ML050810553
| ML050810553 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/23/2005 |
| From: | Levy S Suffolk County, NY, Office of the County Executive |
| To: | NRC/ADM/DAS/RDB |
| References | |
| 69FR71457 000027, NUREG-1437 | |
| Download: ML050810553 (3) | |
Text
COUNTY OF SUFFOLK 3//O/2 &
OFFICE OF THE COUNTY EXECUTIVE 7/* z -5 Steve Levy COUNTY EXECUTIVE Kevin S. Law Michael J.Deering Chief Deputy County Executive Director of Environmental Affairs February 23, 2005 Chief, Rules Review and Directives Branch U.S. Nuclear Regulatory Commission
--- Mail Stop T-6 D59-Washington, D.C. 20555-0001 Re: Millstone Power Station, Units 2 and 3, NUREG-1437, Supplement 22
Dear Chief:
A..draft-Isupplemental impact statement (SEIS) ha§ beeii 'subm'itted to the' Nuclear Regulatory Commission (NRC) by Dominion Nuclear Conne&tici-Iniicorpbrated concerning the application to renew the operating license for'Millstohe'"Po'wer Stiiiiion, Units 2 and 3 for an *additional' 20 years. :The County of Suffolk finds the d6cumnrtxOve'rly narrow in scope, arid lacking detail with regard to .the issues of concern to the 1.4 milli6h rdsiderits of our county. It appears'that public notifications to areas in Suffolk County within the!11'0 'ahdd50 mile emergenyclarming zones were neglected; that there is no need to rush 'ap'eratiniglicense renewal for the plants decades prior to their license expiration; and, that radiological emergency evacuation plans for Suffolk CountV were not addressed. ., . a .. ; ( -
I was dismayed that iapublic hearing was not held in Suffolk County concerning the renewal application and that the Commission failed to contact local municipalities and environmental groups on eastern Long Island (Supplement 22, Appendix D, Organizations Contacted). An analysis-of major points of view concerning significant problemn' and objections raisedby federal, state or local agencies is required by 10 CFR 51.71 in a draft environmental impact statement. In accordance with NRC policy regarding public involvement in reactor license renewal and as Suffolk County residents may be adversely affected by the renewal, we request that a public hearing be held in Suffolk County where the NRC and Dominion can respond to ihes'eis'suies.,/ j lo'.;.'!' ;
Suffolk County views the-applications to'renew Millsto-n'e's operating licenses as premature at this time. -The current operating'licenses do not expire' for periods of lO0lnd 20 years, until July 2015.for Unit 2 and November 2025 for Unit 3; 'With the advanceof science in t he next two.
decades, it is likely that alternative cleaner energy sources and/or conservation 'wifl iiegate the' need for license renewal for outmoded and hazfardoiis nuclear generating plants.' It is'clearlk self-serving for the Commission-to conclude that'eviiiro'nniental impacts for future 'generating and' conservation alternatives'would be greater than those operating Millstone'(Supplement' 22, pages xix and 8-51). The NRC Fact Sheet on Reactor License Renewal states that the license renewal 11.LE DENNISONBUILDINGr,..t10OVETERANSMEMORIALHIGIIWAY . P.O.BOX6100
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2 procedure is expected to take no more than 30 months. Why then is there a push to renew operating licenses decades before it is necessary to perform such a review?
Suffolk County is an important stakeholder in the application to renew the operating licenses because the plants are located within 10 miles NNE of the tip of Orient Point and seven miles WNW of Fishers Island in Suffolk County. Fishers Island and a portion of the Plum Island Animal Disease Laboratory, now operated by the Department of Homeland Security, are located within the Millstone Power Station's primary 10 mile Emergency Planning Zone (EPZ). In the event of an emergency, Fishers Island's residents are to be evacuated to either New London or Stonington Harbor and be bused north to Windham, CT. What is the fate of researchers and operations at Plum Island in the event of a severe accident at Millstone?
A 50-mile Ingestion Planning Zone is identified in the State of Connecticut's Radiological Emergency Plan in the event that a nuclear plant release is carried beyond 10 miles. This EPZ encompasses virtually all of Suffolk County east of the William Floyd Parkway in Brookhaven
-TTownship. -Although -inestion -sugg~estn-arvsessment-of-fuut-and -drinking-%vitcr-a--rcleas -k--
carried southward to Suffolk County is likely require additional public protective actions, up to and including evacuation. This had been deemed infeasible during the public discourse concerning the Shoreham nuclear plant due to the lack of adequate transportation infrastructure.
Since that era, no new major east-west transportation facilities have been constructed, and there has been a significant increase in the population of eastern Suffolk County. Evacuation of eastern Suffolk County remains an infeasible scenario, a fact we consider to be a major factor impeding renewal of Millstone's operating licenses.
NRC regulations limit commercial power reactor licenses to 40 years, but also permit such licenses to be renewed where appropriate. In the case of Millstone, however, renewal for 20 years is not an appropriate public policy decision. The NRC recognizes that some structures and components of nuclear plants may have been engineered on the basis of an expected 40-year service life. Suffolk County is not reassured by the assumption made by the NRC in NUREG-1437, Vol.1, section 5.3.1.
"In assessing the impact on the environmentfrom postulated accidentsduring the license renew'al period, the assumption has been made that the license renewal process will ensure that aging effects on the plant are controlled and that the probability of any radioactive releasesfrom accidents will not increase over the license renewalperiod."
This does not appear to be a credible position in light of.Dominion'szstatement-(Supplement-22,_-r,.
page xviil)-thaiti"didnot identify any major plant refurbishment activities or modifications as necessary to support the continued operation of Millstonefor the license renewal period." The county has difficulty reconciling the two positions that, 1) the NRC will "control" the effects of an aging plant forty years into the future, and yet 2) Dominion foresees no major maintenance activity as necessary for safe operation through the year 2045.
Other significant issues that are not adequately addressed in the SEIS include:
- The cumulative impact of routine operations to aquatic resources, although recognized as significant for winter flounder (Supplement 22, page 4-56), are not adequately addressed or mitigated by the SEIS.
- In the event of a severe accident at Millstone the probability of weighted consequences of a release to groundwater is stated to be small (Supplement 22, page 5-4). However, there is a potential for radioactive fallout directly onto the surface water bodies that serve as the H.LEEDENNISONBUILDING
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3 Fishers Island water supply. Radiological monitoring and the provision of an alternative public water supply for these Suffolk County residents are not addressed in the document.
- Dominion estimates that the dose to the population within 50 miles of the Millstone site from severe accidents to be between 12.8 and 17.4 person-rem. What is the expected dose to county residents living on Fishers Island and the North Fork that are in considerably closer proximity and what health risks are posed by this exposure?
Thank you for the opportunity to comment on this proposal and we look forward to hearing your response at a forum held in Suffolk County.
Sinc e y, teve Levy
'S-uffolkCounty Executive - - I Cc: Diane Screnci, Public Affairs Officer, United States Nuclear Regulatory Commission, 475 Allendale Road, King of Prussia. Pennsylvanial9406-1415 Kevin Law, Chief Deputy County Executive and General Counsel Paul Sabatino II, Chief Deputy County Executive Christine Malafi, County Attorney Lynne Bizzarro, Deputy County Attorney Michael Deering, Director of Environmental Affairs Brian Harper, M.D. Commissioner, Department of Health Vito Minei, Director, Division of Environmental Quality H.LEEDENNISONBUILDING # .100VETERANSMEMORIALHIGHWAY3
- P.O.BOX6100
- HAUPPAUGE.N.Y.11788-0099 * (631)8534000