically stranded. So the example here again is construction for the advanced designs, construction work in progress was the only way they could get their financing. The rest of the industry just stood around and watched. Even though the NRC issued them operating, the construction and the operating license, they didn't use it because there was no confidence in financing. So Paula, want make

[Rep. Kathleen James (Chair)]: sure that we have a chance to really understand some key parts of your testimony and give members a chance to ask questions as well. So moving ahead, I think it sounds to me like the list of 10 sort of reasons to reject nuclear power is available and put noted on your website. I think I'm going to move through that if that's okay. Members can take a look at that and we can certainly reach out to Paul if we have any questions about the list. I was looking ahead through some of your testimony about small modular reactors And I think that that is something that could potentially be relevant to Vermont's future. Know you're aware that we have a decommissioned site at Yankee, in Vernon, and, we have had, you know, conversations from time to time about whether that would be a site for an SMR. And want to make sure I think we blocked aside forty five minutes for your testimony. And I do want to make sure we try to end on time, and we're we're twenty minutes into it. So looking through

[Paul Gunther]: some I did think that I was gonna have forty five minutes in testimony, but you're saying questions and answers as well.

[Rep. Kathleen James (Chair)]: Well, we can- we can- we don't have- we don't have a hard stuff. We could certainly allow an hour and I know you've spent time preparing your testimony. I just want to make sure we get through it because I was watching the clock and we were on number two of your first section.

[Paul Gunther]: So me just say again that all 10 of those concepts apply to SMRs as much as any design. If you want, we can just look at the issues of the SMRs compared with what the US Department of Energy is promising and what we're likely to see. Is that where we could resume?

[Rep. Kathleen James (Chair)]: Well, I think folks are probably going to have some specific questions on some of your testimony points. I was looking in particular and I wanted to make sure I understand on page two, one of your data points is that SMRs are that the technology is at this point unproven and that there are more than 30 different design reviews or different designs under review. And I wanted to make sure that I understood why that means the technology is unproven. Or are you saying that the designs are still kind of all over the place and it's unclear whether they're going to be approved or I wanted to make sure I understand that point about having 30 different designs under review. Right.

[Paul Gunther]: Well, like I said, we've got construction in progress on designs that have not been certified by the US Nuclear Regulatory Commission. Similarly, there are 11 reactor pilot projects under the US Department of Energy that are incorporated into those 30 plus designs. They've not been approved under the National Environmental Policy Act. In fact, are, with the White House and the Trump administration entering into the process, the whole license review and safety and environmental qualification, those are being truncated. Certainly, let's not just think that we're talking about only SMRs are going to be built. The Trump administration, the NRC and the DOE are also talking about revisiting building the thousand plus megawatt reactors. The fact that the industry and the regulator are proceeding without design certification being completed, there are these gaps both within safety and in their environmental qualification that are not certified, thereby not proven or certainly not provided any scientific consequence or consensus.

[Rep. Kathleen James (Chair)]: Thank you. Representative Campbell you had a question.

[Rep. R. Scott Campbell (Vice Chair)]: Presumably, if one or more of these SMR designs is under construction, it's under construction while simultaneously going through a certification or approval process. I I would assume that. Is that correct assumption?

[Paul Gunther]: Yeah. That is, but, you know, you don't really get the whole picture until the the plant is built.

[Rep. R. Scott Campbell (Vice Chair)]: Sure. Right.

[Paul Gunther]: But again, so it's sort of building the road as you travel is what I'm trying to imply.

[Rep. R. Scott Campbell (Vice Chair)]: It's the

[Paul Gunther]: process that we're going through right now.

[Rep. R. Scott Campbell (Vice Chair)]: I understand. I guess what I wanted to ask though about it was, what are are the companies that are building the road as they're traveling on it? What are they predicting or estimating for a timeline to get approval and get the construction complete? Is it a matter of five years or ten years? Well,

[Paul Gunther]: let me say it's ambitious and history doesn't support that ambition. Right. The

[Rep. R. Scott Campbell (Vice Chair)]: But do you have

[Paul Gunther]: a sense of I

[Rep. R. Scott Campbell (Vice Chair)]: just wanted to ask if you had a sense of what number they're putting on it. Is it Maybe it's three years, five It's

[Paul Gunther]: going to vary. For example, in the short term, for Executive Order 14,300 from the White House says that at least three of these 11 designs that the Department of Energy is licensing. And again, the DOE was never authorized by Congress to do commercial operating licenses, but they are under the Trump administration. But the Trump order said that by 07/04/2026, that three of the pilot reactors will have already demonstrated criticality by going critical. The reactor that's under construction in Parsons, Kansas, It is a 15 megawatt SMR. They're drilling a borehole a mile down, and the reactor will go down into the borehole. That was one of the reactors that the Trump administration said would it was chosen to be one of the reactors that would be the pilot would be able to go critical on July 4 as some kind of fireworks celebrating the 200, they're using nuclear power stations and completion. That was a short term view of a pilot project demonstrating criticality. Well, that's not going to happen. It's already slipped into 2027. You need to take any projected time to completion with a grain of salt because they are notoriously inaccurate.

[Rep. R. Scott Campbell (Vice Chair)]: Another question which is about relicensing existing plants and you addressed that at the end of your testimony here on page nine. It has always seemed to me that that would be the quickest way to to include, nuclear and consideration of of of, carbon free, quote, unquote, power. It's the quickest way to add nuclear capacity to our, what we think of as carbon free power. But you make a number of points about why it's not a good idea. I wonder if you could talk about that a little bit.

[Paul Gunther]: Yeah. Well, we're engaged in this. Again, the whole issue of relicensing is we're waiting for an opinion right now from the DC Circuit appellate court because the entire licensing process for that includes the new licensing for these SMRs and the pilot projects for under both the NRC and the Department of Energy, they do not include an environmental review for climate change. You know, we've got seven reactors before the US Nuclear Regulatory Commission that denied beyond nuclear and the Sierra Club a hearing on what are the impacts going to be of relicensing a nuclear power plant that's already been operating for forty years. They're in their forty to sixty license renewal period, and they're asking for an application for sixty to eighty. So we captured in a corral before the DC circuit court that there are these reactors that are asking for operating licenses out to 2053. Well, climate change is an issue certainly by then, but they never projected things like sea level rise. They never projected anything like atmospheric rivers that can cause torrential rain, unprecedented rain that you've seen there in Vermont. But everywhere, anywhere and everywhere, climate change is a it's, you know, best science evaluation right now, but it's coming. Yet the US Nuclear Regulatory Commission is driving its re licensing process like you would a car through your rear view mirror. They don't know what's coming. They are basing their licensing qualification, their environmental qualification on climate change by reviewing what's been the past. That's no longer relevant with climate change. And yet we've had to go to the US Federal Court because the NRC is telling us that climate change is out of scope. That's what we have the NRC before in federal court challenging the notion that climate change is out of scope, that they can deal with it on the robust margin that was built in the original zero to forty year license that got a review for the forty to sixty. Again, it did not include any kind of projection on climate change or the future. But they say that they can deal with it on a day to day licensing manner. But as far as the public's due process, the licensing hearing process is the only opportunity for stakeholders, including state government, to come in and make a challenge on what are in fact best science issues right now? Climate change is coming. It's going to be dramatic. It's getting worse. It's coming faster than we've ever imagined or that our current models reflect. But it's not being incorporated into the nuclear licensing process. This is for this SMRs as well.

[Rep. R. Scott Campbell (Vice Chair)]: Yeah. I mean, that sounds like a serious issue.

[Paul Gunther]: That's the key issue.

[Rep. R. Scott Campbell (Vice Chair)]: Yes. But I guess I wonder, are there other how to put it maybe more mundane or more procedural or more technical issues with relicensing, what are kind of aging plants beyond their original license periods?

[Paul Gunther]: Yes.

[Rep. R. Scott Campbell (Vice Chair)]: There are other concerns. Yes,

[Paul Gunther]: and a major concern. Actually, I'm going to be before the New York Decommissioning Oversight Board on June 18 to testify on the fact that they want to get the Indian Point nuclear power stations relicensed. They're decommissioning, but these two plants, Point two and three, Holtec International wants to get them back online. They're cutting up parts like the reactor pressure vessels for two and three have been taken out of the segment and they're going to put new reactive pressure vessels in before they restart. It's multi billion dollar refab, but they're not going to pull 1,200 miles of electrical cable out of those plants. The original electrical cable, they licensed it for zero to forty years, that provides the power for safety systems, control operations, surveillance equipment. That wiring is just too intrinsic to the construction. But we found a report that was commissioned by the Nuclear Regulatory Commission in 2015 that asked Pacific Northwest National Lab to look at what were the conditions and criteria for license extension and the role of, simply put, the need to do autopsies from decommissioning. So you get a decommissioning plant, you're taking apart, why not go in there and take segments of electrical cable and run it through a test like you would an autopsy to see how much safety margins left or samples of metal welds internals. The PNNL report, we pulled it out of it was on three different scientific websites, the DOE website, the International Atomic Energy Agency website, and the PNNL website was also in the one of the congressional libraries. We raised questions about it in a meeting before the NRC. And they said that report didn't, they never approved it. Even though it was published on government websites, the NRC hold it from those government websites. Report said that those autopsies should be required. Because the NRC saw it as problematic to facilitate license renewal, license extensions quickly, they pulled a scientific report. There was no watermark on there as draft. The IAEA, the International Atomic Energy Agency, which is, you know, around the world, this report was public for nine months. And generally speaking, report identified that there are numerous knowledge gaps. And when the NRC republished that report PNNL twenty seven thousand one hundred twenty they had scrubbed it of any reference to requiring autopsies and they scrubbed it of any references to gaps so gaps the word gap was just taken out. Then they republished it in April 2019, two years after it had been public for nine months. All that was gone. PNNL twenty seven thousand one hundred twenty Rev. Nine doesn't mention gaps and it doesn't mention requiring autopsies or harvesting as it was referred to. So again we're in the DC circuit to basically argue that not only are they not looking at reasonable issues that include climate change, but also include age related degradation that can reasonably be recognized as needing to be scrutinized, particularly under the hard look that the National Environmental Policy Act requires.

[Rep. Kathleen James (Chair)]: Paul, I want to make sure I understand the significance of some of the executive orders. I'm on pages six and seven now. Sounds like two of the EOs are, your organization has been especially engaged with two of the EOs, and I want to make sure I'm understanding the impact of them. So the 14,300 is the one that you mentioned earlier, I think, that basically directs the mandates to NRC to accelerate the deployment of reactors by cutting barriers, setting those strict twelve to eighteen month licensing deadlines that you talked about earlier, and then revising the safety regulations. And then we have one that changes fourteen three zero one that changes the reactor testing at DOE. And so can you just remind me? I so is it what what was the previous role of DOE? Testing long standing

[Paul Gunther]: role. Research reactors. Take it So, you know, the the DOE the DOE, when okay. Going back to the Atomic Energy, Commission, It was abolished in 1974 by the Energy Reorganization Act. It divided the Atomic Energy Commission into two separate agencies, the Nuclear Regulatory Commission, which would have authority over commercial reactors, licensing oversight enforcement. And then it established what would eventually become recognized as the US Department of Energy. But the DOE that was set up to do the research and testing, but to remove them and also promotion. DOE was basically established to do public relations, but they were not authorized to do commercial licensing. Well, 14400 gives them the right to do commercial operating license oversight. 14300 essentially also incorporates the DOE and into oversight of the NRC. So the NRC, which was originally an independent agency, is now, you know, they got visited by DOGE, the Department of Government Efficiency under the Trump administration. And they had large staff reductions, not through layoffs, but just through demoralization. People left the NRC. And DOGE had set up an office in the NRC executive office. And Doge did not report to the NRC. Doge reported to the White House and to the Department of Energy. So there active engagement to subordinate and in big concern to remove the independence from the US Nuclear Regulatory Commission. Again, they established a complete rewrite of energy regulations developed over fifty years into eighteen months.

[Rep. R. Scott Campbell (Vice Chair)]: So,

[Paul Gunther]: you know, that's unrealistic. It's, and it's, it's more like sabotage, than it is, any kind of, reform.

[Rep. Kathleen James (Chair)]: So that see that 10 state attorneys general have filed comments on these executive orders. Is that that something that we I mean, our attorney general has been very active in pushing back against the Trump administration. And I'm curious to know whether it sounds like they've submitted comments about these EOs. Is that the same as filing suit? Can these be overturned in court?

[Paul Gunther]: No. It's we have think I included my last email to you, included that we put a press release out yesterday. There were some New England groups that signed on with Beyond Nuclear and Nuclear Information Resource Service. We're both here in the DC area, but there were some Massachusetts groups that signed on. Again, the whole idea of laying the groundwork by entering into comment that gives you standing to file suit. These 11 attorneys general filed comments, even though, again this DOE notice was not a rulemaking. They never asked for public comment. They never even told the public what they were doing. So we saw the Federal Register notice as a fait accompli that it was effective. It was the Federal Register notice was issued on 02/02/2026 and effective 02/02/2026. So again, the DOE has stepped out of bounds. And again, this is for the Administrative Procedures Act, NEPA. And that's what the attorneys generals are saying is that the executive orders gave permission for these federal agencies just to step out of bounds legally. That should raise alarms. It certainly has with us.

[Rep. Kathleen James (Chair)]: I have a question too I wanted to return representative Campbell was asking about the licensing and on the last page of your testimony you talk about the relicensing and I want to make sure I understand there. Had heard some testimony last week from our senator, Peter Walsh's staff. He's introduced a bill that he's introduced, I think, many times about nuclear decommissioning and some related topics. And one thing that I had asked was about the when do existing nuclear reactors kind of age out? How long do their licenses last? What does that process look like? So I'm seeing on the last page of your testimony something that I don't think we had heard from Senator Welch's staff, unless I just missed it, that it sounds like NRC right now is sort of proactively It sounds to me like you don't wait until the license is up. In your testimony, it makes it sound as though they're sort of proactively moving through the fleet of existing nuclear reactors and issuing multi decade license extensions. Am I understanding that? Or could you talk a little bit Well, more about

[Paul Gunther]: the NRC regulations provide that a licensee can submit an application for license renewal for a twenty year license extension twenty years in advance. The expiration date. The claim is that there is some legitimacy to the claim that an operator cannot necessarily wait until the, well they can't wait until the license expires to put in an application. The review process is just too complicated. Transparency and due process, the public wants an opportunity to review and to make comment, to research before an application can be approved. But twenty years, we've said that's extreme and that more likely five years. I mean, a lot can go on in terms of aging in twenty years, corrosion. Right now, one of the knowledge gaps as I was referencing earlier is particularly in dissimilar welds. Welding material and the base metal that you're welding two parts together, they're different and there's different chemistry there. In the harsh operational environment of a nuclear power plant, pretty much neutron bombardment will change chemistry. It will change the ductility in metal so that no longer becomes brittle. It no longer has the flex to go from super hot metal at 600 degrees Fahrenheit to introducing cold water for emergency core cooling system. With aged metal with wells, contrast could break glass. If you put a wine glass in an oven and filled it with water, it would shatter. You can do the same thing to metal under accident conditions. The embrittlement rate that's a knowledge gap. How quickly does this metal, when does it initiate and how long does it take to surpass the safety margin? Same for cracks. How long does it take for a crack to appear? How long does it take before that initiation till it gets to component failure? That's a big gap right now. That's what we were asking the NRC to talk about when they talk about giving these license extensions and the public no longer has the opportunity to get standing and to expert and interview their expert, we get one shot.

[Rep. Kathleen James (Chair)]: I wanted to ask you about that. If any nuclear reactor has been licensed, so let's say they're halfway through a forty year license, what opportunity, if any, would there be to examine the safety record of their plant or to contest the licensing? Know, would there have to be an accident? I I don't really know how that works. So Right. Well, again,

[Paul Gunther]: we're concerned about the transparency. Terrified of what's going on right now to take away what transparency the inner Sea does provide. That's disappear. About And the NRC, again, I work with NRC. We have mutual respect from NRC and the public interest community because there is in fact a conscience in that agency. They have a code of conduct. They have a Hippocratic oath that do no harm to the public. That's shifting remove commissioners and staff, heads of departments that have been identified as risk averse. They're removing people that think too much about the risk to the public. And they're giving more leeway to those heads, states, commissioners that are promoting getting it done in twelve months. K. And and so, you know, that's so right now, you know, typically, when an application is submitted for a twenty year license, we get from the point of the NRC saying this application has enough information that we can put it in front of the public for their review and comment, we get sixty days take what is ready to go and under the NRC, what's ready to go, we get sixty days to comment within the window to raise contentions. Great. Representative Bailey.

[Rep. Richard Bailey (Member)]: Yeah, I'd like you to give me some, why you're thinking that the SMRs are going down the same cost road that the big nuclear plants are going. I thought, not that I know a lot about it, I thought these were supposed to be cheaper to be built, get online faster than those very big huge plants like Seabrook. And even though you're saying the cost of of nuclear is not correct or whatever we're seeing, it seems to me that Yankee's percolating right along, been percolating right on on the base load for many, many years.

[Paul Gunther]: Well, the figures are they're not the the the SMRs and the gigawatt reactors are, the cost concerns are different in that the cost isn't going to be, of course it's less expensive and quicker to build a smaller plant. But again, it goes back to this idea of what's the difference between what do you lose in terms of print the principle of economies of scale for large reactors that you don't get for small reactors? It's going to be in terms of that you're going to get less electricity out of the small reactor and you're going to need more of those reactors to get the equivalent that you would get out of the large reactor. Yet you're going to lose the economies of scale per kilowatt, it's transposing the overall cost with the amount of electricity that you're going to get out of it when it does operate is going to be more expensive. I can follow-up with some supplemental information to help clarify that. But there is a basic difference between the original generation one reactors. These were small reactors, Yankee Row in Western Mass decommissioned, but it was 180 megawatts. They quit building those because they determined that it was no longer economical to build a small reactor to meet the demand. They went to this whole principle of building on economies of scale and it went from 180 to 1,100 or 600 or Vermont Yankee, what was that six eighty or something close to that? But the idea was, again, competition between economies of scale and this economy of scale, it's dollar sign is on the cost per megawatt or kilowatt hour.

[Rep. Kathleen James (Chair)]: Obviously Great. Testimony is posted on our website and we'll we'll post any subsequent material you wanna send. I think we've kept you for an hour, which we really appreciate the time for the conversation and the time you spent on the written testimony and the footnotes as well. It's really helpful. Do committee members have any final questions for Mr. Gunther before we let him go about his day? Okay. Thank you. Paul, thank you so much for joining us. Please send along any supplemental information you have and we'll make sure that I'm not sure if I saw your additional material that you sent. You said you had sent a press release as well. We'll just we'll make sure it's all posted.

[Paul Gunther]: No. I'll I'll send it again, but I I think that Alex has it.

[Rep. Kathleen James (Chair)]: Great. Okay. Thank you so much for your time. Yeah. We really appreciate your expertise and appreciate your time.

[Paul Gunther]: Good luck.

[Rep. Kathleen James (Chair)]: Thank you so much. Bye bye. And, I think that we are back at 09:00 tomorrow. Although, maybe we should stay live for a minute and look ahead at the agenda. So, let's see. Tomorrow, we have one more witness coming in from which is our decommissioning citizens advisory panel. She's coming in at nine. I have reached out to Commonwealth, which is a company that the fusion company that a couple of our members toured in mass. Alex, have they gotten back to us yet? Like, if you could follow-up, that'd be great. Then 07:10, that is our single plant build. And I think that they are adding some language to that that I haven't had a chance to look at yet, but I think that we should expect H710 to come back to us. And so it's great that Ellen's gonna come in tomorrow, let's counsel, and give us a little heads up on how they might have changed the bill since we passed it out. So that's single plan. Did they vote on it in the senate? No. They're working still working on it in natural resources. Okay. So they can send that back to us without without having more idea about it? They could, but I think they're changing the bill. So that's that's what I'm saying. I think that's in yeah. Seven ten is in natural resources. I just got an email that I haven't had a chance to read yet that says they're changing the language. So that indicates to me that senate natural resources is planning on voting it up, which means it'll go to the senate floor, which means it'll probably make its way back to us. And so it's what I'm trying to do this week is make sure that we have a heads up on anything that act is actually, like, live and coming back to us. So it sounds like h seven ten is still alive, probably heading to the Center Floor, which means it could be coming our way. So we had scheduled

[Rep. Richard Bailey (Member)]: So these are some of the changes that you're thinking about?

[Rep. Kathleen James (Chair)]: We're looking at it from us? Yeah. Or it could be all changes there. I I'm just trying to, like Yep. Ahead to what bills are not dead and make sure that we're staying abreast with what changes might be happening in the Senate. So 07:10, I think is live. I think they're making changes. So I tried to line up a walk through and testimony ahead of time. So we'll see how that works. We had a request from rep Southworth to learn a little bit more about some, like, next gen biomass. Companies over Maine, they're coming in on Thursday. H 73. Dara, do you know what's up with that? I don't think I'm doing good. Okay. I think I hit a speed bump in the Senate. Okay. Probably not like it's there. Okay. We'll So we may hear from I may ask Maria to come in anyway and tell us what happened. Tell us what happened. That's good. Yeah.

[Rep. Richard Bailey (Member)]: What date? '73.

[Rep. Kathleen James (Chair)]: That's disconnection. '53? Yeah. Oh, 07:53. Mhmm. Well On Thursday. I'm on Thursday at ten now. That bill may not make it across that may not make it back to us, but at least we'll get a heads up from Maria about how it might be changing or what happened. And then data centers, I think, is definitely coming back to us, and I wanna make sure that we are ready to know what the heck is going on with that bill. So we've got testimony on Thursday about that. Then, of our other bills, nine forty, that was our miscellaneous PUC bill. That passed the Senate, and I think it's on its way to the governor. Seven eighteen, which representative Campbell mentioned on the floor today. I think that's dead. Then we talked about 07/27. We're anticipating getting back. It is still alive. That's data centers. Seven fifty three, maybe on life support. Seven forty was that's the greenhouse gas inventory that was passed out by natural resources and is probably on the floor. I haven't looked yet, but that's probably heading to the governor. 898, copper to fiber is struggling to live in senate finance. 710, we just talked about. Those are our bills. So stay tuned. Alright. I see.