ML051330352
| ML051330352 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/21/2005 |
| From: | Burton N Connecticut Coalition Against Millstone |
| To: | Kugler A NRC/NRR/DRIP/RLEP |
| References | |
| Download: ML051330352 (12) | |
Text
Richard Emch - Millstone Draft Environmental Impact Statement Page 1 From: <NancyBurtonEsq aol.com>
To: <ajkl @nrc.gov>
Date: Mon, Feb 21, 2005 7:13 AM
Subject:
Millstone Draft Environmental Impact Statement
Dear Mr. Kugler:
Please see attached.
Nancy Burton 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 CC: <rle~nrc.gov>, <secy~nrc.gov>
c:\temp\GW)00001 .TMP Page 11 Pacie 1 cAtemp\GW}OO00l .TMP Mail Envelope Properties (4219D04F.CED: 8: 52461)
Subject:
Millstone Draft Environmental Impact Statement Creation Date: Mon, Feb 21, 2005 7:12 AM From: <NancyB urtonEsq @aol.com>
Created By: NancyBurtonEsq@aol.com Recipients nrc.gov owf4-po.OWFNDO AJK1 (Andrew Kugler) nrc.gov OWGWPOO2.HQGWDOO1 RLE CC (Richard Emch) nrc.gov owf5.po.OWFNDO SECY CC (SECY)
Post Office Route owf4_po.OWFNDO nrc.gov OWGWPOO2.HQGWDOO1 nrc.gov owf5-po.OWFN-DO nrc.gov Files Size Date & Time MESSAGE 116 Monday, February 21, 2005 7:12 AM TEXT.htm 629 MillstoneEISCCAMKuglerRequestExtTime22105.doc 46080 Mime.822 65493 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed
Subject:
No Security: Standard
Richard Emch - MillstoneEISCCAMKuglerRequestExtTime22105.doc Page 1 CONNECTICUT COALITION AGAINST MILLSTONE www.mothballmillstone.orl February 21, 2005 Andrew J. Kugler Chief Environmental Review Section Office of Nuclear Reactor Regulation U.S. Nuclear regulatory Commission Washington DC 20005-1110 Re: Millstone Draft Environmental Impact Statement
Dear Mr. Kugler:
As Chief of the Environmental Review Section at the U.S. Nuclear Regulatory Commission, you are responsible for the environmental review for the application by Dominion Nuclear Connecticut, Inc. to extend the operating license of the Millstone Nuclear Power Plant an additional 20-year term, including preparation of the Environmental Impact Statement.
The Connecticut Coalition Against Millstone has actively participated in the Millstone relicensing proceedings. Coalition members attended and spoke at the January 11, 2005 public meeting which you conducted in Waterford to accept public comments on the draft Environmental Impact Statement which your office prepared in support of Millstone relicensing. At the outset of the meeting, the NRC's meeting facilitator established a limit of 5 minutes per person in making public comments. All were invited to submit more detailed written comments on or before March 2, 2005 in order to have their comments considered by you and your staff prior to issuance of the final Environmental Impact Statement.
The Coalition is gathering information to submit to you and your staff challenging many of the assumptions and conclusions appearing in the draft Environmental Impact Statement.
During the January 11, 2005 meeting, not one public official representing the people of the State of Connecticut appeared to comment on the draft Environmental Impact Statement, other than two representatives of the Town of Waterford, who spoke in favor of relicensing without addressing in any way the environmental consequences of relicensing for an additional 20-year term.
(Melodie Peters, a former state senator who joined the Dominion payroll to advocate in favor of relicensing while serving as co-chairman of the legislature's Energy and Technology Committee, also spoke in favor of relicensing although
I Richard Emch - MillstoneEISCCAMKuglerRequestExtTime22105.doc Page 2',
IRichard Ernob - MillstoneEISCCAMKuglerRequestExtTime22lO5.doc Pacie2l she did not acknowledge her paid status nor did she address the environmental consequences of relicensing.)
Therefore, we believe the Coalition is performing a critical role and a public service in the Millstone relicensing proceedings by endeavoring to provide substantive comments and documentation to assist the NRC in making appropriate corrections to the draft Environmental Impact Statement.
Unfortunately, the Coalition has been impeded in its efforts by your own staff and others within the NRC in the following ways:
(1) The Coalition submitted a request for further information to Richard L.
Emch, Senior Environmental Project Manager, on January 24, 2005. A copy is attached hereto. To date, the Coalition has received no substantive response to the request. Indeed, the Coalition understands that the NRC itself is withholding the documents responsive to the request. (Please refer to Mr. Emch's email of February 18, 2005, a copy of which is attached hereto.)
(2) The Coalition submitted a request for further information to Mr. Ench on February 10, 2005. A copy is attached hereto. To date, Mr. Emch has neglected to even acknowledge receipt of the request nor respond to it in any way.
(3) The NRC has withheld the transcript of the January 11, 2005 Waterford meeting from the public. It was only after the Coalition protested to Mr. Emch on February 18, 2005 that the transcript was suddenly made available to it, although as of February 21, 2005 it is still not posted to the NRC's website and thus is not available to the public. We would like to know for what period of time the NRC withheld the transcript from public disclosure after it was received. We also request the opportunity to review the "uncorrected" transcript to be sure that all "corrections" subsequently made were warranted.
In light of these facts and circumstances, we believe that the NRC itself is actively thwarting its legal responsibility to provide a meaningful opportunity for public comment on the draft Environmental Impact Statetment. Clearly, if prejudice has resulted, it has been prejudice to the public interest.
This therefore is a request that you extend the comment period on the draft Environmental Impact Statement for a period of 30 days, such period to commence upon the Coalition's receipt of the pertinent information requested of Mr. Emch in its January 24, 2005 and February 24, 2005 communications.
Thank you for your assistance.
Very truly yours, Nancy Burton
Page 31
- MillstoneElSCCAMKugierRequestExtTime22iO5.doc Richard Emch - MilstoneEISCCAMKuglerRequestExtTime22105.doc Page 3 11 cc: Hon. Joe Lieberman Hon. Chris Dodd Hon. Rob Simmons Commissioners, U.S. Nuclear Regulatory Commission CONNECTICUT COALITION AGAINST MILLSTONE P.O. Box Niantic CT 06357
IRichard Emch - MillstoneEISCCAMKuglerRequestExtTimne22105.doc 1 Page 4 Richard Emch MillstoneElSCCAMKuglerRequestExtTime22lo5.doc Pa www.mothballmillstone.orq January 24, 2005 Richard L. Emch, Jr.
Senior Environmental Project Manager U.S. Nuclear Regulatory Commission Washington DC 20044 Re: Millstone Nuclear Power Station/Environmental Impact Statement
Dear Mr. Emch:
This is a request for information pertaining to the Millstone license renewal application submitted pursuant to the provisions of the Freedom of Information Act. The information is urgently needed for review by the Connecticut Coalition Against Millstone for timely submission of comments on or before March 2, 2005.
Please provide the following:
(1) All Requests for Additional Information submitted by the NRC to the licensee and all reports, documents, emails and other correspondence generated and received therefrom.
(2) Please identify the names of all officials of the State of Connecticut whose input was received for the draft Environmental Impact Statement (DEIS) and please provide all correspondence between the NRC and such officials and all documents provided by such officials.
(3) Please identify the names of all individuals and their professional, business or governmental affiliations who provided input to the DEIS and please identify the specific contribution of each.
(4) Please identify all consulting contracts entered into with consultants on the DEIS, provide a copy of such contracts and the cost of each such service.
(5) Please identify with specificity what "other available information" was considered which led the staff to conclude 'that there are no impacts of radiation exposures to the public during the renewal term beyond those discussed in the GEIS" and "that there are no impacts of occupational radiation exposures during the renewal term beyond those discussed in the GEIS." (DEIS at 4.3) Please further identify all sources considered.
(6) Please identify all refurbishment identified by the licensee other than "major" refurbishment and identify the methodology used by the NRC staff to evaluate this issue and whether the licensee's characterization of refurbishment issues as not "major" was accurate. (DEIS Section 3.0)
Please send all correspondence responsive to this request to 147 Cross Highway, Redding Ridge, Connecticut 06876, Tel. 203-938-3952.
Sincerely,
Page 5i
- MilIstoneEISCCAMKugierRequestExtllrne22l 05.doc Richard Emch - MillstoneEISCCAMKuglerRequestExtTime221 05.doc Page 5 11 Nancy Burton CONNECTICUT COALITION AGAINST MILLSTONE www.mothballmillstone.orq
I Richard Emnch - MillstoneElSCCAMKuglerRequesitExtTime22105.doc Page Richard Emch MillstoneElSCCAMKugferRequestExtTime22l 05.doc Paae 661 February 10, 2005 Richard L. Emch, Jr.
Senior Environmental Project Manager U.S. Nuclear Regulatory Commission Washington DC20555-0001 Re: Millstone Nuclear Power Station Relicensing
Dear Mr. Emch:
Your and your staff have invited public comment on the draft Environmental Impact Statement. You have set a deadline of March 2, 2005 for written comments.
The Connecticut Coalition Against Millstone is preparing its written comments and requests your further assistance in this regard.
Please identify the following:
(1) NRC documents, with titles, authors and dates, of all studies of health effects of exposure to radionuclides and chemicals present at Millstone upon persons who have worked at Millstone, either as employees or contractors or in any other capacity, since 1970.
(2) NRC documents, with titles, authors and dates of all studies of health effects observed, catalogued or studied in any way in the population of individuals identified in section (1) above after they have left service at Millstone and until their deaths.
(3) NRC documents, with titles, authors and dates of all studies of health effects of exposure to radionuclides and chemicals present at Millstone on persons who have worked at Millstone, either as employees or contractors or in any other capacity, since 1970, based on postmortem evaluation.
(4) NRC documents, with titles, authors and dates of all studies of health effects of exposure to radionuclides and chemicals, present at Millstone as well as discharged from Millstone, upon members of the public.
(5) Please provide citations to the statutes, regulations and other legal requirements which identify what information a nuclear licensee such as the Millstone Nuclear Power Station is required to provide to the NRC with regard to the following:
(a) Reporting data of worker exposure to radiation;
.Richard Emch - MillstoneEISCCAMKuglerRequestExtTime22105.doc Page Richard Emch MillstoneElSCCAMKuglerRequestExtTime22l 05.doc Page 7 1l (b) Reporting data of health effects of worker exposure to radiation and chemicals during their terms of employment or assignment; (c) Reporting data of health effects of worker exposure to radiation and chemicals, both among employees and contract workers, following their departure from the licensee; (d) Reporting data of cancer incidences among present and former workers; (e) Reporting data of cause of death among former workers.
(6) Please identify by title and date all information provided to the NRC by the owners and operators of the Millstone Nuclear Power Station since 1970 responsive to item (5) above.
(7)Please provide the titles of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of brain tumors among workers in the former "site maintenance" department at Millstone c. 1994 as well as the incidence of cancer and other diseases among contract workers fulfilling the job requirements of the former "site maintenance" department after the 'site maintenance" department was eliminated c. 1994 (8)Please provide the titles of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of cancer and disease among persons who have worked as pipefitters at Millstone.
(9) Please provide the titles and dates of all records reviewed by you and your staff with regard to the draft EIS of the phenomenon of the incidences of cancer and disease among non-workers within 5-mile, 10-mile and 50-mile radii of the Millstone Nuclear Power Station.
(10) Please provide the dates and titles of all documents reviewed by you and your staff regarding radiological and chemical effluents discharged by the Millstone Nuclear Power Station since 1970.
(I 1) Please provide a list of the chemicals used and discharged at Millstone since 1970,as reviewed by yourself and your staff, and please provide the analysis applied in the draft EIS of how the environment would be affected if the Millstone Nuclear Power Station were to convert from an open to a closed cooling system, particularly as to how such conversion would reduce or eliminate the need for use and discharge of toxic chemicals to the environment.
(12) At pages 4 4-56 of the draft EIS, the following statements appear:
"CTDEP [Connecticut Department of Environmental Protection]
conducts its own radiological environmental monitoring program around Millstone.... CTDEP concluded that Millstone's radiological effluent and
05.doc Page 8 Richard Emch - MillstoneElSCCAMKuglerRequestExtTime22l Richard Emch - MillstoneEISCCAMKuglerRequestExtTime22105.doc Page 8 1 environmental monitoring data were accurate."
With regard to such statements, please identify the names of all CTDEP individuals who provided such statements to you and your staff, the date(s) such statements were made, whether such statements were in writing or verbal (if in writing please provide a copy), and the dates, times, methods of analysis and monitoring referred to and the results of such monitoring as provided to you and your staff.
(13) Please identify and explain the methodology you and your staff applied in reconciling the CTDEP statements (see (12) above) with Northeast Nuclear Energy's Company's plea of guilty to committing environmental felonies during a period of time (c. 1990s) while CTDEP conducted onsite monitoring of Millstone effluent releases.
(14) At page 4-56 of the draft EIS, the following statement appears:
"CTDEP also concluded that the reports cited above by CTDPH, CASE and the National Cancer Institute reports showed no evidence of a causal link between public exposure to Millstone's radiological effluents and cancer in Connecticut towns."
With regard to such statements, please identify the names of all CTDEP individuals who provided such statements to you and your staff, the date(s) such statements were made, and whether such statements were in writing or verbal (if in writing please provide a copy).
Further with regard to such statements, please state whether you and your staff requested such CTDEP personnel to review other documents asserting such a causal link as submitted to the NRC by the Connecticut Coalition Against Millstone, including affidavits of Dr. Ernest Sternglass, Joseph Mangano, Michael Steinberg and Cynthia Besade and, if not, please explain.
With regard to the above inquiries, when the term "staff" is employed, it is intended to encompass both NRC personnel and consultants engaged by the NRC with respect to the draft EIS.
Your prompt, complete and forthright response to this letter will help enable the Coalition to provide meaningful comments in this National Environmental Protection Act process.
Sincerely, Nancy Burton Please reply to:
Page 91 Richard Emch - MillstoneEISCCAMKuglerRequestExtTime22105.doc
- Page 9!1 Nancy Burton 147 Cross Highway Redding Ridge CT 06876 Tel. 203-938-3952 Ms. Burton:
The corrected transcripts of the afternoon and evening sessions of the public meeting conducted on January 11, 2005, at the Waterford Town Hall regarding
Richard Emch - MillstoneEISCCAMKuglerfRequestExtTime22105.doc Page 10, the draft Supplemental Environmental Impact Statement (SEIS) for Millstone license renewal are attached. We refer to them as corrected transcripts because we have read them and corrected them to say what was actually said at the meeting. For example, the transcripts said "affluence" instead of "effluents" before we corrected them.
We are also sending you hard copies of all the attachments to the transcripts (documents that Gail Merrill and others handed to Chip Cameron to be made part of the transcripts) via FedEx. You should have them tomorrow or Monday.
The transcripts and the attachments will be available in the PDR within the next few days.
In addition, I will be responding to your email request for information regarding radiation exposure issues dated February 10, 2005, within the next few days.
Almost all of the information I will give you is already in the draft SEIS or in the PDR.
Our input to the response to your FOIA request dated January 23, 2005, was provided to our FOIA coordinator a few days ago. Hopefully, you receive the response soon. Almost all of the information in the response is already in the draft SEIS or in the PDR, but the response will probably make it easier for you find and access the information.
These actions should be helpful to you in the preparation of your comments on the draft SEIS. We do not plan to extend the comment period; however, as we said at the meeting, we will include and consider any comments received after March 2, 2005, to the extent that it is practicable to do so. In the past we have found it practicable to accept comments that were a few pages long up to a week or so after the due date. Since I would not be surprised to receive extensive comments from you based on the level of interest you have already demonstrated, I want to encourage you to provide as many of your comments as possible by March 2. I would expect that the videotape you made of the meeting would help in that regard.
Rich Emch