ML021260542
| ML021260542 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/30/2002 |
| From: | Smilan S - No Known Affiliation |
| To: | Masnik M NRC/ADM/DAS/RDB |
| References | |
| 67FR9333 00002 | |
| Download: ML021260542 (6) | |
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'I P.O. Box 740606 Boynton Beach, FL33474-0606 Phone number. (561) 432-3282 Fax number: (561) 432-3976 URGENT URGENT URGENT Send to:Nuclear Regulatory Commission From: Stan Smilan Attention: Michael T. Masnik Date: 4-30-2002 Office Location:
Office Location:
Fax Number: (301) 415-3061 Phone Number: See above SZ 1;'.AS-,
Total pages, including cover: Six (6)
Comments:
Please enter my 'Public Comment' includingthe cover letter, into the record forthe Environmental Issue Scoping Proceedings for St Lucie, Units 1 and 2. Included Is a correction of a misstatement i made regardingthe dosage of radiation received onboard the U.S.S. Biroka in I
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(561) 432-3976 p.2 P.O. Box 740606 Boynton Beach, FL 33474-0606 (561) 432-3282 Via Facsimile and U.S. Mail Fax No. (301) 415-3061 April 30, 2002 Nuclear Regulatory Commission ATTN: Michael T. Masnik 11545 Rockville Pike Rockville, Maryland 20852-2738 Re. 'Public Comment': Environmental Scoping - St. Lucle, Units 1 & 2
Dear Michael:
This letter will confirm our conversation this date concerning sending my written comment for inclusion in the record for the EIS process related to St. Lucie, Units 1 and 2. As you requested I am sending my comment to you via facsimile.
Please enter this cover letter into the same NRC record for the purpose of my having an opportunity to correct a misstatement about dosages received aboard the U.S.S. Biroka in 1954. The correct figures should have been that navy personnel topside, involved in decontamination efforts, received 100 roentgens of exposure - and not 100 miliroentgens as I stated at the St. Lucie meetings and perhaps the Turkey Point meeting I attended.
I distinctly recall my initial impression upon reading the Defense Department documents I referred to: that the sailors had received twenty times the allowable exposure. And, furthermore that they had received Beta burns. I assume there was also alpha-particle contamination involved. I subsequently, learned that there were Japanese fishing vessels that received fallout from the blast. Also, I personally went ashore at the Rongelap Atoll, where there had been radioactive fallout several weeks before from the same detonation.
- Sncerely, JStan 4Srrian Attachnent: 4-pg. 'Public Comment' Stan Smilan Rpr 30 02 01:49p
Apr 30 02 01:
4 9p Stan Smilan (561) 432-3976 p.3 Subj: Written, 'Public Comment' for St. Lucie, Units 1 and 2 License Renewal Date: 4/29/2002 To: St Lucie EISa,!nrc.gov Pages.
of 4 pages STAN SMILAN Independent Candidate (no party affiliation)
Florida State Senate - District 28 P.O. Box 740606, Boynton Beach, FL 33474-0606 Phone: (561) 432-3282 VIA: U.S. Mail & Facsimile April 29, 2002 Chief, Rules and Directives Branch Division of Administrative Services Mailstop T-6D59 U.S. Nuclear Regulatory Commission 11545 Rockville Pike Rockville, MD E-mail at: StLucieEIS@nrc.gov
'Public Comment': Re. Environmental Scoping - St Lucie, Units 1 & 2.
The following written, 'Public Comment' is submitted for inclusion in the record and consideration as 'Environmental Scoping Issues' by the Nuclear Regulatory Commission in the matter cited above.
In order to comply with the legislative intent and mandates of the National Environmental Policy Act (NEPA), the Nuclear Regulatory Commission should proceed slowly, reopen the relicensing process, and offer the county and municipal governments in the five-county, Southeast Florida area further opportunity to become interveners, appoint special counsel and fund technical consultants.
Additionally, 'Environmental Issues Scoping' should include the following:
Implementing leadership and management techniques currently in widespread, industry use, to solicit public, state, county and municipality input into the St. Lucie and Turkey Point re-licensing process.
The NRC bifurcated the license extension and multi-oxide issues. However, the
(561) 432-3976 p.4 Subj: Written, 'Public Comment' for St. Lucie, Units I and 2 License Renewal Date: 4/29/2002 To: St Lucie EIS&nrc.gov Page
_- of 4 pages two issues are inextricably intertwined in the St. Lucie and Turkey Point proceedings; because, FPL opened the MOX issue in FPL's press release related to the ENTERGY merger; FPL announced a strategy to reprocess its spent fuel rods into multi-oxide (MOX) fuel in France and Belgium.
The license extension proceeding for St. Lucie, Units 1 & 2 should consider the population explosion projected for the Southeast Florida Treasure coast.
The siting permit for St. Lucie, Units 1 & 2 should be revisited and reviewed.
Factor in the demographic make-up of the tri-county area: giving weight and consideration to the fact that the second largest Jewish, population concentration in the US is situated in the tri-county area.
Security concerns related to the close proximity of the St. Lucie nuclear plants with on site storage of spent fuel rods containing plutonium - to International Airports in Florida at Miami, Fort Lauderdale, West Palm Beach, Orlando, Tampa, Jacksonville, Florida; and the worlds busiest airport at Atlanta, Georgia.
Nuclear plants in the U.S. are not certified to withstand a high-speed impact from a fully fueled jumbo jet airliner.
Florida Power and Light should guarantee that St. Lucie Units 1 & 2 will not use multi-oxide (MOX) fuel containing plutonium; and will not engage in transporting or storing MOX fuel on site.
Furthermore: The local meetings I attended at St. Lucie and Turkey Pt. were conducted in a perfunctory manner - in regards to soliciting critical public input. The NRC failed to meet its Federal mandate under the National Environmental Act (NEPA) - as outlined in NRC's own guidelines handed out at St. Lucie. The NRC did not meet its burden of complying in fMll spirit with the: "NEPA prescribed PROCESS for preventing uninformed Federal Agency actions. The "National Environmental Policy Act mandates that the NRC: "...Ensures that Federal Agencies will INFORM and INVOLVE the public...."
The NRC's own guidelines quotes the NEPA as defining and mandating: "INFORM the public of potential impacts to the environment; INVOLVE the public in the decision making process; and requires Federal Agencies to be candid in discussing impacts and mitigation and to be diligent in efforts to lessen damages to the environment." The NRC did not INFORM and INVOLVE the public in sufficient manner to solicit critical 'Public Comment," The NRC was at best perfunctory in meeting its burden.
Apr 30 02 01:49p Stant Smilan
(561) 432-3976 P.
5 Apr 30 02 01:
4 9p Subj: Written, 'Public Comment' for St. Lucie, Units 1 and 2 License Renewal Date: 4/29/2002 To: St Lucie EISnrc.tov Page3__ of 4 pages There were no interveners present at the meeting held at Port St. Lucie on April 3, 2002.
Meetings and hearings pursuant to this application were poorly advertised and poorly attended by the public and local governmental entities.
The NRC's actions and lack of due diligence in meeting its responsibility to inform and involve the public's critical input, placed the credibility of the Commission in question. The NRC's actions and inactions in the St. Lucie and Turkey Point hearings give credence to the assessment of the Union of Concerned Scientists that the NRC is arrogant and secretive in their proceedings. Based on my own personal observations of the St. Lucie and Turkey Point meetings I attended, I concur and add that: the NRC is in contempt of the public and the citizenry of the Southeast Florida area.
The license extension proceeding for St. Lucie, Units 1 & 2 should consider the population explosion projected for the Southeast Florida Treasure coast. The Commission's attention is directed to the South Florida Water Management District's estimate that 15 million people will be living in South Florida within 30 years. The March 12, 2002 article that appeared in the Ft.
Lauderdale Sun-Sentinel reported the Southeast Treasure Coast, tri-county area, of Miami-Dade, Broward and Palm Beach counties, alone, would have a population of 7.5 million in 28 years from now. If Martin and St. Lucie Counties are added, the figure easily exceeds a projected population of over 10 million people, potentially impacted by a catastrophic accident - or act of terrorism - at the two St. Lucie and two Turkey Point nuclear power units.
The siting permit for St. Lucie, Units 1 & 2 she be revisited and reviewed to determine if it would prudent and responsible to issue a siting permit for those units today - if proper weight and consideration were given to the population increase to date, and the population growth projected for the area. The NRC should examine and answer the questions: Could FPL get a sitting permit for those plants today; and, for an extended period of operation 20-yrs beyond the initial 40-yr license period?
I urge the NRC to factor in the demographic make-up of the tni-county area: giving weight and consideration to the fact that the second largest Jewish, population concentration in the US is situated in the tri-county area; and, that simple logic would indicate that this area is a prime target considering the geopolitical climate that exists today - with terrorism on the rampage. Security concerns related to the close proximity of the St-Lucie nuclear plants - with on site storage of spent fuel rods containing plutonium - where jumbo-jet aircraft depart heavily laden with jet fuel for destinations in deep-South America, Europe, as well as domestic transcontinental flights.
During the informal session of the April 3, 2002 meeting with NRR staff, I was able to confirm that nuclear plants in the U.S. are not certified to withstand a high-speed impact from a fully fueled jumbo jet airliner. This confirmation was elicited from Mr. Noel F. Dudley, Senior Project Manager, License Renewal Section, Office of Nuclear Reactor Regulation Stan Smilan
(5G1) 432-3976 p.6 Apr-30 02 Ol:50p Subj: Written, 'Public Comment' for St. Lucie, Units 1 and 2 License Renewal Date: 4/29/2002 To: St Lucie EISknrc.gov Page____ of 4 pages During the informal session of the April 3, 2002 meeting with NRR staff, I was able to confirm that the St. Lucie nuclear power plants were capable of using multi-oxide (MOX) fuel. In the Duke Energy decision issued by the NRC on April 19, 2002, the NRC bifurcated the license extension and multi-oxide issues. However, it is my contention that the two issues are inextricably intertwined; because, FPL opened the MOX issue in FPL's press release related to the ENTERGY merger; FPL announced a strategy to reprocess its spent fuel rods into multi-oxide (MOX) fuel in France and Belgium, contracting with the French company COGEMA.
Additionally, the administration's policy for disposal of plutonium from nuclear weapons to comply with the 1996 nuclear nonproliferation treaty requires production and use of multi-oxide fuel - as reported in the NY Times, April 12, 2002.
The NRC has not been candid, as required by NEPA, on the multi-oxide issue. In fact the NRC has been disingenuous in dismissing the issue from consideration in license extension applications. The FPL application should be held in abeyance until the NRC comes forward with a definitive position on multi-oxide fuel. Proper consideration of environmental impact cannot be realistically addressed until the MOX issue is resolved. The MOX issue should be a prerequisite before further consideration of relicensing and 20-yr extensions for St. Lucie, Units 1 & 2.
The NRC has been deficient in using management and leadership techniques to solicit INOLVEMENT by the public, state, local, and municipal government entities into the re-licensing process for St. Lucie and Turkey Point. During a recess in the Turkey Point meeting, at Florida City, with the Advisory Committee on Reactor Safeguards, Mr. Noel Dudley, Senior Project Manager, asked what could NRC do to get better public participation. I repeated for Mr. Dudley my recommendations to the ACRS that the airlines utilize Cockpit Resource Management and leadership techniques that make it incumbent upon an airline captain to solicit input from his crew; the captain cannot use as an excuse for uniformed decisions, that the crew did not advocate another alternative course of action. The Captain must solicit the crew's input. Using this analogy the NRC in the role of ultimate decision maker, must INFORM and INVOLVE the public in the decision making process in conformance with the congressional mandate embodied in the NEPA.
The NRC's conduct in the St. Lucie and Turkey Point proceedings, to date, regarding INFORMING and INVOLVING public input has been grossly deficient.
s/STAN AN P.O. Box 740606 Boynton Beach FL 33474-0606 Phone: (561) 432-3282 Stant Smilan