ML042930387
| ML042930387 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 10/17/2004 |
| From: | Shaw S - No Known Affiliation |
| To: | Office of Nuclear Reactor Regulation |
| Byrdsong A T | |
| References | |
| 50-271-OLA, ASLBP 04-832-02-OLA, RAS 8640 | |
| Download: ML042930387 (4) | |
Text
DOCKETED RAS 8640 USNRC October 18,2004(2:37PM)
From: "Sally Shawl' <acer8sac8crocker.com>
To: <hearingdocket8 nrc.gov> OFFICE OF SECRETARY Date: Sun, Oct 17, 2004 850 PM RULEMAKINGSAND
Subject:
ENVY nuclear reactor uprate proceedings ADJUDICATIONS STAFF SERVED October 18,2004 Docket No. 50-271-0LA
Dear Regulators:
As a resident of Gill, MA, living in the 10-mile emergency evacuation zone of the Vt Yankee nuclear reactor, I am deeply concerned about Entergy's request to increase power at this aging, Mark I-type reactor. I am aware that similar uprates at other reactors of this type such as Quad Cities I and I1 in Illinois have caused costly shutdowns due to steam dryer cracking and valve jamming. While costs to
.consumers should be a concern, the greater issue for those of us living downwind is the accidental release of increased radioactive steam due to valves jamming open, should the structural integrity of the steam dryers fail.
I was amazed at a VSNAP hearing last spring, that Entergy engineers presenting their solution to the steam dryer cracking problem at VY stated they did not repair all the known cracks, and were not asked by the VT Public Service Dept, the VT State Nuclear Engineer, or any other members of the panel what the implications of steam dryer failure would be. Finally, I was allowed to ask the question, and discovered that steam dryer cracks can lead to pieces of the steam dryer falling off and becoming stuck in steam valves. This could result in an inability to shut down the stuck valves to prevent release of radioactive steam to the environment.
Decades of research on the health effects of low-level radiation caused by ingestion or inhalation of radionuclides have shown that the Hiroshima model is inaccurate, and misses the greater public health concern: increased incidences of cancers, miscarriages, stillbirths, Downs syndrome, and low birthweight babies. These effects spiked across the country in the 50s due to atmospheric nuclear testing, and then began to decline as atmospheric testing was banned. Following Chernobyl and TMI, they spiked again, and are once again increasing possibly due to the fact that uprates have increased the output of domestic nuclear reactors (and thereby air and waterborne radionuclides) by around 25% by some accounts. We can no longer ignore the fact that the effect of alpha and beta particles (not just gamma radiation) on developing tissues is a significant cause of disease. I could cite numerous articles, but of course you must already be aware of this, being the agency tasked with public safety in regard to domestic nuclear energy. I can only hope that you keep abreast of the literature that shows that exposure to low level radiation is much more dangerous than previously supposed, and revise your risk analysis and acceptable exposure limits accordingly in order to protect the public.
I am also concerned about the matter of containment overpressure. My husband is an energy engineer with expertise in fluid mechanics, HVAC, and steam systems, and he is sure that this is a very dangerous set of assumptions on the part of Entergy, and would compromise the principle of defense in depth. I do hope the NRC will not allow it.
The most obvious and dangerous existing condition at the VT Yankee plant is the spent fuel storage pool, which sits outside containment, 7 stories in the air, with a conventional industrial roof. One cannot miss the irony that while the Homeland Security Dept. is busy not consolidating terrorist lists, as they were charged to do, a pre-deployed nuclear catastrophe sits waiting to happen in our and many other reactor communities around the country. This is truly unconscionable, when there are ways to harden and protect this enormous source of radioactive pollution against the unthinkable, such as Hardened On-Site Storage (HOSS). We are aware that the spent fuel pool contains the equivalent of tens of thousands of Hiroshimas in radioactive curies, and that we are sitting ducks as long as the pools continue to be overstuffed with closely packed rods, rather than separating the rods from each other and storing them in a hardened above-ground structure (dry casks alone will not adequately protect us). I do not see the sense of allowing Entergy to run at increased power levels, packing even more rods into the reactor than it was designed for, and accelerating the overpacking of rods in the spent fuel pool, thereby
increasing risk to the public in the event of an accident, for one single reason: Entergy's profit. Rather, we should be planning conversion to HOSS before any increase in power is discussed.
I am convinced that civilization advances only by the good works of honest people. I know we can find the answers to our energy, resource and security needs by focusing on the truth, not on who or whom profits or loses by it, and proceeding according to our best judgment and the precautionary principle, and in the interest of the public. It takes only one to lead the way with integrity in any organization. I hope you will deeply consider your responsiblity to the public in this regard.
Thank you for listening.
Sally Shaw 100 River Rd.
Gill, MA 01354 cc: <ask28 nrc.gov>
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
ENTERGY NUCLEAR VERMONT YANKEE L.L.C. ) Docket No. 50-271-0LA and ENTERGY NUCLEAR OPERATIONS, INC. )
1 Vermont Yankee Nuclear Power Station) 1
)
(Operating License Amendment) )
CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing LIMITED APPEARANCE STATEMENT OF SALLY SHAW have been served upon the following persons by U.S. mail, first class, or through NRC internal distribution.
Office of Commission Appellate Administrative Judge Adjudication Alex S. Karlin, Chair U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, DC 20555-0001 Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Administrative Judge Administrative Judge Anthony J. Baratta Lester S. Rubenstein Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Washington, DC 20555-0001 Brooke D. Poole, Esq. Raymond Shadis Robert M. Weisman, Esq. New England Coalition Marisa C. Higgins, Esq. P.O. Box 98 Office of the General Counsel Edgecomb, ME 04556 Mail Stop 15 D21 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 John M. Fulton, Esq. Sarah Hofmann, Esq.
Assistant General Counsel Special Counsel Entergy Nuclear Operations, Inc. Department of Public Service 440 Hamilton Avenue 112 State Street - Drawer 20 White Plains, NY 10601 Montpelier, VT 05620-2601
2 Docket No. 50-271-0LA LIMITED APPEARANCE STATEMENT OF SALLY SHAW Anthony Z. Roisman, Esq. Jay E. Silberg, Esq.
National Legal Scholars Law Firm Matias F. Travieso-Diaz, Esq.
84 East Thetford Rd. Douglas J. Rosinski, Esq.
Lyme, NH 03768 Shaw Pittman LLP 2300 N Street, NW Washington, DC 20037-1 128 Office of tt# Secreta6 of the Cdnmission Dated at Rockville, Maryland, day of October 2004 this 18*h